Feasibility Study Analysis: Volume 2, Site Summaries

                                             EPA-542-X-95-002
                                             May 1995
FEASIBILITY STUDY ANALYSIS, VOLUME II:

                SITE SUMMARIES
                    April
                H 21,
   1995
                     Prepared for:
                         and
       Technology
Office of Solid Waste
    U.S. Environmental
            410 M S
         Washington
Innovation Office
    Emergency Response
  Protection Agency
 :reet, S.W.
  D.C.  20460
            Environmental Management Support, Inc.
                 8601 Georgia Ave., Suite 500
                Silver Spring, Maryland 20910

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7. How did the cost(s) compare to standard technologies? [
' ii ' -'••,!•••
Cost Estimates for IRAAs That Include Standard Technologies
(selected remedial alternative is in bold) i
8.
10.
Oo
O'
Alternative
RAA-1
RAA-2
'!
!•
I
Standard Technology
No action/monitoring
Sheet piling vertical barrier/
dewatering/water treatment/soil
excavation/dff-site incineration/
monitoring '
Estimated Costs
3 Criteria
$755,000
$187,351,000
I
f
9 Criteria
$755,000
$242,931,000
If a standard technology was chosen, why?

A standard technology was not chosen.
:hosen, why?
9. If an innovative technology was

Alternative RAA-6 was selected.; It includes lowering the water table! by three feet and using
in situ soil venting tosremediate Unsaturated soils. Saturated soils and groundwater would be
remediated by injecting groundwater fortified with nutrients and an oxygen source into the
contaminated zone to stimulate biological degradation of contaminants. It was selected
because it permanently removes a high percentage of contaminants. It achieves remedial goais
in a fairly short period of time Mlfoile minimizing impacts to the community. This results from
employing in situ techniques with little disturbance of the site. It satisfies the preference for
treatment. The feasibility of the 'biotreatment component is based on bench-scale tests. The
applicability of this technology will be investigated by performing more extensive pilot tests.

RAA-1 was eliminated because ;ijt would not provide protection to human health and the
environment. RAA-2 would meet state MCLs and permanently remove contaminants from the
site, but would have disadvantages, such as high cost and a long perk>d of remediation. RAA-
3 was eliminated because significant quantities of contaminants woukj be left at the site,
remediation relies on natural flushing of the aquifer, and exposure pathways exist that would
provide inadequate protection to | human health and the environment. Moreover, RAA-3 would
have a relatively high cost for the level of protection provided. RAA4 would be cost-
effective, but cleanup goals would not be reached for many years. RAA-5 would provide
similar levels of protection as Rj
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Disposal:
Excavation, RCRA landfill (on-site and off-site)
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: -, • ••

Biological treatment: Landfarming, contained solid-phase aerobic degradation, anaerobic
degradation, in situ biodegradation
Chemical treatment: In situ hydrolysis, in situ oxidation, in situ reduction, in situ soil
venting (vapor extraction)
Thermal treatment: On-site thermal desorption, pyrolysis
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified ;
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during evaluation by the nine criteria established by the
NCP: long-term effectiveness and permanence; short-term effectiveness; compliance with
ARARs; protectiveness of human health and the environment; reduction in contaminant
mobility, toxicity, or volume; implementability; cost; state/support agency acceptance; and
community acceptance. ,
v ' , '-.'.•
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) '
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
Innovative Technology
Partial soil excavation/on-site thermal
desorption/monitoring
In situ venting (vapor extraction)/
monitoring
Sheet piling vertical barrier/dewatering/
water treatment/in sini soil venting
(vapor extraction)/monitoring
In situ soil venting (vapor extraction)/
ground water extraction/air stripping/
in situ biodegradation/monitoring
Estimated Costs
3 Criteria
$10,044,000
$2,312,000
$12,166,000
$4,507,000
9 Criteria
$10,321,000
$1,977,000
$11,399,000
$4,507,000
-2-
063
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;
Applied Environmental Services
(aka Shore Realty Site)
OU-1
Glenwood landing, Nassau County, New York
i i Region 2

GENERAL SITE INFORMATION
. - -- i
- -. - " ML

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

Methylene Chloride 20
Benzene 0.005
2. What volume of material is to Ire
remediated? *•
The volume of material to be remediated
included: !;
105,000 cubic yards of soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/84
10/86
4/17/91.
6/24/91
Background

PRP-lead !
PRPs: Shore Reality, over 100 third-party
defendants;
FS prepared by: Roux Associates, Inc.
3. What type of site is this?
• ' ' 1i ' '- " . • '.>• : . •'.
Chemicals and Allied Products,,: A former petroleum, gasoline, and solvent chemical facility,
which more recently has been used as a hazardous waste storage facility and chemical waste'
blending facility. '
TECHNOLOGY SELECTION
. ' ' .!! . . •- ' '- •' ' I:- !"'"-'.- "• ' •
4. What standard technologies were considered for selection in this FS*
i! ' • ' • ' t ...-.• •.
Standard technologies considered during the identification and screening of technically feasible
technologies were: ; f
I i ' • • - ''t* • •

Containment: Capping (synthetic, asphalt, or layered), vertical barriers (sheet piling,
slurry w^lls) |
Chemical treatment: Solidificjation/stabilization (cement based, silicate based, thermoplastic)
Thermal treatment: Incineration (rotary kiln, circulating fluidized -bed, multiple hearth,
mobile) I
062
-1-
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Single vs. multistep treatment
Preference for treatment and alternative treatment technologies (vs. containment)
16. How are alternatives compared?

Alternatives were compared by: comparing their costs with excavation and .treatment/disposal;
the time to remediate the site; complexity of the remediation technology; site space controls;
and spread of contamination from excavation and stockpiling. Remediation time for soil
flushing, determined through partition/pore volume flush models, was considered questionable
because soil and contaminant parameters are difficult to quantify. Soil flushing was also
compared to the other technologies as unpredictable based on hydrogeological complexities.
17. What technical considerations had to be considered in the selection of a remedy? Were
technical considerations primary in the selection of the remedy?

Technical considerations primary in the selection of an alternative were the sandy nature of the
site soil and the proximity of the underlying water table. The chosen technology has been
proven highly successful in removing volatile organics, particularly from sandy soil matrices
such as those found at the site. Further, it is expected that the technique will volatilize and
enhance biodegradation of semi-volatiles thus reducing their concentration below action levels.
The proximity of the water table to the contaminated soil, and the potential for water table ,
fluctuations, dictated that a solution reduce the toxicity and volume of contaminants rather than
merely containing them. Thus alternative RAA-SC-2, which proposed capping, was
considered insufficient.
061
-D- , "
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12,
13.
|| _ V ' ,
SC-6 (thermal desorption) because excavation and stockpiling would cause fugitive dust and
run-off problems. Implement^bility was also a factor in eliminating RAA-SC-3 and RAA-SC-
5 that included soil flushing because of the impact on ground water flow and the difficulty in
implementation compared to SVE. RAA-SC-6 was affected because of the lack of space for
stockpiles.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was thai
ARAR? What risk level was selected to establish cleanup goals? j
[\ '. •. 4' • *
No chemical-specific ARARs for soils were identified. The action flevels, which were based
on New Jersey Soil Action Levels set by the New Jersey Department of Environmental
Protection (NJDEP), were considered cleanup goals. j
Contaminant j
Total volatile organics
Total semi-volatile
organics
i
Cleanup Level
1 ppm
10 ppm
ARAR or Other Basis
i NJDEP
NJDEP
For carcinogens an excess upper bound individual lifetime cancer rijsk of between 10"4 to 10"6
was acceptable. For non-carcinogens a Hazard Index less than or e^qual to 1.0 was acceptable.
Was the innovative technology'eliminated because of the cleanup goals? Could the standard
technology meet the cleanup gi?als? i

Although failure to meet cleanup goals eliminated innovative technologies during the initial
screening, no innovative technologies were eliminated during the three-criteria or 9-criteria
screening because of the cleanup goals. Many of the innovative technologies were considered
to have the potential for leaving soil contaminants in the soil at concentrations above NJDEP
action levels. Only thermal desorption was expected to remove the (contaminants of concern to
near detection limits. Standard technologies considered would not itoeet cleanup standards
either. !
14.
Were treatability studies conducted on the innovative technology or'standard technology?
' - ' - [i • .'-'I'
No, but an additional study on soil vapor extraction will be performied during the remedial
design phase. l '
75. What measures/criteria were used to compare alternatives?
11 . , ' - ' •
The following measures were used to compare the alternatives:

- Total cost i:
Time to design/constract/operate
Proven reliability j
Capital costs vs. operational costs
GGO
•• -5-
-------
• Radio frequency heating was eliminated because it was considered experimental and
too costly. .
• In situ vitrification was eliminated because it was considered experimental and tpo
costly
• Critical fluid extraction was eliminated because it was considered experimental and too
costly •
• Solvent extraction was eliminated because it was considered as being primarily used to
treat PCS contaminated soils and sludges.
• Dechlorinqtion was eliminated because it was considered as being primarily used to
treat PCB contaminated soils and sludges.

Innovative technologies included in the RAAs but eliminated during the three-criteria .screening
process include:

• Biodegradation was eliminated because of the following reasons: 1) the complex soil
contamination at the site that would limit the effectiveness, 2) significant reductions in
toxicity could be achieved only if a diverse microbial population capable of degrading
the compounds of interest can be maintained, 3) bench and pilot scale tests would be
required, 4) bioremediation would also require long-term operations to develop and
maintain microbial population and, 5) bioremediation was considered too complex and
experimental.
• Land treatment was eliminated because: 1) it is not proven to be effective for the
degradation of highly chlorinated aromatic compounds and other organics that are
resistant to biological attack, 2) it is not reliable in achieving cleanup standards in soil,
3) it, requires spreading and mixing of contaminated soil into areas that are currently
non-contaminated, 4) it creates a situation where contamination could be spread by
dust, run-off, and infiltration, 5) it might not be implementable because of
environmental regulations, due to the potential to contaminate clean areas.

Innovative technologies that were eliminated during the nine-criteria screening and selection of
a remedy include:

• Soil flushing was eliminated due to: 1) it does not reduce toxicity or volume of the
soil contaminants but only increases the mobility of contaminants to allow collection
and treatment using groundwater extraction and treatment, and 2) large numbers of
variables influence soil flushing and there is uncertainty in achieving remediation
objectives quickly.
• Thermal desorption was eliminated because: 1) it does not destroy contaminants or
reduce their toxicity and will therefore require further destruction or disposal, 2) it
requires excavation and stockpiling that could interfere with plant operations and
require relocation of roads, as well as require stockpile areas off site, 3) a Part B
equivalent would be required.
11. Which of the nine criteria were weighted most highly in selecting the technology? Did one of
the nine criteria eliminate the innovative technology from being chosen? If so, which one?
Which of the criteria supported the use of a standard technology?

Reduction of toxicity, mobility, and volume and short term effectiveness appeared to rank the
highest in selection of the technology. SVE was estimated to take only one year. Under
short-term effectiveness, the short-term impact was considered and helped to eliminate RAA-

-4-. ••.••• . , ' .
059
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Alternative
RAA SC-6
/
1; .
' ' •-- '- I''-- -" :-., ' ' •' " -
Innovative Technology
Excavation and low temperature thermal
desorption
'Estimated Costs
3 Criteria
!|J/A
!
F
9 Criteria
$4,518,000
7. How did the cost(s) compare \\o standard technologies? i
•• ' . '' • '!••••
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) '
Alternative
RAA SC-1
RAASC-2
sit
'i
uidard Technology
No action
Capping ;
Estimated Costs
3 Criteria
k/A
N/A
9 Criteria
$319,000
$135,000
8. If a standard technology was chosen, why?
!!.-"• '
A standard technology was not chosen.
10.
! _ • ' - -
If an innovative technology wti$ chosen, why? • ['
, I - • . f. .'.•-.
, • j ' ^
In situ soil vapor extraction (SVE) with activated carbon off gas treatment with disposal of
residual off-site was selected, for the following reasons: 1) it direcfly reduces the volume arid
mobility of soil volatile and semi-volatile organic contaminants and may indirectly reduce the
toxicity of phenolic soil contaminants through enhanced biodegradation, 2) removal of
contaminants reduces future grpundwater contamination, 3) no shont term risks are produced,
4) past experience on similar projects has shown SVE techniques tci be successful in removing
VOCs in sandy soil, 5) it is technically feasible to construct in the i-emediation (lagoon) area,
6) it is an in situ process and involves no costly excavation and treatment/disposal, 7) expected
cleanup in one year is said to |se typical, 8) major O&M costs are riot expected.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? , I
ij • '•,'•'•• !''• '• • '- •'-
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementabilityj and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include:
058
In situ bioremediationwas, eliminated because it was considered applicable only for
soils below the water liable. ,
-3-
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What type of site is this?

Chemicals and Allied Products. A former resin manufacturer.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: , ,
Access restriction:
Containment:
Physical treatment:
Thermal treatment:
Disposal:
Site fencing, deed restrictions
RCRA cap, multimedia cap, asphalt cap
Stabilization/solidification
Incineration
Excavation, on-site landfill, off-site landfill
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
Biological treatment:
Phys/Chem treatment:
Thermal treatment:
In situ biodegradation, land farming
In situ soil flushing, in situ soil vapor extraction
Low temperature thermal desorption
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified •
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been.
formulated, costs are estimated as part of the three criteria (effectiveness, implemehtability,
cost) screening process to identify alternatives of sufficient merit to undergo detailed
evaluation. The estimated costs are recalculated during an evaluation by the nine criteria
established by the NCP., *"'' _ .

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) r
Alternative
RAA SC-3
RAA SC-4
RAA SC-5
Innovative Technology
Soil flushing
Soil vapor extraction
Soil vapor extraction and soil flushing
Estimated Costs
3 Criteria
N/A •
N/A
N/A
9 Criteria
$499,000
$810,000
$1,016,000
-2-
057
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A.O. Polymer

Trenton, New Jersey
Region 2
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility stiidy?

Maximum concentrations of principal
contaminants were:
2.
Soil (mg/kg)

Tetrachloroethene
1,1,1 -Trichloroethane
Trichloroethene
Trans-1,2-dichloroethene
Toluene
Xylenes(total)
Ethylbenzene
Chlorobenzene
Phenanthrene
2-Methylnaphthalene
Chrysene
Fluorene
Pyrene
Naphthalene
Acenaphthene
Fluoranthene
Benzo(k)fluoranthene
Benzo(b)fluoranthene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(g,h,i)perylene
Indeno(l,2,3-CD)pyrene
Bis(2-ethylhexyl)phthalate
Di-N-butylphthalate
Butylbenzylphthalate >
Dibenzofuran
N-nitrosodiphenylamine(l)
2.6
:32
27
1.34''
iis
;i.5

;9.6
10.56
:4.2
10.74

:2.6
!0.96
JO.88

10.59
;0.52
;0.29
0.26
4-1
'0.26
0.29
!4.6
0.12
What volume of material is to he remediated?

The volume of material to be remediated included:
' •- i
i-
• 7,500 cubic yards of soil
056
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/1/83
4/91
6/28/91
Baickground

EPA Fund-lead ]
PRPs: A.O. Polymer Corporation
FS prepared by: IICF Technology
Incorporated
-i-
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15. What measures/criteria were used to compare alternatives? .

The following measures were used to compare the alternatives:

Time to design/construct/operate
Preference for treatment (vs. containment)

16. How are measures compared?

The chosen alternative was preferred because it employs an innovative source treatment
technology (low temperature thermal aeration) and thus provides long-term effectiveness and
permanence. Implementation time also was a factor in the selection process. For example,
low temperature thermal aeration would take approximately 1 to 2 years, while another
technology, in situ soil aeration, was eliminated because it twould take approximately 15 years
to complete.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The site soil's low permeability would preclude the implementation of soil flushing as a
remedial technology. In the initial screening, low soil permeability was a primary technical
consideration in the decision to eliminate this technology.
055
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aquifers
protectic
The "Decision Tree 1
in of future ground wa
' - ".' • ' - • 1 " - • -
' , ' ' { • ' • •
' • ~ [.'"I''
*rocess" was 'used to set soil cleanup levels that ensure
er quality. ARARs were used as input into this model
.....'•-/ . - - ...••••.
Contaminant
Cleanup Level (ppiri)
ARAB or Other Basis
Carcinogens
1 , 1 -Dichloroethene
Trichloroethene
Tetrachloroethene ;
Noncarcinogens
0.1
0.1
0.1
MCLGVMCL"
MCL
pMCLc
'• - . • • 1'. ' '. . •
i • - ' ' I '...;.
1,1 -Dichloroethene ;
Tetrachloroethene ;•
Total xylenes i
0.1
0.1
100
MCLG-MCL
pMCL
pMCLGd-pMCL
• . . ' . ' . ' ' ' • h' - ' •'
aMaximum Contaminant Level Goal.
bMaximum Contaminant Level. j
Troposed Maximum Contaminant Level. |
Proposed Maximum Contaminant Level Goal. ;1
! ' • • i '-•.-'• ' -
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"* to 10"6
was acceptable. For noncarcinbgens, a Hazard Index less than or eqjual to 1.0 was acceptable.

-'I I ' ' ' " ' *' " ' '
13. Was the innovative technology Eliminated because of the cleanup golals? Could the standard
technology meet the cleanup goals? j
. ' ' ' . • ' ii ' • . • . -" ,•'!.-.•'
Innovative technologies eliminated because of cleanup goals include: —
• " . • ii- " >• - i • •. . • '
:\\ ; ' ' '. | ' 'Jr- .
• In situ soil aeration/vacuum extraction ['.'..
!!' ' t' ' : , ' ' ' '
Standard technologies eliminated because of cleanup goals include: j ' . " • ^

• None
14. Were treatability studies conducted on the innovative technology or 'standard technology?
'• . ' -<\ " '•'•..• ' , I •
No treatability studies were conducted. ' i
054
-5-
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Innovative technologies eliminated during the initial screening include the following:

• In situ soil flushing was eliminated because artificial mounding of ground water in the
area around injection systems can create unusually high natural ground water gradients
that can move ground water chemical concentrations outward; it is suitable only for
soils of relatively high permeability, while site soils have low permeability; treatment
of water prior to reinjection can cause the formation of precipitates that can clog wells
and the aquifer; and maintenance costs are high.
• In situ radio frequency heating was eliminated because it would require a pilot study
and the cost of the process is very high.
« Biodegradation was eliminated because it would not beeffective for treating site
chemicals.
" In situ vitrification was eliminated because it would not be effective for treating site
chemicals. . ,
• Composting was eliminated because it would only be effective for surface treatment
and therefore would not be appropriate for the depths of contamination at the site.
• Steam flushing/thermal stripping was eliminated because it would not be effective for
treating site chemicals. ,
" Solvent extraction was eliminated because its effectiveness in removing the many
VOCs present is untested for full-scale operation, 2) the liquid solvent waste stream
will require treatment resulting in high operational costs.
• . Freeze-crystallization was eliminated because it must be combined with a separation
technology to remove contaminants. • •' • . .

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• In situ soil aeration/vacuum extraction was eliminated because it would not achieve
the low clean-up levels; the time frame for clean-up using soil vapor extraction is
uncertain; difficult to verify attainment of clean-up levels throughout the soil.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted criteria in selecting.a remedial technology were protectiveness of
human health and the environment, long term effectiveness, implementability, and reduction of
toxicity, mobility or volume.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels for soil were set to eliminate human health risks associated with the ingestion
of contaminated ground water and to prevent further leaching of soil contaminants into
-4-,
053
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7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SC-1
(SC-1)
RAA-SC-2
(SC-2)
RAA-SC-3
(SC-3)
RAA-SC-4A
RAA-SC-4B
RAA-SC-7
(SC-7)
Standard Technology
No action/ground water monitoring
Deed restrictions/ground water
monitoring/fence maintenance
Demolition! of existing structures/deed
restrictions/multimedia cap
Demolition! of existing structures/
excavation of unsaturated soils/disposal off
site at RCRA facility
Demolition iof existing structures/
excavation of unsaturated and saturated
soils/disposal off site at RCRA facility
Demolition tof existing structures/
excavation of unsaturated soils/on-site
rotary kiln incinerator/on-site disposal of
treated soils
Estimated Costs
3 Criteria
low
low
moderate
\ery high
very high
high to
very high
9 Criteria
$78,000
$101,000
$956,000
eliminated
eliminated
i
$7,531,000 ,
to
$11,076,000
8.
If a standard technology was cfiosen, why?

Off-site disposal was chosen fot some wastes.
9. If an innovative technology was'chosen, why?

Thermal desorption was selected because: 1) it will permanently eliminate
the soil contaminants on the site, 2) reduce continuing migration of s
ground water, 3) would reach the low clean-up standards set at the
for remediation.
soil
site
through treatment,
contaminants into
, 4) short time required
i i
10. If an innovative technology^ was not chosen, why not? At what stage
technology eliminated? ;
was the innovative
Innovative technologies could tie eliminated from the remedial technology
three stages: during the initial screening; during the screening of the
effectiveness, implementability,!;and cost; or during the detailed evah ation
selection process at
three criteria of
052
-3-
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Disposal:
Excavation, RCRA landfill
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation, composting .
Phys/Chem treatment: Vapor vacuum extraction, solvent extraction, in situ soil flushing
Thermal treatment: In situ vitrification, steam flushing, thermal stripping, radio frequency
heating, ex situ low temperature thermal aeration, pyrolysis
What was the cost estimate for the innovative technology? •

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SC-5A
RAA-SC-5B
(SC-5)
RAA-SC-6
(SC-6)
Innovative Technology
Demolition of existing structures/
excavation of unsaturated soils/low
temperature thermal aeration/on-site
disposal of treated soil
Demolition of existing structures/
excavation of saturated and unsat-
urated soils/low temperature thermal
aeration/on-site disposal of treated soil
In situ soil aeration/vacuum extraction
system/monitor/fence
Estimated Costs
3 Criteria
moderate to
high
moderate to
high
high to very
high
9 Criteria
eliminated
P
$3,553,000
$3,946,000
-2-
051
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tfnion Chemical Co., Inc.
South Hope, Maine
Region 1
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? ;;

Maximum concentrations of principal
contaminants were: ~. [i
Soil (mg/kg)

1,1-Dichloroethene 4
Trichloroethene 46
Tetrachoroethene 600
Xylene 3,600
2. What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
Hi ckground
PRP-Jead
PRPs: Union Chemical
many others
FS prepared by:
The volume of material to be Remediated included:

» 1,500 cubic yards of soil
L I , ,

3.. What type of site is this? >;

Chemicals and Allied Products! A former paint stripping and solvent

TECHNOLOGY SELECTION

4, What standard technologies were considered for selection in this FS?

Standard technologies considered during th? identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
050
Site security, fencing, deed restrictions
Capping (clay, synthetic, multimedia, asphallt/concrete,
single/multilayer), grout injection, grading, rcvegetation
Chemical treatment: Neutralization, oxidation, reduction, chemica fixation, polymerization,
solidification, stabilization . '
Physical treatment: Ambient temperature aeration, on-site storage, off-site storage
Thermal treatment: Incineration (rotary kiln, multiple, hearth, high-pressure boilers,
infrared, fluidized bed, fume, catalytic, circulating bed combus'tor)

. ,ii . . ' '. -[-....-...••
. j ..'••'• -1- .- ' i- .
4/85
10/89
12/17/90
12/27/91
Company and
not listed
Canonic Environmental
manufacturing company.
-------
Were treata
bility studies conducted on the innovative technology or standard technology?

No treatability studies were carried out. It was suggested that treatability studies would be
necessary if any of the innovative technologies were chosen.

15. What measures/criteria were used to compare alternatives? ,

The following measures were used to compare the alternatives:

Total cost
Proven reliability
Long-term O&M
Number of vendors
Time to mobilize treatment equipment

16. How are alternatives compared?

The most expensive alternative is incineration, followed by solvent extraction and ^

there are fewer vendors than for the other technologies. All of the treatment technologies
(incineration, solvent extraction, S/S) would require mobilization demobilization,™^_
Implementation of sediment/soil treatment units, which may require a greater lead time for

remediation. ,' ;

17 What technical considerations had to be considered in the selection of a remedy? Were
technical considerations primary in the selection of the remedy'
Se EPA decided that disruption of the wetlands would be necessary and all of the action
^^SeJwedai^diauptioo-.tod restoration. Technical considerations were not
primary in the selection of a remedy at this site.
049
-6-
-------
•'"'!'' " '
Innovative technologies eliminated daring the detailed analysis include:

" On-site solvent extraction (RAA-5) was eliminated because there would be short-term
risks to workers during remediation, wetlands must be restored following excavation,
treatability studies would be required, and the natural organics in the wetland soils
would have to be replaced for suitable wetland fill. In addition, it is more costly than
the selected alternative, it is and less implementable than the selected alternative
because obtaining competitive bids on the solvent extraction unit may be difficult
because there are fewer vendors, and mobilization may require a greater lead time than
the selected remedy. • i, • . 1
11:
Which of the nine criteria were weighted highest in selection of the technology? Did one of
the nine criteria eliminate the innovative technology from being chosen? If so, which one?
Which of the criteria supported the use of a standard technology? i

For those alternatives that were protective and attained ARARs, the!most heavily weighted
criteria in selection of a remedy were cost and implementability. Except RAA-1 (No Action),
all RAAs were protective of human health and the environment and met all ARARs.
Implementability and cost were the most important criteria in eliminating solvent extraction
and supporting on-site disposal. _ ;
12.
What clean-up goals were selected. If the clean-up goal was based on an ARAR, what was
that ARAR? What risk level was selected to establish clean-up goals?

Clean-up goals were based on ecological risk assessments that were!established to be
protective of Middle Marsh species. • f .
For care
was accc
acceptab
Contaminant
Non-Carcinogens:
PCBs Wetlands
PCBs Terrestrial
PCBs Aquatic
.

Clean-up Level

15 mg/kg
15 mg/kg
19.5 ug/gm
\ ARAR or Other Basis
,!
i
j Mean Interim Sediment
I Quality Criterion
'Mean Interim Sediment
1 Quality Criterion
i Sediment Quality
; Criteria
inogens an excess upper bound individual lifetime cancer risk of between ICT4 to W6
jptable. For non-carcinogens a Hazard Index (HI) less than lor equal to 1.0 was
le. •' •• ; . ... , , •' i: , • .; ,, : .
- •• , r '
-: • • • .' ' , '['•'• -
13. Was the innovative technology eliminated because of the clean-up goals? If a standard
technology \yas chosen, could it meet the clean-up goals? ]
048
Innovative technologies eliminated because of clean-up goals include in situ bioremediation.
The selected standard technologies could reach clean-up goals. !
-5-
-------
The selected remedy, RAA-2B (on-site disposal at Sullivan's landfill), was chosen because it
would significantly reduce mobility of the contaminants by placing excavated sediment/soils
under the RCRA cap to be constructed in OU-1, would not require use of specialized treatment
equipment with limited availability, would be more easily implemented than some of the
alternatives, and is the least costly of the action alternatives. The selected RAA provided no
treatment and was therefore somewhat less permanent than other alternatives. However,
permanence was deemed less important because the PCB levels in soil/sediment at Middle
Marsh were low enough to be effectively contained in the Sullivan's Ledge Landfill.
9. If an innovative technology was chosen, why? •

The selected remedial alternative did not include any innovative technologies. However,
solvent extraction was selected as a contingency remedy for OU-2 in case the timing of OU-1
implementation (capping Sullivan's landfill) prevents further use of the landfill. From pilot
studies, it is expected that solvent extraction could reach PCB cleanup levels and permanently
treat sediment. , .
10. If an innovative technology was not chosen, why? At what stage was the innovative
technology eliminated? '

Innovative technologies could be eliminated from the remedial technology selection process at
three stages:, during the initial screening; during the screening for the three criteria of
effectiveness, implementability, and cost; or during, the detailed evaluation;

Innovative technologies eliminated during the initial screening include: ;

• None ' ' • • '

Innovative technologies eliminated during the screening of the three criteria include:

• In situ bioremediation (RAA-3) was eliminated because the technique has not been
proven or well established for PCBs. Its was uncertain whether its,effectiveness would
be maintained in the dense organic silt present at Middle Marsh. Also, since aerobic
biodegradation is necessary, it was questionable whether microbes could reduce soil
PCB concentrations to the remediation'cleanup goal of 15 mg/kg. It would be
technically difficult to provide the necessary oxygen to maintain aerobic decomposition
in such dense sediment, and implementation of the aerobic phase may cause additional
wetlands impacts. Further, it is possible that the bacteria might prefer the highly
organic sediment in Middle Marsh to PCBs. Finally, there are not many vendors
available to implement this technology.
» On-site bioremediation (RAA-4) was eliminated because the wetlands would be
impacted during excavation and would have to be restored, there would be short-term
risks to workers during remediation, it is not well demonstrated for treating PCBs, few
contractors are available, and dewatering of treated sediments would require treating
the wastewater prior to disposal.
047
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
vseiecieu iciuciuai alternative is in DOldJ
•! • • ' ' / . ••-'• - •" ' ; -.
Alternative
RAA-1
RAA-2A
RAA-2B
RAA-6A
RAA-6B
RAA-6C
RAA-7A
RAA-7B
RAA-7C
RAA-8
Standard Technology
No action/limited environmental
monitoring
In situ containment/multi-layer cap
Excavatiori/dewatering/water treatment/
disposal to Sullivan's Landfill OU-1/
wetlands restoration/long-term
monitoring/institutional controls
Excavation/on-site stabilization and
solidification of sediment and soil/disposal
at OU- I/wetlands restoration/long-term
monitoring/institutional controls
Same as 6A except disposal of solidified
material at RCRA landfill to be
constructed at Middle Marsh
Same as 6A except disposal of solidified
material off site at RCRA landfill
Excavation/on-site incineration of soil and
sediment/disposal of ash at Sullivan's
Landfill/wetlands restoration/long-term
monitoring
Same as 7 A except disposal of ash at
RCRA landfill constructed on golf course
Same as 7A except disposal of ash at off-
site RCRA landfill
Off-site incineration of excavated" sediment
and soil
Estimated Costs
'2 Criteria
$50,000
$1,800,000
$2,000,000
j
$3,200,000
$5,000,000
$6;400,000
$6,600,000
\ -
,|
$8,000,000
$7,100,000
$14,000,000
f .
9 Criteria
$50,000
eliminated
$2,801,100
$5,052,700
$6,074,300
eliminated
$9,824,200
eliminated
$9,962,300
eliminated
8. If a standard technology was ctibsen, why? I
!! ' - I • '
For this OU, EPA determined that there are no significant risks to human health posed by
contaminants in the marsh. The, PCS contamination, however, does present an imminent and
substantial endangerment to biota present in the environment of the marsh. EPA further
determined that disturbance of wetlands and floodplains is the only practicable alternative that
would be protective of the biota! while minimizing adverse impact on [the terrestrial and aquatic
ecosystem. Therefore, a comprehensive wetlands restoration would be implemented for all
wetland alternatives except no action. I
04G
-3-
-------
Containment:
Thermal treatment:

Physical treatment:
Disposal:
Capping .
Incineration, including fluidized bed incinerators, rotary kilns, infrared
thermal units
Stabilization/solidification
Sullivan's Landfill, which is to be capped in the future, disposal at a
RCRA facility
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: ,

Biological treatment: In situ or ex situ biodegradation
Chemical treatment: Solvent extraction
Thermal treatment: Pyrolysis
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-4
RAA-5
Innovative Technology
Contain area/in situ biodegradation
On-site biological treatment of excavated
sediment/soil
Site preparation/excavation/on-site solvent
extraction treatment/off-site disposal of
PCB-cdntaining solvent/disposal of treated
soil and sediment into Middle Marsh/
wetlands restoration/long-term monitoring
Estimated Costs
3 Criteria
$1,500,000
$3,100,000
$4,600,000
9 Criteria
eliminated
eliminated
$7,616,777
-2-
045
-------
Sullivan's Ledge/Middle Marsh
New Bedford, Massachusetts
il Region 1
GENERAL SITE INFORMATION
i.
2.
What were the principal contaminants,
contaminant levels, and media being
addressed in this'feasibility study?
11
Maximum concentrations of principal
contaminants were:
'v\
[ 1
Surface Sediments/Soil (rag/kg):
, _ :\

PCBs 34 !

Subsurface Sediments/Soil (nig/kg):

PCBs 97 ,
What volume of material is to be
remediated? \\ '
Sile History
NPL Proposed:
NPL Final:
FS:
ROD:
EPA Fund-lead
PRPs: 14 ownerfoperatoi
transporters
FS prepared by:
The volume of material to be remediated included:
1982
9/84
5/91
9/27/91
Background
>rs, generators,
;, and disposers ,
Metcalf & Eddy, Inc.
n
Total remediation area of 1.92 acres , |
Total contaminated soil/sediment volume of 5,220 cubic yariis
3. What type of site is this? !i' '. ' i '" • '.
I , '- f
; ; ' ' ' - ,f '
Industrial Landfill, the second, Operational Unit (OU-2) at Sullivan's Ledge consists of
Middle Marsh, a 13-acre freshwater wooded swamp/marsh wetland. | Sediments in Middle
Marsh were contaminated by migrating pollutants from the quarry or disposal area at
Sullivan's Ledge OU-1. i . 1
TECHNOLOGY SELECTION " , ]
":'•.'--'•.• i " ' '

4. What standard technologies were considered for selection in this FS?
• , • i i ' - '
it. .

Standard technologies considered during the identification and screening of technically feasible
technologies were: ' ' | . .
Removal:
' > • ,f ' •
Dragline dredge, backhoe, air conveyance dredging system, bulldozer,
hand shovel, light-weight excavators i
044
-i-
-------
the treatments incorporated into the selected alternative, would serve only to immobilize
contaminants and therefore did not offer the greatest degree of long-term protection and
permanence. Alternatives that proposed incineration, a treatment that would provide a
permanent reduction in site contaminants, were eliminated because of expense or short-term
risks from excavation. Impact on nearby populations was another important factor in choosing
a remedy. Alternatives that would require excavation were eliminated because of VOC
releases. The chosen alternative remediates VOCs prior to excavation. Several alternatives
were eliminated because they would not be cost-effective. Finally, alternatives that proposed
off-site disposal or incineration of site soil were eliminated because it would be difficult and
expensive to find a landfill that would accept dioxin- and PCB-contaminated soil.
'""".' ./

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Because the site is in a residential area, a major factor in selecting a remedy was short-term
risk to the community. Excavation of site soil containing VOCs could pose a short-term risk
due to their volatilization. Other technical site characteristics that were considered in the
selection process were, the low soil permeability and the diversity of contaminants at the site.
These factors restricted the number of viable alternatives and, with the exception of
incineration (which was not chosen), no alternative would reduce all site contaminants:
043
-------
Contaminant
PAHs (total) !
PCBs i
Cleanup Level (ppb)
29,000
1,000
ARAR or Other Basis
Background
1 TSCA" .
Noncarcinogens ' f
Styrene
Lead
14,000
500,000 ,
'•-. | Risk
OSWER Directivec
The cleanup level for dioxin is based on the Agency for Toxic Substances and
Diseases Registry (ATSDR) recommendation for residential Land use.
The cleanup level for PCBs is based on the Federal Toxic Substances Control Act
(TSCA) for Superfund Sites for residential land use. I
The cleanup level for kad is based on OSWER Directive 9365.4-02,,"Interim
Guidance on Establishing Soil Lead Cleanup Levels at Superfund Sites." ,
13. Was the innovative technology Eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? 1
• ' '! - •-•-.••,. - • ')••-••.
Innovative technologies eliminated because of cleanup goals include:!
- i1 .':•!•
11 ' • , i
• Thermal desorption l| i • • • -
* Solvent extraction J ;
• ' ' .:!'••'.'• ;t '
Standard technologies eliminated because of cleanup goals include: '; .

• • ' None ' '!!•'.. •• ..-....-. :[..
i - ~ i , •
14. Were treatabllity studies conducte'd on the innovative technology or standard technology? •
',\: ' -'.. - .. . • , "\, . ' •••...
Treatability studies were carried > out for stabilization/solidification and vacuum vapor extraction
techniques. ; '
75. What measures/criteria were used to compare alternatives?
1L
The following measures were used to compare the alternatives:

Total cost !|
Preference for treatment (vs. containment)
Impact on nearby populations
16. How are measures compared? \\
The chosen alternative was selected because it employed two treatment technologies that
addressed site contaminants: Treatment was preferred over containment. Stabilization, one of
042
-8-
-------
Contaminant
Trans-1,2-
dichloroethene
1,1,1 -Trichloroethane
1 ,2-Dichlorobenzene
1,2,4-
Trichlorobenzene
Ethylbenzene
Styrene
Toluene
Xylenes
Cleanup Level (ppb)
67
300
8,900
720
6,800
170
2,700
22,000
Basis for Leaching Model
MCLG
PQL
- MCLG
pMCLG6
MCLG
MCLGC
MCLG
MCLG
"Maximum Contaminant Level.
''Proposed Maximum Contaminant Level.
'Maximum Contaminant Level, Goal.
Practical Quantitation Limit.
Proposed Maximum Contaminant Level Goal.

Surficial Soils

Cleanup levels for surficial soils were developed to reduce risks associated with direct contact
and ingestion exposure to site soils. Since no ARARs were available for the indicator
contaminants in soils, health-based levels were derived. Health-based cleanup levels were
developed for soil contaminants that were found to pose a risk in excess of •
10'6 or a Hazard Index greater than 1.0, when evaluated under the worst-case scenario.
Occasionally policy-based,cleanup criteria or background levels were utilized.
Contaminant
Cleanup Level (ppb)
ARAR or Other Basis
Carcinogens
Benzene
1 , 1 -Dichloroethene
1 ,2-Dichloroethane
Methylene chloride
1,1,2,2-
Tetrachloroethane
Trichloroethene
Arsenic
Dioxin
15,000
720
4,800
58,000
2,200
40,000
21,000
1
Risk
Risk
Risk
Risk
Risk
Risk
Background
ATSDR"
-7-
041
-------
11.
12.
040
Which of the nine criteria were weighted most heavily- in selecting the technology? Did failure
to meet i, of the nine criteria result in the elimination of the innovative technology? If so
which cn^rion? Which of the criteria supported the use of a standard technology?
' J ! L '
When choosing between alternatives that were protective of human health and the
environment, the deciding factor was implementability.
A t, A D , „,. ' 8°al,S I?*™ selected? Vthe cleanuP Soal was based on an ARAR, what was that
AKAR/ What risk level was selected to establish cleanup goals? ;

Unsaturated Soils

The cleanup levels for unsaturated soils were based on the potential Lgestion of ground water
contaminated by leaching fromjunsaturated-zone soils. Cleanup goals for the leaching scenario
were evaluated using three analytical models: the equilibrium model:, the organic leaching
model, and the MacKay partitioning model. i
Contaminant ,
Carcinogens
Benzene •
Carbon tetrachloride
Chloroform .
1 , 1 -Dichloroethene !
1,2-Dichloroethane •
Methylene chloride ;
1,1,2,2- :
Tetrachloroethane •
1,1,2-Trichloroethane !
Trichloroethene '
Bis(2- ;
ethylhexyl)phthalate ;
1,2-Dichloropropane ;
Dioxin
Hexachlorobenzene !
PAHs ;
PCBs ;
Noncarcinogens , . |
Chlorobenzene
• i
^
Cleanup Level (ppb)
-
4
5
40
" • 5 , , •
1
. •'"! •'
6
„ 3
6
300
3
1
34
10,000
2,300

300
-6-
Basis for Leaching Model
' ' . i -. ';
MCLa
MCL
MCL
MCL
MCL
pMCLb
PQLd
pMCL
MCL
pMCL
MCL
pMCL
pMCL
pMCL
MCL

MCLG

-------
Innovative technologies eliminated during the initial screening include the following:

• Biodegradation was eliminated because of the variety of contaminants present in site
soils; microorganisms that degrade one type of contaminant have different
environmental requirements than organisms that degrade another type of contaminant;
contaminants degraded by one set of organisms may be toxic to organisms that
degrade other contaminants: design and implementation of a biosystem is questionable;
degradation products for all contaminants is unknown; sequential batch reactors would
be difficult to operate; cold weather would decrease performance; degradation of
chlorinated aliphatics, PCBs and dioxins has not been demonstrated at the field scale.
• Soil flushing was eliminated because soils at the site have low permeability; uniform
distribution and collection of flushing solution would be difficult to implement because
of the stratified and heterogenous nature of site soils.
• Soil washing was eliminated because no data is available for PCBs and. dioxin removal
effectiveness; disadvantages with the large volume of surfactant required; the spent
surfactant/contaminant solution to be disposed; and the residual surfactant and
contaminants remaining in the soil.
• Critical and supercritical extraction were eliminated because of the inability to
successfully treat soils that are heterogenous with low permeability and the lack of cost
effectiveness. , * .
• In situ steam stripping was eliminated because it has not been field demonstrated; its
effectiveness for volatile organic compounds is questionable; no significant removal or
treatment of less volatile substances such as PCBs, dioxins and metals is expected;
reduced effectiveness during winter months.
• Ex. situ steam stripping was eliminated because the soil would need to be excavated,
which would create VOC emissions. Furthermore, the technique would not affect the
site's semivolatiles.
• Radio frequency heating was eliminated because there are no vendors and full-scale
equipment; the technology has not been evaluated for removal of PCBs and dioxins;
and it is not expected to remove or immobilize metals; and its reliability can't be
assured because it has not been demonstrated at field scale.
• In situ vitrification was eliminated because it would be infeasible to implement in an
urban setting. Careful control would be necessary to avoid vitrifying nearby facilities
existing utilities and foundations. Associated settling could also damage roads, utilities
and foundations outside the vitrified area. Also, no significant removal of PCBs,
dioxins, and metals is expected.

Innovative technologies eliminated during the detailed analysis include the following:

• Thermal desorption was not chosen because it would require excavation of volatile
organic contaminated soiis; only limited treatability testing done to assess potential for
treatment of PCBs and dioxins and no testing at all for treatment of contaminants in
wet, fine grained soil at site; technical experts expressed doubt about the practical
efficiency of achieving the range of clean-up goals for dioxins and PCBs anticipated
for the site; process might make some metals more teachable by oxidizing them; and
soil treated would be subject to TCLP; high cost compared to other remedies.
• Solvent extraction was eliminated because it may not meet PCB and dioxin clean-up
levels; bench or pilot studies would be required to test effectiveness on dioxins, since
it is not a proven technology for treatment of dioxins.
039
-5- '-'.'•'
-------
7.
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard
Technologies
(.selected remedial alternative is in bold)
.'••'! ' r ••'.--..'..,. ' ' -
Alternative
RAA-SC-1
RAA-SC-2
RAA-SC-10
RAA-SC-12
1 1
Standard Technology
No action/restricted access
Access restrictions/RCRA cap
construction
,
Incineratioii/stabilization/ solidification/
on-site disposal/ construction of RCRA
landfill and cap
Off-site incineration/stabilization/
solidification
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A ,
9 Criteria
$1,050,000
$5,370,000
$53,879,000
eliminated
8. !f a standard technology was chosen, why?
\ i

Solidification/stabilization and a;RCRA cap was selected ^conjunction with soil vapor
extraction to treat any residual contamination left after vapor extraction. In this Feasibility
Study and Record of Decision soil vapor extraction was proposed with a number of alternative
technologies for residual treatment or containment. Solidification/stabilization was selected
because 1) inorganic and non- volatile organic contaminants would remain in soils after
treatment with soil vapor extraction, 2) limits mobility and migration to ground water, 3)
reduces risks from direct contact, inhalation and ingestion, 4) cost, 5)'readily available services
, and materials. h i .
9. If cm innovative technology was'chosen, why? \
' ,E

Soil vapor extraction was selected in conjunction with solidification/stabilization and capping
because: 1) a treatability study showed that VOC clean-up levels can be attained for most
target compounds, 2) removes VOCs which are the bulk of the contarnination at the site, 3)
readily available services and materials, and 4) cost. !
10.
.11 ... , L
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? [
• ', i!' " -. '. • '- . |,' -*"* . - -;
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
038
-4-
-------
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SC-3
RAA-SC-4
RAA-SC-5
RAA-SC-6
RAA-SC-7
RAA-SC-8
RAA-SC-9
RAA-SC-I1
RAA-SC-13
RAA-SC-14
RAA-SC-15

Innovative Technology
Vacuum vapor extraction/RCRA cap
construction
Vacuum vapor extraction/excavate
remaining contaminated soil/
stabilization/solidification/on-site
disposal/construction of RCRA cap
Vacuum vapor extraction/stabilization/
solidification/off-site disposal at RCRA
landfill
Thermal desorption/stabilization/
solidification/on-site disposal/
construction of RCRA landfill and cap
Thermal desorption/stabilization/
solidification/off-site disposal at RCRA
landfill
Vacuum vapor extraction/thermal
desorption/stabilization/ solidification/
on-site disposal/construction of RCRA
landfill and cap ,
Vacuum vapor extraction/thermal
desorption/stabilization/solidification/
off-site disposal at RCRA landfill
Vacuum vapor extraction/stabilization/
solidification/incineration/on-site
disposal/construction of RCRA landfill
and cap
Vacuum vapor extraction/ stabilization/
solidification/off-site incineration
Vacuum vapor extraction/solvent
extraction/stabilization/ solidification/
on-site disposal/construction of RCRA
landfill and cap
Vacuum vapor extraction/solvent
extraction/stabilization/solidification/
off-site disposal/construction of RCRA
landfill and cap
Estimated Costs
3 Criteria3
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$9,020,000
$10,620,000
eliminated
$51,250,000
eliminated
eliminated
eliminated
$17,220;000
eliminated
$10,850,000
$18,620,000
037
-------
3. What type of site is this? 'i

Recycling. A former chemical waste reclamation facility.
TECHNOLOGY SELECTION j[ j
•i! •' i -.
4. What standard technologies weire considered for selection in this FS?
" ' • -•! • ' ' ' p ••..'. •
Standard technologies considered during the identification and screening of technically feasible
technologies were: ~ "j! i
'I I ' • • " - ! --.-•.-•''
'. • - ,. • *\ , -' ' ' i' ''-,..
Access restriction: Fencing, deed restriction i
Containment: Capping j
Physical treatment: Stabilization/solidification, dewatering |
Thermal treatment: Rotary kiln incineration, circulating bed incineration, infrared
incineration
.." Disposal: Excavation, on-site landfill, off-site landfill
Was an innovative technology considered in the FS? If so, which technology?
\\ ' ' ' ' , • i •• ' ,
Innovative technologies considered during the identification arid screening of technically
feasible technologies were: !i i ,
- i ' [• •
Biological treatment: Biodegradation I
Phys/Chem treatment: Solvent extraction, soil flushing (solvent), washing (solvent), vacuum
vapor extraction " i ,
Thermal treatment: Critical and supercritical fluid extraction, thermal desorption, steam
stripping!, radio frequency heating, in situ vitrification
6. , What was the cost, estimate for the innovative technology? \
r . . •: " . !• ' ' ' '• , . •
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAA's), the FS does not quantify costs, After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening prixess (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on nine criteria established by
the NCP: long-term effectiveness and permanence; short-term effectiveness; compliance with
ARARs; protectiveness of humah health and the environment; reduction in contaminant
mobility, toxicity, or volume; implementability; cost; state/support agency acceptance; and
community acceptance. Present value cost estimates were not calcula ed during the three-
criteria screening, i
036
-2-
-------
Silresim Chemical Corporation

Lowell, Massachusetts
Region 1
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? '

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Carbon tetrachloride 450
Chlorobehzene . 260
Chloroform 50
1,1-Dichloroethene 146
1,2-Dichloroethane 490
1,2-Dichloropropane 70
Methylene chloride 480
1,1,2,2-Tetrachloroethane 830
1,1,1-Trichloroethane 1,900
1,1,2-Trichloroethane 33
Trichloroethene 1,900
Benzene 115
Ethylbenzene 630
Styrene 3,800
Toluene 1,200
Xylenes 400
Bis(2-ethylhexyl)phthalate 470
1,2-Dichlorbbenzene 752
Dioxins(2,3,7,8-equiv.) 0.01
Hexachlorobenzene 44
PCBs 1500
PAHs 2255
1,2,4-Trichlorobenzene 240
Trans-1,2-Dichloroethene 13
Arsenic 640
Lead 7,850
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1982
1983
6/19/91
9/19/91
Background

PRP-lead
PRPs: Not listed
FS prepared by: GZA
GeoEnvironmental, Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 137,000 cubic yards of soil
-1-
035
-------
16. How are alternatives compared?

- | ! ' • ' "I
Of the RAAs that underwent detailed evaluation, total cost was the primary measure used to
eliminate in situ vitrification (RAA-SC-5), incineration (RAA-SC-10), and off-site disposal
(RAA-SC-11). Also, in situ vitrification was considered an innovative technology and its
reliability was questioned. Capping was not considered as permanent or as protective as the
selected remedy because it does not treat contaminants and there is ithe potential for future
failure of components of the remedy that would require repair. ;

The Summers Leaching Model '(EPA/540/2-89/057) was used to estimate residual soil and
sediment levels not expected to impair future groundwater quality. !
17.
;. '"' " -I
What technical considerations had to be considered in the selection of a remedy? Were
technical considerations primary in the selection of the remedy? \ • •

The PSC site is about 1.5 acres?; located within the 100 .year fioodplain of the Quaboag River
and is bounded by wetlands to the south and east. Site soils were observed to be stained black
from, spills of waste oil/sludges to a depth of up to six feet and the depth to groundwater
ranges from one to eight feet, which accounts for groundwater contamination from the site.
Space limitations created implementation difficulties for incineration and on-site
biodegradation. The need for both a biodegradation facility and a landfill for the latter
alternative would result in a reduction of the flood storage capacity currently present in this
area. The adjacent wetlands would suffer greatest damage from the incineration and off-site
disposal alternatives due to the more intrusive excavation necessary. However, the majority of
technologies were eliminated because of the wide variety of organic and inorganic
contaminants at the site. Technical considerations could not be cons dered primary in the
selection of a technology at this site. ..-'"'•''
034
>-v
)
-.-^
-10-
-------

Contaminant
Arsenic
Non-Carcinogens:
Total PAHs
Lead
Clean-up Level (ppm)
12
10
375
ARAR or Other Basis
HHRA
ERAC
ERAd
"Human Health Risk Assessment.
bUptake/biokinetic model.
Theological risk assessment. .
''Clean-up levels for lead and zinc were established with an ERA to ensure the
protection of birds.
/ -
For carcinogens an excess upper bound individual lifetime cancer risk of between 10"4 to 10'6
was acceptable. For non-carcinogens a Hazard Index (HI) less than or equal to 1.0 was
acceptable. , , ' .

13. Was the innovative technology eliminated because of the clean-up goals? If a standard
technology was chosen, could it meet the clean-up goals? ,

Most innovative technologies were eliminated during the technology screening process because
they were not considered effective for the organic and inorganic contaminants at the site.
Innovative technologies included in RAAs that were eliminated because of clean-up goals were
on-site bioreclamation and soil flushing. The selected standard technology (in situ
stabilization) could meet clean-up goals.

14. Were treatability studies conducted on the innovative .technology or standard technology?

Yes, several treatability studies were carried out. A limited bench-scale biodegradation study
was'done on PSC Resources soil to evaluate the feasibility of applying bioremediation
techniques to reduce or remove contaminants in the soils at the PSC site, verify the existence
of a microbial population in the contaminated soils,,and evaluate the biodegradation of
contaminants by on-site microbes. Another soil column flushing study evaluated the transport
of VOCs from the soil to groundwater and the effectiveness of using surfactants for flushing
vadose zone soils. A third study explored the effectiveness of a soil stabilization mixture on
site soils.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Proven reliability '
- Preference for treatment
Permanence
-9-
033
-------
ft II?
YS ^^ ***
' ' ' . J ., ,
•f-'.'~
I ' I '
1 1 ' ' ' • '•','•
. , , , 1 , , .. . ,
. [, - . _ • ' ' • , .
Contaminant ;
Benzene* • !
i
Non-Carcinogens: ',
Lead
Total ncPAHs*
1,1-Dichloroethane* ,
Cis-l,2-Dichloroethylene*
Trans-1,2- f
Dichloroethylene*
1 , 1 , 1 -Trichloroethane*.
Clean-up Level (ppm)
1

500
151
243
5
7 ' ' '
135
ARAR or Other Basis
MCL

UBKMb
i risk
risk
\ MCL
MCL
!
MCLG
i , . r •
Lagoon Sediment Clean-up Levels:
Contaminant '
Carcinogens:
Bis(2-ethylhexyl) phthalate*
Trichloroethylene*
Tetrachloroethylene*
Methylene chloride* 1 1
Benzene* \
Total cPAHs j
Non-Carcinogens: I
1,1,1 -Trichloroethane*
Total ncPAHs* :
1,1-Dichloroethane*
Lead '
Acetone* :
Clean-up Level(ppm)

368
4
12
1
3
100

200
1,206
1
500
10
ARAR or Other Basis

MCL
MCL
1 MCL
MCL
MCL
HHRA
!
; MCLG
risk
risk
UBKM
risk
1 ' ' . , , . !
Wetland Sediment Cleam-up Levels:
i . • , " • . -
Contaminant ;
Carcinogens: '
Total PCBs :
Clean-up Level (ppm)

1
AFAR or Other Basis
i • -
HHRA
.:! - ••.-.-' {.._ • •; ; • ;
-------
11.
on the site. Further, it was expected that this technique would require an intense pilot
study to determine its long-term effectiveness prior to full-scale implementation. The
need for both a biodegradation facility and a landfill for this alternative would result in
a reduction of the flood storage capacity currently present in this area.
• Soil flushing (RAA-SC-9) was eliminated because it would be very difficult to:
implement due to the diversity of contaminants present since no individual flushing
solution could address all contaminants. Only a selective reduction in contaminants
would be achieved. Further, there would be potential for exposure in the short term.

Innovative technologies eliminated during the detailed analysis include:

• In situ vitrification (RAA-SC-5) was eliminated because it has not been used in any
commercial applications, raising questions about its implementability, and it requires
very high amounts of electricity not available at the site.

Which of the nine criteria were weighted highest in selection of the technology? Did one of
the nine criteria eliminate the innovative technology from being chosen? If so, which one?
Which of the criteria supported the use of a standard technology?

The most heavily weighted screening factors appeared to be cost and long-term
effectiveness/permanence. RAA-SC-6 and RAA-SC-4 were the least expensive and easiest to
implement RAAs. RAA-SC-6 was superior to RAA-SC-4 with regards to longrterm
effectiveness and permanence and its provision for treatment. RAA-SC-5 (in situ vitrification),
RAA-SC-10 (incineration), and RAA-SC-11 (off-site disposal) would provide greater reduction
in toxicity, mobility, or volume, but were eliminated because they were more costly and more
difficult to implement.
12. What clean-up goals were selected. If the clean-up goal was based on an ARAR, what was
that ARAR? What risk level was selected to establish clean-up goals?

Area soils and sediments were considered a source of VOCs to groundwater. It was believed
that the future contamination of groundwater by soil and sediment leachate would result in an
unacceptable risk to those who drank the contaminated groundwater. For these contaminants,
clean-up levels for soils and sediments were established to protect the aquifer from potential
soil leachate. The Summers Leaching Model (EPA/540/2-89/057) was used to estimate
residual soil and sediment levels not expected to impair future groundwater quality. Interim
clean-up levels for groundwater were used as input into the leaching model. Contaminants
whose clean-up goals were estimated with this model are noted with an asterisk (*).

Soil Clean-up Levels:
Contaminant
Carcinogens:
Total PCBs
Trichloroethylene*
Tetrachloroethylene*
Clean-up Level (ppm)

1
1
2
ARAR or Other Basis
•
HHRAa
MCL
MCL
-7-
031
-------
°. If an innovative technology was chosen, why?

An innovative technology was; not chosen.
" • « ve technobgy
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial Screening; during the screening of the thSl criteria of
effectiveness, implementability, and cost; or during the detailed evaluation
. ' H '.-..• ' [ • • •
»!•••• . •>
innovative technologies eliminated during the initial screening include:

• Low temperature thermal stripping was eliminated because L temperature necessary
to remove PGBs will be in excess of the flashpoint of other constituents
• Vacuum extraction was,eliminated because it does not address inorganic constituents
Molten salt destruction was eliminated because it was not considered implementable
due to uncertainties associated with waste destruction performance
• Solvent extraction was eliminated because the soil is organically rich (attributed to
waste oils) making liquid extraction less favorable and its effectiveness is limited by
the solubility of contaminants and the ability of the solvent to permeate through the
soil to influence entrapped contaminants. \
Dechlorination was elnninated because of its effectiveness with chlorinated organics
S^rfSl?1 ^,M COStS! apd difficulties wi*h implementation.
it does not address inorganic compounds and has
glass method was eliminated because it is an innovative technology that is
difficult to implement at this stage of development and has high capital and O&M
costs. ' f '
f p •' ^ '
In situ bioreclamation vi^as eliminated because it has a limited effectiveness
remediating chlorinated [organic compounds and inorganics, has high initial capital
costs, and has high O&M costs in the future I '
Land treatment was not included in the RAAs, although no explicit reason was given
On-site bioremediation was included in the RAA as the representative biological '
process option. The FS noted that land treatment has limited ; effectiveness on
chlonnated organics and inorganics. !
Wet air oxidation was not included in the RAAs, although noUplicit reason was
given. Incineration and in situ vitrification were included in the RAA as the
representative thermal process option. The FS noted that wetjair oxidation has limited
effectiveness on chlorimited organics and inorganics. ! nas limited
Supercritical water oxidation was not included in the RAAs, although no explicit
reason was given. Incineration in situ vitrification were included in the RAA as the
hTn^Vyhral P^esl °Ption- ** FS noted that supercritical water oxdation
has limited effectiveness on chlorinated organics and inorganics.

Innovative technologies eliminated during the screening of the three catena include:
(]^AA-SC-8) was eliminated because both short-term and long-
term effectiveness are low. Potential for exposure during implementation is great fo
the long-run, the technique would not address inorganic and PCB contamination found
030 ;L
II -6-
-------
Alternative
Standard Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-SC-6
Long-term monitoring/access restric-
tions/lagoon dewatering and treatment/
consolidate sediment and soils/in situ
stabilization of consolidated source
materials/permeable cap over stabilized
mass/wetlands restoration
$3,070,000
$3,067,045
RAA-SC-7
Long-term monitoring/access restrictions/
lagoon dewatering and treatment/construct
stabilization plant/construct residual source
materials storage facility/dewater beneath
AOC with ground water treatment and
discharge/obtain treatability variance/
excavate sediment and soils/on-site RCRA
disposal/stabilize residual source
materials/wetlands restoration
$5,500,000
eliminated
RAA-SC-10
Long-term monitoring/access restrictions/
lagoon dewatering and treatment/construct
on-site incinerator/construct temporary
source material storage facility/dewater
beneath AOC and treat ground water/
excavate sediment arid soil for storage/on-
site RCRA disposal/incinerate source
materials/place incinerator residuals into
disposal facility/cap/wetlands restoration
$15,010,000
$15,009,715
RAA-SC-11
Long-term monitoring/access restrictions/
lagoon dewatering and treatment/dewater
beneath AOC, with groundwater treatment
/excavate and containerize soils and
sediments/off-site RCRA disposal/backfill
excavation/wetlands restoration
$34,626,000
$36,261,417
8. If a'standard technology was chosen, why? ' ;.

In situ stabilization (RAA-SC-6) was chosen because it permanently reduces risks posed to
human health and the envkonment; meets all ARARs; uses readily implementable techniques
that have been successfully used at other NPL sites; emphasizes treatment; has minimal short-
term risks- and is cost-effective. In situ vitrification (RAA-SC-5), incineration (RAA-SC-10),
and off-site disposal (RAA-SC-11), are all more expensive and less implementable than in situ
stabilization. Capping (RAA-SC-4) was considered as cost-effective as the selected remedy,
but does not comply with the statutory preference for treatment and was considered less
protective because none of the contaminants would be eliminated, reduced, or stabilized.
-5-
029
-------
7.
Alternative
RAA-SC-8
RAA-SC-9
'!.-._
Innovative Technology
Long-term monitoring/access restrictions/
lagoon dewatering and treatment/construct
biodegradatkm facility/obtain treatability
variance/excavate sediments and soils/
construct ori-site RCRA disposal facility/
bioremediate residual source materials/cap
disposal facility/wetlands restoration
Long-term monitoring/access restrictions/
lagoon dewatering and treatment/excavate
wetlands and lagoon sediment for disposal
at off-site RCRA facility/in situ soil
flushing of property soils/leachate
collection and treatment/permeable cap
over property ^oils/wetlands restoration
' Estimated Costs
3 Criteria
,$4,255,000
1
$5,020,000
i
•I
(
f
\
9 Criteria
eliminated
eliminated
ii • . • ... ^ - . .
' - ; • • ; ' ' J ".'-• . ,:. • '
How did the cost(s) compare to standard technologies?
1 , -•'•' ' - '
Cost Estimates for RAAs That Include Established Technologies
(selected remedial alternative is in bold) j
028
Alternative
RAA-SC-1
RAA-SC-2
' RAA-SC-3
RAA-SC-4
Si
tandard Technology
No action: long-term monitoring
Limited action: long-term monitoring/
access restriction
Long-term monitoring/access restriction/
lagoon dewzitering and treatment/
permanent cap over lagoon, property,
wetland soils, and sediments/wetlands
restoration
Long-term monitoring/access restrictions/
lagoon dewatering and treatment/consolida-
tion of sediment and soil/impermeable cap
over consolidated source materials/earthen
levee/subsurface drain and vertical barrier/
ground water collection in barrier for
treatment anjfl discharge/wetlands
restoration ;
' Estimated Costs ,
3 Criteria
$(550,000
$760,000
Ji
,l
$863,000
* ?'
(
$2,680,000
i
i
!'
9 Criteria
$648,800
eliminated
eliminated
$2,677,815
J - ''''''.' - ••
1 • ' • . ' ' •
1 - } '..'''
' ' . '1 ' -.4- '' "-'-••- ..-•:•• ;''•'-'
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies eliminated during the identification and screening of technically
feasible technologies were:

Soil

Biological treatment: On-site bioremediation, in situ bioreclamatioh, land treatment
Phys/Chem treatment: Vacuum extraction, solvent extraction, soil flushing, dechlorination
Thermal treatment: Low temperature thermal stripping, vitrification, molten salt . ]
destruction, pyrolysis, molten glass method

Lagoon Sediment

Biological treatment: In situ bioreclamation, on-site bioreclamation, land treatment, activated
sludge
Phys/Chem treatment: Solvent extraction, soil flushing, dechlorination
Thermal treatment: Wet air oxidation, supercritical water oxidation, vitrification, pyrolysis,
molten glass method

Wetlands Sediment

Biological treatment: On-site bioremediation, in situ bioreclamation, land treatment
Phys/Chem treatment: Solvent extraction, soil flushing, dechlorination
Thermal treatment: Low temperature thermal stripping, pyrolysis, molten glass method
What was the cost estimate for the innovative technology?
. i
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of the three criteria (effectiveness, implementabihty,
cost) screening process to identify alternatives of sufficient merit to undergo detailed
evaluation. The estimated costs are recalculated during evaluation by the nine criteria
established by the NCP.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SC-5
Innovative Technology
Long-term ground and surface water
monitoring/access restrictions/lagoon
dewatering and treatment/consolidation of
sediments/in situ vitrification of
consolidated source -materials/permeable
cap over vitrified mass/wetlands restoration
Estimated Costs
3 Criteria
$10,380,000
s.
9 Criteria
$10,383,403
-3-'
027
-------
2. What volume of material is to be remediated?
[•!'' .." -•••'• /
" '
The volume of material to be remediated included:
* .if-,.-. s

B 11,000 cubic yards ofj contaminated property soil
« 450 cubic yards of wetland sediment
.• 1,245 cubic yards of lagoon sediment
1! -
'''

3. What type of site is this? i
f '• " ' r
Waste Oil. A former waste oil reclamation facility.

i i • " : '

TECHNOLOGY SELECTION "
, f ' :

4. What standard technologies were considered for selection in this Fi
Standard technologies considered during the identification and
technologies were: ; :
Soil

Access restrictions:
Containment:
Physical treatment:
Thermal treatment:

Chemical treatment:
Disposal:

Lagoon Sediments

Access restrictions:
Containment:
Chemical treatment:
Thermal treatment:
Physical treatment:

Disposal:

Wetlands Sediment

Access restrictions:
Containment:
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Deed restrictions, fencing
Capping, surface controls (grading)
Dewatering, lime-based pozzolan, sorption
Rotary kiln incinerator, infrared treatment,
thermoplastic microencapsulation
Precipitation, vacuum extraction with carbon
On-sitelRCRA landfill, off-site RCRA landfill
Deed restrictions, fencing
Slurry wall, sheet piling, bottom liner
Precipitation
Rotary kiln incinerator, infrared treatment, „ ,
Evaporation, dewatering, lime based pozzolaa
pozzolaii, asphalt based microencapsulation,
Off-site RCRA landfill
screening of technically feasible
stabilization
c: rculating bed combustor,
adsorption
circulating bed combustor
, portland cement
sorption stabilization
Deed restrictions, fencing i
Capping, coffer dams, revegetation j
Precipitation j
Dewatering, evaporation, sorption stabilizatiop
Rotary kiln incineration, infrared treatment, circulating bed combustor
On-site,: off-site RCRA landfill ..[.-,
026
-2-
-------
PSC Resources Site
OU-1

Palmer, Massachusetts
Region 1
GENERAL SJTR INFORMATION

L What were the principal contaminants,
contaminant levels, and media being t
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg):

Total PCBs 65
Trichloroethylene 390
Tetrachloroethylene 63
Benzene 16
Total ncPAHs 953
1,1-Dichloroethane 7
1,2-Dichloroethylenes '190
1,1,1-Trichloroethane 200 ,
Lead 39,200

Lagoon Sediments (mg/kg):

Total cPAHs ' 7,250
Bis(2-ethylhexyl)phthalate 580
Trichloroethylene 33
Tetrachloroethylene 21
Methylene chloride . 20
Benzene . 340
1,1,1-Trichloroethane 1,700
Total ncPAHs 97,350
1,1-Dichloroethane 10
Acetone 43
Lead 12,600

Wetland Sediments (mg/kg):

Total PCBs 32
Arsenic 22
Total PAHs , 129
Lead 50,100
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1982
9/83
1/10/91
9/15/92
Background

EPA Fund-lead
PRPs: PSC Resources, Inc., Newtown
Refining Co., Refinemet Inter-
national, Ag-Met Refining Co.,
over one hundred other PRPs
FS prepared by: HMM Associates, Inc.
-1-
025
-------
17.
For carcinogens, an excess upper bound individual lifetime cancer ri
was acceptable. For noncarcinogens, a Hazard Index less than or e
14. Were treatability studies

No treatability studies were conducted
risk of between 1Q"4 to W6
to 1.0 was acceptable.
qual

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

.Innovative technologies eliminated because of cleanup goals include

• None

Standard technologies eliminated because of cleanup goals include:

• None
conducted on the innovative technology or (tandard technology?
to compare alternatives?

to compare the alternatives:
15. What measures/criteria were used

The following measures were used

Total cost
- , • reliability

16. How are measures compared?
! • ' t ''
Seven of the ten original alternatives proposed source treatment technologies. Treatment was
preferred because it would ensure the greatest degree of long-term effectiveness and
permanence. The chosen alternative utilized an innovative treatment itechnology that was
considered superior because it minimizes short-term risk and is cost-eiffective. Several
eliminated alternatives (RAA-4, RAA-5, RAA-6, and RAA-7) would ipose short-term risks to
site workers and off-site populations during excavation. The remedy. |was considered reliable
since it had been applied often for contaminants and site conditions. •;
What technical considerations were factors in selecting a remedy? W^ere technical
considerations primary in the selection of the remedy? \
• !' ' - -, ''f- •"•..-•'•
Site-specific wetland ARARs were primary in the elimination of RAA-SC-10 since it would
disturb arid destruct wetlands. ',\ ' ' I
024
-7-
-------
Innovative technologies eliminated during the three-criteria screening include the following:

• Soil flushing was eliminated because 1) it is less effective than Soil Vapor Extraction,
and 2) less reliable than Soil Vapor Extraction.
• In situ heating (unspecified) was eliminated based on cost. ,

Innovative technologies eliminated during the detailed analysis include the following:

• Ex situ vapor extraction was eliminated because it would result in short-term risk
during excavation and it would not be as cost-effective as the chosen alternative.
• On-site low temperature thermal stripping was eliminated because it would result in
short-term risk during excavation arid it would not be as cost-effective as the chosen
alternative.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology? ,

An innovative technology was chosen over several other innovative and standard technologies
because it offered the greatest protectiveness at the least cost, provided short term effectiveness
and was implementable.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Soil cleanup levels were established to protect the aquifer from potential soil leachate. The
Summers model was used to estimate residual soil levels that are not expected to impair future
water quality. Interim cleanup levels for ground water were used as input into leaching model.
Contaminant
Cleanup Level (mg/kg)
Basis for Model Input
Carcinogens
Trichloroethene
Vinyl chloride
1 , 1 -Dichloroethane
O.Q7
0.005
0.36
MCLa
MCL"
SHAb
Noncarcinogens
Toluene
Ethylbenzene
1 ,2-Dichloroethene
1,1,1 -Trichloroethane
14
17.4
0.46
2.1
MCLGC
MCLGC
MCLGC
MCLGC
"Maximum Contaminant Level. /
bState Health Advisory.
cMaximum Contaminant Level Goal.

-6-
023
-------
1 ! - f
™ Hydrolysis was eliminated because 1) it is most applicable to ester compounds, 2)
aromatic VOCs are resistant to hydrolysis, and 3) hydrolysis rates of chlorinated VOCs
are on orders of years, I
• Dehalogenation was eliminated because 1) it is inappropriate for in situ application
since mixing can't be controlled and contact with contaminants can't be ensured, 2)
testing with chlorinated VOCs suggest removal was the result of volatilization.
M Soil cooling was eliminated because it is practical only as a short-term measure
because of energy costs. j '
n Ground freezing was eliminated because it is practical only; as a short-term measure
because of energy costs. I-
B In situ vitrification wzis eliminated because 1) it is most suitable for radioactive and
highly toxic wastes because of cost, and 2) may result in air emissions.

Ex situ Technologies | . ' -
B Solvent extraction was eliminated because 1) applicable primarily to heavily impacted
spill sites, and 2) it is difficult to quantitatively recover solvent from soil.
n Supercritical extraction was eliminated because 1) the process has been lab tested for
PCBs and DDT only, and 2) applicability to VOGs in soil is unknown.
« Addition of agricultural products was eliminated because the technology is in the
research stages, mostly with pesticides, herbicides and sewage sludge.
n Anaerobic digestion bioreactor was eliminated because 1) available reactor designs are
not suitable for soils, 2) chlorinated VOCs degrade relatively slowly and may require
additional carbon sources to support organism growth, and 2) degradation of
chlorinated VOCs may produce toxic metabolites. , I
n Composting was eliminated because 1) most experience is Mth wastewater treatment
sludge, 2) utility for soil is limited because of insufficient djegradable organic matter to
sustain composting process. [
B Land/arming was eliminated because 1) application to hazardous waste sites is in the
early research stage, 2) requires secondary containment, 3) expected not to apply to
contaminated soils but to concentrated wastes, 4) halogenated solvents ; require
pretreatment to enhance degradation. !
n Catalytic oxidation was eliminated because it is applicable lio aqueous waste streams
only. • ;; ' > . .| .. . . ,
n Ex situ dehalogenatioii was eliminated because 1) testing for chlorinated VOCs
indicated removal by Volatilization, not dechlorination, 2) applicable only to PCB oils
- and other concentrated haloaromatic compounds, 3) no research on haloaliphatic
compounds in soil. ; . i
B Molten salt was eliminated because 1) it is applicable to liquids, free-flowing powders,
sludges and shredded solid wastes, 2) not suitable for soils, land 3) mobile units are not
available. : I
B Pyrolysis was eliminated because 1) it is applicable primarily to sludges, liquids and
solid wastes that undergo partial or complete phase changes during thermal processing
and 2) use on soil would encounter operational problems and high costs.
n Wet air oxidation was eliminated because it is applicable only for aqueous waste
streams with less than 5 % organic compounds. f
B Supercritical water oxidation was eliminated because 1) it is primarily applicable to
liquids, sludges and slurries and solids soluble in water, 2) requires minimum of 1 - 2
% organic content to. avoid supplemental fuel requirement, 3) operational costs for
soils may be high because of supplemental fuel requirements.
\
*
022
-------
Alternative
RAA-SC-9
Standard Technology
Off-site disposal
Estimated Costs
3 Criteria
$2,100,000
to
$2,900,000
9 Criteria
eliminated
8. If a standard technology was chosen, why?

•"' See below regarding the use of a cap with soil vapor extraction.
9. If an innovative technology was chosen, why?

In situ vapor extraction with installation of an upgradient interceptor trench and cap to dewater
the soil was selected. The remedy was selected because: 1) in situ treatment would eliminate
disturbance of VOC-impacted soils, 2) treatment using vapor extraction and installation of a
cap would reduce human exposure, 3) prevent further deterioration of ground water, 4)
permanently reduce mobility, toxicity and volume, 5) cost less, 6) easy to implement, 7)
construction methods for the remedy are well-established and the equipment and materials are
readily available, 8) qualified contractors exist. :
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? , .

Innovative technologies eliminated during the initial screening include the following;

In Situ Technologies
• Aerobic biodegradation was eliminated because: 1) it is inappropriate for chlorinated
solvents because of extended time required for aerobic degradation, 2) operational
limitations imposed by low hydraulic conductivities on nutrient/oxygen injection and
recovery of metabolites, and 3) treatment of recovered water may be necessary.
" Enzymatic degradation was eliminated because, 1) it is in the research stage, 2) its
applicability to VOCs is unknown, and 3) most research has been for extractable
organic compounds 'and pesticides.
» Vegetational uptake was eliminated because it is, 1) applicable primarily to metals, 2)
depends upon uptake by root systems of harvestable vegetation, so it is suitable only
for surface and near surface soils. s
• Oxidation was eliminated because 1) it may increase mobility of metals in soils, and 2)
chlorinated solvents incompatible with common oxidizing agents may form more
mobile or different chlorinated products.
• Reduction was eliminated because: 1) it is not applicable to VOCs and 2) it may for
toxic or more mobile VOC products. , , ,
-4-
021
-------
7.
Cost Estimates for RAAs That Include Innovative Techno! ogi
(selected remedial alternative is in bold)
es
Alternative
RAA-SC-3
RAA-SC-4
RAA-SC-6
RAA-SC- 10b
r '
Innovative Technology
In situ vapor extraction/capping
i;
On-site vapor extraction
On-site low temperature thermal
stripping ;;
In situ vapor extraction/ground water
treatment system
Estimated Costs
t
3 Criteria
$600,01)0 to
$700,000"
$700,000 to
$900,000
$i,ooo;!ooo
to!
$i,4oo,;ooo
N/A .
9 Criteria
$690,000
$1,000,000
$2,400,000
$2,100,000
*A range of costs was presented due to uncertainties in exact soil volumes
RAA-SC-10 was developed at the detailed analyses phase and therefore has no three-criteria
cost estimate. Furthermore, this: report renumbered the alternatives for the detailed analyses
phase and, because two options |were eliminated, RAA-SC-10 is referred to as RAA-SC-8
IHC JTo. | • '•
in
How did the cost(s) compare to standard technologies? j

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) I
Alternative
RAA-SC- 1
RAA-SC-2
RAA-SC-5
RAA-SC-7
RAA-SC-8
Standard Technology
No action r ' •
-' I" '
Multilayer cap
Chemical fixation
On-site thermal destruction via rotary
kiln incineration
Off-site thermal destruction at a
RCRA-permitted rotary kiln
incineration unit
Estimated Costs
3 Criteria
$150,000 to
$200,000
$400,000 to
$450,000 1
$1,100,000
to!
$1,300,000
$6,000,000
to I
$8,000,;000
$6,800,!boO
to !
$9,000,000
9 Criteria
$300,000
$790,000
$1,900,000
eliminated
$9,700,000
020
-3-
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Phys/Chem treatment:
Thermal treatment:
Disposal:
Site security, monitoring
Single-layer cap, multilayer cap, bottom grouting
Neutralization, carbon absorption, thermoset fixative, cement/silicate
fixative, thermoplastic fixation, surface microencapsulation, addition of
proton donors, mechanical aeration, dewatering, physical separation
(screens and sieves), filtration, vacuum filtration
Evaporation, rotary kiln incineration, multiple hearth incineration, high
temperature fluid wall incineration, infrared incineration, fluidized bed
incineration, advanced electrical reactor, plasma arc, circulating bed
combustor
Excavation, dredging, RCRA landfill, resource recovery facility,
asphalt batch plant
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation, vegetative uptake, in situ enzymatic degradation,
landfarming, addition of agricultural products and by-products, ex situ
anaerobic digestion, composting
Chemical treatment: Dehalogenation, soil flushing (solvent), vapor vacuum extraction,
hydrolysis, catalytic oxidation, solvent extraction, supercritical water
oxidation, oxidation, reduction
Thermal treatment: In situ vitrification, soil cooling, artificial ground freezing, low
temperature thermal stripping, supercritical extraction, molten salt,
molten glass, pyrolysis, wet air oxidation
What was the cost estimate for the innovative technology?

Maximum concentrations of principal
contaminants were: ;
11
11 •
Soil/Sediment (rag/kg) • i|-
Trichloroethene f
Ethylbenzene 140
Toluene 47
1,1,1-TrichIoroethane 0.064
1,1-Dichloroethane 0.36
Methylene Chloride
Tetrachloroethene
Xylenes
Acetone
Vinyl Chloride
1,2-Dichloroethene
.t
t
270
t
*
History
NPL Proposed:
NPL Final:
FS:
ROD:
4/10/85
7/22/87
2/1/91
3/29/91
Background
j •• • '
Fund-lead . I
PRPs: Richard AJ Mottolo; KJ. Quinn
Company, incorporated; Service
Pumping aiild Drain Company,
Inc. i
FS prepared by: Balsam
Environmental Consultants
"These'compounds were not detected in the soils but were detected at significant
concentrations in ground water. jjSoil cleanup levels were developed for both of these
TMaximum concentrations of these contaminants were not found
What volume of material is to be

The volume of material to be

• 3,400 to 4,000 cubic yards
remediated?

remediated included:

of soil and sediment
3. What, type of site is this?

Uncontrolled Waste Site. A
. 1975 and 1979.
former piggery that was used as a hazardous waste site between
018
-i-
-------
Contaminant concentrations in sediment were all below health-based risk levels The
estimated blood lead level from exposure to lead in sediments was below levels believed to
cause adverse health effects. ,

Cleanup levels were set for ground water but not for sediment.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: -

• None . ,'•'

Standard technologies eliminated because of cleanup goals include:

• None .." . '

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
' • ' ^ •."•.'
Waste left in place/institutional controls

16. How are measures compared?

The chosen remedy is the most comprehensive and protective option. The remedy uses • ^
containment and migration management to address site contamination. One alternative, RAA-
5A, proposed a more protective cap, but was eliminated because the cap design would cause
the permanent loss of wetlands.

RAAs also were compared based on the Hydrologic Evaluation of Landfill Performance
(HELP) computer model, which estimated how much leachate would be generated and where
it would migrate. -

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary, in the selection^/ the remedy?

The primary .consideration was the location of the landfill, which is surrounded by wetlands
and surface water bodies. As was previously discussed (#15), two proposed RAAs were
eliminated for not meeting site-specific wetland and floodplain ARARs.
017
-------
10.
11.
12.
If an innovative technology was not chosen, why not? At what stage was the technology
eliminated? i ( '•.-.,'.

Innovative technologies could be eliminated from the remedial technology process at three
stages: during the initial screening; during the screening of the three criteria of effectiveness,
implementability, and cost; or during the detailed evaluation j

Innovative technologies eliminated from consideration during the initial screening include the
following: » :

• In situ soil flushing wa!s eliminated because of the possibility that contaminants flushed
into the aquifer could not be captured and might intensify the problem; the
heterogeneous and variable nature of landfill materials and difficulty in extracting the
contaminated ground water. [
• Vacuum extraction was; eliminated because the process option is not an effective or
implementable treatment method for the contamination in the landfill.
• In situ biodegradation was eliminated because the monitoring and control of all
elements necessary for effective degradation would be difficult; because of the
fluctuating water table, the location of source material both above and below the water
table; degradation products are more toxic than'the parent compound.
• Low temperature thermal aeration was eliminated because it would require excavation
and would not be implementable because of the volume and nature of the landfill
material. !
• On-site biodegradation was eliminated because it would require excavation and"would
not be implementable, because of the volume and nature of the landfill material.
eliminated during the screening for three crileria include the following
Innovative technologies elii

• .None

Innovative technologies elirninajted during the detailed analyses include the following:

• None
Which of the nine criteria were
to meet one of the nine criteria
which criterion? Which of the
Protection of human health and[
Final decision was based on
weighted most heavily in selecting the
result in the elimination of the innovative
criteria supported the use of a standard
the environment, implementability,
community input into the design of the
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
For carcinogens, an excess upper bound individual lifetime cancer risk
was acceptable. For noncarcinpgens, a Hazard Index less than or eqi al
016
technology? Did failure
technology ? If so,
technology?
community acceptance.
cap.
of between KT4 to 10"6
1 to 1.0 was acceptable.
-4-
-------
Alternative
RAA-4
RAA-4A
RAA-5
RAA-5A
Standard Technology
Modify the top of the existing cap/long-
term maintenance/monitoring of gas
collection/monitor ground and surface
water quality/perimeter fence/surface
drainage improvements/leachate
collection/off-site treatment and disposal
Same as RAA-4, also includes ground
water extraction system/on-site leachate
and ground water treatment
Upgrade entire cap/perimeter fence/monitor
gas collection/monitor ground and surface
water quality •
Same as RAA-5, also includes ground
water extraction system/on-site ground
water treatment :
Selected Reconstruction of the existing landfill
Remedy cap over the entire 60 acres/cap
maintenance/surface drainage system/
gas collection and monitoring/leachate
collection, treatment and disposal/
perimeter fence/long-term monitoring of
surface and ground water
'

The selected remedy was developed during the ROD.
Estimated Costs
3 Criteria
;N/A
N/A
N/A
N/A
N/A
9 Criteria
$5,637,179
$13,567,296
$13,700,349
$24,301,892
$12,553,524a
8. If a standard technology was chosen, why? .

A standard remedy was selected that includes: reconstruction of the landfill cap, surface
drainage control and leachate collection. This remedy was selected because: 1) it prevents
direct contact and ingestion of site contaminants, 2) it reduces the volume of leachate, 3) will
minimize erosion of the landfill into surrounding wetlands, 4) involves little construction
which avoids adverse affects on the wetlands.
If an innovative technology was chosen, why?

No innovative technologies were chosen.
-3-
015
-------
Dir.^osal:
Ph al treatment:
Thermal treatment:
Excavation and off-site disposal
In situ solidification
Incineration
Was an innovative technology considered in the FS? If so, which technology?
Innovative technologies considered during the identification and
feasible technologies were: ;:
scree ning of technically
Biological treatment: In situ biodegradation, on-site biodegradation
Chemical treatment: In situ soil flushing
Thermal treatment: Vacuum'extraction (solvents), in situ thermal
aeration
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible
(prior to the formulation of RAAs), the FS does not quantify costs.
formulated, costs typically are estimated as part of a three-criteria sen
(effectiveness, implementability,and cost) to identify alternatives that
evaluation. In this case, costs were calculated during an evaluation
established by the NCR :
tecl nologies are identified
After the RAAs have been
«ning process
merit a more detailed
biased on the nine criteria
No innovative technologies were incorporated into remedial alternatives.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Established Technologies
(selected remedial alternative is in bold)

Alternative
RAA-1
RAA-2
RAA-3
RAA-3A
i i
Standard Technology
No action •'• • '
Complete existing cap/long-term
maintenance/perimeter fence/monitoring of
gas collection/monitor ground and surface
water quality j:
Complete existing cap/perimeter fence/
long-term maintenance/monitoring of gas
collection/monitor ground and surface
water quality/leachate cpllection/off-site
treatment andidisposal of leachate/surface
drainage improvement
Same as RAA-3, also includes ground
water extraction system/leachate and
ground water treatment on site
Estimated Costs
3 Criteria
N/A
N/A
i
N/A
N/A
• °14 •'. '• ik'" -2- • •-• ' ;: '
9 Criteria
$0
$2,231,611 .
$5,190,155
$13,151,862
-
-------
Iron Horse Park (Shaffer Landfill)
OU-2

Billerica, Massachusetts
Region 1
GENERAL SITE INFORMATION

7. What were the principal contaminants,
contaminant levels, and met
this feasibility study?

Sediment (mg/kg)

1,1 -Dichloroethene
Trans-1,2-dichloroethene
1,2-Dichloroethene
Toluene
Acetone
Methyl ethyl ketone
Acenaphthene
Anthracene
Fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene x
Benzo(g,h,i)perylene
tinants,
addressed in
<

0.1
0.57
0.17
0.039
0.63
0.22
3.3
4.2
2.2
11
4.5

Site History
NPL Proposed: N/A-
NPL Final: 9/94
FS: 1/10/91
ROD: 6/27/91
'
Background

EPA Fund-lead
PRPs: Not listed
FS prepared by: Camp Dresser &
McKee Inc.

, ,
•5.3 • "..••" ;
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 5,000,000 cubic yards of waste material
3. What type of site is this?

Municipal Landfill.. Operational Unit 2 (OU-2) is a former landfill and one of three units at
the site.
TECHNOLOGY SELECTION

4. What established technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ^ " •
Access restriction:
Containment:
Fencing, deed restrictions
Capping

-1-
013
-------
16. How are alternatives compared? • • j

Only alternatives that provided protection to human health and the environment, attained
ARARs, and had proven to be reliable were considered appropriate i^s site remedies. Cost
effectiveness was measured by comparing the level of protectivenesii provided with the cost of
an alternative. Impacts on nearby populations were considered when comparing methods for
reducing exposures to contaminated landfill materials and sediment^ The amount of technical
and support equipment resources required was considered when comparing installation of a
slurry wall versus an interceptor trench/barrier wall. j,
17.
What technical considerations had to be considered in the selection of a remedy? Were
technical considerations primary in the selection of the remedy? !
• n . 'i
A portion of the site lies within a 100 year floodplain of the Cocheco River, 500 feet to the
east. The Bellamy reservoir, a Calderwood well, and four wetland systems are within the
vicinity of the site. The site overlies both an upper and a lower aquifer that are separated by
impermeable clay. RAA-SC-5 and RAA-SG-5A included a slurry wall that was believed to be
potentially detrimental to the clay layer. Technical considerations (beyond the volume of
landfill material) could not be considered primary in the selection ofia remedy at this site.
012
-7-
-------
12.
technologies were considered in the nine criteria evaluation. Only standard technologies were
considered at this point.

What clean-up goals were selected? If the clean-up goal was based on an ARAR, what was
that ARAR? What risk level was selected to establish clean-up goals?
Contaminant
Non-Carcinogens:
Arsenic
Clean-up Level (ppm)
:
50
ARAR or Other Basis

ERLa
The environmental risk level (ERL) is a level deemed protective for environmental
receptors and uses National Oceanic and Atmospheric Administration standards.

Innovative technologies were eliminated primarily because they were not applicable to the
range and volume of contaminants present at the site. No innovative technologies were
eliminated because of cleanup goals. The technology selected for remediation of contaminated
perimeter drainage sediments was excavation and deposition in the landfill prior to capping.
This standard remedy could meet cleanup goals. .
14. Were treatability studies conducted on the innovative technology or standard technology?

A treatability study was conducted by HMM to provide data to evaluate treatment options for
the site and to reduce cost and performance uncertainties for treatment options. The study
consisted of an additional round of sediment, surface water, and groundwater sampling. The
study was aimed at evaluating the implementability and feasibility of groundwater remedial
technologies.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost effectiveness
Impact on nearby populations
Proven reliability
Technical and support equipment resources
Oil
-6-
-------
10. Ifan innovative technology-was,not chosen, why? : ....-

Innovative technologies could be eliminated from the remedial technology selection process at - <
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, :and cost; or during the detailed evaluation.
. . 'i !•' • ' ' !» " ' ' -

Innovative technologies eliminated during the initial screening include:

Solid Waste: [

' ••;! ' • ; ••'• ''I : :' •'. •• . '" ' ••-.. ,
• Wet air oxidation is typically used for treating pumpable aqueous and sludge wastes
It was eliminated because it is not feasible for treating mixtures of waste types present
in solid waste matrices.: i .
• Bioremediation was eliminated because it has only limited effectiveness for chlorinated
solvents (low biodegradation rate) and metals. '
• Dechlorination was eliniiinated because it specifically addresses chlorinated
polyaromatic constituents that do not comprise the majority of contaminants found at
the Dover site. It also has relatively high capital and O&M costs.
• Solvent extraction on a large scale has shown limited success^ it has relatively high
implementation costs, and residual solvent adhering to treated soils presents a process
problem. i !
• Thermal desorption was eliminated because its effectiveness is limited by the vapor
pressure of the contaminants of concern and temperatures necessary to vaporize
contaminants must not exceed the flashpoint of any constituent.
• Soil flushing has limited success at high cost. The composition of the landfill is .
undetermined and soil flushing may not work because it is dependent on solubility and )
surfactant contact that is adversely affected by channeling in the soil matrix
• Vacuum extraction was eliminated because it applies selectively to volatile compounds
and will not address metal contaminants. Further, it can only ^be operated at limited
depths, which precludes its use at greater depths within the laiiidfill.
• In situ vitrification was eliminated because it has never been implemented on a large
scale. Further, it requires significant electrical power and is therefore prohibitively
expensive. ; I" ,
; .'"•!•'
Sediment: -
'ii ' ' • '' ' •' • • •
• In situ vitrification cannot be used because of the saturated state of contaminated
sediments. ,ii . - i
• Oxidation/reduction was eliminated because it shows only limited promise for metal
contaminants and does not address organic constituents. I

No innovative technologies were incorporated into RAAs.

' ii • • '•
i !• . - .•.
11. Which of the nine criteria were weighted'highest in selection of the technology? Did'one of
the nine criteria eliminate the innovative technology from being chosen? If so,' which one?
Which of the criteria supported the use of a standard technology? t
:, .. •

\
<~~^, uic ciucim ui cosi, impiementability, and long-term effectiveness were most heavily )
weighted (pnmanly because there was little difference in other criteria! No innovative
010
-5-
-------
=====
Alternative
RAA-SC-T
•
or
RAA-SC-7A
RAA-SC-8
RAA-SC-8A
RAATSC-9
=======
, — ~ —
Standard Technology
Long-term monitoring/recontouring
of landfill/multi-layer cap/perimeter
barrier/sediment consolidation/
methane gas collection and ventila-
tion/interceptor trench/groundwater
treatment/discharge to Cocheco River
Same as SC-7 except discharge to
POTW
Long-term monitoring/excavation of
hazardous materials and sediment/off-
site treatment and disposal at RCRA
facility/on-site RCRA landfill for
noncombustible materials
Same as SC-8 with discharge to POTW
Excavation/off-site RCRA TSD
facility/off-site RCRA disposal
.
Estimated Costs
3 Criteria
$22,270,600
$22,171,900
$301,350,700
$302,795,000
$1,038,390,000
===============
9 Criteria
$22,270,600
$22,171,900
eliminated
eliminated
eliminated
========
The decision to discharge to the Cocheco River or to the POTW will be made during pre-
design studies.

8. If a standard technology was chosen, why? „ .

RAA-SC-7 or RAA-SC-7A was selected;^ difference between these alternatives is the
ultimate discharge location of treated water, which will be determined during design. The
selected remedy combines the most cost-effective remedial alternatives that are both protective
of human health and the environment and attain ARARs. Alternatives RAA-SC-5 and RAA-
SC-5A would provide similar protection to human health and the environment and ARAR
attainment, however, they would be much more costly and more difficult to implement.
Obtaining clay of sufficient volumes for the low permeability layer of the cap may be difficult
under RAA-SC-5 and RAA-SC-5A. The interceptor trench/barrier wall of RAA-SC-7 and
RAA-SC-7 would require less technical and support equipment resources to install than the
slurry wall of RAA-SC-5 and RAA-SC-5A. The limited excavation provided for in RAA-SC-
7 and RAA-SC-7 would be much easier and quicker to implement.

Other alternative remedial strategies that were proposed, RAA-SC-1 and RAA-SC-2, were less
expensive. However, RAA-SC-1 did not meet any ARARs and provided no protection of
human or environmental health, and RAA-SC-2 met only a few ARARs and provided limited
protection of human health and no protection of the environment.
If an innovative technology was chosen, why?

No innovative technologies were selected or included in the RAAs.
009
-4-
-------
7.
1 • . . " ' • 1
i • , r . • " ••
How did the cost(s) compare to standard technologies? ' \
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SC-1
RAA-SC-2
RAA-SC-3
RAA-SC-3A
RAA-SC-4
RAA-SC-4A
RAA-SC-5
RAA-SC-5A
RAA-SC-6
RAA-SC-6A
Standard Technology
No action with long-term monitoring ,
Limited action with long-term
monitoring
-------
Thermal treatment:

Disposal:

Sediment

Access restrictions:
Containment:
Sediment control:
Chemical treatment:

Disposal:
Rotary kiln incineration, fluidized incineration, multiple hearth
incineration, infrared treatment
On-site RCRA landfill, off-site disposal at an existing RCRA landfill
Fencing, deed restrictions
Soil cover cap, single-barrier cover cap
Dikes, berms '
Thermoplastic/thermosets solidification, surface microencapsulation,
cement and silicate fixatives, oxidation reduction
On-site or off-site at.a RCRA disposal facility
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Solid Waste

Biological treatment: On-site bioremediation
Chemical treatment: Wet air oxidation, dechlorination, solvent extraction
Physical treatment: Soil flushing, vacuum vapor extraction
Thermal treatment: Thermal desorption, in situ vitrification
\
Sediment

Thermal treatment: In situ vitrification
Chemical treatment: Oxidation/reduction
What was the cost estimate for the innovative technology?

No innovative technologies were included in the RAAs^ therefore, no cost esttmates were made
for innovative technologies.
-2-
007
-------
GENERAL SITE INFORMATION
Dover Municipal Landfill
Dover, New Hampshire
v Region 1
1.
What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

No contamination was found in off-site
surface soils. Landfill contents were not
sampled. Maximum concentrations of
principal contaminants were: ;
i i-
., ; *
Sediments (mg/kg):

Arsenic 210 '!'
Cadmium > 3.31 !i
Methyl ethyl ketone 1.7 •;;
Trichloromethane 0.4 i!
NPL Proposed:
NPL Final:
FS:
ROD:
Site History
12/30/82
9/8/83
2/28/91
9/10/91
Background
PRP-lead | :
PRPs: Dover Landfill PRP Group
FS prepared by: JHMM Associates, Inc.
2.
What volume of material is to be remediated?

The volume of material to be remediated included:
'' ' ' .

• 1,300 cubic yards of perimeter drainage sediment
• 3.5 million cubic yards | soil, sludge, and debris in the landfill
3. What type of site is this? ; ' : -

Municipal Landfill. Inactive municipal landfill (accepted some it
industrial waste).
TECHNOLOGY SELECTION ;

4, What standard technologies weitf considered for selection in this FSt
Standard technologies considered during the identification and
technologies were: '•;
Solid Waste

Access restrictions:
Containment:
Chemical treatment:
Physical treatment:

006
Fencing, deed restrictions
Clay and soil capping, single-layer synthetic
.Cement land silicate fixatives, thermoplastic
Mechanical aeration
-i-
)
screenmg of technically feasible
< ap, multi-layer cap
s( lidification
-------
Standard technologies eliminated because of cleanup goals include: ..

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What, measures/criteria we're used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost .
Time to design/construct/operate

16. How are measures compared?

The chosen alternative was preferred because it would achieve remediation goals in the
shortest amount of time (1 to 3 years compared to 18 to 73 years). The selected remedy was
also the least expensive of the alternatives offering containment and ground water treatment.
While the capital costs for the selected remedy were higher due to the construction of a slurry
wall, the operating and management costs were lower due to the reduced treatment time.
' * , ' -
A ground water flow model, MODFLOW, was used to compare the effectiveness of remedial
alternatives RAA-3, RAA-4, RAA^5, and RAA-6.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Although not primary, a shallow water table required components of the remedy to lower the
water table for reduction of leachate mto the groundwater and seeps.
005
-5-- ' ' • •' ' ' ' - . '•
-------
6.
7,
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
' 'l . '
> - " ' - I
Access restriction: Institutional controls (site security, deed restrictions)
Containment: Multilayer cap, slurry wall
Disposal: Excavation
Physical treatment: s , Natural flushing

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
No innovative technologies were considered for remedial action alternatives.
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(pnor to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the three criteria process was eliminated arid the FS went directly
from initial screening to a detailed evaluation. Costs then were estimated during an evaluation
based on the nine criteria established by the NCP. -

No innovative technologies were considered for remedial action alteatives.
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1,3-A
Standard Technology
No action
Minimal action/institutional controls/
deed restrictions/environmental
monitoring
Esltimated Costs
3 Criteria
N/A
N/A
9 Criteria
$0
$1,147,000
002
-2-
-------
Brunswick Naval Air Station
OU-1

Brunswick, Maine
Region 1
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediment (rag/kg)

Mercury 4.7
PAHs 24

Other contaminants at site without
specified concentrations:

Arsenic
Cadmium
Chromium
Cyanide
Lead
Manganese
Mercury
Nickel
Vanadium
Zinc
DDT
PCBs
1,1,2,2 Tetrachloroetharie
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
1987
10/91
6/16/92
Background

Federal Facility
PRPs: U.S. Navy
FS prepared by: B.C. Jordan Co.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 300,000 cubic yards of waste
3. What type of site is this?

Military. A landfill at an active Naval Air Station.

-1-
001
-------
-------
Region/Site Primary Technologies Selected

signet^ - . |°!| ^ ^^ •••;;;;:::::; :•:'1213

vSwaters & Ro^' °' foil vapor extraction
Westinghouse Electric Corp. (Sunnyvale Plant) Incineration... , •••

Region 10

Bangor Ordnance Disposal, OU-1 " Soil washing ........:....... 1241
• Disposal
Bunker Hill Mining & Metallurgical, OU-1 Capping •••••• •• _
Bunker Hill Mining & Metallurgical, OU-2 Capping . • • •
Joseph Forest Products • Unspecified treatment ,;. - * 1260
Umatilla Army Depot (Lagoons), OU-1 Solid-phase biodegradation . 266
Union Pacific Railroad Co. Soil flushing , - - - - • • • V"
Disposal - g
Wyckoff Co./Eagle Harbor, OU-3 Capping . . . . . ... . -
' • • Solidification/stabilization

Yakima Plating Co. DisPosal ••••••••••• ' 129°

Vlll
-------
Region/Site

Mid-America Tanning Co.
People's Natural Gas Co., OU-1
Pester Refinery Co.
Shaw Avenue Dump, OU-1
Region 8

Anaconda Co. Smelter, OU-11
Broderick Wood Products, OU-2

Central City-Clear Creek
Chemical Sales Co., OU-1
Denver Radium Site, OU-8
Denver Radium Site, OU-9
Hill Air Force Base, OU-3
Idaho Pole Co,

Ogden Defense Depot, OU-1
Ogden Defense Depot, OU-3

Ogden Defense Depot, OU-4
Portland Cement (Kiln Dust 2 & 3), OU-2
Rocky Flats Plant (USDOE), OU-2
.Silver Bow Creek/Butte Area, OU-12
Wasatch Chemical Co. (Lot 6)
Region 9

Advanced'Micro Devices, Inc.
Atlas Asbestos Mine, Mine Area OU
FMC (Fresno Plan!:)
Hassayampa Landfill
Indian Bend Wash Area, OUs-1, 4, 5, 6
Iron Mountain Mine, Boulder Creek OU
Jasco Chemical Corp.
Lawrence Livermore Nat. Lab. (USDOE)
Monolithic Memories, OU-1
National Semiconductor Corp., OU-1
Purity Oil Sales, Inc., OU-2
Rhone-Poulenc Inc.(Zoecon) Sandoz, OU-1

Sacramento Army Depot, OU-3
Sacramento Army Depot, OU-4
Primary Technologies Selected , page
i . ' •' ' ' '
In situ solidification/stabilization ........ 1003
Solidification/stabilization
Disposal '
In situ biodegradation I 1Q08
Soil flushing ....... I 1014
In situ biodegradation 1
Disposal , ' . '
In situ solidification/stabilization 1019
:! . '. " '
'i ,
i
\ • "°
! '•'•'•'
Solidification/stabilization . '.'. 1024
Biodegradation .....I ............... 1033
Solidification/stabilization
Capping .. . . .j. . . ..... . . . . .... . 1044
Soil vapor extraction i ............... 1050
Solidification/stabilization 1056
Capping . . (.-:... 1064
Capping 1069
Soil flushing 1 ^ ....... 1073
Land treatment
Disposal , .... .". ... .... . . ..... 1080.
Disposal ... . 1086
Incineration
Disposal ... ......:......... 1092
Solidification/stabilization . ..... 1099
Soil vapor extraction .j HQ5
Solidification/stabilization 1110
In situ vitrification .. j 1117
Land treatment j -. ,

Incineration i 1125
Capping . ... H30
Soil washing ...... .L 1135
Soil vapor extraction .]. 1142
Soil vapor extraction .[ 1149
Capping i. . .... 1155
Solid phase biodegradation ............ 1160
Soil vapor extraction .1 .............. 1166
Soil vapor extraction , 1171
Soil vapor extraction 1179
Soil vapor extraction .!..... 1187
Capping L ............... 1193
Solidification/stabilization
Soil vapor extraction ................ 1199
Soil washing L 1206
Vll
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Region/Site Primary Technologies Selected Page

Peerless Plating Co. Soil vapor extraction 824
Solidification/stabilization
Rasmussen's Dump, OU-1 Capping , , .....:... 831
Savanna Army Depot Activity, OU-1 Incineration ... 836
South Andover Site, OU-2 Disposal 843
Biodegradation
Spickler Landfill, OU-1 Solidification/stabilization .......... 848
Stoughton City Landfill Capping 854
Sturgis Municipal Wells Soil vapor extraction . . . . 859
Disposal ^
Tar Lake, OU-1 Disposal .;....... • • 865
Thermo-Chem, Inc., OU-1 Incineration . . . .:. . . 871
Soil vapor extraction
Torch Lake, OU-1 & OU-3 Capping , ., ............... 877
Disposal ,
Tri-County Landfill Co.AVaste Mgmt. IL Capping 882
Twin Cities AF Reserve Base (SARL) Institutional controls 890
Verona Well Field, OU-2 > Soil vapor extraction 895
Zanesville Well Field • -- Soil vapor extraction . . . 902
Soil washing

Region 6

Cimarron Mining Corp., OU-2 Solidification/stabilization... . . 908
Double Eagle Refinery Co., OU-1 Solidification/stabilization . . 913
Fourth Street Abandoned Refinery, OU-1 Solidification/stabilization 919
Gulf Coast Vacuum Services, OU-1 Incineration . 925
In, situ solidification/stabilization
Gulf Coast Vacuum Services, OU-2 Capping 933
Mosley Road Sanitary Landfill Capping , ; 938
Oklahoma Refining Co. In situ solidification/stabilization . . . 943
i In situ biodegradation
Petro-Chemical Systems, Inc. (TB), OU-2 Soil vapor extraction 951
Capping
Prewitt Abandoned Refinery Disposal 957
Land treatment
Soil vapor extraction

Region 7

29th & Mead GW Contamination, OU-2 Soil vapor extraction ............ .. . .. 966
E.I. Dupont DeNernours & Co. (Road X23) Solidification/stabilization . . ,. . . 972
Disposal
Ellisville Site Incineration ...:.... •. . .' ;..;.. 978
Hastings GW Contamination, OU-10 & OU-2 Capping ............. 983
John Deere (Ottumwa Works Landfill) Institutional controls 988
Lee Chemical Soil flushing 993
Lehigh Portland Cement Co. Capping 998
VI
-------
Region/Site

Oak Ridge Reservation (USDOE), OU-2
Robins AFB (LF #4/Sludge Lagoon), OU-1

Sangamo Weston, Inc./12 Mile Creek, OU-1
Standard Auto Bumper Corp., OU-1
Wrigley Charcoal Plant
Primary Technologies Selected
Capping
In situ solidification/stabilization . .
Soil vapor extraction
,Low temperature thermal desorption
Disposal . '.
Disposal
Incineration
j
Region 5

Acme Solvent Reclaiming (Mor. Plant), OU-2

Allied Chemical & Ironton Coke, OU-2

American Chemical.Service, Inc.
Berlin & Farro
-Buckeye Reclamation, OU-1
Butterworth #2 Landfill
Canrielton Industries, Inc. ;
Carter Industrials, Inc.
Central Illinois Public Service Co.
Chem Central
City Disposal Corp. Landfill
Clare Water Supply, OU-2 ;
Dakhue Sanitary Landfill, OU-1
Electrovoice, OU-1

Fadrowski Drum Disposal ,

Folkertsma Refuse
Fultz Landfill, OU-1
G&H Landfill,.OU-1

H. Brown Co., Inc.
Kentwood Landfill
Kohler Co. Landfill, OU-1
LaGrande Sanitary Landfill
Lemberger Landfill, Inc., OU-1
Main Street Well Field, OU-2
1
Michigan Disposal Service (Cork St. LF)
Motor Wheel, Inc.
Muskego Sanitary Landfill

Pagel's Pit, OU-1
Low temperature thermal desorption
Soil vapor extraction
In situ biodegradation
Incineration
Land treatment
Soil vapor extraction
Low temperature thermal desorption
Solidification/stabilization
Disposal
Solidification/stabilizat on
Capping . . . .-'. . . .
Capping .....'....
Disposal • •
Low temperature them: al desorption
Disposal . .
Soil vapor extraction
Soil vapor extraction
Soil vapor extraction
Capping
Soil vapor extraction
Solidification/stabilization
Unspecified treatment
Capping ,
Capping
Capping
Capping .........
Incineration
Solidification/stabilization
Capping . . I. .
Capping I; .
Solidification/stabilization
Capping
Soil1 vapor extraction
Disposal
Capping ;
Capping
Capping .........
Soil vapor extraction |
Capping . .",|..........;..... 819
649

659

667
676
683
689
695
702
710
715
720
725.
731
735-

744

749
755
761

767
775
780
785
789
795

802
808
813
-------
-ft
Region/Site

Raymark, OU-1
Resin Disposal, OU-1
Rhinehart Tire Fire Dump, OU-2
Saunders Supply Co.

Strasburg Landfill, OU-3
'Tonolli Corp.
Whitmoyer Laboratories, OU-2

Whitmoyer Laboratories, OU-3

Region 4

Agrico Chemical Co., OU-1
Alabama Army Ammunition Plant, OU-1

Arlington Blending & Packaging

Benfield Industries, Inc.
Carolina Transformer Co. .. ,
Carrier Air Conditioning Co.
Charles Macon Lagoon & Drum Storage
Ciba-Geigy Corp. (Mclntosh Plant), OU-2
Ciba-Geigy Corp. (Mclntosh Plant), OU-4
Florida Steel Corp., OU-1
Geigy Chemical Corp. (Aberdeen Plant)
Golden Strip Septic Tank Service
Interstate Lead Co. (ILCO), OU-1

JFD Electronics/Channel Master

Marine Corps Logistics Base, OU-3

Maxey Flats Nuclear Disposal
Medley Farm Drum Dump, OU-1
Primary Technologies Selected
Soil vapor extraction 420
Capping 427
Disposal ...:.... 436
Low temperature thermal desorption 440
Dechlorination
Capping 447
Solidification/stabilization . . . 452
Capping
Disposal
Incineration 462
Solidification/stabilization
Biodegradation ..................... 471
Solidification/stabilization

Solidification/stabilization 481
Incineration 487
Disposal
Low temperature thermal desorption ...... 492
Solidification/stabilization
Soil washing • • 501
Solvent extraction .." 507
Solidification/stabilization
Disposal
Soil vapor extraction . . ...;.... 513
Land treatment 519
Soil vapor extraction
Disposal
Incineration 527
Solidification/stabilization
Soil flushing
Soil vapor extraction
In situ biodegradation
Incineration .- 555
In situ solidification/stabilization
Low temperature thermal desorption1
Soil flushing /
Solidification/stabilization 564
Disposal ..:........ 570
Solidification/stabilization 577
Solidification/stabilization 584
.Capping , ' ' -
Chemical treatment (ex situ) ...... . . . .-, - 589
Solidification/stabilization
Capping . . 594
Disposal
Capping • • • • 602
Soil vapor extraction 609
IV
-------
Region/Site
Primary Technologies Selected
Page
Juncos Landfill, OU-1 Capping ...... ... ........ ......... 192
Kin-Buc Landfill, OU-2 Disposal .......... .....' ...... ..... 197
Mattiace Petrochemical Co., Inc., OU-1 Soil vapor extraction L . . : ............. 202
Nascolite Corp. Disposal ......... 1 ............ ..... 208
Solidification/stabilization
Naval Air Engineering Center, OU-1 Soil flushing . . . ...... ........ ...... 213
Naval Air Engineering Center, OU-2 Soil flushing ..... .[.......... ...... 218
ML Industries, OU-2 Solidification/stabilization ...... ..... ... 223
Pasley Solvents & Chemical, Inc. Soil vapor extraction .......... . ....... 229
Plattsburgh Air Force Base, OU-1 Capping ........ . i . . ..... . . ..... . . 234
Plattsburgh Air Force Base, OU-3 Capping ..... ....[.... . . ........ . . 238
Preferred Plating Corp., OU-2 Solidification/stabilization ....... ....... 242
Ramapo Landfill Capping ........;[.... .......... ... 248
Roebling Steel Co., OU-2 , Disposal ........ !'.... ............ . 253
Solidification/stabilization
Rowe Industries GW Contamination • Disposal ......... , ........ ........ 259
Sinclair Refinery, OU-2 . Capping :• ........ [ ...... .' ........ . . 265
South Jersey Clothing Co. Soil vapor extraction ........... ,".• .... 272
Swope Oil & Chemical Co., OU-2 - Soil vapor extraction ..... ............ 277
Warwick Landfill, OU-1 Capping ...... . . . i ...... ..... ..... 283

Region 3

.Aberdeen Proving Ground (Michaelsville) Capping ......... '.'...:• ........... 288
Abex Corp., OU-1 Solidification/stabilization.... ...... ....293
Arrowhead Associates/Scoville Corp. Soil vapor extraction I ........... ..... 299
Brodhead Creek, OU-1 In situ steam extraction ......... ...... 304
Brown's Battery Breaking, OU-2 Unspecified innovative! technology ........ 310
C &' D Recycling Disposal ......... j ................ 315
' Solidification/stabilization
CryoChem, Inc., OU-3 . Soil vapor extraction .... ' •. ... ....... ...321
Defense General Supply Center, OU-1 " Institutional controls j .............. . 326
Defense General Supply Center, OU-5 Soil vapor extraction j ..... . .......... 333
Dixie Caverns County Landfill, OU-1 Pyrometallurgical reprocessing ....... ... 339
Eastern Diversified Metals, OU-1 & OU-2 Incineration -,...'.. ...... '."... ..... .... 344
Eastern Diversified Metals, OU-3 Recycling/recovery .,!....... ...... ....351
First Piedmont Corp. Rock Quarry (Route 719) Capping . . . . ...... I ...... ....' ....... . 357
, Unspecified treatment j
Halby Chemical Co., OU-1 Solidification/stabilization ..... . ..... ... 362
Hellertown Manufacturing Co. Capping ......... j ........ ...... ... 368
Industrial Lane, OU-2 Capping . . . . . ..... ! . .' ......... ... ; . 374
Letterkenny Army Depot (SE Area), OU-1 Low temperature thermal desorption ...... 379
Lindane Dump Capping ...... . . . .... . ... .... ...'.. . . . 385
Mid- Atlantic Wood Preservers, Inc. Solidification/stabilization . ..... ........ 392
, Capping
Modem Sanitation Landfill Capping . . ...... . j ..... ........... 397
Old City of York Landfill , Capping . . . ... ...-.!'. .......... '.....' 402
Disposal | ' '
Paoli Rail Yard ' . , Solidification/stabilizatiion ..... . . . . .' . ____ 410
-,
.J
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Region/Site

Region 1
Table of Contents

Primary Technologies Selected
Brunswick Naval Air Station, OU-1 Capping ....... 1
Dover Municipal Landfill Capping . ••••-.. 6
Iron Horse Park, OU-2 : Capping ... . . . . 13
Mottolo Pig Farm Soil vapor extraction 18
PSC Resources 1° sit" solidification/stabilization . . . ....... 25
Silresim Chemical Corp. ; Soil vapor extraction .35
Sullivan's Ledge, OU-2 Capping . .,.'. . . . '..... . - • • 44
Union Chemical Co., Inc. Low temperature thermal desorption ....... 50
. Disposal , _ - •

Region 2 ,

A.O. Polymer Soil vapor extraction • - 56 .
Applied Environmental Services Soil vapor extraction . . . . . 62
In situ biodegradation
Asbestos Dump, OU-2 In situ solidification/stabilization -.-.••• 68
C & J Disposal Leasing Co. Dump Disposal . : . 73
Circuitron Corp. - Soil vapor extraction 79
Incineration
Colesville Municipal Landfill Capping ...'... .......: 85
Conklin Dumps Capping . 91
Cosden Chemical Coatings Corp. In situ solidification/stabilization 96
. Disposal . . ,
Curcio Scrap Metal, OU-1 Incineration .....' ., : ... 104
Ellis Property , Incineration ....:... 109
Disposal
Endicott Village Well Field, OU-2 Capping . 116
Facet Enterprises, Inc. ' Disposal ,121
Solidification/stabilization
Fibers Public Supply Wells Disposal . - : • • 127
Capping
Fort Dix (Landfill Site) • Capping 132
Frontera Creek Disposal . . 138,
Garden State Cleaners Co. Soil vapor extraction .............. 143
General Motors (Cen. Foundry Div.), OU-1 Biodegradation > •.. -148
General Motors (Cen. Foundry Div.), OU-2 Biodegradation .........:..-..-. 154
Capping . . . ..
Genzale Plating Co. Soil vapor extraction . - 163
Global Sanitary Landfill, OU-1 Capping 169
Solidification/stabilization
Disposal '
Hertel Landfill Capping .-.,.: .-. .. 174
Industrial Latex Corp., OU-1 Low'temperature thermal desorption ....... 180
Islip Municipal Sanitary Landfill ; Capping . .187
-------
-------
Introduction

This analysis was conducted by the Technology Innovation Office of the Office of Solid Waste and
Emergency Response. The Office of Solid Waste and Emergency Response established the
Technology Innovation Office (TIO) to foster the development and use of innovative technologies for
remediating contaminated sites. Part of TIO's mission is to collect information on the use of
innovative technologies, examine why innovative technologies are not used more frequently, and
remove barriers to their use. Much of the information needed to address these questions may be
contained in RODs and FSs.
i
Abstracts of FSs have been prepared for the following 205 Superfund sites to summarize pertinent
information on why technologies are being selected for site cleanups, why innovative technologies are
eliminated from consideration as remedial technologies, and what conditions at Superfund sites may
affect the selection of innovative technologies for site remediation. The FS abstracts were compiled
from information in source control RODs signed during FY91 and FY92 and their associated FSs.

Source control RODs address the remediation of contaminant sources at Superfund sites, such as soils,
sediments sludges, solid wastes, and other solid (non-aqueous) media. Many of the RODs included in
this analysis also address contaminated groundwater and surface water; however water treatment
technologies have not been examined. This analysis does not include sites where only groundwater
was addressed, where "no action" was selected as the site remedy, and where an interim source control
remedy addressed only the removal of drums or surface debris. Contaminant sources found entirely in
the saturated zone, such as pools of DNAPLs, were not included in the analysis because they generally
are addressed using groundwater treatment methods. In addition, technologies for decontaminating
buildings were not included. , ' ;
-------
Innovative technologies eliminated during the initial screening include the following:

• Landfarming was eliminated because three is insufficient level land at the site and
New York state regulations require that the'bottom of the treatment zone must be
greater than three feet above the seasonal high water table, which is not possible at the
site. Also, the potential of chemicals in the soils to migrate to surface waters is high.
• • Ex situ contained solid-phase aerobic degradation was determined to be technically
infeasible based on land use requirements for treated soil piles.
• Ex situ anaerobic treatment was eliminated because primary contaminants of concern
are most readily biodegradable by aerobic treatment. Anaerobic treatment may only
partially degrade contaminants.
• In situ oxidation was eliminated because complete oxidation of constituents of concern
has not been demonstrated in an in situ process. . ,
• In situ reduction was eliminated because its successful use has been limited to aqueous
solutions and small-scale field plots. Its use on organic constituents has not been well
demonstrated. i
• In situ hydrolysis was eliminated because it is not an effective treatment for the
contaminants of concern at this site.
• Pyrolysis was not appropriate for soils at the site.

Innovative technologies eliminated during the screening of the three Cjriteria include the
following: . . .

• None

Innovative technologies eliminated during the detailed analysis include the following:

• On-site thermal desorption (RAA-3) was eliminated because it involves significant soil
excavation that would expose heavily contaminated soils and 'excavation followed by
thermal treatment is relatively costly. The RAA in which thermal desorption was
included did not provide for treatment of ground-water and saturated soils, relying
instead on natural attenuation of contaminants in these media.} This disadvantage to
the remedial alternative was not related to the effectiveness of the technology but .
contributed to its elimination.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
••'•'• • i
Compliance with ARARs, short-term effectiveness, and cost were the criteria weighted most
heavily in selecting the technology. RAA-1, RAA-3, and RAA-4 would not comply with
ARARs because they would not address contaminants in saturated soiils and groundwater. The
short-term effectiveness of RAA-2 and RAA-3 is low because they involve significant soils
excavation that would expose heavily contaminated soils. 'The cost o:
the selected remedial alternative. .
RAA-5 is twice that of
-4-
065
-------
12. Wha( cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? >
Contaminant'
Cleanup Level (ppb)
ARAR or Other Basis
Carcinogens
Benzene
Methylene Chloride
665
222
Risk
Risk
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to W6
was acceptable.
13.
Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was selected, could the it meet the cleanup goals?

Innovative technologies that were eliminated during the initial screening process because they
could not meet cleanup goals included ex situ anaerobic treatment, in situ oxidation, in situ
reduction, and in situ hydrolysis. The selected innovative remedies, in situ bioremediation of
groundwater and saturated soils and soil venting of unsaturated soils were expected -to meet
cleanup goals.
. . • / .
14. Were treatability studies conducted on the innovative technology or standard technology?

An in situ soil vapor extraction pilot test and a bench-scale biotreatability test were conducted
for this site. The soil vapor extraction pilot test showed that levels of volatile organic
compounds in the soil within the test area were reduced dramatically in the first 5 weeks of
operation. The biotreatability study showed that indigenous bacteria caused the loss of target
compounds and that the potential for bioremediation on the site appeared excellent for
saturated soils. However, the bacteria were not as effective for unsaturated soils.
)
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Waste left in place
Time to remediate
Cost
Permanence
Community impacts
16. How are alternatives compared?

RAA-1, RAA-3, and RAA-4 would leave significant quantities of groundwater contaminants in
place and would rely on natural attenuation processes that would take many years to be
effective. RAA-3 also involves significant soil excavations that would expose heavily ,
contaminated soils. Although RAA-2 would achieve the highest degree of protection,
066
-5-
-------
disadvantages include its extremely high cost, soil excavations that would expose heavily
contaminated soils, and implementation difficulties caused by the needs to install a large water
treatment system, maintain a constant water drawdown over a long period of time, overcome
offVsite incinerator capacity limitations, minimize fugitive emissions, and regulate a high
volume of truck traffic. RAA-5 and RAA-6 would minimize impacts ^p the community and
likely achieve similar levels of remediation but differ significantly in cost due to the more
aggressive dewatering approach of RAA-5.
17. What technical considerations were factors in selecting a remedy? Wf re technical
considerations primary in the selection of the remedy?

The site is part of a small peninsula on the east shore of Hempstead Harbor, with mudflats
(designated as tidal wetlands) around the site and a shallow water table. The upward
groundwater flow at the site prevents surface contaminants from migrating to deeper portions
of the aquifer. Infiltration of rainfall and tidal fluctuations allow for the continued
mobilization of organic chemicals from the soil to the groundwater arijd surrounding surface
water. The shallow water table would make dewatering costly and difficult to maintain, which
contributed to the elimination of RAA-5 (drawdown and soil venting);! The contaminated
mudflat sediments made indirect remediation (eliminating source of contaminants in soils)
preferable due to potential for habitat disruption during active remediation. Technical
considerations could not be considered primary in the selection of the remedy at this site.
-6-
067
-------
Asbestos Dump
OU-2

Morris County, New Jersey
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface Soil (mg/kg)

Asbestos 300,000
2.
What volume of material is to be
remediated?

The volume of material to be remediated
, included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/1/83
6/7/91
9/27/91
Background

EPA Fund-lead
PRPs: National Gypsum Company
FS prepared by: Alliance Technologies
Corporation
« 37,000 cubic yards of asbestos-containing soil

3. Wtiat type of site is this?

Industrial Landfill. An asbestos dump. :

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ' ° . J. •31L'1C

Containment: Clay cap, soil/vegetation cap, asphalt cap, concrete cap >
multimedia cap -
Physical/Chemical treatment: In situ and ex situ cement-based solidification, pozzolanic
_ , solidification, thermoplastic solidification '
Thermal treatment: Incineration ; ;
DisP°sal: Off-site landfill, on-site landfill ;
OG8
-1-
-------
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: | ,
Biological treatment:
Thermal treatment:
In situ biodegradation, ex situ biodegradation
In situ vitrification, ex situ vitrification, pyrolysis
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
-2-
Alternative
RAA-1
RAA-2
RAA-4
RAA-5
Standard Technology
No action
Soil/vegetative cap
In situ cement-based stabilization/
solidification ,
Excavation/off-site landfill disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$0
$1,700,000
$5,700,000
$16,000,000
069
-------
8. If a standard technology was chosen, why? ___

The selected remedy, RAA-4, includes treatment of all materials containing greater than 0.5% " ^
asbestos by^an in situ cement-based stabilization/solidification process. It was selected because
it would provide a high degree of protection and attain cleanup levels without excavation of
waste materials, with some limited short-term risks due to fugitive dust emissions caused by
disturbance of surface and subsurface contaminated materials. Excavation is particularly a
problem at this site because of the risk of creating airborne asbestos concentrations. Although
capping would create less risk of airborne asbestos, in situ stabilization/solidification provides
a much higher degree of long-term effectiveness. '

9. If an innovative technology was chosen, why?
f
.
An innovative technology was not chosen. - -
' •'•;••'•:.• • .
• . ; ' '
10. If an innovative technology was not chosen, why not? At what stage was the innpvative
technology eliminated? , -

Innovative technologies eliminated during the initial screening include: ,
.' .-" ,' - '•'•-.' • • ' . ' '
• In situ vitrification was eliminated because it would not be effective for treating
shallow depths of waste due to heat loss at surface.
» Ex situ biodegradation was eliminated because it was considered not applicable to
asbestos-containing material. No other explanation was given. : i
• In situ biodegradation was eliminated because it was considered not applicable to
asbestos-containing material. No other explanation was given.

No innovative technologies were eliminated during the three-criteria screening process

Innovative technologies eliminated during the detailed analysis include:

• Ex situ vitrification (RAA-3) was eliminated because of the high short-term risk
created by the excavation of asbestos and the high cost of vitrification in comparison
to the selected alternative. '

11. Which of the nine criteria were weighted most heavily in selecting the technology? Did one of
the nine criteria eliminate the innovative technology from being chosen? If so, which one?
Which of the criteria supported the use of a standard technology?

In comparing alternatives that were protective of health and me environment and met all
ARARs, long-term effectiveness and permanence, short-term effectiveness, and cost became
the decision-making criteria. The chosen RAA offered reasonable long-term effectiveness and dj^ "^ r
permanence while minimizing short-term risk and cost. " ^^r *

070 :3.
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that.
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level
ARAR<
Carcinogens
Asbestos
0.5 percent

Transmission Electron Microscopy (TEM) detection limit. T
sensitive method available for measuring asbestos.
>r Other Basis

IBM",

IB TEM is the most
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index (HI) less than ojr equal to 1.0 was
acceptable. , j
13. Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was chosen, could it meet the cleanup goals? \
. • i ' '
No innovative technologies were eliminated because of cleanup goals. The selected standard
technology could meet cleanup goals. I
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare'the alternatives:

Cost effectiveness
•-" Permanence
Preference for treatment
- ' Creation of short-term risk (airborne asbestos)
Need for continuing maintenance
Implementability
Time to complete remediation
16. How are alternatives compared?

Disadvantages of RAA-3 and RAA-5 compared to the selected
cost of implementation, high short-term risk of creating airborne
difficulty of implementing in a wetland environment. A further
that it would not treat contaminants. The selected alternative was
^effective than RAA-2 because it provides a much higher degree of
and permanence due to difficulties of constructing and maintaining a
environment. Time to complete remediation ranged from six months
-4-
alternative included their high
asbestos concentrations, and
disadvantage of RAA-5 was
considered more cost-
long-term protectiveness
cap in a wetland
for capping (RAA-2) to
071
-------
ten months for stabilization/solidification (RAA-4) and did not appear to affect remedy
selection. " ' '"
i: '•—** •

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? !

The site is located in a swamp and in a 100-year flood plain. Site location played a role in the
remedy selection process since erosion and soil movement in a wetlands environment would
continually contribute to degradation of the cap. Further, the shallow water table would
increase the difficulty of excavation required for vitrification and off-site disposal. The nature
of the contaminant (asbestos) and its location in the surface soil caused great concern about the
production of fugitive dust during the implementation of several alternatives (particularly
RAA-3 and RAA-5). Technical considerations could be considered primary in the selection of
the remedy. -'.-.'
072
-5-
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C&J Disposal Leasing Co. Dump
OU-1
r
Eaton, New York
Region 2
*
NPL Proposed:
NPL Final:
FS:
ROD:
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were: ,

Soil (mg/kg)

Bis(2-ethylhexyl)phthalate 29,000
r Di7n-octyl phthalate , 220
Di-n-butyl phthalate 110
Butyl benzyl phthalate 19
4-Methylphenol . - 17
2,4-Dimethylphenol 0.210
Benzene 6
Ethylbenzene 190
Toluene 650
Xylenes 560
4-Methyl-2-pentanone 1,100
2-Butanone 250
1,2-Dichloroethane 8
Trichloroethene 3
Lead 637
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 1,250 cubic yards of contaminated soil and debris

3. What type of site is this?

Industrial Landfill. Former industrial waste disposal area.
Site IHistory
1986
3/89
1/91
3/29/91
Background
EPA Fund-lead
PRPs: Occidental Petroleum, C&J
Leasing, Biirge Company, Charles
Picariello, James Picariello
FS prepared by: Elsasco Services
Incorporated
073
-i-
-------
TECHNOLOGY SELECTION
4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: • -
Containment:

Physical treatment:
Thermal treatment:

Disposal:
Synthetic membrane cap, single-layer cap, multi-media cap, slurry
wall, sheet piles, grout curtains, bottom sealing, vitrified wall barrier
On-site or in situ stabilization/solidification :
Rotary kiln incinerator, on-site fluidized.bed1 incinerator, on-site
infrared treatment, off-site thermal treatment (incineration)
Excavation, on-site landfill, on-site RCRA vault, off-site TSD facility
5.
Was an innovative technology considered in the FS? If so, which technology? , '

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ bioremediation, on-site slurry bioreactor, on-site leach bed, on-
site composting
Phys/Chem treatment: In situ soil washing (soil flushing), on-site soil washing, > situ
oxidation, in situ vacuum extraction
Thermal treatment: In situ steam extraction, on-site low temperature thermal stripping, on-
site high temperature thermal stripping, in situ vitrification, on-site
vitrification
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) ;
Alternative
Innovative Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-6
Ground water monitoring/dewatering/in
situ vitrification/backfill
$1,551,800
$1,551,800
074
-2-
-------
7. How did the cost(s)s compare to standard technologies? . ;

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is IE bold) t
Alternative
RAA-1
RAA-2 s
RAA-3
RAA-4
RAA-5
Standard Technology
No action; ground water monitoring
Land use restrictions/deed restrictions/
ground water monitoring
Ground water monitoring/dewatering
wells/multimedia cap
Ground water moiutoring/dewatering/
excavation and backfill/off-site treatment
and disposal
Ground water monitoring/dewatering/
excavation and backfill/off-site thermal
treatment and disposal .
Estimated Costs
3 Criteria
$528,5100
$558,000
$712,500
$672,400
$1,219,500
9 Criteria
$528,500
$558,500
$712,500
$672,400
$1,219,500
8. If a standard technology was chosen, why? [

The selected alternative,'RAA-4, includes off-site treatment and disposal. It will eliminate
potential for cross-media impacts, provide permanent remediation of jhe site, be easy to
implement, require groundwater monitoring at the site for only one year, and be less costly
than off-site thermal treatment and in situ vitrification. No action (RAA-1) and land use
restrictions (RAA-2) would not prevent contaminant migration from the site. Capping (RAA-
3) would require installation of a permanent dewatering system that may adversely impact
nearby agriculture and wetlands, In situ vitrification (RAA-6) would require 30 years of i
monitoring at the site and would not be as effective in reducing contaminant toxicity, mobility,
and volume. [
9. If an innovative technology was chosen, why?

An innovative technology was mot chosen.
10. If an innovative technology was not' chosen, why not? At what stage was the innovative
technology eliminated? I

Vitrified wall barriers were eliminated because there was no underlying confining,

• In situ soil washing (soil flushing) would be ineffective because the principal
^ contaminants, phthlates, are bound in a "solid plastic matrix" and are not leachable.
i»o^^ f, *u Vj i • "" "•*-f""'<"«»ics present are not iiiKely to be
leached from the solid plastic waste material and the VOCs are incorporated in die
waste matrix and not the soil. '
site ^ VaCUUm} extractlon was eKminated because the majority of contaminants at the

• In situ steam extraction was eliminated because the majority of the waste matrix is
solid plastic residue containing phthlates, which will not be removed by this method
On-stte low temperature thermal stripping was eliminated because the majority of the
waste matrix is solid plastic residue containing phthlates, which will not be removed
oy tnis method. . .
• On-site high temperature thermal stripping was eliminated because process
temperatures are not high enough to destroy the plastic residue in which thd VOCs are
incorporated. - ' :
" ?n'f6 c°™PostinZ was eliminated because the plastic waste matrix will not be readily
Biodegradable. - •'•;••'
• In situ bioremediation was eliminated because the majority of contaminants: are
incorporated in a plastic waste matrix that is not expected to be fully biodegradable
On-stte slurry bioreactors were eliminated because the contaminants are incorporated
in a plastic waste matrix that is not expected to be readily available for biodegradation
On-site leach beds were eliminated because the majority of contaminants are
incorporated in a plastic waste matrix that is not expected to be fully biodegradable
On-site vitrification was eliminated because insufficient quantities of waste exist to '
justify transporting and erecting an on-site plant.
" Inr.?" ?xidation was eliminated because it would not be effective in destroying the
solid plastic waste matrix where VOCs and SVOCs are bound.

No innovative technologies were eliminated during the three-criteria screening process.

Innovative technologies eliminated during the detailed analysis include:

• In situ vitrification (RAA-6) was eliminated because it. would require 30 years of
monitoring at the site, would only reduce contaminant mobility and volume, and would
be more difficult to implement and much more expensive than the selected remedy:

11. Which of the nine criteria were weighted most heavily in selecting the technology? Did one of
ml n™e™tena ell™™te the innovative technology from being chosen? If so, which one?
Whicfi of the criteria supported the use of a standard technology?

Implementability and cost-effectiveness were weighted most heavily is selecting a remedy.
The se ected remedy would be easier to implement than all of the alternatives but RAA-5
ine selected remedy would be more cost-effective than RAA-5. ' '
076
-4-
„, I
-------
12. What cleanup goals were selected? If the cleanup goal was based on Ian ARAR, what was that
'ARAR? What risk level was selected to establish cleanup goals? j

There are no chemical-specific ARARs provided for soil. Cleanup criteria were based on
background levels found in off-site and native soil samples. No specific levels were provided
intheFS or ROD. j

For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For non-carcinogens a Hazard Index (HI) less than oj-equal to 1.0 was
acceptable. ' - i "

The cumulative upper bound risk at the site was estimated to be 2 x Ip"4. The risks for •
carcinogens at the site are at the high end of the acceptable EPA risk range. The estimated HI
for non-carcinogenic effects from dermal contact is 4 and, therefore, greater than the level
accepted by EPA. v

13 Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was chose, could it meet the cleanup goals? -'

A number of innovative technologies were eliminated because they were not considered
suitable for treating the plastic waste matrices found at the site. No innovative technologies
that were considered suitable for the waste type present were eliminated because of cleanup
goals. The selected standard technology, off-site treatment and disposal, could meet the site
cleanup goals.
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost effectiveness
- Waste left in place
Impact on nearby populations
Need for long-term monitoring
Trench dewatering model
16. How are alternatives compared?
lace
The RAAs were compared primarily on the basis of waste left in pi;
Because wastes were under the shallow water table and wetlands were
wastes left in place without treatment (capping, institutional controls)
human health and the environment. A trench dewatering model was
amount of drawdown required to keep the wastes out of the groundwiati
wastes would be left in place (in situ vitrification), long periods of monitoring
-5-
aiid cost effectiveness.
adjacent to the site,
would pose a threat to
used to determine the
:er. Where treated
would be
077
-------
required. For those alternatives that removed waste from the site, cost effectiveness^
d-nermined which alternative was selected. ,
..-•'• : „ . ' • , • .

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
^^ ' , i
The site lies about 100 feet from a regulated freshwater wetland, which feeds into a pond used
as a backup source of potable water for a nearby village. The water table is very shallow and
wastes found at the site lie within the groundwater. There is no underlying confining layer so
that neither a slurry wall nor a vitrified wall barrier were possible. Since the water table is
above the waste, bottom sealing was not feasible. Because of the high water table and the
adjacent wetlands, permanent dewatering required for installation of a cap was not considered
desirable. In addition, the presence of the high water table required that wastes either be
removed from the site or that monitoring be conducted for a period of 30 years. Technical
considerations can be considered primary in the selection of the remedy at this site.
3
073
-6-
-------
Circuitron Corporation
OU-1

East Farmingdale, New York
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface Sediments/Soil (mg/kg):

1,1-Dichloroethene '0.005
Trichloroethene 0.009
1,1,1-Trichloroethane 100
Tetrachloroethene 0.1
; Bis(2-ethylhexyl)phthalate .20
Copper ; 485

Subsurface Sediments/Soil (mg/kg):
1,1 -Dichloroethane
1,1,1 -Trichloroethane
Benzene
Tetrachloroethene
Cadmiunr
Copper
Mercury
0.065
1.5
0.008
0.021
2.8
23.900
6.6
Site
History
NPL Proposed: 6/88
NPL Final: 3/89 |
FS: 1/91 ;
ROD: 3/91 |
Background
EPA Fund-lead ;
PRPs: Circuitron Corporation, 82 Milbar
Corporation, ADI Electronics
FS prepared by: Ebasco Services, Inc.
What volume of material is to be remediated?
\ -- - - .
The volume of material to be remediated included:

• 48 cubic yards of sediment
• 370 cubic yards of soil
What type of site is this? ,

Electrical Equipment. Electronic circuit board manufacturing facility
-1-
079
-------
TECHNOLOGY SELECTION !

4. What standard technologies were considered for selection in this FS? '

Standard technologies considered during the identification and screening of technically feasible
technologies were: • ' •,

Containment: Capping, subsurface barriers
Physical treatment: Stabilization, thermoplastic solidification '
Thermal treatment: Rotary kiln incineration, infrared treatment, fluidized bed incineration
Disposal: On-site disposal, off-site disposal at RCRA facility j
5. Was an innovative technology considered in the FS? If so, which technology? \

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Chemical treatment: Supercritical fluid extraction, in situ hydrolysis, soil washing with
water/solvent I
Biological treatment: In situ biodegradation '
Thermal treatment: In situ vitrification, enhanced volatilization ' ':'
Physical treatment: In situ soil flushing with water, vacuum extraction ;

6. What was the cost estimate for the innovative technology? '

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) ;
Alternative
RAA-4
RAA-5
========
=================
Innovative Technology
In situ vacuum extraction/excavation of
sediments/on-site stabilization and
disposal/site containment
In situ vacuum extraction/excavation of
contaminated sediments/off-site
incineration and disposal/site
containment
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$$73,945
$685,675
i ]
080
-2-
-------
7. How did the cost(s) compare to standard technologies? \
;'•*'' • • ' ' ' 'I
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
8.
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
Long-term monitoring/public education
Long-term monitoring/public education/
access restrictions
Long-term monitoring/repaving the site/
decontaminating the building/diversion of
storm precipitation runoff

Estimated Costs
3 Criteria
N/A

If a standard technology was chosen, why?
N/A
N/A
9 Criteria
$380,160
$412,150
$656,695
•
Off-site incineration was included in the remedy.
9. If an innovative technology was chosen, why? j .. .

RAA-5 was chosen-because it provides source control measures that ivould prevent further
migration of contaminants into groundwater, reduces toxicity and mobility of contaminants,
satisfies the preference for treatment, provides a permanent solution, and is cost-effective
RAA-1 and RAA-2 (natural attenuation) would not provide for a long-term solution. RAA-3
(capping) would require long-term monitoring and maintenance to ensure its effectiveness, also
fluctuations in the water table may cause additional leaching of contaminants into groundwater.
Although RAA-4 (stabilization of sediments) is slightly less costly than the selected remedy, it
is slightly less short- and long-term effective, permanent, and implernientable.

1 , . • i ' '• • . •
10. If an innovative technology was not chosen, why? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the; three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. The preferred
alternative in the Proposed Plan was RAA-5, which also was selected by the ROD.

Innovative technologies eliminated during the initial screening include:

• Soil washing was eliminated because the mixtures of contaminants at the site (volatile
organics, semi-volatile organics, and metals) make the development of a washing
solution very difficult. The technology was considered infezisible because an excessive
amount of washing fluid would be necessary due to the variisd partition coefficients of
the contaminants at the site and large amounts of wastewater would be produced.
081
-3-
-------
• Supercritical fluid extraction was eliminated because of uncertainties in its
performance in treating volatile organics and metals.
• In situ soil flushing was eliminated because of the need for vertical groundwater
barriers that must be supported by a clay layer. Since no clay layer exists to support a
slurry wall, implementation of this technology could enhance the spread of i '
contamination into the aquifer.
• In situ biodegradation was eliminated because the chlorinated compounds at 'this site
would require anaerobic treatment, and this technology was considered uncertain. It
was noted that metal concentrations might inhibit anaerobic degradation. Moreover,
the infiltration of microbes into the aquifer was of concern. , !
• In situ hydrolysis was considered an unproven technology for Superfund sites. It also
was considered infeasible because the site has no confining bottom layer and1 because
it cannot remediate VOCs and semi-volatiles. '
« In situ vitrification was eliminated because it requires an exorbitant amount of
electricity, which makes it very costly. This technique also requires auxiliary
equipment and space that is not available at the site. Finally, the presence of buried
objects, such as the buried barrels and tanks at the site, would make implementation of
this technology very difficult.
• Enhanced volatilization was eliminated because treated sediments would require
additional treatment to control metals.

The three-criteria screening was not performed because only five RAAs were developed.

No innovative technologies were eliminated during detailed analysis. Although RAA-4
included SVE and this alternative was, eliminated, SVE is also included in the selected
alternative. .
Which of the nine criteria were weighted highest in selection of the technology? Did one of
the nine criteria eliminate the innovative technology from being chosen? If so, which one?
Which of the criteria supported the use of a standard technology?

The highest weighted criteria, were protection of human health and the environment and long-
term effectiveness and permanence, and public acceptance. Only two RAAs provided adequate
protection to human health and the environment and permanence. Of these two, the selected
alternative was preferred by the public. '
12. What clean-up goals were selected? If the clean-up goal was based on an ARAR, what
that ARAR? What risk level was selected to establish clean-up goals?

Soil and sediment performance goals were based on leachability modeling.
was
082
Contaminant
Carcinogens:
1 , 1 -Dichloroethane
Tetrachloroethene
Trichloroethene
Clean-up Level (ppb)

5
5
5
ARAR or Other Basis

MCL :
MCL . ;
MCL • •
-4-
-------
Contaminant
Benzene
Non-Carcinogens:
1,1-Dichloroethene
1,1,1 -Trichlofoethane
Copper
Cadmium
Mercury
Bis(2-ethylhexyl)
phthalate
Clean-up Level (ppb)
1,300
10
4.2
ARAR or Other Basis
MCL
MCL
MCL
MCL'
MCL
MCL
MCL
For carcinogens an excess upper bound individual lifetime cancer risk of between W4 to 10'6
was acceptable. For non-carcinogens a Hazard Index less than or equal to 1.0 was acceptable.
13. Was the innovative technology eliminated because of the clean-up go:als? If a standard
technology was chosen, could it meet the clean-up goals? | . .

Innovative technologies that were eliminated because of clean-up goals include in situ
biodegradatioh. The components of the selected remedy that are standard technologies
(excavation and off-site treatment and disposal) could meet clean-up goals.

14. Were treatability studies conducted on the innovative technology or standard technology?
' • • 7 '.'•.•.
No treatability studies were performed.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Permanence
Preference for treatment
Waste left in place
16. How are alternatives compared?

RAAs that would not provide a permanent solution and leave untreated waste in place were
eliminated. The deciding factor in selection of RAA-5 over RAA-41J which both met the above
criteria, was acceptance by the public of RAA^5.
083
-5-
-------
17. What technical considerations had to be considered in the selection of a remedy? Y/ere
technical considerations primary in the selection of the remedy? ^^ V
• ' -—>r
. . ,i-
The site is one acre of flat land in an industrial/commercial land-use area located about 90 feet
above sea level. The site lacks- .1 clay layer between the bedrock and the aquifer, which !.
resulted in the elimination of all remedial technologies that required the use of a vertical
barrier. Sandy soils underlying the site are suited ideally for the use of SVE. Although these
technical considerations affected the selection of a remedial technology, alternatives'•• were •• . !
available and technical considerations could not be judged as primary in the selection of a !'
remedy. ! |
084
-6-
-------
Colesville Municipal Landfill
OUrl

Colesville, New York
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil

Using magneto-meter survey technology,
trbnches of industrial waste were located.
No "hot spots" of contamination were
identified, however, and no sampling and
analysis of potentially contaminated media
were conducted.
Site; History
NPL Proposed:
NPL Final:
FS:
ROD:
10/84
6/86
12/90
3/29/91
Background
i . ' • -
PRP-lead j .
PRPs: Broome County Department of
Public Works, GAF Corporation
FS prepared by: \^ehran-New York,
Inc.
2. What volume of material is to be
remediated?

The volume of material to be remediated included:

• 468,000 cubic yards of waste

3. What type of site'is this?

Municipal Landfill. A former municipal and industrial landfill.

TECHNOLOGY SELECTION '

4. What standard technologies were considered for selection in this FS? •

Standard technologies considered during the identification and screening of technically feasible
technologies were:
... - •' '_ j .:•
Containment: Synthetic membrane'cap, single-layer capr multimedia cap, slurry wall,
sheet piles, grout curtains, bottom sealing, vitrified wall barrier
Physical treatment: Stabilization/solidification ;
Thermal treatment: On-site incineration (rotary kilri, fluidized bed, infrared), off-site
commercial incineration
085
-------
Disposal:
On-site RGRA vault, off-site disposal to TSDF
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: /

Phys/Chem treatment: In situ soil washing (solvent), on-site soil washing (solvent), in situ
chemical oxidation, in situ vacuum extraction
Thermal treatment: In situ steam extraction, on-site low temperature thermal stripping, on-
site high temperature thermal stripping, in situ vitrification, on-site
vitrification
Biological treatment: In situ bioremediation, on-site slurry reactor, on-site leach bed, on-site
composting j'

6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) i
Innovative Technology
Landfill excavation/on-site vitrification
Estimated Costs
3 Criteria
$101,790,000
9 Criteria
eliminated
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action/monitoring program
No further action/existing residential
well monitoring/water supply program
Estimated Costs:
3 Criteria
$128,000
$236,000
9 Criteria
$128,000
eliminated
036
-2-
-------
Alternative
RAA-3A
RAA-3B
RAA-4A1
RAA-4A2
RAA-4B1
RAA-4B2
RAA-4C1
RAA-4C2
RAA-4D1
RAA-4D2
RAA-4E1
• . . , ;
Standard Technology
Existing residential well monitoring/
upgraded water supply system/deed
restrictions/purchase of affected
residences
New water supply to affected
residences/well monitoring
Landfill cap/natural recovery of glacial
outwash aquifer/upgrade water supply
Landfill cap/natural recovery of glacial
outwash aquifer/new water supply
Downgradient pumping/landfill cap/
ground water treatment/surface water
discharge/upgraded water supply
Downgradient pumping/landfill cap/
ground water treatment/surface water
discharge/new water supply
Pumping at landfill and down gradient/
landfill cap/ground water treatment/
surface water discharge/upgraded water
supply
Pumping at landfill and down
gradient/landfill cap/ground water
treatment/surface water discharge/
new water supply
Downgradient cutoff/landfill cap/ground
water collection/ground water treatment/
surface water discharge/ natural
recovery of glacial outwash outside of
cutoff/new water supply
Downgradient cutoff/landfill cap/
ground water collection/ground water
treatment/surface water discharge/
additional pumping outside of cutoff/
upgrade water supply
Complete ground water cutoff/landfill
cap/ground water collection/ground
water treatment/surface water discharge/
natural recovery outside complete
cutoff/new water supply
Estimated Costs
3 Criteria
$679,000
(plus
residential
purchases)
$650,000
$5,550,090
$5,530,000
$5,593,000
$5,647,000
$5,043,000
$5,136,000
$10,9179,000
$11,227,000
$18,«>42,000
9 Criteria
$672,000
(plus
residential
purchases)
$648,000
eliminated
eliminated
$5,595,000
$5,646,000
$5,044,000
$5,135,000
$10,977,000
$11,230,000
eliminated
.' ' •'- ' :' .^ ' •"'.'-• '' .< '. (
j 1 i ' '
037
-------
Alternative
RAA-4E2
RAA-5A
RAA-5C
RAA-5D
Standard Technology
Complete ground water jputoff/landfill
cap/ground water collection/ground
water treatment/surface water discharge/
additional pumping outside complete
cutoff/upgrade water supply
Landfill excavation/on-site stabilization
and solidification
Landfill excavation/off-site treatment
and disposal
Landfill excavation/on-site incineration
Estimated Costs
3 Criteria
$18,766,000
$70,200,000
$297,180,000
$474,084,000
9 Criteria
eliminated
eliminated
eliminated
• • i
eliminated
8. If a standard technology was chosen, why?

The selected alternative includes a landfill cap; pumping at the landfill and downgradient.
This remedy was selected because: 1) the size of^the landfill and the fact that there are not
identified on-site "hot spots" that represent the major sources of contamination, preclude any
remedial response actions in which the landfilled material could be excavated and treated, 2)
cap and leachate collection system will eliminate direct contact, and 3) least expensive of all
the alternatives. '
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? • ;

Innovative technologies eliminated during the initial screening include the following: \

• In situ soil washing was eliminated because the entire mass of waste would need to be
treated to extract a relatively small mass of VOCs.
• On-site soil flushing was eliminated for the same reasons as in situ soil washing.
• In situ vacuum extraction was eliminated because the entire mass of waste would have
to be treated to extract a relatively small mass of VOCs. "•
• In situ steam extraction was eliminated for the same reason as vacuum extraction.
• On-site low temperature thermal stripping was eliminated for the same reason as
vacuum extraction.
038

-4-
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On-site high temperature thermal stripping was eliminated for the same reason as
vacuum extraction.
In situ bioremediation was eliminated because it would require a
lot of oxygen to
create aerobic conditions in the anaerobic landfill, and the entire mass would need to
be treated to extract a relatively small mass of VOCs.
• On-site slurry reactors were eliminated for the same reasons as in site bioremediation.
• On-site leach beds were eliminated for the same reasons as in situ bioremediation.
• In situ vitrification was eliminated because it would be effective Only to a depth of 35
feet, and the site's contaminants were deeper.
• On site composting was eliminated because VOCs would be released from the
mechanical aeration and a large amount of waste would need to be excavated in order
to eliminate a relatively small amount of VOCs. ,

Innovative technologies eliminated during the screening of the three criteria1 include the
following: i

• On -site vitrification was eliminated because its effectiveness was (uncertain.
Furthermore, implementation would be problematic, requiring the: excavation of
municipal waste containing bulky materials that might need to be; decontaminated.

Innovative technologies eliminated during the detailed analysis include the following:

• '' None . ' ' • i . . '

• ;. • '. . " ••..- . ' ••' '. " • |v •:•• . •'.: '.
1. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to me$t one of the nine criteria result in the elimination of the innovative^ technology? If so,
which criterion ? Which of the criteria supported the use of a standard technology?

Three alternatives were deemed equal in protectiveness of human health zind the environment
and in compliance with ARARs, but superior to all other alternatives with respect to their
long-term effectiveness. The, deciding factor among these three were cost-effectiveness and the
time required to attain ARARs. The alternative that attained ARARs fastest and was the most
cost-effective was chosen. i
- - , , •(• ,
i . ' ',
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? \

No chemical-specific ARARs for soil were available. Clean-up goals were established only for
groundwater clean-up. The remedial action objective is to eliminate direct contact with the
waste, the site's leachate seeps and any associated leachate discharges into streams to prevent
further sediment contamination. Because the increased health risk associated with direct
contact of existing sediments is within the acceptable range, remediation of existing sediments
is not necessary. ' r :

For carcinogens, an excess upper bound individual lifetime cancer risk Of between KX4 to 10'6
was acceptable. For noncarcinogens, a Hazard Index less than or equal tcj 1.0 was acceptable.

Since the landfill contains RCRA-listed hazardous waste, regulations specified in NYCRR Part
360 (New York Code of Rules and Regulations) apply to the installation of a multimedia cap.

-5 039
-------
Based on the landfill's size and the fact that no "hot spots" could be identified, remedial
response actions to excavate and treat landfill material are precluded.
13. Was the innovative technology eliminated because of the cleanup goals? Could the
established technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None '
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. It was noted that stabilization/solidification and on-site
vitrification would require treatability studies to determine their effectiveness.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Total cost
Cost-effectiveness
Time to design/construct/operate
16. How are measures compared? •}.'-.

The chosen alternative attains an acceptable risk level (2 x 10's) within the shortest time period
(3 years). One other alternative (RAA-4B2) would attain comparable risk levels in a timely
manner, but would be less cost-effective. Several alternatives (RAA-4D1, RAA-4D2, RAA-
4E1, and RAA-4E2) were eliminated because they would cost too much. The chosen
alternative also had the shortest ,time for operation, Implementation of the selected technology
would remediate the site to ARAR levels approximately two to five times faster than other
proposed alternatives. A ground water flow and contaminant transport model was us|ed to
estimate contaminant transport and to compare the estimated time to reach ARARs and the
decline in risk achieved between alternatives. ;
i
17. What technical considerations were factors in selecting a remedy? Were technical i
considerations primary in the selection of the remedy? '

The nature,of the landfill waste was a primary factor in the choice of a remedial.alternative.
The contaminants of concern were VOCs and the landfill contained an undetermined j amount
of bulky and oversized waste. There was an emphasis towards the elimination of remedies
that required the excavation of waste since VOCs would be released and segregation :of the
waste would be extremely difficult. .
030
-6-
-------
Conklin Dumps
OU-1

Conklin, New York
Region 2
GENERAL SITE INFORMATION
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Ground water, not soils, was tested for
contaminant levels. Chloroethane, observed
in groundwater at 68 ppb, was the
contaminant of concern at the site.
What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
Background
PRP-lead
PRPs: Town of Co;nklin
FS prepared by: O'
Brien and Gere
71,900 cubic yards of upper landfill ,
over an :area of 5.5 acres
32,500 cubic yards of lower landfill over an area of 2.5 acres
3.. What type of site is this?

Municipal Landfill. Inactive municipal landfill.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Disposal:
Deed restriction, fencing
Asphalt cap, concrete cap, clay cap, multimedia cap
Consolidation into one landfill, excavation, off-site landfilling
5. Was an innovative technology considered in the FS? If so, which tecf nology't

No innovative technologies were considered in the FS.
-1-
6/86
3/30/89
1/91
3/29/91
091
-------

6. What was the cost estimate for the innovative technology? '
; • ; •• • i •
No innovative technologies were included in remedial action alternatives, and therefore, no
costs were estimated. ;
7. How did the cost(s) compare to standard technologies? i

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs' have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on the nine criteria established
by the NCR . :
- ! "
Cost Estimates for RAAs That Include Established Technologies \
(selected remedial alternative is in bold) i
Alternative
RAA-1
RAA-2A
RAA-2B
RAA-2C
RAA-2D
RAA-3
RAA-4
Established Technology
No action/long-term monitoring
Long-term ground water monitoring/
fencing/deed restriction/multimedia cap at
both landfills/enhanced leachate collection
with extraction wells/on-site treatment with
air stripping and discharge to surface water
Same as RAA-2A except off-site leachate
treatment and disposal at POTW
Same as RAA-2A except enhanced leachate
collection with interceptor trench
Same as RAA-2C except off-site leachate
treatment and disposal at POTW
Long-term ground water monitoring/
fencing/deed restrictions/multimedia cap at
both landfills/ground water collection with
extraction wells/perimeter leachate
collection/on-site treatment with air
stripping/discharge to surface water
Long-term ground water monitoring/
fencing/deed restrictions/multimedia cap at
both landfills/ground water collection with
extraction wells/perimeter leachate
collection/on-site treatment with chemical
oxidation/discharge to surface water
Estimated Costs
3 Criteria
$111,000
$4,559,000
$4,352,000
$4,644,000
$4,423,000
$4,859,000
to
$4,935,000
$5,114,000
to
$5,344,000
9 Criteria
$111,446
$4,558,947
|
$4,352,078
$4,^44,183
$4,423,255
i
$4,934,726
; !
$5,113,678
' 1
• i
i
i • •
092
-2-
-------
Alternative
RAA-5
RAA-6
Established Technology
Long-term ground water monitoring/
fencing/deed restrictions/multimedia cap at
both landfills/ground water collection with
extraction wells/perimeter leachate
collection/off-site leachate treatment and
discharge at POTW
Consolidation of the upper and lower
landfills at the upper landfill/fencing/deed
restrictions/multimedia cap/perimeter
leachate collection/on-site leachate treatment
with air stripping/discharge to surface water
Estimated Costs
3 Criteria
$7,924,000
!to
$10,893,000
j
'|
$5,218,000*
1
i
I
9 Criteria
$10,893,217
$5,218,316
"Alternative RAA-6 assumes no hazardous material in the lower landfill. If. hazardous material
is found during excavation, the cost would increase significantly. i
8. If a standard'technology was chosen, why? , i
1 .,.-,- i '.•
The selected remedy was RAA-2B, which includes long-term groundwater monitoring, fencing,
deed restriction, multimedia caps at both landfills, enhanced leachate (collection with extraction
wells, and off-site leachate treatment and disposal at a POTW. It would rely on natural
attenuation of groundwater contaminants, which would take 7 to 9 yeiirs to reach site goals, is
the least costly of the action alternatives, and provides short- and long-term effectiveness. Of
the four RAA-2 alternatives (A, B, C, D), RAA-2B was selected because it would be the
simplest to implement. j

RAA-1 (no action) would not protect human health. RAA-3, RAA-4, and RAA-5 include
extraction and treatment of groundwater, which would remediate groundwater within 14 to 24
years, a longer period of time than natural attenuation alone. Extraction would interfere with
natural biological activity by diluting contaminant levels. RAA-5 also would be much more
expensive. RAA-6 included consolidating the upper and lower landfills, which would create a
short-term threat of exposures not warranted by the low groundwater contamination in the
lower landfill. ;
9. If an innovative technology was chosen, why?

No innovative technology was chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ;

Innovative technologies were not considered even during the initial screening of technologies.
The size of the landfill and the aibsence of on-site hot spots of contaminants precluded
excavation and treatment of landfill materials as a means of source control.
-3-
093
-------
11, Which of the nine criteria were weighted most heavily in selecting the technology? Did failure ^&
to meet one of the nine criteria result in the elimination of the innovative technology?. If so, \
which criterion? Which of the criteria supported the use of a standard technology? j —

Short-term effectiveness and cost effectiveness Were weighted most heavily in selectiop of a
remedy at this site. Natural attenuation was estimated to be able to remediate the groundwater
in a shorter time than pump-and-treat alternatives. Consolidation of the upper and lovter
landfills was expected to create unwarranted short-term exposure risks. The selected remedy
was the least costly of the action alternatives. j
! •

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? |

Chemical-specific ARARs for groundwater were based on New York State Class Ground
Water Quality Standards (the chloroethane cleanup level may not exceed 5 ppb). No jspecific
ARARs were developed for soil or sediment. Alternatives developed for this site were aimed
at blocking infiltration of precipitation into the landfill with a multimedia cap. This technique
would be supplemented by leachate collection and treatment. Therefore, treatment ofjlandfill
soil/sediment was not an integral part of any alternative proposed. ; .

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ;
• - ; • ,
No innovative technologies were eliminated because of cleanup goals. The standard i
technology selected could meet cleanup goals. !
- • i '
i
14. Were treatability studies conducted on the innovative technology or standard technology?
. i
No treatability studies were conducted. ]
• , .' / •-•'[./'••
15. What measures/criteria were used to compare, alternatives? !

The following measures were used to compare alternatives: ^ :

Time to design/construct/operate i
Total cost I
Proven reliability j

• • ... |^

16. How are alternatives compared? . ; .
•' . I " i
The time required for natural attenuation to reduce chloroethane concentrations to grpundwater
standards was estimated using a first-order decay equation to be 7 to 9 years. The time
required for groundwater pump-and-treat systems to reduce chloroethane concentrations to
groundwater standards was estimated using a groundwater flow rate equation to be 14 to 24
years, assuming no biological degradation processes. Proven reliability was noted for many of
the treatment technologies as an advantage to its use. Where alternatives would take similar
094
-4-
-------
times for remediation and their reliability was similar, cost was used to select the most
appropriate remedy. ; •
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? \

The site consists of two landfills. The lower landfill is bordered by v/etktnds and a 100- year-.
old floodplain. Sbale/siltstone underlies the entire site. Groundwater occurs between one to ,
14 feet below the lower landfill and at 24 feet below the upper landfill. 1While these technical
considerations were factors in the remedy selection, technical considerations were not primary
in the selection of a remedy. ;
095
-------
Cosden Chemical Coatings Corporation

City of Beverly, New Jersey
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

Toluene 1,600
Ethylbenzene 1,600
Xylene . 7,900
Trichloroethene 1.6
Lead 6,580
Cadmium 2.6
Chromium (total) 36,000
Beryllium 0.6
PCBs 120
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
7/87
7/92
9/30/92
Background i-

EPA Fund-lead j
PRPs: Cosden Chemical Coatings Corp.
FS prepared by: Ebasco Services Inc.
2. What volume of material is to be remediated? \

The volume of material to be remediated included: j
-, i
• 8,000 cubic yards of soil i

3. What type of site is this? . ;

Chemicals and Allied Products. The site housed a paint formulation and manufacturing
facility that produced coatings for industrial applications. The surrounding area is suburban
with some light industry. ,
•!•
i '
TECHNOLOGY SELECTION , ' I

4, What standard technologies were considered for selection in this FS? |

Standard technologies considered during the identification and screening of technically feasible
technologies were: ' h"

Access restriction: Land use restriction, public information,programs \
Containment: Cap (clay, asphalt, synthetic membrane, chemical sealant, multimedia)
09G
-1- ,
-------
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Stabilization (solidification), in situ stabilization (solidification)
Mechanical aeration , <
Incineration (multiple hearth, rotary kiln, infnired,, fluidized bed)
Excavation, on-site RCRA landfill, off-site RCRA landfill, 6n-?site
nonhazardous disposal, off-site nonhazardous disposal
5. Was an innovative technology considered in the FS? If so, which technology?
1' ' !
Innovative technologies considered during the identification and screening of technically
feasible technologies were: ;

Biological treatment: Biodegradation
Phys/Chem treatment: Alkali metal dechlorination (APEG), soil washing and extraction,
supercritical fluid extraction, in situ soil flushing .
Thermal treatment: High-ternperature thermal desorption, in situ yitrification, in situ
vacuum extraction . '•; '
What was the cost estimate for the innovative technology? ;
' . ' • • ' • \ '''..'
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, y^fteir the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that! merit a more detailed
evaluation. The estimated costs then are recalculated during an evaluation based on nine
criteria established by the NCP. . I
! .1
A risk assessment prepared concurrently with the FS showed that.VOC contamination does not
pose an unacceptable risk to human health. Accordingly, the RAAs brought forward from the
FS to the Proposed Plan were changed to exclude specific treatment of VOCs in site soils.
Separate tables are presented for RAAs in the FS and RAAs in the Proposed Plan and ROD.

Cost Estimates for RAAs Tfaat Include Innovative Technologies
(selected remedial alternative is in bold)

FS ' • '. • ' - ''.-•••••'

Alternative
RAA-6
RAA-7 •

Innovative Technology
Excavation/on-site high-temperature
thermal desorption/on-site stabilization
(solidification)/on-site disposal/soil
cover/land use restrictions/ground water
monitoring
In situ vacuum extraction/in situ
stabilization (solidification)/soil
cover/land use restrictions/ground water
monitoring
. • .•'• -2-
Estimate<
3 Criteria
$4,948,300
$3,957,400

1 Costs
9 Criteria
$4,948,300
$3,957,400

097
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

FS *
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology '
No action/soil monitoring
Post warning signs/public education
program/land use restrictions/soil
monitoring
Asphalt cap/land use restrictions/
ground water testing
EXcavation/off-site incineration/off-site
stabilization (solidification)/off-site
disposal/backfill with clean off-site soil
Excavation/on-site incineration/on-site
stabilization (solidification)/on-site
disposal/soil cover/land use restrictions/
ground water monitoring
i
Estimated Costs
3 Criteria
$894,900
$968,8,00
$2,515,100
$15,231,900
$5,788,800
9 Criteria
$894,900
$968,800.
$2,515,100
i
[
$15,231,900
eliminated
Proposed Plan and ROD
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action/soil monitoring
Post warning signs/public education
program/land use restrictions/soil
monitoring
Asphalt cap/land use restrictions/
ground water testing
Excavation/off-site stabilization
(solidification)/off-site disposal/backfill
with clean off-site soil
Excavation/on-site stabilization
(solidification)/on-site backfill/soil
cover/land use restrictions/ground water
monitoring
Estimated Costs
PP
$55,600
$88,000
$2,515,100
$7,187,850
$3,793,250
-
ROD
$55,600
$5$,600
i
$2,515,100
$7,187,850,
• i
i
$3,793,250
. i .
i
i
098
-3-
-------
Alternative
RAA-6
Standard Technology
Excavation/in situ stabilization
(solidification)/soil cover/off-site
disposal/land use restrictions/ground
water monitoring
Estimated Costs
!PP
$3,268,000
i
1 - "
i
ROD
$3,268,000
8. If a standard technology was chosen, why? ,

Compared to other alternatives, the selected remedy achieves ARARii more quickly, or as
quickly, and at less cost. The selected remedy is protective of humain health and the
environment, dealing effectively with the threats posed by the contaminants which were
identified. The principal threat posed by the site is the contaminated soils. Stabilizing the
contaminated on-site soils will protect against future direct contact, iagestion, and inhalation
hazards. Additionally, stabilization prevents the infiltration of soil contaminants into the
ground water. The selected remedy complies with chemical- specific; ARARs in that the
contaminants of concern in the soil will be treated to reduce the direct contact, ingestion, and
inhalation exposure risks to 1 x 10'6 for carcinogens, and to an ffl of less than 1.0 for
noncarcinogens. The selected remedy complies with action- specific! ARARs in that the
stabilized soil will meet RCRA standards for teachability and toxiciry. Of the alternatives that
most effectively address the threats posed by site contamination, the;selected remedy provides
for overall protectiveness in proportion to its cost. The treatment of soils contaminated with
PCBs over 50 ppm at an approved off-site facility significantly reduipes the toxicity, volume,
and mobility of the contaminants. The stabilization of soil contaminated with metals and
PCBs less than 50 ppm will reduce the mobility of these contaminants and, therefore,
represents a permanent solution to the risks posed by the contaminated soil. The toxicity and
volume of the contaminated soil, however, will not be reduced. Considering the relatively
large volume of metals and PCB-contaminated soil (8,000 cubic yards), EPA believes.that the
selected remedy represents the maximum extent to which the toxicity, mobility, and volume
can be reduced in accost-effective manner. The statutory preference for remedies that employ
treatment as a principal element also will be satisfied for the contaniinated on-site soil. The
metal- and PCB-contaminated soil will be stabilized in situ, thereby!reducing risk to human
health. I
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stag* was the innovative
technology eliminated? j

« Biodegradation was eliminated because of significant uncertainties regarding treatment
reliability for both organic and inorganic contaminated soil. Biodegradation is a
developmental technology for hazardous waste cleanup which requires extensive
bench- and pilot-scale testing to verify its effectiveness. While aerobic biodegradation
has been demonstrated to be effective on some organics such as benzene, toluene, and
xylene, uncertainty exists regarding its effectiveness in remediating PCBs, which are
among chemicals of concern at the site. Anaerobic biodegradation might be effective
on chlorinated organics under controlled conditions. The presence of elevated levels
of metals in the soil might adversely affect microorganisms. In addition, volatile
organics would volatize while mixing and aerating the contaminated soil and vj/ould
need to be captured and treated. ,''-.-
• Alkali metal dechlorination (APEG) was eliminated because the APEG processes are
used for the treatment of chlorinated compounds, primarily PCBs. In addition!to
PCBs, the site also needs PAHs and VOCs removal. The alkali metal dechlorination
technology has not been shown to be effective in treating other organics such as the
VOCs and PAHs present in contaminated soil at the site. !
• Soil washing and extraction was eliminated because the most promising soil washing
and extraction application is its use in the extraction of heavy metals. The use' of soil
washing and extraction for organics with a volatile component would require a closed
loop washer with a vapor emissions control system. Large volumes of contaminated
wash water and/or spent extraction solution would be generated which would require
recovery, further treatment, and/or disposal. In addition, multiple contaminants would
require multiple washing steps. Other treatment technologies are available that would Jlfc-' .
be easier to implement and equally effective, without generating large voluniesl of ^pr J
secondary waste. | -^
• Supercritical fluid extraction was eliminated for the following reasons. Supercritical
fluid extraction is currently available from only one vendor; therefore, the availability
of equipment would be limited. This technology would require further treatment for
metals. Since this technology also requires a pumpable waste such as sludge, a soil
slurry would have to be prepared. Supercritical fluid extraction would require & higher
capital cost, and involve processes and equipment that are more complex than other
technologies. :
» In situ soil flushing was eliminated for the following reasons. The contaminated soil
at the site is mainly sandy soil and gravel with high hydraulic conductivity (l.li x 10"2
to 1.96 x 10'3 cm/sec). The ground water table is approximately 20 feet below j grade.
There are no horizontal or vertical confining barriers to isolate the contaminated areas;
therefore, the flushing solution would migrate into the ground water and would) not be
effectively captured. The site also contains a discontinuous lens of silt and clay in
some locations at a depth of approximately 10 feet, which would create dead spots and
make in situ flushing ineffective. In addition, this technology would require treatment
of large volumes of flushing solution. The technology would be difficult to implement
and process efficiency would be uncertain. I
• In situ vitrification was eliminated because, although the technology is commercialized
for low-level radioactive waste stabilization, heavy metal fixation, and hydrocarbon
destruction, the technology is not very effective for volatile organics because volatile
organics migrate laterally during the vitrification process and might escape untreated. .
100 -5-
-------
innovative technologies eliminated during the screening of the three criteria include the
following: I
' , . )•-..'. , .'!'.• :
• None ; . .. -•.!"•••
I :
Innovative technologies eliminated during the detailed analysis include the following:

• High-temperature thermal desorption was eliminated because a risk assessment
prepared concurrently with the FS showed that VOC contamination does not pose an
unacceptable risk to human health. Accordingly, the RAAs brought forward from the
FS to the Proposed Plan were changed and no longer include!specific treatment of
VOCs in the site soils. One of these treatments was high- temperature thermal
desorption.
• In situ vacuum extraction was eliminated because a risk, assessment prepared
concurrently with the FS showed that VOC contamination does not pose an
unacceptable risk to human health. Accordingly, the RAAs brought forward from the
FS to the Proposed Plan were changed and no longer include; specific treatment of
VOCs in the site soils. One of these treatments was in situ vjacuum extraction.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria .result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
i . •' •••
Short-term effectiveness and cost were weighted most heavily in selecting the in situ
stabilization. Compared to other alternatives, the selected remedy costs less and achieves
ARARs more quickly, or as quickly, than the other options. Failure |to meet one of the nine
criteria did not result in the elimination of an innovative technology.!
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that ,
ARAR? What risk level was selected to establish cleanup goals? j
Contaminant
Carcinogens
PCBs
Beryllium
Chromium (VI)
Lead
Noncarcinogens
Chromium (HI)
Cleanup Level (rag/kg)

1
1
390
500

78,000
ARAR or Other Basis
i . i
OS'WER directive
#9344.4-02
Quantification limit3
;Risk-basedb
OSWER directive
•• #9355.4-02
' .
Risk-based
"Calculated from IxlO"6 risk* then deferred to practical quantification limit
-6-
101
-------
13.
"Tor carcinogens, an excess upper bound individual lifetime cancer risk of between 10
to 10"6 was acceptable. For noncarcinogens, a Hazard Index less than or equial to 1.0
was acceptable. !
Was the innovative technology eliminated because of the cleanup goals? Could the Standard
technology meet the cleanup goals? !
, i
Innovative technologies eliminated because of cleanup goals include: . i
i
• None i
- ' . , r i *
Standard technologies eliminated because of cleanup goals include: . i ' , '

• None . i
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. i
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Total cost
Time to design/construct/operate
Proven reliability
Impact on nearby populations
16. How are measures compared? ;
i
RAA-1 and RAA-2 would not reduce the human health hazards associated with direct contact
and ingestion of contaminated soils. RAA-3 would effectively control the dermal contact and
ingestion pathways, and therefore provide adequate protection of human health. RAAi-1,
RAA-2, and RAA-3 would not meet risk-based guidance for cleaning up lead or PCB's. RAA-
4, by removing contaminated soil for off-site disposal, would offer the greatest level of overall
protection. RAA-5 and RAA-6 would offer adequate protection by immobilizing '
contaminants. RAA-6 costs less and achieves ARARs more quickly than, or as quickly as the
other options. The amount of time until protectiveness is achieved is approximately the same
for all of the soil treatment alternatives. Estimated present worth costs for stabilization range
from $3,268,000 for RAA-6 to $7,187,850 for RAA-4. Solidification of metals and P^B
contaminated soil is common to RAA-5 and RAA-6, and is an easily implemented and proven
technology. All of the alternatives would require the implementation of a health and Safety
plan to minimize any short term risks to on-site workers and nearby residents. '•
" . E " I
102
-7-
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? :

Technical considerations were not primary in selecting a remedy. However, in situ soil
flushing was eliminated for the following reasons. The contaminated soil at the site is mainly
sandy soil and gravel with high hydraulic conductivity (1.71 x 10'2 to 1.96 x 10'3 cm/sec).
The ground water table is approximately 20 feet below grade. There are no horizontal or
vertical confining barriers to isolate the contaminated areas; therefore] the flushing solution
would migrate into the ground water and would not be effectively captured. The site also
contains a discontinuous lens of silt'and clay in some locations at a depth of approximately 10
feet, which would create dead spots and make in situ flushing ineffective.
103
-------
Curcio Scrap Metal Incorporated
OU-1

Saddle Brook, New Jersey
Region 2
GENERAL SITE INFORMATION
L
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

PCBs
Lead
4,500
39,300
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 1,800 cubic yards of soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
7/87
6/90
6/28/91
Background
I
PRP-lead j
PRPs: Consolidated Edison Company of
New York, Incorporated; Curcio
Scrap Metal, Incorporated; SECO
Corporation |
FS prepared by: Blasland, Bouck and
Lee ;
3. What type of site is this?

Recycling. An active scrap metal recycling business.
TECHNOLOGY SELECTION ' !

4. What standard technologies were considered for selection in this FS? ;

Typically standard technologies are identified during the initial screening process, In this case,
no initial screening process was conducted. Technologies presented below were extracted from
the proposed RAAs. ;

Access restriction: Fencing, deed restrictions ' ' i
Containment: Asphalt surface pavement :
Chemical treatment: Stabilization/solidification (cement, pozzolan, thermoplastic, pqlymer)
Thermal treatment: Off-site incinerator i
Disposal: Excavation, off-site disposal at RCRA/TSCA landfill , - : "
104
-i-
-------
5. Was an- innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: , ... - j

Thermal treatment: In situ vitrification ;
What was the cost estimate for the innovative technology? i

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) i
Alternative
RAA-1
RAA-2
RAA-3
JfcAA-4
RAA-5
Standard Technology
No action/fencing/deed' restrictions
Asphalt surface pavement
Excavation/off-site disposal at RCRA/
TSCA disposal facility
Excavation/off-site incineration at
RCRA/TSCA permitted incinerator
On-site stabilization/solidification
Estimated Costs
9 Criteria
!EO
$171,000
$1,650,000
$11,400,000
$930,000
ROD
$0 '•'
$242,000
eliminated
$7,500,000"
eliminated
While the decrease in estimated cost between the FS and ROD is noit explained, it appears to
be due to miscellaneous costs (20 percent) and contingency costs (25tpercent) that are included
only in the FS calculation. ! ,
105
-2-
-------

5. If a standard technology was chosen, why?

Excavation with off-site incineration was selected as the remedy at the site, due to the high
concentration of contaminants in the soil and the corresponding high risk associated with the
contamination. EPA is addressing the soil remediation on an expedited basis. The remedy
was selected because of the following reasons: 1) need to expedite clean-up, 2) compliance
with regulations, specifically TSCA (soils contaminated with PCBs at concentrations [greater or
equal to 50 ppm can be incinerated, treated by an equivalent method or disposed in a TSCA
landfill), RCRA Land Disposal Restrictions (LDRs) and NJDEP Soil Action Levels, j 3) other
standard technologies and innovative technologies were not considered equivalent treatment to
incineration by TSCA and would not comply with LDRs or the NJDEP Soil Action Levels, 4)
permanence, 4) need to not interfere with the on-going scrap metal reclamation operations, 5)
• the small size of the site. . • '; . '

9. If an innovative technology was chosen, why? . j ;
" ' i. • ' ',
An innovative technology was not chosen. !
• i * -;1-'-
- • . | '''-'

10. V on innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? !

Innovative technologies could be eliminated from the remedial technology selection process at ^fc ~-\
three stages: during the initial screening; during the screening of the three criteria of i ^P J
effectiveness, implementability, and cost; or during the detailed evaluation. ' ' i ^ ,|

Innovative technologies eliminated during the initial screening include the following: I |

• Biodegradation was eliminated because it is not effective on the types of contaminants i
at the site. i • >
• Vacuum/steam extraction was eliminated because is not effective on the types! of I
contaminants at the site. . , i ,
• Soil flushing was eliminated because it would significantly deteriorate the quality of
groundwater and may have limited effectiveness for the treatment of metals iri soils.

Innovative technologies eliminated during the screening of the three criteria include the J
following: , , j £
• i ~ T
» None, not performed. I :L

Innovative technologies eliminated during the detailed analysis include the following: | • t

• In situ vitrification was eliminated because1) its effectiveness is unproven ami
extensive pilot testing would be required, 2) the time to conduct the pilot test was a ' j
concern due to the magnitude of human health risks presented by the site, 3) no '
Superfund site had been treated at the time of the ROD with ISV, 4) migration
potential of contaminants, 5) requires specialized equipment and highly trained ^^ V
personnel, 6) small size of site would not accommodate ISV equipment. •• ) j
" i " ^«^ _f

106 \
-3- • •. , - ' ' . '
-------
11.
13.
: •
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
Important factors in selecting the remedy were: compliance with
effectiveness; reduction of toxicity, mobility or volume; and impleme
; short term
ntability.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Carcinogens
PCBs
Lead
Cleanup Level (mg/kg)

1
250 -.1,000
ARAR or Other Basis
i
EPA"
NJDEP"
"EPA "Guidance on Remedial Action for Superfund Sites
OSWER Directive No. 9355.4-01, August 1990.
""New Jersey Department of Environmental Protection Soil
wih
PCB Contamination,"

Action Levels.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? .

Innovative technologies eliminated because of cleanup goals include

• None .-
,'*
Standard technologies, eliminated because of cleanup goals include:

• Surface pavement /
» Stabilization/solidification
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Time to design/construct/operate
Proven reliability
Preference for treatment (vs. containment)
- Impact on nearby populations
-4-
107
-------
16. How are measures compared? • •. • • I
!
Due to the magnitude of risk posed by the site to on-site workers, visitors, and nearby
residents, choosing a readily implementable alternative was critical. Proven reliability was,
therefore, an important factor since treatability studies for unproven technologies would require
too much time. Two technologies, in situ vitrification and stabilization/solidification,! were
eliminated because their effectiveness in remediating site contaminants was unknown and they
would require,treatability studies prior to implementation. The selected alternative's treatment
technology was preferred over containment technologies proposed in other alternatives.
17, What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Site size was a primary factor in determining a remedy.
108
-•"I.
-------
Ellis Property

Evesham Township, New Jersey
Region 2
AT STTF INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:
Soil(mg/kg)
Arsenic 31.8
Lead 3,790
PCBs 23
Bis(2-ethylhexyl)phthalate 2.3
1 Chromium 123
Sediment (mg/kg)

Site
NPL Proposed:
NPL Final:
•pc-
ro. .
ROD:
Bac
EPAFund-lead
PRPs: Irving and
FS prepared by: I
T
. Inc.

History
N/A
9/1/83
4/92
9/30/92
kground
Rebecca Ellis
>.oy F. Weston,

Lead
Trichloroethene
103
5.4
2. '"What volume of material is to be remediated?

The volume of material to be remediated included:

• ; 690 cubic yards of soil contaminated with metals
• 60 cubic yards of soil contaminated with PCBs
B 10 cubic yards of soil contaminated with BNA compounds
• 320 cubic yards of sediment
3. • ' What type of site is this?

Recycling. A former drum storage and reconditioning facility
local ed in an agricultural area.
TECHNOLOGY SELECTION

4, What standard technologies were considered for selection in this
FS?
Standard technologies considered during the identification and
technologies were:
screening of technically feasible
109
-i-
-------
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
. Fencing, warning sighs
Capping (clay, concrete, asphalt, synthetic membrane), slurry wall
grout curtains, sheet piling, grout injection, block displacement, run
on/run off controls, coffer dams ,
Stabilization (in situ, ex situ) . ' • :
Incineration - !
Excavation, landfill (on-site, off-site) ' j
6.
i
Was an innovative technology considered in the FS? If so, which technology? j

Innovative technologies considered during the identification and screening of technicallv
feasible technologies were: |

Biological treatment: In situ biodegradation, composting/farming, bioreactor |
Phys/Chem treatment: In situ soil flushing, dechlorination, soil washing, in situ volatilization
Thermal treatment: In situ supercritical extraction, electromagnetic heating with to situ
volatilization, in situ vitrification, low-temperature thermal treatment
- i

What was the cost estimate for the innovative technology? \ •
\

During the initial screening process, in which technically feasible technologies are identified
& t ^ f0rmulatlon of RAAs>'the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process !
(effectiveness, implementability, and co'st) to identify alternatives that merit a more detailed
evaluation. In tins case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. ' '. ' . ""

Cost Estimates for RAAs That Include Innovative Technologies j
(selected remedial alternative is in bold) '
Soil
Alternative
RAA-SS-3A
RAA-SS-3B
Innovative Technology
Excavation/soil washing/on-site disposal
Excavation/dechlorination/on-site
disposal
Estimated Costs
3 Criteria
N/A

N/A
9 Criteria
eliminated

eliminated
Innovative Technology
Excavation/soil washing/on-site disposal
110
-2-
-------
7. How did the cost(s) compare to standard technologies?
*
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Soil
Alternative
RAA-SS-1
RAA-SS-2
RAA-SS-4
RAA-SS-5
Standard Technology
No action
Institutional controls
Excavation/off-site incineration of
PCB-contaminated soil/off-site
disposal and possible stabilization of
soil contaminated with metals
Capping/surface controls
Estimated Costs
3 Criteria
N/A •
N/A
N/A -
• i •
N/A
9 Criteria
$646,000
$732,000
$716,000 to
$1,922,000'
$3,033,000
to
$5,616,000
"Cost range corresponds to different cleanup levels.

Sediment ...'-.
Alternative
RAA-SED-1
RAA-SED-2
RAA-SED-4
Standard Technology
No action
Institutional controls
Excavation/off-site disposal
Estimated Costs
3 Criteria
N/A
1^/A
N/A
9 Criteria
$400,000
$495,000
$376,000
If a standard technology was chosen, why? _ " •: .,

RAA-SS-4 was chosen because it deals effectively with the threats posed by the site's
contaminants, thereby protecting human .health and the environment. jThe principal threat to
the site is contaminated soil and the exposure pathways that include infiltration of soil
contaminants into ground water,, and further migration of contarriinanits into the aquifer.
Excavating site soil will ensure that the source of the risk will be reduced. Removing'soil
contaminants also will prevent further degradation of wetlands caused by surface soil erosion.
The treatment of soil contaminated with PCBs/organic compounds at|an approved off-site
facility will significantly reduce their toxicity, volume, and mobility
-------
comprehensive health and safety plan. This alternative complies with ARARs and it reduces
risk posed by the site's soil to the acceptable range of W4 to 10"6 for carcinogens and an ^^ *\
Hazard Index less than 1 for noncarcinogens. This alternative is cost effective, since ;of the - —"'"'
alten stives that most effectively address threats by site contaminants, it provides overall
protection proportionate to its cost. ' '•

RAAs for sediment were developed in the FS but not carried forward to the Proposed Plan or
the ROD. A remedial action to address the wetlands sediment was deemed unnecessary since
the New Jersey Department of Environmental Protection and Energy (NJDEPE) and EPA
determined that the contaminants in the surface water and sediments of the wetlands do not
pose an unacceptable risk to human health and the environment. '•
i

9. If an innovative technology was chosen, why? •'*•'.
|

An innovative technology was not selected. . i

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? i

Innovative technologies could be eliminated from the remedial technology selection pijocess at
three stages: during the initial screening; during the screening of the three criteria of j
effectiveness, implementability, and cost; or during the detailed evaluation. ' i
• . - •' . . . | -. •~"
Innovative technologies eliminated during the initial screening include the following: ; , ^^ )

• In situ biodegradation was eliminated because it would be very difficult to control or
verify the success of the treatment, toxic byproducts could be formed, and the!
technology would not be effective on metals. i
• In situ supercritical extraction was eliminated because it would not remove metals and
would be applicable only to volatile and semivolatile contaminants, which are ja
concern only in the wetland sediment. Furthermore, the low permeable site solils
would retard the flow of contaminants through the soil^ this technology would!be more
applicable to deep contamination in contrast to the shallow contamination at this site,
and the shallow ground water table would create further problems. | -
• In situ volatilization was eliminated because it would not be applicable to the site since
VOC contamination is in saturated soil. This process would not be effective in
saturated soil since porous soil is required to allow sufficient air flow. \ - .
• Electromagnetic heating with in situ volatilization was eliminated because it wbuld not
be effective on metals and would be inhibited by shallow ground water and tight, low
permeability soil.
• In situ vitrification was eliminated because it would be technically unfeasible to vitrify
sediment located in the wetland without permanently destroying the wetland, i .
• In situ soil flushing was eliminated because of uncertainties associated with introducing
solvents into an uncontrolled environment, the enhanced migration of hazardous .
materials requiring capture and treatment, and the ineffectiveness of this technique in
wetlands since they are periodically saturated. j
• Low-temperature thermal treatment was eliminated because the relatively low !
concentrations of VOC-containing sediment would not justify the permitting arid
112
-4-
-------
11.
12.
expense associated with construction of an on-site treatment system. Further, the
process would not address metals. :
• , Composting/landfarming was eliminated because the degree of treatment and products
of degradation are uncertain. Furthermore, it would not be effective for treating metal-
containing soil and therefore the treated soil would require subsequent
treatment/disposal. !
• Bioreactor was eliminated because treatment would take a long time; it would not be
effective for metals removal or treatment, and therefore metal-containing soil would .,
require further treatment/disposal; and extensive treatability studies would be required
to identify suitable microorganisms and to determine if treatment goals could be met.

Innovative technologies eliminated during the screening of the three criteria include the
following: > ;...'•• ;
i
• Soil washing was eliminated because of its uncertain effectiveness in meeting treatment
action levels for site soil, the high unit cost for construction £|nd operation of the
treatment system, and the requirement for disposal or treatment of the spent wash
solution. , .:....'
• Dechlorination for soil treatment was eliminated because of its uncertain effectiveness
in meeting treatment action levels for site soil, the high unit cost for construction and
operation of the treatment system, and the requirement for disposal or treatment of the
spent reagent solution and wastewater.

Innovative technqlogies eliminated during the detailed analysis include the following:

» None
Which of the nine criteria were weighted most heavily in selecting
to meet one of the nine criteria result in the elimination of the
which criterion? Which of the criteria supported the use of a
the technology? Did failure
innovative technology? If so,
standard technology?
Long-term effectiveness and permanence and compliance with ARARs
weighted most heavily in selecting a remedial alternative. These
the chosen alternative.
were the criteria
criteria were best provided by
Some innovative technologies (soil washing and dechlorination) were
cost.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
NJDEPE requested that soil be remediated to the levels specified in i
Standards for Contaminated Sites (February 1992). While these
recognized as ARARs under CERCLA because they are not yet
that they do not conflict or are not inconsistent with the remedy.
fund the incremental costs associated with this additional cleanup.
The
-5-
eliminated due to high
its
Proposed Cleanup
proposed standards are not
promulgated, EPA determined
NJDEPE has agreed to
113
-------
13.
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Bis(2-ethylhexyl)
phthalate
Lead
PCBs
20/20
46/49
500/100
1/0.45
Risk"/NJDEPEb
Risk/NJDEPE |
Risk/NJDEPE !
Risk/NJDEPE j
Noncarcinogens
Chromium
945/NA
Risk/NJDEPE ;
*EPA's risk-based cleanup levels. j
"WDEPE's proposed residential soil cleanup, levels for contaminated sites. :

These cleanup levels will reduce exposure risk posed by soil to an acceptable range of; lO^to
10' for carcinogens and to a Hazard Index less than 1 for noncarcinogens. '
1 !

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? i

Innovative technologies eliminated because of cleanup goals include: '
l
• Soil washing j
• Dechlorination ;
' ' i .
Standard technologies eliminated because of cleanup goals include: ;
' • " i '-
• None • I
14.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. '
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Single vs. two treatments
Preference for treatment (vs. containment)
Waste left in place/institutional control
114
-6-
-------
16. How are measures compared? '••.!'
,f '
Because of the different types of contaminants present in the soil, treatment of the soil with a
single technology was not practicable. As described in the FS, no single technology would be
effective for treating organic compounds, PCBs, and heavy metals in soil. Furthermore, the
cost of constructing an on-site treatment system would not be justified by the small volume of
metal-contaminated soil. The selected alternative addressed this problem by providing two
individual remedies for PCB-contaminated and metal-contaminated soil.

RAA-5 was eliminated because treatment was preferred over cpntainmbnt since it would offer
greater long-term effectiveness and permanence and meet all ARARs. iRAA-2 was eliminated
because institutional controls were deemed to be unprotective because they would not control
off-site migration or infiltration of contaminants. " i .
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? |
' • i - ' i --
t.
The saturation, low permeability, and high water table were technical considerations in
selecting a remedial alternative; however, no technical considerations were primary. One
reason capping was not chosen is that future fluctuations in the water .liable could bring it into
contact with contaminated soil causing an increase in contaminant volume. Many technologies
were eliminated because they could not be implemented in low-permeability soil. These
include in situ supercritical extraction, in situ volatilization, and electromagnetic heating with
in situ volatilization. ,
-7-
115
-------
Endicott Vfflage Well Field
OU-2

Village of, Endicott, New York
Region 2
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/15/84
6/10/86
7/92
9/92
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Landfill Waste (rag/kg)

BTEX compounds 20
Trichloroethene 110
1,2-Dichloroethene 15
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• No specific waste volume was .
provided; the average depth of waste
is 15 to 20 feet over 60 acres.
3. What type of site is this? . ;
~ i •
Municipal Landfill. An active landfill located in a rural area. ' ' -' !

i
TECHNOLOGY SELECTION '

4. What standard technologies were considered for selection in this FS? \

Standard technologies considered during the identification and screening of technically ifeasible
technologies were: ,
i
Access restriction: Deed restrictions, fencing :
Containment: Capping (native soil, single barrier, double barrier) !
Physical treatment: Gas venting ••.!..
Background \

PRP-lead
PRPs: Endicott Johnson Corporation,
George Industries, Inc., :
International Business Machines
Corporation, Midstate Lithd,
Village of Endicott, Town of
Union • " _ j
FS prepared by: Ground Water j
Associates '
116
-i-
-------
5. Was an innovative technology considered in the FS? If so, which technology

Innovative technologies considered during the identification and screening of technically
feasible technologies were::

Physical treatment: Vacuum extraction
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible
(prior to the formulation of RAAs), the FS does not quantify costs.
' formulated, costs are typically estimated as part of a three-criteria
(effectiveness, implementability, and cost) to identify alternatives that
evaluation. In this case the estimated costs were calculated during an
criteria established by the NCP. No innovative technologies were i
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
tec! nologies are identified
After the RAAs have been
screening process
merit a more detailed
evaluation based on nine
incorporated into RAAs.
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-3C
RAA-3D
RAA-4A
RAA-4B
RAA-4C
Standard Technology
No action
Institutional controls
Native soil cover
Native soil cover/leachate treatment
with air stripping
Native soil coverAeachate transported
to POTW for disposal
Native soil cover/piping leachate to
POTW for treatment and disposal
Low permeability barrier cap
consistent with 6NYCRR Part 360
Low permeability barrier cap
consistent with 6NYCRR Part 360/
leachate treatment with air stripping
Low permeability barrier cap consis-
tent with 6NYCRR Part 360/leachate
transported to POTW for disposal
Estimated Costs
3 Criteria
N/A
N/A
JST)A
\. N/A
N/A
('
NfA
i
N/A
N/A
1
[
N/A
'i.
1 i
9 Criteria
$132,500
$390,000
- $3,267,000
$4,830,000
. $4,811,600'
$4,634,800
$43,508,700
$45,071,700
$45,053,300
-2-
117
-------
Alternative
RAA-4D
(RAA-5A/B)'
,(RAA-5A/C)a
(RAA-5A/D)8
Standard Technology
Low permeability barrier cap consis-
tent with 6NYCRR Part 360/piping
leachate to POTW for treatment and
disposal
Low permeability barrier cap with
6NYCRR Part 360 variance/leachate
treatment with air stripping
Low permeability barrier cap with
6NYCRR Part 360 variance/leachate
transported to POTW for disposal
Low permeability barrier cap with
6NYCRR Part 360 variance/piping
leachate to POTW for treatment and
disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$44,8:76,500
$12,710,000
$12,747,200
*RAA-5 was developed in the Proposed Plan and ROD.

8. If a standard technology was chosen, why?

RAA-5A/B was preferred because it protects human health and the environment by containing
waste with a landfill cap, by controlling landfill gas through monitoring and venting and by
controlling and treating the leachate seep. By reducing leachate production the remedy limits
further contamination of ground water and thereby builds upon other site actions at OU-1 and
OU-3, It complies with all federal and state ARARs. The selected remedy affords overall
effectiveness proportional to its cost because, among other things, it uses a terraced or !
.washboard design to attain a 4-percent slope to promote runoff, thereby reducing infiltration
and leachate generation. The landfill waste will not be treated because it is not practical
Since no "hot spots" were identified, effective excavation and treatment of contaminant's is
precluded. . - | .
9.
If an innovative technology was chosen, why?

An innovative technology was not selected.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative1
technology eliminated? , | .

• None

Innovative technologies eliminated during the screening of the three .< riteria of technologies
include the following:

Vacuum extraction was eliminated because of the high capita and operating costs for
an active gas system, versus a passive gas collection system.
offers only a negligible increase in effectiveness and no regulatoiy basis for selection.

Innovative technologies eliminated during the detailed analysis include the following:

• None
Which of the nine criteria were weighted most heavily in selecting the
to meet one of the nine criteria result in the elimination of the innovative
which criterion? Which of the criteria supported the use of a standard
Long-term effectiveness, reduction of contaminant mobility, and cost
weighted most heavily in selecting a remedial alternative. Of the two
reduce landfill infiltration and resultant leachate generation, the least
were the criteria
RAAs that would best
expensive was chosen.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
No cleanup goals were developed for the landfill. Treatment of the
its size and the fact that no "hot spots" were identified that represent
contamination that could be excavated and treated effectively.
Was the innovative technology eliminated because of the cleanup got Is? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None
•' ' • . I . .
Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or j

Treatability studies were not conducted.
-4.
An active gas system
technology ? Did failure,
technology? If so,
technology?
landfill was precluded by
major sources of
tandard technology?
119
-------
75. What measures/criteria were used to compare alternatives? ..- '•

The following measures were used to compare the alternatives: *

Percentage risk reduction ''•'••
Cost-effectiveness |
Waste left in place/institutional control " >

i •
16. How are measures compared? !

RAA-5 was preferred over RAA-1 and RAA-2 because they would not be protective jof human
health and the environment. No action or institutional controls would minimize landfill
infiltration and leachate generation. RAA-5A/B was preferred over RAA-3 because it provides
a thicker cap and a runoff system, which will better reduce the leachate generation arid provide
a greater reduction in contaminant mobility and volume. Further, RAA-5 will be more
effective in the short term because it limits leachate production, allowing more effective
cleanup of ground water. RAA-4A-D were comparable to RAA-5A/B in most respects
RAA-4A-D would have been slightly more effective in the long term because it meet& the
most stnngent standards for a low permeability cap. RAA-5 is much less costly and is cost
effective.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
120
-5-
-------
Facet Enterprises, Incorporated
'. . - " *
Village of Elmira Heights, New Yprk
Region 2
7. What were the principal
contaminant levels, and
this feasibility study?
contaminants,
media addressed in

Maximum concentrations of principal
contaminants were:
Surface Soil (mg/kg)
Benzo(a)anthracene
Benzq(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
PCBs
Arsenic
'-....

' 43
69
69,
7
16
11
Site
NPL Proposed:
NPL Final:
FS:
ROD:
Bac
PRP-lead
PRPs: Facet Entt
'FS prepared by: 1

247 ' —
History
10/1/81
9/1/83
3/45/92
. 9/29/92
kground
rprises, Inc.
iRM-Northeast, Inc.

Subsurface Soil (mg/kg)

Benzo(a)anthracerie
Benzo(b)fluoranthene
' Benzo(k)fluoranthene
Benzo(a)pyrene
PCBs

Surface Sediments (mg/kg)

Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
PCBs
Arsenic
Chromium
160
330
330
130
28
8,000
30,000
30,000
22 .
6
14
320
3,920
2.
What volume of material w to be remediated?

The volume of material to be remediated included:

• 1,840 cubic yards of surface soil
• 3*,630 cubic yards of subsurface soil
-1-
121
-------
" 2,704 cubic yards of sediment

3- What type of site is this? . '

Industrial Landfill. A manufacturing facility and

TECHNOLOGY SELFCTrnM

4.
associated disposal areas
6.
Access restriction:
Containment:
Chemical treatment:
Physical treatment:
Thermal treatment-
Disposal:
Fencing, security, deed restrictions
Cap (soil, vegetative, RCRA)
Stabilization
Dewatering
Incineration
Excavation, disposal at off-site RCRA landfill
Biological treatment: Biodegradation
Chenuca treatment: Soil washing (solvent)
Thermal treatment: Low-temperature thermal aeration
•
estimate for the innovate technology?
^ntification .d screening of tecnnicall
technologies are identified
d, costs are usually estimated « p^TtC^T8' ^ ^ RAAs ^ been
(effectweness, implementability, and cost) 10^^ u screei»ng process
SSBS -» -
122
Innovative Technology
9 Criteria

$2,342,064
Low-temperature thermal treatment/
KCRA cover
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-6
RAA-7
RAA-8
Standard Technology
No action
Deed restrictions/fencing/security
RCRA cover
Stabilization and RCRA cover
Off-site disposal
On-site RCRA-cell disposal
Off-site treatment (stabilization) and
disposal at RCRA landfill
Estimated Costs
3 Criteria
N/A
tf/A
N/A
N/A
N/A
. N/A
N/A,
9 Criteria
$0
$9,730
$1,047,943
$1,582,718
. $2,811,931
$1,187,101
$2,462,334
. ^HL;
8. If a standard technology was chosen, why?

A standard technology was selected. The remedy includes stabilization and off-site disposal.
This remedy was selected because it: 1) would comply with lland Disposal Restrictions by
using a stabilization method that would meet TCLP standards, 2) other alternatives would have
to meet New York state requirements, 3) risks from exposure to contaminated soil and
sediment would be removed, 4) future use of property will be unrestricted, 5) reduces the
mobility of inorganic contaminants, 6) involves little construction and implementation, 7)
, equipment and personnel are readily available.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ;
! '
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Initial screening was not completed. Innovative technologies eliminated during the initial
screening include the following:

• None ,
-3-
123
-------
' !
Innovative technologies eliminated during the screening of the three criteria include the
following: • . j
I
!
• Soil washing was eliminated because it has not been used extensively, so that! it's
effectiveness is not well documented; soil at the site with a high percentage of silt and
clay will adsorb contaminants and be difficult to remove with soil washing; soil could
be transformed into sludge, which would require dewatering and additional treatment;
a literature survey does not show soil washing use on metal hydroxides; the buffering
capacity of metal hydroxide in the waste would hinder soil washing; no cost j
information is available; no full-scale remediations using soil washing have occurred;
some vendors require a minimum volume to be treated which exceeds the volume o be
remediated at the site; Geraghty and Miller soil washer is not effective for soils
containing greater than 20 to 30 % fines or with particle size less than 63 microns; and
several U.S. remediation contractors, which offered this technology in the past have
ceased performing this work or have ceased operations. I
• Biodegradation was eliminated because: the chemicals of concern at the facility may
not be amenable to this technology, specifically the PCBs and semi-volatiles may not
biodegrade; metals in the soil may prove toxic to microorganisms; contaminant
concentrations may not be high enough to promote biodegradation; extensive bench
and pilot scale treatability studies would be required; remediation would be lengthy
and a time consuming process. !
-•.'".'•"' !
Innovative technologies eliminated during the detailed analysis include the following:; .

• Low temperature thermal treatment was eliminated because: it would require i
treatability testing to ensure effectiveness, and it would have to meet New York State
air regulations prior to full-scale operation. |
.^f,
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology? \
i

The criteria that were weighted most heavily in selecting a remedial alternative were protection
of human health and the environment and long-term effectiveness, reduction in toxicity,
mobility and permanence, and implementability. No innovative technologies were eliminated
due to these nine criteria. [ ,
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Surface Soil
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
i
Carcinogens
Benzo(a)anthracene
Benzo(b) fluoranthene
20
20
Risk3
Risk 1
124
-4-
-------
Contaminant
Benzo(k) fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-
cd)pyrene
PCBs
Arsenic
Cleanup Level (mg/kg)
43
3 -
12
10
19
ARAM or Other Basis
! - "
\ Risk
Risk
; Risk
EPA"
Risk
"For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4
to 10"6 was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0
was acceptable.
bU.S. EPA "Guidance on Remedial Actions for Superfund Sites with PCB
Contamination," OSWER Directive No. 9355.4-01.

Surface Sediment
Contaminant
Carcinogens
Benzo(a)anthracene
Benzo(b) fluoranthene
Benzo(k) fluoranthene
Benzo(a)pyrene
Indeno( 1,2,3-
cd)pyrene
PCBs
Arsenic
Chromiumb
Cleanup Level8 (mg/kg)

3
3
7
1
•" 2
1.
7
1,110
ARAiR or Other Basis

• Risk
Risk
Risk
Risk
Risk
; EPA
:Risk
Risk
"Cleanup levels are lower for the drainage way and Creek
there is a greater potential for exposure.
""Remediation goals assume that all chromium is present as

Subsurface Soil
Contaminant
Cleanup Level (mg/kg)
ARAR
Carcinogens
Benzo(a)anthracene
54
-5-
surface sediments because

hexavalent chromium.
or Other Basis
Risk
125
-------
i
Contaminant
Benzo(b) fluoranthene
Benzo(k) fluoranthene
Benzo(a)pyrene
PCBs
Cleanup Level (mg/kg)
55
118
8
25
ARAR or Other
i
Basis
Risk ;
Risk
i
i
i
Risk '\
EPA
i
'13. Was the innovative technology eliminated because of the cleanup goals? Could the standard,
technology meet the cleanup goals? i

Innovative technologies eliminated because of cleanup goals include:- '" .
i
• None I

Standard technologies eliminated because of cleanup goals include: |

» Capping i
- • i

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. i

i ' •
I .
75. What measures/criteria were used to compare alternatives? |

The following measures were used to compare the alternatives: '
i
Proven reliability . . | ' .
Preference for treatment (vs. containment) i
Time to design/construct/operate i
i

16. How are measures compared? • .<. \

Some technologies were eliminated because their reliability was unproveri and they would
require treatability studies, which would increase cost and implementation time. j
17. What technical considerations were factors in selecting a remedy? Were, technical
considerations primary in the selection of the remedy? '

The percentage of fines in the soil were too high for soil washing. ''~
126
-6-
-------
Fibers Public Supply Wells
OU-2

Guayama, Puerto Rico
Region 2
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg):

Chromium 2,110
Asbestos 40
PCB 1.88
Tetrachloroethene 65
Trichloroethene ,67
, " . -

2. What volume of material is to be
remediated?
~~ - . . '

Site History

NPL Proposed: N/A
NPL Final: . 9/1/84
FS: , 4/91
ROD: 9/30/91

Background

PRP-lead
PRPs: ' Phillips Petroleum
Chevron Chemical Company,
Home Products

Company,
American

FS prepared by: ILeggette, Brashears and
Graham, Incorporated

~ ' ,

The volume of material to be remediated
included:

• 9,010 cubic yards of soil
3. What type of site is this?

Rubber and Plastic Products. A soil disposal area formerly used by a nylon and polypropylene
fiber manufacturing plant.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in, this FS1'

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restrictions, fencing
Containment: Capping, slurry wall
Physical treatment: In situ stabilization/solidification
Thermal treatment: Incineration
127
-------
Disposal:
Excavation, off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology? \

Innovative technologies considered during the identification and screening of technically
feasible technologies were: |
• • i •
i -
Biological treatment: In situ biodegradation, ex situ biodegradation i
Chemical treatment: ' In situ soil flushing (water or surfactants) !
Physical treatment: In situ vacuum extraction j
Thermal treatment: Steam stripping, in situ vitrification, radio frequency decontamination
6. What was the cost estimate for the innovative technology? i -

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action/air monitoring
Deed restrictions/fencing/warning
signs
Capping/deed restrictions/
fencing/long-term maintenance
Excavation/off-site disposal
Estimated Costs
l
3 Criteria
$169,000
$232,000
$450,000
$1,315,000
9 Criteria
$1691000
$232,1000
.' '!
$450JOOO
i
$1,231,000
8. If a standard technology was chosen, why? 1

RAA-4 was chosen because it would eliminate risks of long-term exposure; offers a permanent
solution; reduces contaminant toxicity, mobility, and volume; and provides overall !
effectiveness in proportion to its cost. RAA-4 was selected even though it will pose s
-------
environment. RAA-2 was not chosen because it would reduce only c-ontaminant mobility and
its long-term effectiveness was questionable, as it depended on deed restrictions, which are
difficult to enforce. RAA-3 was eliminated because asbestos would remain on site, require
long-term maintenance, and be less effective in the long term. Also, RAA-2 and RAA-3 may
be less implementable than RAA-4 due to potential difficulties in gaining deed restrictions for
an area that has not been permitted for solid waste disposal.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
11.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? i
' , 'i.'1'.'; '' ' C'
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ biodegradation was eliminated because it would be effective only for organic
, wastes and not for asbestos removal. !
• Ex .situ biodegradation was eliminated because it would be effective only for organic
wastes and not for asbestos removal. •
• In situ soil flushing was eliminated because asbestos is insoluble aind would not be
removed from the soil.
• In situ vacuum extraction was eliminated because it would be effective only for
volatile organic compounds and not for asbestos removal. '
• Steam stripping was eliminated because it would be effective only for organic
compounds and not for asbestos removal. :
• Radio frequency decontamination was eliminated because it wouM not be effective for
chemicals with boiling points lower than 400 degrees centigrade, such as asbestos.
• In situ vitrification was eliminated because it would be very expensive to transport
specialized equipment to Puerto Rico from United States' mainland.

No innovative technologies were include in the RAAs, therefore no innovative technologies
were eliminated during the three-criteria screening process or during detailed analysis.

. i ' '
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?
', '•-!,'<••
For those RAAs that provided adequate protection of human health and the environment and
attained ARARs, long-term effectiveness and implementability were weighted most heavily in
selecting a remedy.
-3-
129
-------
12. What cleanup goals -were selected? If the cleanup goal was based on an ARAR, whait was that
ARAR? What risk level was selected to establish cleanup goals? i
Contaminant
Cleanup Level (%)
ARAR or Other Basis'
Carcinogens
Asbestos
NESHAF
"National Emission Standards for Hazardous Air Pollutants. \

For carcinogens, an excess upper bound individual lifetime cancer risk of between 1014 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? |

Innovative technologies were eliminated primarily because they were not suitable for jthe type
of waste to be treated. No innovative technologies were eliminated because of cleanup goals.
The standard technologies selected could meet cleanup goals. |
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. '
)
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Waste left in place/institutional control
Permanence *
16. How are alternatives compared? !
1 i
Although three alternatives would provide overall protection of human health and the:
environment, the alternative selected would eliminate the risk of long-term exposures!by
removing contaminants from the site, thereby providing a permanent solution. The reliability
of institutional controls in preventing future exposures was questionable. , J
17. What technical considerations were factors in selecting a remedy? Were technical |
considerations primary in the selection of the remedy? ' '

Soil contamination resulted from disposal of sludge and debris in a soil disposal areal(SDA),
which is not in contact with groundwater. (Groundwater contamination resulted from disposal
of contaminants in separate wastewater lagoons.) No surface or subsurface migration of
130
-4-
-------
asbestos from the SDA was noted. Beyond the fact that few technolog
treating asbestos, technical considerations were not primary in selecting
at this site.
-5-
;ies are available for
a remedial technology
131
-------
Fort Dix (Landfill Site)

Pemberton Township, New Jersey
Region 2
GENERAL SITE INFORMATION
7.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Waste

Subsurface waste samples in the landfill
were not collected because of the unknown
nature of wastes disposed of at the site.
Waste types are expected to vary greatly in
relation to spatial distribution and time of
disposal. Based on the sampling and
modeling of ground water, the landfill is
believed to be the source of contamination
to the aquifer.
Site History
NPL Proposed:
NPL Final:
FS: i
ROD:
9/14/84 i
7/87 i
7/87 i
2/24/91 !
Background

Federal Facility
PRPs: U.S. Army
FS prepared by: Camp Dresser &
McKee Inc.
i
2.
Wliat volume of material is to be remediated? ' • i

The volume of material to be remediated included: i
' •' ;
• The volume of material to be remediated was not given. The site .covers 126 acres.
3. What type of site is this? .-;.'•

Military. A former landfill located on the U.S. Army's Fort Dix Military Reservation, j

TECHNOLOGY SELECTION '
- [

4. What standard technologies were considered for selection in this FS? , !
I

Standard technologies considered during the identification and screening of technically feasible
technologies were: i

Access restrictions: Fencing, deed restrictions I
Containment: Capping, slurry wall, grouting, sheet piling - '
Chemical treatment: Solidification/stabilization, immobilization , i
132
iol
rl-
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: ,- ;
'.-,'- , '
Biological treatment: In situ bioreclamation |
Chemical treatment: In situ soil flushing, in situ chemical treatment
Thermal treatment: In situ vitrification
What was the cost estimate for the innovative technology? !
- , •'.'•'•• " , •'• ,1 .••'''';••
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the.FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. No innovative technologies were incorporated into
remedial alternatives. ,
How did the cost(s) compare to standard technologies? • . i '

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) :
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-3C
RAA-3Da
RAA-4A
RAA-4B
Standard Technology
No action
Low permeability cap/expanded
monitoring program
Ground water pumping/on-site treatment
Ground water pumping/off-site
treatment
Plume pumping/off-site treatment and
disposal/downgradient slurry wall/
landfill closure
Partial ground water pumping/on-site
treatment
Ground water interception/6n-site
treatment
Ground water interception/off-site
treatment
Estimated Costs
3 Criteria
|N/A
^N/A
!
i
'i
IN/A " •
IN/A
eliminated
\
•{'N/A;
i
IN/A'
I N/A
i
9 Criteria
$8,400,000
$15,100,000
$28,100,000
$32,900,000
eliminated
N/A
$31,900,000
$36,800,000
' '
a This alternative was developed in the ROD and no present worth cost was estimated.
•' - i \
1
: ' -2- ;'. '. J. ' . ..'•'•..'
133
-------
I
5. If a standard technology was chosen, why? j

The chosen alternative, a low permeability cap, was preferred because it reduces siteirisks by
eliminating direct contact with waste materials in the landfill. Additionally, fencing arid deed
restrictions limit opportunities for contact with on-site soil and grading inhibits erosion and the
transport of contaminants in runoff. The cap also will reduce leaehate formation by limiting
the infiltration of rain water through the landfill. Subsequently this will reduce the rate of
contaminant discharge to ground water and surface water. The chosen alternative, thus,
reduces the mobility of contaminants, minimizes short-term risk, and is the most simple to
implement of all of the proposed alternatives. The chosen alternative meets remediation goals
as quickly as the other alternatives, will not produce residuals that require further treatment or
disposal, and is cost-effective. [
. i ."

9. If an innovative technology was chosen, why? j

An innovative technology was not chosen. i
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? - |.
•!•'.-•

Innovative technologies could be eliminated from the remedial technology selection pjocess at
three stages: during the initial screening; during the screening of the three criteria of:
effectiveness, implementability, and cost; or during the detailed evaluation.
[
. t ' I
Innovative technologies eliminated during the initial screening include the following: !
- - i
• In situ bioreclamation was eliminated because microorganisms that effectively:
synthesize volatile organics to harmless byproducts have not been identified. Aerobic
organism that breakdown halogenated organics have not been identified. Anaerobes
are suspected of converting DCE to vinyl chloride a more toxic compound. Ambient
soils are not homogenous enough to ensure the distribution of "reactants." Numerous
organic food sources would compete with contaminants for biodegradation
Bioreclamation systems would be "frustrated" by the inability to maintain and Imonitor
the distribution of reactants throughout the waste. No full-scale field systems have
been demonstrated in similar hydrogeological systems. •
• In situ vitrification was eliminated because it has not been reliably demonstrated, and
there is uncertainty regarding energy consumption, long-term degradation, andlle'aching
potential. . ' . 6
• In situ soil flushing was eliminated because the hydrogeological and geochemical
nature of the site would preclude the effective delivery of reagents to the contaminants
The progress and effectiveness of the chemical process could not be forecasted or
monitored with confidence, Introduction, control, and formation of potentially!
hazardous substances into the subsurface system could exacerbate the current i
conditions. Performance of full-scale systems has not been adequately demonstrated.
The process would produce a high volume of liquid waste that would require treatment
before disposal. - ' • • .
" In situ chemical treatment was eliminated for the same reasons (except the generation
of liquid waste) as in'situ soil flushing. . !
134
-3-
-------
Innovative technologies eliminated during the screening of the three criteria include the
following:

• None '. . .' - - . ..-•' ;' "" .

Innovative technologies eliminated during the detailed analysis include the following:

• None ' •
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted criterion in the selection of a'remedial alternative was protection of
human health and the environment. The chosen alternative will provide as much protection as
the other alternatives that propose containment and ground water treatment. Ground water
treatment would not provide additional health benefit over landfill capping and closure because
existing site conditions do not pose a significant risk to human health and the environment.
Under present conditions, the total risk to human health in the worst lease scenario is 1 X 10"7.
The estimated cancer risk for future ground water use is, however, greater than the acceptable
range. Capping is believed to be sufficient, since it acts to reduce the infiltration of water
through the landfill and the consequent leachate production. This technique is expected to be
adequate to protect ground water since under existing site conditions the amount of ground
water discharging to surface water is very small and the contamination appears to, be
dissipating through natural processes. .;
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that;
ARAR? What risk level was selected to establish cleanup goals? ;
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens 1
Arsenic
Cadmium
Chromium *
Lead
Nickel
PCBs
Total VOCs
.20
3
100
100
100
1-5
1
i NJDEP
! NJfDEP
; NJfDEP
NJDEP :_ ,
1 NJDEP ' '
: NJFDEP
! NJDEP
l
Noncarcinogens , \
Barium
Copper
400
170
\ NJDEP
' ] NJDEP
135
-4-
-------
13.
Contaminant
Mercury
Silver
Selenium
Zinc
Total cyanides
Cleanup Level (mg/kg)
1
5
4
350
12
ARAR or Other Basis
NJDEP i
NJDEP
NJDEP
NJDEP
NJDEP i
•Based on standards established by the New Jersey Department of Environmental
Protection's Bureau of Industrial Site Evaluation for the evaluation of cleanup plans at
industrial sites under the New Jersey Environmental Cleanup Responsibilities Act.
I

Was the innovative technology eliminated because of the cleanup goals? Could the 'standard
technology meet the cleanup goals? i

Innovative technologies eliminated because of cleanup goals include:

• None ^

Standard technologies eliminated because of cleanup goals include:

• -None . _
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. !
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
16. How are measures compared? j

The chosen alternative was preferred because it meets remediation goals without the use of
treatment. Other alternatives that proposed ground water treatment were deemed unnecessary
and not worth the additional effort and cost. ! .
136
-5-
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17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
This
Excavation of the waste and landfill would not be practical or safe.
consideration precluded the use of many ex situ proposed source treatments
hydrogeologic and geochemical nature precluded the effective delivery
contaminants,.in situ chemical treatment and soil flushing were eliminated
considerations were not, however, primary in selecting a remedy.
-6-
technical
Since the site's
of reagents to the
These technical
137
-------
Frontera Creek

Humacao, Puerto Rico
Region 2
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal contaminants
were:

Soil/Sediments (mg/kg)

Mercury 535
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 180 cubic yards of soil
• 370 cubic yards of sediment
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A ;
8/83 j
4/91 I
9/30/91 ;
Background I

PRP-lead | .
PRP: Revlon Inc. !
FS prepared by: Dynamac Corporation
< i '
3. What type of site is this? • . ~ ' '••

Electrical Equipment. Industrial disposal of manufacturing wastewaters containing mercury
into surface waters. <
TECHNOLOGY SELECTION
• «_ ^ |
I -.
4. What standard technologies were considered for selection in this FS? \

Standard technologies considered during the identification and screening of technically i feasible
technologies were: j
Access restriction:
Containment:
Chemical treatment:

Physical treatment:
Thermal treatment:

Disposal:
Deed restriction, site security i
Single-layer cap, multilayer cap, slurry wall, sheet pilings, barrier walls
Fixation/solidification (cement based, silicate based, sbrbent materials
techniques, thermoplastic techniques, organic polymer processes)
Dewatering, separation-drying beds !
Rotary kiln incineration/multiple hearth incineration, liquid injection,
infrared advanced electrical reactor j
Excavation/dredging, off-site RCRA landfill, on-site RCRA landfill
138
-1-
-------
5. Was an innovative technology considered in the FS? If so, which technology?
' *''..• I
Innovative technologies considered during the identification and screening of technically
feasible technologies were: 1 ' '
- ' • ' " : ! .
Biological treatment: Biodegradation, landfarming ;
Chemical treatment: Soil washing (water or solvent), hydrometallurgical extraction,
oxidation-reduction, soil flushing (water or solvent)
Physical treatment: Soil vapor extraction ;
Thermal treatment: Ex situ low-temperature thermal desorption, in situ vitrification,
pyrolysis " ' • •
What was the cost estimate for the innovative technology? 1

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-6
Innovative Technology
Excavation/on-site thermal desorption/
1 backfill treated soil
Estimated Costs
3 Criteria
N/A '
9 Criteria
$959,000
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
Standard
Technology
No action
Deed restrictions/access restrictions/
monitoring
Excavation/dewatering/off-site disposal
at RCRA facility on mainland USA
Estimated Costs
3 Criteria
N/A -'
N/A
N/A
9 Criteria
$0
$209,000
$562,000-
$730,000
-2-, . ' . • . , ' . ,
139
-------
Alternative
RAA-4
RAA-5
RAA-7
Standard Technology
Excavation/chemical fixation/off-site
disposal at RCRA facility on mainland
USA
Excavation/on-site solidification/fixation
Remove existing water/cap/single layer
clay liner/revegetation
Estimated Cbsts
3 Criteria
N/A
N/A
N/A
9 Criteria
$661,000-
$871,000
$461,000
$442,000
8. If a standard technology was chosen, why? ;

RAA-3 was chosen because it offers protection to human health and the environment/meets
all ARARs, reduces the mobility of site contaminants, provides permanence and long-term
effectiveness, and is cost-effective. RAA-1 and RAA-2 were eliminated because they, did not
ensure protection to human health and the environment and they were not in compliance with
ARARs. Alternative RAA-4 was very similar to the chosen alternative except for the'addition
of off-site treatment, which increased the expense and reduced cost-effectiveness withbut
increasing protectiveness. RAA-5 also offered a reduction in toxicity through treatment;
however, its long-term effectiveness was considered uncertain because future intrusive activity
at the disposal site could result in a contaminant release. RAA-6 offered a reduction jn
toxicity and mobility through an innovative treatment; however, it was eliminated because it
would require an extensive treatability study that would increase the design time of the remedy
and it was more costly. The containment cap proposed in alternative RAA-7 was eliminated
because it was not a permanent solution and would require long-term maintenance, i \
)
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? \
i

Innovative technologies could be eliminated from the remedial technology selection at three
stages in the process: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. !

Innovative technologies eliminated during the initial screening include: • I

• Pyrolysis was eliminated because emissions of metals mat volatilize below 2000° F
would be difficult to remove using conventional air pollution equipment. Elements
cannot be broken down to non-hazardous compounds using thermal treatment, j
• Soil washing was eliminated because its effectiveness with soils and sediments I
contaminated with low levels of mercury has not been demonstrated. ! '
• Hydrometallurgic extraction was eliminated because its effectiveness for use with low
concentrations of heavy metals has not been demonstrated. In addition, there

-3- . -. .
-------
concern that toxic gases would be generated during the process.
• Oxidation-reduction was eliminated because it is not applicable to the wastes found at
this site. .
• Biodegradation was eliminated because the presence of heavy | metals such as mercury
were expected to be toxic to the microorganisms utilized in the process.
• Landfarming was eliminated because the presence of heavy metals such as mercury
were expected to be toxic to the microorganisms utilized in the process.
• Soil flushing was eliminated because it would be very difficult to ensure the required
contact betweeri the flushing agent and the contaminated media in place.
• Soil vapor extraction was eliminated because it is not applicable to inorganic
contamination. :
• In situ vitrification was eliminated because its effectiveness has not been well
demonstrated, it is not applicable to large volumes, and there would be excessive
power requirements due to the high moisture content of soils, which would greatly
increase cost. :
•' • • . : ' - - '
No innovative technologies were eliminated during the three-criteria screening process.
• • ' •!'• • • - ' • ,
Innovative technologies eliminated during the detailed analysis include:
v * '• • .
,• Thermal desorption, RAA-6, was eliminated because it would require an extensive
treatability study, which would increase the design time of the remedy. In addition,
RAA-6 was more costly than the selected remedy. •>
11.
Which of the nine criteria were weighted-most heavily in selecting the
the nine criteria eliminate the innovative technology from being chosen?
Which of the criteria supported the use of a standard technology?
For those alternatives that were protective of human health and the environment
ARARs, the criteria most heavily weighted in remedial technology selection
effectiveness, and short-term effectiveness.
12.
What cleanup goals were selected? Jf the cleanup goal was based on
ARAR? What risk level was selected to establish cleanup goals?
an ARAR, what was that
Contaminant
Non-Carcinogens
Mercury
Cleanup Level (ppm)

35 ppm
ARAR or Other Basis

!Risk
As there are currently no ARARs for mercury, cleanup levels were developed
soil/sediment concentration that would not result in an unacceptable hazard
the baseline risk assessment. A Hazard Index (HI) less than or equal to
-4-
techhology? Did one of
Jf so, which one?
and attained
were long-term
to estimate the
using the results of
1.0 was acceptable.
141
-------
13. Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was chosen, could it meet the cleanup goals? \ .
i •. . -• .J-
Innovative technologies were eliminated primarily because they were not considered [suitable
for the types of waste present at the site. No innovative technologies were eliminateid because
of cleanup goals. The standard technology selected could meet cleanup goals at the site.
• ' • \ ..*•••• =r
14. Were treatability studies conducted on the innovative technology or standard technolpgy? ,

No treatability studies were conducted. '. • j -
15. What measures/criteria were used to compare alternatives? '

The following measures were used to compare the alternatives; \

Cost effectiveness I
Waste left in place/institutional control !
Time to design I

- ' -• -. - | . ' •
i .
16. How are alternatives compared? . \ , '
" i
Cost effectiveness was determined by comparing the level of protectiveness achievedj with total —^_
cost. RAA-4 was eliminated because the addition of chemical fixation prior to off-silte ^Of }
disposal would increase costs but not increase protectiveness. Alternatives that left Waste on
site, such as fixation and capping, were considered to be less permanent than alternatives that
removed or treated wastes. Alternatives that required treatability studies, such as thermal
desorption, increased the time needed to design the remedy and decreased their shortj-term \
effectiveness. . ..•'•'. ••'• -
i " • rr- •
i :','
' I ' • ..'•'•
77. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
i ' •
The only technical characteristic that affected technology selection was that the high moisture
content of the contaminated soil/sediment resulted in the elimination of in situ vitrifie'ation as a
potential remedial technology. Technical considerations were not, primary in the selection of a
remedial alternative at this site. , i
r
142
-5-
-------
Garden State Cleaners
(same FS and ROD as South Jersey Clothing)

Minotola, New Jersey
Region 2
GENERAL SITE INFORMATION
1.
What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

Tetrachloroethylene (PCE)
Trichloroethylehe (TCE)
1.300
6.1
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
Bad
EPA Fund-lead
PRPs: Garden State
Clothing Company
FS prepared by: Ebasco
Incorporated
2. What volume of material is .to be
remediated?

• The volume of material to be remediated
included:

• 200 cubic yards of soil
3. What type of site is this?

Dry Cleaning. An active dry cleaning facility.

TECHNOLOGY SELECTION -

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screenu g of technically feasible
technologies were:
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal: •
Fencing, deed and zoning restrictions
Soil cap, multimedia cap, asphalt cap, concrete cap
Ex situ or in situ fixation
Incineration
Excavation, disposal at a RCRA facility, backfill treated soil
-1-
.. 1988
3/89
8/12/91
9/26/91
ground
Cleaners, South Jersey
ly
Services
143
-------
Was an innovative technology considered in the FS? If so, which technology? '

Innovative technologies considered during the identification and screening of technically
feasible technologies were: ;

Biological treatment: In situ bioremediation ]
Phys/Chem treatment: Soil washing, soil flushing, in situ soil vapor extraction |
Thermal treatment: Pyrolysis, low temperature thermal desorption, wet oxidation,
vitrification
6, What was the cost estimate for the innovative technology? i

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs ^ere
formulated, costs were estimated during evaluation by the nine criteria established by ithe NCP.
The estimated costs were recalculated in the ROD. •'!
• i
Cost Estimates for RAAs That Include Innovative Technologies ,
(selected remedial alternative is in bold) ;
Alternative
RAA-SC-2
RAA-SC-3
RAA-SC-4
Innovative Technology
In situ soil vapor extraction
Excavation, low temperature thermal
desorption, backfill treated soil
Soil flushing
Estimated Costs
9 Criteria
$191,000
$220,000
$73,000
ROD
$649,000
$1,198,000
i
i • . •
$167,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SC-1
RAA-SC-5
Standard Technology
No action
Excavation, off-site disposal, backfill with
borrowed material
Estimated Costs
9 Criteria
$0
$850,000
ROD
$l,7bo,000
$5,890,000
5. If a standard technology was chosen, why?

A standard technology was not selected.
144
-2-
-------
9. If an innovative technology was chosen, why?

All RAAs, except RAA-SC-1-'(No Action), would protect human health and the environment
and attain ARARS. The selected alternative, RAA-SC-2 (SVE for soils), was selected because
it permanently reduces the level of contaminants in soil through treatment, is readily
implementable, and creates no short-term risks. RAA-SC-3 (thermal desorption) was
comparable to the selected alternative for most criteria, but would be more costly, create short-
term risks by excavation, require significant soil preparation, and require numerous approvals
to construct and operate the mobile thermal unit. RAA-SC-4 (soil flushing) was eliminated
because it would temporarily increase mobility of contaminants, increasing short-term risk, and
was less implementable because of potential monitoring problems. Alternative RAA-SC-5
(off-site landfill) offered maximum protection of human health but had the greatest short-term
risk to the community, short-term environmental impact, and cost. ,| '

10. If an innovative technology was not chosen, why not? At what stage'was the innovative
'. technology eliminated? • !

; Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the ^three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. . ,

Innovative technologies eliminated during the initial screening include:

• In situ bioremediation was eliminated because the technology is difficult to control.
Nutrients and oxygen must be distributed to an area where contaminants are not
' uniformly distributed. There was also concern that residual dontaminant levels would
not be low enough to meet ARARs. Further, when TCE and|PCE biodegrade, vinyl
chloride (another toxicant) is produced. \
" Soil washing was eliminated because it would be difficult to implement and because it
' generates relatively large quantities of waste that must be treated or disposed of. "
• Pyrolysis was eliminated because it has not been used in commercial applications,
considerable waste stream pre-processing is required, and it is best applied to highly
toxic organics. I •
• Vitrification was eliminated because it is usually used for less mobile inorganic or
mixed wastes. ' • - ' - . | .
• Wet oxidation was eliminated because it is not applicable to inon-pumpable soil. , '

No innovative technologies were eliminated during the three-criteria screening process.
" . ' '',''"'.-''
Innovative technologies eliminated during the detailed analysis include: ,
. • i „ , . •'
» Low temperature thermal desorption was eliminated because;it v/as not cost effective.
It was considerably more expensive than the selected technology without providing
additional protection to human health and the environment. !In addition, it would
; create short-term risks by excavation, require significant soil (preparation, and require
numerous approvals to construct and operate the mobile thermal unit.
• Soil flushing was eliminated because it would increase contaminant mobility, causing .
VOCs to be released into the aquifer and necessitating additional remedial action. In
addition, it was considered less implementable because of potential monitoring
problems.

- -•• ' ' ; - • '••-••' • . '' !-' •'•'-. " : - •'••' 145
• . - -3- ,.'.•'. . • • - ' '
-------
11.
Which of the nine criteria were weighted most highly in selecting the technology? Did one of
the nine criteria eliminate the innovate technology from being chosen? If so, whic*h one?
Which of the criteria supported the use of a standard technology? , - ;

For the alternatives that were protective of human health and the environment and attained
ARARs, the most heavily weighted criteria were long-term effectiveness, short-term •
effectiveness, and cost effectiveness.
72.
13.
14.
8°al,SWere selected? Vthe cleanuP goal was based on an ARAR, what was that
What risk level was selected to establish cleanup goals? i

In the absence of any existing chemical-specific ARARs for soil, the New Jersey Department
of Environmental Protection (NJDEP) established Interim Soil Action Levels for VOCs in
soil. EPA regards this action level as a "to-be-considered" requirement. As such it can be
used in determining the necessary level of cleanup for the protection of human health' and the
environment. !
Contaminant
Cleanup Level (ppm) ARAR or Other Basis
Carcinogens
ICE
PCE
NJDEP
NJDEP
For carcinogens an excess upper bound individual lifetime cancer risk of between 10^ to lO'6
was acceptable. For non-carcinogens a Hazard Index less than or equal to 1.0 was acceptable.

Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was chosen, could it meet the cleanup goals? i

In situ bioremediation was eliminated because of concerns that it may not be able to riieet
established cleanup levels. A standard technology was not selected for soils at this site.

' ' ' : I •
Were treatability studies conducted on the innovative technology or standard technology?
. ' • -I
No treatability studies were performed at this site, although a treatability study performed at
the Nascohte Corporation, a site with similar soil conditions, was used to develop the
preliminary design system. • :
75.
146
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Impact on nearby populations
Total cost . .

-4-
-------
16. How are alternatives compared?
17.
While all of the action alternatives would ultimately protect human
environment, soil flushing would temporarily increase the level of risk
from the soil would be flushed into groundwater. Off-site disposal
thermal desorption would impact nearby populations because excavation
contaminated soils could potentially result in the generation of dust
remedy, soil vapor extraction, would be less costly than off-site dispoi
desorption. Although soil vapor extraction would be more costly thari
preferred because it would not mobilize contaminants and cause them
groundwater.
health and the
because contaminants
I low temperature
aind transport of
d vapors. The selected
al iind thermal
soil flushing, it was
to enter the
What technical considerations were factors in selecting a remedy?
considerations primary in the selection of the remedy?.
Were technical
Soils at the site are mostly sandy, depth to the water table is about 25
topography is flat with little or no surface runoff. The granular naturi
low moisture content in the vadose zone, and organic nature of the
particularly amenable to the application of soil vapor extraction. Also
a mixed residential and commercial area; therefore, the impact on
significant consideration. Technical considerations could be considered
selection of remedy at this site.
feet, and^the surface
of the soil, relatively
contaminants were
>, the facility is located in
populations was a
primary in the
nearby
-5-
147
-------
General Motors (Central Foundry Division)
QU-1
i- . . • i
Massena, New York
Region 2
GENERAL SITE INFORMATION
1.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil/Sludge (rag/kg)

PCBs
Phenols
31,000
5,000
Sediments (mg/kg)

PCBs ' 5,700
Site History
NPL Proposed;
NPL Final:
FS:
ROD:
N/A
9/83
11/21/89
12/17/90
Background

PRPJead
PRPs: General Motors
FS prepared by: RMT, Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated.included:

• 253,000 cubic yards of PCB-containing materials (soil, sludge, and sediment)

3. What type of site is this? •- / - '

Fabricated Metal Products. An active aluminum casting plant.

TECHNOLOGY SELECTION '

4. What standard technologies were considered for selection in this FS?
Standard technologies considered during the identification and screening of technically feasible
technologies were:

Capping (concrete, asphalt, in situ soil admixtures, sprayed on, soil,
synthetic membrane, composite cover)
Chemical So1idifir.atinn/fiY5it!«r> ;
, Containment:
148
synthetic membrane, composite
Chemical treatment: Chemical solidification/fixation
Physical treatment: Physical separation "
Thermal treatment: Incineration (rotary kiln, circulating bed, infrared)
DlsP°sal: Excavation and disposal off site, construction of facility on site
-1-
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: :

Biological treatment: In situ biodegradation, ex situ bipdegradation
Chemical treatment: Dehalogenation, chemical extraction 1
Thermal treatment: Thermal extraction ;
What was the cost estimate for the innovative technology? •",;"'
/, t * , i • • - . • - t
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation., The
estimated costs then are recalculated during an evaluation based on niine criteria established by
the NCP: long-term effectiveness and permanence; short-term effectiveness; compliance with
ARARs; protectiveness of humam health and the environment; reduction in contaminant
mobility, toxicity, or volume; implementability; cost; state/support agency acceptance; and
community acceptance.
Cost Estimates for FLA As That Include Innovative Technologies
(selected remedial alternative is in bold) j
Alternative
RAA-6A
RAA-6B
RAA-6C
RAA-6E
RAA-7A
RAA-7B
RAA-7C
RAA-7E
RAA-8A
RAA-8B
innovative Technology
Solids excavation/biodegradation
Solids excavation/dehalogenation
Solids excavation/chemical extraction
Solids excavation/thermal extraction
Sediment dredging/biodegradation
Sediment dredging/dehalogenation
Sediment dredging/chemical extraction
Sediment dredging/thermal extraction
Soil/in situ biodegradation
Sediment/in situ dechlorination
Estimated Costs
3 Criteria
$102,000,000
$295,000,000
$210,000,000
$296,000,000
$7,100,000
.$15,000,000
$12,000,000 *'
$15,000,000
. N/A
$360,000
9 Criteria
$102,000,000
$295,000,000
$210,000,000
$296,000,000
$7,100,000
$15,000,000
$11,700,009
$15,000,000
eliminated
$360,000
-2-
149
-------
7.
How did the cost(s) compare to standard technologies?

Cost Estimate- ?or RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2A
RAA-2B
RAA-3A
RAA-3B
RAA-4
RAA-5
RAA-6D
RAA-6F
RAA-7D
RAA-7F
RAA-9A
RAA-9B
RAA-10A
RAA-1 OB
RAA-11
Standard Technology
No action
In situ containment with soil cover
In situ containment with composite
cover
In situ containment of river sediment
with graded filter •;
In situ containment of river sediment
with graded filter and sheet pile
Ground water recovery and treatment
Ground water containment
Solids excavation/thermal destruction
Solids excavation/solidification
Sediment dredging/thermal destruction
Sediment dredging/solidification
Solid excavation/off-site landfill
Solid excavation/off-site incineration
Sediment dredging/off-site landfill
Sediment dredging/off-site incineration
On-site disposal
Estimated Costs
3 Criteria
$1,300,000
$6,200,000
$10,000,000
$3,600,000
$4,500,000
$3,900,000
$7,600,000
$339,000,000
$146,000,000
$17,000,000
$9,000,000
$322,000,000
$2,680,000,000
$15,000,000
$112,000,000
$46,000,000'
$1,260,000
$6,200,000
$12,700,000
$3,610,000
eliminated
$3,870,000
$7,600,000
$339,000,000
$146,000,000
$17,000,000
$8,900,000
eliminated
eliminated
eliminated
$45,560,000
8. If a standard technology was chosen, why?

A standard technology was not chosen^
9. !f an innovative technology was chosen, why? \

Excavation of sludge, soil and sediment, dewatering, and treatment by ex situ bioremediation
another equivalent treatment or incineration based on treatability test results. This remedy was
selected because: 1) it offers a permanent solution utilizing an innovative technology i) New
York States preference for permanent remedies is met, 3) Mohawk Tribes primary concern for
expeditious cleanup that supports removal of contamination from the Reservation and control
150
-3-
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I . - , .
of further migration of contaminants from the GM site onto the Reservation, 4) reduces PCB
toxicity and volume as opposed to addressing only mobility, 5) cost of biprernediation
compared to other treatment, 6) available commercially. |

JO. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? \

Innovative technologies eliminated during the initial screening include the following:

• No innovative technologies were eliminated in the initial screening.

Innovative technologies eliminated during the screening of the three criteria include the
following: , i

• In situ biodegradation was eliminated because no in situ PCB bipremediation projects
are completed on a scale comparable to that'required at this site;! there are large
volume of soil containing PCB at depth up to 30 feet and the water table is below
waste in many areas making it difficult to establish hydraulic control of the process;
heterogeneity of waste and soil may make it more difficult to achieve a high level of
treatment effectiveness. !

Innovative technologies eliminated during the detailed analysis include the following:

• Dehalogenation, chemical extraction, and thermal extraction we're not selected as the
' treatment alternative of choice because they would cost more than biodegradation.
However, they have not been eliminated entirely. Treatability sifudies will be used to
determine if biodegradation is effective. If biodegradation is proved to be ineffective,
other innovative technologies will be tested for implementation, i

77. Which of the nine criteria were weighted most heavily in selection of the technology? Did
failure to meet one of the nine criteria result in the elimination of the innovative technology?
If so, which criterion? Which of the criteria supported the use of a standard technology?

The most important factors in determining a remediation alternative were reducing contaminant
levels with a cost-effective, long-term, and permanent solution and state acceptance. A
treatment technology was preferred over containment, and biodegradation was the least
expensive treatment technology available. j
-4-
151
-------
72.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? \
-.'... | •'
Soil/Sludge ', I
Sediment
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens !
PCBS—St. Regis
Mohawk Indian
Reservation
PCBs — GM facility
Phenol
1
10
50
EPA PCB Guidance ;
and St. Regis Mohawk
regulations :
EPA PCB Guidance ;
and EPA Risk
Assessment
RCRA !
nt
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
PCBs — St. Lawrence
and Raquette Rivers
PCBs — Turtle Creek
1
0.1
i
Federal and NY 1
Interim Sediment i
Quality Criteria i
St. Regis Mohawk !
regulations3 i
Turtle Creek is located on St. Resgis Mohawk Indian Reservation. This cleanup level
is based on St. Regis Mohawk regulations. i

The EPA risk assessment determined that 10 ppm PCB in soil at the GM facility wais
protective of the Mohawk population. EPA also determined that cleanup goals for St.
Lawrence and Raquette River sediments corresponded to a 4 x 10"5 excess cancer risk.
i
i .. . •
For carcinogens, an excess upper bound individual lifetime cancer risk of between lO"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? j
. - . i ,
Innovative technologies eliminated because of cleanup goals include: :

• None • •-• ' i
152
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Standard technologies eliminated because of cleanup goals include: ! N

•.. 'None' . - ' ..•'•". . 'I''.' . , -

'• . " 'r " '

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. Treatability studies will be conducted, however, prior
to implementation of biodegradation. If biodegradation is not effective, treatability studies will
be conducted on.other innovative treatment technologies. • ' •>
'I

75. What measures/criteria were used to compare alternatives? }

The following measures were used to compare the alternatives: !

- Cost-effectiveness i ,
- Preference for treatment (vs. containment) I

16. How are measures compared? i

The chosen alternative utilizes an innovative treatment technology (biodegradation) to
remediate site contaminants. Source treatment was preferred over containment because it
reduces PCB toxieity and volume and not just mobility and therefore provides a permanent
and long-term solution. This solution was considered cost-effective even though it is more.
expensive than other alternatives because it provides increased protection. The effectiveness of
biodegradation will need to be tested prior to implementation. If biodegradation proves to be
ineffective, other treatment technologies will be tested. Incineration will be used only if all
other treatment options fail treatability testing. The use of incineration 'was avoided because
the public viewed it as the least preferred treatment technology. ' \
, i • •

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? \

While EPA plans to address all site contaminants during the cleanup, PCBs drove the remedy
selection process. Moreover, because PCBs are persistent in the environment, there was a
significant emphasis on reducing their toxieity and volume through treatment, as opposed to
reducing their mobility through containment. This consideration was primary in selecting a
remedy. • .". < "••-..
i 153
-6- ' !• • : • •
-------
General Motors (Central Foundry Division)
OU-2

Massena, New York
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal .
contaminants were:
i

Soil/Sludge/Debris (mg/kg)
2.
PCBs
Phenol
41,000
11,000
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/83
11/21/89
3/31/92
What volume of material is to be
remediated?

The volume of material to be remediated'
included:
598,000 cubic yards of soil, sludge, and debris
Background

PRP-lead
PRPs: General Motors
FS prepared by: RMT, Inc.
3. What type of site is this? . j

An active manufacturing facility with several waste areas. This ROD addresses the East
Disposal Area and the Industrial Landfill on the site. Land use in the surrounding are!a
consists of mixed residential and industrial uses. i
TECHNOLOGY SELECTION . ;
• • . • i . '
4. What standard technologies were considered for selection in this FS? j
' - • " I
Standard technologies considered during the identification and screening of technically feasible
technologies were: i
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
154
Fencing, security
Cap (soil cover, composite cover), grading drainage control
Solidification
Incineration
Excavation, off-site/on-site disposal
-1-
-------
Was an innovative technology considered intheFS? If so, -which technology?
: - '- . ' \
For this site innovative technologies were considered in the ROD. !
' ' 'i •
Biological treatment: Biological treatment > "
Chemical treatment: Chemical dechlorination (KPEG), chemical extraction (BEST)
Thermal treatment: Thermal extraction (Taciuk process) ]
o
What was the cost estimate/or the innovative technology? ; •
1 r ' ' .
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Ajfter the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs are then recalculated during an evaluation based on ninie criteria established by
the NCP. The RAAs were changed in the ROD and therefore are presented separately.
i ' '
Cost Estimates for RAAs That Include Innovative Technologies '
(selected remedial alternative is in bold) :

Soil/Sludge/Sediment
Alternative
RAA-6a
RAA-6b
RAA-6c ^
RAA-6e
RAA-7a
RAA-7b
RAA-7c
RAA-7e
RAA-8a
i
Innovative Technology
Solids excavation and biological
treatment (Envirogen, Inc.)
Solids excavation and chemical
dechlorination (KPEG)
Solids' excavation and chemical
extraction (Basic Extraction Sludge
Treatment, BEST)
Solids exqavation and thermal
extraction (Taciuk process)
Sediment dredging and biological
treatment (Envirogen, Inc.)
Sediment dredging and chemical
dechlorination (KPEG)
Sediment dredging and chemical
extraction (BEST)
Sediment dredging and thermal
extraction (Taciuk process)
In situ biological treatment (land-based
materials)
Estimated Costs
3 Criteria
$102,000,000
$295,000,000
$210,OQ[),000
$296,000,000
• • i
$7,ioo;oocr
$15,00(1,000
$12,000,000
$15,000,000
i
N/A
|
9 Criteria
$102,000,000'
$295,000,000
$210,000,000
.$296,000,000
$7,100,000
$15,000,000
$12,000,000
$15,000,000
eliminated
-2-
155
-------
Alternative
RAA-8b
Innovative Technology
In situ biological treatment (river
sediments)
Estimated Costs
3 Criteria
$360,000 ,
9C
$3i
riteria
>0,000
East Disposal Area
Alternative
RAA-E3
RAA-E4
Innovative Technology
Excavation/on-site treatment (biological
treatment, dechlorination, chemical
extraction, thermal extraction)*
Mixed treatment (biological treat-
ment, dechlorination, chemical
extraction, thermal extraction)*/
containment
Estimated Costs
ROD
$34,000,000
to
$37,000,000 ;
$24,000,000
to . '
$38,000,000
"This RAA includes treating contaminated materials with one or more of the following
technologies: solidification, incineration, biological treatment, dechlorination, chemic'al
extraction, thermal extraction. Y

Industrial Landfill , :
Alternative
RAA-L3
Innovative Technology
Excavation/on-site treatment (biological
treatment, dechlorination, chemical
extraction, thermal extraction)* of
contaminated materials in landfill
Estimated Costs
ROD
$61,000,000
to
$203,000,000
'This RAA includes treating contaminated materials with one or more of the following
technologies: solidification, incineration, biological treatment, dechlorination, chemickl
extraction, thermal extraction. •
156
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7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
,RAA-2a
RAA-2b
RAA-3a
RAA-3b
RAA-4
RAA-5
RAA-6d
RAA-6f
RAA-7d
RAA-7f
RAA-9a
RAA-9b
RAA-lOa ,
RAA-lOb
RAA-1 1

Standard Technology
No action
In situ containment (soil cover) of
solids
In situ containment (composite cover)
of solids
In situ containment of river sediments
(graded filter)
In situ containment of river sediments
(graded filter and sheet pile wall)
Ground water recovery and treatment
Ground water containment
Solids excavation and incineration
Solids excavation and solidification/
chemical fixation
Sediment dredging and incineration
Sediment dredging and solidification/
chemical fixation
Solids excavation and off-site
management (secure chemical landfill)
Solids excavation and off-site
management (thermal destruction
facility)
Sediment dredging and off-site
management (secure chemical landfill)
Sediment dredging and off-site
management (thermal treatment
facility)
On-site disposal
Estimated Costs
3 Criteria
$1,300,000
$6,200,GOO
$io,ooo,poo
$3,600,000,
$4,500,000 ,
$3;900,000
$7,600,000
$339,000,000
$146,000,000
$17,000,!000
$9,000,1300
$322,000,000
$2,680,000,000
$15,000,000
$112,000,000
I
$46,000,000
9 Criteria
$1,300,000
$6,200,000
" $12,700,000
.$3,600,000
eliminated
$3,900,000
$7,600,000
$339,000,000
$146,000,000
$17,000,000
$9,000,000
eliminated
eliminated
eliminated
eliminated
$46,000,000
-4-
157
-------
East Disposal Area
Alternative
RAA-E1
RAA-E2
RAA-E3
RAA-E4
RAA-E5
======
Standard Technology
No action
Capping/ground water containment
Excavatibn/on-site treatment
(incineration, solidification)*
Mixed treatment (incineration,
solidification)*/containment
Excavation/on-site disposal
'
Estimated Costs
ROD
$2,000,000
, $9,000,000
to
$11,000,000
$34,000,000
to
$37,000,000
$24,000,000
to
$38,000,000
$27,000,000
'This RAA includes treating contaminated materials with one or a combination of the I
following technologies: solidification, incineration, biological treatment, dechlorinatiori
chemical extraction, thermal extraction. ''

Industrial Landfill
Alternative
Standard Technology
Estimated Costs
ROD
RAA-L1
No action
$2,000,000
RAA-L2
Capping/ground water containment
$9,000,000
to
$11,000,000
RAA-L3
Excavation/on-site treatment
(incineration, solidification)* of
contaminated materials in landfill
$61,000,000
to
$203,000,000
RAA-L4
Excavation/on-site disposal
This RAA includes treating contaminated materials with one or a combination of the !
following technologies: solidification, incineration, biological treatment, dechlorination !
chemical extraction, thermal extraction. '[
15S
-5-
rL7
-------
8. If a standard technology was chosen, why? ;

East Disposal Area ,

Under the selected alternative (RAA-E4 and RAA-L2), non-oily soil >yith PCB concentrations
above 10 ppm and below 500 ppm in the East Disposal Area (approximately 115,000 cubic
yards) will be consolidated, regraded, and contained using a composite cover (RAA-E4). A
containment technology was selected because it can be implemented quickly with moderate
amounts of dust and,therefore has a good deal of short-term effectiveness.

Industrial Landfill
j ' i, • - ,
Under the selected alternatives (RAA-E4 and RAA-L2), the estimated! 424,000 cubic yards of
contaminated material in the Industrial Landfill will be contained with! a composite cover
(RAA-L2). Hotspots containing greater than SOO.ppm of PCBs which] are exposed during
landfill regradmg will be treated in the same manner described below ;for East Disposal Area
contaminants. A containment technology was selected because it can jbe implemented quickly
with moderate amounts of dust and therefore has a good deal of shortrtenn effectiveness.
RAA-L2 involves less materials handling than alternatives which include excavation and
treatment of wastes, and is therefore most easily implemented. !
9. If an innovative technology was chosen, why?

East Disposal Area ;

Under the selected alternative (RAA-E4 and RAA-L2) non-oily soil with PCB concentrations
above 500 ppm, all sludge, and all visibly oily soil (an estimated 59,000 cubic yards of
material) will be excavated and treated to destroy PCBs permanently (RAA-E4). Biological
treatment or an innovative treatment technology will be used wherever EPA determines it to be
viable and implementable. In order to determine the effectiveness of innovative biological
treatment at the General Motors site treatability studies will be performed. At the conclusion
of these studies, EPA will evaluate the effectiveness of biological treatment. Biological
treatment of soil must result in PCB concentrations less than 10 ppm for the treatment to be
considered successful. If any material cannot be treated to meet the treatment residual level
using biological treatment alone, incineration or one of the other innoyative technologies tested
during design which has been demonstrated to achieve site treatment goals will be used.
Preliminary bench-scale tests of site soil by General Motors have demonstrated up to 82
percent reduction of PCBs, from 291 ppm to 52 ppm, after several months of anaerobic and
aerobic biological treatment. In addition, there are indications of successful large-scale
implementation at the French limited site. Biological treatment is most efficient at reducing
toxicity, mobility, and volume of contaminants. New York State has expressed a preference
for permanent remedies, which include the excavation and permanent treatment of the majority
of the PCB mass at the site. The Mohawk Tribe also supports the permanent treatment of all
contaminated material at the site. The Tribe viewed all containment remedies as interim
measures only. Although there are short-term impacts associated whh biological treatment,
these can be mitigated and will not pose an unacceptable risk to the.surrounding community,
General Motors workers, or remediation workers. In addition, biological treatment is the least
, costly of all treatment alternatives evaluated. !
-6-
159
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ^^ "\
' ". ' ' • ! ' . •--*
In the ROD, biological treatment was selected as the first choice to treat contaminated soil and
sludge. If biological treatment does not prove effective, a different innovative technology
(chemical dechlorination, chemical extraction, or thermal extraction) might be implemented at
the site. . !
: ' • i .
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of i
effectiveness, implementability, and cost; or during the detailed evaluation. '<
• ! . ' ' -
Innovative technologies eliminated during the initial screening include the following: I

• None . ' . . . . :
• !'• • • '
t .
Innovative technologies eliminated during the screening of the three criteria include the
following: I
. ., • " 1
• . i • •
• None ; '
j l • . ,
Innovative technologies eliminated during the detailed analysis include the following: '
" ' •''• . i
* Chemical dechlorination (KPEG) was eliminated but no specific reason was given.
The FS states that the reliability of this process has not been fully documented. The
principal uncertainties are the ability to construct processing equipment with a I
throughput adequate to manage the large volumes of material at this site, and'the
treatment effectiveness on site-specific materials. The KPEG process has been: shown
to be effective in the destruction of PCBs on a limited scale. The availability of this
technology for application at the scale required on this site, within the timetable to be
established, is uncertain. [
• Chemical extraction (BEST) was eliminated but no specific reason was given. The FS
states that the effectiveness of chemical extraction has been demonstrated on a limited
scale. The FS further states that the technical feasibility of the BEST process has been
commercially demonstrated, and documented in the U.S. EPA's SITE (Superfund
Innovative Technology Evaluation) project summary report. This technology results in
the production of a PCB-rich extract which requires further treatment. ' •
• Thermal extraction (Taciuk process) was eliminated but no specific reasonwas; given.
The FS states that to date there has been no full-scale demonstration of the Taciuk
process on PCB materials. The reliability of this process has not been fully ;
documented. The principal uncertainties are the ability to construct processing ; •
equipment with a throughput adequate to manage the large volumes of material at this
site, and the treatment effectiveness on site-specific materials. The availability of this
technology for application at the scale required on this site, within the timetable to be
established, is uncertain.
160
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11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
.which criterion? Which of the criteria supported the use of a standard technology?

Soil/Sludge/Debris |

Overall protection of human health and the environment and long-term effectiveness and
permanence were weighted most heavily hi selecting the chosen alternative. The selected
alternative protects human health and the environment through the peiinanent treatment of the
principal threat material in the East Disposal Area and through containment of less
contaminated material. The selected alternative reduces excess carcinogenic health risks to
humans to levels within the acceptable EPA range of 10"4 to W6. The selected remedy
includes excavation and treatment of contaminated materials and is therefore more permanent
and effective over the long-term than remedies which involve containment alone.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? j
Contaminant
Cleanup Level (mg/kg) ARAR. or Other Basis
Carcinogens
PCBs
10
EPA PCB Guidance*
'This cleanup level.is based, in part, on EPA's risk assessment for the alternatives
considered for the site, which indicates that 10 ppm is protective of human health, and
on EPA's August 1990 PGB guidance which recommends soil cleanup levels between
10 ppm and 25 ppm in industrial areas.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ! .
i i '/'','-

Innovative technologies eliminated because of cleanup goals include: j

• " None . i; ' - •

Standard technologies eliminated because of cleanup goals include: < •
!> •"!]',
• '•- ' None . ' • ,"'••'•''.•
"If-'' - \

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. '
181
-------
75.
What measures/criteria were used to compare,alternatives?

The following n sures were used to compare the alternatives:

Cost-effectiveness
16. How are measures compared? *' \
- = ' " i •
' l !
The selected remedy is cost effective because it has been demonstrated to provide overall
effectiveness proportional to its costs. The selected remedy selects an innovative technology1
and, as a last resort, incineration. This is cost effective since innovative technologies are -
generally less expensive than incineration. Mixed treatment/containment is cost effective since
EPA estimates ,t will result in a significant reduction, on the order of 90 percent, in PCB mass
in the East Disposal Area. Treatment of all East Disposal Area material would cost !
substantially more while resulting in treatment of only the remaining 10 percent of the PCB
mass in this area. -
17.
162
What technical considerations were factors in selecting a remedy? Were technical 1
considerations primary in the selection of the remedy? ;

Technical considerations were not primary in selecting a remedy for this site. |
-9-
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Genzale Plating Co.
Franklin Square, New York
Region 2
GENERAL SITE INFORMATION
2.
What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

Trichloroethene 53
Barium 36,400
Chromium 37,300
Nickel 58,000 '
•
,r- -
Site History
i • •
NPL Proposed: N/A
;NPL Final: '! 7/87
FS: 2/91
ROD:/ ; 3/29/91

Background

EPA Fund-lead
PRPs: Genzale Plating Company
FS prepared by: Ebasco Services
Incorporated
remediated?

The volume of material to be remediated included: ;

• 93 cubic yards of soil containing volatile organic contaminants
• 2080 cubic yards of soil containing inorganic contaminants i
3. What type of site is this?

Electroplating.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically
feasible technologies were:
Access restriction:
Containment:
Land-use restrictions, warning signs
Cap (clay, asphalt, synthetic membranes, chemical sealants,
multimedia)
Physical treatment: Mechanical aeration
Chemical treatment: Encapsulation, stabilization/solidification
-1-
163
-------
Thermal treatment: Incineration
Disposal:
Excavation, construction of on-site RCRA landfill, transport to off-
site RCRA landfill
i
Was an innovative technology considered in the FS? If so, which technology? ^ j

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
i
Biological treatment: Biodegradation
Chemical treatment: In situ soil flushing (solvent), in situ hydrolysis, alkali metal1
dechlorination, soil washing (solvent) and extraction, supercritical
fluid extraction ' _ '
Thermal treatment: , In situ vitrification, wet air oxidation, enhanced volatilization
Physical treatment: In situ vacuum extraction I
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) i
Alternative
RAA-SC-3
RAA-SC-4
RAA-SC-5
Innovative Technology
In situ vacuum extraction/in situ
stabilization/solidification/soil cover
In situ vacuum extraction/excavation/ off-
site treatment and disposal/fill with clean
off-site soil
In situ vacuum extraction/surface
excavation of leaching pits/off-site
treatment and disposal/fill with clean
off-site soil
Estimated Costs
3 Criteria
$1,963,200
^ $7,179,700
$1,971,400
9 Criteria
$2,439,300
$8,974,600
1 -
$2,449,500
/-• i
164
-2-
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7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SC-1
RAA-SC-2
Standard Technology
No action
Surface excavation/off-site treatment and ,
disposal/capping
Estimated Costs
3 Criteria
$530,800
$1,464,100
' 1 ' '
9 Criteria
$650,000
$1,815,400
8. If a standard technology was chosen, why? / ,

Off-site disposal of residuals from soil vapor extraction was selected.' See discussion below.
9. If an innovative technology was chosen, why? ;

In situ vacuum extraction for volatile organics followed by surface e)iccavation and off-site
treatment and disposal of excavated material at a Subtitle C facility, was selected for the
following reasons: 1) removing the source to stop further groundwater contamination, 2)
would eliminate direct contact (site located in residential area), 3) liniited space on-site for
other treatment methods,, 4) commercially available technology and disposal facilities
(although limited), 4) easy to implement, 5) cost of removing "hot spots" versus entire site,
6) soils are optimum for in situ SVE, 7) long term effectiveness. ;
10. If an innovative technology was not chosen, why? At what stage was\the innovative
technology eliminated? >

Innovative technologies could be eliminated from the remedial technology selection process
at three stages: during the initial screening; during the screening of liie fihree criteria of
effectivenesSi implementability, and. cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Wet air oxidation was eliminated because it is primarily used! for pretreating complex
organics for subsequent biological treatment. This technology is suitable for treating
pumpable aqueous and sludge wastes and is not recommended for treating large
volumes of dry contaminated materials. Soil would have to Ibe slurried. This
technology would require a large area for on-site treatment that is not available at the
. .
Enhanced volatilization was eliminated because it is not effective for treatment of
metals and space limitation would not permit on-site treatment.
Alkali metal dechlorination was eliminated because APEG is used for the treatment
of chlorinated compounds, primarily PCBs and the contaminants of concern are not
PCBs but VOCs and metals. Demonstration of APEG has nbt been effective in

' ,'• • -3- . - ' ::
165
-------
treating other organics such as VOCs. Also this technology would require a large
area for on-site treatment which is not available at the site. ^^F \
" Soil washing and extraction was eliminated because 1) large volumes of -
contaminated waste water and/or spent extraction solution would be generated, which
would require further treatment, 2) The variety of metals would require a number of
solvents and acids with multiple washing and extraction steps, 3) would require a
large area for on-site treatment, which is not available at the site.
• Supercritical fluid extraction was eliminated because 1) it is not applicable for
removal of metals, 2) it is available from only one vendor and availability of
equipment would therefore be limited, 3) it requires a higher capital cost and
involves more complex equipment than other technologies, 4) space constraints on-
site make this technology impossible to implement.
• Biodegradation was eliminated because: 1) it is a developmental technology for
hazardous waste cleanup, which requires extensive bench and pilot scale testing to
verify its effectiveness, 2) aerobic bioremediation is not demonstrated as effective in
remediating VOCs present at the site, 3) it would require long-term operation,. 4)
elevated levels of metals may have adverse effects on microorganisms, 5)
volatilization of VOCs may occur while mixing and aerating soil. 1
• In situ soil flushing was eliminated because 1) it requires installation of vertical
groundwater barriers which requires reliance on an underlying nonpermeable j layer,
not present at this site, to act as a horizontal barrier, 2) could potentially accelerate
the spread of contamination and force contamination into the lower aquifer.
• In situ-vitrification was eliminated because 1) it is not effective for VOCs because
they migrate laterally during the vitrification process and may escape untreated, 2)
requires exorbitant amounts of electricity, 3) requires large amounts of equipment to
be located on-site for the duration of the operation, 4) site is an active facility located
in a residential area, and 5) it would disrupt existing operations and the residents in
the area. i
• In situ hydrolysis was eliminated because 1) it is in the early developmental stages
and is generally unproven at Superfund sites, 2) requires isolation of contaminated
areas (not possible at this site) due to migration of hydrolysis chemicals and products
in groundwater and making it difficult to capture all of the chemicals and products,
3) not applicable for removal of VOCs and metals present at the site. ! '
.••''• i •
Innovative technologies eliminated during the screening of the three criteria include the
following: | .,
•• • i ••"
• None . i
f
Innovative technologies eliminated during the detailed analysis include the following:!

• None ' • • -, j :
. ' -!._,,

The most heavily weighted criterion was protectiveness of human health and the environment
through long-term and permanent reduction in the toxicity, mobility, and volume of site

186
-4- . -- • . ' v - •
-------
contaminants. Implementability was of major importance because of the small size of the
site. The deciding factor between two equally protective and effective alternatives was cost.

Several of the innovative technologies were eliminated during the initial screening because
they would not remediate the appropriate contaminants or because they were not
implementable given the site's limited space. '
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was
that ARAR? What risk level was selected to establish cleanup goals?

Cleanup goals are low enough so that any leachate generated from the soil would not cause
ground water contaminant concentrations to exceed their corresponding cleanup levels
(MCLs). These concentrations were estimated using a leaching model. Contaminants with no
ground water ARARs would be remediated to background levels.
Contaminant
Cleanup Level (mg/kg)
ARAR or1 Other Basis
Carcinogens !
Trichloroethene
Chromium
0.0084 (FS),
1 (ROD)
6.67
Leaching Model
'i
1
Leaching Model
andMCL
" i
Noncarcinogens , . ,
Barium
Nickel
3,500
30
Bacikground
Bacikground
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? , ' \

Innovative technologies eliminated because of cleanup goals include:

• , None '.-•'' ' ' ! . ;| ,

Standard technologies eliminated because of cleanup goals include: j

• Capping •

- • ;j ' . s

14. Were treatability studies conducted on the innovative technology or 'standard technology?
' ' :!•'.-

No treatability studies were conducted. •
-5-
167
-------
75. What measures/criteria were used to compare alternatives? '
• ' ' •' "' '
The following measures were used to compare the alternatives: i
: • • • . I' -
Cost-effectiveness , (
Preference for treatment (vs. containment)
Impact on nearby populations |

-i
16. How are measures compared? i
i
A source treatment technology was preferred over containment because it offers greater
protection of human health and the environment, long-term effectiveness, and permanence.
Treatment was proposed in three of the five alternatives. The chosen alternative utilized an
innovative treatment and it was chosen because it is the most cost-effective of the three
treatment options. RAA-2 was eliminated because excavation could generate fugitive dust
and vapors, potentially posing a health risk to nearby residents. . . j

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
" I
Protecting drinking water quality was the technical consideration in selecting a remedy. The
site is located over the Upper Glacial aquifer (a nonpotable water source), which covers the
Magothy aquifer, Loop Island's principle water supply. Without a confining layer, the two
aquifers are connected hydraulically. ;
• ' ' . i'
The lack of a confining layer precludes the use of any technology that requires horizontal or
vertical barriers. Both in situ soil flushing and in situ hydrolysis were eliminated since they
actually could enhance the migration of contaminants into the aquifer.
-'''
The proximity of residential homes also was a consideration in choosing a remedy, One
alternative (RAA-SC-2) was eliminated primarily because of the potential risk to residents
from the generation of fugitive dust and organic vapors during excavation. !
"'•--' ( - I ,
These technical criteria were factors in the selection of a remedy but they were not primary.
168
-6-
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Global Sanitary Landfill
OU-1

Old Bridge Township, New Jersey
Region 2
GENERAL SITE INFORMATION

/. What were the principal contaminants,
contaminant levels, and media .addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

No data were collected in the landfill.
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 2,400,000 cubic yards of waste
SitelHistpry
;|
NPL Proposed: N/A
NPL Final: i 3/89 '
FS: L .2/91
ROD: ' 9/11/91

Background

EPA Fund-lead • '
PRPs: Not listed ;
FS prepared by: Killam Associates
3. What type of site is this?

Municipal Landfill. An inactive landfill.
1-
TECHNOLOGY SELECTION !

4. What standard technologies were considered for selection in this FS?i

Standard technologies considered during the identification and screening of technically feasible
technologies were: . .1 ,

Access restriction: Security, fencing ;
Containment: Cap (vegetative cover, NJDEP solid waste, NJDEP hazardous waste,
RCRA, bentonite), slope stabilization j
Chemical, treatment: Stabilization .. . ;
Physical treatment: Leachate management , . •
Disposal: Excavation, off-site disposal ;
169
-i-
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5. Was an innovative technology considered in the FS? If so, which technology?
• - ' : - I '
Innovative technologies considered during the identification and screening of technically
feasible technologies were: |
.'"•-. i-
Biological treatment: In situ bioreclamation . | ,
Phys/Chem treatment: In situ soil flushing
Thermal treatment: In situ vitrification i
What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into remedial alternatives.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
Standard Technology
No action/long-term monitoring ;
NJDEP solid waste cap
NJDEP hazardous waste cap
RCRAcap
Bentonite clay cap
Modified hazardous waste cap
Estimated Costs
3 Criteria
N/Aa
$13,142,000
$23,262,000
$20,202,000
$14,905,000
$15,823,000
9 Criteria
$3,228,000
$13,946,000
$25,365,000
$22,305,000
$15,709,000
$16,627,000
The "no action" alternative was not developed until the detailed analysis stage.
8. If a standard technology was chosen, why?
170
RAA-6 was chosen because of all the proposed alternatives it offers the greatest protection to
human health and the environment. The modified hazardous waste cap proposed in RAA-6

'-2- • - !
-------
will reduce the infiltration of rainwater and thereby reduce the generation of leachate. It will
also provide protection from direct exposure to contaminants. The cap proposed in RAA-6 is
relatively light, which is important given the instability of the side slopes of the landfill. This
cap assures the greatest factor of safety against side slope failure. This alternative can be
implemented easily, and in minimal time. Materials and equipment required for this cap are
readily available. This cap minimizes impact to the nearby wetlands.'' (The ROD also included
solidification/stabilization and off-site disposal as primary remedies.) iOf the alternatives, the
selected remedy affords the highest level of overall effectiveness proportional to its cost and is
therefore the cost-effective alternative. i ••..''•
9. If an innovative technology was chosen, why? -

An innovative technology was not chosen.
" • • i •• . ' •

10. If an innovative technology was not chosen, why not? At what stage vitas the innovative
technology eliminated? 1.'

Innovative technologies could be eliminated from the remedial technology selection process at
' three stages: during the initial screening; during the screening of the fhree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ bioreclamation was eliminated because it would not address'all,site
contaminants. Furthermore, segregation of waste prior to the implementation of this
technique would be required because of the heterogeneous nature of the site?s waste.
• In situ soil flushing was eliminated because it would not address all site contaminants.
Furthermore, segregation of waste prior to the implementation1 of this technique would
be required because of the heterogeneous nature of the site's >jvaste.
• In situ vitrification was eliminated because it would not address all site contaminants.
Furthermore, segregation of waste prior to the implementation! of this technique wpuld ,
be required because of the heterogeneous nature of the site's \yaste. '

Innovative technologies eliminated during the screening of the three ciriteria include the
following: '..'.'..' !

• None • '.,'•''

Innovative technologies eliminated during the detailed analysis include: the: following:

/ • None •. ''. • • • . '• •'. • i .

The criteria that were weighted most heavily in the choice of a remedial alternative were cost
and protection of human health and the environment.

..'. • -" •' • . -3- •• ".' ••'• --I:" ;.;' • • 171
-------
12.
13.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? "
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens '
Total volatiles
Total base neutrals
Arsenic
Beryllium
Cadmium
Chromium
Lead
Petroleum
hydrocarbons
PCBs
1
10
20
1 . • *
3
100
250-620
100
1-5
NJDEP
NJDEP
NJDEP i
NJDEP
NJDEP
NJDEP
NJDEP !
NJDEP
NJDEP
Noncarcinogens ;
Antimony
Copper
Mercury
Selenium
Silver
Thallium
Zinc
10
170
14
4
5.
1
1 350
NJDEP
NJDEP
NJDEP
_ NJDEP
NJDEP .1
NJDEP
NJDEP
«b
"New Jersey Department of Environmental Protection tentative soil action cleanup
levels will constitute TBCs (to be considered) in the absence of State or Federal
ARARs. ;
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None ;
172
-4-
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Standard technologies eliminated because of cleanup goals include: i

• None ,

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
'- - ' ' ' .' 1 . . • '
Cost-effectiveness
Impact to wetlands

'' - - - _ ' J
16. How are measures compared? i
"l
The chosen alternative was preferred because it provided the greatest reduction of infiltration
and the least impact on wetlands. The costs associated with the chosen alternative were
proportional to its superior protection of human health and the environment. Therefore, it was
cost-effective.
17. - What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Two technical considerations were primary in selecting a remedial alternative. The instability
of the landfill sideslopes, which had previously caused the landfill tojcollapse, precluded the
use of a NJDEP hazardous waste cap (RAA-3) or a RCRA cap (RAA-4). Potential impact on
wetlands was another consideration that led to the elimination of two] alternatives (RAA-3 and
RAA-4). ''.'•' '. . .;
.5.
-------
Hertel Landfill

Plattekill, New York
Region 2
GENERAL SITE INFORMATION
minants,
addressed in

rincipal

.--

2
'0.8
1 '
0.9
2
0.4
109
64

Site History 1
NPL Proposed: 10/84
NPL Final: 6/86 - • ;
FS: 7/91 I
ROD: 9/27/91
Background !
i
EPA Fund-lead ! .
PRPs: Not listed
FS prepared by: TAMS Consultants,
Inc. and TRC Environmental
Consultants, Inc. i . „
.' • i

68,100
1. What were the principal contaminants,
contaminant levels, and m<
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediment (mg/kg)

Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Chrysene
Indeno(l ,2,3-cd)pyrene
Arsenic
Chromium
Manganese
2. What volume of material is to be remediated? ]

The volume of material to be remediated included:

• 300,000 cubic yards of soil/waste matrix ! .

3. What type of site is this? ' ' !

Municipal Landfill. A former municipal landfill.

TECHNOLOGY SELECTION ;

4. What standard technologies were considered for selection in this FS? j •

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restriction, fencing
Containment: Capping (clay, synthetic, asphalt, concrete, and multilayer)
Chemical treatment: Stabilization/solidification
Thermal treatment: Incineration (fluidized bed, infrared, and rotary kiln)
174
-i-
-------
Physical treatment:
Disposal:
Mechanical aeration
On-site landfill, off-site landfill
5. Was an innovative technology considered in the FS? If so, which technology?
- I - •
Innovative technologies considered during the identification and screening of technically
feasible technologies were: .

Biological treatment: In situ biodegradation, landfarming j
Phys/Chem treatment: Soil washing (extractant solution), dechlorination, oxidation/reduction,
in situ soil flushing, in situ soil venting j
Thermal treatment: In situ vitrification, radio frequency heating ,
What was the cost estimate for the innovative technology? ,
/ * . ! ; • -
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a,more detailed evaluation. The
estimated costs then are recalculated during an evaluation based cin the nine criteria established
by theNCP. I

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) i
Alternative
RAA-7
i
Innovative Technology
In situ vitrification/ground water
extraction and on-site treatment
Estimated Costs
3 Criteria
$110,000,000
9 Criteria
eliminated
7. How did the cost(s) compare to standard technologies? i,

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) ,' . .
Alternative
RAA-1
RAA-2
RAA-2A
Standard Technology
No action/ground water monitoring
Fencing/deed restrictions/multilayer cap
Fencing/deed restrictions/multilayer
cap/slurry wall
I Estimated Costs
3 Criteria
$2,5(K),000
$7,0()0,030
$1.5iOpO,000
9 Criteria
$2,509,000
. $7,182,000
$13,238,000
-2-
175
-------
Alternative
RAA-3
RAA-4
RAA-4A
.RAA-5
RAA-6
=====
Standard Technology
Excavation of soil and waste/off-site
disposal/ground water extraction and
treatment off site
Fencing/deed restrictions/multilayer
cap/ground water extraction and standard
treatment on site/discharge to surface
water
Fencing/deed restrictions/multilayer
cap/ground water extraction and
innovative treatment on site/discharge
to surface water
Excavation of soil waste matrix/on-site
rotary kiln incineration/ground water
extraction and treatment/surface water
discharge
Excavation of soil waste matrix/off-site
rotary kiln incineration/ground water
extraction and treatment/surface water
discharge
Estimated Costs
3 Criteria
$190,000,000
$8,200,000
$7,900,000
$120,000,000
$510,000,000
9 Criteria
eliminated
$8,744,000
$8,207,000
1
I
i
eliminated
eliminated
gg'j '
8. If a standard technology was chosen, why?

The standard technology selected for this site includes regrading and compacting the landfill
mound to provide a stable foundation for cap placement, and constructing a 13 acre multi-layer
cap over the landfill with an associated gas venting system. The following reasons were given
for selection of this remedy: 1) will minimize infiltration of rainwater and snow melt into, the
landfill and eliminate/reduce leachate seeps emanating from the landfill, thereby reducing the
quantity of water percolating through the landfill materials and leaching out contaminants, 2)
size of the landfill and lack of identified on-site hot spots that represent the major sources of
contamination preclude a remedy in which contaminants could be excavated and treated
effectively, 3) eliminates exposure to surface soil contamination, 4) deed restrictions on use
will eliminate future land use causing exposure and possible compromise of the integrity of the
cap. , ,
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
176
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10. If an innovative technology was not chosen, why not? At what stage vvas the innovative
technology eliminated?
'"•!••
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the; following:

• Soil washing was eliminated because several different washing solutions would be
required to treat all types of soil contaminants.
" Dechlorination was eliminated because it would not be effective for inorganic
contaminants and it would not be applicable to municipal solid waste materials.
• In situ biodegradation was eliminated because it would be ineffective for inorganics
and for large volumes of municipal solid waste materials. ;
• Landfarniing was eliminated because it would be ineffective for inorganic
contaminants and for large volumes of municipal solid waste materials.
• Soil venting was eliminated because it would be ineffective for inorganic contaminants;
• Radio frequency heating was eliminated because it has not been demonstrated on a
large scale or on large volumes of municipal solid waste materials.
• Soil flushing was eliminated because it is only effective for medium solubility organics
and would be ineffective for inorganics, and it would not be; applicable to municipal
solid waste materials. ;

Innovative technologies eliminated during the screening of the three criteria include the
following: , •-,'..•

• In situ vitrification was eliminated because: 1) the effectiveness as applied to a
municipal landfill has not been previously proven, 2) the number of vendors is limited,-
: 3) treatability studies would be required to confirm the effectiveness of these
methodologies prior to design, 3) cost would be high. i

Innovative technologies eliminated during the detailed analysis include the following:
' . ' I .
• None . '••'''••. ' '
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Criteria that weighted heavily in selection of a technology were: 1) implementability - capping
technologies are well developed and reliable; 2) reduction of toxicity, mobility and volume
through installation of a cap - the NCP deems containment remedies; appropriate where
treatment of the waste is impracticable (e.g.5 mixed waste of widely varying composition); and
3) cost. No innovative technologies were included in the detailed analysis, however cost and
implementability eliminated innovative technologies during the .3-criteria screening.
Implementability and cost supported the standard technology.
-t- • •
-------
12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? '
Contaminant
Carcinogens
Benzo(a)anthracene
Benzo(b) fluoranthene
Benzo(k) fluoranthene
Benzo(a)pyrene
Chrysene
Indeno(l,2,3-
cd)pyrene
Cleanup Level (rag/kg)
ARAR or Other Basis

0.26
0.26
0.26
0.26
0.26
0.26
NYSDEC"
NYSDEC
NYSDEC
NYSDEC
NYSDEC
, NYSDEC
Noncarcinogens
Arsenic
Chromium
Manganese
0.06
. 25
2
Risk"
Risk
Risk
"NYSDEC, 1989: Sediment criteria. Bureau of Environmental Protection, Division of
Fish and Wildlife.
"Risk-based cleanup level derived from a future use residential scenario (children)
producing a compound specific hazard quotient of 1.0 or less.
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

No technology could meet the chemical specific ARARs for soils. By designing the final cap
to meet New York Solid Waste Management Facility closure regulations, the alternative will
comply with action specific ARARs.
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. A treatability study is proposed to be carried out
however, prior to the full implementation of the suggested ground water treatment technology.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
178
total cost
waste left in place/institutional controls
proven reliability

-5-
-------
16. How are measures compared? , j .

All proposed source treatment technologies were eliminated because they were not cost-
effective. The construction, operation, and maintenance costs of incineration and in situ
vitrification were considered grossly excessive when compared to their overall effectiveness.
Furthermore, containment technologies were considered appropriate because the landfill
contained mixed wastes. Treatment was considered impractical for wiastes that were not highly
toxic or mobile. The reliability of capping versus undemonstrated technology was considered..
-' 'L '

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Since the site is bordered by wetlands, location-specific ARARs were! a consideration. This
factor did not play a primary role, however, in selecting a remedy. i_
II
' 179
-------
Industrial Latex Corp.
OU-1

Wellington, Bergen County, New Jersey
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and mt
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediments (mg/kg)

PCB Aroclor 1260
Heptachlor epoxide
Arsenic
Beryllium
Lead
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(ghi)perylene
Bis(2-ethylhexyl)phthalate
Chrysene
3,3-Dichlorobenzidine
Ideno(l,2,3-cd)pyrene

Sludge (mg/kg)
minants,
addressed in

incipal

4,000
0.22
49.4
2.2
89.9
13
11
13

Site History
NPL Proposed: 6/88 i
NPL Final: . 3/89 \
FS: 7/92
ROD: 9/30/92
Background

EPA Fund-lead
PRPs: Five PRPs were identified for this
site; however, these were not
named
FS prepared by: ICF Technology Inc.

•• - „ ;
11 - . ' . - ' '
5.1
280
21 •',,*" . - ' •
6
6.4
VOCs
PCBs
Phthalates
Metals
2,800
22,000
5,600
13,000
*:>
2. What volume of material is to be remediated?

The volume of material to be remediated included:

« 32,000 cubic yards of soil
• 2,700 cubic yards of soil and sediments in a drainage channel
" 6 cubic yards of sludges from the septic tanks
130
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3.
What type of site is this?
Rubber and Plastics Products. The Industrial Latex Corporation manufactured chemical .
adhesives, and natural and synthetic rubber compounds from 1951 until 1980. Intermittent
processing of latex compounds continued at the site until October 1983, when all operations
ceased. The property encompasses 9.67 acres in a mixed residential/industrial neighborhood.
TECHNOLOGY SELECTION
: - _ , i
I •"
4. What standard technologies were considered for selection in this FS?

! ' ! \
Standard technologies considered during the identification and screening of technically feasible
technologies were: ,

Access restriction: Fencing, deed restrictions .
Containment: Capping (RCRA cap, multimedia cap, asphalt; cap, soil cap)
Chemical treatment: Stabilization, solids processing :
Thermal treatment: On-site/off-site incineration ' , i ,
Disposal: , Excavation, on-site/off-site landfill J

,j
5. Was an innovative technology considered in the FS? If so, which technology?,

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
r ^- ; ,i - . '
Biological treatment: , Biological-treatment (in situ biodegradation, Land treatment, bioreactor)
Phys/Chem treatment: Solvent extraction, critical fluid extraction, soil vapor extraction, in situ
soil flushing, dechlorination (KPEG) !
Thermal treatment: Low-temperature thermal desorption, in situ vitrification, in situ radio
frequency heating
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) ;
' Alternative
RAAS-4
Innovative Technology
Low-temperature thermal desorption
[Estimated Costs
3 Criteria
N/A
9 Criteria
, $17,100,000
-2-
131
-------
Alternative
RAAS-5
RAAS-6
Innovative Technology
Dechlorination
Solvent extraction
Estimated Costs
3 Criteria
• N/A
N/A
9 Criteria
$16,800,000
$23,700,000
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAAS-1A
RAAS-1B
RAAS-2
RAAS-3
RAAS-7
RAAS-8
Standard Technology
No action
Minimal action
Capping
In situ stabilization
On-site incineration
Off-site landfill
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$83,000
$3,434,000
$7,090,000 '
$11,200,000
$25,300,000
$13,600,000
8. If a standard technology was chosen, why? •','..

The selected remedy includes excavation of the septic system and its transportation off site for
treatment or disposal. No standard technology was selected for remediating on-site soils.
9. If an innovative technology was chosen, why?

The selected remedy RAAS-4 involves excavating contaminated soils, treating them on site
with low-temperature thermal desorption (LTTD), and backfilling treated material. Data
available from the treatability study show that PCBs have been reduced to 2 ppm, the
treatability study treatment goal. It is anticipated that the EPA remediation goal of 1 ppm can
be satisfied by modifying treatment conditions such as residence time and temperature, if
necessary. Full-scale treatment has been demonstrated to achieve concentrations as low as 2
mg/kg. Based on this performance data, the type of soil matrix at the Industrial Latex site,
and the relatively low concentration of contaminants in the soil, there is a high degree of
reliability in achieving target cleanup levels for soil using this treatment. RAAS-4
substantially reduces the toxicity, mobility, and volume of contamination by extracting organic
compounds from the soil and further treating the residuals off site. The LTTD process has
been demonstrated to be effective for a wide range of volatile and semivolatile organic
contaminants. The technology is implementable using commercially available equipment
(X*TRAX technology) and materials. Risks associated with treatment system mobilization and
132
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startup are expected to be minimal. Finally, RAAS-4 satisfies EPA remediation goals and
RCRA Land Disposal Restrictions for hazardous wastes as they apply to backfilling of treated
soil.- ' ' ' '••-' • . ' • - •' ". ',:; -

The ROD states that at that time the State of New Jersey did not yet concur with the selected
soil remediation alternative. ' ;
10. If an innovative technology was not chosen, why not? At what.stage was the innovative
technology eliminated? '

mnovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Critical fluid extraction was eliminated because solvent extraction using triethylamine
was retained as the representative solvent extraction technology for consideration in the
development of RAAs. A disadvantage of this technology mentioned in the FS is that
it does not extract metal contaminants from soil. . . .
• Soil vapor extraction was eliminated because the technology has not been
demonstrated effective in removing PCBs from soil. The FS cites the following
disadvantages of this technology: it requires control of vented vapors to mitigate
atmospheric discharge of hazardous chemicals, and it would not be expected to be
effective for PCBs which do not readily volatilize. ;,
• In situ soil flushing was eliminated because of difficulties in implementation and
questionable effectiveness for removing PCBs to the required cleanup goals. The FS
cites the following disadvantages of this technology: it must be implemented in
conjunction with ground water collection and treatment, though ground water flow
characteristics required to design an extraction system are not; fully understood at this
site; and PCBs, the most ubiquitous contaminant, are not highly soluble in water and
would be difficult to remove from the soil matrix to which it is absorbed.
• Biological treatment (in situ biodegradation, land treatment, ex situ bioreactor) was
eliminated because of the complexity of the process, the lack of demonstrated
effectiveness, and availability of other solids treatment technologies for the site. The
^ FS cites the following disadvantages of this technology: microorganisms that can
degrade PCBs have different environmental requirements than those that can degrade
most PAHs; there is no conclusive demonstration of the effectiveness of
bioremediation for Aroclor 1260; and the technology is not effective in removing ;
metal contaminants from soil. i
» In situ vitrification was eliminated for the following reasons: prganics might volatilize
during treatment and pose risks to nearby residents, and emission would need to be
captured; this technology is unproven in large-scale applications; the presence of
ground water greatly increases the cost of treatment; and this technology restricts
future land use. ! ,
• In situ radio frequency heating was eliminated because it's experimental and pilot test
equipment is not available. I ,
183
-------
Innovative technologies eliminated during the screening of the three criteria include the
following:

B None

Innovative technologies eliminated during the detailed analysis include the following:

« Dechlorination was eliminated but no specific reason was given. During the
evaluation of alternatives the ROD states that there was some uncertainty as to the
residuals associated with this treatment technology and toxicity testing would have to
be performed prior to its implementation. •
" Solvent extraction was eliminated but no specific reason was given. During the
evaluation of alternatives the ROD states that the long-term effectiveness of solvent
extraction was less certain than that of other technologies because of the uncertainty
about the fate of the residual solvent used in the treatment process.
77.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and long-term effectiveness and permanence
were weighed most heavily in selecting an alternative for this site. The selected alternative is
protective of human health and the environment because the soil is treated to remove the risk-
causing contaminants. RAAS-4 deals effectively with the threats posed by the contaminarits
which were identified and will attain a 10"4 to 10* risk level for carcinogens and the HI will be
less than 1 for noncarcinogens. In addition, the selected alternative is one of the most
effective alternatives in the long term and the most permanent because contaminants are
removed from site soils and destroyed. Treatability study results show that LTTD provided
significant removal of PCBs from site soils. The long-term effectiveness of other alternatives
is less certain: there is uncertainty about the fate of the residual solvent used in solvent
extraction, off-site landfilling relies on the long-term integrity of off-site disposal facilities,
stabilization is less certain because it relies on the ability of soil-fixing techniques to :
permanently immobilize the contaminants, and capping requires continued maintenance:for an
indefinite period of time.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? !
134
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
PCB Aroclor 1260
Heptachlor epoxide
Arsenic
Beryllium
Lead
1
0.1
3.6
0.48
,500
Risk1"
Risk8
Background0
Background*
Risk2
-5-
-------
Contaminant
Benzo(a)anthracene '.
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Behzo(ghi)perylene
Bis(2-ethylhexyl)
phthalate
Chrysene
3,3-Dichlorobenzidine
Ideno(l ,2,3-cd)pyrene
Cleanup Level (ppm)
0.4
0.1
.0.5
0.8
3
46
13
1.4
0.2
ARAR or Other Basis
' Risk8
; Risk8
i Risk8
Risk8
Risk8
Risk8
i .
| Risk*
, Risk8
Risk8
"EPA Region 2 Remediation Goals (RG) developed according; to the methodology
outlined in the Risk Assessment Guidance for Superfund (RAGS) Part B. The RG
applies to both surface and subsurface soils. For carcinogens; an excess upper bound
individual lifetime cancer risk of 10"6 was acceptable.
'The New Jersey Department of Environment and Energy (NJfDEE) has proposed
surface soil and subsurface soil cleanup standards for PCBs of 0.45 ppm and 100 ppm
respectively. Proposed surface soil standards apply only to soils in the 0 to 2 foot
depth interval.
cThe remediation level for arsenic is the background concentration. The corresponding
RG is 0.4 ppm. !
dThe remediation level for beryllium is the background concentration. The
corresponding RG is" 0.2 ppm.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? '• \ -

Innovative technologies eliminated because of cleanup goals include:

• In situ soil flushing was eliminated in part due to questionable effectiveness for
removing PCBs to the required cleanup goals.
/ ii
Standard technologies eliminated because of cleanup goals include: ,

• None .
14. Were treatability studies conducted on the innovative technology or standard technology?

The results of a treatability study performed by IT Corporation examining the effectiveness of
LTTD on samples of contaminated soil from this site demonstrated that the process was
effective in reducing Aroclor 1260 concentrations ranging from 9.9 mg/kg to 779 mg/kg in the
untreated soil to less than the study target level of 2 mg/kg. .
-6-
185
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15. What measures/criteria were used to compare alternatives? ^& \

The following measures were used to'compare the alternatives:

- , Cost-effectiveness
Proven reliability •''<.'' •'
Preference for treatment (vs. containment)

16. How are measures compared?

The selected remedy was determined to be cost effective because it provides the highest degree
of protectiveness among the alternatives evaluated, while representing cost value. LTTD was
selected because it is implementable using commercially available equipment and materials.
By treating contaminated soil on site through the use of an innovative process, the selected
remedy .addresses the threats posed by the site through the use of treatment technologies.

17. What technical considerations were factors in selecting a remedy? Were technical '
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. In situ soil flushing was
eliminated because of the heterogeneous nature of the soils at the site; the washing solution
might not have contacted all the soil particles

ise • .7- ' . . . " ;: ". .:' !'
-------
Islip Municipal Sanitary Landfill
Islip, New York
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Sample were collected from ground water,
landfill gases, and ambient air. No soil
samples were reported. The contaminants of
concern were:

Vinyl chloride
Arsenic
Beryllium
Antimony
Thallium
Benzene
Trichloroethene
Tetrachloroethene
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1/87
3/89
6/92 ;
9/30/92
Background

PRP-lead ].
PRPs: Town of Isilip, Department of
Environmental Conservation
FS prepared by: OJMCE of New York,
P.C. '
2, What volume of material is to be remediated? !

The volume of material to be remediated included: ;
. .-. ••''•• r '
• The volume of the landfill is not provided. The proposed cap will cover 54 acres.

3. What type of site is this? j! /
.- I ~*
Municipal Landfill. A former municipal landfill. ' j .
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: , , i ..'-'"'-.
-1-
187
-------
Access restriction:
Containment:
Deed restrictions
Capping (clay, soil, asphalt, multilayer, synthetic membrane additive
derived), slurry wall, grout curtains, sheet piling, various soil mixture
walls, horizontal barriers
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

No innovative technologies were proposed for source treatment.
6. What was the cost estimate for the innovative technology?

7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
(RAA-3A)
RAA-4
(RAA-3B)
RAA-5
(RAA-3C)
RAA-6
(RAA-4A)
Standard Technology
No action
Landfill cap/monitoring/institutional
actions
Landfill cap/pump and treat all ground
water with aeration and activated carbon
Landfill cap/pump and treat all ground
water with chemical precipitation and
air stripping
Landfill cap/pump and treat all ground
water with UV peroxidation
Landfill cap/pump and treat ground
water above 50 ppb VOCs with
aeration and activated carbon
Estimated Costs
3 Criteria
N/A
' N/A
N/A
N/A
N/A •'
N/A
9 Criteria
$0
$15,226,200
$21,214,310
$26,311,710
$40,145,570
$19,430,640
4ft
188
-2-
-------
Alternative
RAA-7
(RAA-4B)
RAA-8
(RAA-4C)
Standard Technology
Landfill cap/pump and treat ground
water above 50 ppb VOCs with
chemical precipitation and air stripping
Landfill cap/pump and treat ground
water above 50 ppb VOCs with UV
peroxidation .
Estimated Costs
3 Criteria
N/A .
N/A
9 Criteria
$23,491,000
$33,372,470
8. If a standard technology was chosen, why? '[
' • ' - ' • -i
The chosen alternative, RAA-6 (RAA-4A), was preferred because it is proactive, technically
feasible, and implementable at the lowest cost. Capping will be an effective means of
reducing the mobility of contaminants through the waste layers because it restricts the
infiltration of precipitation and surface water runoff. This, in turn, reduces percolation and
subsequent transport of contaminants to ground water. Capping the landfill also will be an
effective mechanism of controlling the mobility of vapor phase contaminants because it
controls the transport of subsurface gases to the air through passive vents.. The risk associated
with direct contact with landfill waste will be eliminated after the cap is completed. Deed
restitutions further eliminate human exposure to landfill waste and ground water. The
synthetic membrane cap was preferred because it is chemical resistant and relatively
impermeable. This alternative provides long-term effectiveness because contaminants will be
immobilized. Capping and proposed ground water treatment will act together to eliminate
contaminants permanently from ground water and restore the aquifer to drinking water
conditions. This alternative should be easily implemented since technologies for capping are
readily available. A 52- acre cap, however, is a relatively large construction project, and some
technical problems could be encountered. RAA-6 is the cost-effective alternative. No
treatment for landfill waste was proposed because it would be impractical! due to the large
quantity of waste and the waste's location under an interim cap where hot spots can not be
. identified. < ' .
' ' !
The recommended alternative in the FS was RAA-2. RAA-2 was recommended because
ground water treatment was expected to cause the release of VOCs to the; atmosphere, and it
was uncertain if ARARs would be technically or financially attainable thirough ground water
treatment. The FS also stated that the benefit to health due to ground water treatment was not
great since the aquifer did not need to be used as a drinking water source. RAA-6 (RAA-4A)
was the selected alternative in the Proposed Plan.
9. If an innovative technology was chosen, why?

An innovative technology was not recommended.
-3-
189
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the screening of the three criteria include the
following:

" None ' . ' . .. '
"*•' • "-•
Innovative technologies eliminated during the detailed analysis include the following:

• None
i
-'--'".-
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted criteria in selecting a remedial technology were long-term
effectiveness, short-term effectiveness, and cost-effectiveness. Capping was considered
important because it would ensure greater long-term effectiveness. Capping was proposed in
most RAAs and other criteria directing the choice of an RAA was aimed at ground water
remediation. The chosen alternative was the most cost-effective because it is more protective
than natural attenuation but not as extreme as treating all ground water, which would be more
costly. The chosen alternative also will be more productive in the short-term because it will
treat "hot spots" of contaminated ground water. While the chosen alternative will capture high
levels of contaminants immediately, it would take approximately 5 years for RAA-3A, RAA-
3B, and RAA-3C to begin capturing similar levels of contaminants. The advantage of
removing contaminants quickly is that contaminants will not sink deeper into the aquifer.
Long-term cleanup will depend on natural attenuation as well
' - • •• - - ' i -
;
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
1 .

No cleanup goals were established for source control. The capping of the landfill will impact
and enhance the cleanup of the underlying aquifer.
190
-4-
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13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? i

Innovative technologies eliminated because of cleanup goals include: ;

• None
!l
Standard technologies eliminated because of cleanup goals include:

, • None
' ' 'i '

14. Weretreatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

75 What measures/criteria were used to compare alternatives? • • ,

The following measures were used to compare the alternatives:

Time to design/construct/operate

• ' ' ' ' ' "' . . :i i ,' .
16. How are measures compared?

The chosen alternative was preferred because it proactively addresses; ground water
contamination. Treating ground water "hot spots" was preferred over natural attenuation
because it will take less time to achieve ARARs. Hot spot treatment was preferred over
treatment of all ground water because it will address highly contaminated water more quickly
and it will reach ARARs in a longer but acceptable amount of time. Addressing "hot spots"
was deemed to be important because they threaten the underlying aqiiifer.
'. • •' . • •••'!!

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? j
i
No technical considerations were primary in selecting a remedial alternative.
191
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Juncos Landfill
OU-1

Juncos, Puerto Rico
Region 2
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

1,4-Dichlorobenzene 3
Total phenols 0.5
Arsenic 17
Cadmium 3
Copper 168
Nickel 41
Lead 63
Mercury 49
Zinc 165
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/83
4/91
9/24/91
Background
PRP-lead
PRPs: Becton Dickinson Puerto Rico, Inc.
FS prepared by: McLaren/Hart Environ-
mental Engineering Corporation
-n^.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

« 290,000 to 870,000 cubic yards of waste materials and soils
3. What type of site is this?

Municipal Landfill. Inactive municipal waste landfill. \

TECHNOLOGY SELECTION : •

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: •.:''"'

Access restriction: Fencing, deed restrictions
Containment: RCRA cap, single-barrier cap, revegetation, gas venting system,
regrading landfill slopes
192
-1-
-------
Thermal treatment: Fluidized bed incineration, rotary kiln incineration, infrared thermal
treatment
Disposal: Excavation, off-site disposal ;

* ,• •
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: ,

Biological treatment: In situ biodegradation, on-site solid-phase bicjdegradation, on-site slurry
phase biodegradation, composting i
Phys/Chem treatment: Chemical extraction, in situ chemical treatment, soil washing, soil
flushing . • \
Thermal treatment: Vitrification, pyrolysis
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, .After the RAAs have been
formulated, costs are estimated as part of the three criteria (effectiveness, implementability,
cost) screening process to identify alternatives of sufficient merit to undergo detailed
evaluation. The estimated costs are recalculated during evaluation by the nine criteria
established by the NCP. All innovative technologies were eliminated in the initial screening
process. Costs were not estimated at this point.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4A
Standard Technology
No action: monitoring/assessment every
five years
Fencing/institutional controls/erosion and
sediment control/monitoring
Regrading the landfill/RCRA Subtitle C
cap/passive gas control system/leachate
control system/fencing/erosion control/
monitoring/institutional controls
Regrading landfill/single-barrier cap with
clay barrier/passive gas control system/
leachate control system/fencing/erosion
control/monitoring/institutional controls
Estimated Costs
3 Criteria
$1,088,000
$1,488,000
$7,1<)8,ODO
/'
' i
$6,272,000
9 Criteria
$1,088,000
eliminated
$7,108,000
$6,272,000
• ' -2-
193
-------
Alternative
RAA-4B
RAA-5
Standard Technology
Regrading landfill/single-barrier cap
with geomembrane/passive gas control
system/leachale control system/fencing/
erosion control/monitoring/institutional
controls
Regrading landfill/soil cap/passive gas
control system/leachate control system/
fencing/erosion control/monitoring/
institutional controls . " •
Estimated Costs
3 Criteria
$4,420,000
$5,022,000
9 Criteria
$4,420,000
1
$5,022,000
8. If a standard technology was chosen, why?

A single-layer cap with geomembrane (RAA-4B) was selected because it is protective of
human health and the environment, prevents on-site contaminant contact and leachate
generation, minimizes air emissions, and reduces the migration of contaminants. With the
exception of no action (RAA-1) and fencing (RAA-2^all three action alternatives involved
some type of capping. The selected remedy offers a higher degree of permanence and
protectiveness than the no action, fencing, and soil cap alternatives and has a similar degree of
protectiveness as the RCRA cap alternative. A RCRA cap (RAA-3) would be much more
expensive and its increased ability to prevent infiltration of precipitation is not necessary since
RCRA hazardous waste cannot be proven to have been disposed at the site. A single-barrier
cap with clay barrier (RAA-5A) was more expensive than the selected alternative. The three
capping alternatives were rated very similarly; the major difference between them was cost. It
was determined that the selected alternative offered the highest level of overall protectiveness
proportionate to cost. The increased cost of the other capping alternatives was not reflected in
greater protection of public health and the environment.
9. If an innovative technology was chosen, why?

An innovative technologies was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

• Chemical extraction was grouped into the general category "physical/chemical :. '
treatment," which was considered to be an ineffective method of cleanup due to the
heterogeneous nature of the landfill. Contaminant concentrations at the surface of the
landfill were low, so large volumes of waste would have to be processed to remediate
194
-3-
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small amounts of contaminant. Excavation of waste for treatment was expected to
pose a threat of exposure to workers and local residents. Treatment would produce
residuals that would have to be further treated, and a treatability study would be
required. Implementation would be costly. !
• In situ chemical treatment was grouped into the general category "physical/chemical
treatment" and eliminated for the same reasons as chemical extraction.
• Soil washing was grouped into the general category "physicaiychemical treatment" and
.eliminated for the same reasons as chemical extraction.
• Soil flushing was grouped into the general category "physical/chemical treatment" and
eliminated for the same reasons as chemical extraction.
• In situ biodegradation was grouped into the general category "'biological treatment,"
which was not considered effective due to the heterogeneous type of waste found at
the landfill. In addition, a treatability study would be required and the implementation
of the technology would be costly. Biological treatment is most appropriate for hot
spots, and no hot spots had been detected at this landfill. |
• Solid-phase biological treatment was grouped into the general category "biological
treatment" and eliminated for the same reasons as in situ biodegradation.
• Slurry phase biological treatment was grouped into the general category "biological
treatment" and eliminated for the same reasons as in situ biodegradation.
• Composting was grouped into the general category "biological treatment" and
eliminated for the same reasons as in situ biodegradation. !
• Vitrification was grouped into the general category "thermal treatment (on site)," which
was eliminated because the site lacked the necessary space for its implementation. In
addition, significant material handling would be required, products of incomplete
combustion would be difficult to control, and implementation:would be costly.
r" • Pyrolysis was grouped into the general category "thermal treatment (on site)," which
was eliminated for the same reasons as vitrification.

No innovative technologies were included in RAA, therefore, none were eliminated during the
three-criteria screening process or during detailed evaluation.
'!,.''

11. Which of the nine criteria were weighted most highly in selecting the technology? Did one of
the nine criteria eliminate the innovative technology from being chosen? If so, which one?
Which of the criteria supported the use of an standard technology? (
' •' • . ' ••'•,'
Cost-effectiveness was weighted most highly in selecting a remedy. The selected alternative,
RAA-4B, offered the highest level of overall protectiveness proportionate to cost. The higher
costs of the other capping alternatives were not reflected by greater protection of public health
and the environment. .
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

For carcinogens an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For non-carcinogens a Hazard Index less than or equal to 1.0 was acceptable.
An unacceptable risk of adverse non-carcinogenic effects was estimated for exposures of
children to landfill soil. Remedial action objects were developed to eliminate direct contact
with on-site surface soils and to reduce and control leachate generation.. No specific cleanup
levels for soils/sediments were described. ;
-4-
195
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

The cost for removal, disposal, and filling operations for this landfill would be approximately
$100 million. There were no hot spots to be removed or treated; low concentrations of
contaminants are dispersed throughout the landfill. Therefore, on-site and in situ treatment
technologies were eliminated in the screening process due to excessive cost and
impracticability. No innovative technologies were eliminated because of cleanup goals. The
standard technology selected could meet cleanup goals.

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. -

15. What measures/criteria were used to compare alternatives?
\ ' : - i
' " ! i
The following measures were used to compare the alternatives:

Cost effectiveness
Risk level achieved .
, • .

16. How are alternatives compared? ^Mr |
•- . • -**y'^ -1
' "l
Of those alternatives that would reach a level of risk protective of human health and the
environment, the selected alternative was the least costly The1 higher costs of other
alternatives would not provide a commensurate increase in the level of protection.

I
1 I
17. What technical considerations were factors in selecting a remedy? Were technical ' .' . ' i
considerations primary in the selection of the remedy?

The landfill is bordered by two streams into which runoff from the landfill flows. According
to a study by the U.S. Army Corps of Engineers, the site is beyond the 500-year flood
potential line. The potential for localized flooding during heavy precipitation was recognized.
However, hydrogeology did not play a primary role in remedy selection. Treatment
technologies for landfills are considered to be feasible only if hot spots are found and if there
is a small to moderate volume. Furthermore, as stated in the NCP, EPA expects to contain .
large volumes of low concentrations of material. The volume and nature of contamination at
this site was primary in the selection of a remedy.
196
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Kin-Buc Landfill
OU-2

Edison Township, New Jersey
Region 2
GENERAL SITE INFORMATION
1. , What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Sediment (mg/kg)

PCBs 290
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 2,200 cubic yards of sediment
Site! History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
10/81
7/92
9/28/92
Background

PRP-lead
PRPs: Kin-Buc, Incorporated and SCA
Services, Inc.
FS prepared by: Wiehran,Engineering
Corporation
3. What type of site is this?
• i 1 :
Municipal Landfill. An inactive landfill that accepted municipal, industrial, and hazardous
wastes. The site is located in an industrial and commercial area. i
TECHNOLOGY SELECTION
4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: \
1 *
Access restriction: Fencing, land use restrictions i
Containment: Capping (synthetic membrane, soil cover, composite, sediment
accumulation) !
Chemical treatment: Stabilization/solidification .•;••'
Thermal treatment: Incineration (rotary kiln, fluidized bed, infrared, commercial)
Disposal: Excavation, off-site disposal
-1-
197
-------
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Bioremediation (in situ, on site)
Phys/Chem treatment: Solvent extraction (Basic Extraction Sludge Treatment, Low Energy
Solvent Extraction Process), detergent extraction, KPEG ;
dechlorination, APEG dechlorination, sediment washing, in situ
vacuum extraction
Thermal treatment: In situ steam extraction, on-site low-temperature thermal treatment
(X*TRAX, by Chemical Waste Management Inc.), in situ vitrification,
on-site vitrification , \ •
6. What was the cost estimate for the innovative technology?

Since RAA-2 was eliminated in the FS, alternatives were renumbered in the ROD and these
new numbers are presented parenthetically below. . . .

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3C
(RAA-2C)
Innovative Technology
Excavation/solvent extraction, low-
temperature thermal treatment, or
dechlorination/disposal .
Estimated Costs
3 Criteria
$6,110,000
9 Criteria
$6,325,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
198
Alternative
RAA-1
RAA-2
Standard Technology
No action/long-term monitoring
Fencing/land use restrictions/long-term
monitoring/natural attenuation
Estimated Costs
3 Criteria
$300,000
$456,000
9 Criteria
$261,000
eliminated
-------
Alternative
RAA-3A
(RAA-2A)
RAA-3B
(RAA-2B),
RAA-4
(RAA-3)
RAA-5
(RAA-4)
Standard Technology
Excavation/dewatering/containinent in
OU-1 on-siite containment site
Excavation/dewatering/off-site disposal
Relocate stream/in situ single-layer
cap/fencing/land use restrictions
Limited stream, relocation/slurry wall/
cap/consolidate remaining sediment/
cap/fencing/land use restrictions
Estimated Costs
3 Criteria
$3,610,000
5,110,030
$5,315,000
1
$5,270,000
9 Criteria
$3,637,000
$5,268,000
$5,230,000
$5,009,000
8. If a standard technology was chosen, why?
' ' • ' ' ' i .
RAA-3A was chosen because it protects human health and the environment since it will
prohibit the migration of contaminants from the sediments into the aquatic and terrestrial food
chain. The source of the contamination will be removed from direct contact with the wetlands
that border the landfill and will be placed on site in a containment system. This alternative
can be implemented in the shortest amount of time and minimizes long- and short-term
impacts on the wetlands. RAA-3A utilizes reliable techniques, can be easily implemented, and
is cost-effective. While other, alternatives (RAA-3B and RAA-3C) would offer greater
protection through treatment technologies, their higher costs would not be in proportion to
their increase in protection. RAA-4 and RAA-5 were determined to be less effective and more
costly.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If ah innovative technology was not chosen, why hot? At what stage was the innovative
technology eliminated? |

• Detergent extraction (soil washing) was eliminated because its effectiveness has not
been demonstrated. j • ' -
• Sediment washing (in situ) was eliminated because it would be impractical since the ,
site is characterized by long, shallow stretches of contaminated sediment that would
require extensive surface water control. ;
, • In situ vacuum extraction was eliminated because it would not address PCBs.
-3-
199
-------
• In situ steam extraction was eliminated because it would not address PCBs.
• KPEG dechlorination was eliminated because it has not been widely used on
sediments and APEG dechlorination is mpre applicable.
• - In situ-vitrification was eliminated because the area is frequently saturated with water
and the products generated by PCS pyrolysis are unknown and might be toxic (e.g.,
dioxins). - . .
" On-site vitrification was eliminated because the effectiveness of the process on
sediment has not been demonstrated and the products generated by PCB pyrolysis are
unknown and might be toxic (e.g., dioxins).
• In situ or on-site bioremediation was eliminated because no method has been
developed that would address the site's PCBs.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None ,• , . ,-•'...

Innovative technologies eliminated during the detailed analysis include the following:

" Solvent extraction was eliminated because treatability studies would be too costly.
« Low-temperature thermal extraction was eliminated because treatability studies would
be too costly.
• APEG dechlorination was eliminated because treatability studies would be too costly.

The criteria that were weighted most heavily in selecting a standard technology were /
protection of human health and the environment and cost. While other treatment technologies
would offer slightly more protectiveness than the chosen alternative, the chosen alternative was
preferred because it was the least expensive. ,

Three innovative technologies were proposed in RAA-3C, but this alternative was eliminated
because of the excessive costs of treatability studies and the high unit cost associated with on-
site treatment.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
PCBs
EPA" and EP Method"
"EPA Guidance on Remedial Actions for Superfund Sites with PCB Contamination.
bEPA's Interim Equilibrium Partitioning Method.
:00
-4-
-------
Was the innovative technology eliminated because of the cleanup goals? \Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: •. -.

• ' " 'None . ' ' - • . ' 'I . ' '

Standard technologies eliminated because of cleanup goals include: j

• , None ' • • : . . .
J4. were treatability studies conducted on the innovative ^^^^

No treatability studies were conducted. ,!,"'..'

. 15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: |

Cost-effectiveness
- Time to design/construct/operate

'16 How are measures compared?

selected remedy could be implemented in the shortest amount of time.

i
17 What technical considerations were factors in selecting a remedy? Were technical , ;
considerations primary in the selection of the remedy? ;

Two technical considerations were primary in the selection of an ^native . F** the
medium of concern was sediment and its satura^^pr^ud^te ™«^
chnoogies (vitrification, in situ sediment wash^.
sedimenS were located in wetlands and two alternatives (RAA-4 and ^A-5) were
eliminated, in part because they were invasive to wetlands.
201
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Mattiace Petrochemical Co., Inc.
OU-1

Glen Cove, New York
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Tetrachloroethene 410
1,2-Dichloroethane 4.2
Carbon tetrachloride 3.8
Methylene chloride 35
Trichloroethene 37
4-MethyI-l,2-pentanone 210
Xylenes 2,600
Aldrin 0.21
Alpha chlordane 9.1
Heptachlor epoxide 0.93
1,4-Dichlorobenzene 12
Chromium 101
Arsenic • 16
Beryllium 2
Antimony 22
Lead ' • 204
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
7/85
5/86
7/90
6/27/91
Background

EPA Fund-lead
PRPs: N/A
FS prepared by: Ebasco Services
Inc. !
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 17,349 cubic yards of soil
• 208 cubic yards of pesticide-containing soil

3. What type of site is this?

Chemicals and Allied Products. An inactive liquid storage and redistribution facility located in
an industrial area. ' >
202
-1-
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TECHNOLOGY SELECTION

4. What standard technologies were, considered for selection in this FS?

Standard technologies considered during the identification and screening oiF technically feasible
technologies were:
Access restriction:
Containment:
Thermal treatment:
Disposal:
Warning signs, fencing
Capping (clay; asphalt, concrete, synthetic mernbrame, multilayer)
Incineration (rotary kiln, circulating fluidized bed)
Excavation
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: , I

Biological treatment: In situ biodegradation . , • ;
Phys/Chem treatment: In" situ soil flushing, soil washing, in situ vacuum extraction
Thermal treatment: Low-temperature thermal stripping, wet oxidation, in situ vitrification,
in situ steam stripping ;
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-6
'" • • • -'-- " ' "•
Standard Technology
No action
Multilayer cap/UST removal/off-site
disposal ,
Excavation/UST removal/off-site
disposal/incineration '
=========================================
Estimated Costs
3 Criteria
$246,000
$2,080,000
N/A
================
9 Criteria
$245,656
eliminated
eliminated .
' —
D
8. If a standard technology was chosen, why?

A standard technology was not selected.
9. If an innovative technology was chosen, why?

RAA-3B was selected because it protects human health and the environment by reducing site
soil contaminants to health-based cleanup levels through the use of in situ vacuum extraction
and the excavation of pesticide "hot spots" not amenable to the vacuum extraction technology
This remedy complies with all ARARs. this alternative most rapidly reduces site risk'.
associated with contaminated soil since it involves excavation and off-site disposal of high risk
areas of contamination. Treatment-related impacts will be minimal. Short-term risk posed to
site workers will be minimized through development and adherence to appropriate health and
safety protocols. This alternative will be implementable in terms of the availability of
necessary materials and services, as well as existing administrative requirements or restrictions
The performance of treatability studies will be required to determine the essential design
parameters for in situ vacuum extraction. It is the cost-effective option since its overall
204
-3-
-------
effectiveness is proportional to its cost. The removal and treatment of soil permanently and
significantly reduces the toxicity, mobility, and volume of hazardous substances in the soil
thereby permanently eliminating all the principal source threats of contamination at the site.
10. If an innovative technology was not chosen, why not? At what stage Vyas the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; ,or during the detailed evaluation.
i . -f •'...••-•
Innovative technologies eliminated during the initial screening include the following:
• ... i . •
. i
•. Wet oxidation was eliminated because it would not effectively eliminate the levels of
contamination encountered at the site.
• Soil washing was eliminated because it would not be feasible given the small site area
and the large system required for the soil washing technology1.
• In situ vitrification was eliminated because it is not recommended for volatile organic
contamination, the flammable organics found on the site might also present safety
problems, and it would cost more than other in situ options. "- :
• In situ soil flushing was eliminated because it would not be feasible since the clay
lenses found throughout the site would preclude effective treatment of soils beneath
these lenses. Furthermore, slurry walls would have to be constructed to key into the
horizontal barrier, mechanically isolating the contaminated source and applied ground
water. • i" , '
! '
Innovative technologies eliminated during the screening of the three criteria include the
following: I
. - ' £ -
• In situ steam stripping was eliminated because it was unclear if contaminant levels
would be reduced below ARAR criteria, particularly for the semi-VOCs. In addition,
implementation of the technology might present technical difficulties if the steam
condensation in the contaminated soil could not be prevented. To prevent this
condensation, extraction and injection wells would have to be' spaced close together,
which would escalate the cost. Finally, a pilot study would bb necessary to determine
the operating criteria and level of performance. i
• In situ biodegradation was eliminated because its implementability and effectiveness
on these high levels of chlorinated organics has not been demonstrated. This
alternative would be difficult to assess and, thus, the long-term effectiveness in
protecting human health and the environment can not be insured. "The geology of the
site does not seem to be conducive to bioremediation due to the clay lenses inhibiting
treatment beneath the lenses. It would not treat all site contaminants." Also, the
concentrations of organic contaminants might be too high and toxic to microbial
populations and the low organic carbon content of the soil (less than 1 percent) would
not sustain the bacterial population. The long-term effectiveness of this technique
would be difficult to assess since this technology has not been proven effective for
highly chlorinated solvent waste. '• '• .
205
-4- : •
-------
77.
72.
Innovative technologies eliminated during the detailed analysis include the following:

* Low-temperature thermal treatment was eliminated because it would be more
expensive to implement than the chosen alternative and it would not provide greater
protection. Furthermore, its treatment-related impacts would be greatest since it would
require excavating the largest amount of contaminated soil and it involves on-site
thermal treatment of all contaminated soil. '
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were protection to human
health and the environment and cost. Of the three most protective alternatives (RAA-3B,
RAA-3A, and RAA-5). RAA-3B was chosen because it is the least expensive alternative that
offers the greatest protection. ,

Two innovative technologies, in situ vitrification and low-temperature thermal treatment, were
eliminated, in part because of their high costs. .

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? , <.'
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens - ^
vTetrachloroethene
Trichloroethene
Aldrin
Alpha chlordane
Heptachlor epoxide
0.6
0.07
6.04
0.5
0.07
Risk3
Risk
Risk
Risk
Risk
Noncarcinogens
Xylenes
4-Methyl-l,2-
pentanone
. 259
52.1
Risk
Risk
"Soil cleanup levels were based on achieving an excess lifetime cancer risk of 1O6 for
carcinogens and a Hazard Index of 1 for noncarcinogens.
206
-5-
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• -In situ steam stripping

Standard technologies eliminated because of cleanup goals include:

• None j -
•' • •.'... . ' i • - '
• ' • • • '
14. Were treatability studies conducted on the innovative technology or standard technology?
\ . , ;' '
Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness . . .
16. How are measures compared? j
"i . .• •
Despite its higher cost, RAA-3B was preferred over RAA-3C because the high cost
cprresponded to an increase in protection to public health.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical characteristics were primary in selecting a remedial alternative; however, some
were considerations. For example, soil washing was eliminated because it would be infeasible
given the small size of the site, and in situ biodegradation was eliminated because the clay
lenses would inhibit remediation beneath them. i
207
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Nascolite Corporation
OU-2

Millville, New Jersey
Region 2
GENERAL SITE INFORMATION
1.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)
Acetone
Trichloroethene
Benzene
Toluene
Ethylbenzene
Styrene .
Total xylenes
2-Methylnapthalene
Di-n-butylphthalate
Butylbenzylphthalate
Bis(2-ethylhexyl)phthalate
Benzoic acid
Polymethyl methacrylate
Cadmium
Mercury
Copper
Selenium
Zinc '
10,700
5
5
2
13
71
29
2 '
15
76
19
130
33
1,900
58
1 .4
174
6 ,
868
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/83
9/90
6/28/91
Background

PRP-lead
PRPs: Not listed
FS prepared by: Ebascb Services,
Incorporated
3
volume of material is to be remediated?

The volume of material to be remediated included:

• 8,000 cubic yards of unsaturated and wetlands soil

3. What type of site is this?

Rubber and Plastic Products. An inactive acrylic and plexiglass sheet manufacturing plant
located in a wooded area surrounded by residential and industrial property. '

208 ' ' '•"; ' •'-..•;- ,-••
-------
TECHNOLOGY SELECTION .- ^

4. What standard technologies were considered for selection in this FS? j

Standard technologies considered during the identification and screening of technically feasible
technologies were:
i - •
Access restriction: Fencing, deed and zoning restrictions ,
" Chemical treatment: Solidification/stabilization
Physical treatment: Size reduction, size separation i
Thermal treatment: Incineration ,
Disposal: Excavation, off-site disposal ..,"!'.
5. Was'an innovative technology considered in the FS? If so, which technology?
- i . , .
Innovative technologies considered during the identification and screening of technically
feasible technologies were: " !

Biological treatment: Biodegradation, composting
Phys/Chem treatment: Soil flushing (solvent), soil washing (solvent), dechlorination, soil
yapor extraction |
Thermal treatment: Wet oxidation, radio-frequency heating, pyrolysis
6. What was the cost estimate for the innovative technology? ~

Cost Estimates for RAAs That Include Innovative Techniologies
(selected remedial alternative is in bold) | " .

Alternative
RAA-2

Innovative Technology
Excavate soil with greater than
500 ppm of lead/soil washing/backfill
Estimate!
3 Criteria
N/A
1 Costs
9 Criteria
$2,627,000
-2-
209
-------
7. How did the cost(s) compare to standard technologies?
9.
10.
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-3
Standard Technology
No action
Excavate soil with 500 ppm of lead/
stabilization-solidification/ backfill
Estimated Costs
3 Criteria
N/A
N/A
PCriteria
$0
$2,237,000
8. If a standard technology was chosen, why?

RAA-3 was selected because it will reduce the risk from exposure to site contaminants through
a solidification/stabilization process. Solidification/stabilization will immobilize the
contaminants by binding them in an insoluble matrix which will be covered by top soil.
Institutional controls also will be implemented to deter activities that would disrupt the
solidified mass. (Additional remedies include off-site disposal of some soils.) This alternative
was preferred because it is easily implemented, and solidification/stabilization units and
equipment are readily available for immediate use. Furthermore, solidification/stabilization is a
proven technology and offers the greatest certainty that treated soils will meet cleanup levels.
If on innovative technology was chosen, why?

An innovative technology was not chosen.
If an innovative technology was not chosen, why. not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Biodegradation (ex situ) was eliminated because the process would be inhibited by
heavy metals.
Composting was eliminated because it would be inhibited by heavy metals.
Wet oxidation was eliminated because it would not be effective for remediating metals.
Radio-frequency heating was eliminated because it would not be effective for
remediating metal.
Dechlorination was eliminated because it would not be applicable to site contaminants
Soil flushing was eliminated because ground water could be contaminated.
Soil vapor extraction was eliminated because it is not effective for organics in •
saturated and wetland soils.

-3- • ' :
-------
» Pyrolysis was eliminated because it would not be applicable to soil with high metal
concentrations.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• Soil washing was eliminated because it would be more difficult to implement, it would
generate waste solution, and its effectiveness is less certain than that of the chosen
alternative. ;
11.
12.
13.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria that were weighted most heavily in selecting a remedy were protectiveness of
human health and the environment and implementability! Soil washing was eliminated
because it would be difficult to implement, requiring construction of a ground water treatment
system and custom-designed processing equipment. Furthermore, wastewater would be
.generated which also would require treatment. ;
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? : -
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens ,
Lead
500
OSWER"
"OSWER Directive No. 9335.4-02 \' ,'..

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:!
i
. . ' . • 'i . '
• Soil washing

Standard technologies eliminated because of cleanup goals include: 1 .

• None •...-'''''•• " 'i
211
-4-
-------
14.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted to investigate two technologies: soil washing and vacuum
extraction. Studies showed that these technologies were potential options for remedial action.
15.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Proven reh' ability
16. How are measures compared?

Two alternatives were expected to meet cleanup levels and therefore reduce risk to acceptable
levels. Of these, the chosen alternative was preferred because there was less uncertainty
associated with its effectiveness and implementation.

Further, because no treatability tests were performed for solidification/stabilization a literature
review of the SITE program was carried out to determine the potential use of this technique.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
Technical considerations were not primary in selecting a remedial alternative. The site's
residential nature, however, was a factor in selecting a remedy. There are several homes
located on the boundaries of the site and over 60 homes located within a half-mile radius
Because of the potential future risk of human exposure to site contaminants, the lower end of
EPA soil cleanup levels was chosen.
212
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Naval Air Engineering Center
OU-1

Ocean City, New Jersey
s Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
. contaminants were:

Site 10 - Soil (mg/kg)

Petroleum hydrocarbons 10,820

Site 16 - Soil (mg/kg)

Toluene ' 0.009
2-Methylnapthalene 220
Phenanthrene 0.41
Beta-BHC " 0.026
Petroleum hydrocarbons 14,097

Site 17 - Soil/Sediment (mg/kg)

Toluene 0.007
Petroleum hydrocarbons 0.227
2-Butanone 6
4-Methyl-2-pentanone 29
Toluene .34
Ethylbenzene 13
Xylenes 139
Phenanthrene 91
Fluoranthene 18
4,4-DDD - 1.4
Beryllium •• 3,g
Cadmium 49
Chromium 1,270
Lead 870
Mercury 1.4
Vanadium 100
Zinc 427
Cyanide 26.6
Petroleum hydrocarbons 36,898
NPL Proposed:
NPL Final:
FS:
Interim ROD:
Site History
N/A
1987
9/90
'2/91
Background

Federal Facility
PRPs: Navy, Depijutmient of Defense
FS prepared by: Naval Energy and
, Environmental Support Activity
at the Naval, Air Engineering
Center
213
-i-
-------
2. What volume of material is to be remediated? . • .

The volume of material to be remediated included:

« A volume Was not provided.

3. What type of site is this? .

Military. An active naval base. The OU-1 consists of three sites—#10, #16, and #17—which
were used for barrel and gasoline tank storage, firefighting training, and an underground tank
farm. Land use in the area includes residential, woodland, wetland, and associated flood plain.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

No initial screening was conducted. This study was of limited scope because it was for an
interim remedy. Only one source control technology was discussed (see below).

5. Was an'innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: :

Chemical treatment: In situ soil flushing

6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-3
, Standard Technology
No action
Ground water pumping, treatment, and
discharge to surface water
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria*
N/A
N/A
'Detailed cost estimates, including present worth costs, were not provided; only direct capital
and operation, and maintenance costs were provided.
8. If a standard technology was chosen, why?

A standard technology was not selected.
9. If an innovative technology was chosen, why? '

RAA-2 was selected because it provides the greatest overall protection to human health and
the environment through treatment of ground water and soils. This alternative calls for the
utilization of soil flushing to address the contaminants in soil and ground water treatment.
RAA-2 is an interim action and therefore is intended to be a short-term fix. If the interim
remedial alternative proves to be effective, however, it will be incorporated and/or modified to
become the final action. RAA-2 reduces the mobility and toxicity of ground water
contaminants through ground water treatment. RAA-^2 in the short-term will halt the migration
of contaminated ground water and residual amounts of floating product from entering the
ecologically sensitive areas. It also will stop the migration of contaminants to a tributary of
the Manapaqua Brook, which feeds a major recreational lake. This action prevents the
degradation of the aquifer and limits contaminant exposure risks to the population using the
-3-
215
-------
lake. Furthermore, because soil flushing will be implemented, the remediation process will be
accelerated. Soil flushing will aerate and enhance biological activity and contaminant
decomposition. This alternat: e involves conventional technologies with proven reliability. It
is cost-efficient and expected to attain ARARs. ,

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the .screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. ,

Innovative technologies eliminated during the initial screening include the following:

• An initial screening was not conducted

Innovative technologies eliminated during the screening of the three criteria include the
following: .

• A three-criteria, screening was not conducted x

Innovative technologies eliminated during the detailed analysis include the following: ,

• None

Protection of human health and the environment and short-term effectiveness were the criteria
weighted most heavily in selecting a remedial alternative. RAA-2 provides the greatest
protection to human health since it addresses both ground water and soil. It also provides
protection in the shortest amount of time.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels were not established.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ,

Innovative technologies eliminated because of cleanup goals include:

None /^^ ~\
216
-4-
-------
Standard technologies eliminated because of cleanup goals include:
• None
- ' • (' •' -
14. Were treatability studies conducted on the innovative technology or standard technology?
Treatability studies were not conducted.
•,'''''
75. What measures/criteria were used to compare alternatives?
The following measures were used to compare the alternatives:
- , Time to design/construct/operate '
Preference for treatment (vs. containment)
f • ' , . ' !' -
16. How are measures compared?
•• - . ^ -. . ^ , i
RAA-2 was preferred because it will treat both the soil and ground water. Furthermore, the
incorporation of in situ soil flushing acts to accelerate remediation. T

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? j
Technical considerations were not primary in selecting a remedy.
217
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Naval Air Engineering Center
OU-2

Ocean County, New Jersey
Region 2
Site History
fj
NPL Proposed: N/A
NPL Final: 1987
FS: 9/90
ROD: 12/90

Background

Federal Facility
PRPs: Navy, Department of Defense
FS prepared by: Naval Energy and
Environmental Support Activity
at the Naval Air Engineering
Center
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Toluene 0.38
Ethylbenzene 0.8
Xylenes 2.400
2-Methylnaphthalene 4.783
Naphthalene 1.761
4-Chloroaniline 0.356
Isophorone 0.246
Cadmium 81
Copper 515
Lead , 357
Petroleum hydrocarbons 4.031

Sediments (mg/kg)

Toluene . 0.005
PAHs 0.88
Petroleum hydrocarbons 0.221
4,4-DDT 2.7
4,4-DDD 12
4,4-DDE 0.31
Cadmium 10
Copper 340
Chromium 130
Zinc 385
2. What volume of material is to be remediated?

The volume of material to be remediated included: ,

• A volume was not provided. The contaminated soil is spotty and generally confined to
the drainage swales between the test tracts and the former pump house and
underground tank.
218
-i-
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3. What type of site is this? :
• . • . \ •
Military. The site is located on an active air base and consists of the launching end of five
test tracks and ancillary facilities including a drainage system, a series of dry wells, and
several underground storage tanks. Land use in the area includes residential, woodlands,
wetlands, and associated flood plain. ,
TECHNOLOGY SELECTION
-"• ' "•• '" '" ••' ' ' ' . %, _ '
- . ' : ' ' . ! \ •• ' *
4. What standard technologies were considered for selection in this FS?
'- ' ~ \ ' •
Standard technologies considered during the identification and screening of technically feasible
technologies were:

No initial screening was conducted. The scope of this study was limited because it was for an
interim remedy. Only one source control technology was discussed (see below).
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Physical treatment: In situ soil flushing .
What was the cost estimate for the innovative technology?

During ,the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria scbening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Soil/Sediment
Alternative
Standard Technology
No action
Ground water pump-and-treat/ discharge
to surface water
N/A $550,000
and
$100,000
'Detailed cost estimates, including present worth costs, were not provided; only direct capital
and operation and maintenance costs, respectively, were listed.
Estimated Costs*
9 Criteria
'•fa^bfj^
5. If a standard technology was chosen, why?

A standard technology was not selected. '.-'''••

9. If'an innovative technology was chosen, why?

RAA-2 was selected because it protects human health and the environment through treatment
of ground water and in situ soil flushing: In situ soil flushing will aerate and enhance
biological activity and contaminant decomposition. The incorporation of in situ soil flushing
hnLnhttSted .™atlve was Preferred because it provides the greatest overall protection to
human health;and the environment through the treatment of both ground water and soil. In the
short term this alternative prevents degradation of the aquifer and halts the spread of
contaminated ground water and residual amounts of floating product from entering ecologically
sensitive areas, the Manapaqua Brook and Pine Lake. RAA-2 has the added benefit of
flushing the soil of contaminants and increasing the hydraulic gradient, thus speeding up the
remediation process. The flushing actions help release contaminants adhering to the soil
facilitating the interim cleanup action. RAA-2 reduces contaminant toxicity and mobility and
involves conventional technologies with proven reliability. It complies with all ARARs and is
cost effective Since this is an interim action, long-term effectiveness cannot be addressed
rZfrTi' , acTtion ;fueffective * wi" be incorporated and/or modified to become the final
remedial action. It will be implemented in 3 years
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the imUal screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
220
-3-
-I
-------
Innovative technologies eliminated during the initial screening include the following:

• An initial screening was not conducted ! .
• i • -
Innovative technologies eliminated during the screening of the three criteria include the
following:

• A three criteria screen was not conducted. i

Innovative technologies eliminated during the detailed analysis include the following:
' - ' !
1 • 'None - ' ' , • . . ' '.'!•
i ' *

12., What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

> No cleanup goals were established for soil/sediments.

-I

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? j
i i '
Innovative technologies eliminated because of cleanup goals include: j

• None _

Standard technologies eliminated because of cleanup goals include: !

• • None , '• - • -j . , ,

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
221
-4- • '-''' J. '• :".
-------
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Percentage risk reduction
Time to design/construct/operate

16. How are measures compared? '

RAA-2 was selected because it was more protective overall since it addressed both ground
water and soil through treatment technologies. Furthermore, this alternative will accelerate the
remediation process because it addresses soil.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy.
222
-5-
-------
National Lead Industry

OU-2
Pedricktown, New Jersey
Region 2
GENERAL SITE INFORMATION
1. ' What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?
• - • ' , , , : •
Maximum concentrations of principal
contaminants were:

Slag Piles (mg/kg):
Lead 252,010
Cadmium 1,460
Arsenic , 3,580
Antimony , 19,000
.
L*ad Oxide Piles (mgTkg):

Lead 437,000
Cadmium 650
Arsenic 614
Antimony 2,790

Site History

NPL Proposed: N/A
NPL Final: 9/83
FS: , 6/8/90
FFS, OU-2: 7/17/91
ROD, OU-2: 9/27/91
Background

EPA Fund-lead
PRPs: ML Industries, Inc., National
Smelting of New Jersey, National
Smelting land Refining Company,
Standard Metals Corp, and
generators;
FFS prepared by: EPA Region 2

2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 9,800 cubic yards of kiln slag in four piles

• 200 cubic yards of lead oxide

3. What type of site is this?

Primary Metal Products. An abandoned secondary lead smelting facility. Pollution originated

as a result of secondary smelting of lead bearing materials, including batteries.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?
^ ' : ' ." ' - I

Standard technologies considered during the identification and screening of technically feasible

technologies were: .
-------
Access restriction:
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Upgrading site security
Stabilization/solidification
Hazardous waste handling
Rotary kiln incineration
Excavation, hazardous waste handling, on-site disposal, off-site
disposal , ,
'o
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Phys/Chem treatment: Ex situ waste washing, in situ waste flushing, hydrometallurgical
leaching process
Thermal treatment: In situ vitrification, flame reactor
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SP-2
RAA-SP-3
RAA-SP-4
Innovative Technology
On-site vitrificatidn/on-site or off-site
disposal .
Off-site flame reactor
On-site hydrometallurgic leaching/on-
site or off-site disposal
Estimated Costs
3 Criteria
$5,927,200
$4,215,100
$3,269,500
9 Criteria
eliminated
$4,215,100
$3,269,500
D
224
-2-
-------
7. How did the cost(s) compare to standard technologies?
I
.Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-SP-1
RAA-SP-5
RAA-SP-6
RAA-SP-7
Standard Technology
No action
On-site stabilization/solidification/
on-site disposail
Off-site stabilization/solidification/
off-site disposal
Off-site disposal
Estimated Costs
3 Criteria
$439,900
$3,465,200
' ' , !
- 1
$6,159,100
• i
$4,795,600
9 Criteria
$439,000
$2,303,100
eliminated
eliminated
8. If a standard technology was chosen, why?

The alternative RAA-SP-5 (on-site stabilization/solidification, on-site disposal) was selected
because it is highly effective in treating inorganic contamination and will inhibit leaching of
contaminants, on-site treatment reduces the chances of spillage of hazardous waste in transit, it
does not involve handling of hazardous treatment chemicals, it is relatively simple to
implement because it involves a one-step mixing and placement process, it is proven for
CERCLA waste contaminated with metals, mobile treatment units are available, it is expected
that treated materials would meet RCRA regulatory levels, it is the least expensive alternative,
it is able to maintain permanent protectiveness over the long term, sen/ices and materials are
readily available, and it satisfies the statutory preference for treatment.'
' -- i . • . . , ' ' -
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
- - ' i .. ' '
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the RAAs; or during the
detailed evaluation.

Innovative technologies eliminated during the initial screening include Jhe following:
'i ' •
• - .Ex situ washing/extraction was eliminated because available information indicate that
soils from battery recycling operations, in general, are not highly responsive to soil
washing conditions tested by EPA. Contaminated materials that Imve undergone years
of weathering may not readily re'spond to washing. Lead cannot by physically
separated from the contaminated material by particle size separation. The presence of

v ' •• •. -3- " ; ..'-:'.. 225
-------
11.
metals other than lead may makeJead extraction agents ineffective. Multiple steps of
washing may be required. Extracted solution needs extensive treatment. ;

Innovative technologies eliminated during the RAA screening include the following:

• On-site vitrification (RAA-SP-2) was eliminated because of the limitation in
availability of the electric pyrolyzer, its lack of effectiveness in treating volatile metals,
low processing capacity, lack of full-scale data, and high costs.

Innovative technologies eliminated during the detailed analysis include the following:

• Flame reactor (RAA-SP-3) because its implementability on a commercial scale has not
been proven, it has not been used at any Superfund site, markets have not been
identified for process by-products (may further increase costs), regulatory permits must
be' obtained, implementation depends on availability of an operating facility at the time
of remediation, and it is more expensive than the selected technology. -

" Hydrometallurgical leaching (RAA-SP-4) was eliminated because long-term
monitoring is required, uncertainty exists about its effectiveness and implementability
since.it has not been applied to similar waste material, it is more complicated than .the
selected technology, it requires handling of hazardous materials, it may require a series
of steps to leach multiple contaminants, it would produce a slag and lead oxide residue
that would require disposal, it would produce large amounts of liquid wastes that
would require disposal, and it is more expensive than the selected technology.
Which of the nine criteria were weighted more heavily in selection of the technology? Did
failure to meet one of the nine criteria result in the elimination of the innovative technology?
If so, which criterion? Which of the criteria supported the use of a standard technology?

For those alternatives that were considered protective and attained ARARs, the criteria
weighted most heavily were implementability and cost. Implementability was most important
in the elimination of the flame reactor and hydrometallurgieal leaching alternatives.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
Arsenic
20 .
NJDEP
Noncarcinogens
Lead
Cadmium
Antimony
100
3
10
NJDEP
NJDEP '
NJDEP
)
226
-4-
-------
•New Jersey Department of Environmental Protection—Environmental Cleanup
Responsibility Act Guidelines.

For carcinogens an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For noncarcinogens a Hazard Index less than or equal to 1.0 was acceptable.
13.
Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was chosen, could it meet the cleanup goals? | ,
No innovative technologies were eliminated because of cleanup goals.
technologies selected could meet cleanup goals.
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Proven reliability
Single vs. multi-step treatment

16. How are alternatives compared?

The reliability of the off-site flame reactor (RAA-SP-3) and on-site hydrometallurgical
leaching (RAA-SP-4) was a significant concern. Flame reactors have not been proven on a
commercial scale or at a Superfund site. In addition, markets have not been identified for the
process byproducts, which could increase costs. Hydrometallurgical leaching is a proven
technology within the hydrometallurgical industry, however, the process has not been used for
similar applications on waste materials. In addition, it may require a series of steps to leach
multiple contaminants and would produce a slag and lead oxide residue, which Could require
disposal. The selected remedy, solidification/stabilization (RAA-SP-5) is relatively simple to
implement because a one-step mixing and placement process is used. The technology is
readily available and has been proven effective on similar waste sites In, addition, the selected
remedy is the least expensive treatment and disposal alternative for treating the slag and lead
oxide piles.
The standard
17. What technical considerations were factors in the, selection of a remedy?- Were technical
considerations primary in the selection of the remedy?

base
.The NL Industries facility ,is in an industrial park, near a military
from the Delaware River. A thin layer of topsoil overlies sandy
heterogeneous nature of the waste matrices precluded the use of many
such as those that flush contaminants from waste or entrap
-5-
and a mile and a half
subsurface soils. The
in sjtu technologies,
contaminants, and therefore, was a
227
-------
primary consideration for their elimination. The nature of the waste was most important in
selection of a remedy. Technical considerations did not appear to be primary in the selection
of a remedy at this site.
228
-6-
-------
Paisley Solvents and Chemical, Inc.

Hempstead, New York
Region 2
GENERAL SITE INFORMATION

7. What were the principal contaminants,
contaminant levels, and met
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Trans- l;2-Dichloroethene
1,1,1-Trichloroethane
Trichloroethene
Tetrachloroethene
Toluene
Xylene
Di-n-butyl phthalate
' Naphthalene
Bis-(2-ethylhexyl) phthalate
Fluoranthene
ninants,
addressed in
-
mcipal

82 . '
470
120
270
470
35
150
43

Site
NPL Proposed:
NPL Final:
FS:
ROD:

History
N/A
6/10/86
2/92
4/24/92
Background

PRP-lead

PRPs: Commander Oil Company, Pasley
Solvents

FS prepared by: Metcalf and Eddy,
Incorporated

120
110

What volume of material is to be remediated? -L
. • , ' ' I '" . .
The volume of material to be remediated included: !
'
• 13,000 cubic yards of soil ,|
' ' Ji

What type of site is this? < . ; •

Chemicals and Allied Products. A former tank farm that was used for the storage of oils,
solvents, and chemicals. ,
TECHNOLOGY SELECTION
i
4. What standard technologies were considered for selection in this FS?
• •• . i • ' ' ' ' - '
Standard technologies considered during the identification and screening of .technically feasible
technologies were: • ' . , '
Access restriction:
Containment:
Deed restrictions :
Cap (concrete, clay, and polymeric), dikes, berms
-1-
229
-------
Chemical treatment:
Thermal treatment:
Disposal:
.In situ stabilization/solidification
Off-site incineration, on-site incineration
Excavation, off-site disposal at RCRA facility
Was an innovative technology consideredin the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ biodegradation, ex situ biodegradation
Chemical treatment: Soil washing (aqueous solutions), soil flushing (aqueous solutions)
Physical treatment: Soil vacuuming
Thermal treatment: In situ vitrification
6. What was the cost estimate for the innovative technology?

The RAAs discussed in the ROD are presented parenthetically under the list of alternatives.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) ,
Alternative
RAA-7 (RAA-5)
RAA-8 (RAA-6)
RAA-9
(RAA-7)
Innovative Technology
Soil flushing
Soil vacuuming
Soil vacuum extraction/soil flushing
if needed
Estimated Costs
3 Criteria
$185,000
$1,562,000
$1,649,000
9 Criteria
$185,000
$1,562,000
$1,649,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology
No action/deed restrictions
Estimated Costs
3 Criteria
$66,000
9 Criteria
$66,000
200
-2-
-------
Alternative
RAA-2
RAA-3
(RAA-2)
RAA-4
(RAA-3)
RAA-5
RAA-6
(RAA-4) .
Standard Technology
Excavation of top 4 feet of soil/off-site
disposal/impermeable cap
Excavation of all contaminated soil/off-
site disposal
Excavation of all contaminated soil/off-
site incineration
Excavation of all contaminated soil/on-
site incineration
Excavation of all contaminated
soil/stabilization/sdlidification
Estimated Costs
i
3 Criteria
$5,09.5,900
i
$8,675,000
$43,970,000
$13,890,800
$2,105,000
9 Criteria
eliminated
$8,675,000
$43,977,000
eliminated
$2,108,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why? 1"

The selected alternative includes soil vacuum extraction and/or soil flushing in conjunction
with groundwater extraction and treatment. This remedy was selected because: 1) it would
immediately remove VOCs in the vadose zone and enhance biodegradation of semi-volatiles,
as well as remove semi-volatile and metals with long term soil'flushing if needed, 2) easily
implementable, 3) cost effective, 4) treatment reduces soil as a source of contamination to
groundwater, 5) .avoids excavation. * i
10. If an innovative technology was not chosen, why not? At what stage wtis the innovative
technology eliminated? j
. i
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tliree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:
•-..}••'• ••'.'-
• Soil washing was eliminated because it would involve excavation and subsequent
treatment on-site; be more expensive than soil flushing; and would not offer any
greater benefit. j
• In situ biodegradation was eliminated because it has not been proved effective for
^ chlorinated organics. In addition, the site's heavy metals could inhibit microbial
growth.
• Ex situ biodegradation was eliminated because it has not been demonstrated on a wide
scale and because heavy metals could adversely affect microbial activity.
-3-
231
-------
11.
12.
» In situ vitrification was not incorporated into a remedial alternative but the reason for
its elimination was not discussed.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• None
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted criteria in the selection of an innovative technology were
implementability; reduction of mobility, toxicity and volume; and cost effectiveness.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens ,
Trichloroethene
Tetrachloroethene
Bis(2-ethylhexyl)
phthalate
1
1.4
50
MCL"
MCL
NYAWQS"
Noncarcinogens '
Trans 1,2-
dichloroethene
1,1,1 -Trichloroethane
Toluene
Xylene
Di-n-butyl phthalate
Naphthalene
Fluoranthene
0.5
1
1.5
1.2
50
50
50
MCL
MCL ;
MCL
MCL
NYAWQS
NYAWQS
NYAWQS
"No chemical-specific cleanup levels exist for soils, soil remediation levels protective
of ground water were estimated based on Maximum Contaminant Levels (MCLs).
bNew York Ambient Water Quality Standard. .
232
-4-
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? !

Innovative technologies eliminated because of cleanup goals include: j' - , ' . '

• None : ,

Standard technologies eliminated because of cleanup goals include:

• None
1 '; , i

14. Were treatability studies conducted on the innovative technology or standard technology? -.
. .
No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?
: ' . ' ,
The following measures were used to compare the alternatives: i

, -,. Cost-effectiveness |
- Preference for treatment (vs. containment) '
. i, , j
• ! • " •' '
16. How are measures compared?

The selected alternative employs treatment technologies instead of excavation and disposal.
Treatment technologies were preferred over excavation and disposal because site contaminants
would be directly addressed and short-term risk would be reduced sinpe treatment would be
conducted in ,situ. Cost-effectiveness also was an important factor in (selecting the preferred
alternative. Several alternatives (RAA-5 and RAA-6) offered a similar degree of protection,
but would be much more expensive to implement; therefore, the chosen alternative was the
, most cost-effective. ;
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? !

Site characteristics were not factors in selecting a remedy. [
233
-5- ., T • '
-------
Pittsburgh Air Force Base Landflll-022
OU-1

Plattsburgh, New York
Region 2
GENERAL SITE INFORMATION
L
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

DDD
DDE
DDT
Waste (mg/kg)

Carbon tetrachloride
Chloroform
Bis(2-ethylhexyl)phthalate
PHCs
Aluminum
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Silver
Sodium
Zinc
16
0.855
3.505
0.116
18,000
19,000
1,700
2,100
128,000
151
412
5,150
130,500
974
7,355
18
23,300
33,300
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
11/21/89
7/92
9/93
Background

Federal Facility
PRPs: U.S. Air Force Strategic Arms .,
Command, Department of Energy
FS prepared by: ABB Environmental
Sendees, Inc.
2. What volume of material is to be remediated? . .

The volume of material to be remediated included:

• 524,000 cubic yards of fill material

3. What type of site is this? ;

Military. An inactive landfill on an Air Force Base. The site is located in a suburban ;area.

234 _,_
-------
TECHNOLOGY SELECTION r |
' • ' --'I'- ' ' '
4. What standard technologies were considered for selection in this FS?\

Standard technologies considered during the identification and screening of technically feasible
technologies were: ;
' ' c " - • • ' '
Containment: Cover (soil, clay), hydraulic barrier cover | ,
Chemical treatment: In situ stabilization
Thermal treatment: Incineration !
Disposal: Excavation, disposal in permitted landfill, landfill closure
5. Was an innovative technology considered in the FS? If so, which tecfmolpgy?

Innovative technologies considered during the identification and screeiiing of technically
feasible technologies were: . |
-•- . ' • \ I-
No innovative technologies were considered.
6. What was the cost estimate for the innovative technology?
I . - .
" • ' ' ' • '!•'•' •
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. j -

No innovative technologies were considered for remedial alternatives.

7. How did the cost(s) compare to standard technologies?

• • Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action .
Site grading/vegetative cover/landfill
closure
Low-permeability barrier cover system
Excavation/incineration
Solidification/stabilization
Estimated Costs
3 Criteria
N/A'
'N/A
i
. MA
N/A
N/A
9 Criteria
$676,000
$2,114,000
$5,062,000
eliminated
eliminated
-2-
235
-------
8. If a standard technology was chosen, why? , )
The selected remedy was chosen because it permanently reduces risks to human health and the
environment by eliminating, reducing, and controlling exposures to human and environmental
receptors through engineering controls. The cover eliminates direct exposure to site
contaminants. It also reduces infiltration of precipitation into the landfill waste material and
minimizes the potential for contaminant migration from waste materials. It was estimated that'
the cover will reduce infiltration by 9 percent. The cover will not pose short-term risk or
cross-media impacts because of erosion controls, maintenance, and monitoring that will
mitigate potential impacts. It is easily implemented, attains all ARARs, and is cost-effective.
9. If an innovative technology was chosen, why? ,

An innovative technology was not selected.

10, If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
1 :
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
>" • ' •' • '• : ;
Innovative technologies eliminated during the initial screening include the following:
•
. • •
• None , '

Innovative technologies eliminated during the screening of the three criteria include the
following: ! .

• None • '

Innovative technologies eliminated during the detailed analysis include the following:

• None ' . '
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology?, If so,
which criterion? Which of the .criteria supported the use of a standard technology? .
/ •
The criteria that were most heavily weighted in selecting a remedial alternative were long-term
effectiveness and cost. The chosen alternative provides adequate long-term protection at
minimal cost. .. .
236
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12. What cleanup goals were selected? If the cleanup goal was based on an ARARs, what was
that ARARs? What risk level was selected to establish cleanup goals?,
' ' ' . ' • i -
Cleanup levels were not established for this site because discrete source areas were not found.

I
13. Was the innovative technology eliminated because of the cleanup goalts? Could the standard
technology meet the cleanup goals? ^ i

Innovative technologies eliminated because of cleanup goals include: i

• " None ' • • . . i • . ' ! ;.
• '' ' , !
Standard technologies eliminated because of cleanup goals include: j '

• • None, ... . • ' j
' '' , •. ' . • •
' . , • ' i '
I
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. I ,

15. What measures/criteria were used to compare alternatives?
i ,
The following measures were used to compare the alternatives:

' .-*--. ' . ' I '
Cost-effectiveness ^

i •

16. How are measures compared?

The chosen alternative was preferred because it offers longrterm effectiveness at the lowest
cost. RAA-3 would have offered slightly greater long-term effectiveness but it would be more
costly. RAA-4 and RAA-5 were eliminated in the three-criteria evaluation because they would
be too costly.
• . . - i , •, ' •
"* ' ' i .

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ]

No technical considerations were primary in selecting a remedial alternative.
237
-4-. ' :
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Plattsburgh Air Force Base Landllll-023
OU-3

Plattsburgh, New York
Region 2
Site History
NPL Proposed:
NPL Final:
ROD:
Background
Federal Facility .,
PRPs: U.S. Air Force Strategic Arms -.'
Command, Department of Energy
FS prepared by: ABB Environmental
Services, Inc.
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Fluoranthene 122.5
Naphthalene • 2.725
2-Methylnaphthalene 2.125
Acenaphthalene 12.825
Dibenzofuran 7.325
Phenanthrene 0.144
Anthracene 25.7
Pyrene 105.5
Benzo(a)anthracene 36.5
Chrysene 35
Benzofluoranthene 37
Benzo(a)pyrene ' 21.2
Indeno(l,2,3-cd)pyrene 4.65
Dibenzo(a,h)anthracene 2.8
Fluorene 12.325
Benzo(g,h,i)perylene 3.85
Aroclor 1254 . 0.19
Silver 0.013
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 406,000 cubic yards of landfill waste

3. What type of site is this?

Military. An inactive landfill on a U.S. Air Force base located in a suburban
N/A
11/89
5/92
9/92 ,

area.
238
-i-
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: _ , !
1 •! ' •' ' • '
Containment: Capping, surface water management, vegetation establishment
Chemical treatment: In situ stabilization/solidification i
Thermal treatment: Incineration ,
Disposal: Excavation, off-site disposal ,
l
"' • • ' i ' • ' •' . . .•'
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: . i

No innovative technologies were considered.
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) i
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action
Site grading/vegetation establishment
Low permeable barrier cover system
Excavation/incineration
In situ stabilization/solidification
Estimated Costs
3 Criteria
N/A
N/A
N/A
.. N/A
N/A "
9 Criteria
$793,0000
$1,975,00
$3,586,000
eliminated
eliminated
-2-
239
-------
3. If a standard technology was chosen, why? , <•

The selected remedy was preferred because it offered the greatest protection to human health
and the environment and the greatest long-term protection. The selected alternative minimizes
risk associated with exposure to site contaminants in surface soil through the implementation
of a low permeable barrier cover. This remedy also minimizes the infiltration of precipitation,
thereby reducing the potential for contaminant migration to ground water and for leachate
discharge to wetlands. The implementation of the remedy will not pose any unacceptable
short-term risk or cross-media impacts. The selected remedy meets all ARARs. The selected
remedy is cost-effective since the overall effectiveness will be proportional to its costs. .
9.
JO.
If an innovative technology was chosen, why?

An innovative technology was not selected.

If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

* None

Innovative technologies eliminated during the screening of the three criteria include the
following:
i
* None , . •'.'''

Innovative technologies eliminated during the detailed analysis include the following:

• None
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology?, If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and long-term effectiveness were the criteria
most heavily weighted in selecting a remedial alternative. Though it was more costly and
more difficult to implement, the selected alternative was preferred because it offered the
greatest protection and long-term effectiveness of all of the alternatives considered in the
detailed analyses. , :
240
-3-
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12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? , '
1 - I ' ' -

Cleanup goals were not established for soil contaminants. Chemical-specific ARARs are not
available. Risk-based cleanup goals were not established for LF-023 source control because
discrete source areas (e.g., hot spots) were not found. !
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? i
-. - i .
Innovative technologies eliminated because of cleanup goals include:
1 ' i , • '
!'
• . None . : I

Standard technologies eliminated because of cleanup goals include:

• None , -
14. Were treatability studies conducted on the innovative technology or standard technology?
• : • ' ,1 ' •
.1 ' , '
Treatability studies were not conducted: :
75. What measures/criteria were,used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved \ . . ''
- . Total cost • 'i
Short-term risk '.
Proven reliability , I

16. How are measures compared? •" ],- '
. • i
The chosen alternative was preferred because it reduces site risks more than other alternatives
included in the detailed analyses, thereby providing the greatest protection. Other technologies
(stabilization, incineration) were eliminated after the three criteria analyses. Stabilization was
eliminated because it would be very expensive, would require a treatability study, and would
be difficult to implement. Incineration was eliminated because it would be very expensive and
could pose'short-term risk during excavation. - i
17. What technical considerations were factors in selecting a remedy? Were, technical
considerations primary in the selection of the remedy? " . {
-. . . i
No technical considerations were primary in selecting a remedial alternative. The unknown
depth of contaminants and the lack of any identified hot spots caused the elimination of
incineration and stabilization. ' " ;. . .1 '•"..,
-4-
241
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Preferred Plating Corporation
OU-2

Farmingdale, New York
Region 2
GENERAL SITE INFORMATION

I. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Magnesium
Nickel
Silver
Zinc
Cyanide
Chloroethane
1,1 -Dichloroethane
1,1,1 -Trichloroethane
1,2-Dichloroethene
Tetrachloroethene
Trichloroethene
2.5
1
468
1,890
151
158
7,900
141
14.9
243 .
678
5.9
20
270
15
5.4
5
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/15/84
6/10/86
7/92
9/28/92 .
Background '

EPA Fund-lead
PRPs: Preferred Plating Co.
FS prepared by: Malcolm Pirnie,
Inc. i
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 7,200 cubic feet of soil .

3. What type of site is this?

Electroplating. A former metal plating company located in a light industrial area.
242
-i-
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? | ,
i. - •
'. Standard technologies considered during the identification and screening of technically feasible
; technologies were:

Chemical treatment: Fixation, stabilization/solidification
5. Was an innovative technology considered in the FS? If so, which technology?
• . - ' , - ' i'-
Innovative technologies considered during the identification and screening of technically
feasible technologies were: I
' i ' '
i '
Chemical treatment: Oxidation/reduction, in situ soil flushing, ex, situ soil washing
Thermal treatment: In situ vitrification
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically.feasible technologies are identified
(prior to the formulation of'RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; and community acceptance.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-6
RAA-7
Innovative Technology
Ex situ soil washing
In situ soil flushing via vertical ground
water wells
In situ soil flushing via horizontal
ground water wells '
i
Estimated Costs
3 Criteria
rt/A ;
IR/A
1
N/A
9 Criteria
$2,761,150
eliminated
eliminated
-2-
243
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-4
RAA-5
=====
Standard Technology
No action
Excavation/off-site stabilization and
disposal
In situ stabilization by in situ soil
mixing
In situ stabilization by jet grouting
'
•
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
." Li i i- .^^^— ^^_
—^ ^SSi
9 Criteria
$132,947
$1,423,700
eliminated
eliminated
==^ —
8. If a standard technology was chosen, why?

RAA-2 was selected because it protects human health and the environment. RAA-2 is
designed to be protective by eliminating cross-media impacts posed by highly contaminated
site subsurface soil to the underlying ground water. Since the site is located in a sole source
aquifer area, restoration of the aquifer quality is crucial. By removing the contaminated soil
this alternative ensures that no leaching of contaminants will occur. The elimination of cross-
media impacts will facilitate future implementation of the ground water restoration program.
The selected remedy treats the site's inorganic and organic contaminated soil through ;
excavation, off-site stabilization/solidification, and disposal. This alternative provides long-
term effectiveness and permanence since the potential for future release of contaminants to the
underlying ground water will be permanently eliminated. Extraction and treatment of the, site's
soil reduces the toxicity and mobility of the site contaminants. No short-term adverse impacts
and threats to human health and the environment are expected as the result of implementing
the selected remedy. To minimize and/or prevent worker exposure to contaminants, personal
protective equipment will be utilized. This alternative complies with all ARARs and is cost
effective since it fully protects human health and the environment at the least cost.
9.
If an innovative technology was chosen, why?

An innovative technology was not selected.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ;

Innovative technologies eliminated during the screening of the three criteria include the
following: :

• In situ soil flushing with vertical wells was eliminated because the technology could
increase ground water contamination! Constructing an effective collection system in
the highly permeable site sands would be difficult. In addition, the affected area
cannot be easily identified or controlled; associated environmental and public health
risks could be increased. .
• In situ soil flushing with horizontal wells was eliminated because this technology has
not been previously used for the extraction of heavy metals in soil and due to the
problems associated with recovering flushing fluids in highly permeable site soil.
1 ' 'I , •
Innovative technologies eliminated during the detailed analysis include the following:

• Ex situ soil washing was eliminated because it would be too costly and its
implementability is somewhat uncertain. The technology has been implemented only
on a limited basis in the United States and would, therefore, require treatability studies.
Further, this technique has been used in Europe on a full-scale basis only for the
' removal of heavy metals. The high cost associated with this technique is based on the
assumption that the treatment facility necessary for performing this process would be
available only overseas by the'implementation time; therefore, transportation costs
would be high. i

77. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so, ,
which criterion? Which of the criteria, supported the use of a standard technology?
• . ' - . i
The criteria most heavily weighted in selecting a remedial alternative; were protection to human
health and the environment and cost. The selected remedy was the least expensive treatment
option. > I . '
L, • '
In situ soil flushing was eliminated because it would be infeasible to;implement because of
highly permeable site soil. Ex situ soil washing was eliminated because its costs would be too
high and its implementability is uncertain. ..-.'• | ' ,
245
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No cleanup levels were established. :
I

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? . j

Innovative technologies eliminated because of cleanup goals include: ,

• None

Standard technologies eliminated because of cleanup goals include:

• None .

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives? ".-.'"'

The following measures were used to compare the alternatives: : MB |

Cost-effectiveness :
Proven reliability / ' ' ;|
Capital costs ;

16. How are measures compared?

RAA-2 provides protection to human health and the environment at the least cost. RAA-3
might provide equal protection and would provide a higher degree of long-term effectiveness,
but it would be more costly, and its implementability was less certain. The capital cost for
RAA-3 would be high based on the assumption that the treatment facility necessary for
performing this process would be available only overseas and not in this country by the time
the remedy would be implemented. Therefore, transportation costs would be high. The
implementability of RAA-3 was less certain because the proposed technology, ex situ soil
washing, has been performed only on a limited basis in this country. A treatability study
would be necessary to determine the exact nature of the extraction fluid to be used for
contaminant removal and most of the operating treatment facilities for soil washing are in
Europe.
246
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17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? !
i . • , ' -
While some technical site characteristics were considerations, they were not primary in
selecting a remedial alternative. The high soil permeability would make it difficult to control
in situ soil flushing and implementation of this technology could causle ground water
contamination. In situ stabilization could not be implemented because it would require the
demolition of existing buildings. .• -
-6-
247
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Ramapo Landfill
OU-1

Ramapo, New York
Region 2
j)
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

The remedial action objectives for this site
were based on containment and reduction of
contaminated landfill leachate into ground
water, rather than treatment of soil
contaminants. Soil samples were collected
and analyzed during the remedial
investigation and were included in the risk
assessment; no. principal soil contaminants,
however, were addressed in the FS.
2. What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1982
9/83
9/91
3/31/92
Background

PRP-lead
PRPs: Town of Ramapo
FS prepared by: URS Consultants;
Inc:
The volume of material to be remediated included:

• 2 million cubic yards of fill material

3. What type of site is this?

Municipal Landfill. An inactive landfill site. A portion of the site is currently being used as a
trash compaction and transfer facility by the town of Ramapo.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?
i

Standard technologies considered during the identification and screening of technically'feasible
technologies were: '

Access restriction: Fencing, posting, deed restrictions '
Containment: RCRA cap, multimedia cap, soil cap
Physical treatment: In situ solidification/stabilization
Thermal treatment: Incineration
Disposal: Excavation, disposal at a RCRA facility
248
-1-
-------
•hnoloKV?
5. Was an innovative technology considered in the FS? If so, which tec

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ bioreclamation
Chemical treatment: In situ soil flushing
Thermal treatment: In situ vitrification
6. What was the cost estimate for the innovative technology?
I •' ' -
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives thai: merit a more detailed
evaluation. For this site, the estimated costs were first calculated during an evaluation based
on nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
x reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; and community acceptance. The costs were recalculated in the ROD.
i - . • ' •• '
^ ' !
No innovative technologies were included in remedial action alternatives.
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) '
Alternative
RAA-1-
RAA-2
RAA-3
RAA-4A
Standard Technology
No action/ground water and air
monitoring
Posting/fencing/deed restrictions/
optional alternative water supply/
ground water and air monitoring
Posting/fencing/deed restrictions/
ground water extraction wells/ improved
leachate collection and discharge to
POTW/ground water and air monitoring
Multimedia cap/deed restrictions/
ground water extraction wells/improved
leachate collection and discharge to
POTW/ground water and air
monitoring/passive gas collection and
venting
Estimated Costs
9 Criteria
$3,260,000
$3,970,000
1
$2,530,000
$27,530,000
i
t
,
i
ROD
$3,260,000
$3,380,000
to
$3,970,000a
$6,206,000
to
$14,210,000"
$29,190,000
to
•$35,760,000b
-2-
249
-------
Alternative
RAA-4B
RAA-5
RAA-6
Standard Technology
Same as RAA-4A, except modified
multimedia cap
Multimedia cap with soil side slopes/
deed restrictions/ground water
extraction wells/improved leachate
collection and discharge to POTW/
ground water and air monitoring/
passive gas collection and venting
Multimedia cap/deed restrictions/
alternate water supply/ground water
extraction wells/improved leachate
collection and discharge to POTW/
ground water and air monitoring/ active
gas collection and venting
Estimated Costs
9 Criteria
$23,230,000
$19,800,000
$33,533,000
— -
ROD
$24,890,000
to
$30,880,000"
$21,410,000
to
$28,050,000"
eliminated
The higher end of the cost range reflects the additional cost for an optional alternative water
supply.
bThe higher end of the cost range reflects the additional cost for optional items such as
alternative water supply, ground water pretreatment, and treatment of landfill gases, :
!

8. If a standard technology was chosen, why?

The selected remedy includes: cap installation, ground water extraction, leachate collection,
perimeter drain, deed restrictions. This remedy was selected for the following reasons: 1) it
mitigates ground water contamination by reducing the amount of infiltration into the landfill,
2) size of the landfill, 3) reduction .of vapors, 4) prevents erosion and surface water runoff 5)
reduces contact with contaminated soil, 6) steep slopes limited capping options, 6) technically
implementable. ,

RAA-4B was selected as a contingent remedy.
9.
If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '

• In situ bibreclamation was eliminated because in situ treatment is not considered
feasible for the depth of waste at the landfill (up to 80 feet), j
• In situ soil flushing was eliminated because in situ treatment is, not considered feasible
for the depth of waste at the landfill (up to 80 feet). •'.-[•
• In situ vitrification was eliminated because in situ treatment is not considered feasible
for the depth of waste at the landfill (up to 80 feet).
j-
Innovative technologies eliminated during the screening of the three criteria include the
following: !
•' [ '
• None ! , ,

Innovative technologies eliminated during the detailed analysis include the following:
i
» None • •. T
11. Which of the nine criteria were weighted most heavily in selecting the .technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily was implementability. Though capping does not fully
comply with action-specific ARARs for landfill closure, it was chosen because it meets the
remediation objectives and is the easiest to implement. j
I

12. What cleanup goals were selected? If the cleanup goal was basedonanARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No soil cleanup goals were developed because the primary objective is to reduce the migration
of contaminants to ground water. As a result, containment, instead of treatment, was the
preferred remedial action.
,'.''. | '
For carcinogens an excess upper bound individual lifetime cancer risk of between 10 to 10"
was acceptable. For nbncarcinogens a Hazard Index less than or equail to 1.0 was acceptable.
AH human health risk assessment results were within EPA acceptable levels.
, , .'•!"•

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ;
i • • ' '
Innovative technologies eliminated because,of cleanup goals include: j .
i •
» None • " •'!•'••••
i • •

Standard technologies eliminated because of cleanup goals include: ;

• None

251
- • . • - " „ -4- i
-------
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
15.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability
Waste left in place/institutional controls
16. How are measures compared?

Although the large size of the landfill and the steep slopes make capping the site challenging
the selected technology is implementable and vendors are readily available for construction
Containment met the remedial objectives to reduce human and animal contact/prevent
inhalation of vapors and mitigate leachate to ground water.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were primary in the elimination of the three innovative technologies
considered. The depth of debris (80 feet) at the landfill precluded use of these technologies
In addition, the landfill's steep side slopes would make implementing a multimedia cap
difficult and more expensive.
252
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Roebling Steel Company
OU-2

Roebling, New Jersey
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
2.
Slag(mg/kg)

Arsenic
Carcinogenic PAHs
Chromium (total)

Soil (mg/kg)

PAHs
64
35
2,210
13
Site History
NPL Proposed:
NPL Final:
FFS, OU-2:
ROD, OU-2:
12/82
9/83 ,
6/91
9/26/91
Background
i

EPA Fund-lead
PRPs: Roebling Steel Company, CF&I
Steel Corporation, unidentified
other PRPs,
FS prepared by: Ebasco Services
Incorporated
What volume of material is to be
remediated? • ,

The volume of material to be remediated included:

• 1,458,000 cubic yards of slag material
• 160 cubic yards of soil
3. What type of site is this? .

An inactive production facility for steel wire and cable, as well as recent use for various
industrial operations. . l ."•''.-
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?\
r . ' /
\ . • • ' -
Standard technologies considered during the identification and screening of technically .feasible
technologies were: ,I :
Access restriction: Site fencing, deed restrictions, monitoring
-1-
253
-------
Containment:

Chemical treatment:
Thermal treatment:
Disposal:
Clay cap, synthetic membrane cap, chemical sealants, soil cap,
multimedia cap, vertical barriers
In situ solidification, stabilization (of slag areas)
Incineration -
Off-site disposal at RCRA landfill, on-site disposal at RCRA landfill,
off-site disposal in nonhazardous waste disposal site, on-site disposal'
in nonhazardous waste disposal site
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation
Phys/Chem treatment: Supercritical fluid extraction, soil washing and extraction, in situ
flushing
Thermal treatment: In situ vitrification
6.
What was the cost estimate for the innovative technology?

All innovative technologies were eliminated during the initial screening and, therefore have no
associated cost estimates. ':
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Slag
Alternative
RAA-SA-1
RAA-SA-2
RAA-SA-3A
Standard Technology
No action
Limited action
Excavation/on-site stabilization/
backfilling of hot spots/soil or
vegetative cover of entire slag area
Estimated Costs
3 Criteria
$318,200
$404,300
$9,684,500
9 Criteria
$397,700
. $505,400
$12,105,600
254
-2-
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Alternative
RAA-SA-3B
RAA-SA-4
RAA-SA-5
RAA-SA-6
Standard Technology
Excavation/off-site treatment and
disposal of hot spots/soil or vegetative
"cover of entire slag area
Containment — multimedia (RCRA) cap
Excavation/on-site stabilization
(solidification)/backfilling
In situ solidification
Estimated Costs
3 Criteria
$25,136,800
$21,12o,300
$46,055,700
i
i-
$175,969,200
9 Criteria
$31,421,000'
$26,407,900
eliminated
eliminated
1 RAA-SA-3B underwent detailed evaluation in the FFS but was not considered in me ROD.
A Proposed Plan was not available to explain this difference between ithe EPS and ROD.
1 • i

Soil • - ' ' • • , ' ' |
Alternative
RAA-PS-1
RAA-PS-2
RAA-PS-3
Standard Technology
No action
Limited action
Off-site treatment and disposal
Estimated Costs
3 Criteria
$78,900
$199,000
$91,600
9 Criteria
$98,600
$248,800
$114,500
8. If a standard technology was chosen, why?

Slag

The selected technology, RAA-SA-3 (on-site stabilization of hot spots, capping), was selected
because it is protective, attains ARARs, provides the most permanence of the alternatives
because highly contaminated areas would be treated, reduces the mobility of contaminants, and
affords the highest level of overall effectiveness in proportion to its cbst. RAA-SA-1 and
RAA-SA-2 would not be protective of human health and the environment. RAA-SA-4 might
pose the same risks as RAA-SA-1 or RAA-SA-2 in the long run if the cap system fails or
deteriorates. RAA-SA-3 and RAA-SA-4 would provide overall protection by reducing the risk
' of public exposure, but RAA-SA-3 was chosen because it would be more cost-effective and
more permanent than RAA-SA-4.
i
Soil . ;, .-,-.'.' '•.' j • .

RAA-PS-3 was selected to remediate park soils because it would provide overall protection of
human health and the environment by removing the contaminated material and reducing the
risk of public exposure. In addition, there are ho O&M costs for this alternative. , RAA-PS-1
and RAA-PS-2 would not provide protection of human health and thb environment or attain
ARARs since contaminated soil would remain in place. i
255
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-------
9. If an innovative technology was chosen, why?

An innovative technology was not chosen. ^J

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ; ' .

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening by the three criteria of '
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include:

• Soil washing and extraction was eliminated for the slag material and soil because the
type and number of contaminants would require a variety of washing and extraction
solutions and a number of washing stages to reduce contaminant levels. In addition,
the volume of park soil is too small for a washing and extraction system. Capital and
O&M costs would be high. Bench-scale tests would have to be performed to!
determine if cleanup levels could be reached.
• Supercritical fluid extraction was eliminated because it is not applicable to the
numerous types of heavy metals in the slag material and park soil. In addition, the
volume of park soil is too small for a supercritical fluid extraction system. Capital and
O&M costs would be high. The technology has not been demonstrated at a hazardous
waste site. ,- — -
• Biodegradation was eliminated because it is not applicable for treating metal J
contaminated materials in the slag material. The volume of park soil is too small for a
biological treatment system. It is a developmental technology that would require
extensive, bench and pilot scale testing. Uncertainty exists regarding its effectiveness
in remediating PAH contaminated materials. Capital and O&M costs would be
moderately high. ;
« In situ flushing was eliminated for the slag material because its non-homogeneous
nature (fractured) would be difficult to control the flushing process and achieve
cleanup levels. It would not be feasible for the park soils because of the small areas
of contamination and it is only surface soil. The numerous types of metals and PAHs
in the slag material would require several types of flushing solutions and many stages
to remove the contaminants. Capital costs would be moderately high and O&M costs
would be high.
• In situ vitrification was eliminated because many of the heavy metals in the slag
material would vaporize, requiring air emissions controls. Dewateririg of the slag area
would be difficult because of the fractured nature of the material and the material
abuts the Delaware River. It would not be feasible for the park soil because the
contamination is located in two small separate areas near the surface. Capital costs
would be moderately high and O&M costs would be high. ' ".

No innovative technologies were eliminated during the three-criteria screening process or
during the detailed analysis.
256
-4-
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
•]:'•'
For those alternatives that were protective and attained ARARs, the criteria weighted most
heavily is selecting a remedy were long-term effectiveness and cost. Innovative technologies
were not included in any RAA, therefore, they were not evaluated using the nine criteria.
Innovative technologies were eliminated during the initial screening based on effectiveness,
implementability, and cost. ;
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? '
• '. ' • • ' i . '
, . ^ . (
Soil Remediation ,
Contaminant Cleanup Level (rag/kg) ARAR or Other Basis
Carcinogens
Carcinogenic PAHs
10
NJDEP
"New Jersey Department of Environmental Protection Interim Soil Action Levels,
February 1990. • ' i
Slag Remediation
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Carcinogenic PAHs
Chromium VI
20
10
100 (total Crb)
NJDEF
iNJDEP
NJDEP
Noncarcinogens
Chromium IJJ
100 (total Crb)
NJDEP
"New Jersey Department of Environmental Protection Interim Soil Action Levels,
February 1990. ' i .
"Total chromium is assumed to be 95 percent Chromium IJJ arid 5 percent Chromium
VI.

For carcinogens, an excess upper bound individual lifetime cancer risk of between 10;4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
257
-5-
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13. Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was selected, could it meet the cleanup goals? ^& \

Innovative technologies were eliminated primarily because of the various types (organic and
inorganic) of contaminants and the volume of contaminated material rather than cleanup goals.
The standard technologies selected, ex situ stabilization and capping, could meet cleanup goals.

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives? ' • >

The following measures were used to compare the alternatives:

Impact on neatby populations ;
Preference for treatment , .
Total cost !~
Waste left in place

16. How are alternatives compared? :

^1^ '
The selected remedy will significantly reduce the risks associated with exposure to slag '
contaminants and reduce contaminant migration to the environment through treatment and
containment. The selected remedy will reduce any potential risks associated with direct
exposure to the contaminated park soil through excavation and off-site treatment and disposal.
Of the two alternatives for remediating the slag material that were considered protective, RAA-
SA-3 was less costly that RAA-SA-4 and included treatment (rather than containment) of
highly contaminated material. Of the alternatives for remediating the park soil, other than no
action, RAA-PS-3 was less costly than RAA-PS-2 (limited action) and would not leave waste
in place.

' •
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The slag area, which borders the Delaware River shoreline, ranges in thickness from several
inches to 30 feet, with the thickest deposits generally located adjacent to the river. Depth to
groundwater ranges from zero to 10 feet. The river is subjected to tidal influence (6.9 feet).
The slag fill contains both organic and inorganic contaminants and is believed to contain
numerous fissures and voids due to its very coarse nature. Although the proximity to Aground
water and to the Delaware River led to the elimination of some technologies, the volume and
nature of the contaminated material was more important in selection of a remedy. Technical
considerations could not be considered primary in remedy selection at this site.
258
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Rowe Industries Ground Water Contamination
Town of Sag Harbor, New York
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg) • , •'

Trichloroethene 0.098
1,1,1-Trichloroethane 0.008
Tetrachloroethene 67
Xylenes 0.001
Toluene 0.001
Ethylbenzene 0.002
Acetone • 0.006
Methylene chloride 0.001

Dry well sediment (mg/kg)

Tetrachloroethene 9.1
1,1,1-Trichloroethane 53
Trichloroethene 27
1,1-Dichloroethane 2,4
1,2-Dichloroethene 28
Xylenes 20
Toluene 27
Ethylbenzene 2,3
Acetone 19
Methylene chloride 0.44
Freon 113 230
NPL Proposed:
NPL Final:
FS:
ROD:
Site History
N/A
6/10/86
7/92
9/30/92
Background
i
PRP-lead
PRPs: Nabisco Incorporated, Sag
Harbor Industries
FS prepared by: LEG Engineering
Services, Inc.
2. _ What volume of material is to be remediated?

The volume of material to be remediated included:

• 365 cubic yards of soil/sediment
259
-i-
-------
3. What type of site is this?

Electrical Equipment. An active electronic devices manufacturing facility located in an
industrial area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? :

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Deed notations
Slurry-cutoff wall, capping
Chemical treatment: Stabilization/solidification (lime-based, portland cement, thermoplastic,
in situ)
Physical treatment: Heavy metals separation
Thermal treatment: Incineration (rotary kiln, mobile electric fluid wall, infrared, plasma,
fluidized bed), dehydration .
Disposal: Disposal (on-site landfill, off-site landfill)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Composting/landfarming, liquid-soil contact digestion, white rot
fungus, in situ biodegradation, off-site biodegradation, augmented
bioreclamation
Phys/Chem treatment: Supercritical water oxidation, liquified gas solvent extraction, solvent
extraction, in situ soil flushing, soil washing, Basic Extraction Sludge
Treatment Process (BEST), soil vapor extraction
Thermal treatment: Pyrolysis, low-temperature treatment, in situ radio frequency, in situ
vitrification, steam stripping
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-5
Standard Technology
No action
Deed notation/physical restrictions/
monitoring
RCRA cap/deed notations/physical
restrictions/monitoring
Excavation/off-site disposal
Estimated Costs
3 Cnteria"
$0
$162;000to
$281,000
$111,1000 to
$164,000
$245,000 to
$245,000
9 Criteria
$0
$162,000 to
$281,000
$lll,000(to
$164,000
$245,000 to
$245,000
Ten-year present worth to 30-year present worth.
8. If a standard technology was chosen, why?

RAA-5 was selected because it provides the greatest protection to human health and the
environment by removing a continuing threat to ground water posed by the on-site
contaminated soils. In addition, it protects the sole source aquifer drinking water supply. Soil
with concentrations exceeding the recommended soil cleanup levels wiill be excavated and
disposed of off site. This alternative is the most protective because it ensures that all the
contaminated soil and any residual contamination will be completely removed from the site.
The selected remedy provides a very high degree of long-term effectiveness and permanence
because contaminated soil will be removed and the contaminated areas! restored. The
excavation of soil will effectively reduce the mobility of contaminants by eliminating this
pathway as a continuing source to ground water. The toxicity and volume of contaminated
soil will also be reduced. The short-term effectiveness and implementability of this remedy is
also high in that it will be conducted in a short time and have minimal effects on the -
surrounding community. It complies with all ARARs and is cost-effective. Though the
selected remedy is the most expensive option, it provides the greatest overall protectiveness.
-3-
261
-------
P. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Low-temperature thermal treatment was eliminated because the site's soil contains
more than 10 percent organics. :
• Composting/landfarming were eliminated because the site's soil contains chlorinated
solvents that are not readily biodegradable and cannot be treated by this process.
" Liquid-soil contact digestion was eliminated because the site soil contains chlorinated
solvents that are not readily biodegradable and can not be treated by this process.
» White rot fungus was eliminated because it has not been proved in field applications.
• Basic Extraction Sludge Treatment was eliminated because the site's soil does not
contain oil. , ..
• Solvent extraction "was eliminated because obtaining a solvent or solvent mixture
capable of extracting the contaminants of concern at the site^ would be highly1 unlikely
and might be prohibitively expensive.
• In situ biodegrodation was eliminated because the site's soil contains chlorinated
solvents which are not readily biodegradable and cannot be treated by this process.
• Off-site biodegradation was eliminated because the site's soil contains chlorinated
solvents which are not readily biodegradable and cannot be treated with this process.
• Augmented bioreclamation was eliminated because the site's soil contains chlorinated
solvents which are not readily biodegradable and cannot be treated with this process.

Innovative technologies eliminated during the screening of the three criteria of the technologies
include the following:

• Soil washing was eliminated because of high costs.
" Super critical water oxidation was eliminated because of high costs.
• Liquified gas solvent extraction was eliminated because the size of the equipment
needed and the mobilization/demobilization effort required to implement the
technology would be best suited for sites larger than Rowe.
• In situ soil flushing was eliminated because obtaining a solvent or solvent mixture
capable of extracting all of the site's contaminants would be highly unlikely and might
be prohibitively expensive.
• In situ radio frequency was eliminated because the implementability of this technology
would be limited by many factors, including soil type, moisture content, depth of
contamination, boiling points of contaminants; continuous monitoririg and experienced
field personnel would be required; and costs would be high.
• In situ vitrification was eliminated because of high costs.
• Steam stripping was eliminated because of high costs.

262
-4. '
-------
• Pyrolysis was eliminated because it would be inappropriate for treating the site's soil
constituents. ,
,^ ;. -*- -- ' i..
Innovative technologies eliminated during the detailed analysis include the following:

• Soil yappr extraction was eliminated because obtaining a vendor to implement the
technology for such as small area (20 ft by 20 ft) makes it infeasible.
11, Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and long-term effectiveness were the criteria
weighted most heavily in selecting a remedial alternative. The chosen alternative was
preferred because it offers the greatest protection and permanence-even though it is the most
expensive alternative. One other alternative, soil vapor extraction, that would offer almost
comparable protection and permanence and would utilize an innovative technology was »
eliminated because it would be difficult to find a vendor. ; .

Many innovative technologies were eliminated at least in part because of cost. These include
solvent extraction, soil washing, super critical water oxidation, in situ soil flushing, in situ
. . . radio frequency, in situ vitrification, and steam stripping.
12. What cleanup goals were selected? If the cleanup goal was based oh\an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? j
Contaminant
Cleanup Level (mg/kg) ARAR or Other Basis
Carcinogens
Benzene
Tetrachloroethene
Trichloroethene
0.05
1.5
Ground water3
Ground water
Ground water
Noncarcinogens
Xylenes
Ethylbenzene
Toluene
1,1 -Dichloroethane
1,1,1 -Trichloroethane
1,1 -Dichloroethene
1,2-Dichloroethene
1.2
5.5
1.5
0.2
0.5
0.5
Ground water
Ground water
Ground water
Ground water
Ground water
Ground water
Ground water
-5-
263
-------
"Soil cleanup levels were generated to restrict the concentration of compounds in the
soil to a level that would ensure that contaminants in the soil do not further
contaminate ground water.
.Ji
13.
\
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

" None

Standard technologies eliminated because of cleanup goals include:

• None , .
14.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Preference for treatment (vs. containment)
Waste left in place/institutional control
m
16. How are measures compared?

The chosen alternative was preferred because it provides the greatest protection and long-term
effectiveness. Institutional controls would not be protective since contaminants would continue
to leach to ground water. Institutional controls would offer a lesser degree of long-term
effectiveness since the likelihood of adequately enforcing deed notations and physical
restrictions cannot be guaranteed. Containment would not be as protective because it would
only minimize infiltration and reduce leachate. It also would offer a lesser degree of Ipng-
term effectiveness by eliminating the exposure pathway. Diligent maintenance of the cap and
long-term monitoring would be required for it to be fully effective. Additionally, capping
would not fully eliminate the possibility of contaminated soil acting as a source of ground
water contamination if horizontal flow is present within some portion of the lower 12 ft of
contaminated soil.
17.
Wltat technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
264
-6-
-------
Sinclair Refinery
OU-2

Wellsville, New York
Region 2
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
- • ' . ' . .
Maximum concentrations of principal • _ .
contaminants were:

Surface Soil (mg/kg)

Arsenic 43
Lead 1,190

Subsurface Soil (mg/kg)

t Arsenic ,88
" Lead 791

Site His

NPL Proposed:
NPL Final:
FS:
ROD:
-
Backgn

PRP-lead '
PRPs: Atlantic Richfi
FS prepared by: Ebasi
Incorporated

- ,
Xylene 26 • .
Naphthalene 3

tory'

1981
9/83
3/91
9/30/91 :

mnd

ild Company
;o Services

''
2. What volume of material is to be'remediated?

The volume of material to be remediated included:

• 7,710 cubic yards of surface soil
• 44,000 cubic yards of subsurface soil

3. What type of site is this?

Petroleum Refining. A former refinery. .

TECHNOLOGY SELECTION

4. . What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: .
265
-i-
-------
Surface Soil

Access restriction:
Containment:

Thermal treatment:
Chemical treatment:
Disposal:

Subsurface Soil

Access restriction:
Containment:

Chemical treatment:
Thermal treatment:
Disposal:
Public awareness program
Clay cap, asphalt cap, concrete synthetic membrane/multilayer cap,
soil cap ,
Incineration
Solidification/fixation (in situ and ex situ), thermoplastic solidification
Excavation, on-site disposal, off-site disposal at RCRA landfill
Public awareness program
Clay cap, asphalt cap, concrete synthetic membrane, multilayer cap,
soil cap, sheet piling, grout curtains, slurry walls
Solidification/fixation (in situ and ex situ)
Incineration
Excavation, on-site disposal, off-site disposal at RCRA landfill
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: . ' ' :

Surface Soil

Chemical treatment: Soilwashing
Biological treatment Biodegradatipn (ex situ) :

Subsurface Soil

Biological treatment: In situ bioremediation, landfarming
Phys/Chem treatment: Soil washing, soil flushing, vacuum vapor extraction
m
D.
6. What was the cost estimate for the innovative technology? ;

No innovative technologies were proposed for surface soil remediation.
266
-2-
-------
Cost Estimates for RAAs That Include Innovative Technologies

(selected remedial alternative is in bold) i
Subsurface Soil
=====
Alternative
RAA-2G
RAA-2D
RAA-2E

Innovative Technology
Vacuum vapor extraction/off gas
treatment/long-term monitoring
In situ soil flushing/ground water pumping
and treatment/long-term monitoring
In situ bioremediation/ground water
pumping and treatment/long-term
monitoring .
Estimated Costs
3 Criteria
$3,750,600
$7,930,600
j
1-
$3,310,600
i
i
1.
i
9 Criteria
$2,766,100a
eliminated
eliminated
This decrease in estimated cost was not explained. It reflects a decrease in the estimated

initial cost. •
-.-••• • . . -
7. How did the cost(s) compare to standard technologies? ' | \

Cost Estimates for RAAs That Include Standard Technologies

(selected remedial alternative is in bold)
Surface Soil
Alternative
RAA-1A
RAA-1B
RAA-1C
RAA-1D
RAA-1E

Standard Technology
No action/public awareness/institutional
controls/long-term monitoring
Soil cap/revegetation/long-term monitoring
Consolidation of soils in CELAb/fixation/
RCRA cap/backfill/long-term monitoring
In situ fixation/long-term monitoring
Excavation/off-site landfill disposal/backfill
Estimated Costs
3 Criteria
$263,500
i
$390,000
$562,000
$6i25,600
$1,862,000
9 Criteria
$743,000a
$1, 583,200"
$1,505,000"
$2,394,600"
eliminated
"Large changes in estimated cost between the two screening processes were not explained.

'They reflect increases in both initial costs and O&M costs.

bCentral elevated landfill area. »
267
-3-
-------
Subsurface Soil
Alternative
RAA-2A
RAA-2B
— ==^=
Standard Technology
No action/public awareness/institutional
controls/long-term monitoring
Excavation/backfill/off-site disposal at
RCRA landfill
Estimated Costs
3 Criteria
$353,600
$17,192,200
=====::
9 Criteria
$882,100
$22,869,800
t
8. If a standard technology was chosen, why? ',

The selected alternative for surface soils, RAA-1C (on-site fixation) would be protective,
provide a permanent remedy, involve simple construction and implementation using proven
technologies, restores contaminated areas to ambient conditions, reduces mobility of
contaminants, satisfies the preference for treatment, and is cost effective. RAA-1A (no action)
would not be protective of human health and the environment and would not attain cleanup
goals. RAA-IB (capping) offered a less protective cap than the chosen alternative and would
not meet cleanup goals. RAA-1D (in situ fixation) would not be as effective in the long term,
would not return the area to natural conditions, and the technology was less readily available '
RAA-IE (off-site landfill) would not be cost-effective.

The selected alternative for subsurface soils, RAA-2A (no action) would be cost effective in
that it provides protection of human health and the environment because there are no known
exposure pathways, would not disturb subsurface soils, and would restrict future site access.
All other alternatives (off-site disposal, soil vapor extraction) were considered excessive in
both protection and cost. ,
9. If an innovative technology was chosen, why?

No innovative technologies were selected.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

Surface Soil _

• Soil washing was eliminated because no commercially available package units exist to
implement this complex and labor-intensive technology.
• Biodegradation (ex situ) was eliminated because the contaminants of concern, lead and
arsenic, are not amenable to this type of treatment.
288
-4-
-------
Subsurface Soil

• Soil washing was eliminated because the presence of volatile,! seraivolatile, and metal-
contaminants would make the development of a washing solution to remove all
contaminants difficult. In addition, due to the low partition coefficients of the
semivolatile and metal contaminants, remediation would require excessive washing and
would produce substantial amounts of waste materials requiring further treatment.
• Land/arming was eliminated because it would not address heavy metals. It would
require excavation, which would be very disruptive to the current site users. To
facilitate the treatment beds required for the amount of soil, the current site owners
would lose use of their property until the soils were treated to cleanup goals. •
Excavation, treatment, and disposal would have to be performed in accordance with
LDRs.
' ' • v
Innovative technologies eliminated during the, screening of the three criteria include the
following: , :
• " ' ' ! ' ' •
Surface Soil j

• i' None • • I' ' "' .,
i •
Subsurface Soil . j
,|._ ^ , ,
• In situ soil flushing (RAA-2D) was eliminated because it has j not been demonstrated to
be effective for complete removal of VOCs from soil. Treatability studies would be
required. Uniform and reliable distribution of the surfactant would be difficult due to
the nature of the site; extensive subsurface foundations and piping. It would provide
no substantive improvements in effectiveness or implementability than soil vapor
extraction.
• In situ bioremediation (RAA-2D) was eliminated because it has not been demonstrated
to be effective in remediating unsaturated soils. Treatability tests would be required.
Uniform and reliable distribution of oxygen and nutrients would be difficult due to
areas of low subsurface permeability and underground foundationi and piping. Pockets
of untreated soil may remain on site. f .
- ' : '
Innovative technologies eliminated during the detailed analysis include the following:

Surface Soil } ' .

« None . •'--".• j '

Subsurface Soil
... , . • i
! ' '
• In situ vapor extraction was eliminated because it-is ineffective for the cleanup of
metals and its implementability is questionable in regard to.achieving cleanup levels
due to areas of low permeability and low porosity in subsurface soils. No risks
presently exist from subsurface soils due to the lack of a known exposure pathway,
and subsurface soils do not appear to be acting as a significant source of groundwater
contamination. Institutional controls could provide sufficient; protection to human
health and the environment.

269
••-',. -5- f
-------
77
72.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Surface Soil - .

Of the alternatives that were protective of human health and the environment, long-term
effectiveness and cost were the most heavily weighted criteria in the choice of a remedy. One
innovative technology, in situ soil flushing, was eliminated because it was not cost-effective.

Subsurface Soil

Of the alternatives that were protective of human health and the environment, implementability
and cost were the most heavily weighted criteria. '-'•""

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that,
ARAR? What risk level was selected to establish cleanup goals? \

Surface Soil i
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Lead
• 25 .
1,000
Risk*
OSWER"
"EPA directed that an arsenic soil cleanup level, corresponding to a carcinogenic risk
of 1 x 10"5, be used at the site.
bEPA OSWER Directive (EPA, 1989) interim soil cleanup level for lead. :
Subsurface Soil
Contaminant
Carcinogens
Arsenic
Lead
Benzene
Xylene
Naphthalene
Cleanup Level (ug/kg)
ARAR or Other Basis

25
1,000
0.024
0.98
0.72
Risk
OSWER
Model8 and MCL
Model and MCL
Model and MCL
"For some contaminants, the Summers model was used to estimate the contaminant
concentrations in the soil, which will produce ground water contaminant concentrations
at an acceptable level based on Maximum Contaminant Levels (MCLs)
270
-------
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was selected, could it meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• Soil vapor extraction (subsurface soils)

The standard technologies selected could meet cleanup goals.
14. Were treatability studies conducted on the innovative technology or standard technology?
1 -. • i " . r • ' • '
No treatability studies were conducted. . |
'i •
-[.'•"
i , ,
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

- Risk level achieved
Cost effectiveness
Proven reliability . * •
• ' . , ' -i
\ _
" ' ' '
i
16. How are alternatives compared? '

The selected remedy for surface soils would achieve a 10"5 risk level; achievement of a 10"6
risk level would require cleanup levels below background concentrations of arsenic. On-site
disposal of excavated surface soils is more cost effective than off-site disposal and offers an
equivalent degree of protectiveness. No action for subsurface soil is cost effective in that it
offers the same level of protectiveness as soil vapor extraction and excavation but at
considerably less cost. The short-term effectiveness and implementability of the surface soil
excavation alternative is high in that it involves use of proven technologies.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the, remedy? !
".. r ' •
Technical considerations were not primary to the selection of the remedial alternative.
271
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South Jersey Clothing Company
(same FS and ROD as Garden State Cleaners)

Minotola, New Jersey
Region 2
GENERAL SITE INFORMATION
1.
What were the principal contaminants,
contaminant levels, and media being
addressed in this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

Tetrachloroethylene (PCE)
Trichloroethylene (TCE)
0.82
3.9
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

* 1,400 cubic yards of soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1988
10/89
8/12/91
9/26/91
Background

EPA Fund-lead
PRPs: Garden State Cleaners, South
Jersey Clothing Company
FS prepared by: Ebasco Services
Incorporated
3. What type of site is this? • .- ' '

Dry Cleaning. A former clothing manufacturer and dry cleaning facility.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: .

Access restriction: Fencing, deed and zoning restrictions :
Containment: Soil cap, multimedia cap, asphalt cap, concrete cap ;
Chemical treatment: Ex situ or in situ fixation ; .
Thermal treatment: Incineration ''.-.-
Disposal: Excavation, disposal at a RCRA facility, backfill treated soil
272
\
-------
5. Was an innovative technology considered in the FS? If so, which technology

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
Biological treatment: In situ bioremediation
Chemical treatment: Soil washing, soil flushing, in situ soil vapor
Thermal treatment: Pyrolysis, low temperature thermal desorption,
vitrification
extraction
wet oxidation,
What was the cost estimate for the innovative technology?
~ • '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Aifter the RAAs were
formulated, costs were estimated during evaluation by the nine criteria established by the NCP.
The estimated costs were recalculated in the ROD.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative ,
RAA-SC-2
RAA-SC-3
RAA-SC-4
Innovative Technology
In situ soil vapor extraction
Excavation, low temperature thermal
desorption, backfill treated soil
Soil flushing
Estimated Costs
9 Criteria
$191,000
$220,000
$73,000
ROD
$649,000
$1,198,000
$167,000
How did the cost(s) compare to standard technologies? i

Cost Estimates for RAAs That Include Standard Technologies
' (selected remedial alternative is in bold) i
Alternative
RAA-SC-1
RAA-SC-5
Standard Technology
No action
Excavation, off-site disposal, backfill with
borrowed material
Estimated Costs
9 Criteria
i$o
. $850,000
i
ROD
$1,700,000
$5,890,000
- •!
If a standard technology was chosen, why?

A standard technology was not selected.
273
-2-
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P. If an innovative technology was chosen, why?

All RAAs, except RAA-SC-1 (No Action), would protect human health and the environment
and attain ARARS. The selected alternative, RAA-SC-2 (SVE for soils), was selected because
it permanently reduces the level of contaminants in sojl through treatment, is readily
implementable, and creates no short-term risks. RAA-SC-3 (thermal desorption) was
comparable to the selected alternative for most criteria, but would be more costly, create short-
term risks by excavation, require significant soil preparation, and require numerous approvals
to construct and operate the mobile thermal unit. RAA-SC-4 (soil flushing) was eliminated
because it would temporarily increase mobility of contaminants, increasing short-term risk, and
was less implementable because of potential monitoring problems. Alternative RAA-SC-5
(off-site landfill) offered maximum protection of human health but had the greatest short-term
risk to the community, short-term environmental impact, and cost.

10. V °n innovative technology was not chos'en, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include:

« In situ bioremediation was eliminated because the technology is difficult to control 4fc -
Nutrients and oxygen must be distributed to an area where contaminants are not ^^ . )
uniformly distributed. There was also concern that residual contaminant levels would
not be low enough to meet ARARs, Further, when TCE and PCE biodegrade> -vinyl
chloride (another toxicant) is produced. •
« Soil washing was eliminated because it would be difficult to implement and because it
generates relatively large quantities of waste that must be treated or disposed of. ••
" Pyrolysis was eliminated because it has not been used in commercial applications,
considerable waste stream pre-processing is required, and it is best applied to highly
toxic organics. . , • . •
• Vitrification was eliminated because it is usually used for less mobile inorganic or
mixed wastes.
• Wet oxidation was eliminated because it is not applicable to non-pumpable soil. v

No innovative technologies were eliminated during the three-criteria screening process.

Innovative technologies eliminated during the detailed analysis include:

« Low temperature thermal desorption was eliminated because it was not cost effective
It was considerably more expensive than the selected technology without providing
additional protection to human health and the environment. In addition, it would
create short-term risks by excavation, require significant soil preparation, and require
numerous approvals to construct and operate the mobile thermal unit :
• Soil flushing was eliminated because it would increase contaminant mobility, causing
VOCs to be released into the aquifer and necessitating additional remedial action In Jfe \
addition, it was considered less implementable because of potential monitoring ^P /!
problems. ' • t

274
-3-
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11. Which of the nine criteria were weighted most highly in selecting the technology? Did one of
the nine criteria eliminate the innovative technology from being chosen? If so, which one?
Which of the criteria supported the use of a standard technology? }

72. What cleanup goals were selected? If the cleanup goal was based on
-------
16. How are alternatives compared?
:
While all of the action alternatives would ultimately protect human health and the
environment, soil flushing would temporarily increase the level of risk because contaminants
from the soil would be flushed into groundwater. Off-site disposal and low temperature
thermal desorption would impact nearby populations because excavation and transport of
contaminated soils could potentially result in the generation of dust and vapors The selected
remedy, soil vapor extraction, would be less costly than off-site disposal and thermal
desorption. Although soil vapor extraction would be more costly than soil flushing, it was
preferred because it would not mobilize contaminants and cause them to enter the
groundwater.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Soils at the site are mostly sandy, depth to the water table is about 25 feet, and the surface
topography is flat with little or no surface runoff. The granular nature of the soil relatively
low moisture content in the vadose zone, and organic nature of the contaminants were
particularly amenable to the application of soil vapor extraction. Also, the facility is located in
a mixed residential and commercial area; therefore, the impact on nearby populations was a
significant consideration. Technical considerations could be considered primary in the
selection of remedy at this site.
~\

»'
27o
-5-
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Swope Oil and Chemical Company
OU-2

Pennsauken Township, New Jersey
Region 2
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
i
Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

Acetone 230
2-Butanone 41
Ethylbenzene 320
4-Methyl-2-pentanone 150
Tetrachloroethene 360
Toluene 490
Trichloroethene 620
Xylene 1,900
Bis(2-ethylhexyl)phthalate 15
Isophorone 1
Naphthalene 85
Phenol . 52
Total VOCs 3,991
Total Semivolatiles 275
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
N/A
5/91
9/27/91
Background

PRP-lead ;|
PRPs: 'Not listed | ,
FS prepared by: Geraghty and Miller,
Inc: , • '! ' ' ' '.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 153,000 cubic yards of soil

3. What type of site is this?

Recycling. A former chemical reclamation facility.
277
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6.
were

Access restriction:
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

J^°!°giCS considered during to identification and screening of technically feasible

Fencing, deed restrictions

Ph-m- i* ^ ^P^8011'concrete, asphalt, multilayer, synthetic membrane)
Chemical treatment: Stabilization/solidification
Thermal treatment: Incineration
Disposal: Excavation, on-site disposal, off-site disposal

Was an innovative technology considered in the FS? ,Ifso, which technology?

, Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ or ex situ biodegradation ,
Phys/Chem treatment: In situ soil flushing (solvents, surfactants), ex situ soil washing
(solvents, surfactants), dechlorination, oxidation/reduction, soil vapor
extraction .
Thermal treatment: Enhanced volatilization, ex situ thermal desorption, in situ vitrification
ex situ vitrification, pyrolysis
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(pnor to the formulation of RAAs), the FS does not quantify costs. After fhe RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening procTsto Wentify

±ualVneSh H^3 ^ detaUed CVaIUati0n- F°r this Site' costs wereeLiated during 2
evasion based on the nine criteria established by the NCR Costs were reevaluated in th!
ROD since the selected RAA was a modification of the RAA proposed in the FS.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2
RAA-2-
modified
Innovative Technology

In situ soil vapor extraction/in situ
bioremediation/multilayer cap
^B^_.^__
In situ soil vapor extraction/potential
incidental in situ bioremediation
Estimated Costs
9 Criteria
^i^_

$2,520,000,
N/A
ROD
~™^"™™™™™

$2,09p,000

"•

$2,099,000
278
.1
-2-
-------
How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology
No action/ground water monitoring

Estimated Costs
9 Criteria
N/A
.

ROD
$1,014,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?

Only two options were proposed for this site: no action or an innovative technology. The
chosen alternative utilizes soil vapor extraction to remove volatile and semivolatile organic
compounds (VOCs and semivolatiles). The remedial action selected includes; in-situ vacuum
extraction (with potential enhancement by biodegradation), treatment of air emissions using
carbon adsorption or thermal destruction, if necessary, and groundwater monitoring. The
remedy was selected because: 1) a pilot test conducted at the site indicated that SVE over a 1
year period would effectively reduce VOC parameter concentrations, 2) further studies of site
soils indicated that microorganisms exist at the site that will biodegrade semivolatiles, 3) SVE
is a proven technology for removal of VOCs from soils, 4) operates without emissions or
noise, 4) will operate with out impacting site surroundings and the local community, 5)
reduces soil contaminants that are impacting shallow groundwater. !

The FS also recommended a cap after treatment, but it was not part of the final remedy (the
ROD did not include a cap). A decision on,capping the site was postponed until'after
implementation of SVE. If a cap is not required, it will allow a greater degree of unrestricted
usage of the site. '
10. If an innovative technology was not chosen, why not? At what stage was the \innovative
technology eliminated? I

Innovative technologies could be .eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. |
, \ • i '
Innovative technologies eliminated during the initial screening include the following:
- . - r ' .
• 1 •' - :
• 'In situ vitrification was eliminated because 1) the environmental impact of the off-gas
generated, 2) the high cost, and 3) the depth of contamination which extends to 80
feet.
279
-3-
-------
• In situ soil flushing/washing was eliminated after 1) a treatability study was conducted,
that indicated arsenic and mercury at the site could not be removed with this method,
and 2) it would increase the contaminant concentrations in the groundwater.
• Enhanced volatilization by steam stripping was eliminated because 1) the costs are
high, 2) the condensate provides a pathway where soil contaminants can migrate to
underlying shallow groundwater, and 3) demonstrated steam stripping treatment
systems generally effect soils to a depth of 30 feet or less.
• Thermal desorption was eliminated because it requires excavation of soils and it is not
possible to excavate to 80 feet.
• Ex situ soil washing was eliminated because: 1) excavation is required, 2) it is limited
to soluble organic compounds, it has a limited number of full-scale effective
demonstrations, 3) the cost is high, 4) there are too many site constituents to formulate
a washing agent without strict operational controls.
• Dechlorination (KPEG) was eliminated because 1) depth of contamination precludes
excavation, 2) volume of waste is increased which must be further treated as
wastewater, 3) the cost is very high, and 4) it is only applicable to chlorinated
organics.
• Ex situ bioremediation was eliminated because depth of contamination precludes
excavation.
• Ex situ vitrification was eliminated because 1) depth of contamination precludes
excavation, 2) it is not cost effective, 3) high energy requirements, and 4) the resulting
gas emissions must be captured and treated.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None ,

Innovative technologies eliminated during the detailed analysis include the following:

" None

Only two alternatives were proposed: no action and in situ soil vapor extraction. The chosen
alternative incorporates an innovative technology. Implementability and short term
effectiveness were key in selecting the remedial alternative.
12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

VOCs and semivolatiles in subsurface soil had migrated into the underlying shallow aquifer,
threatening the ground water quality of the potable deep aquifer. Remedial action was
necessary to remove contaminants from the subsurface soil. New Jersey Department of
Environmental Protection (NJDEP) Interim Soil Action Levels were used as soil cleanup goals
to protect ground water. !
280
-4-
-------
Contaminant
Carcinogens
Total VOCs
Total semivolatiles
Cleanup Level (mg/kg)

1
10
ARAR or Other Basis
'
i
NJEiEP
NJE»EP
Could the standard
13. Was the innovative technology eliminated because of the cleanup goals?
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?
Treatability studies tested several soil treatment options, including solidification/fixation, soil
flushing, vapor extraction, and biorernediation. These studies determined that ,
solidification/fixation and soil flushing would not be effective for site remediation as
solidification/stabilization is not a proven method to fix organics and soil flushing would
mobilize site constituents to the ground water. Furthermore, these studies showed that soil
vapor extraction was applicable as it would recover VOCs in subsurface soil. Biodegradation
was applicable to reduce site semi-volatile organics in subsurface soils.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Preference for treatment (vs. containment)

16. How are measures compared? j ..'.'.-
: ' • ' 'I
r
, The chosen alternative reflects a preference for treatment over containment. The chosen
alternative utilizes two innovative treatment technologies to remediate site'soil. This
alternative is a modification of the alternative originally proposed in the FS and does not
include a cap. The cap was eliminated because EPA determined that treatment of soil would.
be adequate to protect the ground water from continued contamination. I
281
-5-
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17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? i • .

The remedial goal was to prevent subsurface soil contaminants from leaching into the lower
aquifer, which is a drinking water source. Two technical criteria were primary in the choice of
a remedial alternative. First, contaminants were located in subsurface soils. This made ex situ
technologies that required excavation difficult to implement, and thermal technologies (in situ
vitrification and enhanced volatilization) much too expensive to implement. Second, the lack
of a containment layer between the soil and aquifer made technologies that would mobilize
contaminants (soil flushing) inappropriate for site remediation. The chosen technologies could
be applied in situ and were effective at subsurface levels.
•J,
282
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Warwick Landfill
OU-1

Warwick, New York
Region 2
GENERAL SITE INFORMATION
1. ' What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of
contaminants were:

Unsaturated
Soil
(mg/kg)

Benzene "0.002
Chorobenzene —
Ethylbenzene 0.079
Xylenes 0.025
Arsenic 0.0046
Barium .0.111
Chromium 0.018
Lead 0.176
principal

Saturated
Soil
(mg/kg)
,,
0.004
0.028
0.22
0.049
0.0046

Site
NPL Proposed:
NPL Final-
PS:
ROD:
/
Back

EPA Fund-lead
PRPs: N/A
FS prepared by: Et
Inc.

0.0665
0.0246
0.136
2. What volume of material is to be remediated?
The volume of material to be
remediated included:
.

History
1985
3/89
2/11/91
6/27/91

ground

'asco Services

:'...*

800,000 to 1,000,000 cubic yards of solid waste. The landfill
including the side slopes, is estimated to be 22 acres.
imound surface area,
3. What type of site is this?

Municipal .Landfill. An inactive municipal and industrial waste dispos.il site located in a
semirural, residential area. i
TECHNOLOGY SELECTION - !

,1 - i
4. Wliat standard technologies were considered for selection in this FS? j
' , I i

Standard technologies considered during the identification and screening of technically feasible
technologies were* j

283
-------
Access restriction:
Containment:
Fencing
Slurry wall, sheet piling, grout curtains, synthetic liner, capping (clay,
synthetic membrane, RCRA cap)

5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

No innovative technologies were identified in the initial screening.
6.
t was the cost estimate for the innovative technology?

No innovative technologies were incorporated into RAAs.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action
Access restrictions/ground water
monitoring/point-of-use ground water
treatment i
Capping/point-of-use ground water
treatment ,
Capping/ground water pump and
treatment/chemical precipitation/point-
of-use ground water treatment
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$887,800
$1,523,800
$14,279,600
$19,013,100
284
-2-
-------
• " • ' •• •' i ' -
Alternative
RAA-5
t
Standard Technology
Capping/subsurface barrier/ground water
pump and treatment/chemical precipita-
tion/carbon adsorption/point-of-use
ground water trieatment
Estimated Costs
3 Criteria
*'N/A|
'1
I
9 Criteria
$30,241,300
8. If a standard technology was chosen, why?.

RAA-3 was chosen because capping the landfill protects human health and the environment
since it reduces the mobility of contaminated materials off site. The cap eliminates the
infiltration of rainwater and snowmelt into the landfill, thus reducing the quantity of water
percolating through the landfill and leaching out contaminants. This also significantly reduces
leachate seeps that contaminate nearby surface water and the leaching of contaminants into the
wetlands and aquifers. The carcinogenic and noncarcinogenic risks associated with ground
water ingestion and inhalation will be eliminated for current ground watet users with the
provision of point-of-use treatment systems on residential wells. This alternative meets all
ARARs and provides long-term effectiveness and permanence because the closure cap
proposed is a permanent technology that will be maintained at regular intervals to ensure its
structural integrity and impermeability. Short-term risks posed by construction activities will.
be mitigated through the use of both proper construction techniques and operations procedures
and of protective equipment and health and safety training. This alternative will be easily
implemented since the procedures, materials, and earthworking equipment, are conventional and
are used extensively in standard commercial and industrial applications. Furthermore, the
technologies1 are readily available and the alternative is cost effective. j
9. If an innovative technology was chosen, why?

An innovative technology was not selected. .
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? • i

Innovative technologies eliminated during the screening of the three criteria include:
. i" ••
• None ' •'••!'
285
-3-
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Innovative technologies eliminated during the detailed analysis include- -«^-
. , - • * . .' • flB ""'
" None ^^ ,.

The criteria weighted most heavily in selecting a remedial alternative were implemeritability,
short-term risk, and cost. The selected alternative was preferred over other alternatives (RAA-
4 and RAA-5) that would be difficult to implement administratively since they would require
an extensive monitoring program and operation and maintenance of the ground water treatment
facility. These alternatives also were more costly. RAA-5 was also not chosen because the
excavation necessary for a subsurface barrier might require specialized operations and
equipment from nonlocal sources. In addition, RAA-5 posed short-term risk to ecosystems
and nearby wetlands during excavation. ,

12. What cleanup goals were selected. If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
I
There are no ARAR-based cleanup levels for soils in New York State. Results from health-
based risk assessment and leaching studies of contaminants exceeding background levels were
used in considering cleanup goals. When estimating human risk, an excess upper bound ^^
individual lifetime cancer risk of between 10"4 to 10'6 was acceptable and for rioncarcinogens a |H|
Hazard Index (HI) less than 1.0 was acceptable. These studies determined that direct exposure
to or ingestion of soil/sediment did not pose an unacceptable health risk. Furthermore, it was '
determined that leaching of soil/sediment would not cause ground water contamination in
excess of ARAR-based cleanup levels. Therefore, no soil/sediment cleanup levels were
established.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None , :,..-'

Standard technologies eliminated because of cleanup goals include:

" None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
286
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75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness .
Impact on nearby populations

16. How are measures compared?

RAA-3 was preferred over RAA-4 and RAA-5 because it provides overall protection
proportional to its cost and is therefore cost effective. Further, RAA-5 was not selected
because the extensive excavation and the implementation of a slurry wall would adversely
affect nearby wetlands and ecosystems.
17.
, . , • . i
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? . •;•...,

The nearby wetlands and fractured bedropk were primary technical considerations in selecting
a remedial alternative. The subsurface barrier proposed in RAA-5 could result in adverse
environmental impacts to-adjacent wetlands. Further, necessary excavation in the vicinity of
the wetlands would cause sedimentatiqn and disruption of the .ecosystem. The heavily
fractured nature of the bedrock could limit the effectiveness of the slurry wall proposed in
RAA-5. i
-5-
287
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Aberdeen Proving Ground (Michaelsville Landfill)
OU-1

U.S. Army Aberdeen Proving Ground, Maryland
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Acetone 41
4,4'-DDD (PPDDD) 0.007
4,4'-DDE (PPDDE) Q.003
4,4'-DDT (PPDDT) 0.004
Endosulfan sulfate (ESFS04) 0.006
Endrin aldehyde (ENDRNA) 0.013
Heptachlor (HPCL) 0.011
Heptachlor epoxide (HPCLE) 0.002
Methylene chloride (CH2CL2) 0.81
Chromium (CR) 19.7
Copper (CU) 12.5
Zinc '(ZN) 44.4
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
4/85
10/4/89
7/12/91
6/30/92
Background .
i
Federal Facility ;
PRPs: U.S. Army \
FS prepared by: Dames and Moore
What volume of material is to be remediated?

The volume of material to be remediated included:

• No volume was given; however, the site covers an area of 20 acres. : ,

What type of site is this? •

Military. The site is an unused municipal solid waste landfill in an Army complex. ,In the
immediate vicinity of the landfill is an industrial sector, a large firing range, an ammunition
receiving and shipping building, a pistol range, and a scrap metal yard. Barracks and on-post
family housing, the City of Aberdeen, and the City of Perryman lie within 4 miles of the site.
288
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ICHNOLOGY SELECTION
What standard technologies were considered for selection in this FS?
Note: The FS "presents a focused feasibility study (FFS), which evaluates cap and cover
system remedial alternatives for the Michaelsville Landfill (MLF)." Some excavation/
incineration technologies are introduced in the ROD. ;
. ' i ••'-.'•
Standard technologies considered during the identification and screening of technically feasible
technologies were:

Containment: Capping
Thermal treatment: Rotary kiln incineration
Disposal: ,Off-site disposal, ori-site disposal (ash1)
5. Was an innovative technology considered in the FS? If so, which technology?
• . '. i .'•''.
Innovative technologies considered during the identification and screening of technically
feasible technologies were:
None
What was the cost estimate for the innovative technology?

No innovative technologies were selected.
7. How did the cost(s) compare to standard technologies?
. I
Cost Estimates for RAAs That Include Standard Technologies
' (selected remedial alternative is in bold) i
r-
Alternative
Standard Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-1
No action
N/A
$0
RAA-2
Redressing existing cap with clay cap/
grading/topsoil and grass/gas venting ,
system ,
-2-
N/A
$7,442,400
289
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Alternative
RAA-3
RAA-4
RAA-5'
RAA-1A8
RAA-2A3
RAA-3A"
Standard Technology
New, multilayer clay cap to Maryland
Department of the Environment
(MDE) requirements/gas venting
system
New, multilayered cap in accordance
with RCRA requirements/gas venting
system
New, multilayer synthetic membrane
cap in accordance with MDE
requirements/gas venting system
Excavation/disposal at off-post
hazardous waste landfill/refilling with
clean fill
Excavation/mobile rotary-kiln
incineration/refill with nonhazardous
ash
Excavation/temporary storage/lining
the cavity/multilayer cap in
accordance with MDE requirements/
gas venting system
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$9,616,600
$10,001,000
$9^07,000
$135,520,000
$182,795,000
/
$21,825,000
3
Note: RAA-5 was listed in the FS as a siibalternative of RAA-3.
"Introduced in the ROD.
5. If a standard technology was chosen, why?

The selected remedy is expected to be very effective in limiting risks associated with 'the site
under current and future land use conditions. Risk reduction will be achieved by covering the
buried waste material with a capping system to reduce the potential for exposure to arid/or
transport of contaminants that could be associated with surface water runoff or surface water
infiltration and subsequent leachate generation or ground water contamination. The capping
alternatives provide a much greater level of short-term effectiveness than the excavation
alternatives because the waste would remain in place and would not pose an increased threat to
human health or the environment during excavation activities. Capping was preferred because
of the size of the landfill, excessive costs associated with the excavation alternatives, and the
difficulties of implementing the excavation alternatives. The selected remedy is consistent
with the Superfund program policy of containment, rather than treatment, for wastes that do
not represent a principal threat at the site and are not highly toxic or mobile in the
environment. Of the capping alternatives, RAA-5 is the most cost-effective. The remedy has
community, EPA, and MDE acceptance.
290
)i
-3-
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9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
12.
13.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? i :
- " • • ' ' " , • ' ; ' ' f ' •
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
' , " , - i "
Innovative technologies eliminated during the initial screening include! the following:

• None .'•.-' '!

Innovative technologies eliminated during the screening of the three criteria include the
following: I
. • • . ' • .. • .
• None • . '
- • • •'-•-. i , '
Innovative technologies eliminated during the detailed analysis include the following:

• None
Which of the nine criteria were weighted most heavily in selecting-the,technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology? '

Short-term effectiveness, implementability, and cost were the criteria weighted most heavily in
selecting a technology. The selected remedy provides a much greater level of short-term
effectiveness than the excavation alternatives, because the waste would remain in place and
would not pose an increased threat to human health or the environment during excavation
activities; implementing a synthetic cap is straightforward; and the multilayer cap is the most
cost-effective of the new caps, and is much cheaper than any of the excavation alternatives
, was based on an ARAR>
risk level was selected to establish cleanup goals? {
N6 soil cleanup levels were given.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
Innovative technologies eliminated because of cleanup goals include:

• None ,
-4-
291
-------
Standard technologies eliminated because of cleanup goals include:

» None
3
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost/unit risk ,
Preference for treatment (vs. containment) '
Waste left in place/institutional control , ' • -
16. How are measures compared?

. RAA-5 was the most cost-effective of the capping alternatives. Treatment technologies were
not considered because "no treatment technologies are currently available that would eliminate
the risks associated with a municipal landfill in a cost-effective manner." The selected remedy
is consistent with the Superfund program policy of containment, rather than treatment, for
wastes that do not represent a principal threat at the site and are not highly toxic or mobile in
the environment. Capping technologies were compared to excavation in regard to short-term
risk of excavating material. , , ,
17. What technical considerations were factors in selecting a remedy? Were technical ,-
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. The size of the landfill was
listed as one of the factors precluding remedies involving excavation and any form of
treatment. , :
292
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Abex Corporation
OU-1

Portsmouth,. Virginia
, Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface and Subsurface Soil (rag/kg)
Lead
Antimony
Nickel
Tin
Copper
Zinc
Cadmium
Silver
Total PAHs
Total PCBs
58,000
10
23,
224
1,200
1,175
21
26
32
12
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
,.N/A
N/A
2/92
9/29/92
Background
.j • --
PRP-lead !
PRPs: Abex Corporation
FS prepared by: GjEO Engineering,
Incorporated
2. What volume of material is to be remediated?

The volume of material to be remediated included:
" . j
» 59,883 tons, or approximately 49,000 cubic yards of soil near i the foundry

3. What type of site is this?

Fabricated Metal. A former brass and bronze foundry and associated'jdisposal area. The site
is located in a residential and commercial/light industrial area. j

TECHNOLOGY SELECTION ' -'."..

4. v What standard technologies were considered for selection in this FS?

Standard technologies considered during the Identification and screening of technically feasible
technologies were:
Access restriction: Fencing, deed restrictions

-1-
293
-------
Containment:
Chemical treatment:
Disposal:
Thermal trt. ment:
Capping, containment barrier
Stabilization/solidification
Excavation, off-site disposal
Smelter flux substitute (recycling)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Phys/Chem treatment: Soil washing .
Thermal treatment: Vitrification
6. What was the cost estimate for the innovative technology?

No innovative technologies were developed into RAAs. '
>
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
, Alternative
RAA-1
RAA-2
Standard Technology
No action
Building decontamination/excavate
surface soil exceeding 500 mg/kg lead/
off-site disposal at RCRA landfill/deed
restrictions/maintain existing caps
Estimated Costs
9 Criteria
$0
$6,689,000 to
$39,695,000
ROD
$0
$4,888,930
294
-2-
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7

Standard Technology
Building decontamination/destroy
existing site caps/excavate residential
surface and subsurface soil exceeding
500 ppm/excavate surface soil
exceeding 500 ppm and subsurface soil
exceeding 1,000 ppm/off-site disposal
Building decontamination/destroy
existing site caps/excavate residential
surface and subsurface soil exceeding
500 ppm/excavate surface soil
exceeding 500 ppm and subsurface
soil exceeding 1,000 ppm/on-site
stabilization/off-site disposal ,
Building decontamination/excavate
residential surface and subsurface soil
exceeding 500 ppm/excavate surface
soil exceeding 500 ppm and subsurface
soil exceeding 1,000 ppm/on-site
stabilization/off-site disposal/asphalt cap
over existing site caps/institutional
controls " '
Building decontamination/excavate
residential surface and subsurface soil
exceeding 500 ppm/excavate surface
soil exceeding 500 ppm and subsurface
soil exceeding 1,000 ppm/on-site
stabilization/off-site disposal/remove
existing site caps/in situ stabilization/
asphalt cap/institutional controls
Building decontamination/excavate
surface soil exceeding 500 ppm/ .
excavate subsurface soil exceeding 500
ppm to a depth of two feet/stabilization
of excavated soil/off-site disposal/
institutional restrictions
Estimated Costs
9 Criteria
$4,384,000 to
$31,757,000
(•
$6,205,000 to
$29,873,000
$4,078,000 to
$19,407,000
$6,334,000 to
$31,454,000
. 1..
$4,2017,000 to
$25,478,000
ROD
$37,895,000
$28,891,000
$22,097,930
, $23,677,930
$16,169,450
8. If a standard technology was chosen, why?

RAA-4 was chosen because i£ provides the greatest protection to human health and the
environment since it remediates all lead-contaminated surface and subsurface soils to. health
based cleanup levels in residential areas. The removal of lead-contaminated subsurface soil in
residential areas was preferred because if contaminated soil was left in place, future activities
such .as gardening or construction would be detrimental to human health. These activities
could be avoided by implementing use restrictions, but the EPA does; not support these
295
-3- . ' • i
-------
restrictions unless no other feasible alternative exists: The chosen alternative will be:protective
in the long-term since the lead-contaminated soil will be stabilized and disposed of off site.
Furthermore, lead will be immobilized by the stabilization process. RAA-4 represents the
most cost-effective option.

At the time of the Proposed Plan, RAA-7 was preferred. A more in-depth analysis, however,
revealed the effects of allowing lead-contaminated soil to remain below two feet. That is, if'
lead-contaminated soil were left below two feet, use restrictions would be necessary for
residential areas with soil lead levels of 500 to 5,000 mg/kg and in nonresidential areas with
soil lead levels of 1,000 to 5,000 mg/kg. These restrictions would significantly impact the
activities of current and future residential populations. During the public comment period, the
public expressed a strong desire to have a remedy that guarantees the protection of human'
health and the environment and would not restrict their future activities. If this could not be
provided, they would prefer to be permanently relocated. The EPA decided to select RAA-4
instead of RAA-7 since all subsurface soil would be remediated to cleanup levels.

9. If an innovative technology was chosen, why?

An innovative technology was not chosen.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '•' -
^~ ' x^l^^P ""^V'
Innovative technologies could be eliminated from the remedial technology selection process at "?? J
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. -

Innovative technologies eliminated during the initial screening include the following:

• Vitrification (ex situ) was eliminated because lead would be present in the offgases
generated during the process.
" Soil washing was eliminated because of its high cost and the lack of bearing capacity
of the clean sand.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• None \(
296
i
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11.
12.
13.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

,The criteria weighted most heavily in selecting a standard technology were protection of
human health and the environment and cost effectiveness. No innovative technologies were,
carried to detailed analysis.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (rag/kg) ARAB! or Other Basis
Carcinogens
Lead (residential)
Lead (noriresidential)
500
1,000
OSWER"
lOSWER"
Directive No. 9355.4-02.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None , '

Standard technologies eliminated because of cleanup goals include:

• Gapping
14. Were tredtability studies conducted on the innovative technology or sandard'technology?

No treatability studies were conducted. .
75. What measures/criteria were used to compare alternatives?
• --- * ' ' . *- ' j
The following measures were used to compare the alternatives:

Cost-effectiveness
- Waste left in place/institutional control
- Impact on nearby populations
-5-
297
-------
16. How are measures compared?

Only RAAs that would permanently reduce and remove site contaminants were considered
sufficiently protective. The complete removal of lead-contaminated soil from the site was a
concern because it was found in several residential areas. RAA-1, RAA-2, and RAA-7 were
eliminated because they were not protective since lead would be left in place. These
alternatives depended on use restrictions or institutional controls and were not considered
adequately protective since future residential activities such as gardening could be hazardous to
human health. In addition, the negative impact imposed by use restrictions on future activities
of local residents was not preferred by either EPA or local residents. RAAs that proposed
containment of contaminants were not considered adequately protective either. RAA-5 and
RAA-6 were eliminated because they would leave contaminants contained on site and would
require long-term maintenance. Two alternatives, RAA-3 and RAA-4, offered comparable
protection. The chosen remedy, RAA-4, is the more cost-effective of the two alternatives.
17.
What technical considerations-were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Current land use at the site is a mixture of residential and commercial/light industrial. \ The site
is expected to remain residential and there is speculation about developing the site in the
future. Future site use was a primary consideration in selecting an alternative that permanently
removed contaminants. Only alternatives that remediated lead-contaminated surface and
subsurface soil to cleanup levels were considered appropriate for the site. \
298
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Arrowhead Associates/Scovill Corp.
(Arrowhead Plating)

Montross, Virginia
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:.

No specific contaminant concentrations were
reported. The contaminants of concern were
VOCs, semi-VOCs and cyanide in surface
soil and VOCs in subsurface soil.
2.
3.
What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
2/90
9/12/91
9/30/91
Background

PRP-lead |
PRPs: Scovill Incorporated
FS prepared by: IGF Kaiser Engineers
The volume of material to be remediated included:

» 750 to 1,000 cubic yards of soil ' •;

What type of site is this?

Electroplating. A manufacturing facility that formerly produced cosmetic cases using
electroplating, lacquering, and enameling processes. It is located in a mral area.
TECHNOLOGY SELECTION . .'
* ' "
4. What standard technologies were considered for selection in this FS?
'. • ' - •
Standard technologies considered during the identification and screening of technically feasible
technologies were: ,
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Deed restrictions
Capping, slurry wall
Stabilization/solidification
Incineration
Excavation, RCRA-permitted landfill (on-site, ioff-site)
-1-
299
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Phys/Chem treatment: In situ soil flushing, in situ spjl vapor extraction, in situ passive
venting
Thermal treatment: Low-temperature thermal aeration, in situ vitrification
6. What was the cost estimate for the innovative technology?
I '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation ' The
estimated costs then are recalculated during an evaluation based on nine criteria established by
the NCP: long-term effectiveness and permanence; short-term effectiveness; compliance with
ARARs; protectiveness of human health and the environment; reduction in contaminant
mobility, toxicity, or volume; implementability; cost; state/support agency acceptance; and
community acceptance.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2A
RAA-3A
RAA-4A
Innovative Technology
In situ vapor extraction/ground water
extraction and treatment by
precipitation, air stripping, and
adsorption
In situ vapor extraction/ground water,
extraction and treatment by
precipitation, UV oxidation, and
adsorption
In situ vapor extraction/ground water
extraction and treatment by
precipitation, steam stripping, and
adsorption
Estimated Costs
3 Criteria
$8,600,000 to
$13,200,000
$8,500,000 to
$12,900,000
$10,100,000
to
$15,000,000
9 Criteria
$13,177,000
$12,919,000
$15,015,000
300
-2-
-------
7. How did the cost(s) compare to standard technologies?
' ' ! '
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) '
Alternative
RAA-1
RAA-2B
RAA-3B
RAA-4B

Standard Technology
No action
Excavation/off-site incineration/off-site
disposal/institutional controls/ground
water extraction and treatment by
precipitation, air stripping, and carbon
adsorption
Excavation/off-site incineration/off-site
disposal/institutional controls/ground
water extraction and treatment by
precipitation, UV oxidation, and
adsorption
Excavation/off-site incineration/off-site
disposal/institutional controls/ground
water extraction and treatment by
precipitation, steam stripping, and
adsorption
Estimated Costs
3 Criteria
$1,250,000 ,
$8,600,000 to
$13,200,000
* I
i
i ' . '
['
$8,500,000 to
$12,900,000
r
i
$10,100,000
to •
$15,000,000
9 Criteria
$1,250,000
$17,573,000
$17,328,000
$19,415,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
If an innovative technology was chosen, why? |
I ' /
The chosen alternative was preferred because it reduces the migration of contaminants from
soils to ground water and reduces risks from irigestion and dermal coititact of soil by future
residents. Treatment of the site's contaminated soil is expected to eliminate secondary sources
of contamination that contribute to ground water contamination. This alternative is expected to
remove contaminants permanently from the soil, thereby reducing contaminant toxicity,
mobility, and volume. With soil vapor extraction, soil contaminants will be collected and
treated. Used carbon will be sent off site for destruction or regeneration. Minimal short-term
risk will be posed by this alternative since excavation is not required and gas emissions will be
closely monitored. Furthermore, gas emissions will be treated by carbon absorption to
eliminate potential impacts on workers and the nearby community. This alternative would be
the easiest to implement because air stripping technology is simple. Finally, the chosen
alternative is cost-effective since it provides as much protection as severed other proposed
alternatives, but costs less. j •
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301
-------
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '

Innovative technologies could be eliminated from the remedial technolc^ selection process at
three stages: during the initial screening; during the screening of the three criteria of "
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ passive venting was eliminated, but no explanation was provided.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Low-temperature thermal aeration was eliminated because incineration is more
effective and less costly to implement. .
• Soil flushing was eliminated because its effectiveness has not been proved, and its
implementation would be difficult because of the complexities of maintaining an
optimum washing fluid.
• In situ vitrification was eliminated because its implementation would be difficult. The
technology is technically complex, site soils are heterogeneous, and additional site tests
would be required. Moreover, its effectiveness is uncertain and it is very costly.

Innovative technologies eliminated during the detailed analysis include the following:

• None ' ' - , ' : •
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

In the ROD, the chosen alternative was preferred because its ground water remediation
components provide the greatest long-term effectiveness and permanence, and is the easiest to
implement. When considering source remedies, short-Term risk and cost were weighted most
heavily. Only two source remediation technologies, in situ vapor extraction and incineration,
were proposed. Of these, in situ vapor extraction would be less costly and would pose ino
short-term risk, since excavation would not be required.

Low-temperature thermal aeration was eliminated because of cost. Soil flushing and in • situ
vitrification were eliminated because they would be difficult to implement and in situ
vitrification would be very costly.
72.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No cleanup levels were derived for soil. Cleanup will continue until the underlying ground
water quality is no longer threatened by soil contaminants. Established ground water cleanup
levels must be met, and soil cleanup levels will be established in the remedial design phase
302
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-------

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? •
i • ,
Innovative technologies eliminated because of cleanup goals include: |
i •• " • •
. • '• None . : • ''•''•'',"'

Standard technologies eliminated because of cleanup goals include:

• . • None ;.'.-•' -' . • .' '•!'".
- -

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. i

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

. - Cost-effectiveness

16. How are measures compared?

Cost-effectiveness was a determining factor. Alternatives such as off rsite incineration and
disposal were eliminated because they would be more costly than the chosen alternative.
Furthermore, RAA-4A was considered equal to the chosen alternate in protection and
effectiveness, but was eliminated because of cost.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
. - ' : ' ' • i •
No technical criteria were primary in selecting a remedy. !
303
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Brodhead Creek
OU-1

Borough of Stroudsburg, Pennsylvania
Region 3
GENERAL SITE INFORMATION
1.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Subsurface Soil (mg/kg)

Ethylbenzene 0.061
Total Xylenes 0.1
PAHs 450
Arsenic 4.1
Total unidentified organics 0.17
Total phenolics 0.13
Site History
NPL Proposed:
NPL Final:
FS:
Interim ROD:
N/A
12/82
1/91
3/29/91
Background

PRP-lead
PRPs: Pennsylvania Power and Light
Company and Union Gas
Company
FS prepared by: Environmental
Resources Management, Inc;
What volume of material is to be
remediated?

The volume of material to be remediated included:

" 179 cubic yards of subsurface soil containing free coal tar
• 27,588 cubic yards of residual coal tar
3. What type of site is this?

Electric Power Production. A former coal gasification plant located in a commercial and
residential area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: .

Subsurface Soil With Free Coal Tar

Access restriction: Fencing, deed restrictions ;
304
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Containment: Slurry wall, sheet piling, grout curtain, bottom sealing
Physical/chemical: Stabilization/solidification (in situ, ex situ), dewatering, mechanical
enhanced volatilization, immobilization-chelation, immobilization-
precipitation, immobilization-polymerization
Thermal treatment: Incineration (on-site, off-site) i
Disposal: Excavation, pumping, off-site TSD landfill, recycling/recovery, on-site
• disposal, on-site replacement i
• ;' .' • 'I •'•..'
Subsurface Soils With Residual Coal Tar I

Access restriction: Fencing, deed restrictions .
Containment: Slurry wall, grout curtain, sheet pile !
Physical/chemical: Solidification/stabilization, immobilization precipitation, immobilization
polymerization
Disposal: Excavation, pumping, recycling, off-site disposal, on-site disposal

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: i

Subsurface Soil With Free Coal Tar 1

Biological treatment: Bipdegradation (aerobic, anaerobic, in situ) I
Physical/chemical: Enhanced recovery (surfactant/steam), oxidation, reduction, in situ
solvent extraction, soil washing, ir, situ vacuum extraction, in situ
vitrification :'.•"'
Thermal treatment: Low-temperature thermal stripping

Subsurface Soils With Residual Coal Tar

Biological treatment: In situ bioremediation '
Physical/chemical: In situ enhanced recovery, in situ vitrification, ivacuum extraction '
. "| • • • '
• / ' = ' ! • • •• . "
6. What was the cost estimate for the innovative technology? i
•' . i
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Aifter the RAAs have been
. formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
' implementability, and cost) to identify alternatives that merit a more detailed evaluation.'"The
estimated costs then are recalculated during an evaluation based on nine criteria established by
the NCP: long-term effectiveness arad permanence; short-term effectiveness; compliance with
ARARs; protectiveness of human health and the environment; reduction in contaminant
mobility, toxicity, or volume; implementability; cost; state/support agency acceptance; and
community acceptance. j

Alternatives presented parenthetically represent designation changes in the detailed analysis
and the ROD. | ,
I " / "

2- 305
-------
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)

Subsurface Soil With Free Coal Tar
Alternative
RAA-6
(RAA-4)
RAA-3
(RAA-5)
Innovative Technology
Excavate subsurface soil/soil washing
Enhanced recovery of free coal
tar/disposal at off-site permitted
incineration facility
Estimated Costs
3 Criteria
$3,707,000
$4,058,000
9 Criteria
$3,954,000
$4,120,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Subsurface Soil With Free Coal Tar
Alternative
RAA-1
RAA-2
RAA-4
RAA-5
(RAA-6)
RAA-7
(RAA-3)
Standard Technology
No action •
Limited action/deed restrictions/
fencing/pumping free coal tar/ship
recovered coal tar to off-site permitted
incineration facility
Excavation/off-site disposal in TSD
landfill
Excavate subsurface soils/off-site
incineration of soils
Excavate subsurface soils/on-site
stabilization/solidification
Estimated Costs
3 Criteria
$0
$1,183,000
$3,376,000
$6,816,000
$2,175,000
9 Criteria
$0
$1,176,000
eliminated
$6,227,000
$2,478,000
Subsurface Soil With Residual Coal Tar
Alternative
RAA-1
Standard Technology
No action
Estimated Costs
3 Criteria
$0
9 Criteria
eliminated
306
-3-
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Alternative
RAA-2
Standard Technology
Limited action, deed restrictions,
fencing
Estimated Costs
3 Criteria
$udo,oob
9 Criteria
eliminated
8. If a standard technology was chosen, why?

Off-site disposal of treatment residuals was selected.
9. If an innovative technology was chosen, why? ;
' '• - • ' • , .•'-'' !• .-.•••
The chosen alternative was preferred because it will remove free coal tar from the on-site
subsurface soil and minimize the potential for contaminants to leach into ground water.
Removing free coal tar will reduce the toxicity, mobility and volume of site contaminants.
This alternative minimizes short-term risk to workers since it is in situ and does not require
excavation. Excavation could cause the release of VOCs. A treatability study will be required
to ensure that remediation goals (60- to 70-percent coal tar reduction) are met. The selected
remedy is cost-effective. Elimination of the principal source of site contamination will ensure
long-term protection. In addition, while stabilization techniques would reduce only
, contaminant mobility, the chosen alternative also would reduce contaminant toxicity and
volume.
) !• .
Alternatives for subsurface soil with residual coal tar were not retained for the detailed
analysis and no explanation was given. ' '"! "
10. If an innovative technology was not chosen, why not? At what stage was the innovative • ,
technology eliminated? .''•;-.." ,
i '..>"•'
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
" effectiveness, implementability, and cost; or during the detailed evaluation. ;
•••.'' '
Innovative technologies eliminated during the initial screening includs the following:
• .- • . • l.
Subsurface Soils With Free Coal Tar ;

• Aerobic biodegradation (ex situ) was eliminated because it wpuld not be applicable to
soils and wastes streams containing concentrated coal tar and metals.
• . Anaerobic biodegradation (ex situ) was eliminated because it would not be applicable
to soils and waste streams containing concentrated coal tar, site organic contaminants,
and metals. ."'.-...'
• Oxidation was eliminated because it would not be effective on site metals and has not
been tried on soils with similar organic constituents. i
• Reduction was eliminated because it would not be effective on site metals and has not
been tried on soils with similar organic constituents.
307
-4-
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" Low-temperature thermal stripping was eliminated because it would not be applicable
to waste streams containing coal tar. ^^ j
• In situ vacuum extraction was eliminated because it would not be applicable to free ---^
coal tar.
• In situ vitrification was eliminated because the high waiter table would preclude its
implementation.
• In situ biodegradation was eliminated because it would not be applicable for soils with
high coal tar.

Subsurface Soils With Residual Coal Tar

• Enhanced recovery (in situ steam extraction) was eliminated because its effectiveness
in subsurface soils is uncertain since die technique is still in developmental stages.
" Vacuum extraction was eliminated because its application for coal tar-related volatile
and semivolatile organics is unknown. ;
" In situ vitrification was eliminated because it could not be implemented due to the ,
high water table and the soil's moisture content. ! .
• In situ bioremediation was eliminated because its viability would be precluded by the
insolubility "of coal tar, the limited availability of the coal tar to microorganisms, and
the recalcitrance of certain coal tar fractions. Furthermore, implementation would
require an enhanced recovery pretreatrnent step to reduce residual tar levels for
bioremediation. Enhanced recovery is expected to have limited effectiveness in
reducing residual coal tar levels.

Innovative technologies eliminated during the screening of the three criteria include the
following: ;

Subsurface Soils With Free Coal Tar ;

" In situ solvent extraction was never incorporated into a remedial alternative and no
explanation was given.

Innovative technologies eliminated during the detailed analysis include the following: \

Subsurface Soils With Free Coal Tar

• Soil washing was eliminated in the detailed analysis and no specific explanation was
provided. , ,

II. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in 'the elimination of the innovative technology?] If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and short-term effectiveness were the most
heavily weighted factors in selecting a remedial alternative. Soil washing was not preferred
because it would require excavation and would pose a short-term risk to site workers. ;
308
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12. What cleanup goals were selected? If the cleanup goal was based onariARAR,what was that
ARAR? What risk level was selected to establish cleanup goals? f
' - * l
No specific cleanup goals were set for soils. The performance goal defined in the ROD was to
remove 60 to 70 percent of free coal tar. Source removal was expected to prevent the future
leaching of contaminants into the shallow ground water.

13. Was the innovative technology eliminated because of the cleanup goals?, Could the standard
, technology meet the cleanup goals? ,

Innovative technologies eliminated because of cleanup goals include:! .
. 'i \ ' '

• None , !
r \ - • -
•' •
Standard technologies eliminated because of cleanup goals include: j
1 " I .
a None . p • ' . • - !
, '!""•,"•-.
" - " . . ' ' | v -
• . .- • ' I.
i i ,
14. Were treatability studies conducted on the innovative technology or standard technology?
i
No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Impact on site workers . ' j
-,' Preference for treatment (vs. containment)

16. How are measures compared? , , -.

The chosen alternative was preferred because it poses the least short-term risk to site, workers.
Since the chosen alternative is in situ, soil excavation will not be required. Excavation would
promote the release of VOCs and allow direct contact with contaminated subsurface soil.
Though the ROD addresses an interim action, treatment was preferred over containment.
Furthermore, though it was noted that long-term effectiveness was not an applicable criterion
because of the ROD's interim status, the chosen alternative was noteid to offer long-term
effectiveness and permanence through the elimination of the source, i

• '. - '.•'' ' • : •• •".-.', • ' ' i'- •'• '' • .
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? j

Technical considerations were not primary in selecting a remedial alternative.
309
.. - ' i .- i ,
-6- ., i ,
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Brown's Battery Breaking
OU-2

Tilden Township, Pennsylvania
Region 3
GENERAL SITE INFORMATION
1. What -were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Lead 170,000
Antimony 13.3
Cadmium 0.7
Cyanide 5.3
Mercury 1.9
Concentrations of BNAs, pesticides, and

Site History
«7
NPL Proposed: 10/84
NPL Final: 6/86
FS: 12/91
ROD: 7/2/92

Background

EPA Fund-lead i
PRPs: General Battery Corporation^
Te'rry Shaner (site owner) ;
FS prepared by: U.S. EPA
.-.'.'
PCBs were not given.

2. What volume of material is to be remediated?.

The volume of material to be remediated included:
39,500 cubic yards of soil in the containment area (created in the 1983 Immediate
Removal Action, the containment area is located in the site's southwest quadrant)
27,500 cubic yards of soil outside the containment area
3. What type of site is this?

Recycling. An inactive battery-reprocessing site located in a primarily rural area.

TECHNOLOGY SELECTION "'*..••'•

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
310
Fencing, signs
Berms, dikes, grouting

-1-
-------
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Stabilization/solidification, chemical precipitation
Screening, wet classification
Incineration, smelting
On-site storage, off-site disposal at RCRA landfill
5. Was .an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: { •
\ .
Chemical treatment: In situ soil flushing (solvent), soil washing (Bureau of Mines process)
Thermal treatment: In situ vitrification, fuming/gasification furnace
What was the cost estimate for the innovative technology?

RAA-5 was presented for the first time in the revised Proposed Plan.

Cost Estimates for FLAAs That Include Innovative Technologies
(selected remedial alternative is in bold) .
Alternative
RAA-5
Innovative Technology
Excavate soil and battery casings/off-site thermal
treatment (fuming/gasification furnace) of soft; and
casings/energy recovery/lead recovery
Proposed
Plan
N/Aa
"Only capital costs were provided.
-2-
311
-------
7. How did the cost(s) compare to standard technologies? .

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action/fencing/long-term monitoring
Excavate soil and battery casings/on-site
stabilization-solidification/off-site
disposal
Excavation soil and battery casings/off-
site disposal at RCRA landfill
Excavate soil and battery casings/on-site
stabilization-solidification of soil/off-site
disposal of soil/off-site incineration (and
energy recovery) of casings/lead
recovery
Estimated Costs
3 Criteria
$296,350
$28,360,000
to
$34,526,000°
$49,444,000
to
$56,949,000
$24,850,000
to
$28,428,000
9 Criteria
$296,000
$28,360,000
$49,000,000
$24,631,000
!
"The range of costs covers the difference in achieving soil cleanup levels of 1,000 mg/kg and
500 mg/kg, respectively.
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?

RAA-5 provides maximum reduction in waste volume via incineration of the casings, and
maximum reduction in contaminant toxicity and mobility by excavating and removing
contaminated soils and casings. Excavation also results in maximum protection of the
environment surrounding the site by avoiding the slight potential risk that would be posed by
leaving treated materials on site, where they could cause some future environmental harm.
RAA-5 provides for maximum reuse/recycling of the metals after their removal from the soil
matrix and is the least costly of the soil alternatives.

EPA acknowledges that RAA-5 includes an innovative technology which has not yet been
tested in treatability or pilot studies. The proposed combination of technologies, however,
have been used individually in other industrial applications and, according to EPA, has a
reasonable expectation of being successful. If not, the preferred alternative would be RAA-2,
as originally chosen in the Proposed Plan issued 8/1/92.
312
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include: the following:
I -
• In situ soil flushing was eliminated because' it might enhance migration of
contaminants to the shallow water table. [
• In situ vitrification was eliminated because it would be difficult to implement given the
shallow water table. j
" Soil washing (Bureau of Mines process) was eliminated based on treatability study
results that demonstrated that soil washing was not appropriate for the site. The fine-
grained nature and high carbon content of the site's soil would impede filtration.

Innovative technologies eliminated during the screening of the three criteria include the
following: ! "
1 • '• • '
• ' None-" ' • ' • ' • • .' ' ' I - ' . ]' ' •

Innovative technologies eliminated during the detailed analysis include; the following:
• • . l
• None i
11.
Which of the nine criteria were weighted most heavily in selecting the, technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedy include reduction of volume and cost.
RAA-5 provides for maximum reduction in waste volume via the incineration of the casings,
as opposed to RAA-2, RAA-3, and RAA-4 which would increase the volume of the waste as a
result of the solidification/stabilization process. In addition, RAA-5 would be protective of the
environment surrounding the site because the slight potential risk of the treated materials in
RAA-2, RAA-3, and RAA-4 causing some future environmental harm at the disposal site is
eliminated. RAA-5 is the least costly of the alternatives. , , i
12. What cleanup goals were selected? If the cleanup goal was based on \an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? j
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Lead
1,000
EF'Aa
"OSWER Directive 9355.4-02: Based on upper bound of residential range of 500 to
1,000 ug/kg; future site use restricted to industrial use only, f
-4-
313
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Two treatability studies were conducted to evaluate stabilization/solidification and soil
washing. These studies determined that stabilization/solidification was an appropriate
treatment for reducing lead leaching and that soil washing was not appropriate for the site
because the fine-grained nature and high carbon content of the site soil would impede
filtration. ,
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost/unit risk
Proven reliability
Reuse/recycling of materials
Preference for treatment (vs. containment)
16. How are measures compared? • • '• .
1 • i

RAA-5 was judged to be the most cost-effective remedy. Proven reliability was an uncertain
factor in selecting RAA-5 because no treatability or pilot studies have been completed. The
proposed combination of technologies, however, have been used individually in other industrial
applications and, according to EPA, has a reasonable expectation of being successful. If not,
the preferred alternative would be RAA-2, as originally chosen in the Proposed Plan issued
8/1/92. RAA-5 provides for maximum reuse/recycling of metals; although other alternatives
were not compared .based on this criterion, it was an important consideration. RAA-5 provides
for maximum reduction in contaminant toxicity and mobility at the site, by excavating and
removing contaminated soils and casings. ',
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a technology. The very shallow water
table resulted in the elimination of the following innovative technologies:, in situ soil flushing
and in situ vitrification. The fine grained nature, high carbon content of the site's soil also
was considered, resulting in the elimination of soil.washing.
314
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C&D Recycling

Foster Township, Pennsylvania
Region3
1- What were the principal contaminants
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:

Soil (mg/kg)
Jfad 324,000
Copper 85j000
Antimony 2,030
PCB 3.6
..
Ash (mg/kg)

Lead 706,666
C°PPer 105,655
Zlnc 8,362

Site
NPL Proposed:
NPL Final:
rS:
ROD:
History
9/85 -
2/21/90
1/10/92
9/30/92

Background
PRP-lead
' ' .

PRPs: AT&T Nassau Metals Corp.; 14
other (unidentified) owners of the
site, operators of the site, and
generators of material sent to
site.

the

FS prepared by: ERM-Northeast

Dioxins/Furans 0.0015
Sediments (mg/kg)
Lead 121,000
Copper 23,200
Zinc 3,660s
Antimony §342

-.'

2.
concentrations were from leach pit data submitted during public lomment period.
What 'volume of 'material is to < be remediated? '

The volume of material to be remediated included:

• 26,273 cubic yards of soil
• 1 65 cubic yards of ash
• 1,200 linear feet of creek sediments
• 1,900 cubic yards of pond sediment
• 24 cubic yards of storm water sewer sediment
-1-
315
-------
3. What type of site is this?

Recycling. The site was used for a metal reclamation operation. The site is located in a
residential/agricultural area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing
Containment: Capping (soil, multilayer)
Physical treatment: Stabilization
Disposal: Excavation, on-site disposal, off-site disposal
5. , Was an innovative technology considered in the FS? If so, which technology? '.

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Chemical treatment: Soil washing, electrokinetics '
6. What was the cost estimate for the innovative technology? ;

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology
No further action/continued main-
tenance of sedimentation and erosion
control systems/ash pile covers/fencing
Estimated Costs
3 Criteria
N/A '
9 Criteria*
$831,020
316
-2-
-------
Alternative
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
/
Standard Technology
Continued maintenance (as in RAA-
l)/common actions (see below)/
.excavation/consolidation/fencing
Continued maintenance (as in RAA-
l)/common actions (see below)/ excava-
tion/consolidation/fencing/soil cover
Continued maintenance (as in RAA-
l)/common actions (see below)/
excavation/consolidation/fencing/
multilayer cap
Continued maintenance (as in RAA-
l)/common actions (see below)/
excavation/consolidation/fencing/
stabilization/off-site disposal
Continued maintenance (as in RAA-
l)/common actions (see below)/
excavation/cbnsolidation/fencing/
stabilization/on-site disposal
Estimated Costs
3 Criteria
MA
N/A
i_
N/A
i
N/A
'
• • . i-
.
N/A
i
,i
9 Criteria"
$2,263,740
($2,270,531)
$3,302,210
($3,863,585)
3,919,220
($4,830,138)
$8,944,565
($11,985,717)
$5,706,345
($7,361,185)
"Costs given for cleanup level of 1,000 ppm lead and 500 ppm lead. iThe 500 ppm costs are
in parentheses. Note that Proposed Plan costs are for 500 ppm lead, i

1
The following common actions were carried out for RAAs 2 through ;6.
Common
Action
CA-1
CA-2
CA-3
CA-4
CA-5
CA-6
CA-7
CA-8
Description
Excavation/cement stabilization of pond and creek sediments/
remediation of pond bottom/temporary diversion of Mill Hopper
Creek
Excavation/possible stabilization of storm water sewer system
sediment/possible co-disposal with other soil of sediment
Decontamination of site buildings
Removal of casing and wire
Deed restrictions
Abandon all wells not used or considered part of groiund water
monitoring network
Monitoring of stream and/or pond water and stream biota ;
s ' . '
Phase IB archeological survey prior to any excavation soil
-3-
317
-------
Common
Action
CA-9
Description
Soil toxicity testing after soil excavation and
regrading is completed
8. If a standard technology was chosen, why?

RAA-5, by including stabilization as an integral remedial action in addition to containment,
provides the greatest protection to human health and the environment! The long-term
effectiveness and permanence and the reduction in toxicity provided by ash, soil, and sediment
stabilization are significant advantages over containment only. In the FS, RAA-6 was chosen
over RAA-5 because the on-site disposal facility, constructed with liners and covers, meets
RCRA requirements, .whereas the off-site disposal facility might not have been constructed
with an impermeable liner; co-disposal with other wastes and the continuous long-term
operation of a commercial landfill could adversely affect the long-term effectiveness and
permanence of stabilized materials; a commercial landfill might not be closed for several years,
during which time only daily covers would be installed, possibly exposing the stabilized
material to storm water infiltration; transportation of the material would be required for off-site
disposal; and off-site disposal would cost $3.2 million more than on-site disposal. This
decision was reversed in the ROD due to public preference for off-site disposal and state
concerns over the design of the on-site containment cell's ability to comply with residual waste
management regulations. However, if the PRPs can show within 180 days of issuance of the
ROD that an on-site remedy is equally or more protective, is cost-effective, and complies with
all ARARs, EPA will solicit public comment and possibly return to on-site disposal.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen
JO.
318
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ':

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the, screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• None

Innovative technologies eliminated during the screening of the three criteria include the
following (note that these technologies were not incorporated into RAAs but were subjected to
a three criteria analysis):

• Soil washing was eliminated because the fine nature of the media, in particular ash and
sediment, would mean the technology would not sufficiently remove target chemicals,
the technology would result in a residual slurry, and further treatment would be
required.

-4- •• .. • • :
-------
• Electrokinetics technology was eliminated because it requires saturated soils. The
technology could not be implemented at the site. !
l
Innovative technologies eliminated during the detailed analysis include the following:

• None
11.
12.
13.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
\
Public and state acceptance were weighted heavily in selecting off-site disposal over on-site
disposal. Overall protection, long-term effectiveness and permanence, and reduction of
toxicity and mobility through soil treatment as opposed to containing the contamination were
both strong influences on the selection of stabilization and containment over containment
alone.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? j
> - ' i '. - •
Several cleanup goals were originally selected for soil, sediment, and stabilized ash. It was
later decided, however, that the area of contamination delineated by lead satisfactorily
addresses unacceptable levels of other site-related contaminants. j
Contaminant
Cleanup Level (ppm) ARAR!or Other Basis
Noncarcinogens
Lead
500 ppm
Risk"
"Based on a child blood level of 10 ug/dL.

For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For noncafcinogens, a Hazard Index less than or equal to 1.0 was acceptable.

• " . ' ; \ ' "

Was the innovative technology eliminated because of the cleanup goats? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• , None

Standard technologies eliminated because of cleanup goals include:

• None . , .
-5-
319
-------
14. Were treatability studies conducted on the innovative technology or standard technology?
- ,. . • .. . • •; •
Treatability studies were conducted to determine the effectiveness and unit cost of
stabilization. Samples of soil and ash from the site were tested, .and the treatability study
report confirmed that ash, soil, and sediment could be immobilized through stabilization.

15. What measures/criteria were used to compare alternatives? '•••"

The following measures were used to compare the alternatives:

Risk level achieved . , '''''.'
Total cost
Preference for treatment (vs. containment)

16. How are measures compared? ' ,

RAA-5 (off-site disposal) does not provide a reduction in risk beyond that provided by RAA-6
(on-site disposal). The selected remedy (RAA-6), however, will eliminate the site risks.
Transporting material off site (RAA-5) would involve higher short-term risks, through possible
accident and subsequent contact, and air pollution, than RAA-6. RAA-5 and RAA-6 are
compared in terms of cost, in that RAA-6 costs approximately two- thirds that of RAA-5.
Preference for treatment was a factor in selecting stabilization and containment over
containment alone. -"Sk

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. The fine nature of the
media, in particular ash and sediment, was a factor in eliminating soil washing.
320
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CryoChem, Incorporated
OU-3

Worman, Pennsylvania
Region3
GENERAL SITE INFORMATION

_ 1. What were the principal contaminants,
. contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

.Tetrachloroethylene 0.46
1,1,1-Trichloroethane 22
1,1-Dichloroethane 4
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 70 cubic yards of soil
Site History
NPL Proposed:
NPLFinal:
FS:
ROD:
7/89
10/89
6/2/90
9/30/91
Background

EPA Fund-lead
PRPs: CryoChem, Incorporated; C.S.
Garber and Sons Incorporated;
other owners and operators of
CryoChem, Incorporated and the
property (not listed)
FS prepared by: Dynarnac
Corporation ,
3. What type of site is this?

Fabricated Metal Products. A metal fabrication facility.
TECHNOLOGY SELECTION
i
4. What standard technologies were considered for selection in this FS?,

Standard technologies considered during the identification and screening of technically feasible.
technologies were: - j
Containment:
Thermal treatment:
Disposal:
Clay cap i
Incineration ' i • ;
Excavation, off-site disposal at RCRA Subtitle C facility
-1-
321
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5. Way an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Physical treatment: In situ/ex situ vapor extraction

6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(pnor to the fonnulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are usually estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, estimated costs were calculated during an evaluation based on the
nine criteria established by the NCR

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-5
(RAA-3)
RAA-5A
(RAA-2)
=======
Innovative Technology
In situ vapor extraction
In situ or ex situ soil vapor extraction/
excavation and disposal of soil at
RCRA Subtitle C facility
' " ' —^— — _ _
Estimated Costs
9 Criteria
$58,000
N/A
ROD
$53,000 to
$66,400'
$106,000 to
$119,000
y
"Costs were estimated for both in situ and ex situ options. The in situ optipn was always the
higher estimate.
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
(RAA-5)
RAA-3
Standard Technology
No action/5-year review
Concrete cap
Excavation/disposal at off-site RCRA
Subtitle C landfill
======================— _=i
Estimated Costs
9 Criteria
$3,100
$16,700
$41,000
ROD
$0
$34,900"
eliminated
322
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? |

No technical criterion was primary in the selection of a remedy.
-5-
325
-------
Defense General Supply Center
OU-1

Richmond, Virginia
Region 3
GENERAL SITE INFORMATION

/. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Antimony 6.6
Arsenic 88
Cadmium 5 ,
Chromium (VI) Q.71
Acetone 0.27
Carbon disulflde 0.033
Chloroform 0.013
Methylene chloride 0.063
Toluene 0.0064
Xylene 0.0028
Benzoic acid 0.055
Anthracene 0.062
Benzo(a)anthracene 0.35
Benzo(a)pyrene 0.3
Benzo(b)fluoranthene 1.5
Benzo(g,h,i)perylene 0.22
Benzo(k)fluoranthene 0.5
Bis(2-ethylhexyl)phthalate 0.87
Chrysene 0.98
Dibenzo(a,h)anthracene 0.046
Di-n-octyl phthalate 1.4
Di-n-butyl phthalate 0.23
Fluoranthene i
Indeno(lA3-cd)pyrene 0.2
4-Nitrophenol 0.05
Phenanthrene 0.17
Pyrene 1
2,4-D 0.13
4,4'-DDD . 0.0042
4,4'-DDE 0.04
4,4'-DDT 0.22
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1984
1987
10/91
5/15/92
Background

Federal Facility >
PRPs: Army Corps of Engineers
FS prepared by: Law Environmental
)i
326
-1-
-------
2. What volume of material is to be remediated?

The volume of material to be remediated included:
, >• ' i • • •
• 27,700 cubic yards of soil ' , • I .

3. What type of site is this? ' .'•',' .

Military. The site is used for the storage of drummed and containerized chemicals. The site is
located on a facility that manages and furnishes military general supplies. Land use in the
vicinity of the facility is primarily single-family residential, intermixed with retail stores and
light industry. . i

TECHNOLOGY SELECTION - j

4. What standard technologies were considered for selection in this FS?\

Standard technologies considered during the identification and screening of technically feasible
technologies were:
' • . ' ' J • •
Access restriction: Fencing, warning signs, deed/zoning restrictions
Containment: Capping (clay, synthetic, asphalt, cbncrete, multi-media), vertical
barriers (sheet piling, grout curtain, slurry wall)
.Chemical treatment: Ex situ stabilization (microencapsulation, solidification)
Physical treatment: Soil aeration j
Thermal treatment: Ex situ thermal treatment
Disposal: Excavation, on-site landfill, off-site landfill, backfilling
' • ' •' I1 >
i ' '
; ' -N -
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: , . '
I . •' '•
Biological treatment: In situ biodegradation (nutrient/oxygen injection, microorganism
seeding, surfactant addition), ex situ biological treatment
Phys/Chem. treatment: In situ chemical oxidation, in situ solvent extraction (aqueous solvent,
miscible organic solvent, organic solvent), ex!'situ soil washing (solvent
extraction), in situ vacuum extraction
Thermal treatment: Ex situ vitrification, steam stripping . ' .
.•'.,' ' i

6. What was the cost estimate for the innovative technology? j

' .' . . • -2- -: ! , '.• ''''327
-------
evaluation. The estimated costs are calculated during an evaluation based on nine criteria
established by the NCP.
i

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4
Innovative Technology
Excavation/soil washing/backfill with
clean soil
Estimated Costs
3 Criteria
$4,294,000
9 Criteria
$6;067,578
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-4
RAA-5
RAA-6
— =====
============================5=
Standard Technology
Multilayer, multimedia cap/grading/
surface water runoff collection/
monitoring wells/extended monitoring
program
Excavation/stabilization/solidification
Excavation/off-site treatment/
backfilling with clean imported soil
Deed restrictions/air monitoring
No action
-^rr^^r:
Estimated Costs
3 Criteria
$842,300
$1,239,000
$9,695,000
$15,000
$0
========
9 Criteria
$825,300
eliminated
eliminated
$15,000
:$0
8. If a standard technology was chosen, why? '

RAA-5, institutional controls, was chosen because although risk-based soil action levels or
background levels for arsenic and antimony were exceeded in one sample each, none of the
constituents found in the soils are present in the ground water at concentrations greater than
MCLs. Additionally, the samples containing arsenic and antimony concentrations greater than
the risk-based action levels or background levels were collected at depths greater than 5 feet
Exposure to these constituents, therefore, would not be expected to occur unless excavation
activities take place at the site. RAA-5 was selected to be the most effective and appropriate
option.
328
-3-
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9. If an innovative technology was chosen, why? ! ,

An innovative technology was not chosen. t

.. : • I. ' . ^ '
' • : f' ,
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
'/ . • !
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ biodegradation was eliminated because potential leachiate generation might
contaminate deeper soil zones.
• In situ chemical oxidation was eliminated because the technology would not be well
demonstrated; and there would be a potential fot either incomplete reaction or
application of excess reagents.
.• In situ vacuum extraction was eliminated because the primary contaminants are
semivolatiles and the contamination is shallow. !
» In situ steam stripping was eliminated because the technology would be more -
applicable to deeper contamination.. j
• In situ solvent extraction was eliminated because the technology would be more
suitable to deeper contamination and there would be a high potential for ground water
contamination. !
• Ex situ biological treatment was eliminated because the technology would not be
applicable to metals.
• Ex situ vitrification was eliminated because the technology w,ould be extremely
expensive to implement and the soil is probably not amenable to treatment.

Innovative technologies eliminated during the screening of the three criteria include the
following: '

• . None • ' , . • . " j

Innovative technologies eliminated during the detailed analysis include the following:
i •
• Soil washing would have the highest short-term exposure potential because the soil
would be excavated; it would be the most difficult to implement since testing and
treatability studies would be required in addition to treatment; and it would be the
most expensive alternative. It ranked higher, however, than the other RAAs in long-
term effectiveness; reduction of contaminant mobility, toxicity, zind volume;
compliance with ARARs; and overall protection. The only explanation for its
'•elimination is that no remedial action was chosen.
-4-
329
-------
U.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

There was no clear indication as to which criteria were most important; however from the
above discussion, Cost-effectiveness seems to be a deciding factor. The selected alternative
institutional controls, provides overall protection to human health and the environment by
restricting access to the site, thus reducing the principal threat of exposure through ingestion or
dermal contact with the contaminated soils. The remedy offers short-term effectiveness since
no excavation is needed and there is no excess risk from exposure to surface materials as
determined in the baseline risk assessment. The remedy is very easy to implement because no
. direct physical actions take place and it is the least costly alternative.

No innovative technologies were considered under the nine-criteria screening.
12'
330
A oals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
—
Contaminant
i s^=:^=
Cleanup Level (mg/kg)
1 .1
ARAR or Other Basis
Carcinogens i . • .
Arsenic
Cadmium
Chromium (VI)
Chloroform
Methylene chloride
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Bis(2- '
ethylhexyl)phthalate
Chrysene
Dibenzo(a,h)anthracene
Indeno(l ,2,3-cd)pyrene
4,4'-DDD
4,4'-DDE
4,4'-DDT
7.2
6.0
60
1,700
1,400
6.1
0.86
6.5
14
740
200
0.79
3.8
43
30
30
Soil background level8
Risk-based
Risk-based
Risk-based
Risk-based ! '•
Risk-based
Risk-based
Risk-based •.
Risk-based
Risk-based ',
Risk-based
Risk-based ;
Risk-based
Risk-based
Risk-based
Risk-based
-5-
-------
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Noncarcinogens
Antimony
Acetone
Carbon disulfide
Toluene
Xylene
Benzoic acid
Anthracene
Benzo(g,h,i)perylene
Di-n-octyl phthalate
Di-n-biityl phthalate
Fluoranthene
4-Nitrophenol
Phenanthrene
Pyrene
,2,4-D
4.8
,1,200
1,200
2,400
24,000
48,000
3,600
41
240
1,200
480
48
85
11
120
Risk-based
Risk-based
Risk-based
i Risk-based
Risk-based
Pisk-based
Risk-based
Bisk-based
Risk-based
Risk-based
Risk-based
Risk-based
Risk-based
Risk-based
Risk-based
The risk-based soil action level was lower than the background soil level, so
background levels were used instead.

For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
• ' ' - ' . *
... .1
' i ' ! •
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard

technology meet the cleanup goals? [
'.'.'-'•'

Innovative technologies eliminated because of cleanup goals include: i

.. i ' •
• -• None i • • •

Standard technologies eliminated because of cleanup goals include:

• None
331
-6-
-------
14. Were treqtability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives? ' ' ' :

Level of contamination, depth of contamination, and lack of ground water
contamination

16. How are measures compared?

The selection of RAA-5 was based on the fact that only two soil samples showed
contamination above cleanup levels and this contamination was located more than 5 feet below
the surface. Furthermore, no ground water contamination was observed. For these reasons
remediation was deemed to be unnecessary.
17.
i

What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. One reason for eliminating
ex situ vitrification was that the soil probably would not be amenable to treatment. \
332
-7-
-------
Defense General Supply Center
OU-5

Richmond, Virginia
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Arsenic 81
Benzene 0.001
Chloroform 0.003
1,2-Dichloroethane 0.015
Tetrachloroethylene 1.5
Toluene 0.002
Triehloroethylene 0.036
Xylene 0:003
Bis(2-ethylhexyl)phthalate 0.81
Di-n-butyl phthalate 0.24
1,2-Dichlorobenzene 0.14
Diethyl phthalate 0.12
Di-n-octyl phthalate 0.41
2-Methylnaphthalene 0.58
4-Methylnaphthalene 0.11
Naphthalene 0.11
Phenanthrene 0.073
Pyrene 0.064
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1984
1987
10/91
3/25/92
Background

Federal Facility j
PRPs: U.S. Army!Corp. of Engineers
FS prepared by: Law Environmental
2. :What volume of material is to be remediated?

The volume of material to be remediated included:

, • 1,000 cubic yards of soil

I • '

3. What type of site is'this? ,

Military. The site consists of acid neutralization pits. The site is located on a facility that
manages and furnishes military general supplies. Land use in the vicinity is primarily single-
' family residential, intermixed with retail stores and light industry.
-1-
333
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: / ,
Access restriction:

Containment:
Institutional controls (zoning and deed restrictions, restrictive
covenants, fencing, and warning signs)
Capping, vertical barriers ] ' .
Chemical treatment: Stabilization
Physical treatment: In situ soil aeration
Thermal treatment: Incineration (rotary kiln, fluidized bed, and circulating fluidized bed)
n,cnocai- Excavation, on-site landfill, off-site landfill
Disposal:
6.
334
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: :

Biological treatment: In situ biodegradation, ex situ solid phase, ex situ slurry phase
Phys/Chem treatment: In situ chemical oxidation, ex situ soil washing, in situ vacuum
extraction ,
Thermal treatment: Infrared thermal desorption, in situ steam stripping

What was the cost estimate for the innovative technology?

Standard Technology
Multilayer, multimedia cap/grading/
surface water runoff collection
Excavation/solidification, stabilization/
backfilling with treated soil
Excavation/circulating1 fluidized bed
incineration
Excavation/off-site treatment/
backfilling with clean imported soil
Deed restrictions
No action
Estimated Costs
3 Criteria
$50,000
$180,000
$380,000
1 .
$350,000
• - i
$15,000
$0
9 Criteria
$43,135
eliminated
eliminated
eliminated
$15,000
$0
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?
! • i •
RAA-7, in situ vacuum vapor extraction, was chosen because it protects human health and the
environment through the treatment of contaminated soils. This remedy also will mitigate the
threat of contaminants leaching from the soils into the underlying ground water. RAA:7 meets
all ARARs and treats soils to well below the proposed risk-based soil action levels. It is the
least costly of the alternatives identified that employ treatment as a principal method of
remediation. By removing the contaminants of concern from site soils, this option will
effectively return the site to its original condition, and is therefore considered the most cost
effective of the alternatives. The selected alternative represents the maximum extent to which
permanent solutions and treatment technologies can be utilized, and ikddresses the statutory
preference of selecting a remedy that utilizes treatment, which reduces the toxicity, mobility,
or volume, as a principal element.

10. If an innovative technology was not chosen, why not? At what stage-was the innovative
technology eliminated?
• ' " ' '• * ;..}•..('
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria °f
effectiveness, implementability, and cost; or during the detailed evaluation.
-3-
335
-------
Innovative technologies eliminated during the initial screening include the following:

" in S!*"biode8radation was eliminated because application of nutrients and surfactants
to shallow contaminated soils might eventually lead to the percolation both of
contaminants and of metabolic breakdown products to keeper zones of the soil and to
ground water, which is shallow at the site.
• In situ chemical oxidation was eliminated because adequate contact is generally
accomplished through mixing contaminated soils using augers, etc., and the use of
augers would be precluded by subsurface obstructions (i.e. the pits)
• In situ steam stripping was eliminated because, for application in the field, steam is
generally forced through hollow stem slotted augers, and the use of augers would be
precluded by subsurface obstruction (i.e., the pits).
• . Ex situ slurry phase biological treatment was eliminated because the contaminated
medium is primarily dry soil and large quantities of water would need to be added to
achieve the appropriate solid/liquid composition; biological treatment does not achieve
100-percent reduction of contaminants, an aqueous residual would be generated that
would require discharge or disposal; MCLs "are much lower for water than for solid
media and therefore effluent controls on this process for the liquid wastestream
would necessarily be more stringent than for a solid phase process" and would
possibly require some form of secondary treatment or polishing step
Infrared thermal desorption was_eliniinated because it was not selected as a
representative thermal treatment. ; •-

teChn°10gieS eliminated during the screening of the three criteria include me
Ex sou soil washing was eliminated. According to comments on soil washing, because
removal efficiency is dependent on soil characteristics, the contaminants themselves
and he specific processes employed, the technology might not reduce contaminants'to
low levels. Comments also state, however, that the technology would remove the
source of contamination and leave soil clean, and that the site soils are conducive to
implementation. It is therefore not clear why the technology was eliminated. :

Innovative technologies eliminated during the detailed analysis include the following:

" ^ Si.tu S°"^se bi°trea"™nt was eliminated because the alternative will not satisfy
treaSd'soll * °r HaZard°US Waste Management Regulations for replacement of
3
77.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? if so
which criterion? Which of the criteria supported the use of a standard technology? '

Of the five balancing criteria, long-term effectiveness and permanence and reduction of
toxicity, mobility, and volume through treatment were the most heavily weighted Bv
namnvinnr the Contaminants of cnnrv.rn human t.ool+1, ancj jjj o • j ,
Failure to meet ARARs resulted in the elimination of RAA-4 (solid phase bibtreatmentX
336
-4-
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? \
•• . • ' , . ' • ' • 1
Contaminant
Cleanup Level (nig/kg)
ARAR oir Other Basis
Carcinogens
Arsenic
benzene
Chloroform
Tetrachloroethylene

Trichloroethylene.

Bis(2-
ethylhexyl)phthalate
5.7
360
1,700
200
0.58
16,000
0.20
740
Risk-based
Risk-based
Risk-based
Risk-based
Model
; Risk-based
Model
Risk based
Noncarcinogens
1 ,2-Dichloroethane
1 ,2-Dichlbroethylene
Toluene
Xylene
Di-n-butyl phthalate
1 ,2-Dichlorobenzene
Diethyl phthalate
Di-n-octyl phthalate
2-Methyhiapthalene
4-Methylnaphthalene
Naphthalene
Phenanthrene
Pyrene
110
0.022
1.3
2,400
24,000
1,200
1,100
9,700
240
600
480
48
85
11
Risk based
Model
: Model
Risk-based
Risk-based
Riisk-based
Risk-based
Risk-based
Risk-based
, Risk-based
Risk-based
Risk-based
Risk-based
Risk-based
"Soil cleanup levels were calculated to protect ground water.] CeJculation parameters
include K^., MCL, and a dilution factor of 55 (based on Summer's Equation).
Other, cleanup levels were determined, but the chemicals were not found at
concentrations exceeding those levels.
-5-
337
-------
13.
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6-
was acceptable. For noncarcinogens, a Hazard mdex less than or equal to 1.0 was acceptable.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? , ' - •

Innovative technologies eliminated because of cleanup goals include: '

• None

Standard technologies eliminated because of cleanup goals include: '

• None . '
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost .
Time to design/construct/operate
Preference for treatment (vs. containment)
16. How are measures compared?

RAA-7 is the cheapest alternative that employs soil treatment. RAA-4 and RAA-7 are
compared in relation to the time needed to remediate the site, in that RAA-4 would complete
remediation in a shorter time period. Preference for treatment was an important consideration
in selecting in situ vacuum extraction, but was not used as a comparison between technologies
Also, RAA-4 and RAA-7 are compared in terms of treatment in that RAA-4 treats the • soil by
breaking the contaminants into safe byproducts, whereas RAA-7 transfers the contaminants to
carbon adsorption units.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. The presence of subsurface
obstructions prevented the use of augers, which eliminated in situ chemical oxidation and in
situ steam stripping. Also, possible contamination of the shallow ground water was a factor in
eliminating in situ biodegradation.
338
-6-
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Dixie Caverns County Landfill
OU-1

Roanoke County, Virginia
Region3
.GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and mec
this feasibility study?

Maximum concentrations of principal
contaminants were:

Fly ash1 (KO61 Waste) (mg/kg)

Antimony
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead
Mercury
Nickel
Selenium ,
Silver
Thallium
Zinc
linants,
iddressed in

ncipal

_\
g)
14
76
30
1,600
420
1.7
49,500
3.1
200

Site
NPL Proposed:
NPL Final:
FS:
Interim ROD:

History
'1/27/87
10/4/89
5/27/92
9/30/91
Background

EPA Fund-lead

PRPs: Roanoke County, Roanoke
Electric Steel Corporation (RES);
EPA identified other PRPs but
they are not listed.
FS prepared by: T

' --
1.5
31
0.9 ,
220,000
etraTech, Inc.

2. What volume of material is to be remediated?

The volume of material to be remediated included:

• s 9000 cubic yards of fly ash
3. What type of site is this?

Municipal Landfill. A former municipal landfill in a rural setting.
'This ROD is an interim action decision that addresses remediation of the fly ash pile only.
-1-
339
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? '

This Interim Action ROD was prepared before the RI/FS for the site was completed therefore
technologies were not considered during an initial screening process. EPA was able to
develop this interim solution because sufficient information was available to determine the
appropriate fly ash remedy.
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies were not considered.
6, What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to1 the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs typically are estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. The estimated costs then are recalculated during an evaluation based on nine
criteria established by the NCP. Costs were developed only in the Interim Action ROD for the
two interim remedial actions. No innovative technologies were considered.
7.
340
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-I
RAA-2
Standard Technology
No action
Removal of fly ash and treatment in
off-site high-temperature metals
recovery facility
Estimated Costs
Interim ROD
$0
$3,927,158
S. If a standard technology was chosen, why?

RAA-2 was selected because this alternative greatly reduces the risk of exposure to the fly ash
pile by removing the waste from the site and using a recovery technology, High- Temperature
Metals Recovery (HTMR). HTMR reduces the toxicity of the fly ash and minimizes the
volume of waste requiring land disposal. The mosf significant ARAR for RAA-2 is the RCRA
Land Disposal Restrictions (LDRs). Treating the fly ash via HTMR (which is the process on
which EPA treatment standards in the KO61 LDR final rule were based) will assure that the
fly ash meets the KO61 treatment standards. EPA determined that HTMR represented the Best
Demonstrated Available Technology (BOAT) for KO61 waste when the waste contains 15
-2-
-------
percent or more of total zinc (i.e., high zinc subcategory). RAA-2 will be technically and
administratively feasible. The excavation, removal, and transport of the fly ash is a standard
site cleanup and construction procedure and should not present any unusual technical or
administrative problems. An HTMR facility is also available. The HTMR process has been
proved to be an effective treatment method for fly ash material.

i '•
9. If an innovative technology was chosen, why?
• • ' . . i "'•.•'
An innovative technology was not chosen.
• !'••--.
i
•
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
i, •
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
' ~'
Innovative technologies eliminated during the initial screening include the following:

• None

Innovative technologies eliminated during the screening of the three c riteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:
j
• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
- • ' ' • !
Overall protection of human health and the environment, compliance with ARARs, and
reduction of toxicity, mobility, and volume through treatment were heavily weighted in
selecting RAA-2. RAA-2 protects human health and the environment from the risks posed by
ingestion, dermal absorption, or inhalation of the fly ash by significantly reducing the toxicity
and volume of the fly ash. The selected interim remedial action also includes measures to ,
protect human health and the environment from accidental releases or migration of
contamination from the fly ash through air emissions and surface runoff. In addition, RAA-2
complies with all ARARs, particularly RCRA land disposal restrictions that apply to KO61
wastes in the high zinc subcategory.
-3-
341
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Carcinogens
Lead
Cadmium
Cleanup Level (rag/kg)
ARAR or Other Basis

0.095
0.032
RCRA"
RCRA
"Cleanup goals are based on on-site disposal criteria developed by EPA during the
recent RCRA KO61 LDR ruling.
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? .

Innovative technologies eliminated because of cleanup goals include:

" None ;

Standard technologies eliminated because of cleanup goals include:

» Stabilization (see Question 14) was eliminated because, based on currently available
data, EPA was not confident that the stabilization process could be readily 'operated at
the site to achieve the appropriate health-based concentration levels.

14.
Were treatability studies conducted on the innovative technology or standard technology?

Roanpke County and Roanoke Electric Steel Corporation (RES) originally developed a
stabilization and on-site disposal plan for remediation of the fly ash pursuant to the 1987
Consent Agreement and Order with EPA. Part of this plan consisted of preliminary treatability
test data for stabilized fly ash from the site. The EP Toxicity concentrations for lead and
cadmium were 0.35 mg/L and 0.73 mg/L, respectively. These levels did not achieve the
required treatment standards of 0.315 mg/L for lead and 0.063 mg/L for cadmium. However
the disposal plan stated that with additional treatability efforts, the stabilization process could'
be optimized to achieve these levels. Since this treatability study was conducted significant
changes were made in the delisting concentration level that must be achieved prior to on-site
land disposal of the treated fly ash. The most significant change occurred with respect to lead
The LDR treatment standard using TCLP analysis for lead is 0.37 mg/L. Fly ash treated to
this level would have to be disposed of in a RCRA Subtitle C/VHWMR hazardous waste
landfill. For treated fly ash to be disposed of in an on-site RCRA Subtitle D/VSWMR solid
waste landfill, TCLP analyses for lead would have to achieve a level of 0.095 mg/L. None of
the analyses performed using the RES stabilization process achieved the level of 0.095 mg/L
342
-4-
-------
75. What measures/criteria were used to compare alternatives?

The following measures were used.to compare the alternatives:

• - Cost-effectiveness
Proven reliability
Preference for treatment (vs. containment)

16. How are measures compared?

The selected interim remedial action is cost-effective because it greatly rediuces the risk posed
by fly ash at the site. The HTMR process was selected because it has been proved to be an
effective treatment method for fly ash material. The selected remedy satisfies the statutory
preference for treatment as a principal element. RAA-2 addresses the primary threat of
incidental ingestion of fly ash using the HTMR treatment process to reduce the toxicity,
volume, and mobility of the fly ash. !
I ' •
i
• • • -1
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
'I
Technical considerations were not primary in selecting this interim remedial action.
-5-
343
-------
Eastern Diversified Metals
OU-1 and OU-2

Rush Town hip, Pennsylvania"
Region 3
„)
GENERAL SITE INFORMATION

/. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Fluff Piles (mg/kg)
PCBs
Lead
Dioxin

Soil (mg/kg)
5,560
40,000
0.0185
DEHP
DNOP
PCBs
Dioxin
Lead
Copper
Zinc
Cadmium
3,300
720
240
0.071
1,920
108,000
1,230
7
Sediment (mg/kg)
DEHP
PCBs
Lead
Copper
Zinc
Iron
Aluminum
4,000
8.4
1,300
3,090
7,850
54,800
30,500
Site History
NPL Proposed:
NPLFinal:
FS:
ROD:
N/A
10/5/89
1/8/91
3/29/91
Background

PRP-lead
PRPs: Theodore Sail, Incorporated
AT&T Nassau Metals
Coiporation
FS prepared by: Environmental
Resources Management
Incorporated
2.
344
What volume of material is to be remediated?

The volume of material to be remediated included:

" 500 cubic yards of dioxin-contaminated fluff
• 5,160 cubic yards of PCB-contaminated fluff
" 480 cubic yards of lead-contaminated soil
-1-
-------
120 cubic yards of metal-contaminated sediments
3. What type of site is this?
I
Recycling. A former metals reclamation facility that is bordered by both residential and
industrial areas.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? ,

Standard technologies considered during the identification and screening of technically feasible
technologies were:
\ ' •
Fluff Piles
Access restriction:
Containment:
Physical/chemical:
Fencing, deed restrictions « i
Capping (single layer, synthetic membrane, multilayer), revegetation
Stabilization/solidification, thermoplastic solidification
Physical treatment: Recycling (bulk processing, physical separation, resin recovery),
grading^ dikes, berms, channels, ditches f
Thermal treatment: Incineration (on-site and off-site)
Soil and Sediment
Chemical treatment: Stabilization/solidification, thermoplastic solidification
Physical/chemical: Physical separation
Thermal treatment:. Incineration (on-site and off-site) |
Disposal: Disposal (on-site and off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Fluff Piles I

Physical/chemical: Contaminant extraction, in situ flushing !
I • '
Soil and Sediment , i
' ' j ' - - ' i " =
Physical/chemical: Contaminant extraction, in situ soil flushing
Thermal treatment: In situ vitrification !,. '
, -2-
345
-------
6. What was the cost estimate for the innovative technology? -

Turing the initial screening process, in which technically f-isible technologies are identified
U '
-------
Alternative
RAA-3B &
GW-4
RAA-4 &
GW-2
RAA-4 &
GW-4
RAA-5 &
GW-2
(RAA-4)
RAA-5 &
GW-4 "
RAA-6

Standard Technology
Fluff recycling by plastics separation/
on-site incineration of fluff and soil/
stabilization of ash/off-site ash disposal/
shallow and deep ground water
collection and treatment
In-place closure/on-site incineration of
fluff and soil/stabilization of ash/off-site
ash disposal/multilayer cap/shallow
ground water collection and treatment
In-place closure/on-site incineration of
fluff and soil/stabilization of ash/off-site
ash disposal/multilayer cap/shallow and
deep ground water collection and
treatment
On-site incineration/stabilization of
ash/off-site ash disposal/shallow ground
water collection and treatment
On-site incineration/stabilization of ash/
off-site ash disposal/shallow and deep
ground water collection and treatment
Off-site disposal at RCRA permitted
landfill
Estimated Costs
3 Criteria
not proposed
i • ' -
$14,182,000
1
not proposed'
i
i
$149,7(X),000
to
$636,024,000
not proposed
- -. •
'
$88,650,000
-r
• \ - ' .
9 Criteria1
$16,187,000
to
$19,333,000
$14,804,000
$17,745,000
$150,322,000
to
$636,803,000
$154,013,000
to
$641,562,000
eliminated
"Ground water remedial actions were added to several alternatives in the detailed analyses
stage. The higher cost reflects the addition of ground water femediatijon.
• ' . ! •
Proposed Plan and ROD j
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action
Limited action/ground water collection/
monitoring
Excavation/incineration/stabilization/
consolidation or disposal off site
Excavation/incineration/stabilization/
consolidation or off-site disposal/shallow
ground water collection, treatment, and
studies

ROD
$0 ' -
$966,000
$11,567,000
$12,429,000
.4.
347
-------
Alternative
RAA-5
Standard Technology
Excavation/incineration/stabilization/
consolidation or disposal off site/shallow and
deep ground water collection and treatment
ROD
$15,843,800
8. If a standard technology was chosen, why?

Incineration, a standard technology, was preferred because it will destroy the greatest amount
of organic constituents (phthalates, PCBs, and dioxin) in the fluff and soils. In addition
incineration will reduce the volume of contaminated media by 80 percent. Because of the
presence of dioxins and PCBs, the incinerator will be required to achieve 99.9999 percent
destruction efficiency for all hazardous organic constituents. An on-site incinerator was
suggested because it is readily available and will eliminate the need to transport contaminated
matenals off site. The elimination of contaminants through incineration will be permanent and
complete. Any residuals/metals in ash, soils, or sediments will be stabilized, a technology that
is considered effective and proven to reduce toxicity and mobility of contaminants, this
alternative was also preferred because it addresses ground water contamination.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
348
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .

• None -

Innovative technologies eliminated during the screening of the three criteria include the
following:

Fluff Piles
! '

* Contaminant extraction (solvent extraction) was eliminated because of its limited
effectiveness since the contaminants are adsorbed to the fluff and it might not remove
lead. Furthermore, the availability of the technology is limited, it would generate
wastewater that would require treatment, and pilot testing would be necessary;
» In situ flushing was eliminated because it is not appropriate for site contaminants, its
availability is limited, and it would require pilot testing. Furthermore, it would
generate.wastewater that would require recovery and treatment and it could potentially
! . , ..""

-5- . • ' '
-------
increase ground water contamination.

Soil and Sediment
Contaminant extraction (solvent extraction) was eliminated because its effectiveness is
unknown since site contaminants are bound to plastics. It might not meet cleanup
goals, services would be limited, it would generate wastewater that would require
treatment, it would require excavation of fluff piles, and it would require a pilot study.
In situ soil flushing was eliminated because it would not be appropriate for site
conditions since recovery of flushing solution would be difficult and it could
potentially increase ground water contamination. In addition, services are limited, the
elutriate would require treatment, and a pilot study would be necessary.
In situ vitrification was eliminated because it would be too costly, it has not been
'demonstrated on a remedial scale, services are limited, and a pilot study would be
needed.
Innovative technologies eliminated during the detailed analysis include the following:

• None
o
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Long-term effectiveness and the reduction of contaminant toxicity, mpbility, and volume were
the criteria that were weighted most heavily in selecting a remedial alternative. In situ
vitrification was eliminated because of its associated excessive costs. '
12. What cleanup goals were selected? If the cleanup goal was based on ah ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens ,
Dioxin
PCBs
Lead
0.020
25
1000
\ EPAa
TSCA"
JOSWERC
"Previous EPA remediation level set for Times Beach, Missouri.
bToxic Substances Control Act. j
COSWER Directive #9355.4-02.
-6-
349
-------
75. Was the innovative technology ei'-ninated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
. j . ' '
Innovative technologies eliminated because of cleanup goals include:

• Contaminant extraction in soil and sediment ' ••

Standard technologies eliminated because of cleanup goals include:

• None ,

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were'conducted. '

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability .

16. How are measures compared? "__ . ,

The chosen standard technologies were preferred because .their effectiveness was well- known. ^^ *
Several innovative technologies were eliminated because their effectiveness was questionable.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ••'•'.

The site has no subsurface impervious unit. Therefore, in situ soil flushing could not be :
implemented, since it would be difficult to develop a elutriate collection system. This
technique potentially could enhance the mobility of contaminants into the ground water. This
factor was not primary in selecting a remedy.
W)
;
350
-7-
-------
Eastern Diversified Metals
OU-3

Rush Township, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Fluff Piles (mg/kg)
PCBs
Lead
Dioxin
5,560
40,000
0.0185
2. What volume of material is to be
remediated?

, The volume of material to be remediated
included:

• 239,000 cubic yards of fluff
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
10/5/89
1/8/91
7/2/92
Background
i
PRP-lead
PRPs: Theodore Sail, Incorporated,
AT&T, Nassau Metals '
Corporation '•
FS;prepared by: Environmental
Resources Management
Incorporated
3. What type of site is this? , '•.'',-

' Recycling. A former metals reclamation facility that is bordered by both residential and
industrial areas. ••'
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? \
' • ; • !•...''
™ • ' ' I i ,
Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing, deed restrictions ' ,
Containment: Capping (single layer, synthetic membrane, multilayer), revegetation
, Physical/chemical: Stabilization/solidification, thermoplastic solidification
Physical treatment: Recycling (bulk processing, physical separation, resin recovery),
energy recovery, grading, dikes, berms, channels, ditches
Thermal treatment: Incineration (on-site and off-site) .!..'.
-1-
351
-------
5. Was an innovative technology considered in the FS? If so, which :.chnology?

Innovative technologies considered during the-identification:and screening of technically
feasible technologies were:
. r
Physical/chemical: Contaminant extraction (solvent extraction), in situ flushing
6. What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into remedial alternatives.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Feasibility Study
352
Alternative
RAA-1
RAA-2
RAA-3A&
GW-2
RAA-3A &
GW-4
Standard Technology
No action/long-term maintenance
Limited additional action/regrading
surface water control/deed restrictions
Fluff recycling by bulk processing/ on-
site incineration of fluff and soil/
stabilization of ash/off-site ash disposal/
shallow ground water collection and
treatment
Fluff recycling by bulk processing/ on-
site incineration of fluff and soil/
stabilization of ash/off-site ash disposal/
shallow and deep ground water
collection and treatment
Estimated Costs
3 Criteria
$966,000
$1,181,000
$8,536,000 to
$15,249,000
not proposed
9 Criteria3
$966,000
eliminated
$9,159,000
to
$15,872,000
$13,350,000
ito
$20,064,000
-2-
-------
Alternative
RAA-3B &
GW-2
RAA-3B &
GW-4
RAA-4&
GW-2
RAA-4&
GW-4 ,
RAA-5 &
GW-2
RAA-5 &
GW-4
RAA-6
Standard Technology
Fluff recycling by plastics separation/
on-site incineration of fluff and
soiystabilization of ash/off-site ash
disposal/shallow ground water
collection and treatment
Fluff recycling by plastics separation/
on-site incineration of fluff and
soil/stabilization of ash/off-site ash
disposal/shallow and deep ground water
collection and treatment
In-place closure/on-site incineration of
fluff and soiystabilization of ash/off-site
ash disposaymultilayer cap/shallow
ground water collection and treatment
In-place closure/on-site incineration of
fluff and soiystabilization of ash/off-site
ash disposaymultilayer cap/shallow and
deep ground water collection and
treatment
On-site incineration/stabilization of
ash/off-site ash disposayshallow ground
water collection and treatment
On-site incineration/stabilization of ash/
off-site ash disposayshallow and deep
ground water collection and treatment
Off-site disposal at RCRA-permitted
landfill
Estimated Costs
3 Criteria
$11,374,000
tp
$14,520,000
not proposed
$14,182,000
not proposed
$149,7013,000
to
$636,024,000
not proposed
$88,650,000
9 Criteria3
,$11,996,000
to
$15,142,000
$16,187,000
to
$19,333,000
$14,804,000
$17,745,000
$150,322,000
to
$636,803,000
$154,013,000
to
$641,562,000
eliminated
"The higher cost reflects ground water remediation costs, added to several illternatives during

the detailed analysis stage.
I • ' ' ' .
1
Proposed Plan and ROD . ,
Alternative
RAA-1
RAA-2
RAA-3
1 Standard Technology
No action '
On-site recycling of flufffdisposal of nonrecyclab
and recycling residuals
RCRA multilayer cap

les

9 Criteria
$0
$13,100,000
to
$21,900,000"
$15,000,000
-3-
353
-------
Alternative
RAA-4
Standard Technolog;
Excavation/incineration/off-site disposal of ash ,
9 Criteria
$150,000,000
to
$636,000,000
"Costs will vary depending on the recycling technology used, the number of machines placed
on site, the volume of nonrecyclables and recycling residuals, and whether the residuals are
hazardous and need treatment.
8. If a standard technology was chosen, why?

RAA-2 was selected because it will prevent exposure through dermal contact, inhalation, and
ingestion, and the further release of hazardous substances from fluff materials into soils
sediments, surface water, and ground water at the site. Recycling will reduce current and
potential site risks by reducing contaminant mobility through the encapsulation of the
contaminants in a recycled product. Recycling will provide a high level of protection because
the fluff will be converted to a nonhazardous form and will be removed from the site through
distribution of the recycled product and the disposal of residuals. The volume of the fluff
piles will be reduced by 60 to 95 percent. Toxicity will be reduced because the recycling
technology will render the materials nonhazardous and physically inseparable from the product.
This remedy provides a high degree of long-term effectiveness and permanence since the fluff
piles will be removed from the site. Recycling can be easily implemented because standard,
readily available machinery is used. Markets for recycled fluff products are expected to be
easily identified. RAA-2 is the most cost-effective alternative. ;
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
JO.
354
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• An initial screening was not done in this FS.

Innovative technologies eliminated during the screening of the three criteria include,the
following:

» Contaminant (solvent) extraction was eliminated because it is unlikely that lead could
be extracted or washed from the surface of the plastic fluff as lead is thought to be an
-4-
-------
11.
inherent component of the plastic. Furthermore, the availability of the necessary
equipment and workers to implement the process is limited as jit is an emerging
technique. It would generate wastewater that would require treatment, and pilot testing
would be necessary.
• In situ flushing was eliminated because an impervious unit beneath the area of concern
does not exist at the site which does not allow efficient collection of contaminated
extraction fluid. Application of a flushing solution may enhance constituent mobility.
, Installation of an elutriate collection system would require an extensive effort that may
result in exposure to site contaminants. There is limited availability of the necessary
equipment and site workers to implement the technology. A treatment system for
spent extraction fluid would be required. Costs would be very high because of the
elutriate system. Remediation time would be very long.
! '
Innovative technologies eliminated during the detailed analysis includes the following:

• None - . '!.''.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
. . • • ' • ' ' i
The criteria that were weighted most heavily in selecting a remedial alternative were long-
term effectiveness and cost. The chosen alternative was preferred because it will provide a
long-term and permanent reduction of contaminants and it is the most protective alternative for
the least cost.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What, risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAB, or Other Basis
Carcinogens
Dioxin
PCBs
Lead
0.020
25
1000
1 EPAa
; TSCAb
OSWERC
"Previous EPA remediation level set for Times Beach, Missouri.
'Toxic Substances Control Act.
COSWER Directive #9355.4-02.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ' , j
• • ! •
Innovative technologies eliminated because of cleanup goals include:

• None
-5-
355
-------
Standard technologies eliminated because of cleanup goals include:

* None

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. ,

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Preference for treatment (vs. containment)
Time to design/construct/operate • \ • • -

16. How are measures compared?

RAA-2 was chosen because it treats site contaminants thereby reducing their toxicity mobility
and volume. Treatment was preferred over containment because site contaminants will be
permanently eliminated. The chosen alternative also was preferred because it is the most cost-
effective option. The estimated cost for RAA-2 is comparable to that for RAA-3 but RAA-2
provides greater protection. RAA-2 offers a similar level of protection as RAA-4 but at a
much lower cost. The time to implement was compared between alternatives in the ROD
The selected alternative, RAA-2, would take about 5 to 10 years, RAA-3 only 2 to 3 years but
would not be a permanent remedy, and incineration would take 9 to 87 years. •' i . •'

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? :

Since the site has no subsurface impervious layer, in situ soil flushing could not be
implemented, because it would be difficult to develop a elutriate collection system This
technique could enhance the mobility of contaminants into the ground water. This factor
however, was not primary in selecting a remedy. '
1
356
-6-
-------
First Piedmont Corp. Rock Quarry (Route 719) j

Danville, Virginia
Region 3
GENERAL SITE INFORMATION
/. What were
contaminant
the principal contaminants,
levels, and media addressed in
this feasibility study?

Maximum
contaminants

Soil (mg/kg)

Arsenic •
Barium
Cadmium
Chromium
Lead
Nickel-
^ Vanadium
P Zinc
W/
O • '\A7hsit \if\litwtG

concentrations of principal
were:

135
9,900
34.5
39.5
145
66
23
7,13 , . •
nf -winter-in] FC tn h& r0mp/1iflt0s??.

Site History

NPL Proposed: N/A.
NPL Final: 7/21/87
FS: 1/91
ROD: 6/28/91

Background

PRP-lead
PRPs: First Piedmont Corporation,
Corning Glass Works, and The Goodyear
Tire and Rubber Company
FS prepared by: Westinghouse
Environmental and
Geotechnical Services,
Inc.
i
The volume of material to be remediated included:

• 65,000 cubic yards of industrial and agricultural landfill waste
• 3,000 cubic yards of soil " .
• 100 cubic yards of carbon black
• 10 cubic yards of a separate waste pile , ,
..3. What type of site is this? . i ,
' • ' • . t • ' . , l •
Industrial Landfill. An abandoned rock quarry and associated landfill located in a rural/residential
area. . '! '
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening pf technically feasible
technologies were: . ( , ! '

Access restriction: Fencing, deed restrictions
-1-
357
-------
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Capping (clay, asphalt, concrete, multimedia), grouting
Stabilization/solidification, ion exchange
Incineration
Excavation, disposal (on-site, off-site)
Was an innovative technology considered in the FS? If so, which technology? •

Innovative technologies considered during the identification and screening of technically feasible
technologies were:

Biological treatment: Biological treatment (aerobic, anaerobic)
Phys/Chem treatment: Solvent extraction (soil washing)
6. What was the cost estimate for the innovative technology?

7. How did the cost(s) compare to standard technologies? '

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action
Fencing/deed restrictions/ground water
monitoring
Institutional controls/excavation/off-site
disposal of non-landfill waste/landfill
cap/leachate treatment '
Institutional controls/excavation/
treatment and on-site disposal of non-
landfill waste/landfill cap/leachate
treatment
Institutional controls/excavation/
treatment and either on-site or off-
site disposal of non-landfill waste/
landfill cap/leachate treatment at
POTW
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
9 Criteria
$0
$285,400
$2,120,500
$2,035,000
$2,154,000
358
-2-
-------
Alternative
RAA-6
RAA-7
' F
RAA-8
RAA-9
Standard Technology
Institutional controls/excavation/
treatment and either on-site or off-site
disposal of non-landfill waste/landfill
cap/on-site leachate treatment
Institutional controls/excavation/
treatment and either on-site or off-site
disposal of non-landfill waste/landfill
cap/slurry wall/leachate treatment at
POTW
Institutional controls/excavation/
treatment and either on-site or off-site
disposal of non-landfill waste/consolida-
tion of landfill waste including a liner
and an undei drain system, landfill cap/
leachate treatment on site or at POTW
Institutional controls/excavation/
treatment and on-site or off-site disposal
of non-landfill waste/in situ stabilization
of landfill waste/landfill cap
Estimated Costs
3 Criteria
N/A
-I
I
N/A
1
N)A
•N7A
i
i
9 Criteria
$2,340,000
$1,889,000
$4,450,000
$4,940,000
8. If a standard technology was chosen, why? \ ~ '. • •
' ' I '
RAA-5 was selected because it protects human health and the environment by reducing
contaminant levels through the excavation and treatment of non-landfill waste. Treated waste w,ill
be disposed of in an off-site facility. It will ensure the elimination of exposure due to direct
contact with the landfill wastes, by constructing a RCRA Subtitle C cap over the landfill thereby
meeting RCRA closure requirements. The implementation of deed restrictions to prohibit
residential development of the site will further augment reducing the potential for direct
contaminant exposure. Landfill closure will reduce the likelihood of contaminant migration and
contaminants in the landfill leachate will be reduced by leachate collection and treatment at a
POTW. It will pose no short-term risk or cross-media impacts. Of all the alternatives, RAA-5
provides the best protection of human health without significant adverse impact to the
environment. It complies with all ARARs and will be the most technically feasible to implement.
If an innovative technology was chosen, why?

An innovative technology was not selected.
-3-
359
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10.
If an innovative technology was not chosen, why not? At what stage was the innovative technology
eliminated? "

Innovative technologies eliminated during the initial screening include the following:

• Biological treatment (aerobic, anaerobic) was eliminated because it would not be
applicable to inorganic contaminants.

Innovative technologies eliminated during the screening of the three criteria include the following:

• Solvent extraction (soil washing) was eliminated because it might generate heavy metal
sludge, there would be potential for spills and for contamination to spread, the nature of
the waste would not lend itself to this technology because it employs mixing, and,finally
there is insufficient space on site to stockpile material.

Innovative technologies eliminated during the detailed analysis include the following:

• None
u.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health arid the environment, long-term effectiveness, and short-term
effectiveness were the criteria weighted most heavily in selecting a remedial alternative. RAA-5
was selected because it offers the greatest long-term protection while minimizing short-term risk
and implementation time.
72.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Lead
500
OSWER"
"Office of Solid Waste and Emergency Response (OSWER) Directive 9355.4-02
360
-4-
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13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Time to design/coristruct/operate
- Preference for treatment (vs. containment)
Impact on nearby populations
Risk reduction/protection to human health

16. How are measures compared?

RAA-5 was selected because it offers the greatest protection in the long term while minimizing
short-term risk and implementation time. RAA-1 and RAA-2 were eliminated because they would
not be protective of human health or the environment. RAA-3 arid RAA-4 would not have
provided a permanent solution as they relied on a passive leachate treatment system while the
selected alternative will collect and treat leachate. Furthermore, RAA-5 will allow natural flushing
of water through the landfill which will be collected and treated, thereby ultimately reducing the
time needed for leachate treatment. RAA-5 offers greater long-term effectiveness that RAA-8 and
RAA-9 which reduce but do not eliminate the flow of ground water. The on-site leachate
treatment system proposed in RAA-6, RAA-7, and RAA-8 was not preferred because it y/ould be
in an unmanned location where a malfunction could go undetected. RAA-7, RAA-8, and RAA-9
also were not preferred because they would require landfill excavation which would pose short-
term risk to site workers and the community. RAA-9 would be the most difficult to implement
because it would require the excavation of buried drums prior to treating the landfill waste. RAA-
8 would be too complex to implement because it would be difficult to determine appropriate
engineering controls to prevent the production of contaminated water or sediment that might occur
from precipitation falling into the open face of the landfill during excavation of the landfill.
17. What technical considerations were factors in selecting a remedy? Were technical considerations
primary in the selection of the remedy? .

Technical considerations were not primary in selecting a remedial, alternative.
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361
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Halby Chemical Co.
OU-1

Wilmington, Delaware
Region 3
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels,' and met
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Lagoon Sediment (mg/kg)

Arsenic
Chromium
Pyrene
B enzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
lihants,
addressed in

ncipal

>•

872
170
17,861
5,334
6,051
3,597
3,155
2,337
Site History
NPL Proposed: 9/85
NPL Final: 6/86
FS: 4/91
ROD: 6/28/91
Background

EPA Fund-lead ;
PRPs: Argus Chemical Coiporation,
Witco Corporation, Brandy wine
Chemical Company
FS prepared by: NUS Corporation

2. What volume of material is to be remediated? • •

The volume of material to be remediated included: -

• 10,300 cubic yards of soil3

3. What type of site is this?

Chemicals and Allied Products. An active chemical processing facility in an industrial area.

TECHNOLOGY SELECTION '

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
The proposed plan and feasibility study for OU-1 included the remediation of the contaminated
lagoon sediments. In the RODy EPA decided to defer lagoon sediment to OU-2 to gather more
information regarding tidal and ground water movement in the lagoon.
362
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Access restriction:
Biological treatment:

Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Fencing, deed restrictions, zoning, warning signs ,
Capping (clay, silt, concrete stone clean fill, multilayer RCRA), slurry
wall, grout curtain, sheet piling ,
Stabilization/solidification
Dewatering , ,
mcineration (off-site, on-site) , . j
Excavation, dredging, off-site landfill, on-site landfill
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Composting, bioreactor, in situ'biodegradatiori
Phys/Chem treatment: Soil washing (surfactant), solvent washing, critical fluid extraction, in
situ soil flushing, in situ soil venting v
Thermal treatment: Low-temperature desorption, in situ vitrification, radio frequency
i heating '
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Soil
Alternative
RAA-S-1
RAA-S-2
RAA-S-3
RAA-S-4
Standard Technology
No action/monitoring
Deed restrictions/fencing/monitoring
Asphalt cap/deed restrictions/
monitoring
Surface soil (top 6 inches)
stabilization/asphalt cap
Estimated Costs
3 Criteria
$655,000
$696,000
$Ui88,000
$1,586,000
9 Criteria
$655,000
$696,000
$1,188,000
$1,586,000
-2-
363
-------
Alternative
(RAA-S-4A)"
RAA-S-5
Standard Technology
Stabilize soil above water table with
contaminants in excess of cleanup
levels/asphalt cap
Excavation/off-site disposal
Estimated Costs
3 Criteria
N/A
$5,610,000
9 Criteria
$2,700,000
$5,610,000 "
*RAA-S-4A was developed in the ROD and represents a slight modification of RAA-S-4.

Lagoon sediment0
Alternative
RAA-L-1
RAA-L-2
RAA-L-3
RAA-L-4
RAA-L-5
RAA-1-6
Standard Technology
No action/monitoring
Institutional controls/public awareness/
monitoring
Soil cap
Stabilization/on-site disposal
In situ stabilization
Excavation/off-site disposal
Estimated Costs
3 Criteria
$0
$75,000
$1,266,000
$6,524,000
$3,421,000
$11,233,000
9 Criteria
r$o
$75,000
$1,266,000
eliminated
$3,421,000
$11,233,000
*Lagoon sediment RAAs were developed in the FS but they were hot carried through to the,
ROD. In the ROD, the scope of OU-1 was defined as soil inside the process area and lagoon
sediment was incorporated into OU-2.
8. If a standard technology was chosen, why?

RAA-S-4 was chosen because it reduces the human health risk associated with direct contact
and ingestion of soil and with inhalation of particulates by immobilizing the contaminated soil
and containing the treated soil beneath an asphalt cap. The chosen alternative reduces
contaminant mobility through stabilization, and reduces infiltration and runoff due to rain
water through capping. This alternative reduces site risk to within acceptable levels of 107* to
10'6. Deed restrictions and fencing ensures that the cap is not disturbed, although long-term
maintenance is required. The selected remedy will not require the,process plant to be shut
down and it eliminates site health risk to workers at the Halby Chemical site. RAA-S-4
utilizes proven technologies and will be easily implemented in a relatively short amount of
time. The chosen alternative is cost-effective since it will meet cleanup goals through'
immobilization at much less expense than other proposed alternatives. ;
364
-3-
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J?. , If an innovative technology was chosen, why?
•
An innovative technology was not chosen.

i. '

10. If an innovative technology was not chosen, why not?. At what stage was the innovative
technology eliminated?

• Solvent washing was eliminated because it would not be feasible or effective on
inorganic contaminants. , j
• Critical fluid extraction was eliminated because it would not lie feasible or effective on
inorganic contaminants.
• Low-temperature desorption was eliminated because inorganics would remain in
treated soil.
• Composting was eliminated because it would not be feasible for. inorganics.
• Bioreactor was eliminated because it would not be feasible foir inorganics.
• In situ biodegradation was eliminated because it has limited effectiveness on complex
PAHs and no effectiveness on inorganics.
• In situ soil flushing was eliminated because of the risk of contjaminating ground water.
Also, it would not be feasible due to extended treatment time. ,
• In situ soil venting was eliminated because most PAHs have low vapor pressure; that .
would limit the effectiveness of the technology and inorganics; would not be treated.
• In situ vitrification was eliminated because it would not be feasible at sites with high
water tables.
• Radio frequency heating was eliminated because it would not be feasible due to the
relatively low vapor pressure of site contaminants. ,
1 * .- : • " "' ' "
Innovative technologies eliminated during the screening of the three criteria include the
following: !'.,..
'' - - I /
• Soil washing was eliminated because its effectiveness was fpuitid to be limited in a
treatability study that demonstrated that contaminants were noli removed.

.Innovative technologies eliminated during the detailed analysis include! the following:
i
• • 'None . ' ' • . . ' ' - • '•'.'!'

11. Which of the nine criteria were weighted most heavily in selecting the ^technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria that were most heavily weighted in selecting a remedial alternative were cost and
meeting cleanup levels. The chosen alternative meets cleanup levels for the least possible cost.
Other alternatives would have been more protective since contaminated soil would have been
I
: . , • - I - '- - ' '

4 365
-------
moved off site or soil would have been remediated to greater depths, but these alternatives
were not considered cost-effective.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens .
Arsenic
PAHs
10
1.2
Background8
Background
"No federal or state chemical specific cleanup levels for soil exist; therefore, the
cleanup level for the site was based on background levels. Additional sampling will
be conducted to establish more statistically representative background sample values,
which will be used as the final cleanup levels for arsenic and PAHs.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

» None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies conducted during the RI determined that soil washing would not;be
effective at the site (contaminants were not removed) and that stabilization would be
appropriate for the site's soil. Further treatability studies will be necessary to ensure adequate
immobilization of arsenic. ' • ,
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost/unit risk .
Preference for treatment (vs. containment)
366
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16. How are measures compared? ,
1 "
•!
The chosen alternative was preferred over some alternatives because it both treats and contains
contaminated soil. It was considered superior to RAA-3 because it minimizes risk subsequent
to cap failure. RAA-4 was preferred because it is cost-effective; it meets cleanup levels at the
least cost. While RAA-5 would be more protective since contaminated soil would be moved
off site, this alternative would be much more costly. Similarly, RAA-ftA would be somewhat
more protective since greater depths of contaminated soil would be treated, but it would be
more costly and it was not considered significantly more protective than the chosen alternative
since contaminants would still remain on site. ;

' • • !
i
i
77. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? \
. i
, .if
No technical considerations were primary in the choice of a remedial iilternative. One
innovative technology, in situ vitrification, was eliminated because the water table was too
high.
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367
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Hellertown Manufacturing Co.

Northampton County, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Lagoon area soil (mg/kg)

Trichloroethene 0.56
PAHs 108
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 76,000 cubic yards of lagoon area soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1987
3/89
8/21/91
9/30/91
Background

PRP-lead ,
PRPs: Champion Spark Plug Company
FS prepared by: Environmental
Strategies Corporation
3. What type of site is this?

Electrical Equipment. An inactive spark plug manufacturing facility located in a residential/
commercial area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: • ,
Access restriction:
Containment:
Deed restrictions
Capping, vertical barriers, liners, grout injection, interceptor trench/
collection system
Chemical treatment: Stabilization, encapsulation ' • ' '
Thermal treatment: Incineration (rotary kiln, fluidized bed, multiple hearth)
Disposal: Removal, disposal, excavation
368
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5. Was an innovative technology considered in the FS? If so, which technology?'
I f
Innovative technologies considered during the identification and screening of technically
feasible technologies were: ' I '
I-
Biological treatment: Landfarming, in situ bioremediation, bioremediation in lined beds,
bioremediation in waste piles, bioslurry, biodegradation in general
Physical treatment: Soil vapor extraction, soil washing -' j. -
Thermal treatment: Pyrolysis, thermal desorption
What was the cost estimate for the innovative technology?

RAA designations changed in the ROD area are presented parenthetically.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-5
-
Innovative Technology
Capping/soil vapor extraction
Estimated Costs
3 Criteria
$14,843,000
9 Criteria
eliminated
How did the cost(s) compare to standard technologies? ,
Cost Estimates for RAAs That Include Standard Technologies .
(selected remedial alternative is in bold)
'
Alternative
RAA-A
(RAA-1)
RAA-1
(RAA-2)
RAA-2
(RAA-3)
Standard Technology
No action
Deed restrictions
Deed restrictions/capping
Estimated Costs
3 Criteria
$241,000,
$0
$408,000
9 Criteria
$241,000
$241,000
$408,000
-2-
369
-------
Alternative
RAA-3
RAA-4
RAA-6
RAA-7
(RAA-4)
(RAA-5)
(RAA-6)1
Standard Technology
Capping/upgrade slurry wall
Capping/clay liner
Excavation/stabilization/capping
Excavation/removal/refill to grade
Ground water pumping and treatment
Ground water pumping and treatment
Impermeable cover/surface water
runoff controls/ground water pump
and treat
Estimated Costs
3 Criteria
$650,000
$3,630,000
$5,739,000
$20,069,000
N/A
N/A
N/A
9 Criteria
eliminated
eliminated
eliminated
eliminated
$1,806,700
$1,836,100
$2,250,000
'RAA-6 was developed in the ROD.
5. If a standard technology was chosen, why?

RAA-6, first developed in the ROD, was chosen because it provides the greatest protection to
human health and the environment by addressing both soil and water contamination with an
impermeable cover that reduces the risk due to direct exposure to soil and reduces the mobility
of site contaminants associated with the infiltration of rain water. Additionally, ground water
treatment reduces contaminant toxicity and mobility in ground water. This alternative was
preferred even though the site was determined to pose only low-level risks. RI data showed
that risk due to direct contact with site soil is within EPA's acceptable range. Further, using
Summers model it was concluded that soil contaminant concentrations were not sufficient to
degrade ground water to levels that exceed MCLs. This alternative is consistent with
Superfund program policy of containment rather than treatment for wastes that do not represent
a principal threat at the site and are not highly toxic or mobile in the environment. Long-term
protection can be provided by the cap with proper maintenance. This alternative can be
implemented easily, will not pose short-term risk, and is cost-effective.
9.
If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, .why not? At what stage was the innovative
technology eliminated? ;

• Pyrolysis was eliminated because it would not eliminate all organics and would
produce a char that would require disposal as hazardous waste. Its effectiveness with
soil is unproven, the technique would be expensive and no more effective in
destroying contaminants than incineration.
• Thermal desorption was eliminated because it would be very expensive.
• Bioremediation in general was eliminated because the site has low levels of VOCs and
PAHs and therefore limited substrate for microorganisms to grow. Further, while high
levels of PAHs would be amenable to biodegradation, the degradation of existing low
levels of PAHs would not be assured. , '
• In situ bioremediation was eliminated because its applicability would be limited by the
highly variable quality and chemistry of the fill material, the lack of substrate to
sustain biological growth, the low degradation rates expected for some PAHs, and the
undesirable creation of wet conditions that could cause contaminants to leach into
' ground water. Further, the rate of degradation and the final concentrations achievable
would be impossible to predict.
• Land)'arming was eliminated because the depth of the contaminated material would
require excavation and spreading of materials over the site. This process would be
impractical because space at the site is limited. | '
• Bioremediation in lined beds was eliminated because it would be impractical to
implement on site due to limited space. '
• Bioremediation in waste piles was eliminated because its effectiveness would be
limited by the substrate available for microorganisms, the .time! required to achieve
acceptable concentrations would be difficult to predict, and the technique would be
expensive. Further, lined beds would be constructed below thp ground water table,
possibly requiring dewatering during construction—a process ihat would produce waste
water that would require treatment.
• Bioslurry was eliminated because it would be impossible to implement since a lot of
the contaminated material in the lagoon consists of large objects that can not be
suspended. Further, this treatment requires large amounts of power, must be closely
supervised, and is best suited for fine grained material.
• Soil washing was eliminated because it would be very complex to implement due to
the varied nature of the fill. This technique requires careful management and an
understanding of the side effects on the soil. A washing solution that mobilizes one
contaminant could precipitate, detoxify, or increase the toxicity of another contaminant.
Also, the use of this technology could affect the physical nd chemical properties of the
soil. , . '

Innovative technologies eliminated during the screening of the three criteria include the
following: ;
i
« 'Soil vapor extraction was eliminated because the ability of thiis technology to
significantly reduce YOC levels is questionable since their concentrations already are
low. According to David Hazebrouk, a vendor, reaching low levels of VOCs (below
1,000 ppb) is only "potentially achievable." Further, the technology would not .
address semiyolati.les or metals. Application of the technology would be difficult due
to pockets of impermeable materials prohibiting drilling and voids that would short-
circuit the system. The site sand is not optimal for this technique because its low
permeability clay or silt makes it difficult to blow air through the wells or to remove
air from the soil. Additionally, soil below the water table in the lagoons would require

• '; . • .'•'!''.'
. , . : ' "- .4- . \ • . ' ;
371
-------
ground water removal prior to treatment. The integrity of the cap could be
compromised in the drilling of vapor extraction wells. It would be very costly.
• •'
Innovative technologies eliminated during the detailed analysis include the following:

* None
11. ^hich of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criterion that was weighted most heavily in selecting a remedial alternative was protection
of human health and the environment. The chosen alternative was the only alternative that
addressed both soil and ground water concerns. Even though soil was determined to be only a
low-level threat to both humans and the environment and it would not lead to the
contamination of ground water above MCLs, the remediation of soil was preferred.

Soil vapor extraction was eliminated because it would be difficult to implement, it is :
expensive, and its effectiveness is uncertain.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No chemical-specific cleanup goals were established for soil. The RI data indicates that fAfe
contaminants in site soil are within EPA's acceptable incremental individual lifetime cancer ^^
risk of W4 to 10'6 based on direct dermal contact and ingestion.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None :

Standard technologies eliminated because of cleanup goals include:

• None •

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
372
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15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
16. How are measures compared? \- . ~

The chosen alternative was preferred because it provides the greatest level of overall protection
since it addresses both soil and ground water. Other alternatives wen? directed at either soil or
water.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
\ .
• . • •, |, •
The low permeability and high moisture content of the site's soil was; a consideration that lead
to the elimination of soil vapor extraction. This technical consideration was not primary in
selecting a remedial alternative. .
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Industrial Lane
OU-2

Williams Township, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study ?

Maximum concentrations of principal
contaminants were:

No principal threats, such as hot spot areas
of highly toxic or highly mobile wastes,
were found in conjunction with the site. The
principal exposure pathway, ingestion and
inhalation of volatile organic compounds
(VOCs) in contaminated ground water, was
addressed by OU-1. OU-2 addresses the
contaminated ground water and the
relatively low-level threat caused by the
unlined municipal landfill.
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1983
1984
8/86
3/29/91
Background

EPA Fund-lead >.
PRPs: PRPs 'are not discussed in the FS
or the ROD .
FS prepared by: NUS Corporation
2. What volume of material is to be remediated?

The volume of material to be remediated included: *

» The estimated total volume of the waste in the landfill is 3 million cubic yards

3. What type of site is this?
' ' i

Municipal Landfill. An inactive unlined sanitary landfill (Chrin Brothers landfill). The site
encompasses 30 acres. The area around the site is currently used for industrial, residential, and
limited agricultural purposes.
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
374
Access restriction: Monitoring
-------
Containment:

Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Capping (synthetic membrane, clay, soil, multimesdia, asphalt, concrete,
chemical sealants), collection /
Solidification/fixation
Grading and revegetation
Incineration
Excavation, RCRA facility (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Bioreclamation
Chemical treatment: Soil flushing , •/
What was the cost estimate for the innovative technology? |

Innovative technologies were not incorporated into the RAAs.
7. How did the cost(s) compare to standard technologies?
i
• ' Cost Estimates for RAAs That Include Standard Technoiogies
(selected remedial alternative is in bold)

Focused PS/Landfill Waste '.'.!'
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
No action/monitoring
-Multilayer soil cap (clay)
Estimated Costs
4 Criteria
$0
$663,000.
$6,354,000
-2-
375
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ROD/Landfill Waste
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-4
Landfill
Closure'
Innovative Technology
No action
Access restrictions/monitoring
Extraction/treatment/discharge of
ground water to Lehigh River
Extraction/discharge of ground water to
POTW
Extraction/treatment/reinjection of
ground water .
Municipal landfill cap (clay)
Estimated Costs
ROD
$2,027,000
v $2,027,000
$12,775,000
(not including
landfill closure
costs)
$44,318,000
, (not including
landfill closure
costs)
$11,937,000
(not including
landfill closure
costs)
$8,000,000
(capital costs only)
"Pennsylvania Department of Environmental Resources (PADER) notified the owner and
operator of the Chrin Brothers Landfill in a letter dated 11/23/90 that the unlined landfill area
must be closed according to Chapters 271 and 273 of the Pennsylvania Municipal Waste
Management Regulations. The state closure requirements, estimated to cost
$8 million, were integrated into the development and evaluation of the remedial alternatives
for the site.

8. If a standard technology was chosen, why?

A low-permeability cap was chosen for the Chrin Brothers Landfill because it will significantly
reduce the amount of leachate emanating from the facility. The landfill, however, will
continue to generate small quantities of leachate, which could act as a continuous source, of
ground water contamination. The remedy for OU-2, therefore, proposes ground water
treatment in addition to capping. The primary remedy for the site (OU-1) and the contingency
measures afforded by closure of the unlined landfill and by ground water extraction and
treatment, provide overall protection of human health and the environment, either by reducing
contaminants to remediation goals, or through a combination of mass reduction, and
institutional and engineering controls. The cap complies with all ARARs for the site. The
municipal landfill poses a relatively low level threat, and is therefore to be closed in
accordance with Chapters 271 and 273 of the Pennsylvania Municipal Waste Management
Regulations, including a cap. In addition, the advantages of using a soil cap over other types
of caps include the availability of the material at the site, ease of construction and
maintenance, and lower cost. The construction methods involved in capping the landfill
376
-3-
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employ standard engineering practice and construction procedures commonly used on
earthwork projects. .
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ' . (

This site has a focused feasibility study, which does not include the usual three-criteria and
nine-criteria stages of evaluation. The innovative technologies considered were eliminated
during an initial screening process.

Innovative technologies eliminated during the initial screening include the following:

• Bioreclamation and soil flushing were eliminated because they are feasible only for
landfills with liners and a leachate collection system at the bottom of the landfill. If
there is no bottom containment, the process could accelerate [the rate of ground water
contamination.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None .•',;'.• ' •

Innovative technologies eliminated during the detailed analysis include the following:

• None •' ' -I . "..
11.
12.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to mee,t one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
The selection of a cap for the Chrin Brothers Landfill was made
Protection of human health and the environment,was the most
selecting a cap. The selected remedy provides adequate protection
environment through closure of the unlined landfill.
before this ROD was issued.
heavi! y weighted criterion in
human health and the
cfl
What cleanup goals were selected? If the cleanup goal was based en an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels were not developed for the landfill waste.

4 377
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard \
technology meet tn^ cleanup goals? • —'

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives? •'•_•'-

The following measures were used to compare the alternatives:

Risk level achieved
Cost-effectiveness , -
Proven reliability

16. How are measures compared?

The selected alternative provides the greatest 'protection of human health and the environment
through a combination of mass contaminant reduction, and institutional and engineering
controls. The chosen remedy also affords overall effectiveness proportionate to its costs and is
therefore cost-effective. Capping was the preferred remedial action for the landfill because
standard engineering practices and construction procedures commonly used on earthwork
projects are used. : •

17. What technical considerations were factors in selecting a remedy? Were technical "
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a cap for the Chrin Brothers Landfill.
>
378
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Letterkenny Army Depot (Southeast Area)
OU-1

Chambersburg, Pennsylvania
Region 3
GENERAL SITE INFORMATION
L.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

Trichloroethylene
Trans-1,2-dichloroethy lene
779
131
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/1/84
7/1/87
8/90
8/2/91
Background
Federal Facility
PRP: U.S. Army Corps of Engineers
FS prepared by: U.S. Army Toxic and
Hazardous Materials Agency
2. What volume of material is to be
remediated?
• -
The volume of material to be remediated
included:

• 8,000 cubic yards'of soil
3. What type of site is this? .

Military.. An active U.S. Army depot.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Limit access, use restrictions, relocation, permanent relocation
Synthetic membrane, capping (clay, asphalt, multimedia, concrete/
chemical sealant, single-layered soil), slurry walls, grout curtain, sheet
piling, membrane wall, dewatering, soil aeration, in situ volatilization
Chemical treatment: Fixation/encapsulation !
Thermal treatment: High-temperature incineration, low-temperature incineration,
thermoplastic solidification, flaming/flashing
Disposal: Excavation, landfilling - i
-1-
379
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: , .

Biological treatment: Microbial degradation, soil aeration (landfarming)
Phys/Chem treatment: In situ soil aeration (SVE), solution mining (soil flushing), soil
washing
Thermal treatment: Low-temperature thermal decomposition, in situ vitrification
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3A
RAA-3C
RAA-4A
RAA-4B
Innovative Technology
In situ volatilization (SVE)
Excavate/mechanically aerate (land-
farming to volatilize contaminants
Excavate/low-temperature thermal
decomposition
Excavate/soil washing
Estimated Costs
3 Criteria
$191,000
$1,103,000
$1,539,000
$3,878,000
9 Criteria
eliminated
eliminated
$1,539,191
eliminated
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1A
Standard Technology
No action/long-term ground water
monitoring only , .
Estimated Costs
3 Criteria
$191,000
9 Criteria
$143,434
380
-2-
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- Alternative
RAA-1B
RAA-2A
RAA-2B
RAA-2C
RAA-3D
RAA-3E

Standard Technology
No action/long-term ground water
monitoring/institutional and land use
controls
Synthetic membrane cap
Clay cap
Multimedia cap
Excavate/on-site high-temperature
incineration
Excavate/off-site high-temperature
incineration
- Estimate!
3 Criteria
$191,000
i ' •
.•
$202,000
$210,000
$254,000
$4,235,000
.
$20,688,000
;
I Costs
9 Criteria
$143,434
eliminated
eliminated
$254,150
$4,235,191
eliminated
10.
8. If a standard technology was chosen, why?

A standard technology was not chosen.
i
9. If an innovative technology was chosen, why?
' - i '
Low-temperature thermal decomposition, RAA-4A, was chosen because it provides good long-
term protectiveness; achieves ARARs; permanently and significantly reduces toxicity, mobility,,
and volume; provides short-term effectiveness; and provides maximum long-term effectiveness
and permanence through destruction of nearly all the VOC contaminants in the soil. It is less
costly than incineration; has proven effective in a pilot-scale field test; has no associated O&M
costs; takes less time to implement than incineration; satisfies the statutory preference for
treatment; Utilizes an innovative technology to the maximum extent practicable; utilizes known
technologies for which the necessary equipment and expertise is readily available; and reduces
risk associated with groundwater exposures.
RAA-1A and RAA-1B were eliminated because they would not protect
environment. RAA-2A, RAA-2B, RAA-3A, RAA-3C, and RAA-4B
they would not meet ARARs. RAA-3E was eliminated because it
without providing additional benefit. RAA-2C was eliminated because
containment and not treatment.
If an innovative technology was not chosen, why not? At what stage
technology eliminated? .
human health or the
were eliminated because
would be unduly expensive
it only would provide
was the innovative
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
-3-
381
-------
Innovative technologies eliminated during the initial screening include the following:!

• Microbial degradation was eliminated because it had not been demonstrated on a full
scale, and extensive testing would be required to determine its feasibility.
» Solution mining (soil flushing) was eliminated because it had not been demonstrated
on a full scale, and extensive testing would be required to determine its feasibility.
• In situ vitrification was eliminated because it was not applicable for chlorinated VOCs.

Innovative technologies eliminated during the screening of the three criteria include the
following:

" In situ volatilization (RAA-3A) was eliminated because it would not meet the cleanup
objectives as demonstrated by a 1989 pilot study. Soil permeability was too low.
• Soil aeration (landfarming) (RAA 3C) was eliminated because it will not meet
response objectives; only 76-79% removal is achievable. .
• Soil washing (RAA-4B) was eliminated because it would not be as effective as other
alternatives, and some development would be required to implement.

Innovative technologies eliminated during the detailed analysis include the following:

• None
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The ROD states (p. 40) that short-term effectiveness and reduction of TMV were regarded as
the most decisive factors in the selection process. However, cost-effectiveness also appeared
to be heavily weighted. Incineration and low-temperature thermal treatment both met all other
criteria, but low-temperature thermal treatment was much less expensive ($1 539 191 vs
$4,235,191).
12. Wfiat cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Carcinogens
Trichloroethylene
Contaminant Cleanup Level (mg/kg)
ARAR or Other Basis
0.225
MCL
In Pennsylvania, soils must be cleaned to the extent necessary to meet the background ground
water cleanup requirements. The ARAR for soil cleanup was developed based on the
Maximum Contaminant Level (MCL) and the soil-to-ground water ratio observed at the site.
For trichloroethylene, the MCL was 5 u/L and the ratio of concentration of soil to ground
water was 45 to 1. The acceptable soil cleanup level developed was 225 ug/kg (45 x 5 u/L)
or 0.225 mg/kg. ,
382
-4.
-------
For carcinogens, an excess upper bound individual lifetime cancer risk
was acceptable. For noncarcinogens, a Hazard Index less than or e
equal
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• In situ volatilization
• Soil aeration (landfarming)

Standard treatment technologies eliminated because of cleanup goals include:

• . None
14. Were treatability.studies conducted on the innovative technology or standard technology?
Two innovative technologies were tested. Pilot scale testing of soils
using low-temperature thermal decomposition. The results indicated
for the site. In situ volatilization would 'not meet the response objecti
1989 pilot study. .''..'.
: of between KT1 to lO'6
to 1.0 was acceptable.
was conducted at the site
(hat it would be suitable
ives as demonstrated by a
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cleanup goal . •'. ,
Preference for treatment (vs. containment)
Cost-effectiveness
Proven reliability '

16. How are measures compared?

The chosen alternative provides a high degree of effectiveness and permanence through
treatment, which was preferred to containment. In addition, pilot studies proved that low
temperature thermal treatment could be reliable and achieve the cleanup levels. One other
alternative (on-site incineration) wa.s similarly effective, but it was almost three times as
expensive, so the chosen alternative also was cost-effective.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? \
" : ' • S , .

Technical considerations were not primary in selecting a remedy. The most important
technical consideration was that metals were not migrating into the glroundwater, probably due
to the retentive properties of the clayey soils with respect to metals. Therefore, source control
remedies were hot needed for remediating metals.
-5-
383
-------
Alternatives involving use of physical barriers were eliminated because the bedrock to which j^
thr barriers would be affixed was composed of porous limestone. Several technologies were, I^P "*)}
ni applicable to chlorinated VOCs or did not apply to unsaturated soils. Three cap materials ~~~^
were eliminated because they were susceptible to degradation by VOCs and freezing and
thawing stresses.
384
-6-
-------
Lindane Dump
Harrison Township, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
' -s

Surface Soil/Subsurface Materials (mg/kg)
Alpha-BHC
Beta-BHC
Gamma-BHC
Delta-BHC
4,4-DDT
4,4-DDE
4,4-DDD
•Phenol
Arsenic
•f
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
517
1.3
206
296
236
2
3.6
6
37
1,380
707
1,220
1.5
11,800
5 -
3,680
NPL Proposed:
NPL Final:
FS:
ROD:
Site History
10/81
9/83
2/92
3/12/92
Background
PRP-lead
PRPs: Elf Atocheni North America, Inc.
FS prepared by: Eckenfelder
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 1.2 million cubic yards of waste
3. What type of site is this?

Industrial Landfill. A former industrial waste disposal area located in an industrial area.
-1-
385
-------
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically, feasible
technologies were:

Surficial Soil

Access restriction: Fencing, deed restrictions ,
Containment: Capping (clay, soil, revegetation, asphalt, concrete, multilayer),
grading, surface water diversion
Thermal treatment: Incineration (rotary kiln, fluidized bed, infrared)
Disposal: Excavation, on-site disposal in RCRA permitted cell, off-site disposal
in RCRA landfill

Subsurface Materials

Access restriction: Fencing, deed restrictions
Containment: Capping (clay, soil, asphalt, concrete, multilayer), grading, surface
water diversion
Chemical treatment: Stabilization/solidification, grout injection, soil mixing
Physical treatment: Dewatering
Thermal treatment: Incineration (rotary kiln, fluidized bed, infrared)
Disposal: Excavation, on-site disposal in RCRA permitted cell, off-site disposal
in RCRA landfill

5. Was an innovative technology considered in the FS? If so, which technology? -,

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Surficial Soil

Biological treatment: Slurry-phase biodegradation, solid-phase biodegradation, composting
Chemical treatment: Critical fluid solvent extraction, Basic Extraction Sludge Treatment,
soil washing, glycolate dechlorination,
Thermal treatment: Pyrolysis, vitrification, pyrolytic centrifugal reactor

Subsurface Materials

Biological treatment: In situ biodegradation, composting, slurry phase biodegradation, solid-
phase biodegradation
Chemical treatment: In situ soil flushing (surfactant), Basic Extraction Sludge Treatment,
critical fluid solvent extraction, soil washing, glycolate dechlorination
Thermal treatment: In situ vitrification, pyrolysis, vitrification, pyrolytic centrifugal reactor
386
-2-
-------
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the fprmulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP: long-term effectiveness and peirmanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; and community acceptance.
i •
Alternatives renumbered in the Proposed Plan and the ROD are presented parenthetically.

No innovative technologies were incorporated into remedial alternatives.
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
RAA-8A
RAA-8B
RAA-9A
(RAA-2)

Standard Technology
No action/long-term monitoring
Limited action
Excavation/on-site disposal
Excavation/off-site disposal
Excavation/on-site incineration/on-site
disposal
Excavation/on-site ihcineration/off-site
disposal
Excavation/off-site incineration/off-site
disposal
Topsoil and vegetative cover
Topsoil and vegetative cover/ground
water extraction and discharge
Clay and soil cap/upgraded leachate
collection and treatment/deed and access
restrictions/ground water monitoring
Estimated Costs
3 Criteria
N/A -
N/A
N/A
N/A
N/A
-
IN/A
IN/A
IN/A
IN/A .
. i
'
JN/A
/ -i, ,
9 Criteria
$2,262,500
eliminated
eliminated
eliminated
eliminated
eliminated
eliminated
eliminated
eliminated
$14,146,000
-3-
387
-------
Alternative
RAA-9B
(RAA-3)
RAA-10A
(RAA-4)
RAA-10B
(RAA-5)
(RAA-6)'
Standard Technology
Clay and soil cap/upgraded leachate
collection and treatment/deed and access
restrictions/ground water extraction and
discharge/ground water monitoring
Multilayer cap/upgraded leachate
collection and treatment/deed, and access
restrictions/ground water monitoring
Multilayer cap/upgraded leachate
collection and treatment/deed and access
restrictions/ground water monitoring/
ground water extraction and discharge
Combination multilayer and clay and
soil cap/upgraded leachate collection
and treatment/deed and access
restrictions/ground water monitoring /
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$15,136,500
$14,114,600
$15,105,100
$14,122,500
* This RAA was first presented in the Proposed Plan.

8. If a standard technology was chosen, why?

The chosen alternative was not developed in the FS, but was first presented in the Proposed
Plan. This alternative represents a combination of RAA-9A and RAA-10A. It was developed
because of a concern that a multilayer cap could not be constructed over the site's .steep side
slopes. This alternative proposes a clay cap for areas where slope stability might impede
placement of a multilayer cap and a multilayer cap over the rest of the site. This alternative
was chosen because it will reduce the infiltration of water through the fill area and thereby
reduce the mobility of contaminants through the fill to the aquifer. In turn, such reduced
mobility will help eliminate the current ground water and seeps MCL violations. The cap will
eliminate the potential exposures to site contaminants that could be in the surface or subsurface
soils. The multilayer cap was preferred over the soil cap, where feasible, because of its lower
permeability and additional protection against infiltration. An additional 14-percent reduction
in infiltration would be provided by the multilayer cap, according to estimates. The multilayer
cap also was considered superior to the clay cap because it offers greater long-term
effectiveness and permanence. The multilayer cap is less susceptible to failure in the long-
term because it provides multiple defenses. Materials needed to produce a multilayer cap are
readily available and the technology can be easily implemented.
9.
If an innovative technology was chosen, why?

An innovative technology was not chosen.
388
-4-
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10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? * -

Innovative technologies eliminated during the initial screening include the following:

Surface Soil !..."'"'

• Pyrolysis was eliminated because the technology has not been fully developed and
would be ineffective for inorganic waste constituents. ,
1 •- Vitrification was eliminated because the technology has not been fully developed.
• Pyrolytic centrifugal reactor was eliminated because the,technology has not been fully
developed. , • !
• Basic Extraction Sludge Treatment was eliminated because it has riot been used to treat
soils and would be ineffective for inorganic waste constituents.
• Critical fluid solvent extraction was eliminated because it would be ineffective for >
inorganics and it has not been demonstrated on a large scale ifor wastewater sludges.
• Soil washing was eliminated because the technology has not been fully developed for
site constituents.
• ' Glycolate dechlorination was eliminated because its effectiveness has not been
demonstrated and it would be ineffective for inorganics. |
• Composting was eliminated because the waste material is heterogenous and not all
biodegradable. j ,
» Slurry phase biodegradation was eliminated because the was! e material is
heterogeneous and not all biodegradable.
• Solid-phase biodegradation.was eliminated because inorganic: constituents and some
organic ones are not biodegradable.
I • ' - • .
Subsurface Material .

• In situ vitrification was eliminated because it would not be suited for loosely packed
rubbish or coal, the contaminant depth is too great for implementation, and waste is
present below the water table.
• In situ soil flushing was eliminated because subsurface soils are not conductive enough
for flushing. i '
• In situ biodegradation was eliminated because waste materials are heterogeneous,
many of them are not biodegradable, and the waste materials exhibit low hydraulic
conductivity. . j '
.' • . Pyrolysis was eliminated because the technology has not been fully developed.
• Vitrification was eliminated because the technology has not been fully developed.
• Pyrolytic centrifugal reactor was eliminated because the technology has not been fully
developed.
• Basic Extraction Sludge Treatment was eliminated because it treats primarily sludge,
site wastes are heterogeneous, and it would be ineffective for inorganics.
• Critical fluid solvent extraction was eliminated because it would be ineffective for
inorganics. : . .
• Soil washing was; eliminated because the technology has not been fully developed for
site constituents, and waste materials are heterogeneous:
.•.j.

•' '' "'" - "-5--' . ; • ' -I" • •- '• •- -'389
-------
" Glycolate dechlorination was eliminated because its effectiveness has not been
demonstrated and waste materials are heterogeneous.
» Composting was eliminated because waste materials are heterogeneous and many of
them are not biodegradable.
» Slurry-phase biodegradation was eliminated because waste materials are heterogeneous
and many of them are not biodegradable. ,
» Solid-phase biodegradation was eliminated because the inorganic and some of the
organic constituents are not biodegradable. ' .

Innovative technologies eliminated during the screening of the three criteria include the
following: , , .

" None

Innovative technologies eliminated during the detailed analysis include the following:

• None
12.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

The protection of human-health and the environment and implementability were the most
heavily weighted criteria in selecting^ remedial alternative. The multilayer cap was preferred
over the clay cap because it would greatly reduce infiltration of the waste and thereby reduce
the mobility of contaminants to the aquifer. Because the multilayer cap could not be
implemented over the site's steep side slopes, a clay cap had to be incorporated into the
remedial alternative. ,

No innovative technologies were eliminated based on these criteria.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No cleanup levels were established for soil. The remedial action is intended to prevent site
contaminants from infiltrating the ground water.

Health risk assessment analyses determined that under the worst case scenario, the greatest
cancer risk value at the site is within EPA acceptable risk levels of lO"4 to 10'6.
*.*
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None
390
-6-
-------
Standard technologies eliminated because of cleanup goals include:

» None :

14. Were treatability studies conducted on the innovative technology or standard technology?
•
No treatability studies were conducted. '

i , '

15. What measures/criteria were used to compare alternatives? i
. i
The following measures were used to compare the alternatives: !

- Reduction of contaminant mobility
Long-term effectiveness

i' • •'
16. How are measures compared? '.I

Source control options included a multilayer cap and a clay cap. The multilayer cap was
preferred over the clay cap because.it is less permeable to precipitation;and therefore is more
effective at reducing contaminant mobility. The multilayer cap also wals preferred because it is
less susceptible to breakdown in the long term.
1
.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? i
' - ' I
In some areas of the site, steep side slopes precluded the use of a multilayer cap; a clay cap
will be implemented in these instances. This site condition was primary in selecting a
remedial alternative since a multilayer cap for the entire site would have been preferred.
-7-
391
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Mid-Atlantic Wood Preservers, Inc.

Harmans, Maryland
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Arsenic 1,200
Hexavalent Chromium * 0.7
Total chromium 865
Copper , 1,280
2. What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/84
5/86
7/20/90
12/31/90
Background

PRP-lead
PRPs: Mid-Atlantic Wood Preservers
FS prepared by: Dames & Moore
The volume of material to be remediated included:

• 5,200 cubic yards of soil
3. What type of site is this?

Lumber and Wood Products. An active wood treating facility located in a mixed industrial/
residential area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
392
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Fencing, land use restrictions
Capping (clay, synthetic), paving, graveling
Stabilization/solidification
Incineration
Excavation, disposal (on-site, off-site)
-1-
-------
5. Was an innovative technology considered in the FS? Ifso> which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation
Chemical treatment: Solvent washing, solution mining
Thermal treatment: Wet air oxidation, vitrification •
What was the cost estimate for the innovative technology?
• -. | •'.'•"
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated asf part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that;merit a more detailed
evaluation. In this case, the estimated costs were calculated during ari evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or Volume; implementability; cost; state/support
agency acceptance; and community acceptance.

No innovative technologies were incorporated into remedial alternatives.
How did the cost(s) compare to standard technologies?
i
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) ,
Alternative
RAA-1
RAA-2
RAA-3
RAA-3A"
Standard Technology
No action/long-term monitoring
Cover soil treatment yard with gravel/
cover storage yard soil with geotextile
and gravel/construct drip pad/natural
attenuation of ground water/long-term
monitoring '
Pave soil with asphalt/construct drip
pad/natural attenuation of ground
water/long-term monitoring
Excavation/stabilization of hot spots
with arsenic in concentrations greater
than 1000 mg/kg/asphalt concrete cap
over soil with 10 to 1000 rug/kg
arsenic/construct drip pad/natural
attenuation of ground water/long-
term monitoring
Estimated Costs
3 Criteria
N/A
N/A
1
1
N/A
i
N/A,
•
.•
- f
9 Criteria
$45,000 .
$318,000
$312,200
$322,600
-2-
393
-------
Alternative
RAA-4
RAA-5
Standard Technology
Excavation/stabilization-solidification/
off-site disposal at RCRA facility
Excavation/stabilization-solidification/
regrade site/construct drip pad/natural
attenuation of ground water/long-term
monitoring
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$2,750,000
$1,080,000
•RAA-3A was developed for the ROD.
8. If a standard technology was chosen, why?
' t • :
The chosen alternative, RAA-3A, was first presented in the ROD. It represents a modification
of RAA-3 which was the preferred alternative in the Proposed Plan. RAA-3A was modified to
include the excavation, stabilization, and disposal of highly contaminated "hot spots" that are
defined as soil with arsenic concentrations in excess of 1000 mg/kg. Soil with arsenic
concentrations between 10 to 1000 mg/kg will remain in place and be capped. This alternative
was preferred because it ensures a greater reduction of site contaminant toxicity and mobility.
Additionally, it improves long-term effectiveness and permanence more than RAA-3. The
chosen alternative will reduce site risks to 10'5. The construction of a cap will eliminate risks
due to direct contact with soil or inhalation of contaminated dust. The preferred alternative
minimizes short-term risk to workers and nearby residents because it only requires the
excavation of small volumes of soil or "hot spots." Because .arsenic and hexavalent chromium
are naturally bound to soil particles, excavation of all site soil was not expected to-greatly
improve site risks. The preferred alternative can be implemented in the shortest amount of
time (3 to 6 months) and it is the least difficult of the treatment alternatives to implement. It
is cost-effective.
9. If an innovative technology was chosen, why?

No innovative technology was chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Solvent washing (extraction) was eliminated because it likely would not be efficient
enough to reduce soil metals to acceptable levels, metals are tightly absorbed to soil.
394
-3-
-------
11.
12,
13.
• Solution mining (soil flushing) was eliminated because the administration of strong
acids to leach heavy metals could cause the migration of contaminants, reduce ground
water pH, and increase environmental risk.
• Biodegradatipn was eliminated because it would not be effective for heavy metals.
• Wet air oxidation was eliminated because it would not be effective for heavy metals.
• Vitrification was eliminated because it is unproved, expensive, and generally
unavailable. v

Innovative technologies eliminated during the screening of the three criteria include the
following:
None
Innovative technologies eliminated during the detailed analysis include the following:
None
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
i '. '
.
The most heavily weighted criteria in selecting a remedial technology were implementability,
short-term effectiveness, and cost. The chosen alternative was prefeired over somewhat more
protective alternatives, such as RAA-4 and RAA-5, because they would not be cost-effective.
Further, these two alternatives would be more difficult to implement and pose greater short-
term risks because they require excavating large volumes of soil.

No innovative technologies were eliminated for these reasons.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR?
-------
' Standard technologies eliminated because of cleanup goals include:

• Soil cover
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Preference for treatment (vs. containment)
Impact on nearby populations
16. How are measures compared?

The chosen alternative, RAA-3A, was preferred because it treats the highly contaminated soil.
Treatment of the Highly contaminated soils was preferred over containment (RAA-3) because it
ensures the reduction of contaminant toxicity and mobility. Two alternatives that would have
offered more protection through the treatment or removal of all site soil were not chosen
because they would be more expensive. Because site contaminants are not very mobile in soil,
the benefits of these alternatives were not considered to be significantly greater than the
chosen alternative. These alternatives were, therefore, not cost-effective. These alternatives
also would require excavating large volumes of soil while the chosen alternative would only
require excavating hot spots. In addition, they would be more difficult to implement and they
would pose a greater short-term risk to nearby populations.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The absorption of site contaminants to soil was primary in selecting a remedial technology.
The chosen alternative was deemed protective enough because it treats contaminant hot spots.
Other alternatives that would treat all site soil were not considered to offer much greater "
protection because the contaminants were tightly bound to soil and therefore not very mobile.
Further, one innovative technology, soil washing, was eliminated because it might not be
effective for contaminants tightly absorbed to soil.
396
-5-
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Modern Sanitation Landfill
York County, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

The landfill wastes were not sampled and
analyzed.

During the RI process ground water
contamination was found to emanate from
the unlined portion of the landfill. Ground
water contaminants of concern include:

Benzene
Chloroform
Dichlorobenzene
Carbon tetrachloride
1,4-dichlorobenzene
1,1-dichloroethane
1,2-dichloroethane
Trans-1,2-dichloroethene
Methyl chloride
Trichloroethane
1,1-dichloroethene^ ,
1,2-dichloroethene
Tetrachloroethene
Vinyl chloride
Site History
NPL Proposed:
NPLFihal:
FS:
ROD:
10/84
6/86
5/10/91
6/28/91
Background
i .
PRP-lead . j •
PRPs: Modern Trjash Removal of York,
Incorporated
FS prepared by: ICF Technology and
Golder Asisociates
3.
What volume of material is to be remediated?

The volume of material to be remediated included:
The FS and ROD do not state the volume of waste material contained in the landfill.
The landfill covers 362 acres.
What type of site is this?

Municipal Landfill. An active municipal and non-hazardous industrial waste landfill located in
a primarily residential and agricultural area.
-1-
397
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction; Fencing, ordinances
Containment: Capping (clay, synthetic membrane, low permeability) slurry wall,
grout curtain
Disposal: Excavation, disposal off-site

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically '
feasible technologies were: " •

Biological treatment: In situ biodegradation
Physical treatment: Vapor extraction
Thermal treatment: In situ vitrification
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
398
Alternative
RAA-2A
RAA-2B
RAA-2C
Innovative Technology
Maintain current methane extraction
system
Maintain current methane extraction
system/cap
Maintain current methane extraction
system/augment ground water
extraction system/cap
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$16,963,500
$17,947,000
$3,509,000
-2-
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for FAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology
No action/cease current extraction
system/monitoring
Estimated Costs
3 Criteria
N/A
I -
9 Criteria
$3,398,000
I
8. If a standard technology was chosen, why?
•''..• ' '
A cap was chosen. The chosen alternative, RAA-2C, was preferred bfecause it .provides the
greatest protection of all the proposed alternatives. The chosen alternative reduces 'site risk by
eliminating direct exposure to site contaminants and reducing the mobility of site contaminants
responsible for contaminating ground water. The completion of the hpdfill. cover system will
reduce the infiltration of precipitation into the landfill, thereby reducing die generation and
mobilization of contaminants to ground water and leachate.
.' \

9. Ij'an innovative technology was chosen, why?

This alternative maintains all currently existing vapor and ground water extraction systems.
Also, the ground water extraction system will be augmented. This alternative reduces the
greatest volume of leachate constituents through both vapor and ground water extraction
technologies. Both the vapor extraction system and the augmented ground water extraction
system will reduce the mobility of contaminants in the shortest timeftame. The chosen
alternative is reliable, relatively simple to operate, and easy to implement. This alternative is
cost-effective. ,
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the screening of the three criteria include the
following:

B None .... •

Innovative technologies eliminated during the detailed analysis include the following:

• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted criteria in selecting a remedial technology were protection of
human health and the environment and the reduction of contaminants. This alternative offers
the greatest protection of all the proposed alternatives since it reduces site contaminant
exposures through both treatment and containment.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

' No cleanup levels were established for soil.
13. W™ the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include;

• None r ' •

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

400
-4- . - ;
-------
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Time to design/construct/operate

16. How are measures compared?
17.
The chosen alternative was preferred because, of all of the proposed
the greatest risk reduction through containment and treatment. It also
the shortest amount of time.
What technical considerations were factors in selecting a remedy?
considerations primary in the selection of the remedy?
No technical considerations were primary in selecting a remedial alternative
Reference:
alternatives, it provides
will reduce site risks hi
Were technical
Berwanger, D., and J. Backer. 1988. Aerobic Biodegradation of Aromatic and Chlorinated
, Hydrocarbons Commonly Detected in Landfill Leachate. Water Pollution Restoration Journal
of Canada. 23(3):460-475. .
-5-
401
-------
Old City of York Landfill

Springfield Township, Pennsylvania
Region 3
GENERAL SITE INFORMATION
L
nnai were me principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:

Refuse-Soil Cover (mg/kg)
Pesticides 0.014
PCB Arochlor 1260 2.1
SVOC (total) 1.2
Refuse-Deep Boring (mg/kg)
Lead 1,930
O*i
Sliver 15.9
Total VOCs 26.8
Note: 27 SVOCs "typically associated with

Site History
NPL Proposed: N/A
NPL Final: 12/82
FS: 9/16/91
ROD: 9/30/91

Background
PRP-lead
PRPs: City of York, Rite-Way Services,
and Alleco, Inc. (on behalf of
The Macke Company and Service
America Corporation)
FS prepared by: Groundwater
Technology, Inc.

municipal landfill refuse" also were detected
in deep soil borings.
Vault Sediments (mg/kg)

Acetone
Chlorobenzene
Di-n-butylphthalate
Benzoic acid
bis(2-ethylhexyl) phthalate
Iron
Lead
0.0002
0.00007
0.014
0.0013
0.001
453
0.0381
Note: Stream sediments and deep sediments also were analyzed, but no cleanup actions were
implemented for these media.
2.
402
What volume of material is to be remediated?

The volume of material to be remediated included:

• 1,120 cubic feet of vault sediment
• 1.7 million cubic yards of refuse
-1-
-------
3.
What type,of site is this?
Municipal Landfill. The site is an unused landfill located in a rural area. The landfill was
used mainly for municipal solid waste, with some disposal of commeircial and industrial
wastes. The land use around the site is primarily farmland and woodlands.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

General Response (applicable to refuse and vault sediments)
Access restriction:
Containment:
Refuse

Physical/chemical:
Thermal treatment:
Disposal:

Vault Sediments

Physical/chemical:

Thermal treatment:
Disposal:
Institutional actions (deed restrictions, access restrictions)
Cap (asphalt, concrete, synthetic membrane, soil, multilayer), vertical
barriers (slurry wall, grout curtains, sheet piles), horizontal barriers
(bottom sealing)
Stabilization/solidification j
On-site incineration, off-site incineration I
Complete removal, partial removal, off-site disposal
Dewatering (centrifugation, gravity thickening, filtration, evaporation),
stabilization/solidification (cement, pozzolan) |
On-site incineration, off-site incineration ]
Complete removal, on-site disposal, off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Refuse j
• " .- [ . •
Biological treatment: On-site biodegradation, in situ bioreclamation,
Physical/chemical: Contaminant extraction (soil washing), soil flushing, vacuum extraction
Thermal treatment: Low-temperature thermal stripping, vitrification
'"•••• . . -, j- •
Vault Sediments
Biological treatment: On-site biodegradation, in situ bioreclamation!
Physical/Chemical: . Contaminant extraction (liquid solvents) f
-2-
403
-------
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify co,sts. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process ,(effectiveness, .
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are normally recalculated during an evaluation based on nine criteria
established by the NCP. ....'' :

In this FS, the three-criteria screening was carried out on RAAs that did not address the entire
site. These RAAs were then regrouped into site-wide RAAs for the nine-criteria analysis.
Further, the selected remedy was a modified combination of two of the RAAs from the nine-
criteria analysis. No innovative technologies were incorporated into RAAs.

7. How did the cost(s) compare to standard technologies? '

Cost Estimates for RAAs That Include Standard Technologies
Three-Criteria RAAs
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
RAA-8
Standard Technology
No further action (includes restrictive covenant and
public drinking water line)
Fencing/ground water monitoring
Ground water treatment
Restoring soil cover
Multilayer cap v
Complete source (refuse) removal/off-site
incineration
Partial source (refuse) removal/off-site incineration
Vault sediment removal/off-site disposal at
treatment/disposal facility
Estimated Costs
3 Criteria
N/A
$836,000
$1,190,000
$1,978,000
$1,636;000 to
$14,338,000*
$158,128,000
$41,091,000
$389,000
"Cost depends on area of cap.
404
-3-
-------
Cost Estimates for RAAs That Include Standard Technologies
Nine-Criteria Site-Wide RAAs
Alternative
Standard Technology
9 Criteria'
RAA-1
No further action (includes ground water
monitoring, restrictive covenant, public drinking
water line) -
$384,400
RAA-2
Vault sediment removal/off-site disposal/ground j
water treatment (Area #3)/ground water monitoring/
restrictive covenant/public drinking water line [
$2,504,700
RAA-3
Soil cover restoration/vault sediment removal/ bff-
site disposal/ground water treatment (Area #3)/ 1
ground water monitoring/restrictive covenant/public
drinking water line '
$5,214,200
RAA-4
Multilayer cap (Area #l)/vault sediment removal'
off-site disposal/ground water treatment (Area |
#3)/ground water monitoring/restrictive covenant/
public drinking water line ;
$5,291,300
($5,597,000)
RAA-5
Multilayer cap (part of Area #3)/vault sediment ,i *
removal/off-site disposal/ground .water monitoring/
restrictive covenant/public drinking water line i
$7,455,200
($7,355,600)
RAA-6
Multilayer cap (all of Area #3)/vault sediment i
removal/off-site disposal/ground water monitoring/
restrictive covenant/public drinking water line L.
$20,866,500
($20,719,600)
RAA-7
Multilayer cap (all of areas #1 and #3)/vault
sediment removal/off-site disposal/ground water
treatment (areas #1 and #3)/ground water
monitoring/restrictive covenant/public;drinking
water line - \
$33,347,000.
($26,000,000)
- -".-,1
presented parenthetically are from in the Proposed Plan and RpD.
-4-
405
-------
Selected RAA
Alternative
Selected RAA"
Standard Technology
Restoration of soil cover/vault sediment
removal/off-site disposal/ground water
treatment (areas #1 and #3)/ground water
monitoring/gas venting and monitoring/
fencing/surface water monitoring/restrictive
covenant/public drinking water line
Estimated
Costs
9 Criteria
$8,000,000
•"***
0
The selected remedial action was a modified combination of RAA-3 and RAA-7.
8. If a standard technology was chosen, why?

The preferred alternative, through ground water treatment in areas #1 and #3, effectively
eliminates the potential risk to human health that might result from exposure to ground water '
at the site and restores ground water at the site. The alternative effectively minimizes the
potential for exposure to landfill refuse by restoring the soil cover. By removing the
sediments from the vaults, the alternative also would eliminate the potential risk to aquatic
organisms from a sudden discharge of sediment from the leachate collection vaults. By not
constructing an impermeable cap over any of the refuse areas, continuous flushing of areas #1
and #3 is allowed through infiltration of precipitation into these areas. The continuous
flushing action would permit the ongoing degradation of constituents in the refuse and
eventually would reduce the mass of contaminants in areas #1 and #3. The preferred
alternative "appears to provide the best balance of tradeoffs among the alternatives with respect
to the nine evaluation criteria."
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

Refuse
406
On-site biodegradation was eliminated because the technology would not be applicable
due to the heterogeneity of refuse.
-5-
-------
• In situ bioreclamatipn was eliminated because the technology would not be applicable
due to the heterogeneity of refuse.
• Contaminant extraction (soil washing) was eliminated because the technology would
not be applicable due to the heterogeneity of refuse.
• Soil flushing was eliminated because the technology would not be suitable for
heterogeneous municipal landfill refuse.
• Low-temperature thermal stripping was eliminated because the technology would not
be applicable due to the heterogeneity of refuse.
• Vacuum extraction was eliminated because a major limitation to vapor extraction
would be the depth to ground water, which would preempt vapor migration, and
because the technology is unproven for refuse material. ; At sites similar to the Old
City of York Landfill, where saturated fill could be encountered at shallow depths,
venting is "expected to be inhibited." Venting is most efficient and effective for a
source that exhibits uniform permeability and gradients. In aoldition, the effectiveness
of venting is reduced significantly in heterogeneous material siuch as refuse where
uniform concentration and permeability gradients might not be established. This could
lead to untreated locations. j '
• In situ vitrification was eliminated because the technology is pnproven, there are
potential hazards from the generation of small amounts of hazardous material due to
the temperatures involved, and process costs are very high due to high energy
requirements. j

Vault Sediments
!••-.•
• On-site biodegradation was eliminated because the technology is not applicable to
inorganic compounds. i
• In situ bioredamation was eliminated because the technology is not applicable to
inorganic compounds. ' ,
• Contaminant extraction (liquid solvent) was eliminated because human health and the
environment could be adversely affected from exposure to fugitive dust and
constituents during excavation and on-site processing for technology implementation;
currently there is a limited availability of the necessary equipment and workers to
implement this process, as it is an emerging technology; a treatment system for the
spent extraction fluid would be required; and capital costs ar«5 expected to be high; as
there is limited availability of services and multiple extraction stages would most likely
be required. I
• 'i
Innovative technologies eliminated during the screening of the three criteria include the
following: , |
''••"' ' .
• . None - - .-•'-'' • j. ' • '
. . " •! .
Innovative technologies eliminated during the detailed analysis include the following:
. ' ' I
• -None . • '••"-. i ' .'
-6-
407
-------
1L Which of the nine criteria were weighted most heavily m selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
"hich criterion? Which of the criteria supported the use of a standard technology?

The nine-criteria screening focused almost exclusively on ground water treatment and
exposure. Regarding source control, however, long-term effectiveness and permanence, and
cost were weighted most heavily in selecting a remedy. The decision to use a soil cap 'over a
multilayer cap was related to long-term effectiveness and permanence, in that a soil cap would
allow continuous flushing of areas #1 and #3 through infiltration of precipitation into these
areas. The continuous flushing action would permit the ongoing degradation of constituents in
the refuse and would eventually reduce the mass of contaminants in areas #1 and #3. The soil
cap is considerably cheaper ($8 million) than the multilayer cap proposed for RAA-7 ($26
million), making the preferred alternative the most cost-effective remedy.

12, What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup goals were not selected for sediments or refuse.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None •

Standard technologies eliminated because of cleanup goals include:

« None ,, ''.'•'.

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted,

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Impact on nearby populations
Total cost

16. How are measures compared?

The impact on nearby populations is discussed in relation to the construction of a multilayer ' ^ \
cap, in that there might be a risk to residents during the construction period. The same f• /
comparison was not made for construction of a soil cap. The soil cap is considerably cheaper ,. ™

408 ' ''
-------
($8 million) than the multilayer cap proposed for RAA-7 ($26 million), making the preferred
alternative the most cost-effective remedy.
17. What technical considerations were factors in selecting a remedy? "Were technical
considerations primary in the selection of the remedy?
\
Technical considerations were not primary in selecting a remedy. One reason vacuum
extraction was eliminated, however, was because a major limitation to vapor extraction is the -
local depth to ground water, which preempts vapor migration. At sites similar to the Old City
of York Landfill where saturated fill may be encountered at shallow depths, venting is
expected to be inhibited.
-8-
409
-------
Paoli Rail Yard
Paoli, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Rail Yard Soil (ppm)

PCB 6,000

Fuel Oil Impacted Soil (ppm)
,•>

PCB 4,900

Residential and Other Soil (ppm)

PCB 21

Stream Sediments (ppm)

PCB 190
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
N/A
6/28/91
7/21/92
Background

PRP-lead
PRPs: Southeastern Pennsylvania Transit
Authority; The National Railroad
Passenger Corporation;
Consolidated Rail Corporation
FS prepared by: Groundwater
Technology, Incorporated
What volume of material is to be remediated?

The volume of material to be remediated included:

• . 28,000 cubic yards of rail yard soil
• 14,000 cubic yards of fuel oil impacted soil
• 1,000 cubic yards of residential and other soil
• 785 cubic yards of steam sediments

What type of site is this?

Transportation. A rail yard.
410
-1-
-------
TECHNOLOGY SELECTION '
• . - . • • ' •[' , • . .

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
i f
Rail Yard Soil/Fuel Oil Impacted Soil/Residential and Other Soil
Access restriction:
Containment:

Chemical treatment:
Thermal treatment:
Disposal:
Sediments

Access restriction:
Containment:

Chemical treatment:
Thermal treatment:
Disposal:
Institutional restrictions, deed and zoning restrictions
Cap (soil, asphalt, concrete, and multilayer), synthetic liners, surface
controls
Solidification/stabilization
Incineration (rotary kiln, fluidized bed, and infrared)
Excavation, on-site disposal in containment cell, off-site disposal at
TSCA permitted landfill
Deed and zoning restrictions, fishing restrictipns
Cap (soil, multilayer, concrete, and geotextile liner with rip rap stone),
surface controls ,
Solidification/stabilization |
Incineration (rotary kiln, fluidized bed, and infrared)
Excavatiqn, on-site disposal in containment cejl, off-site disposal at
permitted landfill j
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screeriing of technically
feasible technologies were:

Rail Yard Soil/Fuel Oil Impacted Soil/Residential and Other Soil j

Biological treatment: Biodegradation
Chemical treatment: KPEG.dechlorination, DCR dechlorinatibn, solvent extraction,
supercritical water oxidation, soil flushing (surfactant)
Thermal treatment; Thermal desorption, in situ vitrification, UV radiation
, -, . ' .> . . .-
Sediments

Biological treatment: Biodegradation
Chemical treatment: KPEG dechlorination,, DCR dechlorination, solvent extraction,
supercritical water oxidation, UV radiation, soil flushing (solvent)
Thermal treatment: Thermal desorption, in situ vitrification, pyrolysis
-2-
411
-------
6. What was the cost estimate for the innovative technology?

Fewer RAAs were presented in the ROD than in the FS, and several were renumbered. The
RAAs discussed in the ROD are presented parenthetically for each media under the list of"
alternatives.

Present worth cost estimates were not'calculated during the initial/three-criteria screening for
any alternatives. ,

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)

Rail Yard Soil ,

412
Alternative
RAA-4B
(RAA-4B)
RAA-5B
(RAA-6B)
RAA-6B
(RAA-5B)
Innovative Technology
Excavation of soil with greater than 500
ppm PCB/KPEG dechlorination/zoning
and deed restrictions
Excavation of soil with greater than 500
ppm PCB/KPEG dechlorinatibn/soil cap
for areas with 25-500 ppm PCB
Excavation of soil with greater than 25
ppm PCB/KPEG dechlorination
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$11,098,949
$15,398,276
$24,424,397
Fuel Oil Impacted Soil
Alternative
RAA-2A
RAA-3A
Innovative Technology
Excavation of soil with greater than 500
ppm PCB/KPEG or DCR dechlorination
In situ biodegradation
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$58,330
to
$84,130
$2,296,198
-3-
-------
Residential and Other Soil
Stream Sediments
Alternative,
RAA-4A \
(RAA-2)
Innovative Technology
Excavation of soil with greater than
2 ppm PCB/KPEG dechlorination
Estimated Costs
3 Criteria
N/A
9 Criteria
$1,506,005
Alternative
RAA-3A
(RAA-3)
RAA-5A
(RAA-4)
RAA-4A
Innovative Technology
Excavation of sediments with greater
than 10 ppm PCB/KPEG dechlorination
Excavation of sediments with greater
than 1 ppm PCB/KPEG dechlorination
Excavation of sediments with greater .
than 10 ppm PCB/soil cap over areas
with 1-10 ppm PCB
iEstimated Costs
3 Criteria
N/A -
I
N/A
. N/A
1 ' -. .
9 Criteria
$919,028
$5,89,2,_617
$5,426,905
How did the cost(s) compare to standard technologies? 1

Cost Estimates for RAAs That Include Standard Technologies
_ (selected remedial .alternative is in bold) j
*• ' r "
Rail Yard Soil
Alternative
RAA-1
(RAA-1)
_,RAA-2
(RAA-2)
RAA-3
(RAA-3)
RAA-4A
(RAA-4A) .
RAA-4C
(RAA-4C)
Standard Technology
No action/long-term monitoring
Deed and zoning restrictions
Soil cap over areas with greater than 25
ppm PCB/deed and zoning restrictions
Excavation/stabilization/solidification of
soil with greater than 500 ppm
PCB/deed and zoning restrictions
Excavation/incineration of soil with
greater than 500 ppm PCB/deed and
zoning restrictions
Estimated Costs
3 Criteria
N/A ,
N/A
N/A
N/A
N/A .
9 Criteria
$546,431
$556,431
$11,304,723
$8,413,618
$14,325,449
-4-
413
-------
414
Alternative
RAA-5A
(RAA-6A)
RAA-5C
(RAA-6C)
RAA-6A
(RAA-5A)
RAA-6C
(RAA-5C)
RAA-7
(RAA-7)
=====
Standard Technology
Excavation/stabilization/solidification of
soil with greater than 500 ppm PCB/soil
cap of areas with 25-500 ppm PCB
Excavation/incineration of soil with
greater than 500 ppm PCB/soil cap of
areas with 25-500 ppm PCB
Excavation/stabilization/solidification
of soil with greater than 25 ppm
PCB/on-site disposal in containment
cell/deed restrictions/erosion and
sedimentation controls
Excavation/incineration of soil with
greater than 25 ppm PCB
Excavation of soil with greater than 25
ppm PCB/off-site disposal in TSCA
landfill
•
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
9 Criteria
$12,540,095
$18,624,736
$16,266,742
$29,165,600
$26,808,830
Fuel Oil Impacted Soil
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action/long-term monitoring
Excavation/stabilization or incineration
In situ stabilization
Estimated Costs
3 Criteria
N/A
. N/A
N/A
9 Criteria
$47,130
$58,330
to
$84,130
$19,752,579
Residential and Other Soil
========
Alternative
RAA-1
(RAA-1)
RAA-2
RAA-3
,* - ' -
Standard Technology
No action ;
Deed and zoning restrictions
Soil cap of areas (37 locations) with
greater than 10 ppm PCB
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$0
$120,408
$878,740
-5-
-------

Alternative
RAA-4B
(RAA-2)
RAA-4C
(RAA-2)
RAA-5
' L
Standard Technology
Excavation of soil with greater than
2 ppm PCB/incineration
Excavation of soil with greater than
2 ppm PCB/stabilization/disposal of
soil at the rail yard
Excavation of soil with greater than 10
ppm PCB/off-site disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$1,606,755
$1,196,004
$1,645,505
Stream Sediments
Alternative
RAA-1
(RAA-1)
RAA-2
(RAA-2)
RAA-3B
(RAA-3)
RAA-3C
(RAA-3)
RAA-4B
RAA-4C
RAA-5B
(RAA-4)
RAA-5C
(RAA-4) .
RAA-6
Standard Technology
No action/long-term monitoring
Excavation of sediments with greater
than 10 ppm PCB/geotextile liner with
,rip rap/long-term monitoring
Excavation of sediments with greater
than 10 ppm PCB/incineration
Excavation of sediments with greater
than 10 ppm PCB/stabilization
Excavation of sediments with greater
than 10 ppm PCB/incineration/soil cap
of areas with 1-10 ppm PCB
Excavation of sediments with greater
than 10 ppm PCB/stabilization/soil cap
of areas with 1-10 ppm PCB ,
Excavation of sediments with greater
than 1 ppm PCB/incineration
Excavation of sediments with greater
than 1 ppm PCB/solidification/
stabilization/disposal of treated
sediments at the rail yard
Excavation of sediments with greater
than 1 ppm PCB/disposal off-site
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A ' -
N/A
9 Criteria
$39,588
$851,508-
$920,648
$900,398
$5,428,525
$5,408,275
$5,909,217
$5,701,717
$5,917,517
-6-
415
-------
8. If a standard technology was chosen, why?
• ; • ' • • ' . ' "\
Rail yard soil - Excavation and on-site treatment with stabilization/solidification for soils with -''
PCB concentrations > 25 ppm and deed restrictions. After treatment the solidified material
would be placed back on-site in a containment cell.

Residential and other soil - Excavation of residential soils to achieve an average PCB
concentration of 2 ppm per property. Excavated soils will be returned to the rail yard property
and treated using solidification/stabilization.

Stream sediments - Excavation of sediments with PCB concentrations exceeding 1 ppm.
Contaminated sediments would be returned to the rail yard and treated using
solidification/stabilization.

Fuel oil impacted soils - Though alternatives are developed in the FS for this area, no source
control remedy is selected in the ROD. The area containing fuel oil impacted soil is covered
with an impermeable asphalt cover and will be remediated with ground water treatment.

PRP did not concur with clean-up goals. PRP proposed: 1) excavation of soils > 500 ppm and
treatment by solidification/stabilization, 2) off-site soils with concentrations > 10 ppm to be
excavated and treated in the rail yard by solidification/stabilization, 3) sediments with
concentrations > 20 ppm excavated and treated in the rail yard by solidification/stabilization.

PRP proposed remedy was picked because: 1) it reduces the mobility of the chemical ijjflk
constituents in the soil and reduces potential for direct contact by (a) adsorption and '^& -v^.
microencapsulation, (b) decreasing the surface area of material across which a transfer or a J
loss of chemical constituents can take place, tc) limiting solubility of contaminants; 2) proven
technology used at a number of sites: 3) if excavation was limited to areas of contamination
above 500 ppm, than critical operations of the railyard would not need to be shut down during
remediation so that AMTRAK and SEPTA passenger service would not suffer adverse
impacts: 4) relatively simple and can be employed using common construction methods; 5)
addition of cement would create an impermeable mass with a high compressive strength and
not increase the volume of material, all of importance in .implementation at a rail yard; 6) cost
effectiveness. Final determination by EPA of the selected alternative considered these
implementability factors, except for number 3.

9. If an innovative technology was chosen, why?

An innovative technology for source control was not chosen.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial/three-criteria screening include the
following:

Rail Yard Soil/Fuel Oil Impacted Soil/Residential and Other Soil/Sediment

• Supercritical water oxidation was eliminated because its effectiveness is uncertain and
implementation would be difficult since the soil would need to be made into a slurry.
• UV radiation was eliminated because the process is still in developmental stages and
its effectiveness has not been determined. The process requires the soil to be
converted into a slurry form, which would create material handling problems.
• Biodegradation was eliminated because its effectiveness has not been proved for all
chlorinated biphenyls outside of the laboratory. . . ' j
• In situ vitrification was eliminated because the effect ofthe tejchnology on
underground utilities at the rail yard and .the load-bearing capacity of the vitrified mass
were uncertain; and too difficult to implement for sediment in streams and tributaries.
• Soil flushing was eliminated because the implementability of the technique was
uncertain. PCBs could mobilize and spread due to the very high hydraulic
conductivity of the site's soils; and not applicable for use on sediments in streams and
tributaries.
• i
Innovative technologies eliminated during the three-criteria screening include the following:

• Thermal desorption was eliminated because: 1) a treatability study showed no
significant difference in the reduction in PCB concentrations in the soil and, therefore,
can't achieve clean-up standards, 2) leachable lead in the treated soil is twice the
TCLP regulatory level of 5 ppm because natural lead in the soil was destabilized by
the process, 3) paniculate carryover was significantly high and would require use of
cyclone separators and baghouses, 4) high paniculate carryover would increase the
amount of carryover dust and filter cake needing disposal in a TSCA landfill.
• Solvent extraction was eliminated because: 1) it could not attainthetreatment
performance of < 2 ppm (maximum residual attained was 16 ppm), '2) large amounts
of suspended fines were present in the extract which would require enhancement by
high-speed centrifugation, which would increase the processing time and the cost.

Innovative technologies eliminated during the detailed analysis include the following:
- " u
• DCR dechlorination was eliminated because proposed treatability studies were never
completed. 1
• KPEG dechlorination was, eliminated because 1) recommended design parameters from
SDTX Technologies, Inc. with regard to reaction time and reagent composition were
not met, 2) KPEG/C1 molar ratios for bench scale testing was '10; however, SDTX has
determined that there is no advantage to full scale operation at KPEG/C1 molar ratios
greater than 3, 3) decanted fines in the reagent would require centrifuges or filters to
recycle the reagent causing material handling difficulties and, delays in operation.
-8-
417
-------
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
w.-dch criterion? Which of the criteria supported the use of a standard technology?

For all media, the criteria that were weighted most heavily in selecting a standard remedial
alternative were: protection of human health and the environment; reduction of contaminant
toxicity, mobility, and volume through treatment; implementability and cost-effectiveness
Dechlorination was the innovative technology proposed for all media except rail yard buildings
and structures. Dechlorination was eliminated because of implementability.
12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? l
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
PCB (rail yard)
PCS (residential)
PCB (sediments)
PCBs (indoor
surfaces)
25
.-. 2.
1
10 ug/100 cm2
Risk"
Risk"
DOF, OSWER
TSCA"
TCB cleanup levels for industrial soil (25 ppm) represents a 3.5 X 10'5 incremental
cancer risk. These levels satisfy EPA's "Guidance on Remedial Actions for Superfund
Sites with PCB Contamination," OSWER Directive No. 9355.4-01, August 1990.
TCB cleanup level for residential soils (2 ppm) represents a 1 X 10'5 incremental
cancer risk. . .
°PCB cleanup levels for sediments in streams and tributaries is consistent with
Department of Interior (DOI), Ocean Assessments Division document "A Discussion of
PCB Target Levels in Aquatic Sediments" and with OSWER Directive No 9355 4-01
August 1990. ' '
"TSCA spill policy referenced in EPA's "Guidance on Remedial Actions for Superfurid
Sites with PCB Contamination," OSWER Directive No: 9355.4-01, August 1990.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? - .

Innovative technologies-eliminated because of cleanup goals include:

• Solvent extraction
• Thermal desorption
418
Standard technologies eliminated because of cleanup goals include:

• Capping
-9-
-------
The standard remedy selected, solidification/stabilization, met the; clean-up goals.
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted for several technologies, including biodegradation, thermal
desorption, solvent extraction, stabilization/solidification, and KPEG aind OCR dechlorination.
Treated residual levels were compared to the equivalent performance standard of 2 ppm.
Studies show that biodegradation would reduce fuel oil contaminants (total petroleum
hydrocarbons) and thereby would immobilize PCBs, but not remove them. Studies also .show
that thermal desorption. and solvent extraction would have difficulties reaching soil PCB
cleanup levels in areas with high PCB concentrations (e.g., greater thikn 900 ppm). Thermal
desorption and solvent extraction were eliminated as potential technologies for this reason.
Treatability studies also show that stabilization/ solidification and KPEG dechlorination
effectively reduce PCBs. The studies indicated, however, that the KPEG dechlorination
process would create material handling/ operational difficulties. Treatability studies on DCR
dechlorination were never completed.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Total cost
Proven reliability
Preference for treatment (vs. containment)
waste left in place ,

16. How are measures compared?
i

Achievement of clean-up standards and risk reduction required was important in comparing
alternatives. Risk reduction was a source of contention between the PRP and EPA. Proven
reliability was very important and was based on past use of solidification/stabilization and the
treatability study done for the FS. Preference for treatment, eliminated many standard
technologies such as off-site disposal and on-site capping. Treated waste had to undergo stress
and volume tests to ensure it could be used on site.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Because PCBs persist and bioaccumulate, their long-term reduction was a primary factor in the'
choice of a remedial alternative. The hydraulic conductivity (permeability) of the site (10~5 to
10"6 cm/sec) is higher than the levels thought to be suitable for soil flushing (10~2 to 10"4). The
potential for high hydraulic conductivity to cause the mobilization arid spread of PCB was a
primary factor in the elimination of this technology. |
-10-
419
-------
Raymark
OU-1

Hatboro Borough, Pennsylvania
Region 3
3
GENERAL SITE INFORMATION

1, What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface soil (mg/kg)

Trichloroethene 0.018
Tetrachloroethene 0.18
1,2-Dichloroethene 0.15
Benzo(a)pyrene 6.9
Benzo(a)anthracene 5.1
Benzo(b)fluoranthene 6.3
Benzo(k)fluoranthene 6.6
Ideno(l,2,3cd)pyrene , 3.4
Benzo(g,h,i)perylene 2.5
Phenathrene 3.7
Fluoranthene 9.6
Pyrene 9.1
Chrysene . 5.4
PCBs 2.1
4,4-DDE 0.076
4,4-DDT 0.426
Cadmium 78.6
Nickel 755
Arsenic 7.9
Beryllium 1.7
Vanadium 40.4

Subsurface soil (mg/kg)

Trichloroethene 3,100

Bedrock (mg/kg)

Trichloroethene 310
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
10/89
7/9l
12/30/91
Background

EPA Fund-lead
PRPs: N/A
FS prepared by: CH2M Hill
420
-1-
-------
2. What volume of material is to be remediated? : ;
1 " i •
The volume of material to be remediated included:
' - i • •
I ' '
• The volume of material to be remediated was not given. The; site covers 4 acres.
r • ' ' ' - • ' '-;••-
I

3. What type of site is this?
.- ' i • • ' • '
Fabricated Metal Products. An active manufacturer of rivets and fasteners. The site is
bordered by mostly industrial and some residential areas.

TECHNOLOGY SELECTION . \
• i - .
4. What standard technologies were considered for selection in this FS?
j . • • ..
Standard technologies considered during the identification and screening of technically feasible
technologies were: ;
i" ' ' r ' •
Access restriction: Fencing, restricted land use
Containment: , Capping (soil, clay, asphalt, concrete, synthetic membrane, multilayer),
slurry wall, vibrating beam, grout curtain, sheet piling
Chemical treatment: Solidification/fixation, neutralization, ion exchange, crystallization,
photolysis i
Physical treatment: Oil/water separation, media filtration, membnine processes,
evaporation, distillation, liquid-liquid extraction, flow and strength
,.' equalization, ion exchange, greensand, irradiation, flotation,
Thermal treatment: Incineration, gaseous incineration
Disposal: Excavation, landfill disposal (RCRA, non-RCRA)
5. Was an innovative technology considered in the FS? If so, which technology?
i j .
Innovative technologies considered during the identification and screening of technically
feasible technologies were: !
- , . '' •. ' j . . .
Biological treatment: Biodegradatioh (aerobic, anaerobic, in situ, ex situ)
Phys/Chem treatment: Solvent washing, critical fluid extraction, oxidation/reduction,
dechlorination, in situ permeable treatment bejds, soil washing (water),
in situ soil vapor extraction, in situ soil/bedrqck flushing
Thermal treatment: In situ thermal evaporation, in situ thermal stripping, in situ
vitrification, pyrolysis, wet air oxidation
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
Innovative Technology
Excavation of surface soil/ stabilization/
disposal at RCRA landfill/soil vapor
extraction of subsurface soil and
bedrock
Excavation of surface soil/incineration/
stabilization/disposal at RCRA landfill/
soil vapor extraction for subsurface soil
and bedrock
Asphalt, cap over surface soil/soil vapor
extraction for subsurface soil and
bedrock
Excavation of surface soil/ stabilization/
disposal at RCRA landfill/soil vapor
extraction for subsurface soil/flushing
for bedrock
Multilayer cap on surface soil/soil
vapor extraction of subsurface soil
and bedrock
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
9 Criteria
$3,419,200
to
$5,461,500
$3,873,500
to
$5,992,300
$3,369,200
to
$5,175,600
$2,412,500
to
$3,644,100
$3,654,400
to
$5,173,000
How did the cost(s) compare to standard technologies?

A standard technology was not chosen.
-3-
-------
9. If an innovative technology was chosen, why?
- .. _ -i - _ •' • •
The chosen alternative was preferred because it provides the greatest protection to human
health and the environment. This alternative is protective because it addresses both current
and future site risks. The cap significantly and expeditiously reduces site risk posed by direct
contact with surface soil. The principal site risk, however, is posed by TCE, located hi
subsurface soil and bedrock. The leaching of TCE to ground water is expected to pose a risk
in excess of 10"4. The proposed cap will reduce the infiltration of pnbcipitation through the
soil and protect ground water by minimizing leaching of residual TCEi into ground water. The
Hydrological Evaluation of Landfill Performance (HELP) model was Used to calculate the
reduction in infiltration provided by various caps. The proposed cap will be designed specially
to reduce infiltration of precipitation. Infiltration rate will be an estimated 24 times slower
than its current rate. The treatment to be implemented at the site is sioil vapor extraction
(SVE). SVE will reduce the major contamination threat to ground waiter, primarily TCE, from
subsurface soil and bedrock. The combination of the cap and SVE is preferred because any
residual contaminants will be addressed without having to rely on a ground water remedy.
The cap also decreases the soil's moisture content, which in turn increases,the soil's porosity,
thereby increasing the efficiency of SVE. Also, cleanup levels could be exceeded by installing
a cap and using SVE. This alternative also was preferred because it will not require
excavation or soil movement and therefore it minimizes short-term risk. Further, because
contamination has been found beneath buildings and in bedrock, excavation would not be
practical. The effectiveness of SVE is certain because, according to previous treatability
testing at the site, SVE could remove VOCs from the subsurface soil and bedrock on site: The
technologies proposed are easily implemented and the chosen alternative iis cost-effective.
JO. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '

Innovative technologies eliminated during the initial screening include; the following:
• - ; ' '' . ; ' I
• Oxidation/reduction was eliminated because it would not be applicable to site
contaminants. ' «-
« Organic chemical dechlorination was eliminated because it wbuld not be applicable to
the site's waste types. . : .
• Biodegradation (aerobic, anaerobic, in situ, ex situ) was eliminated because the
process is unproven for eliminating contaminants of concern. I
• In situ permeable treatment beds was eliminated because it would not be applicable
due to geologic conditions (i.e., the saturated zone in bedrock).
• In situ vitrification was eliminated because it would not be applicable to bedrock
contamination.
• Pyrolysis was eliminated because it would not be applicable tp the site's waste types.
• Wet air oxidation was eliminated because it would not be applicable to the site's waste
types.
-4-
423
-------
Innovative technologies eliminated during the screening of the three criteria include the
following:

" Solvent washing was eliminated because it has limited effectiveness for metals;
residuals would be retained and would require treatment or disposal; it would not be
effective in clay and silt soil; and its implementability would be poor due to low soil
permeability, the proximity of buildings, the large volume of soil requiring excavation,
and the high cost.
• Critical fluid extraction was eliminated because its effectiveness would be limited due
to cadmium in soil. Further, additional treatments for cadmium would still be
required.
• In situ thermal evaporation (radiofrequency) was eliminated because its effectiveness
in bedrock is uncertain and it would not be implementable in bedrock.
" In situ thermal stripping (steam or hot air) was eliminated because it would be more
difficult to design and operate than SVE and would require high maintenance and
costs. Also, increasing the temperature would not be expected to increase the
effectiveness of extraction since contaminants of concern already have a high
volatility.
• Ex situ soil washing (water) was eliminated because it would not be very effective in
clay and silt, the process would generate many residuals that require treatment and •
disposal, excavation would be difficult due to both the large volumes of waste and the
building proximity, and the process would be comparable in cost to in situ
technologies, which are preferred. Finally; surface soils have limited TCE
contamination.

Innovative technologies eliminated during the detailed analysis include the following:

• In situ soil/bedrock flushing was eliminated because of the potential mobilization of
contaminants to ground water.

The most heavily weighted criteria in selecting a remedial alternative were protection of
human health and the environment and permanent reduction of contaminants. The chosen
alternative offers the greatest protection in both the immediate future and the long term
because it proposes technologies that address surface soil and subsurface soil/bedrock. The
proposed technologies act synergistically to reduce site contaminants, possibly even exceeding
cleanup levels.
*.)
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
424
Contaminant
Carcinogens
Trichloroethene
Cleanup Level (ppb)
ARAR or Other Basis
50
Model"
-5-
-------
Contaminant
Cadmium
Benzo(a)anthracene
Benzo(a)pyrene .
Benzo(b)fluoranthene
Indeno( 1 ,2,3-cd)pyrene
PCBs
Benzo(k)fluoranthene
Cleanup Level (ppb)
86,905
1,214
176
1,259
757
263
2,668
ARAR or Other Basis
Risk"
; Risk
Risk
Risk
1 Risk
Risk
Risk
Noncarcinogens
Benzo(g,h,i)perylene
8,111
[ Risk
aSuiiimers model was used to calculate cleanup levels of soil contaminants. This
model predicts the soil concentrations required to prevent ground water contamination
from leaching.
bCleanup levels correspond to a 1CT6 risk.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: j

• , None . , ' • : "'I •..'..;.•_..

Standard technologies eliminated because of cleanup goals include:

• None . . . '. : | .

• '• . ' • J '-'",-'
14. Were treatability studies conducted on the innovative technology or standard technology?
• ' . : ' - I ' ' ' . ' '
1 I' :
EPA conducted a treatability study on SVE and concluded that this technology was effective
and could be used to remove VOCs from the site's subsurface soil and bedrock.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Time to design/construct/operate '
- Proven reliability
-6-
425
-------
16. How are measures compared?

The chosen alternative was preferred because it provides the greatest reduction of site risk
through both SVE and capping. Contaminant levels are reduced, residual risk is addressed,
and the combination ensures that residual contaminants will not be affected by the infiltration
of precipitation. Capping provides the quickest solution to risk posed by direct site contact.
SVE is a proven technology since it was previously tested at the site.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The site's physical setting was a primary consideration in selecting a remedy. TCE, the
principal site contaminant, is currently located in subsurface soil and bedrock which in some
instances is under buildings. The major risk to the site is the future mobilization of TCE to
ground water. The treatment technology selected, SVE, was most technically appropriate
because excavation, which would be very impractical, would not be required.
426
-7-
-------
Resin Disposal
OU-1

Jefferson Borough, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

Acetone 2.046
Bis(2-ethylhexyl)phthalate 0.916
Dibenzofuran ' 0.804
Di-n-butyl phthalate 0.778
Methylene chloride 0.031
2-Methylnaphthalene 1.75
Naphthalene ,' . 9.397
Benzo(a)anthfacene 0.912
Benzo(a)pyrene 0,775
Benzo(b)fluoranthene 0.757
Benzo(k)fluoranthene . 0.733
Chrysene 0.808
Fluoranthene 1.556 '
Phenanthrene 2.113
Pyrene 1.176
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
12/82
9/83
5/91
6/28/91
Background
i
PRP-lead
PRPs: Hercules Incorporated
FS prepared by: Roy F. Weston,
Inc.
What volume of material is to be remediated?

The volume of material to be remediated included:

• 92,000 cubic yards of landfill waste.and soil.
• 23,000 cubic yards of downslope soil.
What type of site is this?

Industrial Landfill. A former landfill surrounded by a suburban residential area.
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427
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Physical treatment:
Thermal treatment:

Disposal:
Fencing, deed notation
Capping (low permeability, soil, synthetic geomembrane, admixtures,
chemical sealants/stabilizers, multilayers), dikes, berms, grading,
revegetation, slurry wall, grout curtains, injection grouting, sheet
piling, bottom sealing, skimmer wells, recovery wells
Dewatering
Incineration (rotary kiln, fluidized bed, multiple hearth, high-
temperature fluid wall reactor)
Excavation, landfill, secure vault, deep well injection
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Composting, slurry phase biodegfadation, solid-phase biodegradation,
land application
Phys/Chern treatment: In situ chemical treatment, soil washing, in situ soil washing
Thermal treatment: Low-temperature thermal stripping, in situ volatilization, in situ steam
stripping, wet air oxidation, molten salt combustion, pyrolysis, plasma
arc pyrolysis, vitrification, in situ vitrification
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. For this site, technologies
were screened generally for all source media. Technologies were then incorporated into media
specific options for the three-criteria screening process (effectiveness, implementability, and
cost) to identify alternatives that merit a more detailed evaluation. Comprehensive site
alternatives were then developed for the detailed analysis and estimated costs were calculated
during an evaluation based on nine criteria established by the NCP: long-term effectiveness
and permanence; short-term effectiveness; compliance with ARARs; protectiveness of human
health and the environment; reduction in contaminant mobility, toxicity, or volume;
implementability; cost; state/support agency acceptance; and community acceptance. >
428
-2-
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Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) i
Landfill waste
Downslope soil
Alternative
WM-5A
WM-6A
WM-6B
Innovative Technology
Excavation/low-temperature thermal
stripping
In situ biodegradation
In situ soil washing
, Estimated Costs
3 Criteria
eliminated
_
N/A
eliminated
9 Criteria
N/A
. N/A
N/A
Alternative
S-5A
S-6A
S-6B,
Innovative Technology
Excavation/low-temperature thermal
stripping
In situ biodegradation
In situ soil washing
I • - ; -
Estimated Costs
3 Criteria
eliminated
eliminated
eliminated
9 Criteria
.'. .N/A
N/A
. N/A
Comprehensive site alternatives for detailed analyses, proposed plan, and ROD
Alternative
RAA-6
Innovative Technology
In situ biodegradation
Estimated Costs
3 Criteria
N/A,
1
1
9 Criteria
$11,765,000
to
$19,985,000
7. How did'the cost(s) compare to standard technologies?
- • . • i'

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) |
Landfill waste
-3-
Alternative
WM-1
WM-2
Standard Technology
No action -
Fencing/deed restrictions/monitoring
Estimated Costs
3 Criteria
N/A
, N>A
9 Criteria
N/A ,
N/A
429
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Alternative
WM-3A
WM-3B
WM-4
WM-5B
Standard Technology
Closure/fencing/multilayer cap
Closure/fencihg/multilayer cap/skimmer
well system
Excavation/off-site disposal
Excavation/incineration
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
. N/A
N/A
N/A
N/A
Downslope soil
Alternative
S-l
S-2
S-3
S-4
S-5B
Standard Technology
No action
Fencing/deed restrictions/monitoring
Excavation/consolidate into landfill/
multilayer cap
Excavation/off-site disposal
Excavation/incineration
/Estimated Costs
3 Criteria
N/A
N/A
eliminated
eliminated
eliminated
9 Criteria
N/A
N/A
N/A
N/A
N/A
Comprehensive site alternatives for detailed analyses, proposed plan, and ROD
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-4
RAA-5
Standard Technology
No action ,.
Fencing/deed restrictions/monitoring
Closure/fencing/multilayer cap
Closure/fencing/multilayer cap/
skimmer well system
Excavation/off-site disposal'
Excavation/incineration
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$2,452,000
$2,860,000
$3,127,000
$4,348,000
$25,538,000
to
$300,239,000"
$92,597,000
to
$174,797,000
430
The large range in cost is due to the possibility that some waste may need treatment prior to
disposal. . . ,
-4-
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8. If a standard technology was chosen, why?

RAA-3B was chosen because it provides a high degree of protection to human health and the
environment. The risk assessment identified ground water as the mosit significant exposure
pathway affecting human health. The chosen alternative, via engineering controls, impedes
further migration of waste or contaminated soil from the landfill. It also protects human health
by eliminating direct contact with site soils through access restrictions and the placement of a
multilayer cap. The alternative meets all ARARs. The proposed cap and leachate collection
and treatment system offer a high degree of implementability. Implementation requires less
time than for other treatment alternatives. The alternative minimizes ?hoit-term risk since it
does not involve intrusive activities in the landfill and offers moderate degree of long-term
effectiveness and permanence. While no treatment of landfill waste is proposed, engineered
controls would be utilized to manage the waste and contaminated media on site. Long-term
maintenance, monitoring, and institutional controls are required to ensiure the effectiveness of
this remedy in the long-term. Further, because of the relatively low risk associated with the
site, EPA has determined that more costly treatment technologies would not be justifiable.
This alternative is cost-effective.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage vitas the innovative
technology eliminated?
I
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Composting was eliminated because a typical open air operation can lead to
uncontrolled release of volatile organics to the atmosphere. Also, very limited land
availability on site restricts the implementability of this process option.
• Slurry phase biodegradation was eliminated because the slurry requirement would
significantly increase effective waste volume. Very limited on-site land availability
and odor concerns would restrict the implementability of this process option.
• Solid-phase biodegradation was eliminated because very limited land availability and
odor concerns would restrict the implementability of this process option.
• In situ chemical treatment was eliminated because it would not be applicable since
inorganics are not a concern at the site.
• Soil washing was eliminated because of concerns about implementability and
effectiveness. Fine-grained site soil (clay) would be unfavorable. The organic
compounds of concern are strongly held within the tight clay-s;oil mixture, which
would limit the method's effectiveness. In addition, fine-grained clay particles would
be difficult to remove from the washing fluid. !
• In situ volatilization was eliminated because of concerns about; its implementability and
effectiveness. Fine-grained site soils would be unfavorable foi> applying an effective
-5-
431
-------
vacuum for extraction purposes. Also, naphthalene has a relatively low volatilityswith
respect to VOCs normally removed with this process.
• In situ steam stripping was eliminated because of concerns about its implementability
and effectiveness. Fine-grained site soil is not conducive to air or steam circulation.
» Wet air oxidation was eliminated because of the availability of other thermal
technology process options that are conventional and have demonstrated effectiveness
for the aromatic organic compounds of concern at the site. It would not be appropriate
for solid residues.
• Molten salt combustion was eliminated, because other thermal technology process
options were available that are conventional and have demonstrated effectiveness for
the aromatic organic compounds of concern at the site.
« Pyrolysis was eliminated because other thermal technology process options were
available that are conventional and have demonstrated effectiveness for the aromatic
organic compounds at the site. Also, transportable units would not be readily
available.
• Plasma arc pyrolysis was eliminated because other thermal technology process options
were available that are conventional and have demonstrated effectiveness for the
aromatic organic compounds at the site.
« Vitrification was eliminated because other thermal technology process options were
available that are conventional and have demonstrated effectiveness for the aromatic
organic compounds at the site. •
• In situ vitrification was eliminated because other thermal technology process options
were available that are conventional and have demonstrated effectiveness for the .
aromatic organic compounds at the site. In addition, an underground fire could start
with the flammable waste materials and coal deposits present at the site.
« Land application was eliminated because it could result in spreading contamination via
infiltration and runoff if the compounds of concern are not effectively degraded by the
microbes. Further, there is limited land availability at the site and odor concerns,
which limit the implementability of this option.

Innovative technologies eliminated during the three-criteria screening include the following:

Landfill waste

• Low-temperature thermal stripping was eliminated because it is unlikely that low
treatment levels could be reached. The ability to achieve low treatment levels is
highly unlikely because of the high concentrations of waste material and the physical
variability of the material. If treatment goals are not attained, additional treatment
prior to off-site disposal would be required, rendering this option not cost-effective.
• In situ soil washing was eliminated because it would result in a large volume leachate
stream requiring treatment and the ability to collect/retrieve extract would be uncertain.
The ability to achieve low treatment levels is highly unlikely because of the high
concentrations of waste material and the physical variability of the material. Further,
if treatment goals are not attained, additional treatment prior to off-site disposal would .
be required, rendering this option not cost-effective. Finally, there is limited
demonstration of this technology and the level of treatment that can be achieved is
unknown.
432
-6-
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Downslope soil
Low-temperature thermal stripping was eliminated because potential excavation would
adversely affect the perched ground water in the unconsolida ed zone, unnamed site
stream and the associated ecological community. Excavation
might result in VOC
emissions to the atmosphere. In addition, unfavorable conditions for effective
treatment exist because of the tight clay matrix of the soil anji the presence of lower
volatility PAH compounds such as naphthalene. ' j '
• In situ biodegrodation was eliminated because the site's low permeability soils would
be unfavorable for effective distribution of oxygen, nutrients,,! and cultured microbes.
"An additional complicating factor is the flow of perched ground water through the
unconsolidated soil zone, with discharge to the site stream, which greatly hinders the
ability to achieve the hydrogeological flow control necessary !to effectively implement
this technology." i
• In situ soil washing was eliminated because site soil is unfavorable for effective
treatment because of its low permeability. The soil tightly holds contaminants in a
clay matrix, hindering effective distribution of required treatment materials. Also, soil
washing is a separation process that results in a liquid waste that would require
treatment and the ability to collect and retrieve extract would be uncertain. "An
additional complicating factor is the flow of perched ground water through the
unconsolidated soil zone with discharge to the site stream, which greatly hinders the
ability to achieve the hydrogeological flow control necessary to effectively implement
this technology." . . . *• ;
' ' ' • , . [ ' •••'''•'
Innovative technologies eliminated during the detailed analysis include the following:

• In situ biodegradation was eliminated because implementation of this process would
be expected to have major limitations. Concerns were raised about the high
contaminant concentrations in the waste material. Some degradable contaminants
might prove toxic or inhibitory to microorganisms at sufficiently high concentrations
In addition the degradation of complex organics, such as BNA compounds, might be
limited by their aqueous solubility. Further, when contaminants exist as large
aggregates, microbial activity, which occurs at the contaminant-water interface might
be limited by the surface area of the waste material itself. These factors could limit
the rate or extent of biological treatment achievable. Thus, the level of treatment
achievability is undetermined. Treatability tests would be required to define
achievable treatment levels. The ability to treat in a highly variable waste and soil
matrix also must be demonstrated. The implementation of this process is likely to be
an extended process because of the high concentrations of contaminants involved.
And because of a long treatment period, the potential for undesirable impacts
increases. Further, microbial activity could mobilize sorbed contaminants. This can
"lead to potential impacts if not properly controlled via recoveiry and or interception.
Finally, this process depends on the subsurface conditions being amenable to
controlled flushing, which might not be feasible in the landfill waste.
' 433
-7- ' • '• : , •-.•-.
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so.
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a technology included protection to human
health and the environment, short-term risk, implementability, and cost. RAA-3B was chosen
because it offers protection that is comparable to other alternatives, it can be quickly
implemented, it will have little or no adverse effects on the surrounding community, and it
costs less. The chosen alternative provides a high degree of protection, which is greater than
that offered by RAAs 1, 2, 3A, and 4, but comparable to RAA-5 and 6. RAA-5 was
eliminated because of short-term risk associated with the large amount of intrusive activity on
the landfill possibly causing traffic impacts and VOC emissions. RAA-6 was eliminated
because of uncertain effectiveness and difficulties in implementation. The chosen alternative is
the cost-effective remedy because it eliminates the exposure pathway at a relatively low cost.
RAAs 5 and 6 are significantly more expensive and would not offer a proportional increase in
protection. RAA-3A is comparable to RAA-3B except for cost. The higher cost of RAA-3B
is justified because this alternative presents a more effective solution for the contamination
with the addition of a skimmer well network.

RAA-6 proposed in situ biodegradation, and it was eliminated because of uncertain
effectiveness, implementation difficulties, and high cost.

* , •
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No cleanup levels are developed for landfill waste or soil.

75. Way the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability tests were not conducted.
t

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost/unit risk
434
-8-
-------
Time to design/construct/operate
Proven reliability
Impact on nearby populations
16. How are measures compared?
• - ' ''''
RAA-3B was chosen because it offers the greatest protection. Of all the alternatives that offer
comparable protection RAA-3B could be implemented in the shortest amount of time. RAA-
3B could be implemented in 9 to 12 months compared, to 24 to 36 months for RAA-5, and 36
to 60 for RAA-6. Further, RAA-3B does not pose short-term risk to pie community since it
does not require intrusive activities at the landfill as RAA-4 and RAA-5 would. RAA-3B also
was preferred because it provides comparable protection to RAA-5 arid RAA-6 at a much
lower cost; RAA-3A is comparable to RAA-3B in cost, however, the higher cost of RAA-3B
is justified because this alternative presents a more effective solution for the contamination
with the addition of a skimmer well network. Finally, the chosen alternative has been proved,'
while RAA-6 was eliminated because of many uncertainties regarding implementation and
effectiveness.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
' • ' i • .
• i
No technical consultation was primary in selecting a remedial alternative
-9-
435
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Rhinehart Tire Fire Dump
OU-2

Winchester, Virginia
Region 3
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Zinc 300

Sediments (mg/kg)

Zinc 2,880
2. What volume of material is to be
remediated?
Site History

NPL Proposed: N/A
NPL Final: N/A
FS: N/A
ROD: 9/92

Background

EPA Fund-lead
PRPs: N/A
FS prepared by: This early remedial
action for OU-2 is being
addressed before the completion
of the final phase of the RI/FS.
The volume of material to be remediated included:

H An unspecified volume of pond sediments

H 1,125 cubic yards of soil

3. What type of site is this? '

Uncontrolled Waste Site. The site is a tire storage site at which a tire fire occurred. The .
operable unit is a lined containment pond built for containment of water generated during
firefighting and oil products from burning tires. The site is located in a sparsely populated
rural area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Disposal:
436
Excavation/off-site disposal

-1-
-------
an innovative technology considered in the FS? If so, which technology?
,t ' • ' • I
No innovative technologies were considered during the identification and screening of ~
technically feasible technologies ! >,

1 ' ' ••
6. What was the cost estimate for the innovative technology? I

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
;
Standard Technology
No action
Excavation/soil and sediment testing/
off-site disposal/water treatment
Estimated Costs
3 Criteria
N/A
N/A.
9 Criteria
$0
$1,300,000

An expedited remedial action was selected. The selected alternative ^as the only alternative
that proposed any action, and, therefore, was the only available choice. By treating the surface
water and removing contaminated soil and sediments, the selected action will eliminate the
migration of contaminated surface water and sediments off site and remediate the surrounding
pond soils to acceptable levels. Contaminated soils and sediments will be removed leaving no
residual environmental risk from the pond. The selected action complies with all ARARs. The
technologies involve standarid site cleanup and construction procedures and should not present
any unusual technical or administrative problems.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
-2-
437
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

" None • •
-" '
Innovative technologies eliminated during the screening of the three criteria include the
following: .

« None

Innovative technologies eliminated during the detailed analysis include the following:

Overall protection of human health and the environment, compliance with ARARs, long-term
effectiveness and permanence, and implementability were the criteria weighted most heavily in
selecting a technology. Overall protection of human health and the environment is achieved
through treating the surface water and removing contaminated soil and sediments, thereby
eliminating the migration of contaminated surface water and sediments off site and remediating
the surrounding pond soils to acceptable levels. The technology complies with all ARARs.
Long-term effectiveness, and permanence is achieved because contaminated soils and sediments
would be removed leaving no residual environmental risk from the pond. The action is easily
implemented because the technologies involve standard site cleanup and construction
procedures and should not present any unusual technical or administrative problems.
*
72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm) ARAR or Other Basis
Noncarcinogens
Zinc
50
Background
Note: Soil and sediment also will be tested to determine if any of the media are
considered to be a hazardous waste under RCRA.
438
-3-
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13.
Was the innovative technology eliminated because of the cleanup
technology meet the cleanup goals? ,
goals? Could the standard
Innovative technologies eliminated because of cleanup goals include:

• None .

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?
Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives?

None

, 16. How are measures compared?

• No measures were used to compare alternatives.
„ ,
17. What technical considerations were factors in selecting a remedy? Were .technical

considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy.
-4-
439
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Saunders Supply Company'

' Chuckatuck, Virginia
Region 3
J
GENERAL SITE INFORMATION

7. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Arsenic 266
Total chromium 252
Copper 158
Hexavalent chromium 1.836
Pentachlorophenol (PCP) 5.1
Dioxins 0.0025
Total petroleum hydrocarbons 572

Sediments (mg/kg)

Pentachlorophenol (PCP) 230
Dioxins 0.00325
Total Petroleum hydrocarbons 797
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1/87
10/89
5/91
9/30/91
Background

EPA Fund-lead
PRPs: Saunders Supply Company
FS prepared by: Ecology and
Environment, Inc.
2. What volume of material is to be remediated? . ' .

The volume of material to be remediated included'.

• 20,000 cubic yards of soil ,
» 566 cubic yards of sediment

3. What type of site is this? ' ,

Lumber and Wood Products. An active lumber yard that previously chemically treated wood.
It is located in a mixed residential and commercial area.
440
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection injhis FS?

Standard technologies considered during the identification and screening of technically feasible
, technologies were:

Access restriction: Fencing, deed restrictions
Containment: Capping (asphalt, cement, concrete, loam/sane, multilayer)
Chemical treatment: UV photolysis
Physical treatment: Stabilization/solidification, encapsulation
Thermal treatment: Incineration (fluidized bed, fix hearth, infrared, multiple hearth, rotary
kiln), electric reactor
Disposal: Excavation, disposal (on-site, off-site)
5.
Was an innovative technology considered in the FS? If so, which technology?
\i
Innovative technologies considered during the identification and screening of technically
feasible technologies were: ^
Thermal treatment:
Biological treatment: In situ bioremediation, white rot fungus, bacteria
Phys/Chem treatment: Dechlorination, soil washing, chemical extraction, critical fluid
extraction, in situ soil flushing j
Molten salt, molten glass, pyrolysis, plasma systems pyrolysis, in situ
steam enhanced vacuum extraction, in situ steam/air stripping, low-
temperature thermal desorption, in situ vitrification, in situ radio
frequency heating
6. What was the cost estimate for the innovative technology?

.During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. Numbers presented parenthetically represent changes in
the nine criteria detailed analyses and the ROD.
i
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) !
Alternative
RAA-4
(RAA-3A)
(RAA-3B)
Innovative Technology
Dechlorination/off-site disposal
Dechlorination/on-site disposal
-2-
Estinnated Costs
3 Criteria
N/A
N/A
9 Criteria
$25,934,000
$14,097,000
441
-------
Alternative
RAA-5
(RAA-4A)
(RAA-4B)
RAA-6
RAA-8
(RAA-5)
Innovative Technology
Low-temperature thermal desorption
of soil/dechlorination of sediment/off-
site disposal
Low-temperature thermal desorption of
soil/dechlorination of sediment/on-site
disposal
Soil washing
In situ vitrification
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$20,485,000
$8,648,000
eliminated
$15,945,000,
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative •
RAA-1
RAA-2
RAA-3
RAA-7
Standard Technology
No action
Asphalt cap/ground water treatment
On-site incineration
Off-site incineration
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$320,000
$3,459,000
eliminated
eliminated
8. If a standard technology was chosen, why?

A standard technology was not chosen
9. If an innovative technology was chosen, why?

RAA-4A was selected because it is the most protective of human health and the environment.
This alternative eliminates risk.due to direct contact with site soil and sediment, and reduces
future risk associated with ground water contamination, because it will permanently eliminate a
potential source of leaching contaminants. PCP contamination in the soil constitutes the major
threat and human health risk at the site. The chosen alternative utilizes two innovative
technologies to treat the soil and sediment and dispose of treated materials off site. Low-
temperature thermal desorption will effectively heat and remove PCP from the soil. The
dechlorination process will be used for, sediment and it will destroy all the organic
contaminants, including PCP and dioxin. Long-term ground water monitoring and institutional
controls ensure the progress of the work. The chosen alternative was preferred because it
442
-3-
-------
eliminates site contaminants and disposes of treated soil and sedimerit off site Through
treatment and disposal, this alternative provides a permanent reduction in site contaminant
toxicity, volume, and mobility. Off-site disposal of treated soil increases the long-term
effectiveness of this alternative as no contaminants will be left on site to leach to ground water
in the future., .The technologies proposed in this alternative will be easily implemented Upon
completion, this alternative will comply with all ARARs. This alternative is cost-effective.
I

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

fonovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
' •! •
Innovative technologies eliminated during the initial screening include the following:

• Molten glass was eliminated because it would be inappropriate for soil with high ash
content, and it is still in innovative developmental stages with regard to
implementability.
• Molten salt was eliminated because it would not be appropriate for material with high
ash content and it has not been demonstrated on dioxin-contaminated materials.
• Plasma systems pyrolysis was eliminated because it is still in research stages for
hazardous waste. . j
• Pyrolysis was eliminated because it has not been demonstrated as an effective method
to destroy dioxins.
• Chemical extraction was eliminated because the complex mixlaire of contaminants
might make it difficult to create an effective solvent, the fine fraction of the soil might
remain contaminated, and the fine particles are often difficult ;to remove from the
solvent. This process is generally limited to waste with organic content in excess of
200 ppm. j
• • Critical fluid extraction was eliminated because its application is undetermined for
hazardous organic waste and its availability might be limited, j
• White rot fungus was eliminated because it would be difficult to meet cleanup levels
for dioxins and furans, land disposal restrictions might prevent the implementation of
land farming, and fine-grained soil might make slurry bioreactor treatment effluent
difficult to settle. , i
• Bacteria was eliminated because it might be difficult to reach cleanup levels. Previous
bench-scale testing suggests that bacteria can degrade PCP, but that PCP in
concentrations greater than 500 ppm could be toxic to microorganisms. Also, land
disposal restrictions might prevent the implementation of land farming, fine grained
soil might make slurry bioreactor treatment effluent difficult toi settle.
• In situ bioremediation was eliminated because it would not achieve cleanup goals for
metals and dioxins, and its effectiveness for PCP contamination is questionable due to
the highly variable concentrations of PGP that would cause inconsistent
biodegradation. The presence of heavy metals could be toxic to microorganisms and
the low permeability of soil would hinder the movement of waler and nutrient throueh
the soil. , 6
• In situ steam enhanced vacuum extraction was eliminated because it would not achieve
cleanup goals for metals and dioxins, and the low permeability | of the soil and

• ' .. . ' - ' - 'J- ' . '• •• 443
-4- •.••-...:••
-------
• heterogeneity of the soil conditions would reduce the overall effectiveness of PCP
removal.
• In situ steam/air stripping was eliminated because it would not achieve cleanup goals
for metals and dioxins. The technique is not well demonstrated and all the mechanism
are not well understood. Commercial availability of the equipment is limited.
• In situ soil flushing was eliminated because a suitable washing solution would be
difficult to formulate due to the complex mixture of contaminants, and the
effectiveness would be limited by the low permeability of the subsurface soil, and the -• 1
high percentage (approximately 30 percent) of silts and clay found in the soil. Further,
contaminants absorbed to clay are difficult to remove by flushing and site
contaminants are primarily found in the clay/silt soil fraction.
• In situ radio frequency was eliminated because its effectiveness would be limited by
the low permeability and high clay/silt content of the soil, it would not be an effective
remedy for metals and dioxins.

. Innovative technologies eliminated during the screening of the three criteria include the '
following: , . ;.

• Soil washing was eliminated because of the questionable effectiveness in achieving
cleanup levels and/or PCP RCRA treatment standardsThe clay/silt sludge generated
would be concentrated with contaminants that require further treatment and/or disposal i
that might not be available since incineration cannot address arsenic and dechlorination
is not effective on silt and clay. A pilot study conducted on soil washing at another
wood treatment facility showed that PCP in concentrations ranging from 5 to 115
mg/kg remained following treatment (Sheehan, 1991). Only 7.4 PCP ppm is allowed tifa \
for RCRA-permitted disposal. ^VF /

Innovative technologies eliminated during the detailed analysis include the following:

» In situ vitrification was eliminated because it would not offer as much long-term
effectiveness and permanence as the chosen alternative. Further it might not be as
easily implemented as the chosen alternative and treatability testing would be
necessary.

The criteria that were weighted most heavily in selecting a remedial alternative were protection
of human health and the environment, compliance with ARARs, long-term effectiveness and
permanence, and cost-effectiveness. The chosen alternative was preferred because it was the ;
most protective option. Following soil/sediment treatment, treated materials will be disposed
off site. Off-site disposal will provide greater long-term effectiveness and permanence because
at the risk based soil cleanup level, PCP might leach into the ground water at levels exceeding
ground water cleanup levels. RAA-3B, RAA-4B and RAA-5 were not chosen because they
would not offer as much long-term effectiveness since contaminants would remain on-site.
Both RAA-3B and RA-4B proposed on:site disposal of treated soil/sediment'and contaminants
remaining in treated soil/sediment could leach into ground water at concentrations in excess of
MCLs. RAA-5 also would contain contaminants on site in a vitrified mass and treatability
studies would be needed to assess the magnitude of residual risk.

444 5
-------
Compliance with ARARs also was a concern. RAA-3B and RAA-4B were not preferred
because they might not comply with ARARs since they contain on-site disposal of treated soil
and sediment. Either alternative would meet the Virginia Solid Waste Management
Regulations requirement for treatment to background conditions prior; to backfilling of treated
soil/sediment on-site. . , i

Finally, while RAA-3A would have offered as much protection and piermanence as the chosen
alternative it was not chosen because it would be more expensive and therefore not cost-
12.
13.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant ,
Cleanup Level (mg/kg)
ARAR or Other Basis
•
Carcinogens ,
Arsenic
Chromium VI
Pentachlorophenol
Dioxin/furansb "
Dioxin/furans'
5i7
• 0.82
1.46
0.001 (TEP)
0.010 (TEF)
i Risk"
Risk
Risk
EPA"
EPA
i
Noncarcinogens •,'•
Chromium HI
Copper
559,000
2,600
Risk
Risk
Tor carcinogens, an excess upper bound individual lifetime cancer risk of 10'6 was
acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was
acceptable. j
bUpper 1 foot of soil and sediment. !
Toxicity Equivalent Factors. ! " -
dU.S. EPA, 1991, Correspondence (Waste Classification) witf'f A. Palestini, U.S. EPA
Region HI, Philadelphia, PA. Also used at Times Beach, Missouri.
eSoil below 1 foot. -• !,'
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

White rot fungus
Bacteria
In situ bioremediation
In situ steam enhanced vacuum extraction
In situ steam/air stripping
-6-
445
-------
Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies on biological treatment were conducted during the RI. The results
suggested that the presence of high concentrations of PCP (greater than 500 ppm) could be
toxic to microorganisms.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: < ,

Percentage risk reduction
Cost-effectiveness
Preference for treatment (vs. containment)

16. How are measures compared?

Cost-effectiveness was a deciding factor. Another alternative (RAA-3A) would have provided
the same degree of protection-and effectiveness as the chosen alternative but it was not jtfa v
selected because it would have cost more. The permanent reduction of risk through treatment ^ir J
and off-site disposal was a prominent factor in selecting an alternative. Other alternatives that
would have left contaminants on site either in a vitrified mass or in disposed treated
soil/sediment were not considered as protective as the chosen alternative. Contaminants left on
site would be a future potential source of leachate into the ground water.

77. Wtiat technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Soil characteristics were primary in selecting a remedial alternative. The low permeability and
high clay/silt content of the soil precluded the use of in situ steam enhanced vacuum !
extraction, in situ soil flushing, and in situ radio frequency. The high ash content of the soil
precluded the use of molten salt and molten glass technologies. And the fine particles of sand
precluded the use of chemical extraction.

References ;

Sheehan, P., April 1991, Personal communication, Regional Manager, Biotrol, Inc. Princeton, '.',
New Jersey. . . ' ' •;'
446
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Strasburg Landfill
OU-3

Newlin Township, Pennsylvania
Region 3
GENERAL' SITE INFORMATION
1. What were the principal contaminants,
contaminant levels* and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:
Sampling was not conducted directly in the
landfill. Sampling was carried out for
sediment around the leachate seeps.
Soil/sediment (mg/kg)
1,1-Dichloroethane 0.085
1,2-Dichloroethene 0.039
Toluene 0.023
4-Methylphenol 0.39.0
Benzoic acid 0.054
Antimony 34
Arsenic 53
Barium 903
Beryllium 3.4
Iron, 425,000
Manganese 2,090
Chromium 192
Nickel ' 33.5 ,
Mercury 0.27

Siteffiiitory
NPL Proposed: 6/88
NPL Final: 3/89
FS: '_ 9/91
ROD: 3/31/92
Background
EPA Fund-lead
PRPs: N/A
FS prepared by: ARCS Contract - no
company name was listed.
. . '
What volume of material is to be remediated?
• , '
The volume of material to be remediated included:

• 3 million cubic yards of waste and soil/sediment

What type of site is this?
Industrial Landfill. A former landfill that received industrial and heavy metal waste. It is
located in a primarily residential and agricultural area.
-1-
i
447
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: '
Access restriction:
Containment:

Disposal:
Fencing - • '
Caps, retaining dikes and berms, drainage control facilities, in situ
grouting
Excavation, disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

No innovative technologies were proposed.
What was the cost estimate for .the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
(RAA-1A)
RAA-2
RAA-3
RAA-4
(RAA-2)
Standard Technology
No action/monitoring '
Limited action/monitoring/deed
restrictions .','
Provide alternative water supply/
ground water monitoring
Point of use ground water treatment
RCRA cap/passive gas collection
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
9 Criteria
$3,044,700
N/A
eliminated
eliminated
$10,420,850
443
-2-
-------
• - • • • - ' '.''..' ' • .
Alternative
RAA-5
(RAA-3)
RAA-6
(RAA-4)
RAA-7
(RAA-5)
Standard Technology
RCRA cap/passive gas collection/
leachate system
RCRA cap/landfill gas collection system
RCRA cap/landfill gas collection
system/leachate collection system
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$11,306,460
$10,998,140
$11,883,750
' • .--'.:. ..•.•••_,'•.
8. If a standard technology was chosen, why? j
."' •" i

The chosen alternative RAA-5 (RAA-3) was preferred because capping tthe landfill with a
RCRA cap reduces the amount of leachate generated by precipitation infiltrating through the
existing landfill cap and the refuse. Further, impacts to the ground water will be effectively
reduced. Landfill caps have been demonstrated to be very effective in preventing human
health risks such as those posed at this site. A leachate collection system collects and treats
leachate that migrates^to the toe of the landfill. Through leachate treatment, this alternative
reduces contaminant toxicity, mobility, and volume. These actions reduce human and
environmental receptor exposure to acceptable levels. The technologies proposed in this
alternative are readily available. This alternative is cost-effective.
9. ' If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• None
Innovative technologies eliminated during the screening of the three criteria include the,
following: .j.
f ' ~ i
• None , :
Innovative technologies eliminated during the detailed analysis include the following:
i' ' •• •
'• None •' '•'.'•'..[••
-3-
449
-------
77. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and cost were the criteria that were weighted
most heavily in selecting a remedial alternative. RAA-1 and RAA-1A would not be protective
since they propose only access restrictions. Currently, recreational activity occurs on site even
though warning notices are posted. RAA-2 also would not be protective enough because it did
not adequately address leachate seeps, which are an identified source of contamination. The
chosen alternative was preferred over RAA-4 and RAA-5 because they would offer only a
small increase in protection but for a much higher cost.

72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No cleanup levels were established for soil/sediment. •

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
* - , *
Innovative technologies eliminated because of cleanup goals include;
•'
1

Standard technologies eliminated because of cleanup goals include:

• None • ,

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. t

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost/effectiveness ~ , •

16. How are measures compared?

Cost and protectivene.ss were the reasons RAA-3 was selected over RAA-4 and RAA-5. It
was felt that the incremental increase in protectiveness offered by RAA-4 and RAA-5 was not
enough to justify their increased cost.
450
-4-
-------
17. What technical considerations were factors in selecting a remedy? Wen" technical

considerations primary in the selection of the remedy? :
•- I

No technical considerations were primary in selecting a remedial alternative.
451
-------
Tonolli Corporation

Nesquehoning Borough, Carbon County, Pennsylvania
Region 3
GENERAL SITE INFORMATION ,.

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Waste Piles and Byproducts (mg/kg)

Lead 317,000

Site Soil (mg/kg)

Lead 95,200

Off-site Soil (mg/kg)

Lead 4,410

Sediments (mg/kg)
Site History
NPL Proposed:
NFL Final:
FS:
ROD:
6/88
10/4/89
1/31/92
9/30/92
Background

PRP-lead
PRPs: 528 PRPs were identified for this
site. 46 PRPs entered into an
Administrative Consent Order
with EPA. Individual PRPs are
not listed.
FS prepared by: Paul C. Rizzo
Associates, Inc.
Lead
Arsenic
Copper
600
34
33.3
Landfill/Solid and Hazardous Waste (mg/kg)

Lead 68,300
2. What volume of material is to be remediated?

The volume of material to be remediated included:

» The waste piles and byproduct materials include approximately 13,000 cubic yards of
battery casings, 2,020 cubic yards of treated sludges, 243 cubic yards of dust, 210
cubic yards of excavated lagoon soils, and 250 drums of melted plastic.
• Approximately 39,000 cubic yards of site soils contaminated with lead above a
concentration of 1,000 ppm will be excavated from on-site areas. 7,300 cubic yards of
soils containing the highest total lead concentrations will be treated (see Question 8).
" The quantity of off-site soil to be remediated was not given.
• The quantity of sediments to be remediated was not given.
452
-1-
-------
• Approximately 105,000 cubic yards of solid and hazardous waste are contained in the
landfill which covers 10 acres. !

3. What type of site is this?

Recycling. A former battery recycling and secondary lead smelting plant which ceased
operating in January 1986. The site covers approximately 30 acres and is located in an
industrial park.
TECHNOLOGY SELECTION
: I '

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: !
\ •
Access restriction:
Containment:

, Chemical treatment:
Physical treatment:
Thermal treatment:

Disposal:
Institutional controls (deed restrictions)
Capping (clay, asphalt, concrete, synthetic membrane, composite, soil),
vertical barriers
In situ stabilization/solidification |
Beneficiation (resource recovery), on-site chemical bonding (alumina
silicates), resource recovery (smelting, extraction/electrolytic recovery,
leaching/microfiltration)
On-site and off-site incineration (rotary kiln, jfluidized/bed combuster,
infrared, plasma arc)
On-site landfill, off-site landfill (CERCLA, municipal waste, residual
waste) • , ~
Was an innovative technology considered in the FS? if so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: . i
1 ' '!•'''

Chemical treatment: In situ electroreclamation, in situ soil flushing, on-site solids
washing/leaching (BOM Process, ETUS, Inc., Canonic Process)
Thermal treatment: In situ vitrification, pyrolysis, on-site molten glass
6: What was the cost estimate for the innovative technology? !

Alternative
RAA-4
Option a and
Option b"

RAA-5
Option a and
Option ba

RAA-6
Option a, b, c
anddb

RAA-7
Option a and
Option ba

i
Innovative Technology
Soil capping/resource recovery (off-site
lead smelter)/RCRA cap on landfill

On-site soil disposal in landfill/resource
recovery (off-site lead smelter)/RCRA
cap on landfill/decontaminate buildings/
natural attenuation
On-site soil treatment (soil washing
and solidification/stabilization)/
resource recovery (off-site lead
smelter)/RCRA cap on land-
fill/decontaminate building

Off-site soil treatment (stabilization)/
resource recovery (off-site lead smelter)/
RCRA cap on landfill/decontaminate
building

Estimated Costs
9 Criteria
$9,000,000
RAA-4a
$9,200,000
RAA-4b
$9,400,000
RAA-5a
$12,300,000
RAA-5b
$16,800,000
RAA-6alc
$16,900,000
RAA-6a2
$24,100,000
RAA-6bl
$24,200,000
RAA-6b2
$26,100,000
RAA-6cl
$26,200,000
RAA-6c2
$37,900,000
RAA-6dl
$38,000,000
RAA-6d2
$27,700,000
RAA-7alc
$27,800,000
RAA-7a2
$43,700,000
RAA-7bl
$43,800,000
RAA-7b2
ROD
$9,200,000
(RAA-4)
eliminated

eliminated

$12,310,000
(RAA-5)
eliminated

eliminated

$24,179,000"
(RAA-6)
eliminated

eliminated

$43,760,000
(RAA-7)
"Option a: Action Level - 3,200 mg/kg lead (calculated risk-based level).
Option b: Action Level - 1,000 mg/kg lead (evaluated at EPA's request).
bOption a: Stabilization, Action Level - 3,200 mg/kg lead (calculated risk-based level).
Option b: Stabilization, Action Level - 1,000 mg/kg lead (evaluated at EPA's request).
Option c: Soil Washing, Action Level - 3,200 mg/kg lead (calculated risk-based level).
Option d: Soil Washing, Action Level - 1,000 mg/kg lead (evaluated at EPA's request).
cOptions 1 and 2 (e.g., RAA-6al and RAA-6a2) specify ground water treatment techniques.
Option 1 incorporates natural attenuation of ground water and Option 2 incorporates ground
water flushing.
-3-
-------
*The selected RAA was modified in the ROD and the final estimated present worth cost for
the modified RAA was $16,616,000 (see Question 8).,
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Alternative
RAA-1
RAA-2
RAA-3
Option a - soil
cap
Option b -
asphalt cap
Option c -
concrete cap

Standard Technology
No action
Limited action/institutional control
Soil capping/RCRA cap on landfill/
decontaminate buildings

Estimated Costs
9 Criteria
$550,000
$4,000,000
$5,700,000
RAA-3a
$6,2100,000
RAA-3b
$7,100,000
RAA-3c

ROD
$550,000
$4,000,000
$6,213,000
(RAA-3)
eliminated

eliminated

8. If a standard technology was chosen, why?

The selected alternative RAA-6b2 is a modified version of the Preferred .Alternative described
in the July 18, 1992, Proposed Plan. During the public comment period, EPA received new
information which indicated that EPA's remedial action objectives ami health-based cleanup
levels could be met by an alternate approach to treating contaminated site; soils. This
information also indicated that such an alternate approach to soils treatment would be more
cost-effective. Based on an evaluation of this information, EPA selected a different "trigger"
level to define soils that pose a principal threat and that require treatment prior to their
consolidation in the on-site landfill. The modified Alternative 6 requires the treatment of
contaminated soils defined as a principal threat (i.e., soils with lead levels exceeding 10,000
mg/kg, or one order of magnitude greater in concentration than the cleanup level) via on-site
stabilization prior to consolidation in the on-site landfill. Remaining soils (i.e., soils
containing lead between 1,000 and 10,000 mg/kg) will be consolidated in the on-site landfill,
in combination with a more passive treatment method designed to significantly reduce the
potential for contaminant leaching. This passive treatment consists of adding a layer of
crushed or pulverized agricultural limestone to the on-site landfill as part of the cap
construction and landfill closure. The modified remedy also differs fijom the Proposed Plan in
the estimated cost for remediation. The modified remedy combines certain features (i.e.,
handling of contaminated site soils) of Alternative 5 with Alternative J5. The estimated present
worth cost of this modified alternative is $16,616,000 (this cost was first ireferred to in Section
XI of the ROD, Explanation of Significant Changes). Other changes in the modified plan
from the preferred alternative in the Proposed Plan include a month shorter implementation
time, and off-site soils will be consolidated in the on-site landfill prioir its closure rather than
treated on site via stabilization.
.4.
455
-------
The modified remedy was chosen because the combination of treatment to address the ^,
principal threats and engineering controls (i.e., containment) to address lower level threats will j
effectively reduce and eliminate the potential risks posed by the site contaminants. The > ' -^
modified remedy was chosen because it provides an equivalent level of protection and long-
term effectiveness as the originally proposed remedy, while being somewhat more cost-
effective. The chosen stabilization converts the contaminated soils into a less soluble and less
mobile form that meets the treatment requirements of RCRA Land Disposal Restrictions. The
on-site treatment of soils prior to disposal significantly reduces the threat posed by
contaminated materials by reducing the toxicity and mobility of contaminants. The
stabilization process increases material volume by approximately 20 percent, but reduce
toxicity and mobility. In addition, the selected modified alternative will attain compliance
with all ARARs. The selected alternative is implementable and utilizes readily available and
reliable technologies. During the completion of the FS for this site, Chemfix conducted a '
treatability study on Tonolli Corporation waste as a representative option for on-site
solidification/stabilization. This study was successful in formulating a lead treatment system
that reduces the leachability of lead in the waste to levels below the regulatory standard of 5
ppm (see answer to Question 14).

9. If an innovative technology was chosen, why?

The selected remedy also includes the off-site resource recovery (secondary lead smelting) of
approximately 13,000 cubic yards of battery casings and wastes. The toxicity, mobility, and
volume of battery casings will be reduced due by shipping the waste off site for resource
recovery. A treatability study conducted during the preparation of the FS confirmed that this ^pr —,.
remedial action determined that battery case materials from the site could be processed in, }
Exide's Reading, Pennsylvania, facility.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• In situ electroreclamation was eliminated because the.presence of slag in the landfill
and the high iron content of site soils would reduce the technical reliability of this :
technology. Metal objects such as iron were reported to increase energy consumption > ;
and remediation time. This technology has not been widely used and therefore does
not have an adequate performance record. The FS states that two in situ field
experiments and one full-scale remediation project have been performed with this
technology (Lageman et al., 1990)
• In situ soil flushing was eliminated because the flushing solution could not be captured
for the unsaturated soils and debris media, given/the porous nature of the mine spoil
and alluvium. The landfill constituents would not be amenable to soil flushing due to ^^
the heterogeneous nature of the material, the unknown distribution of the material, and flip V
the potentially large pieces of slag (up to several feet in diameter) with high A
concentrations of lead (up to 3 percent) scattered throughout the landfill.

456 i
-5- • ' • -
-------
• In situ vitrification was eliminated due to the high moisture content of the landfill. A
significant portion of the site's soil consists of coal mine spoils that might generate
more off-gases than could be controlled by the hood. A recent pilot- scale project (not
referenced in the FS) at another site failed due to off-gases [splattering molten glass
(soil) into the hood.
• On-site solids washing/leaching (BOM Process, ETUS, Inc.) were eliminated because
the Canoriie Process was chosen instead to represent solids washing/leaching treatment
options in the development .of remedial action alternatives slince this process had been
used at the Gould Site in Portland, Oregon. The FS discusses the BOM Process as
implemented by Foster Wheeler Enviresponse (Coles, 1990). TJie Environmental
Technology (ETUS, Inc.) process uses a milder acid solution than the BOM process.
"Other solutions that have met with little or no success include EDTA, anionic
surfactant, tap water (Barth and Traver, 1990) and acid. This process was eliminated
because it is unclear if the washing process would be applicable and it is known that
some materials such as EDTA chelate with lead making treatment extremely difficult."
• Pyrolysis was eliminated because it would not be an effective means of treating lead.
-• On -site molten glass was eliminated because this technology has not been
demonstrated for battery wastes.
• Resource recovery: extraction/electrolytic recovery was eliminated because it would
be ineffective for the site's low lead concentrations. According to a study by PEI
Associates, removal efficiencies for this process approached 90 percent for chelate
solutions with initial lead concentrations greater than 1 percent while removal
efficiencies were below 40 percent for a 0.2-percent lead solution.

Innovative technologies eliminated during the screening of the three; criteria include the
following: .

• Resource recovery: leaching/microfiltration was eliminated but no reason was given.
During the initial screening stage, the FS states that this technology would be a
potentially effective treatment procedure for removing constituents that exist above a
diameter of 0.1 microns. Since this particle size is likely to contain a significant
portion of lead and other metals, this process option was retained. The FS refers to
E.I. duPont de Nemours and Co., Inc. and Overlin Filter Co., and EPOC Water, Inc. as
• two of the available microfiltration processes that might be considered innovative.
,
Innovative technologies eliminated during the detailed analysis include the following:

• Soil washing (Canonic Process) was eliminated based on the results of treatability
screenings completed during the FS for this site. EPA preferred
solidification/stabilization over soil washing. The soil washing technique was expected
to be a slower process than on-site stabilization and would generate a hazardous
residual requiring off-site treatment and disposal. In addition, this technique was
expected to be significantly more costly than stabilization for on-site soils. The soil
washing process was eliminated based on cost, implementation time, and effectiveness.
The stabilization treatment method better met the criterion (if reducing toxicity,
mobility, and volume through treatment.
-6-
457
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting the remedy were overall protection of human
health and the environment, long-term effectiveness and permanence, and reduction of toxicity,
mobility or volume through treatment. Because EPA anticipates the site will be used for
industrial purposes after the cleanup, permanence and long-term effectiveness were of critical
concern. The selected remedy effectively reduces the contaminated area at the site to one-third
of its original area, and minimizes the operation and maintenance requirements for the
remedial activities. Community acceptance also was critical in selecting the modified remedial
action. The original selected alternative was modified based on EPA's consideration of new
information and extensive comments submitted during the public comment period (particularly
from a local water authority and from a group of PRPs for the site). The Commonwealth of
Pennsylvania has not concurred with the selected .remedial action.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

On-site Soil/Waste Piles/Battery Casings
Contaminant
Cleanup Level (mg/kg) ARAR or Other Basis
Carcinogens
Lead
1,000
EPAa
"Cleanup level is based on present EPA policy which uses a range of 500 to 1,000
mg/kg in residential areas to protect the health of young children, as supported by the
Integrated Uptake/Biokinetic Model: As there are currently no recognized methods for
evaluating lead exposure in adults, EPA chose the upper bound of the "residential"
range, as a reasonable cleanup level to protect the health of adult on-site workers.
EPA believes that this soil cleanup level will protect ground water.

Off-site Soil
Contaminant
Cleanup Level (mg/kg) ARAR or Other Basis
Carcinogens
Lead
500
EPA"
•Cleanup level is based on present EPA policy which uses a range of 500 to 1,000
mg/kg in residential areas to protect the health of young children, as supported by the
Integrated Uptake/Biokinetic Model.

Based on comments received from the-U.S. Department of Interior, Fish and Wildlife Service,
EPA deleted the reference to a 450 mg/kg-sediment cleanup level for lead that was included in
the Preferred Remedy described in the Proposed Plan. Additional sampling and bioassays will
451
-7-
-------
be conducted to determine an appropriate cleanup level for the contaminated sediments that
have been detected in Bear and Nesquehoning Creeks. .

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
i . ' i
Innovative technologies eliminated because of cleanup goals include:
/
• None I

Standard technologies eliminated because of cleanup goals include:

• None ..'-••• !

- • I" , • •
14. Were treatability studies conducted on the innovative technology or standard technology?

A small-scale treatability study was conducted by Canohie as a representative option for on-
site solids washing/leaching at the Tonolli site. Canonic completed initial bench-scale
• treatability tests on the Tonolli site samples. Analytical results indicate lhat the tailings
material, plastic battery casings, and ebonite battery casing were all cleaned to pass TCLP.
While the soil did not pass TCLP, an 80-percent reduction in total lead content was achieved.
Based on the analytical and sieve analysis, Canonie feels that the +50 mesh fraction or .85
percent of the soil and 90 percent of the tailings could be cleaned to jpass TCLP, and therefore,
backfilled on site after treatment.
i * .
Chemfix conducted a treatability study on Tonolli waste as a representative option for on-site
solidification/stabilization. The goal of the study was to formulate a lead treatment system that
would reduce the leachability of lead in the waste submitted to levels bellow the regulatory
standard of 5 ppm. Four treatment formulae were proposed and applied to each waste to
convert it into NaturfilR, a nonhazardous clay-like soil produced by the addition of Chemsetun
reagents to the industrial waste. Chemical and physical analyses were performed to assess the
effectiveness of each treatment. All the treatment formulae were successful.

The University of Pittsburgh Center for Hazardous Materials Research (CHMR) and Exide
Corporation, pursuant to EPA contract CR-818199-01-0 under the Emerging Technologies
Program, are investigating the potential for using secondary lead smelters for the recovery of
lead from battery eases and other materials removed from Superfund sites. The purpose of
this investigation is to determine if these materials, which typically contain lead in
concentrations of 1 to 10 percent, can be processed through existing secondary lead smelters in
an ecpnomical fashion to reclaim usable lead. As part of this investigation, CHMR/Exide
processed materials from the Tonolli site in Nesquehoning, Pennsylvania, through Exide's
Reading, Pennsylvania, facility. CHMR/Exide processed test materials from the Tonolli site in
the reverberatory and blast furnaces at Exide's Reading smelter between September 9 and 13,
1991. One reverberatory furnace and one blast furnace were utilized to process the Tonolli
material. A second reverberatory furnace and blast furnace remained in normal routine
operation, which allowed for comparison of the "test" furnaces with the "reference" furnaces.
These tests showed that battery case materials from the site can be processed in the facility's
blast furnaces with various modifications to the system. Battery case material from the site
cannot be processed without size reduction. Estimated processing costs on a unit rate basis

... ' \ -8-
459
-------
and estimated on Exide's method of operation were determined to be $0,15 per pound. The
projected volume of;
cubic yards per day.
projected volume of site material that the Exide Reading facility could process is 30 to 45 VP "\
15. What measures/criteria were used to compare alternatives? . i

The following measures were used to compare the alternatives: -

Risk level achieved ,
Cost-effectiveness
Proven reliability
Preference for treatment (vs. containment)

16. How are measures compared?

The site will be used for industrial purposes after the cleanup; therefore, the level of risk
reduction achieved by the selected alternative was of critical concern. The modified remedy
was chosen over the preferred alternative outlined in the Proposed Plan because it provides an
equivalent level of protection and long-term effectiveness as the originally proposed remedy,
but is more cost-effective. The combination of treatment and engineering controls proposed
under the selected alternative effectively reduces and eliminates the potential risks posed by
the site in a cost-effective manner. Stabilization/solidification and smelting were selected
because these technologies were easily available and reliable and proved effective in J^fc->v
treatability studies conducted during the completion of the FS. The selected remedy meets the ^BP J
statutory requirement to utilize permanent solutions and treatment technologies to the '
maximum extent possible. Treatment was selected to address the site materials and
contaminated media posing the principal threats to human health and the environment. Four of
the six categories of contaminated wastes or environmental media will be subject to treatment
under this remedy.

77. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a chosen remedy for the site. In situ
soil flushing was eliminated because the flushing solution could not be captured in the
unsaturated soils and debris media, given the porous nature of the mine spoil and alluvium.

References

Barth, E.F. and R.P. Traver. Treatment of Lead Battery Contaminated Soil Utilizing Soil
Washing and Solidification/Stabilization Technology; Proceedings of Hazardous Waste
Treatment: Treatment of Contaminated Soils, Sponsored by Air and Waste Management
Association and U.S. EPA Risk Reduction Engineering Laboratory, February 1990, Cincinnati
OH. '
460
-------
• r !
Coles E Treatability Study Review of Soil Washing and Solvent Extraction Technologies far
Potential Applicability toTonolli Site; U.S. EPA Contract 68-C9-0033, Work Assignment OR-
008. ! ,

Lageman, R. et al. Electroreclamation: State of the Art and Future Developments,
Proceedings of Hazardous Waste Treatment: Treatment of Contaminated Soils, Sponsored by
Air and Waste Management Association and U.S. EPA Risk Reduction Engineering
Laboratory, February 1990, Cincinnati, OH. r
461
-10-
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Whitmoyer Laboratories
OU-2

Jackson Township, Pennsylvania
Region 3
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Vault Waste (rag/kg)

Arsenic 157,000
Total organics 140,000
(aniline, benzene, PCE, n-
nitrosodiphenylamine)

Lagoon Waste (mg/kg)

Arsenic 10,000
Organics summed average 12
(pentachlorophenol, bis(2-ethylhexyl)phthalate, n-n-nitrosodiphenylamine)
10/84
,6/86
2/90
12/17/90
Background

EPA Fund-lead
PRPs: Rhom & Haas and SmithKline
Beecham
FS prepared by: Ebasco Services Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

« 4,500 cubic yards of vault waste
• 24,000 cubic yards of lagoon waste

3. What type of site is this?

Pharmaceutical Manufacturing. An abandoned pharmaceutical manufacturing facility in a
predominately agricultural and rural setting.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening'of technically feasible
technologies were:
462
-1-
-------
Access restriction:
Containment:
Chemical treatment:
Physical treatment:

Thermal treatment:
•f
Disposal:
Fencing, deed restrictions
Capping (clay, synthetic, RCRA), jet grouting, sluirry wall
Fixation (stabilization, solidification), thermoplastic
microencapsulation, macroencapsulation, clay pelletizing, reduction,
neutralization
Dewatering, sedimentation, detonation, solids processing (crushing,
screening, magnetic separation) j
Incineration (rotary kiln, infrared, fluidized bed, circulating fluidized
bed) ,
Excavation, recycle, salvage, on-site landfill, ojff-slte landfill
5. Was an innovative technology considered in the FS? If so, which technology?
' • ' ' '•'•'./
Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation (aerobic, anaerobic, in situ, ex situ)
Chemical/physical: In situ soil flushing, dechlorination, vapor extraction, other extraction
technologies such as BEST (Resources Conservation Co.), critical fluid
solvent extraction (CF Systems Corp.), EPA's mobile extraction system
Thermal treatment: Vitrification (in situ, ex situ), low-temperature thermal stripping (X*
TRAX system), radio frequency heating, pyrofysis (plasm arc, high
temperature fluid wall), wet air oxidation
What was the cost estimate for the innovative technology?
. ' •,
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Typically after the RAAs
have been formulated, costs are estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based On
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; and community acceptance.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Vault waste
Alternative
RAA-5
Innovative Technology
Excavation/mix with other site wastes/
vitrification/disposal of treated waste on
site or off site in RCRA landfill
-2-
Estimated Costs
3 Criteria
N/A
9 Criteria
$38,800,000
to
$58,000,000
463
-------
Lagoon waste
Alternative
RAA-5
Innovative Technology
Excavation/in situ vitrification/disposal
of treated waste in off-site landfill or
cap ,
Estimated Costs
' 3 Criteria
- N/A
9 Criteria
$16,400,000
to
$24,200,000
7. How did the cost(s) compare to standard technologies?
Vault waste
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-6a
RAA-7"
Selected
remedy
Standard Technology
No action/ground water monitoring
Deed restrictions/excavation/disposal on
site in RCRA landfill/ground water
monitoring
Excavation/microencapsulation of upper
vault waste/fixation of lower vault,
waste/treated waste disposed on site or
off site in RCRA landfill
Excavation/incineration/fixation of
ash/disposal of fixed material on site or
off site in RCRA landfill
Excavation/disposal in on-site RCRA
landfill/long-term maintenance/deed
restrictions
Excavation/disposal off site-in RCRA
landfill
Excavation/cement fixation of upper
vault waste/incineration followed by
fixation of lower vault waste/treated
waste disposal in off-site hazardous
waste facility
Estimated Costs
3 Criteria
N/A
- N/A ."
N/A
N.A
N/A
N/A
•N/A
9 Criteria
$109,000
$1,379,000
$11,300,000
-to
$15,900,000
$15,630,000
to
$20,500,000
N/Aa •
N/Aa
$18,400,000
a RAA-6 and RAA-7 were proposed by the former site owners and only are presented in the
ROD. No costs were estimated for these alternatives.
464
-3-
-------
Lagoon waste
Alternative
RAA-1
RAA-2

RAA-3

RAA-4

RAA-6
-------
Lagoon Waste: ,

• '• ' : ' ''•
The selected alternative was preferred because fixation treatment will eliminate and
permanently immobilize site contaminants. While alternatives RAA-4 and RAA-5 were
considered more protective since they addressed organics, they were not chosen and no
explanation is given. Other alternatives that proposed containment were not chosen because
they would not ensure long-term protection. The selected alternative also was considered more
protective because treated waste will be disposed off site. The potential of landfill failure from
sink hole formation was a concern because ground water could be contaminated. Moreover, '•
Pennsylvania law prohibits a hazardous waste landfill immediately above carbonated bedrock.'

9. If an innovative technology was chosen, why?

An innovative technology was not chosen.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Vault/Lagoon Waste: ,

• In situ and ex situ biodegradation was eliminated because it was not applicable to site
contaminants. Effective treatment of site contaminants would require both aerobic and
anaerobic techniques. Further, the breakdown of some halogenated aliphatics would
result in vinyl chloride, a toxic intermediate. Most important, the process might be
inhibited by the presence of arsenic, which could not easily be removed from the
waste and would not be addressed by biodegradation. '
• Dechlorination was eliminated because it was not applicable to site contaminants.
« In situ radio frequency heating was eliminated because it is not "independently"
applicable for the primary site contaminants.
" In situ vapor extraction was eliminated because it was not "independently" applicable
for the primary site contaminants.
• In situ soil flushing was eliminated because it was not applicable to site conditions of
highly fractured bedrock and the process is not "independently" applicable for the
primary site contaminants.

Innovative technologies eliminated during the screening of the three criteria include the
following:

Vault Waste:

• Extraction technologies (solvent) were eliminated because they would not achieve
remediation goals and would not be reliable with the site's contaminants. Further,
since contaminants are already highly concentrated, attempts to concentrate further the '

466
-5- ' :
-------
waste would not significantly reduce the waste volume. In addition, it is unlikely that
arsenic can be effectively separated from organic contaminants sinc« it is suspected
that a significant amount of arsenic is present in its organic form.
• Wet air oxidation was eliminated because there was concern that the numerous
components in the vault waste (steel fragments, paper, carbon, sludge, tar, and
solvents) would hamper the waste from being shirried and therefore severely limit the
effectiveness of this option. Volatilized arsenic would be a health hazard, very few
vendors perform this work, and the concentrations of organics lire Mgher than those
typically considered feasible for oxidation.
• Low temperature thermal stripping was eliminated because it v/as laot expected to
achieve the remediation goals. Because of the low temperature employed, many site
organics would not be volatilized and arsenic would not be changed into a form that is
amenable to fixation. >.
• In situ vitrification was eliminated because the sodium and organic content of the
vaults limits its applicability. The sodium content reduces the electrical resistance of
the waste thereby limiting the temperature that can be achieved. The organic content
could severely limit the rate of waste treatment because of air pollution concerns.
••.
Lagoon Waste:

• Extraction technologies were eliminated because of their limited effectiveness in
achieving remediation goals. Since arsenic is already present in substantial
concentrations in the waste, little benefit would be gained froni attempts to concentrate
waste. •.••;•>
• Wet air oxidation was eliminated because the low organic concentration of the waste
severely limits its effectiveness. The iron and arsenic also might interfere with the
oxidation process.
• Low-temperature thermal stripping was eliminated because it Would be ineffective with
site contaminants. Most site organics are nonvolatile at the low temperatures
employed by this process. Further, arsenic would not be chanjged into a form that is
amenable to fixation. I

Innovative technologies eliminated during the detailed analysis include| the following:

Vault Waste:

• Vitrification was eliminated but no specific reason was given.
"'.'•. • I . .:'
Lagoon Waste:

• In situ vitrification was eliminated but no specific reason was 'given.
i
- ' " - ' .•'!'''••'•-
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Vault Waste:
i • i, • .

The most heavily weighted criteria in the choice of a standard remedial technology for vault
waste was the protection of human health and the environment through the permanent
-6-
46'
-------
reduction of site contaminants via treatment. The selected alternative was preferred because it
reduced organics in the upper vault and immobilized the arsenic in the upper and lower vaults
through treatment. Alternatives that proposed landfilling were not considered as protective
because they did not treat contaminants. Further, alternatives that proposed on-site landfilling
would not be protective due to the potential for landfill failure, which would result in ground
water contamination. Alternatives RAA-4 and RAA-5 were considered slightly more
protective than the selected alternative and slightly more effective in the long term since they
treated organics in both the upper and lower vaults. No reason was given for the preference -
for the selected alternative above these two.

No innovative technologies were eliminated due to the nine criteria.

Lagoon Waste:

The most heavily weighted criteria in the choice of a.standard remedial technology for lagoon
waste was the protection of human health and the environment through the permanent
reduction of site contaminants via treatment. This treatment would also ensure that the remedy
would be permanent and effective in the long term. Other options were considered less
protective because they did not treat contaminants. Moreover, the option to landfill on site
was not chosen because of the potential for landfill failure due to sink holes and the associated
contamination of ground water. Treatment was preferred over containment because of future
maintenance needs. Finally, several alternatives would not comply with ARARs since
Pennsylvania law does not allow construction of a hazardous waste landfill above carbonate
bedrock, and RCRA land disposal restriction standards do not allow the off-site disposal of
waste expected to have TCLP and EP Toxicity leachate concentrations above 5 mg/1 arsenic.

No innovative technologies were eliminated due to the nine criteria.
12.
What cleanup goals,were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Chemical specific cleanup goals were not provided. Cleanup is based on RCRA, CAA CWA
and State .standards. '
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

« Extraction technologies were not expected to meet remediation goals.
• Low temperature thermal stripping was eliminated for lagoon wastes because it was
not expected to meet remediation goals.

Standard technologies eliminated because of cleanup goals include:

« On-site landfill would not be in compliance with Pennsylvania hazardous waste facility
criteria in Title 25, which prohibit the construction of a hazardous waste landfill over
limestone or carbonate formations.
468
-7-
-------
14. Were treatability studies conducted on the innovative technology or standard technology?

Vault Waste: Treatability studies were conducted for cement/lime-based fixation and
incineration technologies. These studies examined the effectiveness of these technologies on
lower vault waste. Cement/lime-based fixation was shown to reduce the arsenic teachability of
the waste to below RCRA land disposal requirements. Incineration followed by cementAime-
based fixation was found to destroy all the organics and reduce arsenic mobility within levels
necessary to comply with RCRA hazardous waste regulations. A treatability study was also
carried out to test the effectiveness of clay pelletizing/sintering and results showed that this
technique was not applicable to site contaminants. | •.•'.",
' . _ ' / '
Lagoon Waste: A treatability study was conducted to study the effectiveness of incineration
followed by cement/lime-based fixation methods on lagoon waste. According to study results,
these technologies would reduce arsenic mobility to comply with land disposal restrictions.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Vault Waste: ,

Proven reliability ••,,.'

Lagoon Waste:

Proven reliability
Preference for treatment (vs. containment)

' '
16. How are measures compared?

Vault Waste: Treatability studies were conducted to test the effectiveness of fixation and
incineration of site media and contaminants. Also, microencapsulation (RAA-3) was
considered less reliable than other technologies since there is limited; date concerning its
effectiveness for immobilizing arsenic and organics.

Lagoon Waste: Treatability studies were conducted to test the reliability of fixation of site
sludge. Also treatment was preferred over containment as it was considered a more permanent
and long-term solution because site contaminants would be permanently reduced and no long-
term maintenance would be required.

! ' '
• . .!'•'
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The site geology was primary in selecting a remedial alternative. The site is underlain by
carbonate (limestone) bedrock and studies by the Pennsylvania Topographic and Geologic
Survey have shown that the limestone can be dissolved by infiltratirijg rain water and ground
water. Over time, this could destabilize the overlying rock and soil pausing them to cave in
''
469
-------
(sinkhole collapse). Therefore, on-site landfllling was not preferred because of the potential

for landfill failure due to sinkhole formation. - ~ \

' i ' .if
>
471
-9-
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Whitmoyer Laboratories
OU-3

Jackson Township, Pennsylvania
Region 3
GENERAL SITE INFORMATION

1. " What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Arsenic 28,200
Aniline 72
n-Nitrospdiphenylamine 170
Tetrachloroethene 14
Trichloroethene 0.87
1,2-Dichloroethene 0.84
Benzene , 0.85
Pyrene 25
Benzo(a)pyrene 74
Benzo(b)fluoranthene 84
Indeno(l,2,3-cd)pyrene 75
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 116,000 cubic yards of soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/84
6/86
2/90
12/17/90
Background

EPA Fund-lead !
PRPs: Rhom & Haias zind SmithKline
Beecham |
FS prepared by: Ebasco Services Inc.
3. What type of site is this? ' ' \

Pharmaceuticals. An abandoned pharmaceutical manufacturing facility in a predominately
agricultural and rural setting.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?\

Standard technologies considered during the identification and screening of technically feasible
technologies were:
-1-
471
-------
472
Access restriction:
Containment:
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Fencing, deed restrictions
Capping (semipermeable, clay, bentonite, cement, asphalt, synthetic
membranes, slurry wall, concrete walls, erosion control, clay
pelletizing/sintering
Fixation, microencapsulation, macroencapsulation, neutralization
Dewater, sedimentation, detonation, solids processing -
Incineration
Bulk excavation, discrete removal, dredging, landfilling (hazardous,
non-hazardous), recycling, consolidation
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: • . • • •*

Biological treatment: Biodegradation (aerobic, anaerobic, in situ, ex situ)
Phys/Chem treatment: Oxidation, reduction, dechlorination, in situ soil flushing, ex situ
solvent extraction, wet air extraction, in situ vapor extraction
Thermal treatment: Pyrolysis, low-temperature thermal stripping, vitrification (in, situ, ex
situ), in situ radio frequency heating -

6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Typically, after the RAAs
have been formulated, costs are estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, no three-criteria evaluation was conducted of RAAs and the estimated
costs were calculated during an evaluation based on nine criteria established by the NCP.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-6
Innovative Technology
Bulk excavation/fixation of soil con-
taining contaminants in excess of
"principal threat'Ybiodegradatiqn of
soil with organic contaminants in
excess of "principal threat" cleanup
levels/consolidate soil containing con-
taminants in excess of unsaturated
soil cleanup levels in vadose zone/
treated soil disposed at off-site
intermediate landfill
Estimated Costs
3 Criteria
N/A
9 Criteria
$25,000,000
-2-
-------
Alternative
RAA-8
RAA-9"
Innovative Technology
In situ vitrification of soil with
"principal threat'Vconsplidate and imper-
meable cap on soil with 450 to 1000
mg/kg arsenic/consolidate in vadose
zone soil with 210 to 450 arsenic/soil
cap on any remaining arsenic-
contaminated soil
Soil flushing/three-year pilot study
Estimated Costs
3 Criteria
N/A
' ' 1
N/A
9 Criteria
$44,000,000
N/A .
This alternative was developed by the former site owners and was first presented in the
Proposed Plan.
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
, (selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4A

Standard Technology
No action
Soil Capping
Excavate soil in excess of ground
water-based cleanup levels/consolidate
into vadose zone on site/clay cap/soil
cap over remaining soil with arsenic in
excess of 21 mg/kg
Bulk excavation/soil containing con-
taminants exceeding "principal threat"
disposed off site/soil with concentra-
tions greater than ground water-based
unsaturated soil cleanup levels placed in
intermediate landfill/remaining con-
taminated soil taken off site to
nbnhazardous landfill
Estimated Costs
3 C'riteria
N/A
N/A
N/A
N.A
9 Criteria
$56,000
$4,450,000
$8,300,000
$80,000,000
-3-
473
-------
Alternative
RAA-4B
RAA-4C
RAA-5
Standard Technology
Bulk excavation/soil containing con-
taminants exceeding "principal threat"
disposed off site/soil with concentra-
tions greater than ground water-based
unsaturated soil cleanup levels placed in
intermediate landfill/remaining soil
exceeding ground water-based saturated
cleanup levels relocated to vadose zone/
soil remaining with greater than 21
mg/kg covered with soil cap .
Bulk excavation/soil containing con-
taminants exceeding "principal threat"
disposed off site/soil with concentra-
tions greater than ground water-based
unsaturated soil cleanup levels placed in
vadose zone with impermeable cap/soil
in excess of saturated soil cleanup
levels consolidated to vadose zone
Bulk excavation/soil containing con-
taminants exceeding "principal threat"
fixed and disposed off site/soil with
concentrations greater than unsaturated
soil-based soil cleanup levels con-
solidated in vadose zone and capped
RAA-7 Bulk excavation/incineration of soil
with contaminants exceeding "principal
threat" cleanup levels/fixation of soil
with arsenic concentrations greater than
1,000 mg/kg/consolidation and imper-
meable cap for soil with arsenic concen-
trations of 210 to 1,000 mg/kg/soil
cover over surface soil in excess of 21
mg/kg arsenic
8, If a standard technology was chosen, why?

Capping, a standard technology was chosen (see below).
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$39,000,000
$33,000,000
$27,000,000
$32,000,000
9. If an innovative technology was chosen, why?
474
RAA-6 was chosen because it reduces site risk by immobilizing arsenic in the heavily
contaminated soils with iron fixation and it eliminates organics through bioremediatiori.
Though metals will not be destroyed, the long-term risk will be reduced since the treated soil
-4-
-------
will be disposed of in an off-site landfill, thereby permanently removing them from the site.
Moderately contaminated soil will be consolidated and capped with an impermeable cap,
which will reduce the mobility of contaminants. A soil cover will be placed over site soils
with low levels of arsenic. Deed restrictions also will help prohibit access to the soil. This
alternative minimizes short-term risk since heating is not involved. The technologies proposed
in the alternative are proved, treatability studies showed that fixation irnmobilizes arsenic in
the soil and allows biodegradation to occur. Remediation equipment is readily available.
RAA-6 will attain all ARARs and is cost-effective.
" ' ! •

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '

Innovative technologies eliminated during the initial screening include |the following: ,

• Dechiorination was eliminated because the process would not be applicable to the
primary site contaminants.
• Clay pelletizing/sintering was eliminated because the process would not be applicable
to the site's primary contaminants. I
• Anaerobic ex situ biodegradation was eliminated because the process would not be
applicable to the site's primary contaminants.
• ! In situ radio frequency heating was eliminated because the process would not be
independently applicable to the site's primary contaminants and in situ treatment
typically involves only one process option.
• In situ vapor extraction was eliminated because the process would not be
independently applicable to the site's primary contaminants and in situ treatment
typically involves only one process option.
• In situ biodegradation was eliminated because the process would not be independently
applicable to the site's primary contaminants and in situ treatment typically involves
only one process option.

Innovative technologies eliminated during the screening, of the three criteria include the
following:
• i .
• Ex situ solvent extraction was eliminated because a treatability study showed that its
effectiveness would be uncertain and require long contact time, which would make
subsequent dewatering very difficult. , .
'• Wet air oxidation was eliminated because effectiveness might be limited by the site's
low concentrations of organics. Iron and arsenic also might interfere with the process.
• Oxidation was eliminated because treatability studies showed piat the process would
- not meet remedial objectives.
• Reduction was eliminated because it would not be effective for treating the organics at
the site. While it could be a component of soil washing, treatabillity studies showed
that the process would not meet remedial objectives,
• Pyrolysis was eliminated because it could produce arsine, a more mobile: and toxic
form of arsenic. Arsine, a noncondensable gas, could lead to a significant discharge of
arsenic to the atmosphere and pose risks to human health and the environment. If

475
.'.•.. • -5- • j. '
-------
treatment occurs off site, transportation and treatment permits would be required.
Also, there is limited availability of equipment for on-site pyrolysis
• Low temperature thermal stripping was eliminated because a previous EPA study
(1988) showed that the low temperatures would not be high enough to remove PAHs
that have higher boiling points.
" In situ soil flushing was eliminated because the treatability study showed that its
effectiveness would be uncertain due to the limited availability of appropriate lixiviants
to mobilize arsenic. Further the heterogeneity of the soils and the fractured bedrock
could make it difficult to capture the lixiviant and result in mobilization of the
contaminants.
• In situ vitrification was eliminated because arsenic could volatilize, treatment
equipment and skilled workers would be available but limited, and it is costly.
« Aerobic ex situ biodegradation was eliminated as a single-treatment technology
because it would not address arsenic. It was retained, however, for consideration in a
treatment train.

Innovative technologies eliminated during the detailed analysis include the following:

« In situ soil flushing was reintroduced as a technology by the former site owners in the
proposed plan. It was not chosen because it would require 3 years of testing prior to
implementation, and it would leave contaminants on site that could contaminate ground
water in excess of MCLs. These also was concern that it would be difficult to capture
the flushing solution and that it would take a very long time (10,000 to 24 000 years)
to reach cleanup levels.
• In situ vitrification was eliminated because it would pose short-term risk, would be
more costly than the chosen alternative, and there might be limited availability of
skilled workers and treatment equipment.

11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
^ meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology? '

The criteria that were most heavily weighted in selecting a remedial alternative were long-term
effectiveness, short-term effectiveness, and cost. The chosen alternative provides long-term
effectiveness since it treats and thereby permanently eliminates organics through
biodegradation and immobilizes metals through fixation. Cost-effectiveness was a factor since
both RAA-2 and RAA-3 were eliminated, even though they were less costly, because they did
not provide permanent treatment and would not be as effective protecting human health and
the environment in the long-term. Alternatives RAA-4A, RAA-4B, RAA-4C, and RAA-5
were eliminated because they would be more costly. RAA-7 (incineration) and RAA-8 (in situ
vitrification) were eliminated because they were more expensive and they posed short-term risk
due to the release of volatile organics during heating.
Wer£ selected? V the cl™™P goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels were derived for surface soils based on direct exposures. Other soils (saturated
unsaturated (vadose.zone), and principal threat soils) were thought to threaten ground water '
quality, and therefore cleanup levels were developed
476
-------
Surface Soil
Contaminant
Cleanup Level (rag/kg)
ARAB: or Other Basis
Carcinogens
Arsenic ,
Benzene
Trichloroethene
Tetrachloroethene >
Benzo(a)pyrene
Benzo(b)fiuoranthene
Nitrosodiphenylamine
Aniline
Indeno( 1 ,2,3-cd)pyrene
21
14
38
8.2 .
0.13
0.93
85
73
0.56
Bisk8,
Ilisk
Risk
Risk
Risk
Risk
msk
Risk
Risk
Noncarcinozens
Pyrene
Trans- 1,2-
dichloroethene
1.6
1,000
Risk
Risk
. l . • .. I • • ,
"Risk-based cleanup levels correspond to an excess lifetime czincer risk of 1 x 10"
posed by the surface soils following remediation under the residential use scenario.
For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.

Saturated Soil ! .
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Benzene
Trichloroethene
Tetrachloroethene
Benzo(a)pyrene
Benzo(b)fluoranthene
Nitrosodiphenylamine
Aniline
Indeno(l ,2,3Tcd)pyrene
210
0.002
0.004
0,012
0.104(0.66)"
0.25 (0.66)
0.02 (0.66)
0.002(0.66)
0.52(0.66)
Ground water2
Ground water
Ground water
(Ground water
Ground water
Ground water
Ground water
Ground water
Ground water
-7-
477
-------
478
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Noncarcinogens
Pyrene
Trans-1,2-
dichloroethene
0.033 (0.66)
0.037
Ground water
Ground water
'Soil cleanup levels correspond to concentrations that would not cause ground water to
exceed MCLs, or 10* excess cancer risk if MCLs do not exist.
"Numbers presented parenthetically represent the practical detection limit.

Unsaturated (vadose zone) Soil
Contaminant
Cleanup Level (mg/kg) ARAR or Other Basis
Carcinogens
Ground water2
Ground water
Tnchloroethene
Ground water
Tetrachloroethene
Ground water
Benzo(a)pyrene
Ground water
Benzo(b)fluoranthene
Ground water
Nitrosodiphenylamine
Ground water
0.009 (0.66)
Ground water
Indeno(l ,2,3-cd)pyrene
Ground water
Noncarcinogens
Ground water
Trans-1,2-
dichloroethene
Ground water
)
•Soil cleanup levels correspond to concentrations that would not cause ground water to
exceed MCLs, or 10'6 excess cancer risk if MCLs do not exist.
"Numbers presented parenthetically represent the practical detection limit.

Principal Threat (heavily contaminated) Soil
Cleanup Level (mg/kg) ARAR or Other Basis
-8-
-------
13.
14.
ARAR IDF Other
Cleanup Level (ing/kg)
Contaminant
Trichloroethene
Tetrachloroethene
Benzo(a)pyrene
Benzo(b)fluoranthene
Nitrosodiphenylamine
Indeno(l ,2,3-cd)pyrene
Noncarcinogens
Trans-1,2-
dichloroethene
-Cleanup levels are based on leachate .concentrations , exceeding -RCRAtoxicity
characteristic levels, if available, or 100 time the W excess ciancer nsk in ground
water. Cleanup levels followed by an asterisk (*) were derived using TCLP
methodology. All others were based on equilibrium partitioning using Koc and TOC.

I ' *
Was ^innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ,-' j

Innovative technologies eliminated because of cleanup goals include:

• Soil flushing ,

Standard technologies eliminated because of cleanup goals include: !

• -.-"..'
• Capping •-,'...-

Were.treatability studies conducted on the innovative technology or standard technology?

Treatabilitv studies were conducted to assess the effectiveness of several technologies
SSS^oning. chemical oxidation, and fixation. According |to the results ehem«d.
oxidation and 3oil washing would not be appropriate technologies ^^^
studies also showed that iron fixation immobilized the arsenic in the soil and allowed
biodegradation to take place.
75. What measures/criteria were used to compare alternatives?

The following measures were used p compare the alternatives:

-9-
479
-------
Cost ,
Time to design/construct/operate
Proven reliability
Single versus multistep treatment
Preference for treatment (vs. containment)

16. How are measures compared?

The chosen alternative was considered protective and effective in the long term because it
treats site contaminants. Treatment was preferred over containment because it is more
effective in the long term and the potential for sink holes or erosion in not as great Of the
treatment alternatives, the chosen alternative is the least expensive. A rnultistep treatment was
preferred because it better addresses the mixture of site contaminants. In fact, biodegradation
was eliminated as a process to be used in isolation but was retained for consideration in a
treatment tram. Proven reliability and time to implement also were considered The chosen
technologies, fixation and biodegradation, were preferred because they had proved to be
applicable in treatability testing. Conversely, soil flushing was eliminated because it would
require extensive testing and would take too long to reach cleanup levels.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The heterogeneity of the soil precluded the use of soil flushing. This consideration, however
was not primary in selecting a remedial technology. ' ^"^ "Y

Reference: , '
r of Surrogate Soils—Bench-Scale
Tests, PEI and IT Corp., Contract No. 68-03-3389.
4SO
-10-
-------
Agricb Chemical Co.
OU-1

Pensacola, Florida
Region 4
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

SoiUSludge (mg/kg)
2.
Lead
Fluoride
Arsenic
46,000
510,000
58
What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 420,800 cubic yards of soil
» 32,500 cubic yards of sludge
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
10/4/89
4/30/92
9/29/92
Background
i' '
PRP-lead
PRPs: Conoco Incorporated, Freeport
McMoRan Inc.
FS prepared by: Gcraghty & Miller,
Inc.
3. What type of site, is this?

Agricultural Chemicals. A former sulfuric acid and fertilizer production plant. The site is
bordered by industrial and residential areas.
TECHNOLOGY SELECTION ' - ,
••• " '•' ' : "•!'''

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification arid screening of technically feasible
technologies were:

Access restriction: Fencing, deed restrictions
Containment: Capping (soil, synthetic, multimedia), slurry wall, high-density
polyethylene barrier, clay wall, sheet pile surface water diversion,
grading, berms, channels
Chemical treatment: Solidification/stabilization

. .• -1- "•' ' •
481
-------
Thermal treatment:
Disposal:
Thermal treatment (not specified)
Excavation, on-site disposal in RCRA vault, off-site disposal at RCRA
facility
5, Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation
Chemical treatment: Soil washing

6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-8
RAA-9
Innovative Technology
Clay cap/soil washing/institutional
controls
RCRA vault/soil washing/institutional
controls
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$28,488,000
eliminated
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action/deed restrictions
Limited action/deed restrictions/access
restrictions
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
eliminated
$274,000
432
-2-
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
RAA-10
RAA-11
Standard Technology
Clay cap/stabilization/institutional
controls
RCRA cap/slurry wall/stabilization/
institutional controls
RCRA vault/stabilization/institutional
controls
Soil cover/stabilization/institutional
controls
Clay cap/slurry wall/stabilization/
institutional controls
Clay cap/off-site disposal/institutional
controls -
Stabilization/off-site disposal/
institutional controls
Estimated Costs
3 Criteria
•N)A
i
N|A
; N/A
1
N^A "
I
Nl/A
N/A
N/A
i '
9 Criteria
eliminated
$10,730,000
eliminated
eliminated
$10,510,000
$39,946,000
eliminated
8. If a standard technology-was chosen, why? \

RAA-4 was chosen because it reduces site risks to acceptable levels. .It provides acceptable
levels of overall protection through extraction and treatment of contaminated soil/sludge, it
prevents dermal contact with and ingestion of contaminated soil/sludge, and minimizes
infiltration of surface water and the resulting generation of leachate. Institutional controls
implemented with this alternative further reduce exposure to on-site contaminants. This
alternative minimizes short-term risk. The alternative meets,the statutory preference for
treatment through stabilization of contaminants. Stabilization in conjulnction with institutional
controls provides a permanent solution by reducing the mobility of site contaminants. The
RCRA cap proposed in this alternative was preferred to the clay cap proposed in others
because it offers a greater degree of protection. Implementation of this alternative achieves
ARARs! The chosen remedy employs a proven technology which can be easily implemented
at the site. This technology provides the most cost-effective treatment when compared to the
other alternatives because of its ability to treat most effectively and limit further spread of
contamination. The chosen remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-effective? mzinner for contaminant
treatment at the site.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
-3-
483
-------
10,
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

« Biodegradation was eliminated because it would not be an effective technology for
inorganic compounds which make up the majority of site contaminants.

Innovative technologies eliminated during the screening of the three criteria include the
following:

* None

Innovative technologies eliminated during the detailed analysis include the following:

• Soil washing was eliminated because it would pose short-term risk to the community
from excavation and to site workers because of required soil handling. This increased
short-term risk reduced its overall protectiveness as compared to the chosen alternative
It would be more difficult to implement than the chosen alternative because it poses
additional logistics problems. Implementation of this technology would require
adherence to strict operational procedures and a stringent monitoring and health safety
plan to protect the community during remediation activities. It is an emerging
technology that has not been put to wide-spread commercial use and therefore would
require treatability studies.
m
n.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Long-term effectiveness, short-term effectiveness, and implementability were the criteria most
heavily weighted in selecting a remedial alternative. Other alternates (RAA-8 and RAA-10)
which offered greater long-term protection were eliminated because the short-term risk they '
would pose would reduce their overall protectiveness. RAA-4 was preferred over RAA-7
because it would offer greater long-term effectiveness since it proposed a RCRA cap instead of
a clay cap. ,

One innovative technology, soil washing (RAA-8), was eliminated because it would pose
short-term nsk during excavation and treatment in excess of that posed by the chosen
alternative. It also would pose more implementation difficulties than the chosen alternative
484
-4-
-------
12.
13.
What cleanup goals were selected? I/the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? |
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Lead
Arsenic
_ 500
16
UBKa
Risk"
Noncarcinogens
Fluoride
1,463 -
Model0
The lead cleanup goal was determined by the lead uptake/biokinetic model (UBK),
which predicts the concentration that would result in 95 percent of the hypothetical
future child residential population having a blood lead concentration less than the
Agency benchmark of 10 ug/dL.
This cleanup level is based on an industrial scenario at the 1C]"6 risk level based on
ingestion and inhalation pathways. '
This cleanup level is based on protection of ground water andl was determined by the
Summers Model.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14, Were treatability studies conducted on the innovative technology or standard technology?

A treatability study was conducted to investigate the effectiveness of isolidification/stabilization
for treatment of the contaminated site soil and sludge.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Proven reliability
Impact on nearby populations
-5-
485
-------
16, How are measures compared?

The chosen alternative was preferred because it offers comparable overall protection to other
alternatives with less short-term risk to the community. If fact, other alternatives that would
offer greater long-term protectiveness were deemed to have less overall protectiveness.because
they would pose short-term risk to the community. The chosen alternative had the lowest
present worth cosi The chosen alternative was preferred because it utilizes a proven
technology that can be easily implemented without further development, while soil washing
(RAA-8), an innovative technology, has not been put to widespread commercial use arid might
require treatability studies.
17.
What technical considerations were factors in selecting a remedy? Were .technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
486
-6-
-------
Alabama Army Ammunition Plant (AAAP)
OU-1, Soil Stockpile Area

Talladega County, Alabama
Region 4
GENERAL SITE INFORMATION

7. What were the principal contaminants,
- contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil(mg/kg)

2,4,6rTrinitrotoluene
2,4-pinitrotoluene
2,6-Dinitrotoluene
2,4,6-tirinitrophenyl-
methylnitramine
Lead
Asbestos
6.06 ug/g
1.18 ug/g
0.68 ug/g

6.94 ug/g
185,000
<1 percent
chrysotile
Site History
NPLProposed:
NPL Final:
..FS:,- • ••• "•-
ROD:
1984
1987
10/25/91
12/31/91
Background

Federal Facility ,
PRPs: U.S. Army ICorps of Engineers
FS prepared by: .Mfesfoh Services, Inc.
What volume of material is to be remediated?

The volume of material to be remediated included: "
. I:

• 24,300 to 25,650 cubic yards of soil
• 1,350 to 2,700 cubic yards of asbestos containing material (ACM)
What type of site is this?

Chemicals and Allied Products., The site was used to manufacture explosives and chemicals.
The site is presently in an inactive caretaker status with controlled access. Surrounding, land
use is a mixture of recreational and industrial.
TECHNOLOGY SELECTION . . .

4. What standard technologies were considered for selection in this FS?
• • ' , ' ' i
Standard technologies considered .during the identification and screening of technically feasible
technologies were: •
-1-
487
-------
Soil

Access restriction: Fencing, access restriction signs
Containment: Cap
Phys/Chem treatment: Stabilization (cement, lime-based or pozzolanic, thermosetting organic
polymer)
Thermal treatment: Incineration (rotary kiln, infrared, fluidized bed, circulating bed), high
temperature electrically powered pyrolytic reactor (advanced electric-x
reactor, electric pyrolyzer)

Asbestos Containing Material

Disposal: On-site disposal, off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Chemical treatment: Critical fluid solvent
Thermal treatment: Molten salt destruction
What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into RAAs.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology
No action
Estimated Costs
3 Criteria
N/A
9 Criteria
$0
488
-2-
-------
Alternative
RAA-2
RAA-3
Standard Technology
Separation of soil and asbestos-
containing material (ACM)/on-site
thermal treatment (rotary kiln,
infrared, or fiuidized bed) of soil/
possible stabilization of fly ash or
treated soil/on-site disposal of treated
soil/topsoil cover/off-site disposal of
ACM'
Separation of soil and asbestos
containing material (ACM)/off-site
thermal treatment of soil/possible
stabilization of fly ash or treated
soil/off-site disposal of treated soil/off-
site disposal of ACMb
Estimated Costs
1
3 Criteria
N/A
• 1-"
l
. r
i
• i
N/A
i
i
^1 ' '
i ' .
9 Criteria
$10,672,400
to
$16,736,100b
$68,139,550
. \
Currently, an asbestos repository exists at the AAAP. If this repository is approved for
asbestos disposal, it will be considered for the disposal of ACM.
''No choice is made between the three incineration technologies. Alsol costs do not include
stabilization because it is not presently known how much material will require stabilizing.
Stabilization costs are estimated at $250 per cubic yard. i
8. . If a standard technology was chosen, why?

On-site thermal treatment and on-site disposal were chosen because nib waiting period is
involved for implementation (a 3- to 5-year waiting period exists for off-site thermal
treatment); the remedy does not require off-site transportation of contjiminated soils, thereby,
eliminating the risks from spillage and dust emissions; the remedy is easily implemented since
no waiting period or off-site transportation is required; and the cost of the remedy is
substantially lower, an estimated 15 to 25 percent less than the cost of the other remedial
alternative. ' * •
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage Was the innovative
technology eliminated? ,
. -t ••' -
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
-3-
489
-------
Innovative technologies eliminated during the initial screening include the following:

« Molten salt destruction was eliminated because the technology has not been developed
to the point where it could be implemented for a large-scale facility-wide cleanup. In
addition, molten salt destruction would not be suitable for wastes with a high ash
content because frequent bed recycling and replacement would be required.
• Critical fluid solvent extraction was eliminated because it is an emerging technology
that has not been extensively tested for nitroaromatic compounds. ' •

Innovative technologies eliminated during the screening of the three criteria include the
following: . .

" None

Innovative technologies eliminated during the detailed analysis include the following:

• None
77, Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Short-term effectiveness, implementability, and cost were the criteria weighted most heavily in
selecting a remedy. The remedy does not involve transporting contaminated spils off site,
thereby eliminating the risks due to spillage and dust emissions. Implementability was •
important; alternatives that require no waiting period (there is a 3- to 5-year waiting period for
capacity in an off-site incinerator) and no off-site transportation are easier to implement. Cost
was important in that the selected remedy is substantially less expensive, an estimated 15 to 25
percent less than the cost of the other remedial alternative.
12. What cleanup goals were selected? If the cleanup goal was. based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup of the explosives 2,4,6-trinitrotoluene, 2,4-dinitrotoluene, 2,6-dinitrotoluene, and
2,4,6-trinitrophenylmethylnitramine was based on removing reactivity as determined under
RCRA. , .
490
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Lead
Asbestos (in bulk soil)
5.0 mg/L in TCLP
extract
None if concentration
less than 1%
RCRA
TSCA 40 CFR 763
-4.
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? \

Innovative technologies eliminated because of cleanup goals include:

• None . '

Standard technologies eliminated because of cleanup goals include:

I
• None i ,
• ' " ''••.-• \. '-'-
. - . - , ' \- ' '
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. !
75. What measures/criteria were used to compare alternatives?
' i •
The following measures were used to compare the alternatives: -

Risk level achieved i
Total cost ''.'.. \
Time to design/construct/operate i
i
• - | ...

76. How are measures compared?
i-..
Off-site and on-site treatment were compared in the^above three catejgories. On-site treatment
had a lower short-term risk because no off-site transportation was required. The total cost of
on-site treatment was substantially less than that of off-site treatment: And there was a 3- to
5-year waiting period for off-site treatment compared to no wait for pn-site treatment.
- • ' . .• . .-!•..•••.• ^

17. What technical considerations-were factors in selecting a remedy? Were, technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. Qhe innovative technology,
molten salt destruction, was eliminated partially because of the high ash content of soil.
-5-
491
-------
Arlington Blending and Packaging
<<; in
Arlington, Shelby County, Tennessee
Region 4
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface Soil (pg/kg)

Arsenic 370,000
Chlordane 390,000
Endrin 70,000
Heptachlor 920,000
Heptachlor Epoxide 20,000
Pentachlorophenol 130,000

Subsurface Soil (pg/kg)

Chlordane 120,000
Endrin 20,000
Heptachlor 34,000
Heptachlor Epoxide 170
Pentachlorophenol 8,500

Sediments (pg/kg)

Chlordane 41,000
Heptachlor 2,800
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
7/1989
1/18/1991
6/28/1991
Background

EPA Fund-lead
PRPs: Arlington Blending and
Packaging
FS prepared by: Ebasco Services Inc.
'
2. What volume of material is to be remediated?

The volume of material to be remediated included:

» 24,000 cubic yards of soils/sediments
5.
492
Wliat type of site is this?

Agricultural Chemicals. An abandoned blending and packaging facility where pesticides,
herbicides, and other types of chemicals were formulated and packaged. Located in a
predominantly agricultural and rural setting, it is bordered on the west by a Tennessee
Department of Transportation facility and on the east by a residential housing development.
-1-
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Soil/Sediments

Access restriction:
Containment:
Chemical/physical:
Thermal treatment:
Disposal:
Deed restrictions, fencing, soil and ground waiter monitoring
Capping (RCRA type), vertical barriers (slurry walls)
Solidification
Incineration (rotary kiln, infrared)
Excavation, extraction, disposal at RCRA-perrnitted facilities (on and
off site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening; of technically
feasible technologies were:
Soil/Sediments ,

Biological treatment:
Chemical treatment:
Thermal treatment:
In situ biodegradation, slurry-phase soil bioremed:
In situ soil flushing, soil washing
Pyrolytic incineration, low-temperature thermal
Model 200), in situ vitrification
iiation

1 treatment (X*TRAX
«.
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible tecl nologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives .that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; arid community acceptance. Costs were recalculated in the ROD.
-2-
493
-------
Cost Estimates for RAAs That Include Inn -vative Technologies
(selected remedial alternative i : bold)
Soil/Sediments

Alternative
RAA-5" and
RAA-5A"

•
Innovative Technology
Excavation/on-site low-temperature
thermal treatment/solidification/ on-
site backfilling of contaminated
soils/activated carbon treatment and
discharge of ground water to surface
water or POTW
Estimated Costs
9 Criteria
$9,568,204
(RAA-5)

$9,325,909
(RAA-5A)

ROD
$12,170,167
(RAA-5)

$11,923,774
(RAA-5A)

'RAA-5 would utilize approximately 15 extraction wells for removal of contaminated ground
water from the site whereas RAA-5A would utilize approximately 8 extraction wells.
'This technology is called ex situ thermal desorption in the ROD.
7, How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Soil/Sediments
494
Alternative
RAA-1
RAA-2
RAA-3" and
RAA-3A"
RAA-4" and
RAA-4A"
==3=S==
Standard Technology
No action/ground water monitoring
On-site cleaning caps/land use controls/
fence maintenance/ monitoring
Excavation/off-site incineration/
solidification/landfilling of contaminated
soils and building debris/activated
carbon treatment and discharge of
contaminated ground water to POTW
Excavation/on-site incineration/
solidification/on-site backfilling of
contaminated soils/off-site disposal of
building debris/activated carbon
treatment and discharge of contaminated
ground water to surface water or POTW
Estimated Costs
9 Criteria
$216,542
$68i;683
$37,040,675
(RAA-3)
$36,783,180
(RAA-3A)
$18,067,120
(RAA-4)
$17,885,427
(RAA-4A)
ROD
$249,023
$762,406
$41,348,205
(RAA-3)
$41,086,379
(RAA-3A)
$21,924,186
(RAA-4)
$21,679,158
(RAA-4A)
•-
"RAA-3 and RAA-4 would use approximately 15 extraction wells for removal of contaminated
ground water, whereas RAA-3A and RAA-4A would use approximately 8 extraction wells.
-3-
-------
m
8. If a standard technology was chosen, why? - , ' ' ;
1 ' " ' ' 'i ' • r i
Solidification/stabilization was selected in the ROD for some wastes.
.. - , . • -: •; • - - • •

9. If an innovative technology was chosen, why? , :• I .
• '.'•' • • ' ' ' i
RAA-5 was selected because this alternative will immediately remove exposure pathways to
the public. All the treatment components proposed are readily available and have been
demonstrated to be effective in removing the contaminants of concern 'at the site. The chosen
innovative technology (low-temperature thermal treatment) will permanently remove organic
compounds from contaminated soils. This technology reliably removes pesticides and
pentachlorophenol from contaminated soils with efficiencies in excess ^>f 99 percent as
required by RCRA regulations, with no expected significant risks frond products of incomplete
combustion; Dechlorination of residuals was selected in the ROD. The chosen innovative
thermal treatment is more desirable than the standard thermal treatment of RAA-4 (on-site
incineration) because it starts up and shuts down faster and it substantially reduces the waste
volume. Also, once organic contaminants have been physically separated from site soils,
process water will be further treated at the site's wastewater treatment facility. The off-gas
will be scrubbed by passing it through beds of activated carbon before its release to the
atmosphere, thus further reducing the toxicity of contaminated soils. In addition, this
alternative complies with all applicable ARARs. For the wastes that cannot be treated to meet
the applicable RCRA Land Disposal ^Restrictions, a Treatability Variance will be sought
pursuant to 40 CFR 268.44(h). Also, short-term risks associated with implementing RAA-5
are lower than with RAA-4 because the contaminants do not come into contact with a direct
flame or with fuel combustion products. Numerous vendors are available to furnish and to '.
operate the treatment equipment. RAA-4 was selected as a contingency remedy.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .

• None , j ' " •
• ^ • . 'h '
I . - . . .'
Innovative technologies eliminated during the screening of the three cijiteriia include the
following: _
•-,
--- / i .
• Pyrolytic incineration was eliminated because it has not been demonstrated
commercially on CERCLA wastes. The application of this technology is contingent
upon the successful demonstration of treatability studies.
• In situ vitrification was eliminated because it requires too much energy and is too
costly. This technology has limited economic practicability in the site's soil with

4- 495
-------
variable permeability and ground water because of the energy requirements for driving
off water.
» In situ soil flushing was eliminated because of the potential for adverse environmental
effects and anticipated difficulty in implementation due to site-specific characteristics.
Variable geology and a downward ground water gradient would prevent complete
recovery of the extraction fluids. ,
» Soil washing was eliminated because site-specific conditions limit the effective
implementation of this technology. The high clay content of the soil would limit the
effective treatment of the washing fluids.
» In situ biodegradation was eliminated because it has not been shown to be effective
against pesticides such as chlordane and heptachlor. Pertinent information concerning
biodegradation of pesticides has not been identified. Test results to date have been
inconclusive.
H Slurry-phase soil bioremediation was eliminated since it has not been proved effective
with the contaminants of concern. A treatability study would be required to establi .-
potential degradation rates for site-specific contaminants and to control and manipulate
environmental factors to develop the optimum bioremediation result.

Innovative technologies eliminated during the detailed analysis include the following:

« None
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting an innovative remedial technology for this site
were the protection of human health and the environment, and long-term effectiveness and
permanence. The ROD states, however, that the selected remedy (RAA-5) provides the best
balance of all nine criteria. , .
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? '

Surface Soil
496
Contaminant
On-site Cleanup Level
(Mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Chlordane
Heptachlor
Heptachlor Epoxide
Pentachlorophenol
25,000
10,000
3,000
2,000
635
Risk3
Risk"
Risk"
Risk"
EPAC
-5-
-------
Contaminant
On-site Cleanup Level
ARAR or Other Basis
Noncarcinogens
Endrin
2,700
EPAC
The cleanup level for arsenic was derived on the basis of health-based risk and ground
water protection. •
bCleanup levels are health-based and reduce risk to less than JO'5. * • •
°Value calculated by EPA Region 4 using available empirical data and model analysis
(model not specified).
Contaminant
Carcinogens
Arsenic
Chlordane
Heptachlor
Heptachlor Epoxide ' ,
1 Pentachlarophenol
Noncarcinogens
Endrin
Off-site Cleanup Level
(Mg/kg)

25,000
1,000
300
200
635

2,700
ARAR

/
or Other Basis

Risk3
Risk"
. Risk"
Risk"
EPAC

EPAC
The cleanup level for arsenic was derived on the basis of hesilth-based risk and ground
water protection. ;
bCleanup levels are health-based and reduce risk to less than 10"6.
cValue calculated,by EPA Region 4 using available empirical data and model analysis
(model not specified). !_

Subsurface Soil I
Contaminant
Carcinogens
Chlordane
Heptachlor
Heptachlor Epoxide
Pentachlorophenol
On-site Cleanup Level
(ug/kg)
v
3,300
3,000
2,000
635
ARAF

or Other Basis

EPA"
Risk"
Risk"
EPA"
-6-.
497
-------
498
Contaminant
On-site Cleanup Level
(jag/kg)
ARAR or Other Basis
Noncarcinogens
•Value calculated by EPA Region 4 using available empirical data and model analysis
(model not specified).
bCleanup levels are health-based and reduce risk to less than lO'5.

'
Off-site Cleanup Level
Contaminant
ARAR or Other Basis
Carcinogens
Chlordane
Heptachlor
Heptachlor Epoxide
Pentachlorophenol
3,300
300
200
635
EPA1
Risk"
Risk"
EPA"
Noncarcinogens
"Value calculated by EPA Region 4 using available empirical data and model analysis
(model not specified). ' ,

bCleanup levels are health-based and reduce risk to less than 10:e.

Sediment
Contaminant
On-site Cleanup Level
(wg/kg)
ARAR or Other Basis
Carcinogens
Chlordane
Heptachlor
3,300
3,000
EPAa
EPA"
•Value calculated by EPA Region 4 using available empirical data and model analysis
(model not specified).
Contaminant
Off-site Cleanup Level
(Mg/kg)
ARAR or Other Basis
Carcinogens
Chlordane
3,300
EPAa
-7-
-------
Contaminant
Heptachlor
Off-site Cleanup Level
(Mg/kg)
300
ARAR ii>r Other Basis
!EPAb
'Value calculated by EPA Region 4 using available empirical data and model analysis
(model not specified). • !
•"Cleanup level is health-based and reduces risk to less than 10"16.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? j

Innovative technologies eliminated because of cleanup goals include:

• None ' ' • . [
-!
Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

The Proposed Plan states that a treatability study is being conducted for RAA-5 and RAA-5A
(low temperature thermal desorption) on representative site soils and debris to determine
whether the innovative technology will meet soil cleanup levels. Although the results of the
treatability study were to be available before completion of the ROD, ithis study is not
discussed in the ROD. S •
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost effectiveness '
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared? ,

The selected remedy was chosen because it provides the best balance among the criteria used
to evaluate the alternatives in the Detailed Analysis. RAA-5 achieves adequate protection of
human health and the environment and meets the statutory requirements of Section 121 of
CERCLA in a cost-effective manner. The innovative technology chosen had been successfully
tested on VOGs, polynuclear aromatic compounds, chlorinated organic contaminants, and
PCBs. Although this technology had not been fully developed, the pilot-scale units had been
successfully tested by IT Corporation, Chemical Waste Management, Inc., and Weston
Services, Inc. In addition, treatment was preferred over containment tecause it will
-8-
499
-------
permanently reduce contaminants in the site's ground water and soils, and it will provide for
long-term protection against exposure from these contaminants.

17, Wtot technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Site-specific conditions were primary in eliminating three innovative technologies Because of
the site soil's variable permeability, in situ vitrification was eliminated. In situ soil flushing
was likewtse eliminated due to the variable geology and downward gradient of the ground
water flow which prevents the complete recovery of extraction fluids. The high clay content
of the soil limits the effective implementation of soil washing at this site.
500
-------
Benfield Industries, Inc.
Hazelwood, North Carolina
Region 4
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

, Benzo(a)anthracene '33 .
Benzo(a)pyrene 14
Benzo(b or k)fluoranthene 31
Chrysene 23
Indeno(l,2,3-cd)pyrene 5.1
Naphthalene 120
Pentachlorophenol 19
3.-
Sitei History
NPL Proposed;
NPL Final:
FS:
ROD:
6/24/88
10/4/89
7/16/92
7/31/92
Background
EPA Fund-lead
PRPs: Thomas G;. Benfield
FS prepared by: B&V Waste Science
and Technology Group
What volume of material is to be remediated? '• '

The volume of material to be remediated included: '

• 4,600 cubic yards of soil

What type of site is this? -•'•..''
i,
Chemicals and Allied Products. The site was occupied by a bulk chemical mixing and
repackaging plant until it burned down in 1982. The site is surrounded by light industrial,
commercial, and industrial areas.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Land use restrictions, fencing
Containment; Capping (soil, clay, asphalt, asphaltic concrete, concrete, gravel,
• synthetic membrane, RCRA multilayer, chemical sealants), slurry wall,
-1-
501
-------
Chemical treatment:
Physical/chemical:
Physical treatment:
Thermal treatment:

Disposal:
grout curtain, vibrating beam, sheet piling, rock grouting, grout
injection, block displacement, gradient control, surface controls,
dust/vapor suppression ~
Neutralization (in situ, on-site), precipitation ,
Stabilization/solidification (lime-fly ash, portland cement), organic
contaminant stabilization/solidification, microencapsulation, Surface
encapsulation
Solids separation, decontamination ' '"'.' ' "
Incineration (rotary kiln, multiple hearth, fluidized bed, circulating bed,
high temperature fluid wall reactor, infrared)
Excavation, RCRA landfill (on-site, off-site)
5.
Was an innovative technology considered in the F$? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Landfarming (on-site, off-site), composting, slurry biotreatment, in situ
bioremediation
Physical/chemical: In situ soil flushing, oxidation (in situ, on-site), reduction (in situ, on-
site), water leaching, solvent extraction, soil washing, in situ soil vapor
extraction
Thermal treatment: Molten salt incineration, plasm arc torch, low-temperature thermal
extraction, pyrolysis, vitrification (in situ, on-site)
6. What was the cost estimate for the innovative technology? .'

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
502
Alternative
RAA-3
RAA-4
RAA-6
Innovative Technology
Soil washing/slurry biotreatment
Solvent extraction
In situ bioremediation
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$1,033,100
$2,630,500
$1,034,000
-2-
-------
7. How did the cost(s) compare to standard technologies? j

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-5
RAA-7
\ . - ... ;
Standard Technology
No action
RCRA cap
On-site incineration
Off-site incineration
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9Criteria
$100,000
$997,500
$7,262,700
$15,804,100
8.
If a standard technology was chosen, why?

A standard technology was not selected.
9. If an innovative technology was chosen, why?

The chosen alternative was preferred because it reduces risk by decreasing the toxicity,
mobility, and volume of site contaminants. In addition, by remediating to soil cleanup levels,
the technique will protect the underlying ground water. The treatment proposed, slurry
biotreatment, provides a long-term and permanent reduction of site contaminants. The
permanent elimination Of site contaminants was preferred over containment because
contaminants left on site could migrate to ground water during seasonal water table changes
when leachate would be generated. Slurry biotreatment was preferred over other innovative
treatment technologies because its effectiveness is more certain and it will reach cleanup levels
more quickly. Slurry biodegradatibn has been successfully demonstrated under the EPA SITE
program for wood preserving wastes .which have similar contaminants to those found at this
site. Slurry biotreatment was preferred over other innovative and standard treatment
technologies that offered comparable protectiveness because it was more cost-effective.
10. If an innovative technology was not chosen, why not? At what stage was the innovative .
technology eliminated? ' ' i

Innovative technologies eliminated during the initial screening includ|e the following:

• Oxidation (in situ, on-site) was eliminated because it has not been proved effective for
PAH-contaminated soils. Furthermore, contaminants may degrade into more toxic
products.--
-3-
503
-------
504
« Reduction (in situ, on-site) was eliminated because its effectiveness in tearing organics
has not been proved. "~" .""\
a Water leaching was eliminated because the site's PAH contaminants have extremely '-—/
low water solubilities; therefore, the process would be ineffective.
a Molten salt incineration was eliminated because mo full-scale demonstrations have
been completed on PAH-contaminated waste materials. . '
a Plasm arc torch was eliminated because it is applicable only to liquid organic wastes
and finely divided, fluidizable sludges. . •
•* Low-temperature thermal extraction was eliminated because it would hot be effective
in removing the four-and five-ring PAHs. ' i:
» . On-site vitrification was eliminated because it is an experimental process that only has , • ' &
been pilot tested. Material handling would be required to size/sort the contaminated i
materials before implementation , S
a In situ soil vapor extraction was eliminated because it would not be effective in |
treating the semivolatile organic contaminants in the soils, since they have very low *'
.,.vapor pressures. ', !
a In situ vitrification was eliminated because She very high local water table would I
i interfere with implementation. The offgas system would not be completely effective in i
, capturing all volatilized contaminants. ',•*;,-.,.-• r
• In situ soil flushing was eliminated because it would be difficult to collect the solvent
; because of the high local water table. "'*

Innovative technologies eliminated during the screening of the tihree criteria include the :t
following: ^^^ ::

' '" vmSr ""****
s-= ^Landfarming (on-site) was eliminated because it would ^be less effective and take ~7 J
longer to treat than slurry biotreatment, would require pilot testing, might not be ;
completely effective in treating carcinogenic PAHs, and might not meet PAH cleanup '
levels, r.
* " Composting was eliminated because it would be^less effective and take longer to treat !;
than slurry biotreatment, would require pilot testing, might not be completely effective
in treating carcinogenic PAHs, and might not meet PAH cleanup levels. ':',:.
K Pyrolysis was eliminated because extensive permitting and performance requirements
could preclude its use, materials handling would be required, the technique might not
be acceptable in a residential area, and char might be hazardous and require further i '
treatment.
B Landfarming (off-site) was eliminated because it has not been fully demonstrated for :
four- and five-ring PAHs. It would be practical only as a second option for the
contaminated soil if soil volume is much larger than estimated in the FS.

Innovative technologies eliminated during the detailed analysis include the following:

» Solvent extraction was eliminated because it would not be cost-effective.
• In situ bioremediation was eliminated because its effectiveness for remediating site
contaminants was less certain than that of the selected alternative.

-4-
-------
11.
Which of the nine criteria were weighted most heavily in selecting the
to meet one of the nine criteria result in the elimination of the i,
which criterion? Which of the criteria supported the use of a standard
technology? Did failure
innovaiive technology? If so,
technology?
The criteria most heavily weighted in selecting a remedial alternative
effectiveness and cost. Solvent extraction was eliminated because it
12.
What cleanup goals were selected? If the cleanup goal was based on
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg) | ARAR or Other Basis
Carcinogens
ivere long-term
was mot cost-effective^
an ARAR, what was that
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b and/or k)
fluoranthenfe
Chrysene
Indeno(l,2,3-cd)
pyrene
Pentachlorophenol
0.8
0.3
1.6
1.6
2.8
Leaching Model3
Risk"
Leaching Model
Leaching Model
Leaching Model
Leaching Model
Noncarcinogens
Naphthalene
10
Leaching Model
13.
The risk assessment determined that soil did not pose an unacceptable risk to human
health. Soil cleanup levels were established, however, because the levels of
contaminants in the son will continue to affect ground water quality for an estimated
200 years. Soil remediation levels were developed based on!the contaminants ability
to migrate through the soil and leach into the underlying ground water. The
Multimedia Leaching model was used for generating cleanup goals.
"The health-based goal for benzo(a)pyrene was more protective than the teachability
goal. For carcinogens, an excess upper bound individual lifetime cancer risk of
between 10"4 to 10"* was acceptable. For noncarcinogens, a JHazard Index less than or
equal to 1.0 was acceptable. !
. .'•••". i'
»-" . . - •'• • .•
i, , , • ' •
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? |
" \ ! '
I -.•-••
Innovative technologies eliminated because of cleanup goals include:
'
i . •
• Landfarming J ~
• Composting ,
505
-5-
-------
Standard technologies eliminated because of cleanup goals include:

M None •'"•.,.

/ A Were treatability studies conducted on the innovative technology or standard technology? - ^

No treatability studies were conducted. i.

1$ What measures/criteria were used to compare alternatives? *
t .--'''., - f '-
The following measures were used to compare the alternatives: s

Cost-effectiveness - /
Time to design/constnict/operate
Proven reliability '
Preference for treatment (vs. containment)

16. How are measures compared? „ i,

Slurry biotreatment was preferred over other treatment alternatives (solvent extraction I
incineration) that were rated equally for nonfinanciai; criteria because it had the lowest present ;
worth cost. While another innovative technology, in situ bioremediation, was less costly than JH . I
slurry bioremediation it was not chosen because it would take longer to meet cleanup levels ~ V
and it has not been proved effective for the remediation of PAHs. Slurry biodegradation was -
preferred because it is reliable. It has been successMly demonstrated under the EPA SITE •'
program for wood-preserving wastes that have similar contaminants to those found at the !
Benfield site. Treatment was preferred over containment. Although capping would be less
costly, it was eliminated because it would leave contaminants in place untreated as a I
continuous source of ground water contamination. Seasonal water table fluctuations would '•!
increase the mobility of contaminants to ground water through the generation of leachate
Time to meet cleanup levels was another consideration. The chosen technology was preferred !
over other biological treatments such as landfarming and composting, because it would reach
cleanup levels more quickly.

If. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in choosing a remedial alternative. The high water
table oid, however, preclude the use of in situ vitrification.
506
'-6-
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Carolina Transformer Company

Fayetteville, Cumberland County, North Carolina
Region 4
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and med'
._• this feasibility study ?

Maximum concentrations of principal
contaminants were:

Soil/Sediments/Debris (mg/kg)

PCB (Total)
Dioxins/Furans
Toluene
Dichlorobenzene
Chlorobenzene
Trichloroethylene
Tetrachloroethylene
Copper
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 5,780 cubic yards of on-site soil/sediments
• 9,565 cubic yards of off-site soil/sediments
linants,
Addressed in
ncipal
)
2,100
0.00042
2.4
0.75
0.048
0.004
0.004
130
Site
NPL Proposed:
NPL Final:
FS:
ROD:
History .
7/22/87
N/A ,
3/4/91
8/29/91
Background
EPA Fund-lead
PRPs: Carolina 1
FS prepared by: I
and Techn

ransforrher Company
J&V Waste Science
ology Corp.

3. What type of site is this?

Electrical Equipment. Formerly the site of the CaroHna Transformed Company, which
conducted an electrical transformer rebuilding and repair business from 1967 to 1982, the site
has been vacant since 1986. The site is located in a predominantly rural setting. A food
processing facility called Larry's Sausage is adjacent to the site. '
TECHNOLOGY SELECTION i

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: | ' • .

Access restriction: Deed restrictions, fencing, permits
-1-
507
-------
5.
6.
508
Containment:
Chemical treatment:
Physical treatment:
Thermal treatment:

Disposal:
Capping (native soil, clay, synthetic membranes, sprayed asphalt
asphaluc concrete, concrete, multilayered cap), vertical barfers
horizontal bamers, surface controls, segment control barriers
Neutralization, solidification/fixation/stahilization
Sojids processing, dewateririg, air emission/gas treatment
toemton (rotary kiln, fMdized bed, circulating fluidized bed,

Excavation, resource recovery, temporary storage, wastewater
discharge, evaporation ponds, landfill (RCRA, non-RCRA, TSCA)
Was an innovative technology considered in theFS? IfSQ, which technology?

Biological treatment: Aerobic, biodegradation, anaerobic biodegradation new
What
the cost estimate for the Innovative technology?
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Soil/Sediment
Innovative Technology
Excavation/on-site chemical
_ ' ^^^""^™^^™™

Excavation/on-site solvent extraction
I a-tflf**n T7*«M^__ —A* f*-a -m —
.. «.v^ fvjiTWiiK, CAilifCllllJ
(Basic Extraction Sludge Treatment
ri> t* o m i * \
[B.E.S.T.] system).
soil/sediments to 1 ppm, whereas "B"
alternatives treat soil/sediments to 10 ppm.
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) j
Soil/Sediment
Alternative*
S/S-1
S/S-2
S/S-3A and
S/S-3B
S/S-4A and
S/S-4B
Standard Technology
No action
Fence/deed restrictions
Excavation/off-ske landfill
Excavation/on-site incineration
Estimated Cosw
3 Criteria
N/A
N/A
N/A
aThe "A" alternatives treat PCB-contaminated soil/sediments to 1 ppm
alternatives treat soil/sediments to 10 ppm.
9 Criteria
$0
$172,000
$9,228,800
(S/S-3A)

$8,463,600
(S/S-3B)
$18,019,300
(S/S-4A)

$16,301,200
(S/S-4B)
whereas "B"
wastes at the site.
8. If a standard technology was chosen, why? . - -

A standard technology 03-3) was chosen to remediate the debris/splifl

9. If an innovative technology was chosen, why?

An innovative technology was chosen to treat contaminated soil/sediments at the site.
Alternative S/S-6A was selected because it will protect the local corpmunity and the
environment by chemically treating contaminated soil/sediments with PCB concentrations
above 1 ppm. In demonstration-scale projects, the solvent extraction process has removed over
99 percent of PCBs from soils and sediments. Similar removal efficiencies are expected for
dioxin/furans and other organics. Although the process does not reduce ithe toxicity or volume
of inorganic contaminants, metals such as mercury, lead, zinc, chromium, and copper are
converted to their lowest solubility states, thus minimizing their mobility. In addition, the
selected remedy meets the statutory requirement of utilizing permanent solutions and treatment
technologies to the maximum extent practical. In a sensitivity analysis conducted on each of
the soil/sediment alternatives, the selected alternative S/S-6A shared! the highest rating with
alternative S/S-5A. | ,
-3-
509
-------
JO. If an innovative technology way not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

« Ground freezing was eliminated because it would not be feasible in the region's warm
climate and it would not provide a long-term solution.
« Critical fluid extraction was eliminated because it would not be applicable to this site
No reason was provided.
" Aerobic and anaerobic biodegradatipn were eliminated because they would not be
applicable to most contaminants of concern.
a New biotechnologies were eliminated because they would riot be applicable to most
contaminants of concern.
« Land treatment was eliminated because it would not be applicable to most
contaminants of concern. ' ", .
• Soil vapor traction was eliminated because it would not be applicable to this site
since low levels of VOCs are present.
B Soils flushing was eliminated because it would not be applicable to this site The
process would solubilize currently immobile contaminants.
" Wet air oxidation was eliminated because it would not be applicable to this site No
reason was provided.

Innovative technologies eliminated during the screening of the three criteria include the
following:

« Bioreclamation was eliminated,because its effectiveness has not been demonstrated for
A SvJDS. - '
" Oxidation ^yas eliminated because it would be effective only for limited contaminants
and it might increase ground water contamination problems.
" Reduction was eliminated because it would be effective .only for limited contaminants
and it might increase ground water contamination problems.
» Vitrification was eliminated because, although effective, it would require offgas
collection and treatment It is less appropriate for shallow soil contamination
» Pyrolysis was eliminated because, although effective, residuals might require additional
treatment. ,

Innovative technologies eliminated during the detailed analysis include the following:

» Organic chemical dechlorination was eliminated but no specific reason was provided
This technology shared the highest rating with the selected innovative technology in a
sensitivity analysis conducted for comparison purposes. The ROD states, however
that this alternative might not be in compliance with parts of TSCA chemical-specific
and action-specific regulations, including 40 CFR 761.60, 761,70, and 761.75
Soil/sediments with PCB concentrations exceeding 50 ppm are specifically required by
Part 761.60 (a)(4) to be disposed of in an incinerator (761.70), chemical waste landfill
(761.75), or by equivalent treatment (761.60 (a)). Chemical dechlorination would
require pilot treatment tests to be considered an equivalent treatment method since
510 •-•
->>'
-4-
-------
limited studies are available to document its effectiveness. Effectiveness might vary
with soil/sediment composition and other factors. i
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
- • - ' - I , . - •
Soil/Sediment

The criteria most heavily weighted in selecting an innovative technology for soil/sediments
were protection of human health and the environment, long-term effectiveness and
permanence, and reduction in toxicity, mobility, and volume of contaminants through
treatment. The "A" alternatives are most protective because they chemically treat PCB-
contaminated soil/sediments to 1 ppm, whereas the "B" alternatives only treat PCB-
contaminated soil/sediments to 10 ppm. The selected alternative, S/S-I6A, provides a permanent
remedy that removes the contaminants from the associated media and disposes of the reduced
contaminated waste stream off site. '...-•'(
•i • " "
Debris/Solid Waste

the criteria most heavily weighted in selecting a standard technology^ are protection of human
health and the environment and compliance with ARARs. The selected alternative, off-site
landfill, permanently removes contaminated debris/solid waste from l|he site and eliminates the
threat of direct contact with PCBs.
. • . . |.'
1 • '..'.' H
No innovative technologies were eliminated due to the nine criteria. \ •
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? I
i ~ '
Soil/Sediments
Contaminant
Cleanup Level (sag/kg)
ARA1R or Other Basis
Carcinogens
PCBs (Total):
Dioxins/Furans
1 (10a)
1.2E-04
TSCAb
'Risk6
"Alternative cleanup level.
''EPA PCB soil cleanup guideline to remove all soil/sediments with total PCB
concentrations greater than 1 mg/kg would reduce the carcinogenic risk to
approximately 10"5. The same degree of protection can be_abhieved by removing
soil/sediment with a total PCB concentration greater than 10j mg/kg combined with
placing ,10 inches of clean soil over any soil/sediments exceeding 1 mg/kg.
cAn excess upper bound individual lifetime cancer risk of between 10"4 to 10"6 was
acceptable. • _ • •
-5-
511
-------
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None * ' . •--

Standard technologies eliminated because of cleanup goals include:

• None
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Preference for treatment (vs. containment)
Impact on nearby populations
Proven reliability

16. How are measures compared? ~ . '

The selected remedy provides a permanent and cost-effective solution. The selected remedy
also meets the statutory requirement of utilizing permanent solutions and treatment
technologies to the maximum extent practical. In addition, the potential impact on an adjacent
food processing facility was a significant consideration in eliminating alternatives S/S-4A and
4B. Extensive stack emission controls would be required to ensure that the incinerator
proposed in S/S-4A and 4B would not affect this facility. Finally, the chosen innovative
technology, solvent extraction, was selected because of its demonstrated PCB-removal
efficiency from soils and sediments of over 99 percent. ,,
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. The depth of contamination
played a role, however, in eliminating vitrification as a treatment technology because it would
be less appropriate for the site's shallow soil contamination.
512
-------
Carrier Air Conditioning Co.
Collierville, Tennessee
Region 4
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

Trichloroethene (TCE) 1.200
1,2-Dichloroethene (DCE) 0.2
Tetrachloroethene (PCE) 0.011
Lead 21.4
Ziric' 77.8
SiteHist:ory

NPL Proposed: | 6/88
NPL Final: i 1990
FS: . ! 4/92
ROD: | 9/3/92

Background
I •• '
PRP-lead |
PRPs: Town of Collierville, Carrier
Corporation
FS prepared by: Environmental and
Safety Designs, Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 76,500 cubic yards of soil
3. What type of site is this?

Fabricated Metal Products.1 The site is used to manufacture residential heating and air
conditioning units. Land use in the immediate vicinity of the site is industrial/commercial and
undeveloped.
TECHNOLOGY SELECTION ,
1 * ' ' " .
4. What standard technologies were considered for selection in this FS?\

Standard technologies considered during the identification and screening of technically feasible
technologies were: .
Access restriction:
Containment:
Fencing, deed restrictions
Capping (RCRA-type, clay, soil, synthetic, asphalt, concrete type),
vertical barriers (slurry wall, sheet piling), surface/sediment controls
(surface water diversion, sediment barriers), dust/volatile organic
compound controls (capping, revegetation, sp:ray-on suppressants, other
engineering controls)
-1-
513
-------
Physical treatment:
Thermal treatment:
Disposal:
Ex situ solidification} ex situ stabilization, ex situ microencapsulation
Incineration (fluidized bed, rotary kiln, infrared)
Excavation, off-site disposal, on-site disposal
5. Was cm innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: , ,

Biological treatment: Ex situ aerobic/anaerobic solid phase biodegradation, ex situ aerobic/
anaerobic slurry phase biodegradation, in situ aerobic/anaerobic
biological treatment
Phys/Chem treatment: Ex situ soil washing, in situ chemical treatment (soil flushing with
solvents for extraction, chemical treatment with stabilizing or oxidizing
agents for treatment to degrade or immobilize), ex situ waste pile
vapor extraction, in situ vapor extraction
Thermal treatment: Ex situ low-temperature thermal desorption, in situ vitrification
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2
RAA-3
RAA-4A
Innovative Technology
Continued operation of existing soil
vapor extraction/ground water
containment and treatment
Expansion of existing soil vapor
extraction/ground water containment
and treatment
Expansion of existing soil vapor
extraction/expanded ground water
containment and treatment via air
stripping
Estimated Costs
3 Criteria
$3,000,000
to
$4,000,000
$5,000,000
to
$7,500,000
$5,700,000
to
$8,000,000
9 Criteria"
eliminated5
($2,968,754
to
$4,064,847)
$5,500,000 to
$7,500,000
($5,568,140
to
$7,451,775)
$5,700,000 to
$7,900,000
($5,717,755
to
$7,932,765)
514
-------

Alternative
RAA-4B

RAA-5

RAA-6A

RAA-6B

Innovative Technology
Expansion of existing soil vapor
extraction/expanded ground water
containment and treatment via UV
oxidation

Excavation/low-temperature thermal
desorption/expansion of soil vapor
extraction/ground water containment
and treatment

Excavation/low-temperature thermal
desorption/expansion of soil vapor
extraction/expanded ground water
containment and treatment via air
stripping
Excavation/low-temperature thermal
desorption/expansion of soil vapor
extraction/expanded ground water
containment and treatment via UV
oxidation

Estimated Costs
3 Criteria
$6,000,(XX)
to
$8,400,000

$9,500,000
to
$14,000,000

$9,800,000
to
$14,500,000

•
9 Criteria*
$6,000,000 to
$8,400,000
($6,054,423
to
$8,417,675)
$9,500,000 to
$14,000,000
($9,467,667
to
$13,956,482)
$9,800,000 to
$14,500,000
($9,788,616
to
$14,508,506)
$10,000,000
to
$14,900,000
($10,014,179
to
$14,851,035)
"Costs in parentheses are for the ROD.
bRAA-2 was eliminated after the three-criteria screening in the FS, but jvas presented in the
ROD. '•'-••-•'
7.' How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologic
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology
l
No action/discontinue existing soil
vapor extraction/discontinue ground
water containment and treatment
Estimated Costs
3 Criteria
$1,400,000 to
$2,200,000
I
9 Criteria"
$2,100,000
($1,437,223
to
$2,180,152)
"Costs in parentheses are for the ROD.
3-
515
-------
5. If a standard technology was chosen, why?
••'.'•. • • mum -v
A standard technology was not chosen. , ^^ \)

9. If an innovative technology was chosen, why?

RAA-4A was chosen primarily based on decisions pertaining to ground water treatment. With
regards to soil remediation, RAA-4 (soil vapor extraction) was selected because it irreversibly"
removes VOCs from soils to levels at or below soil cleanup levels. The remedy poses no
short-term threats that cannot be readily controlled. In addition, no adverse cross-media
impacts are expected from the remedy. By utilizing treatment as a significant portion of the
remedy, the statutory preference for remedies that employ treatment as a principal element is
satisfied.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• In situ biological treatment was eliminated because of uncertainty with'implementation fl)
and the complication of fugitive air emissions. Implementation of bioremediation ^^ •
would require establishment of an environment that is supportive of the required
microorganisms and contact with the target contaminant. Although biological
degradation of TCE has been seen to occur naturally at Collierville, and it has been i
stimulated and utilized as a remedy at other TCE-contaminated sites, site-specific
variables are not well understood. Significant treatability testing would likely be :
required. Volatilization and air emission of organic compounds during bioremediation i'
could reduce contaminant levels more than actual metabolysis. Therefore, air
emissions must be mitigated during treatment. Note that the FS does not specify that
this is in situ biodegradation; however, since both ex situ biodegradation technologies
are eliminated separately, this must refer to in situ treatment.
• In situ chemical treatment was eliminated because of the proximity of the underlying
aquifer and uncertainty regarding the clay layer thickness.
• In situ vitrification was eliminated because the technology would not be applicable to
the site contaminants.
• Ex situ soil washing was eliminated because the technology would provide no
advantage in effectiveness over soil vapor extraction or low-temperature thermal
desorption for-volatile organic contaminants. There would be the potential for fugitive
air emissions and the generation of liquid residuals requiring further treatment.
• Ex situ slurry-phase bioremediation was eliminated because the technology would
provide no advantage in effectiveness over soil vapor extraction or low-temperature
thermal desorption for volatile organic contaminants. There would be the potential for
fugitive air emissions and the generation of liquid residuals requiring further treatment. A V
• Ex situ soil (presumably waste pile) vapor extraction was eliminated because it would •» I
be no more promising than in situ soil vapor extraction or low-temperature thermal ^^ ;

516
-4-
-------
11.
desorption, and would pose the complication of fugitive air emissions, which would be
more difficult to control than with the closed treatment systems. ,
Ex situ solid phase bioremediation was eliminated because with the primary
remediation target TCE and natural degradation products, successful implementation, of
bioremediation is more complicated than with'light, simple hydrocarbon compounds.
This technology holds no advantage over waste pile vapor extraction or thermal
treatment, and fugitive volatile compound emissions would be more difficult to
control. [
Innovative technologies eliminated during the screening of the three criteria include the ,
following: .
• r I ' ' . ' ! ' .'•'•.,'
• . • ' ' "
• None

Innovative technologies eliminated during the detailed analysis include the following:

• Ex situ low-temperature thermal desorption was eliminated because invasive
excavation measures would affect ongoing manufacturing operations in a more
disruptive fashion than would soil vapor extraction; excavation, would expose remedial
workers to a greater potential for physical injury relative to the; less invasive soil vapor
extraction; and excavation would increase VOCs and fugitive dust emissions.
Although low-temperature thermal desorption combined with s^il' vapor, extraction
would provide certain and relatively rapid treatment of shallow source area soils, it
would cost significantly more than soil vapor extraction alone.
Which of the nine criteria were weighted most heavily in selecting the [technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
• ' ' •
Selection of RAA-4A was based primarily on ground water remediation; however, a choice
between soil remediation technologies needed to be made. The criteria weighted most heavily
in selecting a remedy included short-term risk and cost. Short-term risk from RAA-5 and
RAA-6 are higher than would be associated with RAA-3 and RAA-4 because excavation
activities would increase VOCs and fugitive dust emissions. Further, iinvasive excavation
measures would affect ongoing manufacturing operations in a more disruptive fashion than
would soil vapor extraction, and excavation would expose remedial workers to a greater
potential for physical injury relative to the less invasive soil vapor extraction. In relation to
cost, although low-temperature thermal desorption combined with soil vapor extraction would
provide certain and relatively rapid treatment of shallow source area soils, it would cost
significantly more than soil vapor extraction alone.
-12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Carcinogens
Trichloroethene
Cleanup Level (fig/kg)
ARAR or (Other Basis
533
Model8
517
-------
*From EPA's Center for Environmental Assessment Modeling (CEAM) Exposure
Assessment Multimedia Model (MultiMed) to protect the aquifer.

For carcinoeens, an excess upper bound individual lifetime cancer risk of between 10" to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.

75. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

« None ,

Standard technologies eliminated because of cleanup goals include:

• None
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Time to design/construct/operate
Short-term risk

16. How are measures compared?

RAA-5 and RAA-6, which include low-temperature thermal desorption and soil vapor
extraction, would take approximately 2 to 3 years to remediate site soils, whereas RAA-3 and
RAA-4, which only use soil vapor extraction, would jequire 3 to 5 years. Short-term risks
1 from RAA-5 and RAA-6, however, are higher than those associated with RAA-3 and RAA-4
because excavation activities would increase VOCs and fugitive dust emissions. Further,
invasive excavation measures would impact ongoing manufacturing operations more than soil
vapor extraction would, and excavation would expose remedial workers to a greater potential
for physical injury relative to the less invasive soil vapor extraction.
'1
•<**&*
17.
What technical considerations were factors in selecting, a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. In situ chemical treatment,
however, was eliminated because of the proximity of the underlying aquifer and uncertainty
regarding the clay layer thickness.
518
-6-
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Charles Macon Lagoon & Drum Storage

Cordova, Richmond County, North Carolina
Region 4
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1/87
7/87
7/91
9/30/91
Background

PRP-lead |
PRPs: Dorothy Macon, Nicholas
Dockery, Sairfax Dockery, John
C. Dockery, C&M Oil
Distributors line., Crown Cork
and Seal Coj. Inc., Acme
Nameplate & Mfg., Inc., Carolina
Aluminum Ifroducts Distributing
Co., Clark Eiquiipment Co.
FS prepared by: Siirine Environmental
Consultants
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Subsurface Soils/Lagoon 7 (mg/kg)

Tetrachloroethene (PCE) 31

Subsurface Soils/Lagoon 10 (mg/kg)

Acenaphthene 31
Acenaphthylene 310
Anthracene 160
Benzo(a)anthracene 150
Benzo(a)pyrene 140
Benzo(b)fluoranthene 120
Benzo(k)fluoranthene 120
Chrysene 140
Dibenzo(a,h)anthracene 30
Fluoranthene 200
Fluorene 250
Ideno(l,2,3-cd)pyrene 47
Naphthalene 3,100
Phenanthrene 1,300
Pyrene 410
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 1,300 cubic yards of subsurface soil from Lagoon 7
• 1,000 cubic yards of subsurface soil from Lagoon 10 including 930 tons of creosote

3. What type of site is this?
... \. . •. : - '

Waste Oil. This site is a former oil recycling and antifreeze manufacturing facility in a
predominantly agricultural setting. Four residences are within 100 yards of the site.
-1-
519
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Subsurface Soils/Lagoon 7 and 10

Containment: Capping, subsurface barriers (slurry walls, grouting, sheet piling),
container piles .
Chemical treatment: Stabilization/solidification (cement-based, silicate-based, thermoplastic
microencapsulation), modified clay-based stabilization
Thermal treatment: Incineration (transportable, commercial)
Disposal: Landfilling (commercial, on-site)
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Subsurface Soils/Lagoon 7 and 10

Biological treatment: Land treatment (bioremediation), bioreactor, enhanced biodegradation
Chemical treatment: Supercritical carbon dioxide extraction, Basic Extraction Sludge
Treatment (BEST) process, oxidation, reduction, supercritical waiter
oxidation, soil washing, soil flushing
Thermal treatment: Low-temperature thermal separation, soil vapor extraction, vitrification
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
SC-3
Innovative Technology
Soil vapor extraction (Lagoon 7) and
capping (Lagoon 10)
Estimated Costs
3 Criteria
$680,000
9 Criteria
$1,000,000
520
•2-
-------
Alternative
SC-4
SC-5
Innovative Technology
Soil vapor extraction (Lagoon 7}/
bioremediation and cap (Lagoon 10)
Soil vapor extraction (Lagoon 7) and
off-site 'disposal (Lagoon 10)
Estimated Costs
3 Criteria
$890,000
$6401,000
9 Criteria
$1,500,000
$520,000
7. How did the cost(s) compare to standard technologies? j
•\
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) |
Alternative
SC-1
SC-2
SC-6
Standard Technology
No action
Capping (Lagoons 7 and 10)
Off-site incineration
Estimated Costs
3 Criteria
$100,000
.$776,000
$6,700,000
9 Criteria
$190,000
$690,000
eliminated
If a standard technology was chosen, why?

A standard technology was not chosen.
If an innovative* technology was chosen, why? .
• ," ' ' • ' '
The selected alternative (SC-4) involves the operation of a soil vapor extraction (SVE) system
at Lagoon 7 to remove tetrachloroethene (PCE), and biological remediation of Lagoon 10
wastes in a controlled cell.

SVE was chosen because this treatment will significantly reduce chemicals that affect ground
water quality above the identified ARARs. SVE would permanently ijeduee the volume of
PCE in soils by more than 90 percent, based on a reduction of PCE fijom 31 mg/kg to the
target cleanup level of 3 mg/kg. This technology would address the sble risk to ground water
posed by PCE-contaminated site soils. Also, the target cleanup level can be achieved using
standard SVE design and construction practices. Site conditions are appropriate for the
application of SVE. A Superfund Innovative Technology Evaluation (SITE) Program
demonstration showed that SVE systems are effective in soils with permeabilities of 10"8 cm/s
when the porosity is sufficient for application. The site soil's permeability is approximately
2.5 x 10"5 cm/s, and calculated actual and effective porosities at the site are approximately 40
and 20 respectively, which would be sufficient for application of SVE',. The process also has
been used successfully for full-scale remediation in the Piedmont region. Even though a
permeability barrier would exist in the perched water zone beneath some portions of the site, a
simple, or horizontal SVE design could be implemented for soils lying above the perched
-3-
521
-------
water and SVE used in conjunction with passive air inlet wells could be used for soils below ^^
the perched aquifer. In addition, SVE could incidentally remove SVOCs as part of the *^ \
primary objective of VOG removal, even though SVOCs are not targeted for removal through —<*,
SVE. Removal would be effected either through enhanced biodegradation due to increased
oxygen levels in the subsurface or through direct volatilization. Installation of the SVE system
at Lagoon 7 could proceed concurrently with biological treatment of the Lagoon 10 soils. ;

Bioremediation (land treatment) was chosen because its effectiveness on Lagoon 10
contaminants has been demonstrated under a variety of environmental conditions and soil
types. Previous studies have reported 80- to 90-percent removal of these compounds in fewer i.
than 4 months of treatment. This technology has been demonstrated at other sites and has
been selected to treat similar compounds at other Region 4 sites. In 1983, biological treatment
(landfarming) of site contaminants was conducted by EPA during an intermediate removal
action. The data indicate that bioremediation of residuals in Lagoon 10 would also be
successful. In addition, this technology was selected because Lagoon 10 wastes will be
permanently destroyed and bioremediation would satisfy the Superfund Amendments and
Reauthorization Act's (SARA) preference for alternatives involving treatment. Also, land <
treatment can effectively treat Lagoon 10 wastes and maintain positive containment of
relatively mobile intermediates, in contrast to enhanced biodegradation, which was eliminated
from consideration because of its potential to produce vinyl chloride from PCE. -!

10. If an innovative technology was not chosen, why not? At what stage was the innovative ';
technology eliminated? '

' ..'• " '
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
• I
Innovative technologies eliminated during the initial screening include the following:

• Bioreactor wasi eliminated based on effectiveness and cost. Monitoring and
maintenance requirements are far greater for bioreactors adding significantly to the
cost. Sizing requirements could effect the implementability of this technology when
applied to Lagoon 10 wastes. The FS referenced two sources of information, ECOVA
Corp., 1991, and EPA/540/2-88/004 (Technology Screening Guide for Treatment of
CERCLA Soils and Sludges), Sept. 1988, during the evaluation of this technology.
• Supercritical carbon dioxide extraction was eliminated because, according to an EPA
study, this technology gives poor recoveries of adsorbed organics from activated
carbon and synthetic resins (B.W. Wright, et al., 1986). Also another EPA study
found that this process removes greater than 40 percent of only 4 of the 23 organic
compounds tested (Ehntholt, D.J., 1985). Although pilot tests have been conducted
with this type of technology, no full-scale operations have been applied.
• BEST processjwas eliminated because it would not be as cost-effective as other
treatment alternatives, when used to treat limited volumes of soil. Only limited '"••
volumes of Lagoon 10 soil need to be treated (Resource Conservation Company, . •:
1991). The FS referenced material from EPA/540/2-88/004 during the evaluation of
this technology. - ,
• Oxidation was eliminated because this technology would be better suited for water 4jh v
than soil. The solids in a soil slurry would interfere with the UV/hydrogen peroxide ^P' /
or ozone reaction, thereby rendering this technology ineffective.

522 ' • . . • ' •'•. • " ;' . • •; • .••;
-------
• Reduction was eliminated because of the limited number of site contaminants
, addressed by the process and the lack of full-scale operation.
• Supercritical water oxidation was eliminated because the effectiveness of this
technology on soils is not sufficiently demonstrated. The FS refers to the MODAR
system and emphasizes that a full-scale MODAR system has jnot yet been built.
• Soil washing was eliminated because site soils have an appreciable silt and clay
content (approximately 50 percent), which would hinder the contaminant contact and
mass transfer properties of surfactant solutions. Soil washing was determined to be
ineffective at a Michigan Superfund site for compounds with j similar or greater
solubilities than at this site. ,
• Low-temperature thermal separation technologies (LTTA, X'jTrax, LT3) were
eliminated because they would not be effective for the removal of a number of the
chemical residuals from Lagoon 10 soils based on the boiling points of these residuals
and system operating temperatures. Shortage of full-scale uniits makes it technically
and economically unfeasible to mobilize a unit to a site unless there is at least 10,000
cubic yards of material; only 1,300 cubic yards need to be treated at Lagoon 7.
• Enhanced biodegradation was eliminated because the potential of producing vinyl
chloride from PCE precludes the use of this technology at Lagoon 7.
• Soil flushing was eliminated because of the concern that mobilized contaminants would
not be recovered completely by the extraction system and therefore could affect ground
water conditions. Site soil permeabilities are generally low sind somewhat variable
making remediation to an acceptable level difficult. Furthermore, many of the site's
compounds have high 'octanol-water coefficients, making thep difficult to remove from
soils. , . ' i .
• Vitrification was eliminated because the site's soil moisture content would limit the
effectiveness of this technology. Site soils are generally composed of a clay-silt-sand
mixture. Since clays are very porous and aggressively retain water, soil moisture
conditions at the site are a concern. Soil moisture content also is a concern in soils
overlying a shallow perched water table. The moisture contained in the perched water
table would inhibit soil vitrification at lower depths.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None . . . ; . ' •

Innovative technologies eliminated during the detailed analysis include the following:
: '• 'i
»• None •'•-.'•. ' ' I ' . •
11. Which of the' nine criteria were weighted most heavily in. selecting the technology? Did failure
•to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Subsurface Soils ' i - .
I

The most heavily weighted criteria in selecting SC-4 were long-term effectiveness and
permanence, and reduction of toxicity, mobility, or volume of contaminants of concern. The
migration of Lagoon 7 PCE to ground water would be permanently [controlled by capping (SC-
2) or by SVE (SC-3, SC-4, and SC-5). While capping would greatly reduce the mobility and
-5-
523
-------
effective toxicity of contaminants in site soils, it would not reduce the volume of these
com-minants. SVE would permanently reduce the volume and mobility of site contaminants
that could contaminate ground water above cleanup levels. Bioremediation would effect a
permanent but undetermined reduction in the volume of Lagoon 10 contaminants.
12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Subsurface Soils/Lagoon 7
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
Tetrachloroethene (PCE)
3.0
Model3
"Cleanup level is based on a compound's potential effect on ground water. Chemical
concentrations in subsurface soils that are protective of ground water were developed
using the Vadose Zone Interactive Process (VIP) model.

Subsurface Soils/Lagoon 10
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
Benz(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenz(a,h)anthracene
Idenopyrene
2.0
(Total)
Riskb
"For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4
to 10 was acceptable.
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? "

Innovative technologies eliminated because of cleanup goals include:

» None

Standard technologies eliminated because of cleanup goals include:

• None .. ,
524
-6-
-------
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability study was conducted. A treatability study was proposed, however, for the
chosen bioremediation technology in the FS and the ROD to determine if the indigenous
microbial population is capable of degrading the contaminants in Lagoon 10.

i
''!'••'=''
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: . |

Cost/risk
Proven reliability
Single vs. multistep treatment
- Preference for treatment (vs. containment)

• • '
16. How are measures compared? I
' • • ' ' ' i
Although the selected remedy is the highest cost alternative, it is prel;erred because it provides
a greater reduction in risk. SVE was chosen because, according to a SITE program
demonstration, this technology is effective in soils with permeabilities and porosity similar to
the site soils (Stinson, 1989). Also, SVE has been successful in full-scale remediation projects
in the Piedmont region (Vicellon facility, Fountain Inn, SC). Bioremjediation was chosen
because it had been demonstrated effective on Lagoon 10 contaminants Hinder various
environmental conditions and soil types. Previous studies have reported 80- to 90-percent
removal of these specific compounds in less than 4 months of treatment (Mahaffey et al.
1990). Using SVE and bioremediation would satisfy SARA'S preference for remedial actions
that involve treatment as a principal element. '...'.

Subsurface soil chemjcal concentrations that are protective of ground water were developed for
this site using the Vadose Zone Interactive Processes (VIP) model. !
: ' •. ".' •- •• ".i • ' , '• '

17. What technical considerations were factors in selecting a remedy? Were technical ,
considerations primary in the selection of the remedy? ,

Technical considerations were primary in selecting a remedy.
•' i ' i ••••',
SVE was selected because soil permeability and porosity at the site are appropriate for the
implementation of this technology. Site soils also were instrumental in eliminating several
innovative technologies from further review. Site soils have an appreciable silt and clay
content (approximately 50 percent), precluding the use of soil washing as a treatment
technology. Also, site soil permeabilities are generally low and somewhat variable—a factor
in eliminating soil flushing from consideration. This site's soils are generally composed of a
clay-silt-sand mixture, which is very porous and aggressively retains [water, and these soils are
overlying a shallow perched water table. These soil moisture conditions were the primary
consideration in eliminating in situ vitrification.
52
-------
References:
Ehntholt, D.J. 1985. "Isolation and Concentration of Organic Substances from Water—An
Evaluation of Supercritical Fluid Extraction." U.S. EPA Project Summary EPA-600/51-84-
028.

U.S. EPA. 1988. Technology Screening Guide for Treatment of CERCLA Soils and Sludges
EPA/540/2-88/004, p. 63.

Wright, B.W. and R.D. Smith. 1986. "Supercritical Fluid Extraction of Paniculate and
Absorbent Materials." U.S. EPA. EPA/600/54-86/017.
526
-8-
-------
Ciba-Geigy Corp. (Mclntosh Plant)
OU-2
. ;
Mclntosh, Alabama
Region 4
GENERAL SITE INFORMATION

1. What -were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface and Subsurface Soil (mg/kg)

DDT 3,780
DDD 8,590
DDE 8,410
AIpha-BHC 4,370
Beta-BHC 751
Delta-BHC 315
Gamma-BHC 753
Chlorobenzilate 650
Diazinon 786
Chloroform < 16,600
Toluene . 6,360
Benzene 5,650
Chlorobenzene 414
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A,
9/83
1/90
9/30/91
Background

PRP-lead
PRPs: Ciba-Geigy [Corp.
FS prepared by: BCM Engineers Inc.
2. What volume of material is to be remediated? - '•• '
j - '
, The volume of material to be remediated included: .'!.',
I
• 65,000 cubic yards of highly contaminated soil and sludge
• 62,300 cubic yards of moderately contaminated soil and sludge

3. What type of site is this? !

Chemicals and Allied Products. An active chemical manufacturing cojnpany that has produced
products such as pesticides, agricultural chelating agents, industrial secjuestering agents,
laundry brighteners, plastics resins, and antioxidants. Located in an industrial setting, OU-2
consists of 18 former waste management areas. •
-1-
527
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:

Chemical treatment:
Physical treatment:

Thermal treatment:
Disposal:
Land use restrictions, fencing :
Capping (soil, clay, synthetic membrane, asphalt, concrete, multilayer,
single layer), slurry wall (soil bentonite, cement bentonite)
Fixation/stabilization (Hazcon)
Stabilization (portland cement pozzolan), debris removal, screening
(vibratory, grizzly), crushing/grinding (hammermill), blending/mixing
(pugmill), magnetic separation -
Incineration (rotary kiln, liquid injection, fluidized bed)
Excavation, on-site disposal
Other standard technologies were listed.in the appendix but not referred to in the main FS text.
Therefore, they are not represented in this list.
J:
5. Was an innovative'technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation, bioslurry
Chemical treatment: Solvent extraction

Many innovative technologies presented in the appendix were not mentioned in the main FS
text and are not included in this list. These technologies'were not incorporated into any RAAs
and their elimination was not explained.
ill
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify, costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on nine criteria established by
the NCP: long-term effectiveness and permanence; short-term effectiveness; compliance with
ARARs; protectiveness of human health and the environment; reduction in contaminant
mobility, toxicity, or volume; implementability; cost; state/support agency acceptance; and
community acceptance.
*•* - .
Tables are provided for each of the 18 sites. The RAAs were consolidated in the Proposed
Plan and ROD and are presented in separate tables following the cost estimates provided for
the three-criteria and nine-criteria screenings.

528
-------
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) ;
Site 1
Alternative
RAA-7

Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/multilayer cap
Estimated Costs
3 Ciiteria
$5,047,000
9 Criteria
eliminated
Site 2 ''•';. ' ' . ,
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/multilayer cap
Estimated Costs
3 Criteria
$2,759,000
i
9 Criteria
eliminated
Site 3A '..• ^ ....-•
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
"returned to site/synthetic membrane. cap
Estimated Costs
3 Criteria
$3,568,000
"i
9 Criteria
eliminated
Site 3B
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction prbcess/incinerate/ash .
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Estimated Costs
3 Criteria
$1,609,000
: 1 •
• •
, 1
.;
i '
9 Criteria
eliminated
529
-------
Site 3C
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Estimated Costs
3 Criteria
$3,983,000
9 Criteria
eliminated
Site 3D
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/ synthetic membrane cap
Estimated Costs
3 Criteria
$1,953,000
9 Criteria
eliminated
Site 3 General
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Estimated Costs
3 Criteria
$19,261,000
9 Criteria
eliminated
b:
Site 4A
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Estimated Costs
3 Criteria
$714,000
9 Criteria
eliminated
' ~i
530
-4-
-------
Site 4B
Alternative
RAA-7
RAA-8

Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/
treated soil returned to site/synthetic
membrane cap
Excavate/grizzly screen, shredder,
vibratory screen/incinerate solids/
hammermill, magnetic separator/
bioslurry/synthetic membrane cap .
Estimated Costs
3 Criteria
$5815,000
$563,000
9 Criteria
eliminated
eliminated
Site4C
, •• . • ' . i . . •
Alternative
RAA-7
RAA-8
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Excavate/grizzly screen, shredder,
vibratory screen/incinerate solids/crush,
magnetic separator/bioslurry/synthetic
membrane cap
Estimated Costs
3 Criteria
$800,00
$642,000
1" . •
9 Criteria
eliminated
eliminated
Site 5 , . ] '-.-.-
Alternative
RAA-7
Innovative Technology
Slurry wall/excavation/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
. returned to site/synthetic membrane cap
Estimated Costs
3 Criteria
$5,984,000
'i.
9 Criteria
eliminated
-5-
531
-------
Site 6
Alternative
RAA-7
RAA-8
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Excavate/grizzly screen, shredder,
vibratory screen/incinerate solids/crush,
magnetic separator/bioslurry/synthetic
membrane cap
Estimated Costs
3 Criteria
$8,199,000
$7,394,000
9 Criteria
eliminated
eliminated
Site?
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Estimated Costs
3 Criteria
$8,001,000
9 Criteria
eliminated
Site 9
Alternative
RAA-7
Innovative Technology
Slurry wall/excavate/remove debris/
screen, crush, magnetic separator/
solvent extraction process/incinerate/ash
disposal in RMP land vault/treated soil
returned to site/synthetic membrane cap
Estimated Costs
3 Criteria
$13,311,000
9 Criteria
eliminated
532
-------
Proposed Plan and ROD for All Sites
Alternative
RAA-5

Innovative Technology
Excavate soil and sludge/remove
debris/possibly pretreat soil with
solvent extraction or low tempera-
ture thermal desorption or critical
fluid injection/incinerate soils with
high levels of contamination/
stabilization-solidification and
possible dechlorination of soils with
low level contamination/dispose ash
and solidified materials in RCRA
land vault/if cleanup levels are not
reached following excavation of 20
feet, in situ soil flushing, vacuum
extraction, or bioremediation
Estimated Costs
PP
Not proposed
in 7/30/90 PP
1
• ' _

i
i •
i.
i
•
f

i .
i
'
.
ROD
$94,000,000
to
$120,250,000

, •

7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Site 1 ' '
Alternative
RAA-1
RAA-2
RAA-3
V
RAA-4
RAA-5
Standard Technology
No action
Slurry wall/excavate/stabilization/
multilayer cap ,
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/ash
disposal in RMP land vault/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/stabilization/
disposal in on-site RPM land vault/
multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/fixation/
place fixed material into on-site RPM
land vault
Estimated Costs
3 Criteria
N/A
$1,920,000
$4,442,000
$3,(|98,000
L " i '
$5,216,1300
9 Criteria
$0
$1,920,000
eliminated
$3,098,000
eliminated
-7-
533
-------
Alternative
RAA-6
RAA-8
RAA-9
RAA-10
RAA-11
Standard Technology
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic
separator/incinerate/multilayer cap
Slurry wall/excavate soil/debris
removed/screen, shred, crush/incinera-
tion solids/soil fixation/return fixed soil
to site/multilayer cap/excavate sludge/
remove debris/screen, shred, crush,
magnetic separator/incinerate sludge/
disposal of ash on-site in RPM land
vault
Slurry wall/excavate sludge/remove
debris/screen, shred, crush, magnetic
separator/incinerate sludge/ash disposal
in RMP land vault/excavate soil/stabil-
ization/place in RMP land vault/
multilayer cap
omitted
Excavate sludge/remove debris/screen,
shred, crush, magnetic separator/
incinerate/disposal of ash in on-site
RMP land vault/excavate soil/stabilize/
place in RMP land vault
Estimated Costs
3 Criteria
$9,610,000
.$6,901,000
$5,887,000
omitted
N/A
9 Criteria
eliminated
eliminated
$5,887,000
omitted
$11,029,000
Site 2
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action
Slurry wall/excavate/stabilization/
multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/disposal in on-site
RPM land vault/multilayer cap
Estimated Costs
3 Criteria
N/A
$1,027,000
$1,713,000
$1,418,000
9 Criteria
$0
$1,027,000
eliminated
$1,418,000
';}
534
-------
Alternative
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-11
Standard Technology
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excayate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/ash disposal in RMP land
vault/multilayer cap
Slurry wall/excavate soil waste/debris
removed/screen, shred, crash/ incinerate/
soil fixation/return fixed soil to site/
multilayer cap/excavate solid waste/
remove debris/screen, shred, crash,
magnetic separator/ incinerate/dispose
ash on-site in RPM land vault
Slurry wall/excavate solid waste/remove
debris/screen, shred, crash, magnetic
separator/incinerate/ash disposal in RMP
land vault/excavate soil/remove debris/
stabilization/place in RMP land vault/
multilayer cap
omitted
Excavate sludge/remove debris/screen,
shred, crash, magnetic separator/
incineration/dispose ash in on-site RMP .
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
$1,986,00
j
$3,436,000
•j
r
$2,383,000
I
1
1 '"'
l
-. , «!'
I
$2,525,000
!'
omitted
N/A
-
l
1
9 Criteria
eliminated
eliminated
eliminated
$2,525,000
omitted
$1,280,000
Site 3A
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Slurry wall/excavate/stabilization/
multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crash/incinerate/fixation/
return fixed material to site/multilayer
cap
Estimated Costs
3 Criteria
N/A :
$9^1, 000
$2,067,000
1 ..
9 Criteria
$0
$951,000
eliminated
-9-
535
-------
Alternative
RAA-4
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-11
Standard Technology
Slurry wall/excavate/remove debris/
screen, shred, blend/stabilization/dispose
in on-site RPM land vault/synthetic
membrane cap/incinerate debris
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/ash disposal in RMP land
vault/synthetic membrane cap
Slurry wall/excavate soil/debris
removed/screen, shred, crash/incinerate
solids/soil fixation/return fixed soil to
site/multilayer cap/excavate sludge/
remove debris/screen, shred, crush,
magnetic separator/incinerate sludge/
dispose of ash on-site in RPM land
vault
Slurry wall/excavate solid waste/remove
debris/screen, shred, crush, magnetic
separator/incinerate/ash disposal in RMP
land vault/excavate soil/stabilization/
place in RMP land vault/synthetic
membrane cap
omitted
Excavate sludge/remove debris/screen,
shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
$1,608,000
$2,518,000
$4,912,000
$3,783,000
$2,913,000
omitted
N/A
9 Criteria
$1,608,000
• (
eliminated
eliminated
eliminated
$2,913,000
omitted
$2,383,000
Site 3B
Alternative
RAA-1
RAA-2
Standard Technology
No action
Slurry wall/excavate/stabilization/
multilayer cap
Estimated Costs
3 Criteria
N/A
$785,000
9 Criteria
$0
$785,000
536
-10-
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-11
Standard Technology
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization /dispose in on-site
RPM land vault/incinerate debris/
synthetic membrane cap
Slurry wall/excavate/remove debris/ ,
screen, shred, crush/incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/ash disposal in RMP land
vault/synthetic membrane cap
Slurry wall/excavate soil/debris
removed/screen, shred, crush/incinerate
solids/soil fixation/return fixed soil to
site/multilayer cap/excavate solid waste/
removed debris/screen, shred, crush,
magnetic separator/incinerate/dispose
ash on-site in RPM land Vault
Slurry wall/excavate solid waste/remove
debris/screen, shred, crush, magnetic
separator/incinerate/ash disposal in RMP
land vault/excavate soil/stabilization/
place in RMP land vault
omitted
Excavate solid waste/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
$1,686,000
$1,319,000
$2,017,000
$3,774,000
$3,039,000
$2,590,000
omitted
k/A
9 Criteria
eliminated
$1,319,000
eliminated
eliminated
eliminated
$2,590,000
omitted
$4,456,000
Site 3C

Alternative
RAA-1
i
Standard Technology
No action
,

Estimated Costs
3 Criteria
N/A
9 Criteria
$0
-11-
537
-------
Alternative
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-1 1
Standard Technology
Slurry wall/excavate/ stabilization/
multilayer cap
Slurry wall/excavation/remove debris/
screen, shred, crush/incinerate/ fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavation/screen, shred,
blend/stabilization/disposal in on-site
RPM land vault/synthetic membrane
cap/incinerate debris
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/ash disposal in RMP land
vault/multilayer cap
Slurry wall/excavate soil/remove debris/
screen, shred, crush/incinerate solids/soil
fixation/return fixed soil to site/
multilayer cap/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/dispose
ash on-site in RPM land vault
Slurry wall/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/ash
disposal in RMP land vault/excavate
soil/stabilization/place in RMP land
vault/synthetic membrane cap
omitted
Excavate solid waste/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
$869,000
$2,214,000
$1,650,000
$2,723,000
$5,425,000
$3,935,000
$3,062,000
omitted
N/A
9 Criteria
$869,000
eliminated
$1,650,000
eliminated
eliminated
eliminated
$3,062,000
omitted ||
$2,215,000
538
-12-
-------
Site 3D
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-1 1
Standard Technology
No action
Slurry wall/excavate/ stabilization/
multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap/incinerate debris
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/ fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/ash disposal in RMP land
vault/synthetic membrane cap
Slurry wall/excavate soil/remove debris/
screen, shred, crush/ incinerate solids/
soil fixation/return fixed soil to site/
multilayer cap/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate solid
waste/dispose ash on site in RPM land
vault
Slurry wall/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/ash
disposal in RMP land vault/excavate
soil/stabilization/place in RMP land
vault/synthetic membrane cap
omitted
Excavate sludge/remove debris/screen,
shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
I Estimated Costs
3 Criteria
N/A
$438,000
$1,150,000
$877,000
.$1,395,000
•' " r
$2,637,000
$1,789,000
$1,4181,000
omitted
K/A
' , -13-, ' -
9 Criteria
$0
$438,000
eliminated
$877,000
eliminated
eliminated
eliminated
, $1,481,000
omitted „
$2,055,000
======
,....:. c
539
-------
Site 3E
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
RAA-8
RAA-9
RAA-1 0
RAA-1 1
Standard Technology
No action
Slurry wall/excavate/ stabilization/
multilayer cap
Slurry wall/excavate/remoye debris/
screen, shred, cnish/incinerate/ fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap/incinerate debris
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/ash disposal in RMP land
vault/synthetic membrane cap
Slurry wall/excavate/remove debris/
incinerate/ash disposal in RMP land
vault/treated soil returned to site/
multilayer cap
Slurry wall/excavate soil/remove debris/
screen, shred, crush/incinerate solids/
stabilize soil/dispose in RMP land vault/
excavate solid waste/ remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash on site in RPM
land vault
omitted
omitted
Excavate solid waste/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
N/A
$1,439,000
$3,288,000
$2,373,000
$4,023,000
$7,925,000
$6,393,000
$4,621,000
omitted
omitted
N/A
9 Criteria
$0 .....
$1,439,000
eliminated
$2,373,000
eliminated
eliminated .
eliminated
$4,621,000
omitted
omitted
$4,428,000
540
-J4-
-------
Site 3 General
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-1 1
Standard Technology
No action
Slurry wall/excavate/ stabilization/
multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/ fixation/
return fixed material to site/multilayer
cap ,
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/ fixation/
place fixed material into, on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/ash disposal in RMP land
vault/synthetic membrane cap
Slurry wall/excavate soil/debris
removed/screen, shred, crush/ incinerate
solids/soil fixation/ return fixed soil to
site/multilayer cap/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/inciherate/dispose
ash on site in RPM land vault
Slurry wall/excavate solid waste/remove
debris/screen, shred, crush, magnetic
separator/incinerate/dispose ash in RMP
land vault/excavate soil/stabilization/
place in RMP land vault/synthetic
membrane cap
omitted
Excavate solid waste/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP I?K! vault
Estimated Costs
3 Ciriteiria
N/A
$6,085,000.
$13,080,000
$10,000,000
$16,2126,000
i ••
$27398,000
$23,2121,000
i
$19,167,000
i.
omitted
N^A
9 Criteria
$0
$6,085,000
eliminated
$10,000,000
eliminated
eliminated
eliminated
$19,167,000
omitted
$18,485,000
' :
f -
•• •/ . • . I5-. ' •- • ,'• • ; • -5
541
-------
Site 4A
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-1 1

Standard Technology
No action
Slurry wall/excavate/stabilization/
multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crush/incineration/
fixation/return fixed material to site/
multilayer cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in RMP land
vault/synthetic membrane cap
Slurry wall/excavate soil/remove debris/
screen, shred, crush/incinerate solids/soil
fixation/return fixed soil to site/
multilayer cap/excavate sludge/remove
debris/screen, shred, crush, magnetic
separator/incinerate sludge/dispose ash
on site in RPM land vault
Slurry wall/excavate sludge/remove
debris/screen, shred, crush, magnetic
separator/incinerate sludge/dispose ash
in RMP land vault/excavate soil/stabil-
ization/place in RMP land vault/
multilayer cap
omitted
Excavate sludge/remove debris/screen, ,
shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
N/A
$473,000 .
$599,000
$509,000
$640,000
$860,000
$494,000
$466,000 ,
omitted
N/A
9 Criteria
$0
$473,000
eliminated
$509,000
eliminated
eliminated
eliminated
$466,000
omitted
$1,019,000
542
-------
Site 4B
Alternative
RAA-1
RAA-2
> - .
RAA-3
RAA-4
RAA-5
RAA-6
RAA-9
RAA-10
s
RAA-1 1
Standard Technology
No action
Slurry wall/excavate/ stabilization/ '
multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/ fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in RMP land
vault/synthetic membrane cap
Slurry wall/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/dispose
ash in RMP land vault/excavate soil/
fixation/place in RMP land vault/
multilayer cap
Excavate/remove debris/incinerate solid
w^ste/dispose ash in RMP land vault/ .
stabilize soil/place in RMP land vault/
synthetic membrane cap
Excavate sludge/remove debris/screen,
shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabiiize/place
in RMP land vault
Estimated Costs
, 3 Criteria
N/A
, $505,000
$594,000
$490,000
$561,000
$627,000
$609,000
N/A
N/A
9 Criteria
$0
$505,000
eliminated
$490,000
eliminated
eliminated
eliminated
$558,000
$1,525,000
-17-
543
-------
Site 4C
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-9
RAA-10
RAA-1 1
Standard Technology
No action
Slurry wall/excavate/ stabilization/
multilayer cap
Slurry wall/excavate/remove debris/
screen, shredu crush/ incinerate/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap/incinerate debris
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in RMP land
vault/synthetic membrane cap
Slurry wall/excavate solid waste/remove
debris/screen, shred, crush, magnetic
separator/incinerate/dispose ash in RMP
land vault/excavate soil/fixation/ .
multilayer cap
omitted
Excavate solid waste/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
N/A
$539,000
$672,000
$580,000
$720,000
$960,000
,$882,000
$822,000
* N/A
9 Criteria
$0
$539,000
eliminated
$580,000
eliminated
eliminated
$822,000
eliminated
$1,099,000
SiteS
Alternative
RAA-1
RAA-2
Standard Technology
No action >
Slurry wall/excavate/ stabilization/
multilayer cap ',
Estimated Costs
3 Criteria
,N/A
$2,062,000
9 Criteria
'. $0
$2,062,000
544
-18-
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
RAA-8
I
RAA-9
RAA-10
RAA-11
Standard Technology
Slurry wall/excavate/remove debris/
screen, shred,, crush/ incinerate/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in RMP land
vault/synthetic membrane cap
Slurry wall/excavate soil/remove debris/
screen, shred, crush/incinerate solids/soil
fixation/return fixed soil to site/
multilayer cap/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/dispose
ash on site in RPM land vault
Slurry wall/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/dispose
ash in RMP land vault/excavate soil/
stabilization/place in RMP land vault
omitted
Excavate solid waste/remove debris/ -'
screen, shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
$3,930,000
$2,578,000
$4,548,000
$7,825,000
$6,712,000
$5,310,000
omifted
N/A
9 Criteria
eliminated
$2,578,000
eliminated
eliminated
eliminated
$5,310,000
omitted
$6,377,000
Site 6 . • ,
Alternative
RAA-1

Standard Technology
No action
? -19-
Estimated Costs
3 Criteria
N/A
9 Criteria
$0
' • • , ' ' ' • '
545
-------
Alternative
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-9 -
RAA-10
RAA-11

Standard Technology
Slurry wall/excavate/ stabilization/
multilayer cap ,
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/ fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in RMP land
vault/synthetic membrane cap
Slurry wall/excavate sludge/remove
debris/screen, shred, crush, magnetic
separator/incinerate sludge/dispose ash
in RMP land vault/excavate soil/
stabilization/place in RMP land vault
Excavate/remove debris/incinerate solid
waste/dispose ash in RMP land vault/
stabilize soil/place in RMP land vault/
synthetic membrane cap
Excavate solid waste/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Estimated Costs
3 Criteria
$1,877,000
$5,666,000
$3,708,000
$7,129,000
$14,767,000
$11,793,000
$10,893,000
N/A
9 Criteria
$1,877,000
eliminated
$3,708,000
eliminated
eliminated
eliminated
$10,893,000
$8,705,000
Site?
Alternative
RAA-1
RAA-2
Standard Technology
No action
Slurry wall/excavate/ stabilization/
multilayer cap
Estimated Costs '
3 Criteria
N/A
$1,251,000
9 Criteria
$0
$1,251,000
546
-20-
-------
Alternative
RAA-3
RAA^4
RAA-5
RAA-6
RAA-8
RAA-9
RAA-10
RAA-11
Standard Technology
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/fixation/
return fixed material to site/multilayer
cap - • •
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/synthetic membrane
cap
Slurry wall/excavate/remoye debris/
screen, shred, crush/ incinerate/fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crash, magnetic separator/
incinerate/dispose ash in RMP land
vault/synthetic membrane cap
Slurry wall/excavate soil/debris
removed/screen, shred, crash/incinerate
solids/soil fixation/return fixed soil to
site/multilayer cap/excavate solid waste/
remove debris/screen, shred, crash,
magnetic separator/incinerate/dispose
ash on site in RPM land vault
Slurry wall/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/dispose
ash in RMP land vault/excavate
soil/stabilization/place in RMP land «
vault/multilayer cap
omitted
Excavate solid waste/remove debris/
screen, shred, crash, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
'Estimated Costs |
3 Criteria
$4,649,000
$3,023,000
$5,876,000
$12,384,000
$10,471,000
$9,52(5,000
omitted
N/A
9 Criteria
eliminated
$3,023,000
eliminated
eliminated
. eliminated
$9,526,000
omitted ||
$6,581,000
Site 8 .-:'.-•
• • • . > • " •
Alternative
RAA-1 •

Standard Technology
No action
Estimated Costs
3 Criteria
N/A
9 Criteria
$0
-21-
547
-------
Alternative
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
Standard Technology _
Slurry wall/excavate/
stabilization/multilayer cap
Slurry wall/excavate/remove debris/
screen, shred, crush/ incinerate/fixation/
return fixed material to site/multilayer
cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/multilayer cap - . .
Slurry wall/excavate/fixation/multilayer
cap
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in RMP land
vault/multilayer cap
Estimated Costs
3 Criteria
$10,100,000
$38,801,000
$28,078,000
$35,542,000
$31,749,000
9 Criteria
$10,100,000
eliminated •
$28,078,000
eliminated
eliminated
Site 9
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6

Standard Technology
No action
Slurry wall/multilayer cap
Slurry wall/remove structures/ excavate/
remove debris /screen, shred, crush/
incinerate/fixation/return fixed material
to site/multilayer cap
Slurry wall/remove structures/ excavate/
screen, shred, blend/ stabilization/
dispose in on-site RPM land vault/
synthetic membrane
Slurry wall/excavate/remove debris/
screen, shred, crush/incinerate/ fixation/
place fixed material into on-site RPM
land vault
Slurry wall/excavate/remove debris/
screen, shred, crush, magnetic separator/
incinerate/dispose ash in RMP land
vault/synthetic membrane cap
Estimated Costs
3 Criteria
N/A
$2,594,000
$11,806,000
$4,994,000
$13,122,000
$25,717,000
9 Criteria
$6
$2,594,000
eliminated
$4,994,000
eliminated
eliminated
*
548
-22-
-------
Alternative
RAA-8
RAA-9
RAA-10
RAA-11
Standard Technology
Slurry wall/excavate soil/debris
removed/screen, shred, crush/incinerate
solids/soil fixation/return fixed soil to
site/multilayer cap/excavate solid
waste/remove debris/screen, shred,
crush, magnetic separator/incinerate/
dispose ash on site in RPM land vault
Slurry wall/excavate solid waste/
remove debris/screen, shred, crush,
magnetic separator/incinerate/dispose
ash in RMP land vault/excavate soil/
stabilization/place in RMP land vault
omitted
Excavate sludge/remove debris/screen,
shred, crush, magnetic separator/
incinerate/dispose ash in on-site RMP
land vault/excavate soil/stabilize/place
in RMP land vault
Site 10
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action
Slurry wall/remove buildings and slab/
concrete cap
Remove buildings and slab/fixation/
replace buildings and slab
Remove buildings and slab/slurry wall/
excavate/incinerate/dispose in on-site
RPM land vault/concrete cap
Site 11
Alternative
RAA-1
RAA-2
Standard Technology
No action
Remove slab and fence/clay wall/
backfill/concrete cap

-23-
Estimated Costs
3 Criteria
$12,747,000
$8,719,000
omitted
N/A
9 Criteria
eliminated
$8,719,000
omitted
$21,171,000
Estimated Costs
3 Criteria
N/A
$423,000
$799,000
$1,694,000
9 Criteria
$0
$423,000
$500,000
eliminated
Estimated Costs
3 Criteria
N/A
$746,000
9 Criteria
$0
$746,000
549
-------
Alternative
RAA-3
RAA-4
Standard Technology
Remove slab and fence/clay wall/
excavate/remove debris/screen, shred, .
crush/incinerate/fixation/return fixed
material to site/concrete cap
Slurry wall/excavate/screen, shred,
blend/stabilization/dispose in on-site
RPM land vault/concrete cap/fencing
Estimated Costs
3 Criteria
$2,139,000
$944,000
9 Criteria
eliminated
$944,000
Proposed Plan and ROD
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action .
Slurry wall/multilayer RCRA cap
Excavate soil and sludge/stabilization
and solidification/dispose on site in
land vault
Excavate soil and sludge/remove
debris/incinerate soils with high levels
of contamination/stabilization-
solidification soils with low level
contamination/dispose ash and solid-
ified materials in RCRA land vault
Estimated Costs
PP
$0
$23,404,000
$66,648,000
$95,000,000
to
$131,677,000
ROD
$0
$23,400,000
$41:250,000
. $90,000,000
to
$116,250,000
*:>.
8. If a standard technology was chosen, why?

A standard technology was not chosen.

9. If an innovative technology was chosen, why?

RAA-5 was chosen because it was the most comprehensive and protective option. It proposes
the potential use of several innovative technologies. Four innovative technologies will be
tested during the design phase to determine their effectiveness in pretreating the waste to
enhance the efficiency of thermal treatment and solidification-stabilization or to replace these
standard technologies. Furthermore, several innovative in situ technologies will be tested and,
if proven effective, used to remediate soil below 20 feet. This alternative provided the greatest
protection to human health and,the environment because it addressed both the excavated soil
and the underlying soil. Soils below 20 feet that did not meet cleanup criteria were considered
important because they could contaminate ground water. This alternative provides the most
immediate response to removing contaminants closest to ground water. In addition, this was
550
-24-
-------
the only alternative that proposed treatment for contaminated soil belov^ 20 feet. The chosen
alternative also was preferred because it proposed incineration, a technology that has been
demonstrated effective in destroying site contaminants. Therefore, incineration ensures the
permanent reduction of contaminant toxicity, mobility, and volume and will substantially
reduce risk over the long term. Furthermore, incineration ensures that RCRA hazardous waste
regulations will be met. New equipment might be designed and constructed to meet thermal
treatment capacity needs.

The FS proposed approximately 10 RAAs for each of the 18 sites. The preferred alternative
for 1-7 sites included thermal treatment. In the FS, containment was preferred for one site (Site
8). In the ROD, this site was deferred by EPA and will be addressed u) a future operable unit.
i ''
i
The original Proposed Plan (6/30/90) identified nine RAAs, of which fiye were eliminated in
the Amended Proposed Plan due to their similarities. The preferred alternative in the
Amended Proposed Plan was thermal treatment. Following a review of j comments on the
Amended Proposed Plan, a Modification to the Amended Proposed Plan was prepared. The
Modification proposed an additional RAA that would rely on thermal destruction but would
allow the flexibility to test and use appropriate ex situ and in situ innovative technologies.
This additional RAA is comparable to RAA-5 in the ROD, the chosen silternative,

70. If an innovative technology was not chosen, why not? At what stage was the innovative
• technology eliminated? : •

Innovative technologies eliminated during the initial screening include tike following:

• None •. • • . • • '
i -

Innovative technologies eliminated during the screening of the three criteria include the
following: : „' I

• Bioslurry, was eliminated but no explanation was given.

Innovative technologies eliminated during the detailed analysis include the following:
. -; • i
• None -" . '•-..!'
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and long-term effectiveness and permanence
were weighted most heavily in selecting a remedy. The chosen alternative provides the best
overall protection through treatment of contaminated soils that could be jexcavated and
contaminated soils that would remain in place. The soils that would remain in place were
considered important because they could contaminate ground water and inhibit its cleanup for
551
-------
approximately another 100 years. Long-term effectiveness also was important and the chosen
alternative was considered superior in this regard. Other alternatives proposed less permanent
remedies such as containment, which would require long-term maintenance or
stabilization/solidification, which could potentially allow waste to leach into thu ground water.
Furthermore, there was concern that if excavated soil was found to have high levels of
contamination, solidification/stabilization would not be sufficient to comply with RCRA
disposal regulations.

No innovative technologies were eliminated for these reasons.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Surface Soil „

Cleanup levels for surface soils (i.e., the top 12 inches of soil) are based on a worker exposure
scenario and assume commercial/industrial land use. Cleanup levels also are based on a 1 x
10'6 carcinogenic risk level and a hazard quotient of 1 for noncarcinogens.
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
DDT
DDD
DDE
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC
17
24
17
1
3
2
4
Risk
Risk
, Risk
Risk
Risk
Risk
Risk
Noncarcinogens ,
Chlorobenzilate
Diazinon
39,922
1,796
Risk
Risk
Subsurface Soils

To protect ground water, cleanup levels for the contaminated subsurface soils are based on a 1
x 10"4 carcinogenic risk level and a hazard quotient of 1 for noncarcinogens. The health-based
cleanup levels were calculated using either the Summers or Pestan model. The Summers
model was used in areas where contamination has extended to or near the ground: water (Areas
1, 4, and 9) and the Pestan model was used for areas where an uncpntaminated zone exists
between the contaminated soils and the ground water (Areas 2, 3> 5, 6, 7, 10, and 11).
552
-26-
! iyf
fit:
-------
13.
Contaminant
Cleanup Level (mg/kg)
(Summers/Pestan)
ARAR or Other Basis
Carcinogens
DDT
DDD
DDE
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC .
5,034/7,500
6,758/7,500
16,527/17,250
4/156
17/152
3/154
1/37
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Noncarcinogens
Chlorobenzilate
Diazinon
209/340
10/10
Risk
.Risk
: \ i ,
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? | .
• ' ' ' •' ' !

Innovative technologies eliminated because of cleanup goals include:

• None ' ...

Standard technologies eliminated because of cleanup goals include:

" Stabilization/solidification of soils with high levels of contamination might not meet
KCRA hazardous waste disposal regulations.

14. Were treatability studies conducted on the innovative technology or standard technology?
- • ^ i
No treatability studies were conducted.
75.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Time to design/construct/operate/remediate
Proven reliability
-27-
553
-------
16. How are measures compared?

The chosen alternative was preferred because it quickly remediated the site through treatment
of underlying soils, whereas RAAs 1, 2, 3, and 4 would rely on natural flushing. It was
estimated that natural remediation of underlying site soils would impede the remediation of
ground water, causing cleanup to take 100 years. The chosen alternative not only removes the
source of ground water contamination but also decreases the time necessary to remediate
ground water through pump-and-treat technologies.

Proven reliability was also an important factor in selecting a remedy. Thermal treatment was
described as effective in the treatment of contaminants such as those found at the site. The
effectiveness of stabilization/solidification with organic contamination was considered
uncertain. , ,
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

EPA concluded that it would be technically impractical to excavate to depths below -20 feet
because the excavated area could cave in. This restriction defined the amount of soil that
could be treated ex situ; therefore, in situ technologies were necessary to treat contaminated
soil below 20 feet.
*

554
-------
Ciba-Geigy Corp. (Mclntosh Plant)
OU-4

Mclntosh, Alabama
Region 4 ,
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Subsurface Soil (mg/kg)

Volatile Organics

Benzene • . ' 1.04
Chlorobenzene 1.98
Chloroform 0.372
m-Xylene ' ' - 2,410
o- and p-Xylenes 1,200
Toluene 3,150

Base/Neutral Extractables

1,2,4-Trichlorobenzene 1.36
Nitrobenzene 0.269

Chlorinated Pesticides ;

Gamma-BHC 422
4,4'-DDD ' 42
4,4'-DDE 27.8
4,4'-DDT 47.8

Manufactured Pesticides

Ametryn 310
Atrazine 1,809
Bladex ,23
Cyanazine 74.2
Diazinon , 720
Galecron 750
Methidathion (Supracide) 41
Metolachlor (Dual), 150
Prometon 9.9
Prometryn 4,029
Propazine 1,180
Simazine ' 321
Terbumeton 42
-1-
Site IHistory
NPL Proposed:
NPL Final:
FS:
ROD:
PRP-lead
PRPs: Ciba-Geigy
FS prepared by: BCM
N/A /
9/83
1/90 (Final
revision 2/92)
7/14/92
Background
Corp.
Engineers Inc.
555
-------
Terbutryn
Terbuthylazine
Tolban

Metals

Arsenic
Chromium
Copper
Lead

Cyanides, total
75.5
280
3.9
150
1,490
22.5
180

10.5
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 63,000 cubic yards of subsurface soil
» 46,000 cubic yards of iron slurry waste
3. What type of site is this? '

Chemicals and Allied Products. An active chemical manufacturing company that produces
products such as pesticides, agricultural chelating agents, industrial sequestering' agents,
laundry brighiteners, plastics resins, and antioxidants. Located in an industrial setting, OU-4 is
the former waste management area, Site 8.
TECHNOLOGY SELECTION .

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:

Physical treatment:
Chemical treatment:
Thermal treatment:

Disposal:
Institutional controls (land and water use restrictions) ,'
Caps (multi- or single-layer: clay, synthetic membranes, asphalt,
concrete, soil mixtures), vertical1 barriers (soil bentonite slurry wall)
Fixation/stabilization (lime-based pozzolan, portland cement pozzolan,
silica based CHEMFIX process, HAZCON process), bulk removal
(mechanical, manual, semisolid), screening (grizzly screen, vibratory
screen), shredding (multiple blade), crushing/grinding (hammer mill),
blending/mixing (pugmill), magnetic separation (rotating drum), in situ
. deep soil mixing, volatile organics/air mixture^treatment, air drying
Neutralization
Incineration (rotary kiln, fluidized bed, infrared, circulating bed),
advanced electric reactor, liquid injection
Excavation, on-site landfill •
556
-2-
-------

' , I
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: \
«-i ,

Biological treatment: Anaerobic treatment, white rot fungus, co-oxidation, composting, solid
phase, bioslurry
Phys/Chem treatment: Chemical hydrolysis, chemical reduction, oxidation by hydrogen
peroxide, ozonation, oxidation by hypochlorite!, dechlorination (KPEG),
alkali metal/polyethylene glycol, solvent extraction, critical fluid
injection, in situ soil flushing, in situ vacuum extraction
Thermal treatment: Pyrolysis, high-temperature thermal desorptiocl, low-temperature
thermal desorption, vitrification
6. What was the cost estimate for the innovative technology? ,

During the initial screening process; in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. AJfter the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. '"The
estimated costs then are recalculated during an evaluation based on nine criteria established by
the NCP, The RAAs were consolidated in the Proposed Plan and ROD and are presented in
separate tables following the cost estimates provided for the three-criteria arid nine-criteria
screening. .
' ' ' • !
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)

Feasibility Study
Alternative
RAA-11

Innovative Technology
Remove contaminated water/organic
solid waste and low-level contaminated
soil treatment (excavation to 20 feet
maximum, debris removal, drying,
grizzly screen, shredder, vibratory
screen, hammer mill, magnetic separa-
tor, on-site rotary kiln incineratibn, ash
disposal in on^site vault)/nonhazardous
solids treatment (on-site rotary kiln
incineration)/elevated-level contam-
inated soil treatment (pugmill stabiliza-
tion, on-site disposal in vault)/on-site
fixation iron cake waste treatment/
possible further treatment (backfilling
with sandy soil, vertical isolation wall,
soil flushing with ground water)
Estimated Costs
I
3 Criteria
$49,723,000
,
['
|'
.'l
I
,|
!
1
i
i
1
i
1
- • / |
•
i . .
9 Criteria
$49,723,000

' -3-
557
-------
Fronted Plan and ROD
Alternative
Standard Technology
Estimated
Cost
RAA-4
Excavation/pretreatment could include solvent
extraction followed by liquid injection incineration, or
low-temperature thermal desorption followed by
volatile organics/air mixture treatment and/or critical
fluid injection followed by liquid injection
incineration/treatment could include solidification/
stabilization, possible blending followed by on-site
incineration, disposal in RCRA landvault, in situ soil
flushing, in situ vacuum extraction, in situ
bioremediation, and/or in situ fixation
$49,723,000
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5

Standard Technology
No action
Soil bentonite slurry wall/backfilling/
grading/multilayer cap/protective soil
cover/topsoil/vegetation
Soil bentonite 'slurry wall/excavation/
debris removal/grizzly screen/ shredder/
vibratory screen/hammer mill/on-site
rotary kiln incineration of nonhazardous
material/fixation/material returned to
site/multilayer cap
Soil bentonite slurry wall/excavation/
debris removal/grizzly screen/ shredder/
pugmill stabilization/on-site disposal in
RMP vault/debris decontamination/on-
site rotary kiln incineration of
nonhazardous solids/multilayer cap
Soil bentonite slurry wall/solid waste
fixed with in situ deep soil mixing/
backfilling/multilayer cap
Estimated Costs
3 Criteria
N/A
$10,909,000
N/A
$30,359,000
N/A
9 Criteria
N/A
$10,909,000
eliminated
r
$30,359,000
, eliminated
* I
558
-4-
-------

Alternative
RAA-6
/
Standard Technology
Soil bentonite slurry wall/soil and solid
waste treatment (excavation, debris
removal, grizzly screen, shredder,
pugmill stabilization, disposal in RMP
vault)/organic waste treatment (excava-
tion, debris removal, drying, grizzly
screen, shredder, vibratory screen,
hammer mill, magnetic separator, on-
site rotary kiln incineration, ash disposal
in on-site RMP vault)/nonhazardous
solids treatment (on-site rotary kiln
incineration)/multilayer cap
ikstiimated Costs
3 Criteria
N/A •'.
9 Criteria
eliminated
"Costs not given

Proposed Plan and ROD
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Soil bentonite slurry wall/multilayer cap/possible
solidification/stabilization/institutional controls

•s
Excavatiqn/solidification/stabilization/on-site disposal in
landvault/backfilling/vegetation/in situ fixation/possible
institutional controls
If a standard technology was chosen, why?
Standard technologies were chosen as part of RAA-4 discussed below.
Estimated
Cost
N/A
$10,909,000
$30,359,000

If an innovative technology was chosen, why?
: ' . ' . - ' .
RAA-4 from the Proposed Plan and ROD was chosen because it is the most comprehensive
and protective option. It proposes the potential use of several innovative technologies, which
will be tested during the design phase to determine whether pretreating [waste with them would
enhance the efficiency of thermal treatment and solidification-stabilization zind whether they
could replace these standard technologies. Furthermore, several innovative in situ technologies
will be tested and, if proved effective, used to remediate soil below 20 ;feet. This alternative
was the only one that proposed treatment for contaminated soil below 20 feet. This alternative
provided the greatest protection to human health and the environment because it addressed
both the excavated soil and the underlying soil. Soils below 20 feet thait did not meet cleanup
criteria were considered important to address because they ,would remain a source of ground
water contamination. This alternative provides the most immediate response to removing

-5- I 559
-------
contaminants that are the closest to ground water. The chosen alternative also was preferred
because it proposed incineration/a technology that has been demonstrated to destroy site
contaminants effectively. Incineration ensures the permanent reduction of contaminant
toxicity, mobility, and volume and will substantially reduce risk over the long term.
Incineration also ensures that RCRA hazardous waste regulations will be met. New equipment
might be designed and constructed to meet thermal treatment capacity needs. The iron slurry -
waste will be treated by in situ fixation because the waste is completely unsuitable for thermal
treatment or stabilization.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .

Site contaminants were categorized according to their treatability characteristics. Technologies
were then screened as to their effectiveness in reducing concentrations of the contaminant
groups. One objective of the evaluation was to select representative process options, if
possible, for each technology type to facilitate further evaluation. The representative
technologies were then used to develop performance specifications during preliminary design.
The following innovative technologies were not selected as representative technologies during
the initial screening and no explanation was provided:

Anaerobic treatment
White rot fungus
Co-oxidation (co-metabolism)
Composting
Solid phase
Bioslurry
Chemical hydrolysis
Chemical reduction
Oxidation by hydrogen peroxide
Alkali metal/polyethylene glycol
Pyrolysis
High-temperature thermal desorption
i
Note: Bioremediation could be included in the final remedy; however, no technologies were
specified.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Long-term effectiveness, permanence, and protection of human health and the environment
were weighted most heavily in selecting a remedy. The alternative was chosen because it
provides the best overall protection through treatment of excavated contaminated soils, as well
as of contaminated soils that remain in place. Treatment of excavated soils includes
solidification/stabilization, dechlorination if proved effective during remedial design, and/or on-
560
-6-
-------
site thermal treatment (not specified). Treatment of soils remaining in J>lac« includes
stabilization/fixation of iron slurry wastes, and soil flushing, vacuum extraction and/or '•
bioremediation, depending on the level of effectiveness or determined during the remedial
design. The soils that remain in place are a source of contamination tci ground water and
could inhibit its cleanup for approximately another 100 years. The chosen alternative was
considered superior in its long-term effectiveness. Other alternatives proposed less permanent
remedies, such as containment, which would require long-term maintenance, or
stabilization/solidification, which could caiise leaching of waste into the ground water.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Surface Soil (top 12 inches of soil)
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens ,
Gamma-BHC
4
Risk8
Noncarcinogens
Diazinon
Bladex
Simazine
Atrazine
Prometryn
1,800
4,100
4,100
10,000
8,200
,

Risk
Risk
Risk

•
Risk
Risk
aA 1 x 10'6 carcinogenic risk level and a hazard quotient of 1 for noncarcinbgens was
used to establish cleanup level. ' ! . .

Subsurface Soils , j .
Contaminant
Cleanup Level (mg/kg)
(Summers/Pestan)
ARAR or Other Basis
Carcinogens
Gamma-BHC
1.0/105
Bisk3
Noncarcinogens
Diazinon
Bladex
Simazine

Atrazine
3.6/61
2.0/37
3.7/1,000

3.6/19
Risk
Risk
Risk

Risk
-7-
561
-------
Cleanup Level (mg/kg)
(Summers/Pestan)
ARAR or Other Basis
•Cleanup levels for the contaminated subsurface soils were derived to protect ground
water and are based on a 1 x 10"4 carcinogenic risk level and a hazard quotient of 1 for
noncarcinogens. The health-based cleanup levels were calculated using either the
Summers or the Pestan model. The Summers model was used in areas where
contamination has extended to or near the ground water and the Pestan model was
used for areas where an uncontaminated zone exists between the contaminated soils
and the ground water. ' ' -
13. Was the innovative technology eliminated because of the cleanup goals? Cbuld the standard
technology meet the cleanup goals? ^anaara

Innovative technologies eliminated because of cleanup goals include:

• ' None • • •' .

Standard technologies eliminated because of cleanup goals include:

• Stabilization/solidification

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Time to design/construct/operate/remediate
Proven reliability
16. How are measures compared?

The chosen alternative was preferred because it quickly remediates the site through treatment
of In r§, ' NatUral remediation of underiyi*g *te soils would impede the remeSon
of ground water causing ground water cleanup to take an estimated 100 years. The chosen
alternative not only would remove the source of ground water contamination but also wouW
decrease the time necessary to remediate ground water through pump-and-treat technologies.

Proven reliability also was an important factor in selecting a remedy. Thermal treatment has
been demonstrated to be effective in treating contaminants such as the site's. The
effectiveness of stabilization/solidification with organic contamination was uncertain.
562
-8-
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ! ,
• • ' " I-. •
EPA concluded that excavating soils that are deeper than 20 feet would be technically
impractical because the excavated area could cave in. Since the amoiint of soil that could be
treated ex situ was therefore limited, in situ technologies were necessary to treat contaminated
soil below 20 feet.
-9-
563
-------
Florida Steel Corp.
OU-1
Indianitown, Florida
Region 4
GENERAL SITE
1.
2.
3.
What were the principal contaminants
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Emissions Control (EC) Dust (mg/kg)

Cadmium
Lead
Zinc
956
27,600
242,000
Soil/Sediment (mg/kg)
Cadmium
Lead
Zinc
PCBs
380 .
17,000
110,000
1,100
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
12/82
3/13/92
6/30/92
Background
PRP-lead
PRPs: Florida Steel Corporation
FS prepared by: Ardaman &
Associates, Inc.
Concentrations of principal contaminants in incineration ash and slag were not reported.
What volume of material is to be. remediated?

The volume of material to be remediated included:
10,700 cublc yards of incinerator ash contaminated with metals
What type of site is this?

Prima, Meta, Product, A fonner «, mill bordered by
«*».•••
564
-i-
-------
TECHNOLOGY SELECTION
'! . '
4. What standard technologies were considered for selection in this FS?
- ' •' •'.
This FS did not have an initial screening phase, therefore, standard technologies considered in
the development of remedial alternatives were: j

PCB-Containing Soil

Chemical treatment: Stabilization/solidification !
Thermal treatment: Incineration. . j
Disposal: , Excavation, off-site disposal at RCRA/TSCA facility, pn-site disposal
* • •• • .!' •-,.'...
Lead-Contaminated Soil/Sediment, EC Dust, and Incinerator Ash

Containment: RCRA cap \
Chemical treatment: Stabilization • . , .
Disposal: Excavation, off-site disposal at "HTMR" facility, on-site disposal at
RCRA-type landfill facility !. '
5. Was an innovative technology considered in the FS? If so, which technology?

This FS did not have an initial screening phase, therefore, innovative technologies considered
in the development of remedial alternatives were: t

PCB-Containing Soil j

Biological treatment: Biological treatment !.
" '•!*'.• ^
Lead-Contaminated Soil/Sediment, EC Dust, and Incinerator Ash

Thermal treatment: In situ vitrification

6. What was the cost estimate for the innovative technology? |

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the.FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during sin evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implemeritability; cost; state/support
agency acceptance; and community acceptance. *
585
-------
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
PCB-Contaminated Soil
Alternative
RAA-4
Innovative Technology
Excavation/biological treatment
Estimated Costs
3 Criteria
N/A
9 Criteria
eliminated
Lead-Contaminated Soil, Sediment, EC Dust, Incinerator Ash, and Slag
Alternative
RAA-7
Innovative Technology
In situ vitrification
Estimated Costs
3 Criteria
N/A
9 Criteria
eliminated
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

PCB-Contaminated Soil
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Excavation/off -site disposal of soil
with greater than 50 ppm PCBs/on-
site solidification of soil with 25 to 50
ppm PCBs
Excavation/on-site incineration/disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$0
$306,750
eliminated
Lead-Contaminated Soil, Sediment, EC Dust, Incinerator Ash, and Slag
Alternative
RAA-1
RAA-2
Standard Technology
No action/long-term monitoring
Excavation/off-site treatment at high-
temperature metal recovery facility/off-
site disposal
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$345,000
$21,160,000
566
9.
"<-*-'% .iTfTT
)
-3-
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
Standard Technology
Excavation/on-site solidification/on-
site disposal in RCRA landfill with
RCRAcap.
Excavation/solidification/on-site
disposal in single-lined landfill with
RCRAcap
RCRA cap over contaminated area
Excavate/consolidate/RCRA cap
Estimated Costs
3 Criteria
. N/A
WA
. N/A
N/A
9 Criteria
$6,698,000
$6,098,000
eliminated
eliminated
8. If a standard technology was chosen, why?

PCB-containing soil: A standard technology was chosen because it y ill. greatly reduce the risk
of dermal contact and ingestion of PCB-containing soil. PCB mobility will be reduced
through treatment. Stabilization of PCB-contaminated soil will provide a long-term and
permanent solution. This technology is proven and readily available for implementation. Soil
with high levels of PCB contamination will be disposed of off site and therefore contamination
will be reduced permanently. !

Lead-contaminated media: The chosen alternative was preferred because it will greatly reduce
the risk of dermal contact and ingestion of metal-containing soil, including EC dust, by
solidifying the waste and disposing of it in an on-site landfill. It offers a permanence and
long-term effectiveness because contaminants will be bound in a cement matrix. Through
solidification and disposal in a RCRA double-lined landfill, this alternative provides an extra
measure of ground water protection. This alternative is cost-effective;. ,

The preferred alternative in the FS for lead-containing soil was RAA^4, considered the most
cost-effective alternative. In the Proposed Plan and ROD, however, :RAA-3 was deemed more
cost-effective, and became the preferred alternative. RAA-3 will be more protective of ground
water since it proposes disposal in a double-lined landfill instead of a single-lined landfill.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen^ why not? At what stage was the innovative
technology eliminated?
.
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implernentability, and cost; or during the detailed evaluation.
-4-
567
-------
Innovative technologies eliminated during the initial screening include the following:

• None ,

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Biological treatment for soil with PCBs was eliminated because "discussions with EPA
Headquarters, TSCA Branch indicated that the effectiveness of this technology for
PCB contamination had not been demonstrated."
• In situ vitrification for lead-containing soil was eliminated because it was not
considered implementable for the shallow depth of EC dust requiring remediation.
Also, the technology was regarded as unproven with excessively high costs but no
significant advantage in performance.

Innovative technologies eliminated during the detailed analysis include the following:

Protection of human health and the environment and implementability were weighted most
heavily in selecting a remedial alternative. No innovative technologies were eliminated,,
however, based on these criteria.
72.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
568
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Lead (soil)
Lead (slag)
PCBs
600
1,360
25
EPAa
Risk"
TSCAC.
Tlie soil lead cleanup level was derived based on the leachability of lead from soil
into the ground water. EPA's cleanup level for lead in ground water, 15 ppb, was
used as the basis for the derivation.
bSlag lead cleanup levels were developed to protect human health in an industrial
setting. Slag is not subject to cleanup levels based on ground water protection because
it-produces low levels of lead in leachate and does not" threaten ground water at levels
below 1,360 ppm.
•Toxic Substances Control Act PGB spill policy for areas with restricted access.
-5-
EiM
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? !

Innovative technologies eliminated because of cleanup goals include: | . -
' - . ' > •
• None . j .

Standard technologies eliminated because of cleanup goals include: ;
I . - t ^ ,
• None
i . i .'.'..
' . f
14. Were treatability studies conducted on the innovative technology or standard technology?
'•'••.. i -
No treatability studies were conducted. .
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Time to design/construct/operate
- Proven reliability ,
i • ,
•
• •••-- |/

16. How are measures compared?
• • - i '
Time to implement the remedy was a consideration. RAA-2 for lead contamination was
eliminated because it would take significantly longer to implement depending on the off-site
treatment/disposal facility's capacity to accept waste. Proven reliability also was a
consideration. Two innovative technologies, in situ vitrification and biological treatment, were
eliminated because their reliability was uncertain. i

I1
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ,

No technical considerations were primary in selecting a remedial alternative.
-6-
569
-------
Geigy Chemical Corp. (Aberdeen Plant)
0U-4

Aberdeen, Moore County, North Carolina
Region 4
GENERAL SITE INFORMATION
/.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Surface Soil (mg/kg)

Aldrin
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC
DDD
DDE
DDT
Dieldrin
Endrin Ketone
Alpha-chlordane
Gamma-chlordane
Toxaphene
Heptachlor
Heptachlor epoxide
Endosulfan I
Endosulfan sulfate
14
21
4.1
19
3.2
28
11
54
9.7
0.28
0.045
0.049
450
500
21
18
2,000
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
10/4/89
3/92
8/27/92
Background

PRP-lead
PRPs: Ciba-Geigy Corp., Olin Corp.,
Kaiser Aluminum & Chemical
Corp., Lebanon Chemical Corp.,
Aberdeen and Rockfish Railroad,
Columbia Nitrogen Corp.
FS prepared by: Sirrine Environmental
Consultants
r
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• Less than 1,000 cubic yards of soil (ROD)

3. What type of site is this? '

Agricultural Chemicals. Located in a sparsely populated residential area, the site is a former
pesticide formulator and distributor of liquid and dry fertilizers. A railroad traverses the site's
southern portion.
570
-------
TECHNOLOGY SELECTION |

4. What standard technologies were considered for selection in this FS? \

Standard technologies considered during the identification and screening of technically feasible
technologies were: [ .

Containment: Cap . T i • .
Physical treatment: Classification (pretreatment)
Chemical treatment: Stabilization/solidification
Thermal treatment: Off-site commercial incineration, bn-site incineration
Disposal: Off-site commercial landfilling, on-site landfill
1.1 •
. . ' ~ . '

5. Was an innovative technology considered in the FS? If so, which technology?
• • ' ' • [ . ,
Innovative technologies considered during the identification and screening of technically
feasible technologies were: '

Biological treatment: Land treatment, bioreactor, hi situ enhanced biodegradation ,
Phys/Chem treatment: Supercritical CO2 solvent extraction, critical fluid solvent extraction,
' Basic Extraction Sludge Technology (BEST) process, soil washing, in
situ soil flushing, in situ vapor extraction I
Thermal treatment: Supercritical water oxidation (MODAR, Inc.), jlow-temperature thermal
aeration (LTTA, by Canonie Environmental), X*TRAX system (by
Chemical Waste Management, Inc.), low-temperature thermal treatment
(LT3, by Weston Services, Inc.), low-temperalure thermal desorption,
vitrification
' " i . -

,6. What was the cost estimate for the innovative technology?

RAAs were revised and added in the ROD. Two tables are provided, one; for RAAs in the
Feasibility Study and one for RAAs in the ROD-
-2-- - • • , \ . •• -.'571
-------
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
ROD
Alternative
RAA-4
Innovative Technology
Excavation/low-temperature thermal desorption/soil
returned to original location
Estimated
Costs
ROD
$700,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Feasibility Study
Alternative
RAA-1
RAA-2A
RAA-2B
RAA-3A
RAA-3B
- -===
Standard Technology
No action
Incineration and off-site disposal of 140
cubic yards of soil
Incineration and off^she disposal of 670
cubic yards of soil/off-site disposal of
foundation debris
Capping of 140 cubic yards of soil
Capping of 670 cubic yards of soil and
foundation debris
=====
Estimated Costs
3 Criteria
$140,000
$127,000 to
$330,000
$510,000 to
$1,500,000
$180,000
$350,000
9 Criteria
$140,000
$110,000 to
$470,000
$380,000 to
$1,500,000
$240,000
$280,000
ROD
572
•
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Excavation/incineration (if needed) and off-site disposal
of top foot of soil exceeding remediation levels/off-site
disposal of foundation debris
Capping of soil exceeding remediation levels
============
Estimated
Costs
ROD
$140,000
$600,000
to
$2,440,000
$275,000
-3-
-------
Alternative
RAA-5
Standard Technology
Excavation/homogenization and sizing/on-site inci
on-site disposal

leration/
Estimated
Costs
ROD
$1,327,100
8. If a standard technology was chosen, why?

By excavating the soil and disposing of it in an approved landfill (precede*! by incineration, if
necessary) the soil is permanently disposed of and/or treated. Given the small volume of soil
that requires remediation, expensive and complex technologies would jnot be appropriate. Off-
site landfilling and off-site incineration have been conducted successfully on site contaminants
in the past. These technologies are reliable and cost-effective.
9. If an innovative technology was chosen, why?

" No innovative technology was chosen
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the piree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
" - -I - '
• I-
Innovative technologies eliminated during the initial screening include? the following:

• Land treatment was eliminated because many chlorinated pesticides require anaerobic
conditions before reductive dechlorination can occur. Landfarming fosters only
aerobic biodegradation of organic compounds.
Bioreactor was eliminated because successful biodegradation
of chlorinated pesticides
requires sequential anaerobic/aerobic bioreactor systems. Effective monitoring and
management of sequential processes would not be possible.
Supercritical CO2 extraction was eliminated because an EPA study found it to give
poor recoveries of adsorbed organics from activated carbon and synthetic resins, which
might reflect the process's effectiveness on other solid residuals. According to another
EPA study, this process's removal levels were greater than 40 percent for only 4 of 23
organic compounds tested. While pilot tests have been conducted on this type of
technology, no full-scale operations have been applied.
Critical'fluid solvent extraction was eliminated because the1 technology lacks sufficient
development. Though demonstrated under EPA's SITE program, the technology has
not yet been demonstrated for the removal of pesticides from soils. Additionally, no
full-scale application of the technology has been conducted at a Superfund site.
BEST (Basic Extraction Sludge Technology) process was eliminated because no full-
scale application of the technology has been conducted at a pesticide-contaminated
site. Though bench-scale tests using site soils indicate that soils containing pesticide
-4-
573
-------
11.
concentrations in excess of 1,000 ppm could be remediated to levels of less than 1
ppm, the technology was considered to be not fully developed.
« Supercritical water oxidation (MODAR, Inc.) was eliminated because the effectiveness
of the process with soils has not been sufficiently demonstrated.
• Soil washing was eliminated because the treatment's duration is insufficient for a
potential vendor to operate such a system. ' • .
• Low-temperature thermal aeration, (LTTA, by Canonic Environmental) was eliminated
because, given the small volume of site soils requiring remediation, the treatment
would not be cost-effective.
• X*TRAX system (by Chemical Waste Management, Inc.) was eliminated because given
the small volume of site soils requiring remediation, the treatment would not be cost-
effective.
• Low-temperature thermal treatment (LT3, by Weston Services, Inc.) was eliminated
because, given the small volume of site soils requiring remediation, the treatment
would not be cost-effective.
" In situ vapor extraction (SVE) was eliminated because generating and maintaining a
vacuum in surficial soils would not be a technically effective use of SVE
Furthermore, pesticide residuals in the site soils are not amenable to SVE due to their
low Henry's law values.
• In situ enhanced biodegradation was eliminated because biodegradation of chlorinated
pesticides requires sequential anaerobic/aerobic conditions, and controlling these
conditions within the upper foot of soil would be impractical.
» In situ soil flushing was eliminated because of concerns that mobilized contaminants
would not be recovered completely by the extraction system and, therefore, would
degrade ground water conditions. Furthermore, site-related pesticides have relatively
high Koc values, making them difficult to remove from soils.
• In situ vitrification was eliminated because the technology requires further
development. During a recent large-scale test at a Superfund site, a fire occurred in a
22IT1 °n SyStem' As a result'the sole marketer suspended the technology and
bPA Region 6 withdrew its order to use in situ vitrification at a Texas Superfund site.

Innovative technologies eliminated during the screening of the three criteria include the
following: ,

• None

Innovative technologies eliminated during the detailed analysis include the following:

• Low-temperature thermal desorption was eliminated because the low volume of
contaminated soils requiring remediation renders this alternative impractical at this site.

Long-term effectiveness and permanence was an important criterion in selecting a remedy
Off-site disposal and incineration would result in a permanent reduction in site risks .Low-
temperature thermal desorption and on-site incineration also could reduce risks These
technologies, however, were considered not implementable or practical given the small soil
volume requiring remediation..
0
574
-5-
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? [
13.
Contaminant
Cleanup Level (ing/kg)
ARAR or Other Basis
Carcinogens
Aldrin
Alpha-BHG
Beta-BHC
Delta-BHC
Gamma-BHC
Alpha-chlordane
Gamma-chlordane
DDD
DDE
DDT
Dieldrin
Endrin ketone
Toxaphene
0.113
0.28
1.15
NCb - , '
1.5
1.4
1.43
7.6
5.5
4.75
0.13
. NC /..
2.0
Risk8
Risk
Risk
Risk
Risk
Bisk
Bisk
Risk
Risk
Risk
Risk
Risk
Risk
Tor carcinogens, an excess upper bound individual lifetime cancer risk of between 10
to 10"6 was acceptable. % !
bNot calculated. |
' I
Note: As decided in the FS, the rate limiting compound for site riskis was toxaphene. The
removal of all toxaphene concentrations greater than 50 or 5 mg/kg youM result in a residual
LECR (not defined) of 10'5 or 10'6, respectively. Removing toxaphene also would reduce the
levels of BHC-isomers, DDT, and other pesticides concurrently. This decision was superseded
in the ROD by the cleanup levels presented in the table above.

i
Was the innovative technology eliminated because of the cleanup gotils? Could the standard
technology meet the cleanup goals?
, , •• " I
Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
-6-
575
-------
14.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted on the Basic Extraction Sludge Technology (BEST)
process. Bench-scale testing using soils from the site indicated that soils containing pesticide
concentrations in excess of 1,000 ppm could be remediated to levels of less than 1 ppm No
full-scale application of the BEST process, however, has been conducted at a site affected bv
pesticides. Because of its limited development, the BEST process was eliminated
-—r;
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: '

Cost/unit risk
Proven reliability
Preference for treatment (vs. containment)

16. How are measures compared?

A large number of technologies were eliminated because the small volume of contaminated
soils did not warrant using an expensive, complex technology. Furthermore, the selected
remedy is most cost-effective because it permanently treats the waste.

Proven reliability was another factor resulting in the elimination of a large number of
innovative technologies. Again the issue of the small volume was considered, in that the use
of such uncertain (and often expensive) technologies cannot be justified.

According to a section of the FS about statutory determinations, the chosen technology
satisfies the preference for treatment "by the use of off-site disposal which encompasses
incineration for the soils containing characteristic hazardous waste and land disposal for the
residual soils at an approved RCRA landfill." The issue of preference for treatment as
opposed to containment, however, is not expressed anywhere else in the report.
)
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were primary in selecting a remedy. The small volume of
contaminated soils resulted in the elimination of a number of innovative technologies because
or high costs. Because the soils requiring remediation were very close to the surface certain
technologies, such as vapor extraction, were deemed to be unsuitable
576
-7-
-------
Golden Strip Septic Tank Service
Simpsonville, South Carolina
Region 4 ;
GENERAL BYTE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
\
Soil/Lagoon Sludge (ppm)

Antimony 1,940
Arsenic 76
Cadmium 12,000
Chromium 97,200
Copper 69,900
Cyanide 4,520
Lead 5,290
Mercury 13.8
Nickel 6,140
> Zinc 77,600
Acetone 2
bis(2-Ethylhexyl)phthalate 130
2-Butanone 0.28
Chlorobenzene 38
PCE 18
. Toluene 12
Xylenes 11
1,2-Dichloroethene 0.077
Ethylbenzene 1.9
Methylene chloride 0.073
Styrene 0.19 .
1,1,1-Trichloroethane 0.15
Site History
NPL Proposed:
NPL Final;
FS:
ROD:
1/87
6/87
5/91
9/12/91
Background
• ' .1 . '
I • .
PRP-lead
PRPs: Metal Products Corp., Sterling
Drug, Inc., 'Colonial Heights
Packing, Injc., E-Systems, Inc.,
W.R.Grace & Co.-Conn., BASF
Corp., and Carolina Plating and
r' Stamping Corp.
FS prepared by: RMT, Inc.
2., What volume of material is to be remediated?

The volume of material to be remediated included:

• Approximately 28,000 cubic yards of soil and lagoon sludge
3. What type of site is this?

'Uncontrolled Waste Site. An inactive waste hauling and disposal facility.
-1-
577
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Soil/sludge

Access restriction:
Containment:

Physical/Chemical:
Thermal treatment:
Disposal:
Fencing, deed restrictions, conservation easement
Capping (asphalt, soil, clay, synthetic membrane, concrete,
multimedia), slurry wall, grout curtain
Physical separation, in situ precipitation, stabilization/solidification
Incineration (infrared, circulating bed, rotary kiln), roasting
Excavation, dredging, dewatering, landfilling (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Soil/sludge

Biological treatment: Batch biodegradation, in situ biodegradation
Physical/Chemical: Soil washing (Laidlaw, GSW), in situ steam stripping (Toxic
Treatment), vacuum extraction
Thermal treatment: Vitrification (in situ, ex situ), thermal separation
6. What was the cost estimate for the, innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial! alternative is in bold)
Alternative
RAA-7A
RAA-7B
Innovative Technology
Ex situ vitrification/on-site disposal of
solids '
Soil washing/on-site disposal of solids
Estimated Costs
3 Criteria
$19,400,000
$13,800,000
9 Criteria
eliminated
eliminated
578
-------
Alternative
RAA-8A
Innovative Technology
In situ vitrification
Estimated Costs
3 Criteria
$13,2(K),000
9 Criteria
eliminated
7. How did the cost(s) compare to standard technologies? '

Cost Estimates for RAAs That Include Standard Techncjlogies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-4
RAA-5
RAA-6
RAA-7C
RAA-8B
RAA-8C
- - ' i
Standard Technology
No action/long-term monitoring
Fencing/conservation easement
Composite cap
Multimedia cap
Excavation/stabilization/off-site disposal
of soil and sludge
Excavation/stabilization/off-site disposal
of sludge and capping of^soil
Excavatiori/on-site disposal of solids
Stabilization/solidification/on-site
disposal of solids
In situ stabilization/solidification
In situ precipitation
Estimated Costs
3 Criteria
$1,300,000
$1.400,000
$3,200,000
$3,500,000
$12,500,000
I
$$,1.00,000.
$7,0130,000
$4,5ittO,(M)0
-
1
'$4,100,000
$4,3tX),000
9 Criteria
$1,300,000
$1,400,000
$3,200,000
$3,500,000
$12,500,000
$6,100,000
eliminated
$4,500jOOO
$4,100,000
eliminated
8. If a standard technology was chosen, why? • \
- . ' , i .• " • • -
The chosen alternative was preferred because it offered the greatest protection of human health
and the environment since stabilization will immobilize contaminants! Stabilization will
eliminate the threat to human health by preventing direct contact with the identified waste
constituents. This technique also provides a "capping effect" over the less affected subsoils
containing waste constituents. This alternative can be carried out on site, which was preferred
since short-term risk would be increased if truck traffic is necessary for transport of materials
off site. This alternative will also provide long-term effectiveness and permanence since
contaminants will be immobilized and reduced in both toxicity and mobility. This alternative
is cost-effective. i
-3-
579
-------
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '

Innovative technologies eliminated during the initial screening include the following:

• In situ steam stripping was eliminated because organics constitute only a small portion
of site contaminants and a relatively flat topography is necessary to implement the
technology successfully.
» Vacuum extraction was eliminated because organic constituents are a minor fraction of
site contaminants.
» In situ biodegradation was eliminated because organic constituents are a minor fraction
of site contaminants.
« Batch biodegradation was eliminated because organic constituents are a minor fraction
of site contaminants.

Innovative technologies eliminated during the screening of the three criteria include the
following: .

" f* s!1" vitriflcati°" was eliminated because it has not been demonstrated technical
feasible for metal-bearing soils and sludges. The process does not appear capable of
treating volatile metals, such as arsenic and cadmium. The level of risk reduction
associated with this technology can easily be achieved by other remedial options in a
more cost-effective manner.
• Soil washing was eliminated because it would generate large quantities of hazardous
waste water that would require further treatment.
• In situ vitrification was eliminated because its technical feasibility has not been
demonstrated in the field. The level of risk reduction associated with this option can
be achieved by other remedial options in a more cost-effective manner.

Innovative technologies eliminated during the detailed analysis include the following:
\
• None
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and cost were the most heavily weighted
cntena in selecting a remedial alternative. Two innovative technologies, in situ vitrification
and vitrification, were eliminated due to their high cost. •
530
-4-
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? !
1 Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
r "
Carcinogens ,
Cadmium
1 Arsenic
Chromium6
Lead
PCE
Nickel
bis(2-Ethylhexyl)
phthalate
Methylene chloride
Tetrachloroethene
65
18 .
580
500
56
1,300
200
,380
56
Risk8
Background1*
Risk
EPAd
Risk
Risk
'Risk
Risk
Risk
Noncarcinogens
Acetone
Antimony
Copper
Cyanide
Mercury
Zinc
2-Butanone
Chlorobenzene
1 ,2-Dichloroethene
Ethylbenzene
Styrene
Toluene
- 1,1,1 -Trichloroethane
Toluene
Xylenes
6,000
26
2,400
1,300
20
13,000
3,000
1,200
1,200
6,000
95
12,000
5,500
12,000
120,000
Risk
Risk
Riisk

Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Since no federal standards for toxics in soil exist, health risk-based calculations,
assuming future residential use, were used to derive most clesinup levels.
-5-
531
-------
75.
Tor carcinogens, an excess upper bound individual lifetime cancer risk of 10'6 was
acceptable. For noncarcinogens, a Hazard Quotient of 0.3 was used to allow for
exposure to multiple contaminant^ whose effects might be additive
Tor arsenic, an excess upper bour.J individual lifetime cancer risk of 10'5 was used
because background levels exceed the typical cancer risk of 10'6
"The chromium cleanup level assumes that 10 percent of total chromium is in the
hexavalent state.
"The lead cleanup level is based on EPA guidance for Superfund Sites OSWER
Directive 9335.4-02. '
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None .

Standard technologies eliminated because of cleanup goals include:

• None , -
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Preference for treatment (vs. containment)
Cost-effectiveness
Short-term risk to site workers
Proven reliability
16. How are measures compared?

Treatment was preferred over containment since containment would not be permanent or
effective in the long term. Source removal was eliminated because of the short-term risks
posed by transporting waste materials and the high costs. Two innovative technologies in situ
vitnficanon and ex situ vitrification, were eliminated because they were not cost-effective
v[t°riVfiL "y T a ^T- TW° inn°Vative technol°gi^ in «tu vitrification and ex situ
vitrification, were eliminated because their technical feasibility has not been demonstrated
The chosen alternative proposed stabilization, a proven technology that is easy to implement

Innov^^TV60, °cgy',S°iI WaSWng (LaidISW' GSX)> Was Proved effecti^ in a Superfund
Innovative Technology Evaluation (SITE) demonstration. This technology, however was
eliminated because it would generate waste. '
582
-6-
-------
17. What technical considerations were factors in selecting a remedy? Weft technical
considerations primary in the selection of the remedy? ,

No technical considerations were primary in selecting a remedial technology.
-7-
583
-------
Interstate Lead Co. (ILCO)
OU-1

Leeds, Alabama
Region 4
GENERAL SITE INFORMATION
1.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study ?

Maximum concentrations of principal
contaminants were:

Soil/Sediment (rag/kg)
Arsenic
Chromium
Lead
Antimony
1,500
71
130,000
1,600
What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:.
ROD:
N/A
6/86
7/91
9/30/91
Background

EPA Fund-lead
PRPs: Interstate Lead Co.
FS prepared by: CH2M Hill
Southeast, Inc.
The volume of material to be remediated included:

• 123,700 cubic yards of waste material
3. What type of site is this?

Primary Metal Products. Located in a mixed industrial and residential area, the site consists of
an 8.5-acre active lead smelting facility and seven subsites where waste (furnace slag battery
chips, and wastewater treatment sludge) was disposed. ,

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of. technically feasible
technologies were: . ••
Access restriction:
Containment:
Fencing, deed restrictions
Soil cover, cap (clay, asphalt, concrete, multilayer, synthetic
membrane, clay-geomembrane), block displacement, grout injection,
liners, surface sealing, grading, revegetation, drainage, curtain barriers
• cofferdams, stream diversion ' '
584
-i-
-------
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
•' "
Solidification/stabilization, neutralization [
Dewatering i
Incineration
Excavation, dredging, on-site disposal in RCRA landfill, off-site
disposal in RCRA landfill i
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: . % I "
•''"•• • ' ' - ' - • • ' i'. •
Biological treatment: In situ bioreclamation, on-site biological treatment
Phys/Chem treatment: In situ soil flushing, chemical reduction, soil \yashing, in situ soil
vapor extraction
Thermal treatment: In situ vitrification
What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into remedial alternatives.
How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard techiuoloigies
(selected remedial alternative is in bold)
Alternative
RAA-SC-1
RAA-SC-2
RAA-SC-3
RAA-SC-4
Standard Technology
No action
Multilayer cap
Excavation/off-site RCRA landfill
disposal
Excavation/solidification/replacement
on site/RCRA cap

' -2-
\ Estimated Costs
3 Criteria
N/A
N/A
N/A.
N/A
9 Criteria8
$5,000 to
$33,000
$310,000 to
$3,690,000
$820,000 to
$28,830,000
$680,000 to
$12,780,000
5S5
-------
Alternative
RAA-SC-5
Standard Technology
Excavation/move material to central
location/solidification/replacement on
site/RCRA cap
Estimated Costs
3 Criteria
N/A
9 Criteria8
$1,230,000
to
$12,780,000
The FS presents the results of an analysis of five remedial action alternative for seven
subsites. These results are summarized in the ROD and in the table above. The alternatives
are the same for each subsite, except for cost, which varies by waste volume. The costs
presented above represent the range of costs across individual subsites. '

& If a standard technology was chosen, why?

The chosen alternative was preferred because it eliminates the potential for human exposure to
contaminants via direct contact and reduces contaminant mobility, thereby decreasing the
potential for ground water contamination. Though it requires long-term maintenance, this
remedy offers long-term effectiveness through treatment by solidifying the waste.
Solidification was preferred because it is a proven technology and treatability studies have
demonstrated that it will treat the lead-contaminated waste material to below RCRA Land
Disposal Restriction levels. The chosen alternative minimizes short-term risk since it does not
require the transport of waste. Also, it is the most cost-effective option since it offers greater
protection than other alternatives but at a lower cost.
P. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ,

Innovative technologies eliminated during the initial screening include the following:

« In situ bioreclamation was eliminated because the process is not applicable to site
contaminants.
« In situ soil vapor extraction was eliminated because the process is not applicable to
site contaminants. , .
« On-site biological treatment was eliminated because the process is not applicable to
site contaminants. •
586
-3-
-------
Innovative technologies eliminated during the screening of the three criteria include the
following: |

• In situ soil flushing was eliminated because it would be difficult to implement at the
site. Because of the site's varied soil conditions, flushing would be inconsistent. High
clay and/or silt content would reduce the percolation of .surfactant through the. soil.
• Chemical reduction was eliminated because it would be difficult to implement given
the site's varied topography and subsurface obstructions. Sandy loam soil is preferred
to d&Y- v -^
• In situ vitrification was eliminated because it would be difficult to implement and less
effective given the buried metals and combustible solids. The retention of volatile
metals in the melt would be reduced nearer the surface. j
• Soil washing was eliminated because site-specific treatability studies indicate that
although implementable, the process would not be effective for the site conditions.

Innovative technologies eliminated during the detailed analysis include the following:

• None
11 ' Which of the nine criteria were weighted most heavily in selecting rfwj technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Cost and protection of human health and the environment were the mbst heavily weighted
criteria in the selection of a remedial alternative. Several innovative technologies (soil
flushing, chemical reduction, and in situ vitrification) were eliminated because they would be
difficult to implement.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Contaminant
Cleanup Level (mg/kg)
AFAR or Other Basis
Carcinogens :
Lead (soil)
Lead (sediment)
Arsenic
Chromium
(hexavalent) .
300
50
10
'1,750
teachability3
RASPL"
Risk6
Risk
Noncarcinogens
Antimony
32
Risk
"Soil remediation goal developed for protection of ground water. At this cleanup level,
leaching would not cause the level of ground water contamination to exceed 15 ug/L.
bRegional Aquatic Species Protection Level.
-4-
587
-------
Tor carcinogens, an excess upper bound individual lifetime cancer risk of W6 was
acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was
acceptable. , - -
13,
Innovative technologies eliminated because of cleanup goals include:
19 None

Standard technologies eliminated because of cleanup goals -include:

• None
14.
15.
17.
Were treatability studies conducted on the innovative technology or standard technology?
ah ofstabilization/solidification on lead-contaminated
soil from the site and another treatability study was conducted in 1990 on the waste and
contaminated soil in one subsite. Information from these studies was refernS tot thTpS and
supported the use of a stabilization/solidification process for site soil/sedtat Motion.

What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effective ,
Preference for treatment (v. containment)
Impact on nearby populations
16. How are measures compared? .

The chosen alternative, RAA-4, was considered to be the cost-effective option since it offers
comparable protection to RAA-5, but costs less. It also was preferred because ^
short-term risk by requiring the transport of materials that would pose a risk to woricT
the community Treatment was preferred over containment since both direct ™re a
contaminant mobility will be reduced; containment would address only direct exposure
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
' characteristics.
thnn o Slte S S011' 'oPWhy. and waste deposition, finding one "
technology that would be appropriate across all subsites was difficult. This technical
consideration was primary in selecting and eliminating remedial technologies
588
-5-
-------
JFD Electronics/Channel Master
Oxford, North Carolina
Region 4
GENERAL SITE INFORMATION
1.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sludge (mg/kg)
Chromium
Nickel
Antimony
Cadmium
Copper
Cyanide
Zinc
24,000
11,000
120
N/A
N/A
N/A
N/A
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
PRP-lead
PRPs: Unimax Coi-poration
Master, Granville
Developers
FS prepared by: B< chtel
Environmertal, Inc.
What volume of material is to be
remediated? • .

The volume of material to be remediated included:

• 3,000 cubic yards of soil/sludge
6/88
10/89
4/92
9/10/92
Background
ion, Channel
ille Industrial
3. What type of site is this?

Electrical Equipment. A former manufacturing facility that produced
satellite systems, the site is bordered by industrial and residential areajs.
television antennas and
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?
Standard technologies considered during the identification and
technologies were:
Access restriction: Fencing, deed restrictions
Containment: Capping (RCRA, non-RCRA), slurry wall,
block displacement
-1-
screening of technically feasible
sheet piling, grout curtain,
589
-------
Physical/chemical:
Thermal treatment:
Disposal:
Stabilization, surface encapsulation
Incineration
Excavation, landfill disposal (on-site, off-site)
3
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation ;
Physical/chemical: Chemical extraction, soil washing, soil flushing (in situ, ex situ),
'chemical reduction-oxidation, in situ vacuum/steam extraction
Thermal treatment: Low-temperature thermal stripping, vitrification (in situ, ex situ/
Vortec), pyrolysis
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of.RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment-
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support '
agency acceptance; and community acceptance.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4
RAA-5
Innovative Technology
Excavation/reduction-oxidation/
stabilization/backfill/cap
Excavation/on-site vitrification/
backfill/cap
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$1,151,000
$1,119,000
590
-2-
-------
7. How did the cost(s) compare to standard technologies? |
- . ' ' j •
Cost Estimates for RAAs That Include Standard Technoliogi(5S
(selected remedial alternative is in bold)
8.
Alternative
RAA-1
RAA-2
RAA-3
• . '
Standard Technology
No action/reviews
Fencing/deed restrictions/concrete cap
Excavation/disposal at RCRA TSD
facility
Intimated Costs
3 Criteria
N/A
N/A
N;|A
i
9 Criteria
.$333,000
$862,000
$2,400,000
If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?

The chosen alternative was preferred because it will reduce site risks. In addition, any further
degradation of the ground water will be mitigated ,by reducing the toxiicity and mobility of
contaminants in soil and sludge. The selected alternative will provide long-term effectiveness.
Following treatment by oxidation-reduction, which will destroy the inorganics in the
soil/sludge, stabilization techniques will immobilize remaining metals in the soil/sludge.
Oxidation of cyanide is a proven method of destruction and leaves no hazardous residuals.
Stabilization is a widely used treatment technology for inorganics. Berth technologies are
available from a large number of vendors. Short-term risks to the cornmumity are negligible
and workers' risk can be easily managed, The selected alternative wais deemed cost-effective.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tfiree criteria of "
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

'• Chemical extraction was eliminated because it would not be Applicable for the
treatment of metals and cyanide.
• Soil washing was eliminated because it would not be applicable for sludges.
• Ex situ soil flushing was eliminated because it would not be applicable to cyanides.
• Low-temperature thermal stripping was eliminated because it would not be applicable
to cyanide or metals.
• Biodegradation was eliminated because it would not be applicable to cyanide or
metals. . ' ,
-3-
531
-------
" Pyrolysis was eliminated because it would not be applicable to metals or cyanide
In situ vitrification was eliminated because it would not be applicable because of'the
proximity of the Bandag warehouse. *
• In situ soil flushing was eliminated because it would not be applicable to the
heterogeneous nature of the sludge waste and associated soil
" cyanlde^rmeSs""*
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard

technology meet the cleanup goals? , ;

Innovative technologies eliminated because of cleanup goals include: j

• None '

Standard technologies eliminated because of cleanup goals include:

• None >

14. Were treatdbility studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
i

- " i
75. What measures/criteria-were used to compare alternatives? '

The following measures were used to compare the alternatives: |

• ' • i
i • .
Cost-effective

Proven reliability i
I

I, •
!
76. How are measures compared?
• , • . • ' ' - - i •

When compared to three alternatives that offered treatment, the chosen alternative was

preferred because it was the most cost-effective and is a readily available, proven technology.

'.•,;., v ; • • / .

17. What technical considerations were factors in selecting a remedy? W^ere technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
-5-
593
-------
Marine Corps Logistics Base (MCLB)
OU-3

Albany, Georgia
Region 4
GENERAL SITE INFORMATION

/. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

PSC1 16 Subsurface Soil (rag/kg)

1,2,4-Trichlorobenzene 80
Hexachlorobenzene 2.2
Pentachlorobenzene 60
1,2,4,5-Tetrachlorobenzene 2
Tetrachlorobenzene 200
Trichlorobenzene 40
Aroclor-1260 (PCBs) 310

PSC 17 Surface Soil and Subsurface Soil
(mg/kg)

Benzo(a)anthracene 0.62
Benzo(b/k)fluoranthene 1.4 ...
Chrysene 0.68
Pyrene 14
Aroclor-1260 0.16
Chromium (total) 49,000
Chromium VI 87
Lead 3j900
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 30 cubic yards of soil at PSC 16
• 300 cubic yards of soil at PSC 17
Site History
NPL Proposed:
NPL Final:
FS:
Interim ROD:
N/A
12/89
7/92
8/14/92
Background

Federal Facility
PRPs: Department of the Navy
FS prepared by: ABB Environmental
Services, Inc.
Potential source of contamination (see Question 3)
594
-i-
-------
3. What type of site is this? !

Military. MCLB Albany is an active facility with 24 potential sources of contamination
(PSCs). Of these, 12 PSCs were identified for the Remedial Investigation/Feasibility Study
process and were divided into five operable units. OU-3 consists of PSC 16 and PSC 17.
PSC 16 is a former transformer location and PSC 17 is a chrome plating waste spill area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? [

Standard technologies considered during the identification and screening of technically feasible
technologies were: , i
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Fencing, institutional controls
Surficial capping (clay, asphalt)
Stabilization
Incineration (rotary kiln)
Excavation, on-site RCRA landfill, off-site RC;RA landfill
5. Was an innovative technology considered in the FS? If so, which technology?
\
Innovative technologies considered during the identification and screening of technically
feasible technologies were: ; '
, • ' .1 - • ' . •
Biological treatment: In situ biodegradation ' |. '
Chemical treatment: Soil flushing, soil venting, solvent extraction, phemical hydrolysis,
dechlorination, soil washing
Thermal treatment: Vitrification
6. What was the cost estimate for the innovative technology? j

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, ^fter the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability,;and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during ah evaluation based, on
nine criteria established by the NCP.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
- Alternative
RAA-5B
(PSC 17 only)
Innovative Technology
Excavation/soil washing

Estimated Costs
3 Criteria
N/A

9 Criteria
$606,100

-2-
535
-------
7.
How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Standard Technology
RAA-31
RAA-4A
(PSC 16 only)
:
RAA-4Bb
(PSC 17 only)

RAA-5A
(PSC 16 only)
Limited action/access restriction/
monitoring
Multilayer cap
Excavation/off-site incineration
Excavation/off-site stabilization/
landfill disposal

Excavation/disposal at TSCA landfill
f
»gy
•
tion/

an
tion/
—
landfill
=====
: .
Estimated Costs ,-J
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
•"
9 Criteria |
$0
$188,300
(PSC 16)
$99,900
(PSC 17)
$242,200 II
(PSC 16)
$190,000
• (PSC 17)
$327,800
$475,000 |
$198,200
The selected remedy for PSC 16 is RAA-3.
"The selected remedy for PSC 17 is RAA-4B.
8. If a standard technology was chosen, why?
Sound w 1116™, R°D -Hat a^reSS6S °nly P3rt °f ** MCLB site «W does "<* dr
ground water contamination. The remedial actions described in the Interim ROD are
however, the final actions for soil at PSC 16 and 17.

PSC 16
any
596
v wil1 ™°
-------
cover surrounding PSC 16 would readily support the installation of a cap with a paved cover
abutting the existing parking lot and concrete pad storage area. RAA--3 also will provide the
•" necessary long-term protection required for human health. The FS states that capping of waste
materials is a proven technology and is commercially available. The selected alternative will
meet federal and state ARARs, but will not meet the health-based TBCs (To Be Considered)
because wastes are contained and not treated.
. •!• - • j '
PSC 17 I •' ' ' .
, • • . '
The selected remedy for PSC 17, RAA-4B, incorporates excavation aind transportation of
contaminated soils to a permitted facility for stabilization and landfill jdisppsal. Stabilization of
the soils will reduce contaminant solubility and mobility, thereby reducing the potential
migration of contaminants. RAA-4B protects the public and the environment for all current
and future conditions through the excavation and treatment of soils. RAA-4B provides a
permanent solution to the exposure scenarios and reduces the toxicity,and mobility of soil
contaminants. Long-term risks will not be posed by the stabilization ^nd disposal of soils
from PSC 17 because the design mix for the stabilization of the confeimiriants in the soils
ensures that the potential leachate will not exceed RCRA Land Disposal Regulations ;
requirements (TCLP 5 mg/L). In addition, the actual disposal method for stabilized soils
ensures that the public and environment are protected from exposure ]to metals. No long-term
management or operation and maintenance (O&M) requirements would be associated with
RAA-4B. Also, the chemical technology used for stabilizing metals in soils has been proved
for both on- and off-base applications. Finally, although the selected j alternative does not ;
satisfy the health-based federal and state TBCs because contaminants are only contained, all
ARARs would be met by this technology.

9. If an innovative technology was chosen, why? . j

An innovative technology was not chosen. i •
.•'•"' . i. '
1 '
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
•- ' - '!''•. '• -
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the: three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ biodegradation was eliminated because neither PSC 16 nor PSC 17 would
contain contaminants that are biodegradable.
• Soil flushing was eliminated because this technology would not te effective for PCBs
and might adversely affect the building foundation at PSC 16. Also, leachate would
be difficult to collect and would require treatment prior to disposal.
• Soil venting was eliminated because it would not be effective on metals (PSC 17) of
pesticides/PCBs (PSC 16). j
• Solvent extraction was eliminated because the technology has had only limited pilot-
scale success on soils with high fines materials. The mix of contaminants might
require several treatment steps and solvents.

• • '• . •• ,' ' • , . .'••-4-""- ' ' ' -.'•[' / ' ' ': 597
-------
• Chemical hydrolysis (in situ) was eliminated because this treatment was developed
only for controlled industrial wastes. This technology also could affect the existing
building foundation and buried utility lines at PSC 16.
• Dechlorination (in situ) was eliminated because it would not be applicable to metals
(PSC 17). The technology also could damage the building foundation and the
electrical utility line at PSC 16. .
" Vitrification was eliminated because the volume of contaminated soil is less than the
minimum system designs of 1,000 cubic yards. The buried electrical conduit (PSC 16)
would short-circuit treatment.

Innovative technologies eliminated during the three-criteria screening include the following:

« The three-criteria screening process was not conducted in this FS.

Innovative technologies eliminated during the detailed analysis include the following:

« Soil washing was eliminated because although this technology would reduce the
mobility and volume of contaminants, it would not reduce toxicity. Instead, this
technology would concentrate contaminants into a process residual which would
require further treatment prior to its disposal off site at a permitted landfill facility.
Specific pilot testing -would be necessary to evaluate the soil treatment unit's
effectiveness and reliability before full operation could be implemented at PSC 17.
The use of surfactants to extract the contaminants from the soils requires careful
management and knowledge of reactions that might adversely affect the treatment
system. Water/surfactant systems pose some problems because a cost-effective
leachate treatment system has not yet been developed to extract the contaminants
selectively and pass the surfactants through intact for maximum recycling of the soil
wash solution. Implementation requires a high volume of water and electrical power
for the mobile treatment system.
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

PSC 16 Soil

Short-term effectiveness, implementability, and costs were weighted heavily in selecting the
remedial action for PSC 16. RAA-3 does not require soil excavation and therefore minimizes
potential impacts to the on-site building at PSC 16. In contrast, RAA-4A and RAA-5A both
would require excavating soils adjacent to and beneath the building foundation. In addition
the costs for RAA-3 were significantly lower than for alternatives RAA-4A and RAA-5A.
Overall protection of human health and the environment, and reduction of toxicity, mobility or
volume were weighted heavily in selecting the remedial action for PSC 17. The chosen
remedy protects the public and environment for all current and future conditions through the
treatment of soils. The chosen remedy, RAA-4B, reduces the contaminant toxicity and ,
mobility. In contrast, RAA-5B would not address the toxicity of soils but would concentrate
contaminants into a process residual requiring further treatment prior to its disposal.
533
-5-
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

These target cleanup levels were developed in the FS; they were not discussed in the ROD.

PSC 16 Soils ,
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens .
PCB-1260
5.8
Risk"
Noncarcinogens ,
Tetrachlorobenzene
(2 isomers)
96
Health-based"

Tor carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4
to 10~6 was acceptable.
"Cleanup level based on health based Remedial Action Objective.
PSC 17 Soils
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
PCB-1260
PAHsb
Lead
Chromium (2 foot
depth of soils)
Chromium (greater
than 2 foot depth of
soils)
1
, 0,45
264
80
.-, 265
EPAa
Health-based0
EFAd
EPAe
EPA"

"EPA regulatory guidance for recommended cleanup concentrations of PCB-1260,
OSWER Directive No. 9355.4-01, August, 1990.
"Carcinogenic PAHs were detected only in background sampleis. Though these
contaminants were assumed to be unrelated to the source of contamination at PSC 17,
a target cleanup concentration was set for them. \
'Cleanup level based on Remedial Action Objective.
dEPA, Human Health Evaluation Manual, OSWER Directive 9285.6-03, 1991.
eEPA, Supplemental Region IV Risk Assessment Guidance, March 26, 1991.
-6-
599
-------
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

" None

14.
75.
Standard technologies eliminated because of cleanup goals include:

« None / "

Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. According to the FS, however, treatability tests are
necessary to demonstrate the effectiveness of stabilization and to select the most effective
reagent process mix because the stabilization process (RAA-4B) is dependant on actual soil
and contaminant characteristics.

What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared?

PSC16

RAA-3 was considered cost-effective because it is protective of human health and the
environment and is less expensive than RAA-4A and RAA-5A.

PSC17

¥A:4B'JdthouSh significantly more expensive than RAA-3,,was considered more cost-

??A !!S faUSe, RAA'4B Wi" eliminate current and P°tential foture exP°s"re pathways
RAA-4B also will not require O&M, as will RAA-3. The chemical technology used to '
stabilize metals in soils is proven for both on- and off-base applications. The statutory
preference for treatment over containment was satisfied at PSC 17 because the selected remedv
employs a stabilization treatment. »^ucuy
600
-7-
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy. Toppgraphy and land
features at both PSC locations were conducive for the constraction of a cap and the installation
of monitoring wells.
-8-
601
-------
Maxey Flats Nuclear Disposal
Fleming County, Kentucky
Region 4
GENERAL SITE INFORMATION

L
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Radionuclides (pCi/g)
Tritium
Cesium-137
Cobalt
560,000
0.8
0.3
Soil/Organics (mg/kg)

Toluene 0.25

Soil/Inorganic (mg/kg)

Arsenic 106

Sediments/Radionuclides (pCi/g)

Tritium 70

Sediments/Organics (mg/kg)

Methylene chloride
Toluene
Acetone
2-Butanone
Di-n-octyl phthalate,
Phenanthrene
Fluoranthene
Pyrene
0.005
0.005
0.01
0.01
1.8"
0.51
0.41
0.38
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1984
1986
12/88
9/30/91
Background

PRP-lead
PRPs: U.S. Department of Defense, U.S.
Department of Energy, 82 PRPs
including radioactive waste
generators and transporters such
as private companies in the
nuclear industry, hospitals,
research institutions, and
laboratories
FS prepared by: Ebasco Services Inc.
2.
602
What volume of material is to be remediated?

The volume of material to be remediated included:
™ °f contaminated soil and sediment were not given in the FS or the
ROD. The proposed cap will cover approximately 40 to 50 acres. During the
-1-
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operation of the facility approximately 176,000 cubic yards of low-level, radioactive
waste was disposed in 52 large, unlined trenches (some of which were up to 680 feet
long, 70 feet wide, and 30 feet deep). ' |
3, What type of site is this?

Department of Energy. A former nuclear disposal facility, the site is surrounded'by woodlands
and open farmland. A number of residences, farms, and some small commercial establishments
are located on roadways near the site. > j
TECHNOLOGY SELECTION
—Mil ""•"' ' ' |

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: • • .\ . '
' ' ' ' !;' •••'••''-.
Soil/Sediments j
' "" . ' ' I
Access restriction: Institutional controls, monitoring
Containment: Capping, bulk heads, sheet piling, grading, dikes and berms,
compaction
Chemical treatment: Neutralization, in situ polymerization, in situ fixation/stabilization, in
situ chemical precipitation, solidification, activated carbon adsorption
Physical treatment: Solids processing, evaporation
Thermal treatment: Incineration ;
Disposal: Excavation, exhumation, on-site landfill, off-iiite landfill, deep well
injection, surface impoundments
5, Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: , . '

Soil/Sediments
!
Biological treatment: In situ biological processes,'permeable treatment beds :
Chemical treatment: Soil flushing, chemical oxidation
Thermal treatment: In sita vitrification, cryogenic freezing
6. ' What was the cost estimate for the innovative technology? j
I ' • . • ' . ,. . '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit, a more detailed evaluation. The
-2-
603
-------
7.
estimated costs then are recalculated during an evaluation based on nine criteria established by
the NCP. No innovative technologies were incorporated into remedial action alternatives.

How did the cost(s) compare to standard technologies?

Since the RAAs changed between the FS and ROD, separate tables are presented.

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Soil/Sediments

Feasibility Study
604
Alternative
L. _
RAA-1
j—
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
I RAA-8
RAA-9
RAA-10
RAA-1 1
Standard Technology
No action/monitoring
Leachate removal/complete trench
grouting/horizontal flow barrier
Pile-supported structural cap/horizontal
flow barrier
Structural cap/leachate removal/
horizontal flow barrier (Structural
cap/dynamic compaction/horizontal flow
barrier)
Synthetic cover/Ieachate removal
Modified synthetic cover/leachate
removal/injected grout
Engineered soil cap/synthetic liner/
leachate removal/injected grout
Engineered soil cap/synthetic liner/
leachate removal/injected grout/north
cutoff wall
Engineered soil cap/synthetic liner/
leachate removal/dynamic compaction/
horizontal flow barrier
Engineered soil cap/synthetic liner/
leachate removal/dynamic compaction/
injected grout/horizontal flow barrier
Engineered soil cap/synthetic liner/
leachate removal/complete trench
grouting/horizontal flow barrier
Estimated Costs
3 Criteria
$7,000
$50,000
. $62,000
$47,000
$27,000
$27,000
$27,000
$28,000
$36,000
$37,000
$52,000
9 Criteria
$12,000,000
eliminated II
eliminated
$58,000,000
eliminated
$36,000,000
$37,000,000
$41,000,000
$49,000,000
$50,000,000
eliminated
-3-
-------
•v1".
Alternative
RAArl2
RAA-13
RAA-14
RAA-15
RAA-16
RAA-17
RAA-18
RAA-19
RAA-20
RAA-21

Standard Technology
Engineered soil cap
Engineered soil cap/ground water
barrier
Engineered soil cap/leachate removal/
horizontal flow barrier
Engineered soil cap/leachate removal/
injected grout
Engineered soil cap/leachate removal/
injected grout/horizontal flow barrier
Engineered soil cap/leachate removal/
surface compaction " -. '
Engineered soil cap/leachate removal/
surface compaction/horizontal flow
barrier
Engineered soil cap/leachate removal/
dynamic compaction/horizontal flow
barrier ,
Engineered soil cap/leachate removal/
dynamic compaction/injected grout/ -
horizontal flow barrier
Engineered soil cap/leachate removal/
complete trench grouting/horizontal
flow barrier
Estimated Costs
3 Criteria
,$29,000
$32;000
$39,000
$37,000
$41,000
$37,000
$40,000
$46,0013
$47,000
$62,000
9 Criteria
eliminated
eliminated
eliminated
eliminated
eliminated
eliminated
eliminated
eliminated
$57,000,000
eliminated
Soil/Sediments
[ .
ROD ,
Alternative
RAA-1
RAA-4
RAA-5
RAA-8
Standard Technology
Estimated Costs
PP and ROD
No action/monitoring $6,803,000
Structural cap/dynamic compaction/horizontal flow1 $65,507,000
barrier
Natural subsidence/initial cap/final engineered s oil $33,553,000
cap/synthetic liner/horizontal flow barrier — . •
"Natural Stabilization"
Natural subsidence/immediate engineered soil $47,407,000
cap/synthetic liner/horizontal flow barrier
: . '• -- - .' -«- -. .'• ; .-•; , 6C
-------
Alternative
Standard Technology
Estimated Costs
PP and ROD
RAA-10
'Dynamic compaction/engineered soil cap/synthetic
liner/horizontal flow barrier
$44,328,000
RAA-11
Trench grouting/engineered soil cap/synthetic
liner/horizontal flow barrier
$68,859,000
RAA-17
Dynamic compaction/engineered soil cap/horizontal
flow barrier
$56,554,000
8. If a standard technology was chosen, why?

RAA-5 was chosen in the ROD because the natural stabilization process will allow the
materials to subside naturally to a stable condition prior to the installation of a final engineered
cap. Stabilization of the trenches by natural subsidence over a relatively long time period will
virtually eliminate the potential problem of future subsidence expected with other alternatives
in which the trenches would be stabilized by mechanical means and a final cap installed within
a few years. The natural stabilization alternative, therefore, will reduce the redundancy of
efforts necessary to construct and maintain the final cap. Natural stabilization does not disrupt
intact metal containers such as 55-gallon drams, thereby providing an extra measure of
protection to prevent movement of radionuclides to the hillsides. The other alternatives have
the potential of rupturing intact containers and releasing radioactive material immediately to
the trenches. Additional benefits of the natural stabilization alternative will be the opportunity
for continued data collection and analyses and the ability to take advantage of technological
advances during the subsidence period. .
-r
•
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Soil flushing was eliminated because it would not be implementable given site-specific
conditions. Many of the site contaminants have very low solubilities; therefore, very
large volumes of water would be required to flush out these contaminants. In addition
the method is not applicable to the site's soil and rock because of their low hydraulic '
conductivities. Also, since not all of the water injected would be recovered as
leachate, off-site migration could result.
606
-5-
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Cryogenic freezing was eliminated because this technology would not be
implementable at this site. The technology would require not ^>nly an extensive and
costly installation effort, but also long-term active maintenance and institutional care
and control. In addition, the technology lacks a Ipng-term performance record.
In situ vitrification was eliminated because it could not be implemented and it lacks a
suitable performance record. A collection system to gather and tnsat the effluents
generated by this process has not yet been designed or built for a site similar to Maxey
Flats. Also, trenches with a high metal content would pose a problem.
In situ biological processes were eliminated because these processes would not affect
,radiological contaminants, the bulk of site contaminants. Additionally, a major effort
would be required to implement biological processes effectively and this technology
has not been used at a site similar to Maxey Flat.
Permeable treatment beds were eliminated because their applicability to site-specific
conditions is limited by the nature of some of the contaminants. Additionally, the low
permeability of the site's soils and rock, and the indeterminate palthways and direction
of subsurface flows make this technology difficult to implement. This technology also
is difficult to implement because' the water level at this site is
relatively deep (25 to 30
feet), and treatment beds have limited lifetimes.
• Chemical oxidation was eliminated because it would not be effective for the
radiological contaminants, !
. . ^ * . • i, , •
Innovative technologies eliminated during the screening of the three criteria include the
following: I

• None j
) . ' , '- ' . [• •'..-•'•'•
Innovative technologies eliminated during the detailed analysis include the following:

. ' • None ' . • _ ., , '>•!.'•

11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
I
The difference between the six RAAs evaluated in the ROD were nol great except with regard
to the following four criteria: implementability; reduction of toxicity, mobility, or volume;
state acceptance; and community acceptance. All RAAs provide the same degree of long-term
and short-term effectiveness, overall protection of human health and the environment, and
ARARs. RAA-5, however, is the least difficult to implement, using proven and reliable
technologies to achieve final remediation, while not requiring- time-ceinsuming research and .
development prior to implementation. It is less likely to result in container rupture (which was
used to evaluate the alternatives reducing toxicity, mobility, and volume, thereby protecting
containers within the trenches. Finally, both the state and community favor the Natural
Stabilization technology. .(
I •

12.. What cleanup goals were selected? If the cleanup goal was based oh an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? ;
r
I . • ; • ' •
Specific cleanup goals were not provided. ';.
r

:6 I 607
-------
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75, What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability

16. How are measures compared?

The selected remedy was chosen because it utilizes proven and reliable technologies to achieve
final remediation and does not require extensive research and development prior to
implementation. In contrast, the state rejected the use of grouting (RAA-11) since the
technology would have to be demonstrated prior to its implementation.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting an alternative. The state however
rejected the use of RAA-10 and RAA-17 for either ajjite demonstration or total site
remediation because of uncertainties regarding dynamic compaction's effect on the underlying
geologic strata. In addition, soil flushing was:eliminated because this technology is not
applicable to the site's soil and rock because of their low hydraulic conductivities., Permeable
treatment beds were eliminated because of the low permeability of the site's soil and rock the
indeterminate pathways and direction bf subsurface flows, and the deep water level at this site
608
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Medley Farm Drum Dump
OU-1

Gaffney, South Carolina •
Region 4
GENERAL STTH INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum .concentrations of principal
contaminants were: ,
Soil (rag/kg)

1,1,2-Trichloroethane
1,1,2,2,-Tetrachloroethane
1,2-Dichloroethene
1,2-Dichloropropane
Ethylbenzene
Methylene chloride
Styrene
Tetrachloroethene
Trichloroethene
Vinyl chloride
1,2,4-Trichlorobenzene
Butylbenzylphtalate
Di-n-butylphthalate
Di-n-octylphthalate
Bis(2-ethylhexyl)phthalate
Toxaphene
PCB-1254
Chloroform
1,2-Dichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,1,1 -Trichloroethane
0.16
0.091
0.2
0.021
0.033
0.023
0.011
0.069
0.07
0.21
1.2.
1.1
1.1 '
5.4
33
0.52
1.9
0.06
3.7
0.047
0.014
0.56
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/86
3/90
3/91
3/29/91
Background
' i
PRP-lead |
PRPs: Not listed
FS prepared by: Sirrine Environmental
Consultants
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 53,000 cubic yards of soil
-1-
609
-------
3. What type of site is this?
a rural area.
for the disposal of industrial waste
6.
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS?

65 C°nsidered during *» *»«&*<* and screening of technically feasible
Deed restrictions
Capping, slurry walls, grouting, sheet piling, bottom sealing
Stabilization, fixation . *
Incineration (rotary kiln, infrared, fluiclized bed)
Off-site landfilling
Access restriction:
rh» ,
Chemical treatment:
Thermal treatment:
Disposal:
5. Was an innovative technology considered in the FS? If so, which technology?

during the i
Biological treatment: Bioreactor, landfarming, in situ biodegradation
Phys/Chem treatment: Soil washing, soil flushing, chemical oxidation, in situ soil vapor
extraction ,
Thermal treatment: Low-temperature desorption, in situ vitrification

What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After fhe RAAs have been
formulated costs are estimated as part of a three-criteria screening process (eff^eness
implementability, and cost) to identify alternatives that merit a more detailed evaluation 'The
Se NCP C°StS ""* "* rCCalCuIated durin* m "valuation based on nine criteria established by

Alternatives presented parenthetically represent changes in the ROD.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
(RAA-4)
Innovative Technology
Soil vapor extraction
Estimated Costs
3 Criteria
$500,000
9 Criteria
"~ •• .—
$620,000
610
-2-
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
(RAA-2)
RAA-2
(RAA-3)
Standard Technology
No action/long-term monitoring
Institutional controls/deed restrictions
Deed restrictions/low permeable cap/
long-term maintenance
Estimated Costs
3 Criteriia
$100,000
not proposed
$810,000
i
i.
9 Criteria
$140,000
$140,000
$1,000,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
.• I. ' • . •
9. If an innovative technology was chosen, why?

An innovative technology, soil vapor extraction (SVE), was preferred jbecause it will reduce
VOCs in the soils by more than 95 percent and thereby keep site soils from affecting ground
water quality. A treatment technology provides a permanent and long-term solution,
mitigating principal threats at the site. VOCs are the only site compounds that can raise
ground water contamination levels above MCLs, In contrast to natunil degradation of VOCs,
which would take 20 years, SVE will expedite the remediation of soil to approximately 1 year.
SVE also will reduce semi-VOCs, though no remedial levels have been set for semi-VOCs as
they will not raise ground water levels above MCLs. This technology was preferred because
its effectiveness has been demonstrated. SVE was shown to be effective in soil of similar
porosity and permeability in a Superfund Innovative Technology Evaluation (SITE)
demonstration and for similar seiruVVOCs at another NPL site (Bluff Road, Columbia, SC).
This alternative poses no short-term risks to on-site workers, is easily implemented, and is
readily available. i
10.
I- •., •
< ' • , '
If an innovative technology was not chosen, why not? At what stage ijvas the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Bioreactor was eliminated because it would require excavation.
• Land/arming was eliminated because it would require excayaitkm.
• Chemical oxidation was eliminated because it would require excavation.
-3-
611
-------
11.
« Soil washing was eliminated because it would require excavation.
• Low-temperature thermal desorption was eliminated because it would require
excavation. ,
« In situ biodegradation was eliminated because the low permeability of site soils would
limit its effectiveness. Furthermore, chlorinated VOCs at the site are resistant to
biodegradation because of their sorption to soils.
• Soil flushing was eliminated because its effective application would be limited by the
low permeability of site soil. Chlorinated VOCs also would be difficult to remove
from soil. The greatest concern was that mobilized compounds would not be removed
completely by the extraction system and would contaminate ground water. Also,
washing fluids would solubilize chemicals impeding their subsequent treatment
Finally, it was noted that soil flushing had recently failed an EPA demonstration test
• In situ vitrification was eliminated because it has not been widely used treating soil
depths similar to those at the site.'

Innovative technologies eliminated during the screening of the three criteria include the
following: ,

• None
1 •»* ' ,
Innovative technologies eliminated during the detailed analysis include the following:

• None ;
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology? '

Long-term effectiveness and the permanent reduction of contaminants were the most heavily
weighted criteria in selecting a remedial alternative. No innovative technologies were
eliminated, however, based on these criteria.
n' JSfp?^8oaf,wer,eselectfd? IfthecleanupgoalwasbasedondnARAR>whatwas'fa*
AKAR/ What risk level was selected to establish cleanup goals?

According to the baseline risk assessment, the cumulative chemical concentrations of surface
soil do not pose a significant risk to human health. Consequently, specific remediation goals
for surface soils were not developed. The levels of contaminants in subsurface soils, however
will continue to affect the ground water over an estimated 20 years. Therefore, remediation '
levels (the FS-specified remediation goals and not cleanup levels) for subsurface soils were
calculated based on a leaching model and MCLs for the protection of ground water
612
Cleanup Level (jig/kg) ARAR or Other Basis
-4-
-------
•'-•'• • ' • > ., .
Contaminant
Tetrachloroethene
Chloroform
Methylene chloride
Cleanup Level (jig/kg)
1,600
3,000
40
ARAR or Other Basis
Model/MCL
Model/MCL
Model/MCL
Noncarcinogens
Acetone
1 , 1 -Dichloroethane
1 , 1 -Dichloroethene
1 ,2-Dichloroethene
1,1,1 -Trichloroethane
1,1 ,2-Trichloroethane
12,000
100
270
2,100
26,000
160
Model/MCL
NJIodd/MCL
Model/MCL
Model/MCL
Model/MCL
ftjlodel/MCL
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
'
Innovative technologies eliminated because of cleanup goals include: |
' ' ' i-' •
•• i ' •
• None - •. • . . . ' . i, .

Standard technologies eliminated because of cleanup goals include:

» None ' •. I .
•
- . - ; -.'./. i.

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

- Proven reliability •'.;>..

16. How are measures compared? j

The chosen technology, SVE, was preferred because its effectiveness! has been demonstrated in
a SITE.demonstration for soils of similar porosity. It also has been shoAvn to be effective for
semi-VOCs at another NPL site (Bluff Road, Columbia, SC). Other
eliminated because their reliability was unproven. Soil flushing was
uncertainties concerning the potential mobilization of contaminants. It was noted that soil
technologies were
eliminated because of,
-5-
613
-------
flushing had recently failed an EPA demonstration test (Hazardous Waste Consultant 1988) -
In situ vitrification also was eliminated because its effectiveness at depths such as the site's
was undetermined.
77.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The depth of the contaminated soil, soil porosity, and soil permeability were all technical
factors that were primary in selecting a remedial alternative. Subsurface soil potentially
requiring remediation extends to approximately 65 feet below land surface. Since this .depth
would preclude excavation, all in situ technologies requiring excavation were eliminated The
depth of the soil requiring treatment also was a factor for eliminating in situ vitrification since
it had never been demonstrated at such great depths. Because of the low permeability of site
soils, in situ biodegradation and in situ soil flushing would not be effective. The soil
permeability and porosity were, however, sufficient for SVE to be effective.
614
-6-
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Oak Ridge Reservation (USDOE)
OU-1
(United Nuclear Corporation, also OU-1)

Y-12 Plant, Oak Ridge, Anderson County, Tennesseje
Region 4
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Drummed Soils/Sludges
Strontium
Nitrate
19.0 dpm/g
8,880 mg/L
What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
12/21/89
3/91
6/28/91
Background

Federal Facility ;
PRPs: U.S. Department of Energy
FS prepared by: Science Applications
International Corporation
1,958' cubic yards of drummed, cement-fixed sludge |
3,204 cubic yards of drummed contaminated soil
288 wooden boxes of contaminated building and process equipment demolition debris
3. What type of site is this?

Department of Energy. An inactive uranium recovery landfill. It is one of several hundred
waste disposal sites or areas of contamination at the Oak Ridge Reservation site requiring
Superfund remedial action.
TECHNOLOGY SELECTION
_^__—^—^—.^^———^—^—~_ _ ^
.
4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing
Containment: Capping (RCRA cap, clay, asphalt, concrete, geosynthetic,
multilayered), underground barrier (vertical walls, horizontal walls)
-1-
615
-------
5.
Chemical treatment-

Physical treatment:

Thermal treatment:
Disposal:
Chemical aqueous waste treatment (neutralization/pH adjustment
precipitation/flocculation)
Waste processing, physical aqueous waste treatment (sedimentation
filtration, activated carbon, ion exchange)
Incineration • -•
Landfill (off-site, 6n-site), treatment facility (off-site, on-site)
Was an innovative technology considered in the FS? If so, which'technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biological wastewater treatment (aerobic, anaerobic attached growth
anaerobic suspended growth) '
Phys/Chem treatment: Chemical oxidation, soil washing
6.
7.
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
ft»L* H fT ° °f,fAAs)' ^ FS d°eS n0t quantify costs- After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed

costs were calculated during •" evaluation based on
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
Innovative Technology
1^M.^^•—••^___

Treatment using a combination of solid
waste processing/soil washing and
anaerobic fixed film/treatment of the
aqueous waste/modified RCRA cap
Estimated Costs
3 Criteria

N/A
9 Criteria
"•" i.

$3,033,000
How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
—•ii »^.

RAA-2
Standard Technology
No action/site security
616
Multilayered capping
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria

$483,000
— ' ' ._

$1,467,500
-2-
-------
Alternative
RAA-4
Standard Technology
Off-site shipment and disposal
Estimated Costs
3 Criteria
N/A
9 Criteria
$14,073,000
8. If ,a standard technology was chosen, why?

RAA-2 was selected because potential nitrate and strontium-90 contarriinalion in ground water
is remediated below the MCL under this alternative. Alternative RAA-J2 reduces the mobility
of contaminants by encapsulating and isolating the source from the underlying aquifer system.
This alternative minimizes farther leachate production and potential future contamination of
ground water. In addition, RAA-2 requires little handling or movement of the drums and
boxes, thereby minimizing exposure to workers from fugitive dust. Also, RAA-2 is easily
implemented because capping is a generally available technology and has been sufficiency
demonstrated for final closures of landfills, and no further technical development is required.
Similar caps have been extensively used at the Oak Ridge Reservation.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
' ' ' ' - '!''••
10. if an innovative technology was not chosen, why not? At what stage \\>as the innovative
technology eliminated? I
> • ' . • '-••• .'..• • ..' •-, I ..
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the ^hree criteria of . •__
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:
, . ! • , •
• Aerobic biological treatment was eliminated because it would! not be applicable to site
contaminants. The major contaminant of concern is nitrate, which requires an
anaerobic environment for biological degradation. I
: • , Chemical oxidation was eliminated because it would not be applicable to site
contaminants. The contaminants of concern are not oxidizablle. ,

Innovative technologies eliminated during the screening of the three criteria include the
following: ,
none
Innovative technologies eliminated during the detailed analysis include the following

• Soil washing and anaerobic fixed film biological treatment were eliminated because
these treatment technologies pose the greatest short-term risk}
because of the extensive
handling and movement of the drums. Also, these technologies are the most difficult
to implement because of engineering, design, and administrative requirements.
-3-
617
-------
U.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of ^standard technology ?

The most heavily weighted criterion in the selection of a standard remedial alternative was
fJT- Upr0t£flon of human health and Ae environment. The selected remedy, RAA-2 offers
Uie highest degree of protection because it requires minimal worker exposure to wastes' and
disruption of the site, eliminates the direct contact exposure pathway, and ensures that future
maximum nitrate concentrations in ground water do not exceed the safe drinking water
standard. RAA-3 and RAA-4 provide less overall protection of human health and the
environment because of significant handling and processing of the waste and potential
exposure to the environment. The FS states, however, that the use of these treatment ;
technologies will reduce by 70 percent the toxicity and volume of the main constituent of
concern, nitrate. Of the technologies, only these technologies reduce the toxicity and volume
ot the nitrate in the source material.
Sdectfd? V ^e cleanup goal was based on an ARAR, whatwasthat
What risk level was selected to establish cleanup goals? . " ,
Contaminant
Cleanup Level
ARAR or Other Basis
Carcinogens
Strontium-90
io-(
Risk2
Noncarcinogens
Nitrate
SDWA MCLb
in6 mUSt meet m excess uPPer bound individual lifetime cancer risk
of 10 for strontmm-90 to prevent future contamination of ground water from landfill
iVSStCS.

bSafe Drinking Water Act maximum contaminant level. '
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? "unuum

Innovative technologies eliminated because of cleanup goals include:

• None .

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?
Treatability studies were not conducted.
618
-4-
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15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

- Time to design/construct/operate - »j
Impact on nearby populations | ,
i
p ," i
i ' . '
16. How are measures compared? }

RAA-3 was elimiriated partly because its implementation time is the longest of all the
alternatives: 25 months, as opposed to 12 months for RAA-4, and 8 months for the selected
remedy, RAA-2. The chosen alternative also will produce minimal exposure to workers from
fugitive dust. In contrast, alternatives RAA-3 and RAA-4 involve significant handling and
processing of the waste, posing a higher risk of exposure to workers apd nearby populations.
I

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy.
-5-
619
-------
Robins Air Force Base
(Landfill #4/Sludge Lagoon)
OU-1

Houston County, Georgia
Region 4
GENERAL SITE INFORMATTrw
7.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:

Soil/Sludge Lagoon1 (mg/kg)
1,2-Dichloroethene 100
Tetrachloroethene 59
Trichloroethylene 2,500
Vinyl chloride 0.110
A *
Arsenic 45
Cadmium 599
Chromium-Total 6.4

Site History
NPL Proposed: N/A
NPL Final: 1987
FS: 2/91
ROD: 6/25/91

Background
Federal Facility Lead
PRPs: U.S. Department of Energy
FS prepared by: CH2M Hill
. •

Lead 972
Soil/Landfill (mg/kg)

Arsenic 12
Cadmium 15
Chromium-Total 52
Lead 155
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 15,000 cubic yards of soil in the sludge lagoon
« The volume of material in the landfill is not given; however, the landfill covers an
area of 45 acres
'The contaminated material in the Sludge Lagoon is a mixture of sludge, soil, and peat
620 _!.
-------
3. What type of site is this? j '

Military. The site is a logistics management and repair center for aircraft, missiles, and
support systems. Operable Unit-1 includes a 45-acre inactive landfill and a 1.5-acre sludge
lagoon. Land use in the area is mixed residential and industrial. Part [of the site lies within
the 100-year floodplain of the Ocmulgee River. j

TECHNOLOGY SELECTION j

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: .
j

Soil/Sludge Lagoon/Landfill i •
i
/ ' !
Access restriction: Institutional controls (use restrictions, deed resstricCions, fences)
Containment: Capping (single-layer cap, multilayer cap), soil cover, horizontal
barriers, surface controls (surface sealing, grading,, soil stabilization,
clearing/revegetation, surface drainage) |
Chemical treatment: Solidification ! ' '
Thermal treatment: Incineration (rotary kiln) :
Disposal: Excavation, on-site RCRA landfill, off-site RCRA landfill
I ' f
v j ,
|
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Soil/Sludge Lagoon/Landfill

Biological treatment: Slurry bioreactors, bioreclamation
Chemical treatment: Soil flushing, oxidation, chemical reduction
Thermal treatment: Low-temperature volatilization, soil vapor extraction, in $itu
vitrification
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, jjtfter the RAAs have been
formulated, costs are typically estimated as part of a three-criteria scrpening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during sin evaluation based on
nine criteria established by the NCP: long-term effectiveness and peirmanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; and community acceptance.
2 621
-------
Cost Estimates for RAAs That Include Innovative Technologies

(selected remedial alternative is in bold)
Soil/Sludge Lagoon
Alternative
Innovative Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-2-SL
In situ soil vapor extraction/in situ

solidification
N/A
$6,300,000
RAA-3-SL
Excavation/low-temperature volatiliza-

tion/solidification/onsite RCRA landfill
N/A
$14,300,000
7.
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technology

(selected remedial alternative is in bold)

Soil/Sludge Lagoon
les
Alternative
RAA-l-SL

(RAA-IA-SL)
RAA-4-SL
Standard Technology
No action
Limited action/institutional controls
Excavation/incineration/solidification/

replacement on site
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$0
$0
$17,500,000
•RAA-l-SL and RAA-IA-SL are considered as one alternative in the FS and two in the ROD.

Soil/Landfill -
Alternative
RAA-la-L

(RAA-1A-L)

RAA-2-L
RAA-3-L
Standard Technology
No action

Limited action/institutional controls
•———; __

Cover renovation/lagoon ground

water control
Multilayer cap/leachate and lagoon

ground water control
Estimated Costs
3 Criteria

N/A

N/A
N/A
N/A
9 Criteria
•^MMBH

$756,000

$3,630,000b

$12,200,000
622
JRAA-1-L and RAA-1A-L are considered as one alternative in the FS and two in the ROD,
-3-
tr
-------
bOnce selected, the cost estimate for this alternative was recalculated ijn the ROD due to the
addition of clay in the cover renovation. The final estimated present yvorth cost of RAA-2 is
$4.4 million to $13.3 million for a clay cover renovation, and $4.4 million for lagoon ground
water collection and treatment.
8. If a standard technology was chosen, why? ;

Soil/Landfill , j

A standard technology with modifications was chosen to remediate contaminated soils in the
landfill. The modifications to the selected alternative, RAA-2-L, include the addition of clay
to the cover and a leachate control system. The original RAA-2-L was rejected by EPA and
Georgia Department of Environmental Protection (GDEP) because it jiid not comply with the
RCRA ARAR requirement for a landfill cover of lower permeability man the underlying layer.
The addition of clay to the landfill cover, however, will reduce infiltration-by increasing runoff
of precipitation from the landfill cover, ensuring that the landfill cover permeability is less
than the underlying soil's, in compliance with the RCRA ARAR. R/^A-2-L also was selected
because landfill leachate production will be reduced because surface water run-on will be
diverted from the landfill and the renovated cover will be sloped properly to minimize
standing water. In addition, the selected alternative is the simplest to implement.

9. If an innovative technology was chosen, why?

Soil/Sludge Lagoon

The selected alternative for soils in the sludge kgoon, RAA-2-SL, combines in situ soil vapor
extraction (ISVE) with in situ solidification. An advantage of combining these treatment
technologies is that hazardous substances can be treated without exciivatiion. This approach
addresses the CERCLA preference for treatment while avoiding excavation, which poses short-
term risks from release of VOG air emissions. Thus, the treated material will not be subject to
RCRA land disposal restrictions (LDRs), which would have affected the implementability of
the selected alternative. In compliance with ARARs, this alternative includes a cap over the
sludge lagoon to minimize leaching and meet closure requirements. Once RAA-2-SL is
complete it should be easier to achieve the chemical-specific, ground water ARARs. The
practicable implementability of RAA-2-SL also is influenced by the high ground water table at
the lagoon and the physical properties of peat. By treating the soil in place, short-term risks to
workers and the community also will be reduced. In addition, ISVE was chosen because the
process has been demonstrated to be effective in removing VOCs from soil. RAA-2-SL
removes an estimated 75 to 90 percent of VOCs and greatly reduces! the risk of releases
through solidification of residual contaminants.

1
10. If an innovative technology was not chosen, why not? At what stage was the innovative ;
technology eliminated? !

Innovative technologies eliminated during the screening of the three criteria include the
following: j
• ~ •
• In situ vitrification was eliminated because its applicability is questionable and it . .' i'
would not cost significantly less than demonstrated technologies such as incineration. ;
The high percentage of organic material in the peat could release a lot of energy as it ;
was heated and possibly damage the gas collection hood. Further testing of the Btu
value and inorganic chemistry of the peat would be required to assess whether in situ
vitrification would be applicable. The saturated portions of the sludge, soil, and peat
mixture also makes this application .questionable.

Innovative technologies eliminated during the detailed analysis include the following:

• Low-temperature volatilization (LTV) was eliminated because of concerns regarding its
short-term effectiveness. LTV would require excavation of soil, sludge, and peat
which would create dust and erosion, thereby increasing the potential exposure of
workers to hazardous substances. Also, LTV would generate more noise than in situ
treatment. LTV is part of RAA-3-SL which requires significantly more truck traffic
than the other alternatives because of the need to import material to construct the
RCRA landfill. Verification was needed as to whether LTV could meet the LDR
treatment criteria for F006 wastes. If the criteria were not met, treatability testing for
solidification would have to be performed. In addition, not all semivolatile compounds
would be removed from the soil at the lower temperatures used in this technology
EPA was planning a SITE demonstration of the LTV process on PCB-contaminated
soils in 1990. '

Soil/Sludge Lagoon

Compliance with ARARs was a major factor in selecting a remedy for contaminants in the -
sludge lagoon. Under the selected alternative, hazardous substances can be treated without
excavation; thus, the treated material would not be subject to RCRA land disposal restrictions

624 5
-------
(LDRs). Short-term effectiveness also was important. RAA-3-SL and RAA-4-SL would pose
a greater risk for worker exposure to hazardous substances compared ito the selected
alternative, because the sludge lagoon waste would be excavated and handled.
• . ' ' • • ' ! '
Soil/Landfill

Compliance with ARARs was a major factor in selecting a remedy foi- the landfill because
action-specific ARARs (RCRA) affecting this site require a landfill cover that is less
permeable than the underlying layer. The selected alternative was the; only one that complies
with ARARs by adding clay to the cover. Overall protection of human health and the
environment also was a significant factpr in selecting the remedy. Thie chosen alternative will
achieve source control and attain remedial action objectives for protection of public health and
the environment.

LTV was eliminated because of concerns about its short-term effectiveness.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
' \ , • . . '
Contaminant-specific cleanup goals were not established for soils at the sludge lagoon because
they would depend on ground water goals (to be developed in Operable Unit 3). An RI/FS
currently underway will develop goals for ground water based on potential receptor locations
and fate and transport analyses. The sludge lagoon cleanup goals most liikely will be based on
meeting the ground water goals in a TCLP extract.
:, I
' ' ' - I '
13. Was the innovative technology eliminated because of the cleanup goqls? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

, '• •', None " ' .

Standard technologies eliminated because of cleanup goals include:

• None , • , ! '

14 Were treatability studies conducted on the innovative technology or standard technology?
' • ' • * . ' '' • ."''.'
Treatability studies were not conducted; however, pilot scale leachate: collection tests are
planned, and bench and pilot-scale treatability testing of the landfill lieachate, sludge lagoon
soils, and ground water will be performed. The FS indicated that a treatability study of a
sludge lagoon sample program as part of the SITE demonstration will indicate whether
solidification would be effective for the contaminated soils at the.sludge lagoon. Results of
this study were expected in July 1990.
-6- 625
-------
15.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness -
Proven reliability
Single-step vs. multistep treatment
Preference for treatment (vs. containment)
16. How are measures compared? ,

The selected remedies were determined to be cost-effective. Proven reliability was an
important factor in comparing alternatives. ISVE was chosen because the process has been
demonstrated to be effective in removing VOCs from soil, and LTV also has been shown in
both bench- and pilot-scale tests to remove more than 99 percent of chlorinated VOCs from
soils. Because of the combination of organic chemicals and metals in the sludge lagoon
which all have different characteristics, different technologies were combined to treat each
substance. For the sludge lagoon, ISVE treats VOCs and in situ solidification treats the
remaining metals and organic compounds. Another advantage of combining these technologies
is that the contaminated sludge/soil mixture can be treated in place, thereby satisfying the
CERCLA preference for treatment to reduce the toxicity, mobility, and volume of hazardous
wastes.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting remedies; however, such considerations
were factors in the elimination and selection of treatment technologies. Because of the high
percentage of organic material in the peat, in situ vitrification was eliminated. In addition the
saturated portions of the sludge, soil, and peat mixture complicated the use of this technology
The practicable implementability of RAA-2-SL is influenced by the high ground water table at
the lagoon and the physical properties of peat. Unfavorable soilconditions, including low
permeability, high moisture content, and high humic content, could inhibit ISVE and
solidification. As a result, the long-term effectiveness of RAA-2-SL will have to be evaluated
further through site-specific predesign studies.
•it?
626
-7-
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Sangamo Weston, Inc./Twelve-Mile Creek/Lake Hartwell PCB Contamination
OU-1 (Sangamo Weston, Inc.)

Pickens County, South Carolina |
Region 4
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil and Sediments (mg/kg)

PCBs 34,300
Tetrachloroethene , 560
Trichlorethene 2,500
Xylenes 270
Bromodichloromethane 0.015
Acetone 100
Bis(2-ethyhexyl) phthalate 0.70
Di-ri-butylphthalate , 0.55
1,2-Dichloroethene 0.062
1,1,1-Trichloroethane 99
1,2-Dichlorobenzene 0.57
Ethylbenzene 41

Lagoon Sludge (mg/kg)

PCBs 26,400
Tetrachloroethene 0.011
Trichlorethene 0.14
Aluminum , 355,000
Arsenic 230

Solid Waste (ppm)

PCBs 49,000
Tetrachloroethene 910
Trichlorethene ... 8,300
Xylenes 5,200
Phenol •.: 56
Benzoic acid 66
Chloroform 0.062
2-Hexanone . 5.7
Isophorone 6.5
'. , Bis(2-ethyhexyl) phthalate '36
Site History
NPL Proposed:
• NFL-Final:.
FS:
ROD:
1/87
2/90
4/90
12/19/90
Background

PRP-lead
PRPs: Sangamo "^feston, Inc.
FS prepared by: RMT, Inc.
-1-
627
-------
Butylbenzylphthalate
Di-n-butylphthalate
Cyanide
Aluminum
Antimony
Arsenic
1,2-Dichloroethene
1,2-Dichlorobenzene
Ethylbenzene
Toluene
22
40
721
210,000
1.7
200
0.14
7.9
510
960
What volume of material is to be remediated?

The volume of material to be remediated included:

• 48,200 cubic yards of contaminated soil and sediments
• 23,000 cubic yards of lagoon sludges
• 2,900 cubic yards of solid waste
3. What type of site is this?

Electrical Equipment. A former manufacturing facility whose major products included
electrolytic capacitors, mica capacitors, power factor capacitors, and potentiometers. This ROD
addresses the Sangamo Plant site and six other disposal areas: Cross Roads site, Breazeale
site, Dodgens site, Welborn site, Nix site, and John Trotter site. Located in a predominantly
rural area, the Sangamo Weston site is approximately 220 acres, most of which is forested.
The Cross Roads site is about 5 acres and is heavily wooded. The Breazeale site is about 7
acres and vegetation consists primarily of grass cover. The Dodgens site is 6.5 acres and
vegetation consists of grass cover. The Welborn site is about 4 acres and is marked by eroded
areas with deep ravines. The Nix site is 7.5 acres and vegetation consists of grass-covered
pasture with wooded portions. The John Trotter site is 3 acres and consists of grass cover and
wooded areas. , . '. . '
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:'
*
Soil and Sediments/Sludge/Solid Waste

Access restriction: Fencing, deed restrictions
Containment: Capping (sprayed asphalt, soil, clay, synthetic membranes, concrete,
•I1;"
" r
Physical/chemical
treatment:
composite cover), vertical barriers

Solidification/fixation, dewatering
Physical treatment: Preprocessing, mechanical dredging, hydraulic dredging
628
-2-
-------
Thermal treatment:
Disposal:
Incineration (rotary kiln)
Excavation, landfilling (on-site and off-site)
I , .
5. Was an innovative technology considered in the FS? If so, which technology?
- • ' -I - , '
Innovative technologies considered during the identification and screening of technically
feasible technologies were:

SoU and Sediments/Sludge/Solid Waste i
i • " "

Biological treatment: Batch biodegradatiori (composts), in situ biodejgradation
Phys/Chem treatment: Soil washing, glycolate dechlorination (KPEG process), vacuum
extraction, in situ steam stripping j
Thermal treatment: Thermal separation (low-temperature thermal stripping (LTTS),
X*TRAX process), vitrification
What was the cost estimate for the innovative technology?

Soil and SedimentsVSludge/Solid Waste .
Alternative
RAA-8b and
RAA-Sc
Innovative Technology
Limited ground water action/on-site
treatment of soil and sludge (LTTS
[RAA-8b]) or glycolate dechlor-
ination (RAA-8c)/on-site disposal
of solids
E<
3 Critei
RAA-8
$28,200,0
$45,500,1
RAA-S
$35,500,0
$57,000,1
timated Costs
ia
b
00-
300
c
00-
XX)
9 Criteria
RAA-8b
$28,200,058 -
$31,777,919
RAA-Sc
$35,523,616-
$41,890,406
-3-
629
-------
1^ — '
Alternative
RAA-9a,
RAA-9b
|RAA-9c, and
RAA-9d

RAA-lOb and
IRAA-lOc

RAA-llb and
RAA-llc

RAA-12b and
RAA-12C

RAA-13b and
RAA-13c

Innovative Technology
Treatment of ground water/limited
action on soils (in situ biodeg-
radation)/on-site treatment and
disposal of sludge (rotary kiln
incineration [RAA-9a]), LTTS
(RAA-9b), glycolate dechlorination
(RAA-9c), or physical stabilization
(RAA-9d)/off-site treatment and
disposal of solid wastes

Limited ground water action/on-site
treatment of soil or sludge (LTTS
[RAA-lOb] or glycolate dechlor-
ination [RAA-lOc] of soil and
sludge)/off-site disposal of solids
-

Treatment of ground water/on-
site treatment of soil and sludge
(LTTS [RAA-llb] or glycolate
dechlorination [RAA-llc])/on-site
disposal of solids

Treatment of ground water/on-site
treatment (LTTS [RAA-12b] or
glycolate dechlorination [RAA-
12c])/off-site disposal of solids
-

Consolidated remedy/no action/
limited action/excavation and
treatment of active and inactive
lagoon sludges (LTTS [RAA-13b]
or glycolate dechlorination [RAA-
13c])
Estimated Costs |
3 Criteria . •' 9 Criteria |
RAA-9a
$36,400,000

RAA-9b ,
$45,800,000-
$47,000,000
RAA-9c
$45,700,000 -
.$47,500,000
RAA-9d
$43,900,000
/
RAA-lOb
$48,000,000 -
$65,900,000
RAA-lOc
$55,000,000 -
$75,600,000

RAA-llb
$47,900,000 -
$63,300,000
RAA-llc
$55,300,000-
$78,400,000
RAA-12b
$62,400,000 -
$77,300,000
RAA-12c
$68,700,000 -
$91,000,000
RAA-13b
$13,400,000 -
$14,600,000
RAA-13c
$13,300,000 -
$15,100,000
RAA-9a
$39,569,065 -
$41,031,565
RAA-9b
$48,890,169 -
$49,189,169
RAA-9c
$48,838,169 -
$49,286,669
RAA-9d
$47,024,019-
$47,771,519
Eliminated in
FS but
presented again
in ROD.
Cost estimate
given in ROD:
$27,100,000
RAA-llb
$47,853,983 -
$51,707,063
RAA-llc
$55,285,102 -
$61,064,722
RAA-12b
$62,430,282 -
$66,145,752
1 RAA-12c ,
$68,715,557 -
$74,288,762
RAA-13b
$13,409,257 -
$13,697,857
RAA-13c
$13,345,115-
$13,778,015
*In the evaluation of innovative and standard technologies, treatment of sediments was not
discussed separately but was included in the discussion of treatment technologies for soil.
630
-4-
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Soil and Sediments/Sludge/Solid Waste

Alternative
RAA-1
RAA-2
RAA-3a and
RAA-3b

RAA-4a and
RAA-4b

- -

RAA-5

RAA-6

RAA-7

RAA-8a and
RAA-8d

Standard Technology
No action/monitoring
Limited action/institutional controls
Limited action for ground water/
containment of solids (composite cover
[RAA-3a] or multimedia cover [RAA-
3b])
Limited action for ground water/
containment of soil and sludge
(composite cover [RAA-4a] multimedia
cover [RAA-4b])/off-site disposal of
solid wastes

Limited ground water action/oh-site
disposal of solids

Limited ground water action/off-site
disposal of solids

Treatment of ground water/on-site
disposal of solids
Limited ground water action/on-site
treatment (rotary kiln .incineration
[RAA-8a] or physical stabilization .
[RAA-8d] of soil and sludge)/on-site
disposal of solids

Estimated Costs
3 Criteria
$5,100,000
$5,306,000
RAA>3a
$7,900,000
RA^i-3b
$8,600,000
. i
. i
i •
• !
RAA-4a
$10,3C)0,000
RAA-4b
$11,000,000
$12,700,000
"i
i
i
;
$57,01)0,000
1
I
1' ' '
,

$29,4130,000
i "
RAA-8a
$49,400,000
RAA-8d
$14,400,000
l ••
9 Criteria
$5,108,973
$5,276,164
RAA-3a
eliminated
RAA-3b
$7,851,810
Eliminated in
FSbut
presented
again in ROD
RAA-4a
$10,300,000
RAA-4b
$11,000,000
Eliminated in
FS but
presented
again in ROD
$12,700,000
Eliminated in
FS but
presented
again in ROD
$57,000,000
$29,363,716

RAA-8a
$49,414,312 -
$58,719,322
RAA-8d
$14,372,589 -
$15,677,496 |
-5-
631
-------
Alternative
RAA-lOa and
RAA-lOd
RAA-llaand
RAA-lld
RAA-12a and
RAA-12d
RAA-13a and
RAA-13d
Standard Technology
Limited ground water action/on-site
treatment of soil and sludge (rotary kiln
incineration [RAA-lOa] or physical
stabilization [RAA-lOd])/ off-site
disposal of solids
Treatment of ground water/on-site
treatment of soil and sludge (rotary kiln
incineration [RAA-11 a] or physical
stabilization [RAA-lld])/on-site
disposal of solids
Treatment of ground water/on-site
treatment of soil and sludge (rotary kiln
incineration [RAA-12a] or physical
stabilization [RAA-12d])/off-site
disposal of solids
Consolidated remedy/no action/limited
action/excavation and treatment of
active and inactive lagoon sludges
(rotary kiln incineration [RAA-13a] or
physical stabilization [RAA-13d])
3 Criteria
RAA-lOa
$64,300,000

RAA-lOd
$77,100,000
RAA-lla
$71,300,000

RAA-lld
$3.4,500,000
RAA-12a
$85,100,000

RAA-12d
$99,200,000
RAA-13a
$14,100,000
RAA-13d
$11,200,000
9 Criteria
RAA-10"
$271,023,749

RAA-lOd
$27,100,000
RAA-lla
$71,302,695 -
$81,320,704
RAA-lld
$34,541,148 -
$35,946,432
RAA-12a
$85,054,182 -
$94,714,377
RAA-12d
$99,166,517-
$99,762,387
RAA-13a
$14,086,297 -
$14,836,657

RAA-13d
$11,248,605-
•RAA-10 is a modification of the a, b,"c, and d alternatives considered in the three-criteria
section of the FS. RAA-10 incorporates only off-site incineration of contaminated materials.
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?

The selected alternative, RAA-llb, has several components including: treatment of ground
water; excavation of materials contaminated with greater than 1 ppnuof PCBs at two of the
disposal sites; excavation of materials contaminated with greater than 10 ppm of PCBs at the
remaining four disposal sites; excavation of materials contaminated with greater than 25 ppm
of PCBs at the Sangamo Plant site; and treatment of all excavated materials to 2 ppm of, PCBs
using LTTS technology. Residuals from this treatment will be disposed of in an on-site
landfill. Of the treatment technologies considered, LTTS provides the best overall protection
of human health and the environment. This technology uses an indirect heat source to remove
contamination from the soil, thereby condensing it into a more manageable volume In
632
)i
-6-
-------
I
addition, the removal efficiency of LTTS has been shown to be greater than 99.95 percent for
PCBs. Its effectiveness for treatment of volatile organic compounds also has been
demonstrated. On the basis of pilot studies, a treatment capacity of 5 tons/hour can be
expected with this technology. The FS states that the X'TRAX process is currently being used
at a SITE demonstration in California. Given the available demonstration data, this technology
is fully implementable. Furthermore, mis innovative technology offers pennanent treatment.
Its combination of treatment and disposal in an on-siie secure landfill v/ill provide an effective
means of reducing toxicity, mobility, and volume of waste constituents. Finally, RAA-llb will
comply with all ARARs. Treatment of excavated materials over 25 pprh PCBs will meet the
corresponding chemical-specific TSCA requirements.
i. ' .
! '
i," '
10. If an innovative technology was not chosen, why not? At what stage wiis tlie innovative
technology eliminated?

Innovative technologies eliminated during the first tier of the three-critpria screening include
the following:
I • •
• In situ steam stripping was eliminated because it would not be applicable to PCB-
containing areas. The FS states that EPA planned to conduct ik SITE demonstration of
this process during the fall of 1989. ! ;
• Vitrification was eliminated because it has not been demonstrated at a CERCLA site
with PCBs and VOCs. Also, the presence of cadmium impedes the implementation of
this technology. The FS references three vitrification processes: the Westinghouse
electric pyrolyzer; the Retech process; and the Geosafe Corporation process.
• Soil washing was eliminated because the formulation of a suitable washing fluid is
difficult for complex mixtures. Solvents react with or adhere to soil, reducing
mobility. Fine particles may be difficult to remove from washing fluid. High humic
content will limit desorption. The FS states that GSX of Greensboro, North Carolina,
offers a soil washing process that has successfully completed a SITE demonstration.
• Batch biodegradation was eliminated because anaerobic dechlprination of PCBs
followed by aerobic degradation has hot been demonstrated Oil a Ml scale or at a
CERCLA site. The FS states that batch biological treatment of PCB-affected soil and
sludge is commercially available through at least one vendor, Detox Industries. The
process has been permitted in EPA Region 6. Treatability studies would be required
to evaluate more fully the technology's effectiveness on Sangamo waste material.
• • •. ^ • ' • '
Innovative technologies eliminated during the second tier of the three-jcritisria screening include
the following:

• Vacuum extraction was eliminated but no reason was provided. The FS did state,
however, that this technology is effective in removing VOCs from soils but not PCBs.
It also mentioned that vacuum extraction has been demonstrated zit many sites
including EPA's SITE program.
-7-
633
-------
Innovative technologies eliminated during the detailed analysis include the following:

• In situ biodegradation was eliminated because its technical implementability has not
been demonstrated and the availability of experienced vendors is uncertain. In addition
the long-term effectiveness of biodegradation is poor in areas where affected soils lie '
above ground water.
» Glycolate dechlorination (KPEG process) was eliminated because it has not been
demonstrated to be effective in the field and it is uncertain how protective this
treatment would be. Also, since the technology is relatively new, it would be difficult
to implement at the site. The FS states that the KPEG process is presently available
on a commercial basis from Galson Services, Inc. Galson has demonstrated the KPEG
technology in the field in PCB-affected soil at an NPL site; however, the process is
not yet permitted. Treatability testing would be needed to demonstrate the
effectiveness of this process on the site's waste materials. A:L. Sandpipe also offers a '
similar treatment process that has not been as widely demonstrated as the KPEG
process.
J
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? if so
which criterion? Which of the criteria supported the use of a standard technology? '

Soil and Sediments/Sludge/Solid Waste

The most heavily weighted criteria in selecting an innovative treatment technology were long-
term effectiveness and implementability. Treatment will eliminate waste constituent source
areas, providing long-term, effectiveness. The chosen innovative technology is fully
implementable based on demonstration data and test studies whereas other innovative
technologies were eliminated because of a lack of demonstration data.

Two innovative technologies, in situ biodegradation and glycolate dechlorination were
eliminated because they would not meet the implementability .criterion.
72.
i T SdeCtfd? ?** deanUP 8°al WGS bOSed °n an ARAR> what
What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm) ARAR or Other Basis
Carcinogens
Tor carcinogens, an excess upper bound individual lifetime cancer risk of 10"6
acceptable.
was
634
-8-
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13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup-goals? j

Innovative technologies eliminated because of cleanup goals include:

'• None • ' , • .. ' ' , •

Standard technologies eliminated because of cleanup goals include: i
• ' ' ' -!
• None :

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted, During remedial design, however, a treatability study
.will be conducted to determine'if any of the contaminated materials vfill irequire additional
treatment beyond thermal separation in order to meet the 2 ppm criteria. If necessary, a ROD
amendment will be completed to account for this required treatment.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

•'-''' _ Proven reliability
Preference for treatment (vs. containment) !.
.-. ' : ' * • ; I'- '. .

!,,"'•
16. How are measures compared?

According to the FS, identification of remedial technologies for this ipite was based on: review
of recent EPA guidance documents; review of SITE program results;] discussions with
commercial vendors of specific technologies; and field observations of specific technology
applications, both through the SITE program and private cleanups. Alternative RAA-1 Ib ,was
chosen because its effectiveness in treating the contaminants of concern had been
demonstrated. The selected remedy emphasizes treatment over conbdnment, a preferred
method because of its long-term effectiveness.
. 'i ' '' .
-., • •• • • , •'- i-

77. • What technical considerations were factors in selecting a remedy? 'Were technical
considerations primary in the selection of the remedy?

' ' ' ~ j
Technical considerations were not primary in selecting a remedy.;
635
-9- ' ! ": '••:'.••
-------
Standard Auto Bumper Corp.
OU-1

Hialeah, Dade County, Florida
Region 4
I
GENERAL SITE INFORMATTDNT

/. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Surface Soil1 (mg/kg)

Chromium
Nickel
Copper
Lead
Cyanide
Zinc

Subsurface Soil (nig/kg)

Chromium
Nickel
Copper
Lead
2,300
4,200
600
160
12
400 '
9,100
9,700
4,700
520
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/8'8
10/89
8/92
9/28/92
Background

EPA Fund-lead
PRPs: Standard Auto Bumper
FS prepared by: EPA
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 2,500 cubic yards of contaminated soil

3. What type of site is this? •

Electroplating. Standard Auto Bumper is an active chromium and nickel plating facility which
has been in operation since 1959. The site is located in an industrialized area.
™ PpAv,, subsurfaceusoi! did not exceed TCLP regulatory levels, indicating that there are
no RCRA hazardous wastes at the site. The TCLP results, however, do indicate contaminants
leach, thus contributing to ground water contamination.

636
can
-1-
-------
TECHNOLOGY SELECTION i .
• ' r
" . " J
4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Institutional actions (deed restrictions)
Containment: Vertical controls (slurry walls, grout curtains, s;heetpile walls),
infiltration controls, capping ;
Chemical treatment: Stabilization/solidification
Disposal: Excavation, off-site landfill
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: L
i • •
Chemical treatment: Soil washing, soil flushing - i - •
Thermal treatment: In situ vitrification •,',".'
6. What was the cost estimate for the innovative technology?

RAAs designations changed in the ROD and are presented .parenthetically below.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-6
(RAA-3)
RAA-8
RAA-9
RAA-10
Innovative Technology
Excavation/on-site soil washing/on-site
soil replacement
In situ vitrification
Excavation/vitrification/on-site disposal
Excavation/vitrification/off-site disposal
Estimated Costs
, 3 Cjriteria
$1
3,650
$153,225
$l,b,2;25
N/A
9 Criteria
$891,650"
eliminated
eliminated
eliminated
Total present worth costs are presented in Section 5.0 Comparative Analysis for Alternative
Selection in the FS.
-2-
637
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
(RAA-2)
RAA-5
RAA-7
(RAA-4)
Standard Technology
No action
Deed restrictions/fencing
Capping/ground water monitoring
Excavation and off-site disposal
Excavation/consolidation/capping/
ground water monitoring
Excavation/stabilization/solidification/
on-site disposal/ground water
monitoring
Estimated Costs
3 Criteria
$94,700
$112,600
$198,850
$40,186
$198,850
$153,225
9 Criteria
$94,700"
eliminated
eliminated
$338,186
eliminated
$385,225
Total present worth costs are presented in Section 5.0 Comparative Analysis for
Selection in the FS.
Alternative
8. If a standard technology was chosen, why?

The selected remedy RAA-4 (RAA-2) includes excavation of contaminated soils and
transportation of them to a Florida Class I landfill. Treatment was found to be unnecessary for
site wastes, due to the nonhazardous nature of the contaminated soil as defined by RCRA. A
cleanup action is, however, necessary to reduce the risk to human health and the environment.
RAA-4 (RAA-2) was selected because risk of exposure from further migration of the
contaminants through the soil is reduced by removing the contaminated soil to the cleanup
levels. The removal of waste off site will eliminate any long-term risks of exposure at the
site, and no long-term monitoring at the site will be required. This alternative also offers a
high degree of certainty that it will be executed successfully and is considered to be an
irreversible permanent remedy. The selected alternative provides protectiveness in a relatively
short time (2 months). In addition the selected alternative does not require specialized
materials and equipment beyond common excavation equipment and is a proven technique
which would not require treatability studies. The chosen remedy is the most economical
alternative and offers similar protectiveness to the other alternatives. This alternative can be
readily implemented at the site and complies with all ARARs.

The Proposed Plan identified RAA-7 (RAA-4) as the preferred alternative, in part because of
the preference for an on-site treatment alternative. During the public comment period,
however, staff at Florida Department of Environmental Regulation (FDER) voiced a preference
for RAA-4 (RAA-2) because this alternative does not require the long-term O&M that RAA-7
638
-3-
-------
would require. In RAA-7, ground water monitoring for up to 30 years was necessary to
ensure the integrity of the stabilization/solidification treatment.

The Proposed Plan stated a cleanup goal for nickel only. EPA and FE>ER decided that a
cleanup goal also was necessary for chromium.

9. If an innovative technology was chosen, why?

An innovative technology was riot chosen.

10. If an innovative technology was not chosen, why not? At what stage iVas the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the | three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
• . ' • . - • • ' j . ', ' '
Innovative technologies eliminated during the initial screening includs the following:

• Soil flushing was eliminated due to the complexity of its implementation. The FS
states that this technology would have a number of potential pitfalls due to its
sensitivities. In situ soil flushing depends on complete solvent contact with the waste,
which is mainly a result of the hydraulic conductivity of the koil.. At this site, the
average horizontal hydraulic conductivity is about 2.21 x 10':fcm/sec. Given the area's
sandy soils, there also is the potential for uncontrolled migration of the contamination
. using the in situ method. In addition, chromium removal would likely require use of a
solvent (acid) for treatment, which could leave residual material in the soil. Due to
distribution uncertainties, large quantities of solutions must be applied. Contact
patterns and residence time are less certain than in the above|ground soil washing
system. Also, this technology was chosen only at one site iri 1990 to treat PCBs and
metals such as arsenic, chromium, lead, and cadmium.

Innovative technologies eliminated during the screening of the three criteria include the
following:
'•"'!' • •
• In situ vitrification was eliminated because mis technology vrould be more costly than
the other treatment measures without providing substantially! greater public health and
environmental protection, or technical reliability. This innovative technology would
not offer the potential for comparable or superior performance or implementability at
this site; fewer or lesser adverse impacts than other available approaches; or lower
costs for similar levels of performance than demonstrated treatment technologies
(CERCLA s330.430(e)(5)). Vitrification has not been demonstrated to be as
technically feasible as the other treatment alternatives due tcj the subsurface conditions
at the site. The combination of relatively high soil permeability at the site and the
presence of ground water would create additional construction and economic demands
on the process. For the in situ process, temporary ground water diversion would be
necessary. This treatment requires a minimum depth of treatment of 5 to 7 feet and
the depth at the site is on the borderline of this range. Vitrification also has excessive
energy requirements to melt the soil which drive the cost uj; In addition, extremely

-4- i 639
-------
httle information exists on the staged vitrification process proposed in RAA-9 and
RAA-10. This technology has not been actively utilized at a Superfund site and is
only offered by three or four vendors. The success of this technology has been
questionable, with a recent problem with off-gas collection. Overall this process has
not been shown to be effective on a wide-scale use and would not be justified with
such a small quantity of soil to be treated at this site (2,500 cubic yards).

Innovative technologies eliminated during the detailed analysis iiiclude the following:

» Soil washing was eliminated because this technology has not been demonstrated
effective in attaining the cleanup goals. Soil washing has been selected as the
remedial alternative at other Superfund sites (it has been selected at more than eight
Superfund sites since 1986); however, the cleanup goals for these sites were higher
than those for this site. Also, soil washing was not shown to be as effective as
stabilization/solidification for the site contaminants in small-scale treatability tests
(process was not totally effective at removing the chromium) and soil washing would
require a larger area for the process operation than the fixation alternative This
treatment technology would reduce the volume of contaminated soil by washing the
contaminants from the soil into a concentrated waste stream, which would require
additional treatment or off-site RCRA hazardous waste disposal. This alternative also
would require the longest implementation time of 5 to 7 months and therefore this
process poses a risk of accidental exposure to the soil washing additive. Because of
the risk that cleanup goals might not be easily met during the soil washing process
additional washes and additives would be needed, which would further slow the
process. This alternative requires treatability tests to determine effectiveness and
optimal design prior to starting. Soil washing would require specialized equipment
materials, and labor, which is available from a variety of vendors. There are more'
vendors available for stabilization/solidification that have demonstrated effectiveness
than for soil washing. Soil washing requires more elaborate process equipment than
the other treatment alternative, stabilization, which would increase costs. The nature of
the contaminants and the characteristics of the soil have been shown to be more
responsive to stabilization/solidification than soil washing. <

In making the determination for off-site disposal, the modifying criteria of state acceptance
p AY^i^vf1' Staff St ** EDER disagreed with EPA'S initial Pwfencd alternative
KAA-/ (KAA-4) because the long-term monitoring was excessive and suggested that this
requirement could be avoided by selecting a comparable alternative RAA-4 (RAA-2) Upon
re-evaluation of the two alternatives, EPA determined RAA-4 (RAA-2) Was more reliable
long-term effective, permanent, implementable, and cost-effective remedy for the estimated
quantity of contaminated soil at, the site. Long-term effectiveness and permanence also was
weighed heavily in selecting the chosen alternative because the elimination of long-term risks
of exposure at this site was necessary to protect ground water. The Biscayrie Aquifer is i
located beneath the site and is the sole source of municipal drinking water for southeast
Florida. '
640
-5-
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12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR
Carcinogens
Nickel
Hexavalent chromium
370
52

F
Noncarcinogens
Total chromium
519
or Other Basis-

Model8
isk basedb
'.••
Ijtisk based
Three ground water models were used to determine these soil cleanup levels. The fate
and transport model, MULTIMED, was used to calculate the levels of contribution to
ground water that would be caused by given soil levels of nickel and chromium. The
geochemical, metals speciation model, MINTEQA2, was used to determine the relative
mobilities of nickel, chromium, and other possible contaminants ait the site. Finally,
the results of MULTIMED were cross-checked with a leaching-flow continuity model,
the SUMMERS model, to arrive at the final soil cleanup level for nickel.
"Although modeling was conducted, due to the uncertainties cjf modeling the fate and
colloidal transport of trivalent chromium, a lexicological approach was used. The
cleanup levels for chromium are based on an inhalation risk, which also will ensure
that any leachate from the site will not cause the state drinking water standard (0.1
mg/L) or MCL (0.1 mg/L) for chromium to be exceeded. The; cleanup level was
developed to provide a level that would result in a risk level of less than 10"6 and a
hazard index of less than 1.0.

An additional performance standard was generated for this site that slates:

• All soil to be disposed of off site must be nonhazardous waste as defined by the TCLP
test (40 CFR 261). :
» The landfill must meet FDER Class I landfill regulations.
13. Was the innovative technology eliminated because of the cleanup godls? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• Soil washing

Standard technologies eliminated because of cleanup goals include:

• None •. • '.
-6-
641
-------
14. Were treatability studies conducted on the innovative technology or standard technology? HM

According to small-scale soil washing treatability tests conducted at this site, soil washing
would not be as effective as stabilization/solidification. Screening-level treatability tests were
performed during the RI and indicated site soil was not amenable to the use of test
hydrochloric acid as an extracting agent. Another treatability test would have been necessary
prior to the actual application of this alternative. • ,
, , _ . *
c
' •"' • • .. " ; I:,
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Cost-effectiveness
Proven reliability

16. How are measures compared?

The selected alternative would remove all waste to an off-site landfill, thereby eliminating any
long-term risks of exposure at the site. After evaluating all of the alternatives which satisfy
the two threshold criteria of protection of human health and the environment, and compliance
with ARARS, EPA concluded that the selected remedy offers the highest level of overall
effectiveness proportional to its cost. In situ vitrification was not chosen because it has not
been shown to be effective on a wide scale. Extremely little information exists on the staged
vitrification process used in RAA-9 and RAA-10. This technology has not been used at a
Superfund site and is only offered by three or four vendors. RAA-4 (RAA-2) was chosen
because this alternative incorporates proven techniques which would not require treatability
studies.

17, What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ,

Technical considerations were primary in selecting an alternative for this site. A soil cleanup
level for nickel of 370 mg/kg was determined by EPA for the protection of ground water.
This cleanup level is considerably more stringent than the protective level for direct exposure
to soil calculated in the risk assessment (1,600 mg/kg). EPA determined that soil cleanup
levels are necessary to protect ground water at this site because the Biscayne Aquifer is
located beneath the site and is the sole source of municipal drinking water for southeast
Florida. In addition, two innovative technologies were eliminated in part because of technical
considerations. Vitrification was eliminated because it would not be as technically feasible as
the other treatment alternatives due to the subsurface conditions at the site. The combination
of relatively high soil permeability at the site and the presence of ground water would create
additional construction and economic demands on the process. For the in situ process,
temporary ground water diversion would be necessary. This treatment would require a
minimum depth of treatment of 5 to 7 feet and the depth at the site is on the borderline of this
range. Soil flushing was eliminated in part because with the sandy soils of the area there J||| "\
would be the potential for uncontrolled migration of the contamination using this technology. ^K /
64:
-7-
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Wrigley Charcoal Plant

Wrigley, Hickman County, Tennessee
Region 4
GENERAL SITE INFORMATION
1. What were the principal
contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Black Coal-Tar Waste
Site (rag/kg)
Carcinogenic PAHs

in Soil/Primary

Burn-Pit Wastes/Primary Site (ing/kg)

Lead
Chromium :
Copper
Zinc
Nickel
Cadmium
Barium
Black Coal-Tar Waste
Phenols
Total PAHs
VOCs
Copper
Lead
Nickel
Zinc
; Barium

1,600
- 270
7,900
2.300

Site

NPL Proposed;
NPL Final:
FS:
Interim ROD:

Bac
EPA Fund-lead
PRPs: Investigati
determine
are PRPs 1
operations
FS prepared by: 1

' ; ' •
160
36

History

NA
3/89
7/91
9/30/91

kground

sns are continuing to
whether or not there
o ftmd cleanup

ibasco Services Inc.

120
Leakage from Process Tanks/Primary Site (mig/kg)
- •' i ' ' •
20,000

737 , '
1,750 . • ' .
2,400
340 '
no.
110 ' .
50
Grease Pit Area/Maintenance Building (mg/kg)
Dibenzofurans-TEQ
Dioxin
0.0062 .
0.000076
Waste and Debris Piles/Primary Site (mg/kg)

Tentatively identified compounds
(TICs) in tar-cubes 920
-1-
643
-------
Deep Sediments/Storage Basin (mg/kg)

Semi-volatile compounds 74,032
Metals 6,025
VOCs 610

Lagoon Sediments/Irrigation Field (mg/kg)

Phenol 0.013
Toluene 0.011
Methylene Chloride 0.120
Tetrachloroethene 0.005
Lead 0.091
Arsenic 0.031
Copper 1.2

Soil/Athletic Field (mg/kg)

Lead 1,000
Copper 69,000
Manganese 3,100
Zinc 42,000
Cobalt 81
Chromium 56
Barium 640
Aluminum 9,400
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 3.5 cubic yards of black coal-tar waste in soil from the Primary Site
• 15 cubic yards of burn-pit wastes from the Primary Site
" Approximately 19 cubic yards of black coal-tar waste leakage from the process tanks
at the Primary Site -
• Approximately 100 cubic yards of exposed black coal-tar waste visible in the spillway
at the Primary Site
• Approximately 20 cubic yards of ACM contaminated soils at the Primary Site
• 50 cubic yards of tar-cubes

No interim remedial activities were proposed for the Grease Pit, Storage Basin, Irrigation
Field, and Athletic Field.
3. What type of site is this?

Wood Charcoal Production. A variety of industrial operations were conducted on this site
intermittently from 1881 to 1985. The majority of these operations consisted of pig iron and
wood retorting/wood distillation byproduct manufacturing. The site is located in a
predominantly rural setting but is flanked by private residences.
644
-2-
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ;

Soil/Sediments/Waste and Debris

Access restriction: Deed restrictions, fencing I
Containment: Capping (RCRA and non-RCRA type)
Physical treatment: Dewatering
Thermal treatment: Incineration (rotary kiln, infrared, fluidized bed)
Disposal: Excavation, on-site and off-site RCRA landfill, discharge to surface
waters . -
i . •
. ' i • .

5. , Was an innovative technology considered in the FS? If so, which technology?
' ' i
Innovative technologies considered during the identification and screening of technically
feasible technologies were: I

Soil/Sediments/Waste and Debris I

Biological treatment: Slurry-phase bioremediation ' j
Chemical/physical: Soil washing, chemical dehalogenation ,
Thermal treatment: Pyrolytic incineration, in situ vitrification, low-ternperature thermal
extraction > .
• ' - •- ' • ' ' • '
• \ ' ' • ' '
6. What was the cost estimate for the innovative technology? *
I' '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability; and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs are calculated during an evaluation based on nine
criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementabiljity; cost; state/support
agency acceptance; and community acceptance.

No innovative technologies were incorporated into RAAs.
-3-
645
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Primary Site
Alternative
IRAAM
IRAA2
IRAA3
IRAA4
IRAA5
Standard Technology
No action/institutional controls
Limited action: fencing/institutional
controls/site monitoring
Off-site treatment/disposal and on-site
containment of waste debris
On-site stabilization/solidification of
Storage Basin surface sediments/off-site
RCRA landfill treatment disposal of
Grease Pit soil and water debris
Soil capping with solidification at
Storage Basin/on-site treatment/off-site
RCRA landfill disposal of Grease Pit
soil and waste debris
Estimated Costs
3 Criteria
N/A
N/A
N/A
' N/A
N/A
9 Criteria
$36,000
$169,004
$953,668
($984,998)"
eliminated
eliminated
"Interim Remedial Alternative Action.
"Present worth cost for IRAA 3 in ROD.
8. If a standard technology was chosen, why?

The selected alternative was preferred because it addressed the most serious threats by
removing or consolidating contaminated media at the Primary Site, and restricting access at the
Primary Site and the Storage Basin. The interim activities chosen would achieve significant
risk reduction while a final remedial solution is developed. The selected alternative also meets
ARARs as applicable to excavation, transportation, treatment, stabilization, and disposal of
contaminated media such as coal-tar waste.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
i, t,
I
••sld^
646
-4.
-------
10. If an innovative technology was not chosen, why not? At what stage was tlie innovative
technology eliminated? , |

Innovative technologies could be eliminated from the remedial technology selection process at
three stages:- during the initial screening; during the screening of the tliree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. •
• • fl i".'' '•..'"• ' •
Innovative technologies eliminated during the initial screening include Ithe following:

• Pyrolytic incineration was eliminated because it would require sophisticated equipment
and other incineration methods were better suited for this particular application.
• In situ vitrification was eliminated because of the extensive energy and capital required
to implement this technology. ,
• Low-temperature thermal extraction was eliminated because it [would be ineffective in
remediating soils containing nonvolatile contaminants such as dioxins and
'dibenzofurans. .
• Chemical dehalogenation was eliminated but no specific reason was given. The FS
recognized, based on bench-scale tests and field tests for otherJ sites, that this
technology has obtained reduction efficiencies greater than 95 percent. The FS also
recognized that the APEG process has received approval from JEPA's Office of Toxic
Substance under the Toxic Substance Control Act for PCB treatment.
• Slurry-phase bioremediation was eliminated due to the variety of Kite contaminants and
the nonconformity of the site soil. In addition, the uncertainty
concerning the presence
of dioxins at the site could complicate the use of this technology.
Soil washing was eliminated but no specific reason was given.
that several unfavorable characteristics of soil and waste could
The FS states, however,-
affect the effectiveness
of this technology including: complex mixtures of waste type, variation in waste .
composition, and the treatment of clay soil containing semivolatiles.

Innovative technologies eliminated during the screening of the three ciiteria include the
following:

• None .
' • - - . ' . ' '
Innovative technologies eliminated during the detailed analysis include the following:

•' None ' i

11. Which of the nine criteria were weighted most heavily in selecting the^technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted,criteria in the choice of a -standard interims remedial technology for
the site were reduction of toxicity, mobility and volume (TMV), and overall protection of
human health and the environment. IRAA 3 will reduce the TMV of Grease Pit and coal-tar
contaminants, and the mobility of surface waste by permanently removing wastes from the site.
This alternative also reduces or controls significant, immediate, and potential threats from
direct exposure to hazardous contaminants at the site.
-5-
647
-------
12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels for the interim activities were not addressed in the FS or ROD because such
goals were beyond the limited scope of this action.
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

•' None

Standard technologies eliminated because of cleanup goals include:

• None ,
14. Were treatability studies conducted pn the innovative technology or standard technology?

Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved .
!I,

j
16. How are measures compared? -

The interim RAAs were compared based on their potential to reduce risks at the Primary Site
by eliminating or containing the most imminent and substantial threats to human health and
the environment while permanent solutions are developed for the entire site.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? • '

Technical considerations were not primary in selecting an interim remedial action alternative
for this site. "
648
-6-
-------
Acme Solvent Reclaiming, Inc.
(Morristown Plant), OU-2

Winnebago County, Illinois
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility ^study?

Maximum concentrations of principal
contaminants were:

Soil/Sludges/Bedrock (rag/kg)

1,1,1-Trichloroethane 0.01
1,2-Dichloroethene 44
Tetrachloroethene 31
Trichloroethene . 4.5
4-Methyl-2-pentanone 1A
Naphthalene 320
Total PCBs 290
Aluminum 17.9
Arsenic 0.0209
Barium 1-19
Chromium . ' 14.5
Iron 54.9
.Lead 52.5
Zinc • 4.44
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1982 '
9/83
7/25/90
12/31/90
Background
• . f ' ..
PRP-lead | ,
PRPs: Acme Solvents Steering
Committee!
FS prepared by: Harding Lawson
Associates |
2. What volume of material is to be remediated?

The volume of material to be remediated included:

Phase I1 of ROD: Waste Areas
6,000 tons-of soil and sludges
Two 8,000-gallon storage tanks containing sludges and liquids
'There are two. areas of concern at this site. The first includes the tanks
and waste areas; the
second includes other less highly contaminated areas. Two documents were written during the FS to
address these areas and the ROD is divided into two phases because the U.S. EPA and the Illinois
EPA intend to remediate the tanks and the waste areas as quickly as possible (Phase I alternatives),
prior to the remediation of the less highly contaminated areas (Phase H alternatives).
-1-
649
-------
Phase H of ROD: Remaining Soil and Bedrock

« Soil volume estimated between 4,800 and 9,100 cubic yards .. u ~.
» Bedrock gas estimated at 391 pounds :atenai
*:>
3. What type of site is this?

Recycling. From 1960 to 1973, the site served as a disposal site for paints, oils, and still
bottoms from the Acme Solvent Reclaiming, Inc., a solvent reclamation plant in Rockford
Illinois. The site consists of approximately 20 acres of rolling uplands in a predominantly
rural area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this

Standard technologies considered during the identification and screening of technically feasible
technologies were: . .

Access restriction: Deed restrictions, site fencing
Containment: Capping (synthetic membrane, multilayer, multimedia, soil cover)
Chemical treatment: Fixation/stabilization
Thermal treatment: Incineration (rotary kiln, multiple hearth, plasma arc, fluidized bed,
advanced electric reactor, "infrared), RCRA incineration
Disposal: Excavation RCRA landfill (on-site and off-site)

5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Composting, aboveground bioreactor, white rot fungus, microbial
degradation, soil aeration
Phys/Chem treatment: BEST (Basic Extraction Sludge Treatment) Process, liquid gas solvent
extraction, soil washing, soil flushing/chemical detoxification,
chemical oxidation, soil vacuum extraction, dechlorination
Thermal treatment: Thermal desorption, pyrolysis, in situ vitrification, radio frequency
heating
6. What was the cost estimate for the innovative technology?

650
-2-
-------
of the three criteria, and for Phase II alternatives during an evaluation
established by the NCP. , .
based on nine criteria
Cost Estimates for RAAs That Include Innovative Techn^lofpes
.(selected remedial alternative is in bold)
: - i '
There was no nine-criteria evaluation conducted; for Phase I RAAs. Costs were calculated
during the three-criteria screening for each RAA and were recalculate^ in the ROD.
Phase I: Waste Areas
Alternative
RAA-1
RAA-2
RAA-3a
RAA-3b
RAA-4a
RAA-4b ,:
RAA-5b
RAA-8a
RAA-8b
>, ' "
Innovative Technology
Soil vapor extraction/RCRA cap
Soil vapor extraction/in situ
solidification
Excavation/chemical oxidation/
solidification/off-site disposal
Excavation/chemical oxidation/
solidification/on-site placement
Excavation/soil washing/off-site
treatment of washing liquids and
contaminants/off-site disposal
Excavation/soil washing/off-site
treatment of washing liquids and
contaminants/on-site placement
Excavation, followed by low-
temperature thermal stripping/off-site
disposal
Excavation/low-temperature thermal
stripping/solidification/off -site
disposal
Excayation/low-temperature thermal
stripping/solidification/on-site
placement
Estimated Costs
3 Criteria
$1,162,000
$1,173,000
$7,990,000
$6,390,000
$6,080,000
'$4,680,000
$3,400,000
$4,30p,OCiO
$2,700,000
( •
ROD
$1,036,000
$1,173,000
$7,990,000
$6,390,000
f .
$6,080,000
$4,680,000
$3,400,000
$4,300,000
$2,700,000
Differences in costs and RAA designations between the FS and the ROD are presented
parenthetically below.
-3.-
651
-------
Phase II: Remaining Soil and Bedrock
•"
Alternative
RAA-3b
(RAA-3)
RAA-5
RAA-6a
RAA-6b
— =s=s===
Innovative Technology
Thermal desorption (LTTS) and soil
cover
Soil cover and soil/bedrock vacuum
extraction (SVE)
Thermal desorption of soil/bedrock
vacuum extraction (SVE)
Off-site incineration and soil/bedrock
vacuum extraction (SVE)
============
; •
Estimated Costs
3 Criteria
N/A
N/A
. N/A
N/A
9 Criteria
$8,268,000"
($9,400,000 to
$14,210,000")
$9,726,000
> ($7,948,000
to
$12,475,000)
$12,657,000
($13,335,000
to
$19,186,000)
$34,605,000
($25,406,000
to
$42,140,000)
Present worth costs are based on achieving a lO'5 risk level and on a 30-year return period
Other costs were presented in the FS for W4 and 10'6 risk levels and a 5-year return period'
Range corresponds to costs presented in ROD for cleaning up to a lifetime excess cancer risk
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Phase I: Waste Areas
Alternative
N/A
RAA-5a
RAA-6a
RAA-6b
RAA-7
====3===
-==============
Standard Technology
No action
Excavation/off-site disposal
Excavation/on-site incineration/on-site
placement
Excavation/on-site incineration/
solidification/on-site placement
Excavation/off-site incineration
'
Estimated Costs
3 Criteria
N/A
$1,900,000
$13,001,100
$14,001,100
$13,000,000
========
ROD
N/A
. _
$1,900,000
$13,000,000
$14,000,000
$13,000,000
~
*)
-4-
652
-------
Phase II: Remaining Soil and Bedrock
Alternative
RAA-1
RAA-2a
RAA-2b
RAA-2c
RAA-2d
RAA-3a
RAA-4a
RAA-4b
Standard Technology
No further action following Phase I
Soil cover
Soil cap
Off-Site landfill disposal
Soil fixation/stabilization
Incineration and soil cover
Soil cover and discharge of treated
ground water to surface water
Soil cover and reinjection of treated
ground water ,
Estimated Costs
$5,519,000a
($2,900,000)
$4,484,000
($3,700,000
to
$6,830,000")
$7,352,000
($9,400,000
to
$14,210,000)
•Present worth costs are based on achieving a 10'5 risk level and on a 30-year return period.
Other costs were presented in the FS for 104 and 10'6 risk levels and a 5-year period.
"Range corresponds to costs presented in the ROD for cleaning up to a lifetime excess cancer
risk of lO"4 to 10*. L
8. If a standard technology was chosen, why?

A standard technology was not chosen as the primary remedy.
If an innovative technology was chosen, why?

Phase I •-;..'

RAA-8a provides the best overall protection of human health and the environment and
provides 100 percent assurance of long-term reliability because contaminants are destroyed or
completely removed from the site. After implementation, RAA-8a (off-site disposal) will
completely eliminate risks at the site, and RAA-8b (on-site placement) will allow a minimal
risk of exposure. The selected remedial alternative relies on technologies that are relatively
easy to construct and operate. Low-temperature thermal stripping ^desorption) has been
successfully demonstrated at a U.S. EPA Superfund Innovative Technology (SITE) project
Because of the moderately low volume of materials to be removed and the moderately high
throughput of the LTTS system (more than 300 tons per day, as quoted by the vendor), the
' ' I '•,-'.
. . c • ' -5- • -.;•':'..
0653
-------
time until protection is achieved is expected to be less than 3 months. In addition, the LTTS
system has an offgas treatment system that will minimize community and worker exposure.
Finally, RAA-8 is expected to comply with ARARs, and because this alternative either
destroys, immobilizes, or removes the remaining concentrated waste materials from the site, it
is expected to comply with the goal of permanence to the extent practicable.

Phase H

The selected alternative provides for both soil and ground water treatment and therefore
provides the best overall protection of human health and the environment. RAA-5 provides
the best long-term effectiveness and permanence because this alternative treats contaminants in
ground water, soils; and bedrock, in addition to including the soil cover or cap.
Implementation of the soil/bedrock SVE system to mitigate the potential for the affected
soil/bedrock to affect underlying ground water provides additional protection to human health
and the environment, and further reduces the toxicity, mobility, and volume of chemicals in
the environment. Construction of the SVE system utilizes well-established, conventional
construction techniques and should not require any unique operator skills or technology to
operate. Vacuum extraction equipment (SVE equipment) is commercially available and has
been effectively demonstrated in U.S. EPA's SITE program. Finally, the selected alternative
meets all applicable ARARs. '.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ,

Innovative technologies eliminated during the initial screening include the following:

• Pyrolysis was eliminated because inorganics form an insoluble char residue, which
must be treated or disposed of. This technology would not be cost effective for site
soils with VOC concentrations less than 6 mg/kg.
» Radio frequency heating was eliminated because it is ineffective against inorganics, it
has been demonstrated only in one field test, highly chlorinated organics might not'be
treatable, and it is not commercially available.
« Composting was eliminated but no specific reason was given for its elimination.
• Above ground bioreactor was eliminated because the site's soils do not have a high
enough organic content to support a bioreactor.
* White rot fungus was eliminated because this technology is not commercially available.
• Microbial degradation (in situ) was eliminated because it has not been proven
effective for mixed waste and the concentration of organics at the site is too low to
support this technology. '
• Soil aeration was eliminated because it is difficult to achieve good contact and in situ
contact design is difficult. In addition, this technology has not been demonstrated and
further development would be required.
» BEST Process was eliminated because organic concentrations in site soil are too low
for effective treatment.
• Liquid gas solvent extraction was eliminated because organic concentrations in site soil
are too low for effective treatment.
0654
-6-
-------
• Chemical detoxification (in situ) was eliminated because this pipcess has not been
demonstrated fully. , |
• • -- • i • ,
Innovative technologies eliminated during the screening of the three criteria include the
following: I

n Dechlorinatlon was eliminated on the basis of relative cost. The dechlorination
process option would be an additional treatment step that would not provide any
advantages over the other listed alternatives and would add considerable cost to
treatment.
• Chemical oxidation (ex situ) was eliminated because this technology would be no more
effective than soil flushing, but its operation would cost more. Also, there are two
potential problems with chemical oxidation: (1) the process generally is used with
slurries with a suspended solids concentration of 3 percent or less, and (2) the lead in
organic sludges will oxidize into a more toxic and mobile form (U.S. EPA, 1988); lead
is present in some site soil. - ' ' I '' . .
• Soil washing was. eliminated because this technology would be no more effective than
soil flushing, but would cost more to operate. | ;
• In situ vitrification was eliminated because its performance has not been demonstrated.
• Soi//Z«5Wng was eliminated but no reason was given for its elimination. The FS
states that this technology does not remove inorganics and that there are limited
applications data. i • • . -.

Innovative technologies eliminated during the detailed analysis include the following:
!' ••
• None . . '' .' |

• ' -" ' !
11 Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
were weighed heavily in
Phase I and Phase II: Soil/Sludges/Bedrock

Protection of human health and the environment and implementation
selecting remedial alternatives for Phase I and Phase E actions. Implementation of LTTS
treatment of waste area soils and sludges in Phase I, SVE treatment of remaining contaminated
soils and bedrock gas in Phase II, and capping of all contaminated areas will protect against
risks from direct contact with soils. In addition, removing VOCs ftpm soils and bedrock
through SVE and LTTS will reduce the source of VOCs to the aquifer and will thereby reduce
the overall time required to remediate the aquifer. All risks resulting from exposure will be
reduced to a 1 x 10'5 carcinogenic risk level or an HI of less than 1., RAAs incorporating
these technologies, therefore, provide excellent protection of human health and the
environment. Additionally., both of the selected alternatives involve technologies that are easy
to construct and operate, and have been demonstrated successfully by the U.S. EPA SITE
program. ,
I 0655
.7. ... \- • •:..
-------
12' J^D^S^ 8°afS wereselected? Jfthe cleanuP Soal was based on an ARAR, what was that
AKAKf What risk level was selected to establish cleanup goals?

These cleanup levels are for the Phase I remedial action. Soil vapor extraction will be
implemented during Phase II in areas where VOCs in soil exceed the cleanup standards set
forth below.

Soil Cover
0656
Contaminant
Cleanup Level (ug/kg)
ARAR or Other Basis
Carcinogens
Benzene3
Tetrachloroethene
Trichloroethene
Vinyl chloride3
7.9
140
16
0.6
Modelb
Model
Model
Model
Noncarcinogens
1,1,1 -Trichloroethane
1,1 -Dichloroethenea
1,1 -Dichloroethane3,
1,2-Dichloroethene
4-Methyl-2-pentanone
Naphthalene
7,300
0.8
2.4
1,430
723
4,550
Model
Model
Model
Model
Model
Model
"While these contaminants were not detected in soil, soil cleanup levels were
established to protect ground water.
"Soil cleanup levels were developed using the Summers Leach Model to determine a
VOC concentration in soils that would ensure, VOC concentrations in ground water
would not exceed a 1 x 10'5 carcinogenic risk level. U.S. EPA's Hydrologic
Evaluation of Landfill Performance (HELP) model was used to calculate the
infiltration reduction provided by the soil cover and multimedia cap. •

Multimedia Cap with Flexible Membrane Liner: These VOC cleanup levels are for
LTTS residuals to be landfilled on site.
Contaminant
Cleanup Level (ug/kg)
ARAR or Other Basis
Carcinogens
Benzene3
Tetrachloroethene
Trichloroethene
69
1,200
140
Model"
Model
Model

-8-
-------
13.
Contaminant
Vinyl chloride3
Cleanup Level (jig/kg)
0.52
ARAB or Other Basis
Model
/V pn rare inn gens ...
1 ,1,1-Trichloroethane
l,l-Dichloroethenea
1 , l-Dichloroettianea
1 ,2-Dichloroethene
4-Methyl-2-pentanone
Naphthalene
64,000
6.9
21 .
13,000
6,100
40,000
. , Model
Model
Model
Model
Model
Model
While these contaminants were not detected in soil, soil cleaniip levels were
established to protect ground water. j •
"Soil cleanup levels were developed using the Summers Leach Model to determine a
VOC concentration in soils that would ensure VOC concentrations in groundwater
would not exceed a 1 x 10'5 carcinogenic risk level. U.S. EPA's HELP model was -
used to calculate the infiltration reduction provided by the soil cover and multimedia
cap. • i
, . • . . . ' . i •
In addition PCBs must be treated tp 10 mg/kg. '!.."'.
, ' . " • I , " . ,.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include;

• None ' ]• ...'.•-'

Standard technologies eliminated because of cleanup goals include:
I . -
• None !
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Proven reliability
• Preference for treatment (vs. containment) ,.
0657
-------
16. How are measures compared?

Phase I, RAA-8 and Phase II, RAA-5 achieve significant risk reduction at a total present worth
cost of 515,012,000 to $16,612,000. Alternatives involving incineration offer a somewhat
higher degree of permanence but at a significantly.higher cost. Other alternatives are less
costly than the preferred alternatives, but provide less treatment. The chosen alternatives are
therefore cost effective.

Several innovative technologies were considered for Phase I. LTTS followed by solidification
was selected because it afforded a higher degree of certainty of achieving the remedial action
goals For all contaminants than some of the less established technologies considered Radio
frequency heating and white rot fungus, considered for Phase H RAAs, were eliminated
because of concerns about reliability and commercial availability of these technologies. Soil
aeration, chemical detoxification, and vitrification, considered for Phase II RAAs, were
eliminated because these technologies have not been demonstrated.

The selected remedies for Phase I and Phase II represent the maximum extent to which
permanent solutions and treatment technologies can be utilized in a cost-effective manner at
this site. RAA-5 was chosen over RAA-4 for Phase II because RAA-4 would not treat: VOCs
in soil and bedrock.
77.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy for this site. Because site
soils did not have a high enough organic content, the aboveground bioreactor, microbial
degradation, the BEST Process, and the liquid gas solvent extraction procedure were
eliminated from consideration.
References

U.S. EPA. 1988. U.S. Environmental Protection Agency. Technology screening guide for treatment
of CERCLA soils and sludges. EPA/540/2-88/004.
0658
-10-
-------
Allied Chemical and Ironton Coke
OU-2

Ironton, Ohio
Region 5
GENERAL STTE INFORMATION

/. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Coke and Tar Plant Soil (rag/kg)
2.
Benzo(a)pyrene
Naphthalene ,
Benzene •' ' •

Ice Creek Sediment (mg/kg)

Naphthalene

Lagoon Materials (mg/kg)

Benzo(a)pyrene
Naphthalene
Arsenic
Benzene
330
32
8
38
2,000
17,000 .
0.026
0.067
Site History
NPL Proposed:
NPLFinal:
FS:
ROD:
N/A
1983
7/90
12/90
Background

PRP-lead !
PRPs: Allied-Sigrial, Corp.
FS prepared by: IT Corp!
What volume of material is to be remediated?

The volume of material to be remediated included:

• 40,000 cubic yards of soil
• 150,000 cubic yards of sediments in Ice Creek
• 579?,000 cubic yards of sediments and debris in lagoons
3. What type of site is this? ,
K
Coal Products. An inactive coke plant and an operable tar plant located in an
industrial/residential area, adjacent to Ice Creek, a tributary of the Ohio River.
-1-
0659
-------
J-'
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Jgies considered during the identification and screening of technically feasible
Fencing, deed restrictions
Capping (asphalt, multimedia), slurry wall, grout curtain, sheet piling,
grout injection, block displacement, cultivation (in situ stabilization)
Solidification/stabilization (cement-based, silicate-based, thermoplastic-
based, organic polymer-based, lime-based, self-cementing)
Incineration (cyclone, infrared, rotary kiln, fluid bed, cement kiln
multiple hearth, high-temperature fluid wall, corona glow, plasma arc
circulating bed, ocean), industrial boiler/furnace, glassification
Landfill (on site, off site)
Access restrictions:
Containment:

Chemical treatment:

Thermal treatment:

Disposal:
;;t :
i
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: J

Biological treatment: Land application, microbial degradation (in situ biodegradation)
Phys/Chem treatment: Soil aeration, solvent flushing
Thermal treatment: Low-temperature thermal stripping, molten salt incineration, in situ
vitrification, thermal desorptioh, pyrolysis
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is In bold)
0660
— ==============
Alternative
RAA-2
RAA-3
==============================================
Innovative Technology
Bioremediate lagoon materials and
soils/limited action — sediments/ground
water management control
Bioremediate lagoon materials and
soils/localized slurry wall/ground water
management control
=========================
Estimated Costs
3 Criteria
$39,912,100
$39,564,200
9 Criteria
eliminated
eliminated
:f-

• E
-2-
-------
Alternative
RAA-4
RAA-5
RAA-11A
RAA-11B
RAA-12A
RAA-12B
RAA-13
RAA-14
RAA-18
Innovative Technology
Bioremediate lagoon materials/no
action—soils/limited action—
sediments/ground water management
control
Bioremediate lagoon materials/ landfill
soils on siteAimited action—
sediments/ground, water management
control
Partially bioremediate/incinerate lagoon
materials and soils on siteAimited
action—sediments/ground water
management control .
Partially bibremediate/beneficial use of
lagoon materials and soils as a fuel in
off-site industrial boilers/sediments/
ground water management control
Partially bioremediate/incinerate lagoon
materials and soils on site/bioremediate
Ice Creek sediments/ground water
management control .
Partially bioremediate/beneficial use of
lagoon materials and soils as a fuel in
off-site industrial boilers/bipremediate
Ice Creek sediments/ground water
management control A
Estimated Costs
3 Criteria
$36,863,800'
$39,264700
$124,331,100
$82,147,800
$127,321,700
$84,359,800
Bioremediate/solidify and stabilize
lagoon materials and soils/solidify arid
stabilize Ice Creek sediments/ground
water management control .
$67,273,900
Partially bibremediateAandfill lagoons
materials and soils on site/limited
action—sediments/ground water
management control
Bioremediation of Lagoons 1 through
4 and beneficial use of Lagoon 5 as a
fuel in on^site industrial boiler/
bioremediation of coke plant soils/
capping of tar plant soilsAimited
action—sediments/ground water
management control
$50,164,100
9 Criteria
eliminated
eliminated
$121,745,000
eliminated
$131,728,000
$77',578,000
eliminated
eliminated
NA*
$49,528,000
"This RAA was developed for the nine-criteria screen.
-3-
0661
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7. How did the cost compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
OGG2
Alternative
RAA-1
RAA-6
RAA-7
RAA-8
RAA-9
RAA-10
RAA-15A
RAA-15B
RAA-16
RAA-17
Standard Technology
No action
Solidify/stabilize lagoon materials,
soils, and sediments/ground water
management control
Landfill lagoon materials and soils on
site/limited action—sediments/ground
water management control
Partial on-site incineration and
beneficial use of lagoon material and
soil as a fuel in off-site industrial
boilers/limited action—sediments/
ground water management control
Landfill lagoon materials, soils, and
sediments on site/ground water
management control
Landfill lagoon materials and soils off
site/limited action—sediments/ground
water management control
Partially solidify and stabilize/
incinerate lagoon materials and soils
on site/solidify and stabilize Ice Creek
sediments/ground water management
control
Solidify and stabilize/beneficial use of
lagoon materials and soils as a fuel in
off-site industrial boilers/solidify and
stabilize Ice Creek sediments/ground
water management control
Landfill lagoon materials, soils, and
Ice Creek sediments on site after
solidification and stabilization/ground
water management control
Landfill lagoon materials and soils off
site after solidification and stabili-
zation/limited action—sediments/
ground water management control
3 Criteria
$0
$47,483,600
$42,979,300
$166,793,700
$50,229,400
$133,465,500
$120,839,200
$83,519,700
$72,546,200
$153,667,600
9 Criteria
$0
eliminated
eliminated
$161,120,000
eliminated
eliminated
eliminated
,$85,677,000
eliminated
eliminated
-4-
"y.
-------
Alternative
RAA-19
Standard Technology
Cap and slurry wall of lagoon
materials/no action oh soils/limited
action — sediments/ground water
management control
Estiimated Costs
3 Criiteriia :
N
A*.
9 Criteria
$30,946,000
'This option was not costed in the three-criteria screening, but was added- later:

8. If a standard technology was chosen, why? , ,
• ' " . .' .. - t- • \ .
A standard technology was not selected. , i

- - . L
'.-,._ i
9. . If an innovative technology was chosen, why? . * !

RAA-18 was selected because it reduces and controls potential risks to human health and the
environment posed by exposure from ingestion of contaminated soils; and ground water. The
contaminated soils will be treated via bioremediation and waste fuel recovery to reduce their
toxicity and carcinogenicity. The soils and waste will be treated so that risk levels associated
with ingestion of contaminated soil and waste will fall within the cumulative risk range of. 10"4
to 10"6 for carcinogenic compounds and so that the cumulative hazard indices for
noncarcinogens will be less than one. Implementation of this alternative will not pose
unacceptable short-term risks or cross media impacts. ^The selected remedy is designed to
meet all ARARs except where it will be necessary to receive waivers form the State. The
waivers are justifiable because "compliance with such requirements is technically impractical
from an engineering prospective" and "the remedial action selected will attain a standard of
performance that is equivalent to that regarded under the otherwise applicable standard,
requirement, criteria, or limitation, through the use of another methods or approach." The
chosen alternative provides long-term effectiveness since two waste treatment technologies will
be utilized at the site. Bioremediation and waste fuel recovery will be applied to soil and
waste materials. Each of these technologies permanently destroys the waste constituents. It is
the most cost-effective option.
• ' . . I •
The selected remedy represents a slight modification to the original RAA-18 alternative, which.
included the addition of land treatment bioremediation of Tar Plant |soils (thereby increasing
the volume of soil to be treated with bioremediation) and off-site disposal of the ash and
scrubber wastes resulting from the waste fuel recovery.
• . - I . • •
' ' j. ,
I-
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? . , .
1 . i " '
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of tip three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
-5-
0663
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Innovative technologies eliminated during the initial screening include the following:

• Soil aeration was eliminated because of extended depth, composition, and large
volume of waste involved.
• Solvent flushing was eliminated because of the large areal dimensions of the site and
the presence of sticky tar-like substances indicate a substantial volume of fluid would
be needed for flushing.
• Low-temperature thermal stripping was eliminated because it would not achieve the
temperatures necessary to volatilize the semivolatiles in the wastes.
• Molten salt incineration was eliminated because it would be unable to process either
the semisolid, solid, or both forms of known wastes at the site. "• •
• In situ vitrification was eliminated because the technology would not be applicable to
the waste zones with free flowing water. At the site, the ground water table intersects
the bottom-most wastes at the site. In addition, the large amount of waste to be
treated is a negative aspect.
• Thermal desorption was eliminated because it is hot applicable to treating all site
wastes.

Innovative technologies eliminated during the screening of the three criteria include:
t
• Land application was not incorporated into an RAA; however, no explanation for its
elimination was provided. ,
• Bioremediation of lagoon materials was eliminated because lagoon materials possess a
high heating value and the process was deemed to be less effective than using this
waste for beneficial fuel. In addition, certain portions of non-solubilized contaminants
may persist in the environment.

Innovative technologies eliminated during the detailed analysis include:

• None
'
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were long:term
effectiveness and permanence, reduction of contaminant toxicity, and'cost. The chosen
alternative will provide the greatest permanent reduction of site contaminants for the least cost.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Total carcinogenic
PAHs"*
Arsenic
0.97
0.56
Risk"
Risk
0664
-6-
-------
13.
Contaminant
Total carcinogenic
PAHs
Benzene
Cleanup Level (mg/kg)
1.4
0.485
Noncarcinogens
Naphthalene
650
ARARbr<
Grounc
Groun
r
Groun
Total carcinogenic PAHs is defined as the total concentration of benzo(a)pyrene,
chrysene, and ,dibenzo(a,h)anthracene. !'-''',. •' t
"Cleanup levels are based on the site-specific risk assessment assuming the ingestion ot
contaminated" soil by future residents,.and represent the concentrations that pose an
excess upper-bound individual lifetime cancer risk of 10" .
Cleanup levels were established to protect ground water and are meant to ensure that
remaining contaminant levels will not exceed the ground water cleanup levels.

*Two cleanup levels were developed for total carcinogenic
soiywaste cleanup and one for the protection of ground water.
PAHs at this site; one for
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? • , '

Innovative technologies eliminated because of cleanup goals include:

• ' None " ' • , • . '' •

Standard technologies eliminated because of cleanup goals include:.

• None . • .

14. Were treatability studies conducted on the innovative technology or Standard technology?
I
Treatability study were not conducted. j
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost/unit risk
Proven reliability
. Preference for treatment (vs. containment)
-7r
0665
-------
16. How are measures compared?

The selected remedy was preferred because through the destruction'of-waste and contaminated
soil it will greatly reduce the threats to human health by reducing site contaminant toxicity
Stabilization would have limited the potential for exposure of the waste to humans and the
environment; however, the permanence of stabilization has not been fully demonstrated and
would have to be modeled in a pilot study prior to implementation. Also, stabilization would
be more difficult to implement given the uncertainty regarding the development of an effective
solidification process. Capping was considered the least permanent option because none of the
„ waste actually would be destroyed. The chosen option is cost effective because it is
considerably less expensive than other alternatives which achieve similar effectiveness
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedial alternative.
68G
-------
American Chemical Service, Inc.
Griffith, Indiana
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and mec"
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediment/Waste (mg/kg)

BEXT Compounds
Chlorinated Benzenes
Chlorinated Ethenes
Chlorinated Ethanes
Ketones
Phthalates
PAHs
Phenols
PCBs
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 135,000 cubic yards of soil, sediment, and waste
linants,
iddressed in

ncipal

3,002
11
1,110
11
0.7
0.15
m-
2
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
Back

PRP-lead
N/A
9/84
6/92
9/30/92
ground

PRPs: Not identified
FS prepared by: Warzyn Inc.

i
26 ' ' ' .-.-':•
3. What type of site is this?

Recycling. Formerly a solvent recovery facility, a chemical manufacturer now is located on
the site, which is in a residential area.
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS.'
' • • ' ' . '' '
Standard technologies considered during the identification and screening of technically feasible
technologies were:
' ' i' .
Access restriction: Fencing, deed restrictions
Containment: Capping (clay, asphalt, concrete, multilayer), surface grading, injection
grouting, vegetative cover, dust control
-1-
687
-------
5.
Phys/Chem treatment: Fixation (in situ, ex situ), in situ photolysis
Thermal treatment: Incineration (rotary kiln, infrared)
Disposal: Excavation, RCRA landfill (on-site, off-site)

Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
leasiole technologies were: .

Biological treatment: Biodegradation (aerobic, anaerobic, in situ, ex situ), bioreactor,
landfarming, bioharvesting
• Phys/Chem treatment: Oxidation/reduction (in situ, ex situ), dechlorination, vacuum vapor
extraction (in situ, ex situ), solvent extraction (in situ, ex situ) soil
washing (in situ, ex situ), in situ steam stripping, in situ radio
frequency
Thermal treatment: Low-temperature thermal treatment, in situ vitrification, wet air
oxidation
6.
was the cost estimate for the innovative technology?
rin ,K PrOC6SS' in *hich technic*»y feasible technologies are identified
(pnor to the formulation of RAAs), the FS does not quantify costs. After the RAAs have
formulated, costs are typically estimated as part of a three-criteria screening pro^eVs
SSST?1 ;7Iementf **-. ** cost> «° ^ntify alternatives that merila more detailed
^criteria C°StS W£re <" duri<* - Cation based on
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Soil, Sediment, and Waste
Alternative
RAA-3B
RAA-4
RAA-5
RAA-6A
Innovative Technology
Excavation/on-site low-temperature
thermal treatment of waste
— —^ . .
In situ steam stripping of buried waste
and soil
Excavation/on-site incineration of
buried waste/in situ vapor extraction of
soil

gy
—
rature
ed waste
ied waste
lOf
•action of
!
Estimated Costs
3 Criteria
—
N/A
. N/A
N/A
N/A

9 Criteria
$43,150,000
_
$48,950,000

$31,050,000
$41,150,000

688
-2-
-------

Alternative
RAA-6B
RAA-7B
RAA-8A
RAA-8B

Innovative Technology
Excavation and on-site low-tempera-
ture thermal treatment of buried
waste/in situ vapor extraction of soil/
on-site disposal/cap
On-site low-temperature thermal
treatment of buried waste and soil
Excavation and landfarming of buried
waste and soil
Excavation and slurry-phase bioreactor
treatment of buried waste and soil
Estimated Costs
3 Criteria
N/A
NJ/A
Isf/A
1>I/A
9 Criteria
$35,850,000
$62,450,000
$32,250,000
$41,250,000
7. " How did the cost(s) compare to standard technologies? I
• i •
Cost Estimates for RAAs That Include Standard Technologies.
(selected remedial alternative is in bold) j
• Alternative
RAA-1
RAA-2 •_•
RAA-3A
RAA-7A
Standard Technology
No action
Slurry wall/natural flushing of waste,
soil, and sediment
Excavation and on-site incineration of
buried .waste
On-site incineration of buried waste and
soil
Estimated Costs
3 Criteria
H/A
N/A
1
1
N/A
i1
N/A
'
9 Criteria
$0
$10,050,000
$52,850,000
$82,650,000
8. If a standard technology was chosen, why?

Solidification/stabilization and off-site disposal were selected for some wastes.
If an innovative technology was chosen, why? '

RAA-6B was chosen because it provides the greatest protection to humain health and the
environment since it will reduce site risks to 10'6. This alternative will reduce risks of direct
contact to waste and soil. The treatment technologies proposed—low-temperature thermal
treatment (LTTT) and in situ vapor extraction (ISVE)—will remediate site contaminants to
required cleanup levels for waste and soil respectively. These treatment technologies
permanently remove site contaminants, thereby providing long-ternj effectiveness and
• i p ..'•-.

, ' - ' " -3- -' {•'•"'. •
669
-------
eliminating the need for long-term maintenance. LTTT was preferred because it has been
proved, affording a great degree of certainty towards achieving remedial cleanup. While ISVE
is less certain ofmeeting final cleanup levels, soils that fail to meet those levels will then be
-ated with LTTT. RAA-6 was preferred over alternatives that would require excavation
• ,ich would pose short-term risks to workers and nearby residents. The chosen alternative
offers a great degree of protection. Though its costs are somewhat higher than for other
alternatives, it is the most cost-effective. While incineration would provide comparable
protection, LTTT was preferred because it is less expensive
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

» Ex situ solvent extraction of waste was eliminated because of the very high levels of '
contaminants in the waste and because the waste matrix would not be amenable to
phase separation by this technique.
• Soil washing (in situ, ex situ) were eliminated for soil and waste because of their
complex organic matrix, as well as the hydrophobic nature and high soil adsorption
affinity of most of the detected VOCs and SVOCs. Because of the high organic
concentrations, aqueous-based solutions would not be effective in extracting organics
which would likely remain preferentially dissolved in the oil phase.
• Ex situ oxidation/reduction was eliminated because the cost would likely be
prohibitive due to the large volume of materials involved.
» Wet air oxidation was eliminated because it would be applicable only to aqueous waste
streams, and not to solid, sludge, or slurry-phase waste matrixes.
• Bioharvesting was eliminated because the depths and concentrations of site
contaminants would be too great for contaminant accumulation in plants
» In situ oxidation/reduction was eliminated because it would be too difficult to monitor
and adjust in situ.
• In situ solvent extraction was eliminated because implementation would be difficult
Uniform distribution of contaminants would be necessary, and agitation and sufficient
contact time would be required, which would not be possible in situ. Furthermore
most extraction solvents are toxic, which could affect ground -water if adequate '
collection systems are not developed.
• In situ radio frequency for waste was eliminated because of the exorbitant energy
requirements associated with volatilizing areas of concentrated waste. Furthermore a
health and safety risk could be posed by uncontrolled VOCs emission that could either
escape the capture system or create a potentially explosive gas stream
• /0"TewooaS eliminated because * would not be applicable to nonchlorinated
and SVOCs, and there is presently no means of applying it to soils.

670
-4-
-------
Innovative technologies eliminated during the screening of the three criteria include the
following: t

• In situ biodegradation (aerobic, anaerobic) was eliminated because: the incomplete
degradation of organic contaminants could create toxic byproducts; chlorinated •
compounds might not be amenable to aerobic treatment; the complexity of organic
contamination at the site requires both anaerobic and aerobic treatment; uniformly
distributing oxygen and nutrients would be difficult because of the nonhomogeneous
zones of permeability; high levels of site contaminants are expected to be toxic to
microorganisms; and no studies have demonstrated that this technique would be
successful in such a contaminant matrix.
• In situ vitrification was eliminated because high organic 'contaminant levels could
overload the offgas treatment system; a combination of high soil permeability and the
presence of ground water and buried drums could interfere with the technique, possibly
causing electrical shorting; the soil moisture content that is constantly being recharged
by the high water table would require dewatering and capping before the vitrification
process; vitrified source areas would interfere with present ground water flow patterns;
the technique has not been demonstrated on a full-scale basis; iind volatilized gases
could migrate away from the treatment zone and spread to gresiter depths.
• Ex situ low temperature thermal treatment was eliminated because no commercial are
available presently. .' '. ,
'••••. Ex situ vacuum vapor extraction was eliminated because it would be less effective and
more costly than in situ vacuum vapor extraction. j
• In situ solvent extraction for soil was eliminated because it has not been demonstrated
on a full-scale basis; vendor availability is limited; the. complexity of site contaminants
would make it difficult to identify a single solvent or appropriate mixture of extraction
solution; waste would be generated that would require disposal; arid other processes
offer comparable effectiveness at similar costs. j
• In situ radio frequency for soil was eliminated because it would not be amenable for
treatment of PCBs and inorganic metals, it has not been demonstrated on a full-scale
basis, and it has high operational costs!
• Ex situ biodegradation (aerobic, anaerobic) was eliminated because high organic
contaminant concentrations would likely be toxic to microorganisms.
''.'-• • ' ' . ''•.!•''.••'•''-.•
Innovative technologies eliminated during the detailed analysis include I the following:

• Landfarming was eliminated because its effectiveness and imp] ementability are
uncertain. The technique has not been demonstrated on a contaminant matrix or scale
analogous to the site. Furthermore, excavation would be required, which would
present a short-term risk to site workers and nearby residents.
• Bioreactor was eliminated because its effectiveness and impletnenliability are uncertain.
The technique has not been demonstrated on a contaminant matrix or scale analogous
to the site. Furthermore, excavation would be required, which [would present a short-
tejm risk to site workers and nearby residents, . . . "
• In situ steam stripping was eliminated because it has not been [demonstrated on a full-
scale basis, no known vendor is available, and the augers usedSto treat the waste could
puncture the clay-confining layer and introduce contaminants to the lower aquifer.
-------
11.
12.
Which of the nine cntena were weighted most heavily in selecting the technology? Did failure

to meet one of the nine criteria result in the elimination of the innovative technology? If so

nhich criterion? Which of the criteria supponed the use of a standard '
m°St heavily in selecti°g a
, ^ i ** m°St 6ffeCtiVe a1*6™1"6 in Coving the risk posed by
contanunated soil, the technique was eliminated because the excavation of waste and soil
would expose site workers and nearby residents.

Landfarming and bidreactor treatments were eliminated because of short-term risks to workers
and residents. In situ radio frequency was eliminated, in part because of its high cost. In situ

extraction were eiiminated because *
672
, 8°al WaS based °n an ARAR' wh*t was that
risk level was selected to establish cleanup goals?

Soil, Sediment, and Waste *
Contaminant
Cleanup Level (mg/kg) ARAR or Other Basi
Carcinogens
Tetrachloroethene
bis(2-Ethy!hexyl)

phthalate
Trichloroethene
Pentachlorophenol
4,4'-DDD
" ^~m^.^—^_

2,4-Dinitrotoluene
1,1-Dichloroethene
Carbon tetrachloride
bis(2-Chloroethyl) ether
-6-
-------
Contaminant
4,4-DDT
Chloroform
Hexachlorobutadiene
1,2-Dichlorethane
Methylene chloride
1 ,2-Dichloropropane
Hexachlorobenzene
gamma-BHC (lindane)
Cyclic ketones.
1,1,2-Trichlorethane
n-Nitrosodiphenylarriine
1,1,2,2-
Tetrachloroethane
Vinyl chloride
alpha-BHC
beta-BHC
, 2,6-Dinitrptoluene
4'4'-DDE
1 ,4-Dichlorobenzene
Heptachlor epbxide
Cleanup Level (rag/kg)
0.088
9.5
0.36
0.64
6.2
0.42
0.018
0.046
7.3
0,51.
12.0
0.28
0.031 :
0.0047
0.016
0.044
0.16
2.4
0.0033
ARAR or Other Basis
Risk
Risk
: Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Noncarcinogens . 11
Antimony
Toluene
Cadmium
Ethylbenzene
Barium
Chromium VI
Naphthalene
N-chain alkanes
Nitrogenated benzenes
1,1,1 -Trichloroethane
15-0.5
, 5,000-167
51-2
1,300-43
2,600-87
1,400-47
; 82-3 .
760-25
6.2-0.2
2,300-77
Risk"
Risk
Risk
^ Risk
Risk
Risk
Risk
Risk
Risk
Risk
-1- . . - ^ .--..'.
673
-------
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Branched alkanes
———————

4-Methyl-2-pentanone
630-21
—™—>™^^M*

490-16
Methyl propyl benzenes
Halogenated alkanes
2,300-77
•~-^—^—^^i^«i

0.63-0.02
—' ...

1,300-43
Endosulfan I
Dimethyl ethyl

benzenes
1,2-Dichloroethene (cis)

2-Butanone
250-8.3
———™«^

620-21
Noncyclic acids
1,000-33

85-3
Methylated

naphthalenes
2,400-80
•MHBWMb

150-5
Chlorobenzene
Xylenes (mixed)
26,000-867
ii ii

1,200-40
Oxygenated benzenes

Diethyl benzenes
Propenyl benzenes
1,2,4-Trichlorobenzene
16-0.5

2,700-90
Chloroethane
•For carcinogens, an excess upper bound individual lifetime cancer risk of 10'" was

r, noncarcinogens, a Hazard Index (HI) from 1.0 to 0.03 was acceplable
policy for unrestricted access sites.

»» of1cleanuPulevels ^ noncarcinogens corresponds to His of "1.0 to 003 "

0 03 value nught relate to a Hazard Quotient of 0.3 to allow for exposure' to '

multiple contaminants whose effects might be additive
674
-8-
i,,;
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None ' , [ • ' :

Standard technologies eliminated because of cleanup goals include: |
'I .
; • None
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. Treatabilities studies will be conducted to determine if
in situ vapor extraction will be able to meet remediation levels. If in isitu vapor extraction
cannot meet cleanup levels, VOC/SVOC-contaminated soil will be excavated, treated with low-
temperature thermal treatment to health-based standards, and redepositpd. A pilot study of in
situ soil washing using various surfactants performed jointly by the U.S. EPA and Air Force at
the Volk Field fire, training pit showed no appreciable decrease in organic contaminant concen-
trations in soil following 7 days of flushing. In situ soil flushing was jdeemed ineffective for
contaminants with a high affinity for soil adsorption, such as the site contaminants.
17.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Preference for treatment (vs. containment)
.Impact on nearby populations
Proven reliability

16. How are measures compared? . .
i
The chosen alternative provides a high degree of effectiveness and permanence through source
treatment, which was preferred over containment. The magnitude of risk to on-site workers
and nearby residents posed by excavating soil resulted in RAA-6B being chosen instead of
RAA-7, the most effective alternative. Proven capability also was an
important factor. Two
alternatives (landfarming and slurry-phase bioreactor treatment) were 3liminated due to the
lack of proven reliability and the need for extensive treatability studies.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were primary in selecting a remedy. Biohatvesting was, eliminated
because the contaminants were too deep for it to be effective. In situ biodegradation was
eliminated because it would be difficult to implement since the site w[as comprised of
nonhomogeneous zones of permeability. In situ vitrification was elinjiinated because the high
water table would make it difficult and expensive to implement.
-9-
675
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Berlin and Farro Liquid Incineration, Incorporated
Swartz Creek, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
, this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediment (rag/kg)

Arsenic 68
Benzene i
Ethylbenzene 23
Toluene 21
Xylenes 240
Lead 118 1
Hexachlorobenzene 7
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/8/93
12/22/89
9/30/91
Background

PRP-lead
PRPs: Berlin and Farro Trust Fund,
National Bank of Detroit, Trustee
FS prepared by: Woodward-Clyde
Consultants
2. Wtiat volume of material is to be remediated?

The volume of material to be remediated included:

• 48,000 cubic yards of soil and sediment
3, What type of site is this?

Industrial Landfill. A former liquid incinerator and landfill.,

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

weref" C°nSidered ^ ** identification and serening of technically feasible
Access restriction:
Containment:
676
Fencing, deed restrictions
Capping (concrete, multimedia, clay, asphalt), synthetic membrane
revegetation, slurry wall, sheet piling, grout curtains, sprayed on liners
„, . , Sllt barners, vibrating beam, grout injection '
Chemical treatment: Stabilization, precipitation, polymerization, detoxification, chelation
-------
Physical treatment:
Disposal:
Mechanical aeration
Excavation, off-site disposal at RCRA facility
5. Was an innovative technology considered in the FS? If so, which technology?
I
Innovative technologies considered during the identification and screening of technically
feasible technologies were: "
i ' L. " I'

Biological treatment: In situ aerobic degradation, in situ anaerobic degradation
Chemical treatment: Soil flushing (solvent), dehalogenation, hydrolysis, reduction
Thermal treatment: Low temperature thermal stripping, ground freejzing, in situ
vitrification, steam stripping j,
What was the cost estimate for the innovative technology? .
V '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
-implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on the nine criteria established
by theNCP.
•- • ' • \
No innovative technologies were incorporated into remedial alternativejs.
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4

Standard Technology
No action/long-term monitoring
Fencing/deed restrictions/ground water
restrictionsAong-term monitoring
Fencing/deed restrictions/slurry wall/two
multimedia caps/ground water
monitoring ~ ' • ,
Fencing/deed restrictions/excavation of
soils with risk in excess of lO^/off-site
disposal/clay cap/ground water
collection, treatment, and discharge to
surface water
Estimated Costs
1
1
3 Criteria
$iob,ooo
$425,000 ,
$7,0^5,000
i
1
$7,420,000
1
..
9 Criteria
$100,000
$425,000
$7,045,000
$7,420,000
677
-------
Alternative
—»^—^—••
RAA-5
RAA-6
RAA-6A
RAA-7
RAA-7A
RAA-8
RAA-9
Standard Technology
Excavation of soils with risk in excess
of ICTVon-site incineration/cap/ground
water collection, treatment, and
discharge to surface water
Fencing/deed restrictions/excavation of
soils with risk in excess of 10'6/
multimedia liner/leachate collection/ on-
site fly ash solidification/ground water
collection, treatment, and discharge to
surface water/long-term monitoring
Deed restrictions/excavation of soils
with risk in excess of lO^/off-site
disposal at RCRA facility/backfill/
reyegetation/ground water collection,
treatment, and discharge to surface
water
Fencing/deed restrictions/excavation of
soils with risk in excess of 10'6/
multimedia liner/leachate collection/
Portland cement solidification/ multi-
media cap/ground water collection,
treatment, and discharge to surface
water
Fencing/deed restrictions/excavation of
soils with risk in excess of 10'6/
multimedia liner/leachate collection/
Portland cement solidification/multi-
media cap/ground water collection, and
off-site treatment and discharge
Fencing/deed restrictions/excavation of
soils with risk in excess of 10'6/fly ash
solidification/multimedia cap/ground
water collection, treatment and
discharge to surface water for 10 years

Fencing/deed restrictions/excavation of
soils with risk in excess of lO^/fly ash
solidification/multimedia cap/ground
water collection, treatment and
discharge to surface water for 30 years
Estimated Costs
3 Criteria
9 Criteria
$8,645,000 $8,645,000
$10,415,000 $10,415,000
,$13,100,000 $13,100,000
$11,635,000
$11,610,000
$5,930,000
$7,450,000
$11,635,000
i
$11,610,000
$5,930,000
$7,450,000
678
-3-
-------
Alternative
Selected
Alternative
Standard Technology
Deed restrictions/excavation of soils
with risk in excess of W*/fly ash
solidification/disposal of waste into
on-site RCRA containment cell/
remove free liquid/backfill/
revegetation/ground water collection,
treatment, and monitoring
Estimated Costs
3 Criteria
N/A
9 Criteria
$8,119,300"
This alternative is proposed for the first time in the ROD.
8. If a standard technology was chosen, why?
- ' ' . 'I ,
The selected alternative was developed and presented in the ROD. Fnim nine developed
alternatives, EPA selected a remedy that combines the soil and on-site sediment excavation
element of RAA 6 and the off-site sediment excavation and the groundwater treatment
proposed in RAA 9. For the selected alternative, approximately 48,OOQ cubic yds. of on-site
contaminated soil, sediment and drain sediments will be disposed of on-site in a cell which
will meet the ARAR requirements of RCRA Subtitle C and Michigan Act 64. Treatment will
remove free liquids and solidify the materials. The proposed cell will have: 1) more long-term
effectiveness and permanence than RAA-6, the engineered cell described in the FS (treatment
will be required for any excavated materials exhibiting characteristics of RCRA hazardous
waste), 2) Michigan has promulgated rules that specify general standards for clean-up of
contaminated sites in Michigan and which are considered ARARs (these rules establish criteria
for three acceptable cleah-up types - type A achieves background levels, type B achieves
specific standard risk-based clean-up levels, and type C is based on site-specific risk
assessment - only those remedies which dispose of all materials which exiseed Type B clean-up
standards in a cell that satisfies Michigan Act 64 and RCRA minimum technology
requirements meets the type C criteria, 3) treatment of contaminated Soils and sediments to
remove free liquids and stabilize characteristic wastes reduces leachate migration, 4) uses
1 common construction equipment and readily available technology.

The selected remedy was different from the remedy in the Proposed P|lan (July 1990). The .
Proposed Plan identified on-site incineration of approximately 38,000 cubic yards. PRPs and
the public expressed strong opposition to on-site incineration. Opposition was based pn the
short-term risk presented by the estimated 380 days of operation of the incinerator. In addition
incineration is not considered an effective treatment for metals. Off-site disposal proposed by
the community was not selected by EPA because of the questionable 'availability of using
hazardous waste disposal capacity for materials with relatively low levels of contamination and
the transportation risks associated with off-site disposal.
.If an. innovative technology was chosen, why?

An innovative technology was not chosen.
-4-
679
-------
JO.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• In situ aerobic degradation was eliminated because soil constituents (metals) would
inhibit microorganism metabolism. Furthermore, the site's nonuniform hydrogeology
and the soil's high moisture content would make implementing this technology
difficult. . • 6J
« In situ anaerobic degradation was eliminated because it would be a slow and
incomplete process, which is considered an experimental technology for small
quantities of waste materials.
• Soil flushing was eliminated because it is only for the most mobile elements/
compounds and its effectiveness in clay soils has not been demonstrated
• Ground freezing was eliminated because the technology has not been proved and
associated thermal maintenance costs would be high.
• Hydrolysis was eliminated because of the toxic byproducts that would be generated
and it is an unproven technology.

Innovative technologies eliminated during the screening of the three criteria include the
following:

» Dehalogenation was eliminated because it has been tested only on oily wastes and
sludges containing PCBs; clay soils at the site would require extended reaction times
special separation processing and result in poor solvent recovery; no data is available
on laboratory investigation of process effectiveness on C-series compounds, and- is in
pilot scale development which is not sufficiently developed to warrant further
consideration.
« Steam stripping was eliminated because it would not be effective in soils with low
permeability, in saturated soils, or in nonuniform hydrogeology.
• In situ vitrification was eliminated because it has not been used in any large-scale
commercial applications; long term effectiveness of the process is unknown; saturated
soils at the site would create large volumes of water vapor and overburden the off-gas
emission control system, resulting in an increase in the volume of wastewater for
treatment; higher electrical and operating costs would also result from treatment of
saturated soils; consolidation of soils and sediments would increase treatment
effectiveness but would increase short term impacts to the community; additional costs
would be incurred in bnnging the required power to the site-ability of the off-gas
collection system to capture all generated gases is uncertain; cost estimate? are much
higher than costs of other remedial technologies. "
• Low temperature thermal stripping was eliminated because it has not been proved
effective. ,

Innovative technologies eliminated during the detailed analysis include the following:

• None
6SO
-5-
-------
11.
12.
13.
Which of the nine criteria were weighted most heavily in selecting the \technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
•"-'""• '. • !
Community acceptance was a major factor in on-site disposal, because of the rejection of
incineration originally proposed by EPA. Compliance with state ARARs for clean-up were
also of major importance in selecting the remedy. , -vj
. i. ' "
No innovative technologies were incorporated into remedial altemativeis.

. • •-" • • -i
i . •
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (rag/kg)
ARAR
or Other Basis
Carcinogens
Benzene
Lead
Arsenic
Hexachlorobenzene
(C-66)
0.02
20.8
10.6,
1.4

Risk8
Background11
Background

Noncarcinogens
Toluene
Xylene
Ethylbenzene
16
6
1-4
Risk

Michigan Actc
M
ichigan Act
Michigan Act
"Cleanup levels are health-based and reduce risk to less than 10"6.
bCleanup levels are based on natural background levels.
These cleanup levels, determined according to Rule 299.5711. of the Michigan
Environmental Response Act (Michigan Act 307), establish standards to prohibit
ground water contamination.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? j

Innovative technologies eliminated because of cleanup goals include:

• None . ' i :
'' • >
' • , -- .
Standard technologies eliminated because of cleanup goals include: !

• None • '.. . "' ' . '•
-6-
681
-------
14.
15.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability tests were conducted for soil stabilization technologies by Hazcon, Inc. Soil
stabilization tests showed that volatile organics are released, and semivolatiles and metals are
immobilized; several tested compounds are effective stabilizing agents; and fly ash is the least
expensive stabilization agent, but generates higher metal leachate concentrations.

What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: >

Risk level achieved ,
Total cost
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared? , • ' ,

The selected alternative was preferred because it reduces soil contaminants to the lowest risk
level achieved (10') by a proposed alternative. The chosen alternative emphasizes treatment,
which was preferred over containment because of its long-term effectiveness. Of all the
alternatives that incorporated waste treatment, the chosen alternative cost the least. The
treatment technology proposed in the preferred alternative was deemed to be reliable Two
technologies (dehalogenation and low temperature thermal stripping) were eliminated because
they are still under investigation and their reliability and effectiveness is uncertain
17.
Wliat technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The nonuniform site hydrogeology and low permeability of the site soil were technical
considerations that were factors in the elimination of several innovative technologies including-
in situ aerobic degradation; steam stripping; soil flushing; and in situ vitrification. These site
characteristics were considerations but were not primary in the selection of the remedy.
682
-7-
-------
Buckeye Reclamation
OU-1

Richland Township, Belmont County, Ohio
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Soil

No principal contaminants were addressed in
the, feasibility study for the soils at the site.
However, samples from the waste pit, soils,
leachate, ground water, and surface water
were analyzed. The following twelve
contaminants were included in the risk
assessment:
Inorganics

Arsenic
Beryllium
Lead
Cadmium
Chromium
Nickel
Organics

Benzene
Trichloroethene
Carbon tetrachloride
1,1-Dichloroethene
Carcinogenic PAHs
Toluene
Waste pit contaminants (rag/kg)
Benzene
Toluene
Ethylbenzene
Xylenes
Chromium
19
142
303
907
0.276
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/8/93
4/30/91
8/19/91
Background

PRP-lead
PRPs: Ohio Resource (Corporation;
Cravat Coal Company; Ashland
Chemical Company; Aristech
Chemical Company (formerly
' U.S. Steel Corporation); Beazer
East, Inc. (formerly Koppers
Company, Inc.); Triangle PWC;
SKF Industries; Kittle Hauling
FS prepared by: Versar, Inc.
2. What volume of material is to be remediated? ,

The volume of material to be remediated included:

• 1,300,000 cubic yards of soils

' • , . \
3. What type of site is this?

Municipal Landfill. A municipal solid waste landfill site.
-1-
683
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: -

Access restriction: Deed restrictions, fences
Containment: Capping (clay/soil, asphalt, concrete, standard landfill cap, RCRA cap)
injection grouting .
Chemical treatment: Solidification/stabilization, lime fly ash injection
Thermal treatment: Incineration (rotary kiln, 'multiple hearth, fluidized bed, plasma arc,
infrared), high temperature fluid wall reactor
Disposal: RCRA landfill
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Composting, solid phase treatment, in situ biodegradation, slurry phase
treatment
Chemical treatment: Chemical oxidation/reduction, soil washing (solvent), dechlorination, in
situ vacuum vapor extraction, soil flushing (solvent), in situ chemical
treatment
Thermal treatment: • Thermal volatilization, wet air oxidation, molten salt incineration, in
situ vitrification, pyrolysis
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(pnor to the formulation of RAAs), the FS does not quantify costs. After the RAAs have be.en
lormulated, costs are estimated as part of a three-criteria screening process (effectiveness
implementabihty, and cost) to identify alternatives that merit a more detailed evaluation 'llie
estimated costs then were recalculated during an evaluation based on nine criteria established
by the NCP. No innovative technologies were considered technically feasible during the initial
screening process, therefore no costs were estimated. '
'Ill;
i
634
-2-
t v_
-------
7.' How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-4A
RAA-4B

Standard Technology
No action
Institutional actions •', . .
RCRA, Subtitle C cap/chemical
treatment of ground water
RCRA cap/wetlands treatment
Ohio Administrative Code solid
waste (standard) landfill cap/
chemical treatment of ground water
Ohio Administrative Code solid
waste (standard) landfill cap/
wetlands treatment
Estimated Costs
3 Criteria
$0
$1,786,000
$196,913,0010
$193,084,000
$52,492,000
$48,663,000
9 Criteria
$0
eliminated
$196,913,000
$193,084,000
$52,492,000
$48,663,000
8. ' If a standard technology was chosen, why? | ,

An Ohio Administrative Code solid waste landfill cap was selected because: 1) it would
provide protection to trespassers by covering contaminated soil, 2) reliable technology for
minimizing infiltration and reducing leachate, 3) the types of contaminants in the soils pose
difficulties in implementing treatment, 4) short term health risks involved in excavation, 5)
high cost of excavation and treatment versus little overall environmental benefit, and 6) it is a
well proven technology. .
9. If an innovative technology was chosen, why? . j.

Wetlands treatment of leachate was selected because: 1) it is effective over the long term, 2)
once established wetlands should be a self contained system, 3) will increase water quality
which benefits wildlife habitats.
i _
10. If an innovative technology was not chosen, why not? At what stage\ was the innovative
technology eliminated? - ; ' .

m
Innovative technologies eliminated during the initial screening include the following:

* ? >OSt"%' SOMPhase treatment' and in situ biode^-idotion were eliminated because
tht would not be effective for treating some inorgar,cs that are not readily
biodegradable. * '
» Slurry phase treatment was eliminated because of the large volume of material to be
remediated.
» Chemical oxidation/reduction was eliminated because it would treat selected inorganics
at specific PH ranges and would not be applicable for the type and range of organic
'contaminants present at the site.
Soil washing was eliminated because it is only applicable when used in conjunction
with other treatment technologies.
Dechlorination was eliminated because chlorinated hydrocarbons are not the
predominant contaminants at the site.

* ln fVu "I™"™ Vap°r extraction was eliminated because, due to low soil permeability
and the fractured bedrock around the site, a vacuum system would be difficult to
implement.
" Soil flushing was eliminated because the site soil's low permeability would impede the
distribution and collection of treatment solutions.
• In situ chemical treatment was eliminated because, due to the presence of organic
compounds in soils and the low permeability of soils, effective distribution of reagents
would be difficult.
» Thermal volatilization was eliminated because iMias been demonstrated for hazardous
waste only on a pilot-study scale.
• Molten salt incineration was eliminated because the technology has not been proved
on a large scale for the various wastes present at the site.
" In situ vitrification was eliminated because the technology only has been demonstrated
on hazardous waste in lab- and bench-scale tests.

Innovative technologies eliminated during the screening of the three criteria include the
following: ' •

• Wet air oxidation was eliminated because implementation would require excavation of
large volumes of material that pose potential health risks.

Innovative technologies eliminated during the detailed analysis include the following:

" None . .
if-
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology? '

Cost weighed and long-term effectiveness were weighted heavily in the selection of the
treatment technology.
636
-4-
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? Whatfisk level was selected to establish cleanup goals?
• i
No cleanup goals were specified for the remediation of soils because llhe selected source
control response action was containment.
' ' p ' "' ' .'• ' • ' "

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
' i ,_'•••-
Innovative technologies eliminated because of cleanup goals include:

• None
' .'!'•'
Standard technologies eliminated because of cleanup goals .include: |
' !
• 'None, • '- - ' '•. \' ''"''" ^ • '

\ - '
14. Were treatability studies conducted on the innovative technology or standard technology?
• - I-
No treatability studies were conducted on source control remedies. However, treatability
studies were planned for this site to assess the effectiveness of the wetlands treatment method.
The objective of the treatability studies is to determine if the levels, of contaminants of
concern, mainly metals, can be lowered to meet discharge limits.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Waste left in place/institutional control
Time to design/construct/operate
Proven reliability

16. How are measures compared?

The large volume of waste present at the site prohibited the use of technologies requiring
excavation due to potential adverse impacts on workers, high costs, iind the time required to
implement such measures. The option to contain wastes was therefore deemed the most
feasible for the site.
1 - ' !
• ' " "I . "
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The landfill's slope was a primary technical consideration in selecting the Ohio Administrative
Code solid Waste landfill cap. The steep slope prohibited the installation of a RCRA cap. The
I - "_

. - ; ' -, ': '*' ' -5-' ".'• .-• ' i ' :. '637
-------
presence of fractured bedrock, soil's low permeability, and the volume of waste to be
remediated were all factors in selecting an appropriate remedy.
F..
\,f-
638
-6-
-------
Butterworth #2 Landfill
Grand Rapids, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
2.
Soil (mg/kg)

Arsenic
Beryllium
Chromium
•PCBs
Dieldrin
43
8.5
43,000
72
5
What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
12/82
10/31/91
9/29/92
Background
i . -
PRP-lead
PRPs: Butterworth Landfill Steering
Committee
FS prepared by: McLaren/Hart
Environmental Engineering
Corporation
The volume of material to be remediated included:
i. ' • >" :
• 3,000,000 to 5,000,000 cubic yards of waste. The Butterwoitii Landfill encompasses
approximately 180 acres.
3. What type of site is this? ' • j

Municipal Landfill. The site is a former municipal landfill that received both residential and
industrial wastes until 1973. The site is located predominantly within the 100-year flood plain
of the Grand River. The area immediately surrounding the site is predominantly industrial.
TECHNOLOGY SELECTION
: : : ' , . |

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Institutional controls (fencing, deed restrictions)
Capping (low permeability, soil cap)
Stabilization/solidification
Incineration
-1-
639
-------
5.
Disposal:
Excavation, landfill (on-site, off-site)
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation, to situ bioremediation
Chemical treatment: Soil washing, soil flushing, solvent extraction, soil vapor extraction
I nermal treatment: Dechlorination, in situ vitrification
6. What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into the RAAs.
7.
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

The designation of RAAs changed in the ROD, These changes are presented parenthetically
DwJQ inr ,* . .
630
=====
Alternative
RAA-1
RAA-2
RAA-6/
RAA-II
(RAA-2)
RAA-7/
RAA-IIA
RAA-8/
RAA-IIB
======================
Standard Technology
No action/monitoring
Institutional controls/monitoring
Soil cap (Michigan Act 641 cap)/
establishment of alternative
concentration limits (ACLs) for
ground water
Soil cap (Michigan Act 641 cap)/
upgradient vertical barrier for ground
water
Soil cap (Michigan Act 641 cap)/
ground water extraction
===========================,
Estimated Costs
3 Criteria
$1,400,000
$1,800,000
$15,230,000
. $16,820,000
$16,590,000
9 Criteria
$l,400,000a
eliminated
-~— — — __ __ _
$15,230,000
$16,820,000
$16,590,000
-2-
-------
9.
Alternative
RAA-9/
RAA-HC
RAA-10/
RAA-m
RAA-11/
RAA-fflA
(RAA-3)
RAA-12/
RAA-IHB
RAA-137
RAA-fflC
(RAA-4)
•
Standard Technology
Soil cap (Michigan Act 641 cap)/
downgradient vertical barrier for ground
water/ground water extraction
Low permeability cap (Michigan Act
641 cap)
Low permeability cap (Michigan Act
641 cap)/upgradient vertical barrier for
ground water
Low permeability cap (Michigan Act
641 cap)/ground, water extraction
Low permeability cap (Michigan Act
641 cap)/downgradient vertical barrier
for ground water/ground water
extraction
Estimated Costs
3C
$2(V
$24,!
$26,:
riteiria
wo.poo
)00,000
540,000
$26,310..,000
$30,
150,000
9 Criteria
$20,440,000
$24,900,000
$26,540,000
$26,310,000
$30,150,000
The no action alternative presented in the ROD does not include mcjnitoring and therefore its
estimated cost is $0. . . •
8. If a standard technology was chosen, why? 'I
'• . I • " - r
The selected alternative RAA-2 includes the installation of a soil cap!, or the existing landfill
covers will be repaired/retrofitted to meet the requirements of the Michigan Solid Waste
Management Act 641. The selected alternative provides protection fjromi the major exposure
pathways on site by preventing contact with site soils and the landfilil contents through
capping. RAA-2 provides long-term effectiveness by containing theilandfilled waste on site
through engineering controls. Cap materials are expected to be obtainable from nearby
sources, and the engineering expertise and construction practices, and equipment for
installation, operation and maintenance of this component.of the selected alternative are
available and proven. The selected alternative also meets both fedeijal and state ARARs
associated with closure requirements for solid waste landfills, at the
alternatives.

!.
If an innovative technology was chosen, why?

An innovative technology was not chosen.
lowest cost among the
10. If an innovative technology was not chosen, why not? At what stage, was the innovative
technology eliminated? v ^

Innovative, technologies could be eliminated from the remedial techijiology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

-3- •'••.
691
-------
Innovative technologies eliminated during the initial screening include the following:

• Biodegradation was eliminated because it would be ineffective for inorganics and
would require intensive handling of materials. It also was rejected because treatment
would require excavation, which is not considered feasible or cost-effective given the
large volume of waste material and potential greater risk to on-site workers and nearby
residents. J
• In situ bioremediation was eliminated because implementation of this technology
requires homogeneous subsurface conditions. If heterogeneous subsurface conditions
exist, such as are found in solid waste (landfill) materials at the site, flow channels
would be formed by the injection of the biological inoculant. Flow channels would
hinder the effectiveness of the remedy, as well as the verification of performance In
addition, this technology would not address the inorganic contaminants at the site
• Soil washing was eliminated because of the large quantity of contaminants that would
have to be treated and the high cost of implementing this technology.
• Soil flushing was eliminated because it would be difficult ,to implement this technology
because of the heterogeneous nature of the landfill, and because of the large volume of
contaminants.
« Solvent extraction was eliminated because it would involve intensive handling of
materials, and it would be difficult to implement based on the large volume of waste
and associated cost of treatment.
• Soil vapor extraction was eliminated because its implementation would require
homogeneous subsurface conditions. If heterogeneous subsurface conditions exist
such as are found in solid waste (landfill) materials at the site, flow channels would be
formed by the injection of the air stream. Flow channels would hinder the
effectiveness of the remedy, as well as the verification of performance. In addition
this technology would not address the inorganic contaminants at the site.
• Dechlorination was eliminated because it would require intensive handling of
materials, and its effectiveness would be limited. Thermal treatment which requires
excavation is not considered feasible or cost-effective given the large volume of waste
material and the potential greater risk to on-site workers and nearby residents
« In situ vitrification was eliminated because it would be difficult to implement because
it is an innovative technology, and because of the heterogeneity of contaminants The
large volume of contaminants and. associated cost of treatment was also a factor in its
elimination.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• None
692
-4-
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of'a standdnd technology?

Overall protection of human health and the environment was weighed jmost heavily in selecting
a standard remedial action for this site. The major exposure pathways} of concern at this site
are the potential for inhalation and ingestion of, and dermal contact with contaminated site
soils. Based on these pathways of concern, the alternatives were evaluated on their ability to
reduce exposure to soils. The selected alternative is protective of human health and the
environment because it eliminates the major exposure pathway by preventing contact with site
soils through the construction of a landfill cover. Short-term effectiveness also was weighted
heavily in selecting the chosen alternative. Community and worker health would be more
difficult to protect under RAA-3 and RAA-4 because of the activity of excavating the
landfilled waste to enable the installation of vertical barriers under these alternatives.
Uncovering waste would increase the potential for exposure to hazardous constituents by direct
contact and inhalation. ; ,

The selected alternative also incorporates the establishment of ACLs, which are site- specific
chemical concentrations for ground water at a site. The State of Michigan has indicated that it
does not agree with the use of ACLs at this site and, therefore does not concur with, the
selected alternative. ,
72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup goals were not established for this site.
' ' v • ' • ' - ". 1 ''•>.'' .' •' •

13. Was the innovative technology eliminated because of the cleanup goa!,s? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

: Standard technologies eliminated because of cleanup goals include:

• ' None i •

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
-5-
693
-------
Proven reliability
16. How are measures compared?

The selected alternative is considered cost-effective because it provides protection from site
risks at the lowest cost compared to all the other alternatives. RAA-3 and RAA-4 are more
expensive than RAA-2, and do not provide any additional reduction in site risks The
selection of a soil cap was influenced by the availability and proven reliability of engineering
expertise and construction practices for capping, and by the availability of equipment for
installation, operation, and maintenance of landfill caps.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not considered primary in selecting a remedy for this
site.
• r
8;
694
-6-
-------
Cannelton Industries

Sault Ste. Marie, Michigan
Region 8
GENERAL SITE INFORMATION
1.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Arsenic 3,600
Barium 10,300
Cadmium 341
Chromium 328,000
Lead 10,100
Mercury 25
PAHs 17

Site History

NPL Proposed: 6/88
NPL Final: 8/30/90
FS:
4/92
ROD: 9/30/92

Background

EPA Fund-lead

PRPs: Cannelton Industries, Inc.
'. Algoma Steel Corporation
FS prepared by: WW Engineering &
Science
. .

Sediment (mg/kg)
< -
Arsenic 29.6
Barium 202
Cadmium 26.1
Chromium 40,000
Lead 603
Mercury 2.3
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 199,700 cubic yards of soil, sediment and waste
. - - I
- . " . \
3. What type of site is this? . - • - >. ,
I '
Food and Kindred Products. A former tannery located in a residential and light industrial area
adjacent to Tannery Bay.
-1-
695
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Physical treatment:
Deed restrictions, fencing
Capping (synthetic membrane, natural soil, clay, asphalt, concrete,
multimedia), slurry wall,, vibrating beam, grout curtain, metallic sheet
piling, clay wall, horizontal barriers
Aeration, in situ soil aeration
Thermal treatment: Incineration (rotary kiln, liquid injection, fluidized bed, infrared)
Disposal:
Excavation, off-site disposal, on-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Slurry degradation, microbial degradation
Phys/Chem treatment: Soil washing, oxidation, in situ soil flushing, enhanced volatilization,
soil vapor extraction
Thermal treatment: In situ vitrification

6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
696
Standard Technology
No action
Excavation/on-siiedisposal/dewatering/
ground water treatment/institutional
controls

'-2-
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria8
$0
$30,200,000
I
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7*

Standard Technology
Excavation/off-site disposal/dewatering/
ground water treatment/institutional •
controls
Excavation/incineration/dewatering/on-
site disposal of ash/ground water
disposal off site/institutional controls
Excavation/incineration/dewatering/
ground water treatment off site/off-site
disposal of ash/institutional controls
Excavation/on-site disposal/ground
water treatment off site/institutional
controls
Excavation/on-site disposal/
dewatering/ground water treatment/
institutional controls/preservation of
on-site wetlands
Estimated Costs
3 Criiteria
N/A '
N/A
N/A
\
N/A
N/A
9 Criteria2
$34,800,000
$49,800,000
$51,500,000
$25,900,000
$19,700,000
t ' ''
*Developed in the ROD and, while similar to RAA-2, this alternative addresses a lesser
volume of soil/sediment/waste since cleanup levels are different (an explanation is provided in
the response to Question 8).
8. If a standard technology was chosen, why? , j
r.
RAA-7 was selected because its implementation will reduce and control potential risks to
human health and the environment posed by exposure to site contaminants by excavating soil
and sediment above human health based cleanup criteria and containing it in an on-site .
landfill. The site risk will be reduced to a level of 10'6 for carcinogens and the Hazard Indices
for noncarcinogens'will be less than one. Removal of .soil/sediment/waste reduces the source
of ground water and surface water contamination. The selected remedy removes a lesser
volume of soil and sediment than other alternatives, but the remaining chemical concentrations
in'the wetlands and sediments have not been shown to be significantly toxic to organisms in
the studies done to date, RAA-7 also protects the environment. The xemedy attempts to
balance wetland preservation and reduction of dredging and potential resuspension of
contaminated sediments with removing contaminant threats from the environment. Removal of
tannery waste from the bay will improve the physical habitat for benl;hic organisms and reduce
the potential for resuspension of exposed waste on the shoreline of TJannery Bay. The long-
term effectiveness of this option is a function of the long-term integrity of the landfill which is
expected to be good if the landfill is well designed and maintained over time. Treatment was
determined to be impractical, and because of the low mobility of the principal contaminants,
containment of the source material was considered to be a safe and reliable option. This
alternative poses no short-rieim risk, meets all ARARs, and is cost-effective. It protects human
health and the environment for the least cost compared to other action options. >
I
-3-
697
-------
The selected remedy was modified in me ROD based on comments and additional information.
Ihe derivation of cleanup standards was changed from ."20 times" the back calculated ground
water concentration to health-based risk based on direct human contact. This change was
made because current ground water and surface water information show that these two media
are only minimally contaminated and currently present no unacceptable risk to human health
The soil/sediment cleanup levels proposed under the chosen alternative, including those to be
derived by additional testing, would protect ground water and surface water, especially when
taking into account the large flow volumes of both the ground water discharge and the St
Mary's River, It is also likely that after cleanup standards are derived and excavation is '
complete, contaminant levels will remain above background. EPA believes that management
of some mplace contamination under RAA-7 is protective of the environment, based on the
relative effects of contaminants left in place compared to the effects of excavation and
dredging activities. The environmental benefits of removing all contamination must be
weighed against the destructive nature of excavation activities that would be required
Leachate studies will be conducted to ensure that the concentrations of contaminants in
leachate are evaluated against health-based standards for the medium with which it interfaces
and its ability to comply with Michigan Act 307. If leachate studies find the contribution of
contaminants from the site soil/sediment to be within the range of the contribution from
background soil/sediment, compliance with the Act will be considered attained "EPA's
opinion is that large-scale destruction of a quality wetland habitat and dredging and possible
resuspension of a large volume of sediments would degrade the environment more than
leaving some elevated levels of chemical contaminants in place and may not be cost effective "
9.
If an innovative technology was chosen, why?

An innovative technology was not selected.
)
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

Slurry degradation was eliminated because it would not remove metals from soil
Enhanced volatilization was eliminated because it would not remove metals from soil
Soil washing was eliminated because treatability studies showed that soil washing had
little effect on the major site contaminants of concern.
Microbial degradation was eliminated because it does not treat metals.
Oxidation was eliminated because it does not treat metals.
In situ soil flushing was eliminated because treatability studies showed that the process
had little effect on the major site contaminants of concern.
Soil vapor extraction was eliminated because it would not be effective for treatment of
metals. .
In situ vitrification was eliminated because it cannot be implemented given the site's
high water table.
698
-4-
-------
Innovative technologies eliminated during the screening of the three criteria include the
following: I
I -
J- •
• ' None , . ' ; . : ' , t
- i

Innovative technologies eliminated during the detailed analysis include the following:
None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting the technology were protection of human health
and the environment, short-term risk, implementability, and cost effectiveness. The chosen
alternative was preferred because it reduces site risk to human health as effectively as other
alternatives but is more protective of the environment since it removes a lesser volume of
soil/sediment in the wetlands. Minimizing the loss of Wetlands reduces the loss of habitat for
numerous birds, mammals, and amphibians that occupy the area. It ppses less short-term risk
due to the release of contaminants during dredging activities. Administratively, on-site
landfilling is easier to implement because a permit for landfill construction would not have to
be obtained from the State. Finally, alternatives that proposed incineration were eliminated
because they would not be cost effective and there was concern that metals would be
mobilized in the resultant ash.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARA»i or Other Basis
Carcinogens
Lead
Cadmium
Arsenic
Carcinogenic PAHs
Chromium VI
400
100 ,
12.8
0.33
23

Risk"
Risk
Elackgroundb

MDLC
. Risk
Noncarcinogens , v
Chromium in
Mercury.
5,300
TBDd

Risk
TBD
Tor health-based risk estimates, an excess upper bound individual lifetime cancer risk
of 10"6 is acceptable for carcinogens and a Hazard Index less than or equal to 1 is
acceptable for noncarcinogens.
-5-
699
-------
"Background concentration was chosen as a cleanup level because the health-based risk
level was below background.
•Method detection limit (MDL) was used as a cleanup level because health-based
levels were below the MDL.
''To be determined. EPA acknowledges that, while potentially compliant with the
rules, the mercury levels at the site might not be protective of surface water; EPA
believes that further assessment is warranted.
13.
14.
15.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: x

• None .

Standard technologies eliminated because of cleanup goals include:

" None

Were treatability studies conducted on the innovative technology or standard technology?

In preparation for the FS, two bench-scale treatability studies were conducted on site
soil/sediment to evaluate stabilization and soil flushing as potential technologies for treating
contaminants at the site.

Wfiat measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Cost effectiveness
1
16. How are measures compared? .

RAA-7 was selected because it reduces risk to health-based cleanup levels at the least cost and
is therefore the cost-effective option. Further, RAA-7 was selected because it will provide the
appropriate balance between short-term and long-term risks.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
F

One technical consideration that was primary=in selecting a remedial alternative was the
destruction of wetlands. The chosen alternative was preferred because it would cause less
destruction of wetlands and preserve natural habitat better than all the other alternatives. It
was determined by EPA that lessening cleanup levels and decreasing excavation volumes was
appropriate and protective. " .
700
-6-
"I1"'
"If,
-------
1
The high water table was another technical consideration, but was not primary in selecting a
remedial alternative. The high water table caused the elimination of in situ vitrification.
-7-
701
-------
Carter Industrials, Inc.

Detroit, Michigan
RegionS
f
1
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:

Soil/Debris (mg/kg)

PCBs - 12,000
Arsenic 5
Lead 28,000
Cadmium 34
1,3-Dichlorobenzene 180
1,4-Dichlorobenzene 3
Xylene 25
Chlorobenzene 36
Benzo(a)anthracene 5
Pyrene 11
1,2,4-TrichIorobenzene 11 ,
Pentachlorobenzene 700
Tetrachlorobenzene 1,600
1-Ethyl, 2-methylbenzene 1
Copper 17,000
Zinc 8,500
IT"
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/24/88
3/31/89
4/19/91
9/18/91
Background

EPA Fund-lead
PRPs: Carter Industrials, Inc., Spector-
Carter Metal
FS prepared by: B&V Waste Science
& Technology
What volume of material is to be remediated?

The volume of material to be remediated included:

• 46,000 cubic yards of contaminated soil and debris

What type of site is this?

Recycling. A former scrap metal storage and salvage operation in an urban setting: The
surrounding land use is mixed residential and light industrial. ,
702
-i-
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?
i
The FS for this site supplements a 1986 Engineering Evaluation/Cost .Analysis prepared for
EPA in which a number of technologies were developed for consideration and screened. No
initial screening is conducted in the FS. Standard technologies incorpprat<;d into RAAs were:
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:

Disposal:
Institutional controls, site access restrictions
Multilayer cap • , : '.
Pozzolonic solidification, quicklime treatment
On-site rotary kiln incinerator, Shirco Infrared System, circulating bed
combuster, advanced electric reactor, off-site JSCA incinerator
Excavation, on-site and off-site RCRA landfill! off-site TSCA landfill
.• _ -h ' .
5. Was an innovative technology considered in the FS? If so, which technology?

The FS for this site supplements a 1986 Engineering Evaluation/Cost .Analysis prepared for
EPA in which a number of technologies were developed for consideration and screened. No
initial screening is conducted in the FS. Innovative technologies incoijporated into RAAs
were: ! . .
Chemical treatment:
Thermal treatment:
Critical fluid (CF) extraction, on-site solvent e|xtra.ction
In situ vitrification, low-temperature thermal djesoirption (LTTD)
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)

Soil/Debris , !
Alternative
RAA-3
RAA-9 or
Hybrid Alt.2
Innovative Technology
In situ vitrification
In situ vitrification/off-site RCRA
landfill
Estimated Costs
3 Criteria
NyJA
N;JA
9 Criteria
$23,461,000
$20,544,000
-2-
703
-------
Alternative
RAA-12 or
Hybrid Alt.5
RAA-13 or
Hybrid Alt.6
RAA-14 or
Hybrid Alt?
•
Innovative Technology
Critical fluid extraction/incineration of
residual PCB oils/off-site TSCA
landfill/off-site RCRA landfill
Solvent extraction/off-site incineration
of residual PCB oils/off-site TSCA
landfill/off-site RCRA landfill
Low-temperature thermal desorption
with incineration of residual PCB
oils/off-site TSCA landfill/off-site
RCRA landfill
=====^====
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$49,402,000
$20,542,000
$18,052,000
($19,508,000")
J)
'Present worth value given in the ROD.
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Soil/Debris
Alternative
RAA-1
RAA-2
RAA-4
RAA-5
RAA-6
RAA-7
Standard Technology
No action/continued operation and
maintenance of in-place stabilization
measures
On-site incineration:
Rotary kiln
f
Infrared
Circulating bed
Pozzoloriic solidification
On-site RCRA landfill
On-site capping
Off-site TSCA landfill
==================
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
N/A
-• N/A .
9 Criteria
$246,000
$40,864 to
$55,599
$25,030 to
$39,763
$13,107 to
$27,841
$3,913,000
($4,734,141)a
$4,167,000
$1,647,000
($l,856,000)a
$22,804,000
704
-3-
-------
8.
Alternative
RAA-8 or
Hybrid Alt.l
RAA-10 or
Hybrid Alt.3
RAA-11 or
Hybrid Alt.4
RAA-15 or
Hybrid Alt.8
Standard Technology
Off-site TSCA incinerator/off-site ,
TSCA landfill/off-site RCRA landfill ,'
Off-site TSCA incinerator/off-site
TSCA landfill/off-site RCRA landfill
Off-site TSCA incinerator/off-site
TSCA landfiWoff-site RCRA landfill
Quicklime treatment
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$50,308,000
$100,719,000
$51,797,000
$3,662,000
The present value given in the ROD.

If a standard technology was chosen, why?

A standard technology was not chosen.,
9. If an innovative technology was chosen, why?

The selected alternative is a slight modification of RAA-14 by incdrpc|ratmg the construction
of an on-site containment cell. The selected alternative was chosen because:

• LTTD achieves substantial risk reduction through treatment of|the site's principal
threat: PCBs. PCBs would be concentrated into a small volume iind incinerated. Any
contaminated residual material or contaminated material that cannot be treated would
be contained on site.

• It involves much less off-site transport of waste materials, thereby lowering short- term
risks from potential accidents and increased handling requireirentii.

• It meets all ARARs except for a Michigan Solid Waste Management Rule specifying
isolation distances for sanitary landfills. This requirement willjbe waived pursuant to
CERCLA Section 121(d)(4)(D) which allows the agency to select a remedy that does
not meet an ARAR but attains a standard of performance equivalent to that required
under the otherwise applicable standard, through use of another method or approach.
The selected alternative will attain the required equivalent standard of performance.
\
• It permanently destroys PCBs segregated from soils. ,

• It uses an innovative technology that has undergone engineering scale testing to verify
its effectiveness at the site and to facilitate the remedial design.

• It achieves the required risk reduction more completely than suiy other on-site
treatment option except in situ vitrification and at substantially less cost than the off-
site treatment options. ',,''..
-4r
705
-------
During the public comment period, the PRPs submitted a justification for a Type C cleanup
under Michigan Act 307 to the state. This justification was accompanied by a proposal to
modify the original Proposed Plan (PP). Some elements of the PRPs' proposal were
incorporated into the selected alternative, The two key components of the original PP that
were modified are: (1) the original requirement of off-site landfilling of TCLP toxic material
and the contaminated soils; and (2) treatment using LTTD of soil contaminated with PCBs at
levels over 1 mg/kg. While it had not been demonstrated that the required cleanup level of 1
rng/kg could be achieved, information suggests that PCB levels could be reduced to less than
10 mg/kg. In addition, EPA and the State of Michigan found that the modified alternative
involves much less off-site transport of materials and is a protective and cost-effective remedy
10.
11.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

" None

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• In situ vitrification was eliminated because of its limited availability since only one
hazardous waste contractor markets the technology. This technology would not be as
readily compatible with possible future remediation as remedies that permanently
remove the contaminated material from the site. In addition, this technology would
take longer to implement (25 months) than the chosen alternative (12 months)
• Critical fluid extraction was eliminated because it would take the longest amount of
time to complete and it may be difficult to implement in cold weather Also this
technology would generate large volumes of solids requiring on-site disposal'and
would not be as cost-effective as the chosen alternative..
• Solvent extraction was eliminated because it could result in short-term risk from toxic
air emissions. Air emission controls and air monitoring would be required.

Overall protection of human health and the environment, compliance with ARARs, long-term
effectiveness and permanence, and cost-effectiveness were weighted most heavily The chosen
innovative technology achieves the required risk reduction more completely than any other on
sue treatment options (except for in situ vitrification) and at substantially less cost than other,
706
-5-
-------
off-site treatment options. It meets all ARARs except for a Michigan Solid Waste
Management Rule that specifies isolation distances for sanitary landfills. An ARAR waiver
will be invoked Once the threshold criteria of protection of human health and the
environment and ARARs compliance were satisfied, long-term effectiveness was used in
remedy selection. | •
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level
ARAR or Other Basis
Cnrrinngens
PCBs
Lead
Cadmium
Arsenic .
Benzo(a)anthrazene
1 mg/kg
100 jig/kg
80 ug/kg
50 ug/kg
330 ug/kg
EPA8
Michigan Act 307b
Michigan: Act 307b
MIOL0
MDLC
Nonrnrrinngens ,_ ^.
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
Xylene
Chlorobenzene
Pyrene
1,2,4-
Trichlorobenzene
Pentachlorobenzene
Tetrachlorobenzene
1 -Ethyl, 2-methyl
benzene
10,000 ug/kg
20 Mg/kg
6,000 ug/kg
2,000 ug/kg
4,000 ug/kg
200 ug/kg • • ;
100 ug/kg
40 ug/kg
MDLd
Michigan Act 307b
Michigan Act 307"
Michigan .Act 307"
Michigan Act 307b
Michigan Act 307b
Michigan Act 307"
Michigan Act 307b
Michigan Act 307"
MDLC
aU.S. EPA's Guidance on Remedial Actions for Superfund .Siftes with PCB
Contamination, 1989. '.'•.[. '' \ . -
"Michigan Act 307, Type B cleanup achieved levels that protect ground water from the
migration of soil contaminants into the ground water; protects against unacceptable
human health risks due to direct contact; and protects surface waiter quality.
'Michigan Department of Natural Resources acceptable Method Detection Limit
(MDL) was used rather than the level based on carcinogenic! risk.
dNo specific cleanup level for this contaminant was given in the ROD.
-6-
707
-------
13.
For carcinogens, an excess upper bound individual lifetime cancer risk of between 1Q-4 to \n*
was acceptable. For noncarcinogens, a Hazard Index less than or e^ua. t^Twas acceptaWe.

Innovative technologies eliminated because of cleanup goals include:
" None .

Standard technologies eliminated because of cleanup goals include:
" None '
14. Were treatability studies conducted on the
15.
innovative technology or standard technology?
to <* FS °r «

ion to demonstrate that a cleanup level of 1 mg/kg coul be reachd

What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives-

Risk level achieved
Single vs. multistep treatment
Cost effectiveness
Proven reliability
Preference for treatment (vs. containment)
Impact on nearby populations
16. How are measures compared?

Of the 15 alternatives considered, those involving thermal destruction of PCB contaminated
matenal and secure containment of TCLP toxic material were considered to offer tt^S

to a muhn ,agr 6XTg S1? ^^^ The diversity of the waste materials readily lem self
L,7 H T gy m °f remediation' •"» hybrid RAAs were developed to combine
of w± ±° gl6S T remedial altematives ** addressed the various types andTantities
of wastes at the site and provide for cost effective treatment of the contaminated soils to the
maximum extent possible. Four alternatives were considered most cost-efTtte^1-2 RAA
70S
)
-7-
-------
9, RAA-13, and RAA-14. The chosen alternative utilized an innovative treatment technology
that had proven reliability because it had undergone engineering scale testing to verify its
effectiveness at the site. Treatment was preferred because it would ensure the greatest degree
of long-term effectiveness and permanence. RAA-14 resulted in permanent destruction of
PCBs. RAA-13 was eliminated because it posed short-term risk to sitip workers and off-site
populations. , [

i
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the femedy? j

Technical considerations were not primary in selecting a remedy for ihis site.
-8-
709
-------
Si.
Central Illinois Public Service Company
Taylorville, DUnois
Region 5
GENERAL SITE INFQRTvTATTDKr
_ What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

Xylene

Sediments (mg/kg)

Fluoranthene
Dibenzo(a,h)anthracene
0.005
1.57
1.489
Polyaromatic hydrocarbons 2.6
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1/13/88
8/28/90
5/91 '
9/30/92
. Background

PRP-lead
PRPs: Central Illinois Public Service
Company
FS prepared by: John Mathes &
Associates
2. What volume of material is to be remediated?

The volume of material to be remediated included: '
v
• 12,000 cubic yards of soil and sediment

3. Wtiat type of site is this? • .

Coal Products. A former gas production facility located in a residential area. !

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: '

Access restriction: Land use restrictions
Containment: Capping, grading, revegetation
Thermal treatment: Incineration
Disposal: Excavation (complete, partial), disposal (on-site, off-site)
710
-i-
-------
The chosen alternative includes a permanent remedy to address the residual contamination in
ground water and thereby addresses the remaining principal threat posed by ground water
through an active ground water pump-and-treatment program. This remedy provides a
permanent and long-term solution. It is easily implemented and meets all ARARs.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
.. technology eliminated? !
'i
'!
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation, In this case, a
three-criteria screening was conducted for both individual technologies and specific
alternatives.
Innovative technologies eliminated during the initial screening include
the following:
None
Innovative technologies eliminated during the screening of the three criteria of technologies
include the following:

• None

Innovative technologies eliminated during the detailed analysis include; the following:

• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria most heavily weighted in selecting a remedial alternative were protection of
-human health and the environment and long-term effectiveness. The selected remedy was the
most protective option since it addressed both soil/sediment and ground water. Further, it
addressed the residual risk associated with ground water with a permanent remedy.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels for soil/sediment were not established. ,
-4-
713
-------
75. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Preference for treatment (vs. containment)
Waste left in place/institutional control

16. How are measures compared?

RAA-5 was preferred because it provides the most protective and permanent remedy since it
actively addresses the residual risk associated with ground water treatment. RAA-3 was not
preferred because it would have utilized institutional controls to address residual risk
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedial alternative.
714
-5-
-------
Chem Central
(Chem Central/Grand Rapids Corporation;*

Wyoming, Michigan ,. ,|,
Region 5
GENERAL SITE INFORMATION

1. . What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

1,1-Dichloroethylene 0.02
Trichlofoethylene 0.22
Tetrachloroethylene 81
Bis(2-ethylhexyl)phthalate 57
PCB 0.32
Toluene 15
Arsenic 4.3
Zinc 66 :.
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
12/82
7/87
5/91
9/30/91
Background
. I .
PRP-lead
PRPs: Chem Central
FS prepared by: WW Engineering and
Science
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 6,200 cubic yards of contaminated soil
3. What type of site is this?

Chemicals and Allied Products. A chemical distribution plant.
TECHNOLOGY SELECTION

•• ' ' ' ' I '
4. . . What standard technologies were considered for selection in this FS?,

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Disposal:
Deed restrictions, fencing
Soil cap, sheet piling .
On-site excavation, disposal at a RCRA facility
-1-
715
-------
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: •

Biological treatment: Enhanced biodegradation, bioreclamation
Chemical treatment: Soil flushing (surfactant)
Physical treatment: In situ soil vapor extraction
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the fonnulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated first during an evaluation based
on nme criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment-
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support '
agency acceptance; and community acceptance. The costs were recalculated in the ROD.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
7.
Alternative

RAA-2
RAA-3
RAA-4
Innovative Technology
In situ soil vapor extraction
In situ soil vapor extraction/soil
flushing

In situ soil vapor extraction/
bioreclamation
Estimated Costs
9 Criteria
$170,000

$450,000
$620,000
ROD
$182,400

$450,000
$620,000
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-5
RAA-6
Standard Technology
No action/deed restrictions/ground water
monitoring
Soil cap/ground water monitoring
Fencing/ground water monitoring
.
Estimated Costs
9 Criteria
$410,000
$54,000
$31,000
b -2-
ROD
$410,000 .
$54,000 -
$31,000

-------
Alternative
RAA-7
RAA-8
Standard technology
Soil cap/fencing/ground water
monitoring
Excavation of on-site soils/disposal off
site in a Class n landfill8
lEsttmated Costs
9 Criteria
$85,000
$560,000
ROD
$85,000
$560,000
"If the soil must be managed as a hazardous waste, the estimated cost will be $13,000,000.

• , i. " • •
. - • ^ \ '
8. If a standard technology was chosen, why? ' > !| ' -

A standard technology was not chosen.

9. If an innovative technology was chosen, why?

The technology selected was in situ Soil Vapor Extraction. The remedy was selected for, the
because: 1) it reduces migration potential of contaminants to surface drainage, 2) migration of
contaminants from soil to ground water will be reduced, 3) proven technology for VOCs in
unsaturated soils, 4) easy to implement, 5) cost, 6) avoids removal and replacement of railroad
track which would disrupt operations at this still active site, 7) excavation at the site would be
difficult because of buildings which would require sheet piling along Buildings to protect
foundations from collapse, 8) won't mobilize residual contaminants.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '

Innovative technologies eliminated during the initial screening include the following:

. • None • ' • . • ' ! '

Innovative technologies eliminated during the screening of the three (criteria include the
following:

• None !j
I
Innovative technologies eliminated during the detailed analysis include the following:
I
1 J ' ' .
• Soil flushing was eliminated because it would be too costly Jind difficult to implement.
• Bioremediation (biodegradation and bioreclamation) was eliminated for the same
reasons as soil flushing. ,
-3-
717
-------
12.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Cost-effectiveness and ease of implementation were weighted most heavily in selecting a
technology. In addition to meeting all the criteria, the chosen innovative technology is more
cost-effective and the easier to implement than the other technologies.
D Were selected? Vthe clea™P goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (rag/kg)* | ARAR or Other Basis
Carcinogens
1 , 1 -Dichloroethylene
Trichloroethylene
Tetrachloroethylene
Bis(2-ethylhexyl)
phthalate
PCB
Arsenic
0.001
0.064
0.014
0.05
0.0004
6.0004C
Michigan Act 307b
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Noncarcinogens
Toluene
Zinc
,,,,
0.8C
28C
**"" -' ""!!!•!". ' -»— — —
Michigan Act 307
Michigan Act 307
~ '
•Soil cleanup levels were established to protect ground water from leaching soil
contaminants. Cleanup levels were set at twenty (20) times the ground water cleanup
level for each chemical. v
Remedial action cleanup standards were based on Michigan Environmental Response
Act 307, Type B cleanup criteria. Cleanup levels developed by Type B criteria are
health-based and reduce risk to less than 10"6. •
TTiis value is based on a Chronic Oral Reference Dose.
*
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None , •

1 Standard technologies eliminated because of cleanup goals include:

• Capping
718
-4-
-------
14. Were treatability studies conducted on the innovative technology or standard technology?
: . - ' , i
No treatability studies were conducted. Treatability studies might be conducted, however,
during the operation of the soil vapor extraction system to determine if semivolatile
compounds are reduced to below the soil cleanup levels. •••"•..

75. What measures/criteria were used to compare alternatives? !

The following measures were used to compare the alternatives: ': • .

Total Cost
Preference for treatment (vs. containment)
Proven reliability

16. How are measures compared? ;

The chosen alternative reflects a preference for treatment over containment. Alternatives that
• utilized source treatment technologies were considered superior because they would reduce
contaminant toxicity, mobility, and volume. The selected alternative was considered a proven
technology for the site contaminants and unsaturated soils. Alternatives that proposed
containment technologies were eliminated because they would not prevent future ground water
contamination and would require long-term maintenance. While all the alternatives that
offered source treatment would be equally protective, the selected alternative is the most cost-
effective./ •' •• ,' - • .'• ..'"',. 5'/' '
'--•-•• ' • • . - ''
17.- What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
, • - • '- ••'*•':''. '..•'-
Two alternatives, RAA-3 and RAA-4, required removing a railroad line running onto Chem
Central's property, which would interrupt the company's business for a short time period. In
addition, it would dramatically increase the cost and time needed to implement these remedies.
This site characteristic was not primary, however, in the selection of a remedy.
-5-
719
-------
City Disposal Corporation Landfill
Dunn, Wisconsin
Region 5
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Acetone 20.25
Methylene chloride 0.082
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

" 700,000 cubic yards of landfill waste
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/9/81
9/21/84
3/24/92
9/28/92
Background

PRP-lead
PRPs: Waste Management of
Wisconsin, Inc., Sara Lee
Corporation, Garber Industries,
Inc., Inland Container Corp;,
Ohmeda, Sub-Zero Freezer Co.,
and Webcrafters, Inc.
FS prepared by: P. E. LaMoreaux and
Associates, Inc.
3. What type of site is this?

Municipal Landfill. A former landfill located in a predominantly agricultural area.

TECHNOLOGY SELECTION ,

4. Wliat standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restrictions: Fencing, deed restrictions
Containment: Capping (synthetic membrane, clay, composite clay/synthetic)
Chemical treatment: Stabilization/solidification
Physical treatment: Landfill gas collection system, leachate collection system
Thermal treatment: Incineration
Disposal: Excavation, on-site disposal, off-site disposal
720
-i-
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: !

Biological treatment: In situ bioremediation , .
Chemical treatment: Soil flushing (solvent) i
Physical treatment: Gas injection/gas extraction, in situ vapor extraction, vacuum heap
extraction i
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case the estimated costs were calculated during an evaluation based on nine
criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementabiliity; cost; state/support
agency acceptance; and community acceptance.
'- - 1 . '
The RAA designations changed in the Proposed Plan and ROD from the Feasibility Study and
are presented parenthetically.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-5
(RAA-2)
RAA-6
(RAA-3)
RAA-7
(RAA-4)
Innovative Technology
Fencing/deed restrictions/synthetic
cap/landfill gas extraction/in situ vapor
extraction (cells 6 and 12)a/ground
water monitoring
Fencing/deed restrictions/composite
cap/landfill gas extraction/in situ
vapor extraction (cells 6 and
12)/ground water monitoring
Fencing/deed restrictions/clay
cap/landfill gas extraction/in situ vapor
extraction (cells 6 and 12)/ground water
monitoring
Estimated Costs
3 Criteria
N/A
'i -
N/A
1, • •
1
k/A .
9 Criteria
$3,905,200
$3,925,000
$3,617,000
"Cells 6 and 12 were the landfill compartments where industrial waste was placed.
-2-
721
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4

Standard Technology
No action/landfill gas extraction
Fencing/deed restrictions/synthetic
cap/ground water monitoring/landfill
gas extraction
Fencing/deed restrictions/clay
cap/ground water monitoring/landfill
gas extraction
Fencing/deed restrictions/composite
cap/ground water monitoring/ landfill
gas control system
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
t
— ^
9 Criteria
$587,000
eliminated
eliminated
eliminated
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9, If an innovative technology was chosen, why?

RAA-6 (RAA-3) was selected because it is the most protective of human health and the
environment since it prevents direct contact with site contaminants. Compared to the other
alternatives, RAA-6 is cost-effective, providing the best overall protectiveness proportional to
its costs. , . • . . -

Source control will be achieved by covering the landfill wastes, thereby minimizing leachate
production and contamination of ground water. The proposed cap's design and construction
have been proved effective and implementable. The landfill cover complies with state
requirements for closure of landfills containing solid and hazardous waste (NR 504 7
Wisconsin Administrative Code), RAA-6 was the only alternative to propose a cap that
complies with hazardous waste landfill cover requirements. Landfill gas control minimizes
risks posed by landfill-generated gases.

Source removal will be accomplished through in situ vapor extraction, which will permanently
and significantly reduce the volume and toxicity of VOCs in the landfill. The in situ vapor
extraction and treatment system, which have been proved effective at other sites, will remove
VOCs from the waste and reduce site risks to within an acceptable risk range of 10"4 to 10'6.
722
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology election process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ bioremediation was not incorporated into a remedial alternative but no
explanation is given for its elimination.
« Soil flushing was not incorporated1 into a remedial alternative but no explanation is
given for its elimination. ;
• Vacuum heap extraction was not incorporated into a remedial a|lteraativ& but no
.explanation is given for its elimination.
• Gas injection/gas extraction was not incorporated into a remedial alternative but no
explanation is given for its elimination.

Innovative technologies eliminated during the screening of the three criteria include the
following:"

• None i

Innovative technologies eliminated during the detailed analysis include the following:
i i
I
: • None . ,'•.'; ''.''•

11. • Which of the nine criteriaTwere weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criterion that was weighted most heavily in selecting a remedial alternative was
compliance with ARARs. Only the chosen alternative complies with source control state
ARARs for closure of the site. Source control alternatives that did not comply with ARARs
were eliminated. , , j!

No innovative technologies were eliminated due to this criterion.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was. that
ARAR? What risk, level was selected to establish cleanup goals? |

No soil cleanup levels were established. .}••',
-4-
723
-------
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14.
Were treatability studies conducted on the innovative technology or standard technology?

A treatability study of the biodegradation of site contaminants was conducted. Contaminants
currently found at the site were found to be biodegradable.
15.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Compliance with ARARs
Risk reduction
Total cost
16. How are measures compared?

All the source control alternatives proposed capping and in situ vapor extraction The
alternatives were distinguished by the type of cap proposed. The chosen alternative was
preferred because it complies with.all ARARs for hazardous waste landfills. The caps
proposed in the other alternatives would comply only with solid waste requirements The cap
proposed m RAA-5 would have been more protective of ground water since it would provide a
99-percent reduction in exfiltrate from the waste, compared to the chosen alternative's 80-
percent reduction in exfiltrate. RAA-5 also would have cost less and posed less short-term
nsk since it would have required fewer track trips than the chosen alternative. The chosen
alternative, however, was preferred because it was the only alternative that satisfies all
AJKAJRs. . - -
77.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy.
724
-5-
-------
Clare Water Supply
OU-2

Clare, Michigan
Region 5
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
Background

PRP-lead ' -
PRPs: Colt Industries (now Coltec), Ex-
Cello Corporation, Ransburg
Corporation,, and United
Technologies Automotive
FS prepared by: Djimes and Moore
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediments (rag/kg)

Benzene , 0.027
1,1,2-Trichloroethane 0.056
Trichloroethene 1,100
Tetrachloroethene 40
Methylene chloride 6
1,2-Dichloroethane 0.019
Xylenes (total) 120
Ethylbenzene 26
1,1,1-Trichloroethane 510
Trans-1,2-Dichloroethene 350
Styrene ' 0.015
2. What volume of material is to be remediated?

The volume of material to be remediated included:

, • 54,800 cubic yards of soil

3. What type of site is this?

Uncontrolled Waste Site. A public water supply located on the former
industrial manufacturers and fuel storage companies.

TECHNOLOGY SELECTION • ;

4. What standard technologies were considered for selection in this FS?
11/82
9/21/84
5/92
9/16/92
Standard technologies considered during the identification and
technologies were:
-1-
site of several
screening of technically feasible
725
-------
Access restriction:
Containment:

Chemical treatment:
Physical treatment:
Thermal treatment:

Disposal:
Fencing, deed restrictions
Capping (clay, soil, asphalt, concrete, synthetic, and multimedia)
slurry wall, sheet piles, drainage ditch
Stabilization/fixation, c 'crnical reaction
Drying beds, mechanical filtration
Incineration (rotary kiln, multiple hearth, fluidized bed, infrared
plasma arc) '
Excavation, off-site disposal at a RCRA landfill, off-site disposal at a
sanitary landfill, on-site disposal in a RCRA landfill, on-site disposal
in a sanitary landfill . •
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
reasible technologies were:

Biological treatment: Biodegradation (In situ), composting, bioharvesting
Physical treatment: In situ soil washing (aqueous)
Chemical treatment: In situ vapor extraction; solvent extraction, chemical reaction
(oxidation)
Thermal treatment: Thermal volatilization, in situ vitrification, molten salt
6.
was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified

oZla^d6 T ati°n 'T^' ^ FS d°eS n0t quantify COSts' After"*e RAAs have teen
formulated, costs are typically estimated as part of a three-criteria screening process
^S^'p' imP.Iementa™itv> and cost) to identify alternatives that merit a more detailed
evaluation. For djis site the estimated costs were calculated during an evaluation based on the
nine cntena established by the NCP. Estimated costs are recalculated in the ROD.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4A
RAA-5B
Innovative Technology

In situ soil vapor extraction/fencing/
deed restrictions/ditch rerouting
UV photochemical oxidation/shallow
injection wells/fencing/deed
restrictions/ditch rerouting/ground
water monitoring
Estimated Costs
9 Criteria
•^—• n-
$20,467,000
$11,374,000
ROD
•—»^^»^

$20,467,000
$11,374,000
726
-2-
-------
7. ' How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Alternative
RAA-1
RAA-2
RAA-3
RAA-4B ,
RAA-5A

Standard Technology
No action/ground and surface water
monitoring
Fencing/deed restrictions/ditch rerouting
Same as RAA-2, plus a multimedia cap
Excavation/sheet piling/carbon
adsorption/off-site incineration and
disposal/deed restrictions/ditch rerouting
Ground water collection/air stripping/
carbon adsorption/shallow well
reinjection/fencing/deed restrictions/
ditch rerouting/ground water monitoring
Estimate*
9 Criteria
$2,886,000
$3,562,000
$4,291,000
$85,760,000
$23,616,1300
J Costs
ROD
$2,886,000
$3,562,000
$4,291,000
$85,760,000
$23,616,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
If an innovative technology was chosen, why?

RAA-4A was chosen for the remediation of the contaminated soil area because, in addition to
fulfilling all of the nine criteria, it was the most effective means of reducing toxicity, mobility,
and volume of soil contaminants. It would reduce residual risk from exposure to soil and
sediment through treatment. It could ultimately eliminate the need for long-term enforcement
of institutional controls and provide a site-wide remedy that is effective in the long term. I
can be performed on soils located under buildings. It could enhance aerobic bacterial
degradation of VOCs that may be occurring^ It is.a demonstrated technology, with adequate
equipment and specialists available. It is more cost-effective than off-site treatment and
disposal. It satisfies the statutory preference for treatment. RAA-1, RAA-2, and RAA-3 were
eliminated because they would not include any treatment technologies arid thus would not
significantly reduce the risk to human health and environment. RAA-4E. (off-site treatment
and disposal) was eliminated because it would not be as effective in reducing the toxicity and
volume of soil contaminants as RAA-4A. RAA-4B would require eiccavation, which would be
infeasible for the 15,000 cubic yards of contaminated site soil that is under buildings. In
addition, the cost of RAA-4B would be prohibitive. RAA-5B also was chosen to complement
RAA-4A by treating ground water. While RAA-5A and RAA-5B both provide plans for
ground water remediation, RAA-5B was chosen because it is more cost-effective.
-3-
727
-------
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ,

Innovative technologies eliminated during the initial screening include the following:

« Composting was eliminated because it would not be applicable.
• Molten salt reaction was eliminated because it has not been proved effective on a large
scale for a wide variety of contaminants and no commercial units are available
• Bioharvesting was eliminated because not all site contaminants will bioaccumulate
« Solvent extraction was eliminated because it could introduce additional contaminants to
the site. It would not be applicable.
" Chemical reaction (oxidation) was eliminated because precipitation of iron and
manganese oxides and hydroxides could clog delivery system and reduce soil
permeability.
" Thermal volatilization (in situ and ex situ) was eliminated due to the difficulty in
preventing uncontrolled releases of volatiles to the atmosphere and because it is only
effective for volatiles. Few full-scale operations have been completed; and capital and
O&M costs are high. ,
» In situ vitrification was eliminated because there are few full-scale operations and it
would limit future site use. Capital costs are high and O&M costs are very high
• Biodegradation (in situ) was not included in any RAA and no specific explanation was
given. Clay soils at some parts of the site may decrease its effectiveness. Difficulty
in monitoring effectiveness may affect its implementability.
» Soil washing (in situ) was eliminated because it was not considered necessary within
the remaining process options. The permeability of the soil may be reduced.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• None
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology? ' :

Protection of human health and the environment; ability to reduce toxicity, mobility and
volume of soil contaminants; and cost-effectiveness were weighed most heavily in the selection
of an innovative technology.
728
-4-
-------
12. What cleanup goals were selected? If the cleanup goal was based on
ARAR? What risk level was selected to establish cleanup goals?
Soil/Sediments
an ARAR, what was that
Contaminant
Cleanup Level (ug/kg)
ARAR or Other Basis
Carcinogens
Benzene
1 , 1 ,2-Trichloroethane
Trichloroethene
Tetrachloroethene
Methylene Chloride
1 ,2-Dichloroethane
Vinyl Chloride
20
12
60
14
100
. 8
0.4
i '
Noncarcinogens
Xylenes (total)
Ethylbenzene
Trans-1,2-
Dichloroethene
1 , 1 , 1 -Trichloroethane
Cis 1,2-
Dichloroethene
Styrene
6,000
1,400
2,000
4,000
'1,400
20
Michigan Act 307s
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
! MDLb
j MDL
'!"'-, "
Michigan Act 307
Michigain Act 307
Michigain Act 307
;!
Michigiin Act 307
Michigan Act 307
1
Michigan Act 307
"Soil cleanup levels are 20 times the Michigan Act 307 Type B ground water criteria.
•"Michigan Department of Natural Resources' acceptable Method Detection Levels in
soil.
••'.'" • . i"
EPA has determined thatcleanup to this level achieves an aggregate risk level for carcinogens
of 7 x 10-6. . . i
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
• : ' . , ,u .
Innovative technologies eliminated because of cleanup goals include:

• None - ' ,
729
-5-
-------
Standard technologies eliminated because of cleanup goals include:

• Capping
14.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were proposed to evaluate the implementability and effectiveness of soil
vapor extraction. According to the FS, a pilot study on contaminated soil should be conducted
to assess the effectiveness of removing the contaminants and to determine the spacing of vapor
extraction wells needed to remediate the soil in a cost-effective manner.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Time to design/construct/operate
Proven reliability
Single vs. multistep treatment
Preference for treatment (vs. containment)
Impact on nearby populations

16. How are measures compared?

Since the Clare Water Supply site is the only feasible source of drinking water for the 3 300
residents of Clare, Michigan, the complete and expedient remediation of contaminated soils is
important. The selected remedy, soil vapor extraction, satisfies the remedial action goals and
achieves acceptable risk levels for all soil contaminants. Combined with a ground water
treatment system, it is the most cost-effective remedy and requires the least time to design
construct, and achieve remedial action goals. Soil vapor extraction has proven to be a reliable
technology and, unlike other alternatives, requires no long-term management after completion
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were primary in selecting a remedy. Because more than 15 000 cubic
yards of the contaminated soil is located beneath buildings on the site, soil vapor extraction
was preferred over excavation and disposal. '
730
-6-
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Dakhue Sanitary Landfill
OU-1

Hampton Township, Dakota County, Minnesota
, Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Soil

No soil samples from the landfill were
collected arid analyzed. Volatile organic
compounds (VOCs) were found in
monitoring wells downgradient from the
landfill. Leaching from the landfill was
identified as the most likely mechanism for
release of contaminants. The prevention of
leaching was the focus of the FS.
Site History
NPL Proposed:
NFL Final:
FS:
ROD:
10/26/89
8/30/90
3/91
6/28/91
Background ..

EPA Fund-lead
PRPs: Dakhue Sanitary Landfill, Inc.
FS prepared by: U.S- Environmental
Protection Agency, Region 5
2. What volume of material is. to be
remediated?

The volume of material to be remediated included:

• 1,500,000 cubic yards of soil

3. What type of site is this? "'.'''.'

Municipal Landfill. Former landfill for the disposal of mixed municipal and commercial
' waste. It also accepted small amounts of industrial waste.
TECHNOLOGY SELECTION ' •; ' '

4. '' What standard technologies were considered for selection in this FS? ^
\
Standard technologies considered during the identification and screening of technically feasible
technologies were:

Containment: Capping (clay, synthetic membrane, bentonite,, bentonite/soil admixture,
cement and cement/soil admixtures, lime sludge and lime sludge/soil
admixtures, asphalt, and sand), encapsulation
Thermal treatment: Incineration « j
731
-------
Disposal:
5.
6.
7.
Excavation and off-site disposal, excavation and on-site reburial in a
RCRA landfill
Was an innovative technology considered in the FS? If so, which technology?

No innovative treatment technologies were considered because contaminant hot
found and because of the volume and characteristics of the waste present.
What was the cost estimate for the innovative technology?

No innovative technologies were considered.

How did the cost(s) compare to standard technologies?
rinr *? tial T6611111! ErOCeSS' ln Which technica»y feeble technologies are identified
(pnor to the formulation of RAAs), the FS does not quantify costs. After foe RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening proceT

altematives '** merit a more detailed
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1

RAA-2
RAA-3
RAA-4
Standard Technology

No action

Cover system with a clay barrier layer
that meets the Minnesota Rules for
Mixed Municipal Waste landfill covers

Cover system with a clay barrier
layer that meets the Minnesota Rules
for Mixed Municipal Waste landfill
covers, frost protection
• — : _
RCRA cover system for hazardous
waste closure
Estimated Costs
3 Criteria
M^HHVK
$0

$7,800,000

——————
$9,800,000

$13,000,000
9 Criteria
^••^MM

$7,800,000

•••'

$9,800,000

~————™
$13,000,000
8. If a standard technology was chosen, why?

RAA-3 was chosen because it protects public health and the environment, is the most cost-
effecuve alternative, and provides adequate long-term effectiveness because of the frost
protection component. RAA-1 would not adequately protect human health and the
environment. RAA-2 would not provide adequate long-term effectiveness because of the lack
732
III
-2-
-------
of frost protection. RAA-4 would provide adequate long-term effectiveness, but would not be
as cost-effective as RAA-3. i
9. If an innovative technology was chosen, why?

No innovative technology was considered. :

. . ,| - •
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? , j

Innovative technologies eliminated during the three-criteria screening mclrade the following:
J .'' '
• None '!•',.
f •'!
Innovative technologies eliminated during the detailed analysis include the following:
j
; - i1
• None • •' ' i
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion?. Which of the criteria supported the use of a standard technology?
' . ' ' ',''.'
Protectiveness of human health and the environment, long-term effectiveness, and cost were
weighted most heavily in selecting a standard technology.

72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Because treatment was not considered, no soil cleanup goals were established. No soil risk
levels were calculated.
;
73, Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

» None , ' •, ' '.. ' ••'•'•
733
-------
Standard technologies eliminated because of cleanup goals include:

• None
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Time to design/construct/operate

16. How are measures compared?

Cost-effectiveness was the primary criterion used to compare alternatives The chosen
alternative reduces human health risk to an acceptable level at an acceptable cost. Lower risks
could be achieved by another alternative, but the costs would be prohibitive Ease of
implementation also was considered in the selection process. The construction time of the
chosen alternative was expected to be less than other alternatives.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? •

Technical site considerations were hot primary in selecting a remedy. Media conditions were
much more important. The hazardous waste was intermixed with municipal wastes at the
landfill, making treatment of only the hazardous components impossible. The large volume of
wastes in the landfill also made removal and treatment of the wastes inappropriate due to high
costs and high short-term risks. Incineration, excavation, and transport were ruled out because
of the potential release of air emissions. The coarse-grained texture of the material in the
landfill favored a continuous layer or gas control layer. The impact of frost, burrowing
animals, drying, and differential settling were considered in choosing a barrier layer for the
landfill cap.
734
•-4-
-------
Electro-Voice, Inc.
OU-1

Buchanan, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Dry Well and Lagoon Area Soil/Sludge
(rag/kg)

Arsenic 0.014
Beryllium 0.0005
Benzene 1.6
bis(2-Ethyhexyl)phthalate 14
PCB-1254 0.375
Styrene 3.4
Tetrachloroethene 14
Trichlorethene - 0.42
Benzo(a)anthracene 0.85
Benzo(k)fluoranthene 2
Benzo(b)fluoranthene 2
Benzb(a)pyrene 0.91
Benzo(ghi)perlyene 0;37
Chrysene 0.83
Dibenzo(a,h)anthracene 0.15
Ideno(l,2,3-cd)pyrene 0.34
Ethylbenzene 95
Naphthalene 14
Toluene 330
Xylenes 0.006
Lead 0.083
Cadmium 0.735
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
9/8/83
11/21/84
1/91
(5/23/92
Background
,i
PRP-lead
PRPs: Electro-Voic:e, Inc.
FS prepared by: Fishbeck, Thompson,
, Carr & Huber
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 30,000 cubic yards of dry well soil
• 30,000 cubic yards of lagoon area soil/sludge
-1-
735
-------
3. What type of site is this? . '

Electrical Equipment. An active audio equipment facility located in a residential area.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ,
5.
6.
Dry Well Soil

Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Deed restrictions, fencing, signs
Capping, slurry wall
Chemical fixation
Incineration
Excavation, landfill (on-site, off-site)
Lagoon Area Soil/Sludge

Access restriction: "Deed restrictions, fencing, signs
Containment: Capping, slurry wall
Chemical treatment: Chemical fixation ,
Thermal treatment: Incineration
Disposal: Excavation, landfill (on-site, off-site)

Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ bioremediation, composting
Chemical treatment: Solvent extraction, dechlorination
Thermal treatment: Soil vapor extraction, in situ vitrification, wet air oxidation

What was the cost estimate for the innovative technology?

RAAs were developed for specific media in the three-criteria analysis and for site-wide media
m^^e"CflnaanfIySiSandtheROD- Some RAAs were changed in the Proposed Plan
and ROD and these changes are presented parenthetically below
736
,J
-2-
-------
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Dry Well Soil
Alternative
RAA-DW-3
RAA-DW-4A
RAA-DW-4B
RAA-DW-5
Innovative Technology
Soil vapor extraction/bioremediation/
cap
Soil vapor extraction/bioremediation/
partial excavation and incineration
Soil vapor extraction/bioremediation/
partial excavation/landfill disposal
Soil vapor extraction/bioremediation/ in
situ vitrification
Estimated Costs
3 Criteria
$1,100,000
$2,500,000
i
$1,500,000
$2,400,000
'i
9 Criteria
—
—
, ->- -
—
Lagoon areas soil/sludge

No innovative technologies were incorporated into remedial alternatives.

Site-wide
Alternative
RAA-3
(RAA-3A)
(RAA-3B)
RAA-4

- -
Innovative Technology
Dry well area cap/soil vapor extraction/
bioremediation/lagoon area cap/ground
water extraction and treatment
Soil vapor extraction/excavation/
stabilization/landfilling of sludge
layer/lagoon area cap/on-site ground
water extraction and treatment/off-
site ground water monitoring .
Soil vapor extraction/excavation/
incineration of sludge layer/lagoon area
cap/on-site ground water extraction and
treatment/off-site ground water
monitoring
Dry well area soil vapor extraction/
bioremediation/partial excavation/
lagoon area cap/on-site and off-site
ground water extraction and treatment
Estimated Costs
3 Criteria
l .

i'
'
9 Criteria
$2,100,000
$4,100,000
49,400,000
$3,100,000

-3-
737
-------
Alternative
(RAA-4A)
(RAA-4B)
Innovative Technology
Dry well area soil vapor extraction/
excavation and landfilling of sludge/
lagoon area cap/on-site and off-site
ground water extraction and treatment
Dry well area soil vapor extraction/
excavation and incineration of sludge/
lagoon area cap/on-site and off-site
ground water extraction and treatment
RAA-5 Dry well area soil vapor extraction/
bioremediation/in situ vitrification/
lagoon area cap/on-site and off-site
ground water extraction and treatment
Estimated Costs
3 Criteria
9 Criteria
$5,700,000
$11,010,000
$3,400,000
"
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Dry Well Soil
Alternative
RAA-DW-1
RAA-DW-2
Standard Technology
No action
Institutional controls
Lagoon Area Soil/Sludge
Alternative
RAA-L-1
RAA-L-2

RAA-L-3
RAA-L-4
Standard Technology
No action
Institutional controls

Multilayer cap
Excavation/landfill disposal
Estimated Costs
3 Criteria
$0
$48,000
9 Criteria
Estimated Costs
3 Criteria
$0
$58,000
$180,000
$24,000,000
9 Criteria
eliminated
eliminated
738
-4-
-------
Site wide
Alternative
RAA-1
RAA-2
(RAA-5A)
(RAA-5B)
Standard Technology
No action
Access restrictions
Excavate/landfill dry well areas soil and
sludge/cap lagoon areas soil/on-site and
off-site ground water pump and treat
Excavate/incinerate dry well area soil
and sludge/cap lagoon area soil/on-site
and off-site ground water pump and
treat
Estimated Costs
3 Criteria
, .1
- -r— •
I
• ![
1
' i' x-
9 Criteria
$0
$310,000
$8,900,000
>
$13,000,000
If a standard technology was chosen, why?
' ' ' ' ' ' ! ' -
Solidification/stabilization and capping of residuals were selected for some wastes.

.. ' . - • . i • •
If an innovative technology was chosen, why? ,
< 'i ,
i
RAA-3A was chosen because it protects human health and the environment by reducing risk
posed by ingestion of and dermal contact with contaminated ground water, and ingestion and
inhalation of dry well soil and lagoon area soil. This alternative provides protection through
treatment of the principal threat (dry well area soil), treatment of the contaminated onsite
ground water, capping of the lagoon area soil, and monitoring offsite ground water. Dry well
area soil treatment will reduce site contaminants to below Michigan Act 307 Type B levels.
The underlying sludge will be removed and, solidified if cleanup levels cannot be met with
solvent vapor extraction (SVE).' Containment of lagoon area soil ensures long-term
effectiveness and permanence by preventing contact with these soils, and eliminates
infiltration, which minimizes, if not eliminates, contaminant movement in the soil column.
Ground water pump and treatment for the onsite ground water remediates the most highly
contaminated ground water first. Monitoring the offsite ground water allows EPA to detect
any changes in the offsite ground water before selecting a final remedy. This alternative
provides long-term effectiveness sinceithe main threats to the site, dry well soil and
contaminated ground water, are treated first. Treatment of dry well urea soil and ground water
permanently reduces contaminant toxicity, mobility, and volume. Capping the lagoon areas
soil reduces contaminant mobility. This alternative meets all state and federal ARARs. In
accordance with Michigan Act 307, this alternative meets Type B cleanup criteria for dry well
soil and Type C cleanup criteria for lagoon area soil. The chosen alternative poses no
unacceptable short-term risk. The technologies proposed, SVE and capping, are well-
established technologies and should not be difficult to implement. 'Die chosen alternative is
the least .expensive of the treatment alternatives and has been deemeijl the cost-effective option.

In the Proposed Plan, RAA-4A was the preferred alternative. Since jpublishing the Proposed
Plan, EPA determined that to use an operable unit approach is more appropriate at this time
-5-
739
-------
for this site than a final remedy selection. This decision was made after considering the
substantial number of public comments that indicated a preference for monitoring, rather than
remediating, the offsite ground water. EPA determined that the operable unit approach is more
appropriate at this time because it is a more focused, logical approach that first treats the
contaminated soils, which are the source of ground water contamination, and the more highly
contaminated onsite ground water.
10.
740
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Dry Well Soil

Innovative technologies eliminated during the initial screening include the following:

• Dechlorination was eliminated because it would not be applicable to aromatic
compounds found in the dry well.
» Wet air oxidation was eliminated because it has not been proved for the treatment of
high-solid content waste.

Innovative technologies eliminated during the screening of the three criteria of the technologies
include the following:

• Composting was eliminated because it has not been demonstrated to be effective for
the remediation of organic contaminants in the well soil and its implementation might
greatly increase the risk of exposure to contaminants.
• Solvent extraction was eliminated because it would not be cost-effective given the
small volume of contaminated soil.

Innovative technologies eliminated during the detailed analysis include the following:

« In situ bioremediation was replaced by landfilling and incineration in RAAs 3A 3B
4A, 4B, 5A, and 5B, in the Proposed Plan and ROD; however, no explanation was '
given for this change.
• In situ vitrification was not eliminated, but it was not included into an RAA and no
explanation was given. Some discussion suggests that negative aspects of the process
include: site buildings could be damaged by the .process given their proximity to the
contaminated soil; and there is limited information regarding the efficiency and
potential drawbacks of the process and therefore treatability studies would be
necessary.

Lagoon Area Soil/Sludge

Innovative technologies eliminated during the initial screening include the following:

• Composting was eliminated because it would not be applicable to primary lagoon
contaminants.
-6-
-------
11.
lagoon contaminants.
Dechlorination was eliminated because it would not be
Solvent extraction was eliminated because it would not be applicable to primary

applicable to primary

applicable to primary
lagoon contaminants.
Wet air oxidation was eliminated because it would not be
lagoon contaminants.
Soil vapor extraction was eliminated because it would not be
lagoon contaminants. -
Innovative technologies eliminated during the screening of the nine criteria of the technologies
in the FS include the following:

• In situ vitrificaiion was eliminated because this treatment would immobilize site
contaminants; however, the metal contaminants on site are largely immobile in the soil
matrix and are not leaching in quantifiable levels to ground water. Treatment to
prevent leaching, therefore, is not required. Moreover, the capital costs would be very
high. The feasibility would be limited by the lack of vendors for the technology. This
process is patented and the only commercial vendor licensed to supply this process is
Geosafe Corp.
- _ i:' -
Innovative technologies eliminated during the detailed analysis include the following:

• In situ bioremediation was replaced by landfilling and incineration in RAAs 3A, 3B,
4A, 4B, 5A, and 5B, in the Proposed Plan and ROD; however, no explanation is given
. for this change. >
•jj

Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
• ••• . , . •[•••••'..';
The criteria that were weighted most heavily in selecting an RAA we;re long-term protection
and cost. The chosen alternative was the least costly of the alternatives that were deemed
protective through treatment of source contaminants. \ t
12. What cleanup goals were selected? If the cleanup goal was based on art ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

1 In the FS, many potential cleanup levels were developed in accordance with Michigan Act 307
Type A, B, or C criteria for both dry well soil and lagoon soil. A m!ore abbreviated list of
cleanup levels was presented in the ROD. The cleanup levels presented in this review are
those found in the ROD.

Dry Well Soil i
Contaminant
Cleanup Level (ng/kg) ARAB, or Other Basis
Carcinogens
Arsenic
0.4
;! Background3
, -7-
741
-------
Contaminant
Cleanup Level Oig/kg)
&RAR or Other Basi
Michigan 307b
bis(2-Ethyhexyl)
phthalate
Michigan 307
Michigan 307
Michigan 307
Tetrachloroethene
Michigan 307
Benzo(a)anthracene
Michiean 307
Benzo(k)fluoranthene
Michiean 307
Benzo(b)fluoranthene
Michiean 307
Benzo(a)pyrene
Michigan 307
Benzo(ghi)perlyene
Michigan 307
Michigan 307
Dibenzo(a,h)anthracene
Michigan 307
Ideno(l,2,3-cd)pyrene
Michigan 307
Frichlorethene
Michiean 307
Noncarcinogens
for cleanup levels •
'Michigan Act 307 Type B soil cleanup criteria for aquifer protection
• ?r href'h6-based risk assessments, an excess upperbound individual lifetime cancer
nsk of 10- was acceptable and a Hazard Index of 1 or less for noncarcinogens was
flCCGtS
742
Lagoon Area Soil/Sludge

A Type C remedy developed pursuant to Michigan Act 307 has been determined to be relevant
and I appropriate for the lagoon area soils because these soils are located in a natural depression
an unlikely area for future development. Children, however, might currently and in the future
trespass and play in this area. The cap will be designed in accordance with the State of
Michigan s Act 64. A hazardous waste cap will eliminate or decrease dermal contact with and
mgestion of lagoon area soil. A cap also will eliminate or decrease infiltration into the soils
-8-
-------
thereby decreasing the mobility of cadmium, which is present at elevated levels in the lagoon
area and could pose a future threat to ground water. , '

• N'- • • , ."'"'"•.. , - ' ' ^ '}• ' '• •• ' •
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? • . •;' s •

Innovative technologies eliminated because of cleanup goals include:
f :
• • ' •• None' - , ' ' J' ' - .'
" . • * i1
Standard technologies eliminated because of cleanup goals include: |

• None ,
• ' ! /

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives? |

The following measures were used to compare the alternatives:

Cost-effectiveness ,
Preference for treatment (vs. containment) , ;
Waste left in place/institutional control

16. How are measures compared?
- 1 • .
• • . J
RAA-3A, a treatment alternative, was preferred over RAA-2, a containment alternative,
because treatment alternatives are more effective in the long term at eliminating risk
than the containment alternatives. Furthermore, institutional controls might not
guarantee reduced risks to human health or the environment in the future. Of all the
treatment alternatives, RAA-3A was the least expensive.

' • - • I ' •"''.'
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
' \ ' • •
No technical considerations were primary in selecting a remedial alterative. The proximity of
buildings to contaminated site soil was a limiting factor in the use of in situ vitrification.
.,. ' ,V>' 743
-------
Fadrowski Drum Disposal

Franklin, Wise, .in
Region 5
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study ?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Total PAHs 24.3
Toluene 1.8

Test pits (rag/kg)

Toluene 0.24
Total PAHs 180
4,4-DDT 0.31
Aroclor 1254 1.9
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
1986
5/91
6/10/91
Background

PRP-lead
PRPs: Acme Printing Ink Company
FS prepared by: Warzyn Engineering,
Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 142,000 cubic yards of soils with low-level contamination
• 25 cubic yards of characteristically hazardous soils
3. Wliat type of site is this?

Uncontrolled Waste Site. A former landfill, the site is in a semirural area surrounded by
mixed residential, light commercial development.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction: Deed restrictions, controlled land use, assess restrictions
744
-1-
-------
Containment:

Physical treatment:
Thermal treatment:
Disposal: '
Capping (soil cover, clay and topsoil, clay, rooting zone, topsoil, NR
504, multilayer RCRA) !
Recycling
Incineration
Excavation, off-site disposal, oh-site disposal ;
5. Was an innovative technology considered in the FS? If so, which technology?
^ ' • '' •• ..'.'' • ..I-'.--
Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Thermal treatment: In situ vitrification
What was the cost estimate for the innovative technology? .1
, • • • i ' • . •
- i • •' . • - - ' '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs typically are estimated as part of a three-criteria screening process .
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during ah evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementabililty; cost; state/support
agency acceptance; and community acceptance.
I
Cost Estimates for RAAs That Include Innovative Techmoloipes
(selected remedial alternative is in bold)
Alternative
RAA-6
Innovative Technology
Fencing/deed restrictions/in situ
vitrification/ground water monitoring
Estimated Costs
3 Criteria
N/A
'* •
9 Criteria
$63,600,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action
Fencing/deed restrictions/ground water
monitoring

' . -2-
Esfimated Costs
3 Criteria
N/A
N/A
9 Criteria
$0
eliminated
745
-------
Alternative
RAA-3A
RAA-3B
RAA-4
RAA-5A
RAA-5B
Standard Technology
Fencing/deed restrictions/ground water
monitoring/Wisconsin cap/leachate
collection/long-term monitoring
Fencing/deed restrictions/ground water
monitoring/RCRA Subtitle C compliant
cap/leachate collection/long-term
monitoring
Fencing/deed restrictions/excavate soil
and drums/off-site incineration and
disposal
Fencing/deed restrictions/ground
water monitoring/excavate contam-
inated soil and drums/recycle and off-
site disposal/Wisconsin cap/leachate
collection/long-term monitoring
Fencing/deed restrictions/ground water
monitoring/excavate contaminated soil
and drums/recycle and off-site
disposal/RCRA Subtitle C compliant
cap/leachate collection/long-term
monitoring
^
Estimated Costs |
3 Criteria
.N/A
/ N/A
N/A
N/A
N/A
9 Criteria 1
$2,030,000
$3,900,000
$11,400,000
$2,230,000
$4,110,000
. s
8. If a standard technology was chosen, why? ' -

RAA-5A was chosen because the Wisconsin cap provides protection to human health and the
environment. The cap eliminates direct contact to site contaminants and reduces infiltration of
water into the disposal area, thereby reducing contaminant mobility through the disposal area
The chosen alternative also reduces contaminant toxicity and volume through excavation and
off-site treatment and disposal of contaminated soil and drums. Recycling is the proposed off-
site treatment, to be confirmed once the nature of the buried waste is identified. Because a
portion of the site waste will be excavated prior to capping, this alternative reduces the source
of contamination to ground water more than containment alone would. The long-term
effectiveness of this alternative depends on appropriate monitoring and upkeep This
alternative incorporates standard technologies and is easy to implement. No unacceptable
short-term nsk will be posed by this remedy. Standard safety programs will be implemented
to mitigate the nsk of explosion during the excavation of drums. RAA-5A was deemed to be
cost-effective.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
746
-3-
-------
10. If an innovative technology was not chosen, why not? At whaVstage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tiiree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• None
» ' ' •- i ' , '
Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include; the following:

• In situ vitrification was eliminated because it would be too costly and extremely
difficult to implement given the site's large variety of debris. Furthermore, this
alternative would take seven times longer to implement than all other alternatives.

11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
i
The criteria that were most heavily weighted in selecting a remedy were cost-effectiveness and
the reduction of contaminant toxicity, mobility, and volume. The chosen alternative
incorporates removal, treatment, and containment technologies to reduce site risks. In addition
to reducing site risks from direct exposure to site wastes, the chosen alternative eliminates the
source of ground water contamination. Other treatment technologies that also would reduce
contaminant toxicity and volume were not cost-effective. The Wisconsin cap was preferred
over the.RCRA Subtitle C cap because the RCRA cap was more expensive and provided only
limited additional benefit.

In situ vitrification was eliminated because it would be extremely difficult and time-consuming
to implement, and it was prohibitively expensive.

' . , • ' - , ,i .
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels were not established for this site.
-4- 747
-------
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
lecnnology meet the cleanup goals? - ,

Innovative technologies eliminated because of cleanup goals include: s

1 None

Standard technologies eliminated because of cleanup goals include:

• None
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Time to design/construct/operate
Preference for treatment (vs. containment)

16. How are measures compared?
anroth Preferred'because il b<*h treats and contains site contaminants, an
approach that reduces he source of ground water contamination more than containment alone
would In contrast to in situ verification, which takes 7 years to implement, the chosen
alternative takes only J year. The chosen alternative was deemed cost-effective. In addition
to costing less than other treatment technologies, the chosen alternative was far more cost
effective than containment technologies because of its greater benefits. The Wisconsin cap

^ ^^ ^ RCR 3S more expensive ^ less
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
748
-5-
-------
Folkertsma Refuse
OU-1

Walker, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants*
contaminant levels, and media addressed in
this feasibility study?

No principal contaminants were addressed in
the feasibility study for the waste material,
sediments, or muck at the site because
containment was selected as the remediation
technology. The site's contaminants,
however, include volatile organic
compounds, semivolatile organic compounds
(including pblynuclear aromatic
hydrocarbons [PAHs], and PCBs), and
inorganics.
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1986
1989
6/19/90
6/28/91
Background

EPA Fund-lead
PRPs: None listed
FS prepared by: PRC Environmental
Management, Inc.
2. What volume of material is to be
remediated?

The volume of material to be remediated included:

• 57,000 cubic yards of waste material
• 1;300 cubic yards of sediments
• 12,300 cubic yards of muck
3. •' What type of site is this?

Industrial Landfill. A former industrial landfill.
TECHNOLOGY SELECTION
i
4. What standard technologies were considered for selection in this FS?
Standard technologies considered during the identification and screening of technically feasible
technologies were: !
Waste Material/Sediments/Muck

Access restriction: Deed restrictions, site fencing
-1-
749
-------
5.
6.
Containment:

Chemical treatment:

Thermal treatment:

Disposal:

Sediments

Disposal:
Capping (clay, asphalt, concrete, gravel, multimedia), slurry wall grout
curtain, sleet piles, vibrating beam, grout injection, block displacement
Organic polymer solidification, cement solidification, HAZCON
solidification, Soliditech solidification
Incineration (rotary kiln, fluidized bed, multiple hearth, infrared
plasma arc) off-site incineration, high temperature fluid wall reactor
Excavation, on-site sanitary landfill, off-site RCRA Subtitle C landfill
type H landfill, type HI landfill, off-site sanitary landfill
Mechanical excavation, hydraulic excavation, dewatering (drying beds
mechanical filtration, centrifugation, gravity thickening)
Was an innovative technology considered in the FS? If so, which technology?

during the identification •* screening of
Waste Material/Sediments/Muck

Biological treatment: Composting, landfarming, biodegradation, bioharvesting, soil aeration
Chemical treatment: Oxidation, solvent extraction, soil washing (solvent), dfchlorination
vapor extraction '
Thermal treatment: Thermal volatilization, molten salt reactor, in situ vitrification
was the cost estimate for the innovative technology?
? °CeSS> ln Which technically feasible technologies are identified
f " °f RAAS)' the FS d°eS ~n0t ^Uantify costs" After t^ RAAs have been
n hr are/Stln!ated SS ^ °f a three-criteria weening process (effectiveness,
in plementabihty and cost) to identify alternatives that merit a more detailed evaluation

S TCP C°S, rthaTCalCUlated dUri'ng m 6ValUati0n ^ °n "ine Criteria esSh
the NCR Costs at the three-cntena screening were calculated for independent remedial
technologies and not for remedial action -alternatives.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Innovative Technology
9 Criteria
— t
$42,200,000
750
-2-
-------
7 How did the cost(s) compare to standard technologies? - j

Cost Estimates for RAAs That Include Standard Technologus
(selected remedial alternative is in bold)
======
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
RAA-8
^-f^=!!^^=^=^^^^=^^=^=^=^=i^=;
Standard Technology
No action
Clay cap
Concrete cap
Excavation/off-site disposal at RCRA ,,
Subtitle D landfill '
Excavation/off-site disposal at RCRA
Subtitle C landfill
Excavation/thermal treatment/on-site
disposal
Excavation/HAZCON or Soliditech
solidification/on-site disposal
In situ stabilization/solidification
Estimated Costs
3 Criteria
N/X"
N/A
N/A
N/A
i
N/A
N/A
N/A
I
1
'N/Aa '
9 Criteria
$561,000
$1,500,000
$3,300,000
$9,500,000
$23,000,000
$39,000,000
$23,000,000
$17,000,000
8. If a standard technology was chosen, why?

A standard technology (RAA-2) was chosen because it reduces exposure to contaminants and
reduces the potential for contaminants to migrate to ground water, doesn't require excavation
or thermal techniques which would pose a risk to the community from fugitive dust and air
emissions, and is the least costly.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? " ' . - ,

Innovative technologies could be eliminated from the remedial technblogy selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
-3-
751
-------
Innovative technologies eliminated during the initial screening include the following:

" Composting was eliminated because it would not be effective in treating the metals
present in the waste and the technology has not been proved effective for polynuclear
aromatic hydrocarbons (PAHs) 3 or more rings.
• Landfarming was eliminated because it has not been proved effective for the site's
wide variety of metallic and organic contaminants and it is very difficult to biodegrade
high-ringed PAHs to clean-up goals. , -
• Biodegradation was eliminated because it has not been proved effective for PAHs with
three or more rings. Mixing also would be complicated by scrap in the landfill and it
would be difficult to monitor.
• Bioharvesting was eliminated because PAHs do not bioaccumulate.
" Soil aeration was eliminated because the contaminants have low vapor pressures and
are sorbed strongly to wastes and sediments.
• Soil washing was eliminated because contaminants have low water solubility, are not
volatile, and are sorbed strongly to wastes and sediments.
• Dechlorination was eliminated because they would not be applicable to the site's
contaminants.
" Thermal volatilization was eliminated because the contaminants have low vapor
pressures and are sorbed strongly to wastes and sediments.
« Vapor extraction was eliminated because it would not be applicable to site
contaminants. .
» Molten salt reactor was eliminated because it has not been proved effective on a large
scale for a wide variety of contaminants, and no commercial units are available
• Oxidation was eliminated because it is not effective for treating materials with high
organic content and may oxidize metals (Cr) to more toxic forms.

Innovative technologies eliminated during the screening of the three criteria include the
following:

» Solvent extraction was eliminated because it would not be effective for the site's
contaminants. Overall implementability would be hampered by the need for a solvent
treatment system and additional materials. Capital and O&M costs would be high It
was not considered effective because the media requires further treatment and disposal
after the process is completed. The solvents and contaminants left in the treated
material could be more mobile than the original contaminants and would pose public
health and environmental risks.

Innovative technologies eliminated during the detailed analysis include the following:

• In situ vitrification was eliminated because the effectiveness could be affected by the
amount of metal in the fill area, generation of air emissions pose a risk to community
time to complete is long, few vendors are available and the process requires ;
specialized equipment and it's very costly.
„*'
752
-4-
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
''.--- •' | .
The most heavily weighted criteria in selecting the technology were reduction in mobility of
contaminants, short-term effectiveness, implementability, and cost. Sljiort-term risk, short-term
effectiveness, and implementability eliminated the innovative technology.

.. K ' •
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? !
. I . . ,
No cleanup goals were specified for the remediation of waste materials, sediments, or muck
^ because containment was the selected response action. '.!:•'.

For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10f
was acceptable. For noncarcinogens, a Hazard Index less than or .equal to 1.0 was acceptable.
/ ' ' I ' .
, ' ' i, . "
13. Was the innovative technology eliminated because of the cleanup goaj.s? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:
' ' ' i !- '
• None

Standard technologies eliminated because of cleanup goals include: [
i ' ^ . ' . •
" None . ' ' • ."!•'•' r , -
' ^ ' ',\
• 1 ' -

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. ' , j

. - \\ ~ . • "
• i. ,' '
15. What measures/criteria were Used to compare alternatives? :\
\\ ' , .
,' ' •
The following measures were used to compare the alternatives: j

Total cost
Time to design/construct/operate
Short-term effectiveness [

'i ' •
J ' '
16. How are measures compared? . \ :

The selected remedy is the most cost-effective alternative proposed. While other alternatives
. •-' would ensure greater long-term effectiveness, the selected remedy reduces site risks to within
EPA's.acceptable risk range for carcinogens (10"4 to 10'6) and noncarcinogens (HI < 1) at the
lowest cost. The selected alternative does not emphasize treatment and does not meet the
-5-
753
-------
catena to reduce contaminant toxicity, mobility, or volume. While two other alternatives
(RAA-6 and RAA-9) would meet these criteria, they would pose greater short-term risk to site
workers and the community during implementation, would take much longer to implement
and would be more difficult to construct and operate.' . '
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Folkertsma Refuse contains large volumes of low-level organic and inorganic waste material
which are best remediated by engineering controls such as capping. Soil permeability was
another consideration in selecting a remedial technology.
754
-6-
-------
Fultz Landfill
OU-1

Byesville, Ohio
Region 5,
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? .

Maximum concentrations of principal
contaminants were:

Leachate Sediment (mg/L)
Methylene chloride
Toluene
Arsenic
Beryllium
Cadmium
Lead
Nickel ,
Chlorobenzene
Ethylbenzene
Xylenes (total)
Barium
Mercury .
Selenium
Thallium
Sediment (mg/kg)
1,1 Dichloroethane
Benzene
Toluene .
Pentachlorophenol
Arsenic
Beryllium
Cadmium
Lead
Nickel -
Chlorobenzene
Ethylbenzene
Xylenes (total)
Antimony
Barium
Chromium
Copper • .
0.01
0.024
0.022
0.00 1
0.003
0.049
0.039
0.057
' 0.064
0.008
0.831
0.0001
0.0007
0.0006
!
0.018
0.017
0.15
0.39
0.077
0.002
0.007
0.163
0.073
0.086
0.017
0.014
0.01 ,
0.113
- 0.028
68.5
Site Histtory
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
N/A
6/91
9/30/91
Background

EPA Fund-lead ;
PRPs: Not listed
FS prepared by: PRC Environmental
Management, Inc.
-1-
755
-------
Mercury
Selenium
Thallium
14.3
0.002
0.002
Surface Soil (mg/kg)

Methylene chloride 0.056
Toluene 0.12
Arsenic 0.027
Beryllium 0.001
Cadmium 0.004
Lead 0.049
Nickel 0.058
Barium 0.265
Chromium 0.037
Copper 0.219
Mercury 0.0002
Selenium 0.002
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 770,000 cubic yards of landfilled material

3. Wliat type of site is this?

Municipal Landfill. Closed sanitary landfill where hazardous industrial wastes were co-
disposed with municipal waste. The landfill, overlies two abandoned coal mines, one of which
is flooded and used as a source of potable water.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction:

Containment:
Chemical treatment:
Disposal:
Deed restriction, land use and development restrictions, fencing with
warning signs, zoning ordinances
Single-layer capping (soil, clay, concrete, or asphalt) multi-layer cap of
low permeability material and/or synthetic liners, subsurface support to
prevent mine subsidence, grading, and revegetation, sediment and
erosion control, slurry wall
Stabilization/solidification
On-site or off-site disposal
756
-2-
-------
an innovative technology considered in the FS? If so, which technology?
Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Chemical treatment: Soil washing, in situ soil flushing, reduction/oxidation
Thermal treatment: Vitrification, general in situ thermal treatment
Biological treatment: General biological treatment v • "
What was the cost estimate for the innovative technology? ,

How did the.cost(s) compare,to standard technologies? i
i
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action
Deed restrictions on land and water
use/public information: program/zoning
and ground water drilling ordinances/
fencing and sign positing/ development
of an alternative water supply/long-term
monitoring of air, surface water,
leachate, ground water, and sediments
RAA-2 with multi-layer RCRA (Subtitle
C) cap with gas venting system and a
leachate collection system/installation of
subsurface structural supports to prevent
collapse of the cap/wetlands
replacement ,
RAA-3 with ground water extraction
and on-site treatment
Estimated Costs
3 Criteriia"
N/A
N/A
i
•NiA
N/A
9 Criteria
$0
$2,300,000
$21,000,000
$21jOOO,OOOb
• • /
-3-
757
-------
• Ilernative
RAA-5
RAA-6
RAA-7
RAA-8
RAA-9
RAA-10
Standard Technology
RAA-2 with RCRA (Subtitle C) on-site
landfill/excavation and compaction of
wastes and the site for reburial in
landfill/treatment of the abandoned
underground mine to prevent
subsidence/backfilling of the mine with
rock underdrain/erosion and sediment
coritrols/dewatering of excavated
materials/wetlands replacement
RAA-3 with subsurface barrier (slurry
wall)
RAA-4 without multi-layer cap and
leachate collection system
RAA-3 with an upgrade to the Byesville
Water Treatment Plan to prevent
potential contamination of the public
drinking water supply
RAA-4 and RAA-5
RAA-2 with a coal mine aquifer cut-off
barrier of low permeability compacted
clay/erosion and sediment controls/
dewatering of excavated material/
surface water control/wetlands
restoration
Estimated Costs
3 Criteria^
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$57,000,000
$21,000,000
eliminated
eliminated
eliminated
eliminated
*No specific costs were given at 3 criteria stage. •
bln the ROD, the present worth cost given for RAA-4 was $19,480,700.

8. If a standard technology was chosen, why?
f
A RCRA cap was selected because it is protective of human health and the environment; it
meets state standards for closure of existing landfills, and solid waste landfill siting criteria,
easy to implement with widely available equipment and materials and well established reliable
methods.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
738
-4-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
"'•-,'• . j • • '
Innovative technologies1 could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of .,,;..
effectiveness, implementability, and cost; or during the detailed evaluation.. . .

Innovative technologies eliminated during the initial screening include: the following:

• Soil washing was eliminated because it would be difficult to implement due to the
requirement to excavate and treat all landfilled wastes. j
• Reduction/oxidation was eliminated because it would be difficult to implement due to
the requirement to excavate and treat all landfilled wastes. -
• Soil flushing was eliminated because it would be difficult to implement due to the
requirement to excavate and treat all landfilled wastes.
• Vitrification was eliminated because the depth of the landfill, the low level of
contamination, the soil type, and the commingling of hazardous v/ith nonhazardous
wastes would make the technology difficult to implement.
• In situ thermal treatment was eliminated because it could not ^be Implemented safely
due to the danger of an underground fire starting within the landfill and spreading to
the abandoned mines below.
• Biological treatment was eliminated because the depth of the landfill, the low level of
contamination, the soil type, and the commingling of hazardous v/ith nonhazardous
wastes would make the technology difficult to implement. !
. - i .
Technologies eliminated during the screening of the three criteria include the following:
.i - .
• None ''.'..
:j . . • -
Technologies eliminated during the detailed evaluation include the following:

• None. . .. , . . • . • i ' , • • •
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and implementability wzis the criteria
weighted most heavily in selecting a technology.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
'•'••• '!
No cleanup goals were established for soil or sediments. Risk were hot calculated for potential.
exposures to soil and sediment. i
759
-5- '
-------
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? .

Innovative technologies eliminated because of cleanup goals include:

• None • • .

Standard technologies eliminated because of cleanup goals include:

« None ,
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Time to design/construct/operate

16. How are measures compared?

Remedial alternatives were primarily compared based on achieving the lowest risk levels from
exposure to ground water and surface water during implementation. Ease of implementation
was a secondary measure.
77.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The abandoned room-and-pillar coal mines found under the landfill complicate the use of
containment because of the potential for subsidence caused by the areas where the coal has
been removed. A multi-layer cap was preferred over a single-layer cap because single-layer
caps are less durable, require more maintenance, and do not meet ARARs. The large volume
of materials was a primary consideration in the evaluation of treatment technologies that
required excavation because it would be difficult to separate the hazardous components from
the rest of the waste and all landfilled materials would have to be treated. Also, the volume of
waste would create storage problems, volatile emissions, contaminated runoff from storage
piles, and the need to dewater. In situ thermal treatment was eliminated as unfeasible because
of the danger of an underground fire starting within the landfill and spreading to the
underground mines. In situ soil washing, vitrification, and biological treatment were
eliminated because the depth of the landfill, the low level of contamination, the soil type, and
the commingling of hazardous with nonhazardous wastes made these technologies difficult to
implement.
760
-6-
-------
G & H Landfill
OU-1

Shelby Township, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
+•
Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

PCBs 180
BETX 10,000
PNA 880
Chlorinated VOCs 4,030
2. What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/83
8/17/90
12/21/90
Background

EPA Fund-lead j
PRPs: N/A ,:•
FS prepared by: CH2M Hill
The volume of material to be remediated included: |
• , i ,
• 800,000 cubic yards of landfill material
• ' 1

3. What type of site is this? J

Municipal Landfill. A inactive landfill bordered by industrial and residential areas.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Deed restrictions, fencing
Surface controls, capping (soil, clay, asphalt, concrete, single-layer,
multilayer, synthetic membrane, clay-geomenibrane) vertical barriers,
horizontal barriers
Solidification/stabilization j
Incineration i
Excavation, disposal (on-site, off-site) |
-1-
761
-------
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ bioreclamation
Phys/Chem treatment: In situ soil flushing, oxidation, reduction, in situ soil vapor extraction
inermal treatment: Low-temperature volatilization, in situ vitrification
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4A
Innovative Technology
$40,000,000
Soil-clay cap/slurry wall/ground
water extraction and treatment/(exca-
vation of soil with greater than 500
ppm PCBs/treat with incineration,
vitrification, or other EPA-approved
destructive technology)"
.

•Excavation and treatment of PCB-contaminated soil outside the slurry wall was added to the
chosen alternative in the ROD. It is not anticipated that soil with these high levels will be
encountered. .
Estimated Costs
3 Criteria

N/A
9 Criteria
7.
762
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologi
(selected remedial alternative is in bold)
es
Alternative
RAA-1
RAA-2
-=======
Standard Technology
No action
Fencing/deed restrictions/ground water
monitoring
•
Estimated Costs
3 Criteria
N/A
•N/A
9 Criteria
$0
$3,600,000
-2-
-------
Alternative
RAA-3A
RAA-3B
RAA-4B
RAA-5A
RAA-5B
RAA-6A
RAA-6B

Standard Technology
Soil-clay cap
Soil-clay cap/slurry wall
Soil-clay cap/slurry wall/ground water
injection, extraction, and treatment
Soil-clay cap/slurry wall/ground water
extraction and treatment/excavation of
hot spots/disposal in on-site RCRA
landfill
Soil-clay cap/slurry wall/ground water
extraction and treatment/excavation of
all site waste/disposal on-site RCRA
landfill
Soil-clay cap/slurry wall/ground water
extraction and treatment/excavation of
hot spots/incineration of hot spots
Soil-clay cap/slurry wall/ground water
extraction and treatment/excavation of
hot spots/incineration
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
'|
N/A
'i
N/A
i T
|
. N/A
9 Criteria
$29,000,000
$38,000,000
eliminated
eliminated
eliminated
$470,000,000
eliminated
8. If a standard technology was chosen, why?

Standard, technologies were chosen (see below).
If an innovative technology was chosen, why? ;|

RAA-4A was chosen because it reduces risk associated with direct exposure to site soil and
contaminated ground water.'1 A cap that meets state and federal landfill closure criteria will
provide a barrier to direct contact. It also will decrease the rate of precipitation infiltration
through the landfill by approximately 80 percent. Implementation of ;the cap and slurry wall
will further impede the mobility of landfill contaminants and reduce ground water contaminant
loading into the aquifer outside the slurry wall. Ground water pumping and treatment will
restore the aquifer to usable conditions. It offers long-term effectiveness since the ground
water outside of the slurry wall will be treated. This alternative has proposed soil excavation
and treatment if PCBs in excess of 1 ppm are discovered in soil outside of the slurry wall.
The excavated soil will be treated by either incineration, vitrification, or any other EPA
acceptable destruction technology deemed appropriate. This alternative minimizes short-term
risk since soil will be excavated only if high levels of PCBs are discovered outside of the
slurry wall. Implementation of this alternative can be accomplished iin 4 years and ground
water cleanup standards will be met in 30 years, making this the most timely of all the
alternatives. Cap materials are readily available and implementation iwill be large scale, but
straightforward. Implementation of the slurry wall will require some, compatibility testing to
-3-
763
-------
10.
n.
Slte'S WaSte
The selected alternative is cost-
r
*"
A>
nnplementability, and cost; or during the detailed evaluate,

Innovative technologies eliminated during the initial screening include the following

!t would not te
WOUld te dWcn"
wouid
not
landfill
'
foiling: teChn°10gieS eHminated dUring the SCreenin* °f the *« criteria include the

" ^'£ZeratUre V0latilization Was not -^orated into an RA but no explanation

Innovative technologies eliminated during the detailed analysis include the following:

• None

764
-4-
-------
' 12. What cleanup goals were selected? If the cleanup goal was based on
ARAR? What risk level was selected to establish cleanup goals?
an ARAR, what was that
Contaminant
Cleanup Level (rag/kg) | ARAB, or Other Basis
Carcinogens
PCBs ,
Michigan Act 307V
i EPAb
'Michigan Act 307, Type B cleanup achieved levels that are based on the reduction of
contaminants to levels that pose an individual lifetime cancer risk of 10"6.
''EPA's Guidance on Remedial Actions for Superfund Sites with PCB Contamination,
1989.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? i
• • ' , ' ' '. -i • '.
Innovative technologies eliminated because of cleanup goals include:

• • None , - ''•.•'•,-
!•
Standard technologies eliminated because of cleanup goals include: j

• None . T
14. Were treatability studies conducted on the innovative technology or standard technology?

• i .
Treatability studies were not conducted. ; /,
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Time to design/construct/operate
Impact on nearby populations
16. How are measures compared? ' '

Cost-effectiveness and time to reach cleanup levels were considerations in selecting a remedial
alternative. The chosen alternative, RAA-4A, was very similar to RAA.-3A. Though slightly
more .expensive, RAA-4A was preferred because it will achieve ground water cleanup levels
within a reasonable time frame. With the implementation of active ground water cleanup,
cleanup goals will be reached within 30 years. Natural attenuation of ground water, as
proposed by RAA-3, would take more than 30 years. Short-term risk to nearby populations
- also was a concern. Though RAA-6A would more immediately reduce site contaminants,

. -5- '• •
765
-------
17.

consider
-------
H. Brown Co., Inc.

Walker, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soils/(Surface and Subsurface)1 (mg/kg)

Lead 649,000
Antimony 4,980
Arsenic , 463
Beryllium 13.6
Chrysene 120
Isopropene 0.24
Benzo(a)anthracene 15.95
Benzp(a)pyrene 6
Benzo(b)fluoranthene 15.7
Benzo(k)fluoranthene 10.9
Dibenzo(a,h)anthracene 3.9
Ideno(l,2,3-cd)pyrene 4.3
Bis (2-ethylhexyl)
phthalate (BEHP) 120
N-nitrosodiphenyl
amine(NNDPA) 2.5
-. PCBs (Aroclor-1254) 9.6
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
3/29/85
6/10/86
6/29/92
9/30/92
Background

EPA Fund-lead
PRPs: Tessie Brown, H. Brown Co., and
''•"" approximately 1,400 PRPs
FS prepared by: PRC Environmental
Management, lee.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• ••- 180,000 cubic yards of soil
• Volume of sediments to be remediated was not given
'Other data were presented in Table 11 of the ROD as "current"; however, it is unknown whether
these data were validated or used in the risk assessment. .!-,•'
-1-
767
-------
3. What type of site is this?

Recycling. A former battery reclamation operation which had been operating since 1961.
Prior to 1961, the site was an uncontrolled dump. H. Brown ceased active reclamation,
including battery shredding in 1981 or 1982. From then on, the operation has accepted scrap
nonferrous metals that are sold to off-site purchasers. The site is located in a light industrial
area.
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Institutional actions (fencing, deed restrictions)
Containment: Capping (clay, asphalt, concrete, multicomponent)
' Phys/Chem treatment: Solidification, soil aeration
Thermal treatment: Incineration, smelting
Disposal: Excavation, on-site landfill (RCRA, sanitary), off-site landfill (RCRA)

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Ex situ aerobic biodegradation, ex situ anaerobic biodegradation, in
situ biodegradation
Phys/Chem treatment: Vapor extraction, soil washing, Bureau of Mine's (BOM) process,
modified lead leaching process
Thermal treatment: Vitrification

6, What was the cost estimate for the innovative technology? , •

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) j
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
Standard Technology
No action
Limited action
Limited containment
Complete containment
Limited containment/drainage
remediation . • "
Complete containment/limited drainage
remediation
Soil containment/ground water
treatment/drainage remediation
Estimated Costs
3 Criteria
$0
$440,000
$4,500,000
$4,600,000
$4,500,000
$4,600,000
. .1 ' -
$6,()00,QOO
I ,
9 Criteria
$0
eliminated
eliminated
eliminated
eliminated
eliminated
$6,000,000
(ROD
$6,900,000)
-3-
769
-------
Alternative
Standard Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-9
Soil disposal/ground water
treatment/drainage remediation
$41,000,000
$41,000,000
RAA-15
Solidification and containment of
soil'/ground water treatment/drainage
remediation
$15,000,000
$15,000,000
"Contaminated sediments to be treated and disposed along with contaminated soil.
8. If a standard technology was chosen, why?

RAA-15 was selected because solidification and containment of all soil exceeding cleanup
standards permanently reduces and controls existing and potential risks through treatment and
. engineering controls and provides the greatest overall protection and long-term effectiveness
for the site. This alternative also has a high degree of short-term effectiveness. The
solidification process substantially reduces the mobility of site contaminants and is easy to
implement because vendors are readily available and the technology involved does not require
pilot-scale studies or rely on off-site treatment or disposal. In addition RAA-15 complies with
all ARARs for contaminated soil at the site. The solidification process is a BDAT for treating
lead-contaminated soils, and its use should provide compliance with Land Disposal Restriction
(LDR) regulations and cleanup standards for all media at the site. Because treatment will
render the contaminated soil nonhazardous, the construction of a RCRA-corhpliant
multicomponent cap and a high-density polyethylene (HDPE) curtain will meet ARARs
required for m-place closure under Michigan Hazardous Waste Management Act (Act 64)
Finally the selected alternative can be implemented at a moderate cost compared to the other
alternatives.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Ex situ aerobic and anaerobic biodegradation were eliminated because they would not
be applicable due to the high concentrations of inorganic contaminants at this site.
• Vitrification was eliminated because it would not be applicable to the site. Battery
chips might bum because of the very high temperatures used by the process.
770
-4-
-------
» In situ biodegradation was eliminated because it would not be; applicable since
biological treatment is effective only on certain organics.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Vapor extraction was eliminated "because of low vapor pressure of organic
contaminants in soil at the site, relatively low permeability of site soil for air, and the
age of contaminants in the soil at the site, vapor extraction would not be effective in
' lowering the concentrations of organic target contaminants (TCs) in soil at the H..
Brown site." The FS used the U.S. EPA Soil Vapor Extraction Technology Reference
Handbook (EPA, 1991) to determine the applicability of vapor extraction for soil
treatment at this site. ' |
• Soil washing was eliminated because it would not be effective for remediating soil at
this site because: the diverse nature of debris in the site's soil1 likely would clog the
soil washing system, slowing the washing operations, possibly affecting treatment, and
adding to O&M costs; organic contaminants in the soil likely >vould cause problems in
formulating a suitable washing^solution; and release of hydrogen isulfide gas during the
regeneration of surfactant could result in potentially hazardous; working conditions.
• BOM process was eliminated because the modified lead leaching process was expected
to be more effective than the BOM process, at a comparable cost. The BOM process is
difficult to implement, it has not yet been tested on a,full-scale basis, and it is not
available from any vendor; therefore, equipment involved in title process would have to
be originally designed and fabricated. The FS states that this process also might be
difficult to implement for the same reasons as soil washing.

Innovative technologies eliminated during the detailed analysis include the following:
-\ ., . , • . •
• The modified lead leaching process was eliminated because this technology would be
more difficult to implement than standard technologies, primarily because no vendor is
currently available and the equipment for treating the soil would have to be originally
designed and fabricated. In addition, pilot-scale testing would be required to determine
whether full-scale treatment is possible. This technology also would have the lowest
short-term effectiveness because of the required pilot-scale tesiting of the soil treatment
process before implementing the rest of the alternative. Any (alternative that requires
treatment must meet federal LDR treatment standards (40 CFR 268). This ARAR
might not be met if the lead leaching process is found to be ah ineffective treatment
process. i
• Smelting was eliminated but no specific reason was given. Smelting was proposed in
RAA-11, RAA-12, RAA-13, and RAA-14. These alternatives were eliminated due to
issues related to the other components of the remedy and not specifically because they
proposed smelting. The ROD states that RAA-11, RAA-12, RAA-13, and RAA-14
would be somewhat difficult to implement because of the need for regulatory
determination of compliance for the receiving facility. The FS states that, although a
smelter that would accept the lead contaminated soil has been identified, the ability of
the smelter to comply with CERCLA off-site policy, and to maintain sufficient
treatment capacity would have to be investigated. !
5 771
-------
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Long- and short-term effectiveness were significant criteria in selecting chosen remedy for this
site. Because all of the alternatives would meet ARARs, the greatest degree of variability was
for long- and short-term effectiveness. Alternatives that would leave untreated waste in place
were judged to have correspondingly low long-term effectiveness, whereas alternatives that
would treat the waste before on-site containment were judged to have a high degree of long-
term effectiveness and permanence. Alternatives that would require pilot-scale studies prior to
implementation (such as the innovative alternatives) would have low short-term effectiveness.
The selected alternative was considered to have a high degree of short-term effectiveness
because it would be easily implemented with minimal planning and readily available vendors.
12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup goals were not established specifically for sediments; however, sediments will be
consolidated with site soils and all soils/sediments exceeding cleanup standards will be treated
by an in situ solidification/stabilization process.
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Lead
Beryllium
Arsenic
NNDPA
PCBs
Benzo(a)anthraceneb
Benzo(a)pyreneb
Benzo(b)fluorantheneb
Benzo(k)fluorantheneb
Chryseneb
Dibenzo(a,h)anthraceneb
Ideno(l,2,3-cd) .
pyreneb
BEHP
500
0.6
6.6
0.33
1
0.33
0.33
0.33
0.33
0.33
0.33
0.33
0.33
Michigan Act 307a
Background
Background
,. Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Noncarcinogens
Antimony
0.5
Michigan Act 307
772
-6-
-------
Contaminant
Isopropeneb
Cleanup Level (mg/kg)
90
ARAR or Other Basis
Michigan Act 307
"EPA's selected soil cleanup standards for this site are in compliance with Michigan
Act 307 and its implementing rules in that they meet the standard for selection of a
Type C cleanup (R 299.5717(2) and 5719(1)).
"Contaminant does not pose a significant risk, but its current cpncentration violates an
ARAR.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

OBG Laboratories, Inc. (OBG) conducted a bench-scale treatability study for Ecology &
Environment, Inc. (E&E) involving the identification of solidification/stabilization methods for
decreasing the leaching characteristics of lead-bearing waste fill material from the site. OBG
found that the H. Brown materials can be easily solidified to produce a material having
improved structural integrity with improved leachability and permeability. TCLP leaching
tests on selected mix designs yielded generally favorable results with respect to contaminant
fixation, 'especially with the wastes having lower initial lead concentrations.
'" • I-
the treatability study was obtained from the Administrative Record; however, the Feasibility
Study, Proposed Plan, and ROD do not refer to this treatability study,
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Time to design/construct/operate
Proven reliability
Preference for treatment (vs. containment)

16. How are measures compared?
The cost of the selected alternative, RAA-15, is moderate compared
Those less costly alternatives, however, would not offer permanent
-7-
1:6 the other alternatives. .
solutions and are therefore
773
-------
less cost effective than the selected alternative. The lead leaching process was rejected
because it would be more difficult and take longer to implement, primarily because the
equipment would have to be originally designed, and pilot-scale testing would be necessary to
determine whether full-scale treatment is possible. The selected alternative was chosen
because it utilizes proven and easily available technologies. The statutory preference for
treatment as a principal element of a remedy is satisfied by the 'selected alternative
Alternatives leaving untreated waste in place were rejected because of their low long-term
effectiveness. • • .• •
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy, however, two innovative
technologies were eliminated in part due to technical considerations. Vapor extraction was
eliminated partly because of the "relatively low permeability of site-soil for air " and soil
washing and was eliminated because the diverse nature of debris in the site's soil is likely to
clog the soil washing system.
774
-8-
-------
Kentwood Landfill

Kentwood, Michigan
Region 5
GENERAL SITE INFORMATION

. 1. What were the principal /contaminants,
contaminant levels, and media addressed in
this feasibility study?

Landfill leachate has contaminated surface
soils with the following contaminants;
(concentrations not found in the FS):

Soil (mg/kg) ' ' , .

. Acetone
2-Butanone .
Ethylbenzene
Toluene
Xylene
Diethylphthalate
4-Methylphenol
Fluoranthene
Phenanthrene
Bis(2-ethylhexyl)phthalate
Butylbenzylphthalate
Di-b-buty Iphthalate
Arsenic
, Barium
Chromium
Iron
Nickel
Zinc
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
12/30/82
9/8/83
11/12/90
3/29/91
Background

PRP-lead j
PRPs: City of Kehtwood, County of
Kent
FS prepared by: Fishbeck, Thompson,
Carr & Huber
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 2 million cubic yards of soil
3. What type of site is, this? , • ,
i .
i.
Municipal Landfill. Municipal landfill that accepted garbage, rubbish, construction, and
demolition waste. , i
-1-
775
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
5.
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Access controls and site monitoring
Cap improvements (grading, vegetation)
Stabilization, fixation
On-site or off-site incineration
Excavation, off-site landfill, on-site cells
Way an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Composting
Physical/chemical treatment: Solvent extraction, dechlorination, wet air oxidation
6. What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into remedial action alternatives.

7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-LF-1/
RAA-1
RAA-LF-2/
RAA-2
•
Innovative Technology
No action
Access restrictions/site monitoring
=*===========;========,==,
Estimated Costs
3 Criteria
$0
$220,000'
9 Criteria
$0
; $1,000,000
776
-2-
-------
Alternative
RAA-LF-3/
RAA-3
RAA-4
RAA-LF-4/
RAA-5
RAA-LF-5
•-...•
Innovative Technology
Access restrictions/site monitoring/cap
improvements/landfill gas control/
leachate collection/on-site ground water
extraction wells/discharge of leachate
and contaminated ground water to a
POTW
Access restrictions/site monitoring/cap
improvements/landfill gas control/
leachate collection/on-site and off -site
ground water extraction wells/
discharge of leachate and con-
taminated ground water to a POTW
On-site incineration with off-site ash
disposal/on-site and off-site ground
water extraction wells/discharge of
contaminated ground water to a POTW
Excavation/off-site disposal
Estimated Costs
3 Criteria
$1,300,000
l' ,
not proposed
i
$160,000,000
$60,000,000
9 Criteria
,$5,200,000
$5,700,000
$160,000,000
eliminated
8. If a standard technology was chosen, why?
1 > -1 '
The chosen alternative (RAA-4) includes extraction and treatment of ground water and capping
of the landfill. Furthermore, this alternative provides the most extensive ground water
extraction plan, which will lower the water table and minimize the production of leachate from
laterally moving ground water. Capping reduces exposure to landfill: contaminants and reduces
infiltrations of precipitation associated with leachate generation. It protects the environment by
reducing risks of surface water discharges of contaminants and reduces ground water
contamination. The selected remedy reaches remediation;goals within the shortest amount of
time. This alternative minimizes short-term risk to workers as it does not require excavation.
This alternative was preferred because it is the most cost-effective option. While one other
alternative proposed incineration, which would treat source contaminants in a more permanent
.manner, it would be extremely costly. The chosen alternative was considered cost-effective
since it would meet cleanup levels as quickly as incineration. > . • •
If an innovative technology was chosen, why?

An innovative technology was not chosen.
-3-
777
-------
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? _

Innovative technologies eliminated during the initial screening include the following:

• Solvent extraction was eliminated because the technology would not be. effective with
heterogeneous wastes and is not applicable to all contaminants.
* Composting was eliminated because of the large volume of waste, on-site space
constraints, the lack of data on its effectiveness in treating large volumes of waste, and
the potential health risks associated with associated excavation.
• Dechlorination was eliminated because it would not be applicable to many organic and
inorganic contaminants found on site.
• Wet air oxidation was eliminated because it would not be suited for large-scale solids
handling and contacting and its effectiveness for damp solid waste has not been
demonstrated commercially.

Innovative technologies eliminated during the screening of the three criteria include the
following:

" None

Innovative technologies eliminated during the detailed analysis include the following:

• None , .-••.'
11.
12.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

The criteria that were weighted most heavily in selecting a technology were protection of
human health and the environment and cost-effectiveness. Innovative technologies were not
incorporated into RAAs.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Contaminated surface soils were grouped with the landfill contents in setting remedial action
objectives. No chemical-specific cleanup levels were established for soil. Soil remediation
goals correspond to a maximum cumulative carcinogenic risk range of 10"4 to 10'6 and a
Hazard Index below 1.
778
-4-
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: . ,

• None ' • . • , .'.-'• • |L • •

Standard technologies eliminated because of cleanup goals include:, i
••!-••'
• None l ,
• ' •[

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. i ,
-

15. What measures/criteria -were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Time to reach remediation goals

16. How are measures compared? "
* • " ' , | ' '
The selected alternative was preferred because it is the most cost-effective. The one
alternative that included treatment, and therefore provide a more permanent and Idng-term
solution, was not selected because it was much more costly. Furthermore, the chosen
alternative will reach remediation goals hrthe same amount of time as the other alternative,
and in a shorter time than most other alternatives. ,. - J
17. What technical considerations-were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
' ' • ' \ '
Technical considerations were not primary in selecting a remedial alternative. The nature and
volume of the waste were primary. The site is comprised of a landfill that has waste below
the natural ground water table. This waste is in direct contact with laterally moving ground
. water. Ground water is believed to be the major source of leachate, .which is produced both
by infiltrating precipitation and by ground water moving through the landfill. The selected
alternative was chosen because it addresses both of these problems by preventing the
infiltration of precipitation through capping and lowering the water table with extraction wells.
Both of these actions will act to reduce the production of leachate.
-5-
779
-------
Kohler Company Landfill
OU-1

Kohler, Wisconsin
Region 5
D
GENERAL SITE INFORMATION
7.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal ~
contaminants were:

Waste/Soil (mg/kg)

4-Methylphenol 1.5
PCBs 4.3
Copper 110.
Lead 194
Zinc 207
Cadmium 5.3
Site History
Jt
NPL Proposed: N/A
NPL Final: 1983
FS: 8/91
ROD: 3/92

Background

PRP-lead
PRPs: Kohler Company
FS prepared by: Geraghty & Miller,
Inc. ,
What volume of material is to be remediated?

The volume of material to be remediated included:

» A volume of landfill waste was not provided. The entire landfill spans 40 acres with £
depth ranging from a few feet to 60 feet.
ft)
3. What type of site is this? '

Municipal Landfill. An active landfill surrounded by undeveloped land and a few residences.

TECHNOLOGY SELECTION

4, What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restrictions, fencing
Containment: Capping (concrete, asphalt, soil, single-layer, multilayer, RCRA, clay,
native material, synthetic membrane, inert materials), grout injection,
slurry wall, sheet piling, diversion runoff system
Chemical treatment: Stabilization/solidification, neutralization
780
.1-
-------
Thermal treatment: Incineration (rotary kiln, fluidized bed, circulating bed)
Disposal: Excavation, disposal (off-site, on-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: .

Biological treatment: In situ bioremediation, slurry bioreactor, composting
Phys/Chem treatment: Solid/liquid extraction, soil flushing, soil vapcjr extraction
Thermal treatment: In situ vitrification, thermal extraction
What was the cost estimate for the innovative technology?

9 Criteria
$5,977,000

7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action ,
Institutional controls
Institutional controls/State of >
Wisconsin solid waste cap/leachate
treatment

3C
I
Estimated Costs
nteiria
I/A
N/A
N/A
' ."•.•'. - -2- -
9 Criteria
$0
$89,000
$4,673,600
- . " - " • ' . '
731
-------
Alternative
RAA-4
Standard Technology
Institutional controls/RCRA cap/leachate
treatment
Estimated Costs
3 Criteria
N/A . .
9 Criteria
$7,089,700
8. If a standard technology was chosen, why?

RAA-3 was selected because it will protect human health and the environment by reducing and
controlling potential risks through closure and capping of the landfill. Through containment of
the waste, it minimizes the risk posed by direct contact, inhalation, or ingestion of site-related
contaminants. By reducing filtration, it reduces the potential for contaminant movement from
the waste into the ground water. The institutional controls, by minimizing site access and
controlling land and ground water use, add to the alternative's protectiveness. This alternative
complies with all ARARs and is cost effective. Implementation of RAA-3 poses no short-term
risk to workers and dust suppression techniques will be used,to address the potential for
• paniculate emissions. The technologies used in the chosen alternative are technically feasible,
readily available, easily implemented, and considered reliable. The proposed solid waste cap
will take less time to implement than the hazardous waste cap .proposed in RAA-4.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
JO. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• In situ vitrification-was eliminated because it has not widely been tested and likely
would not be effective for the depth of fill (20 to 40 feet) that exists in many areas.
The heating process in this technology also likely would produce air emissions, which
might require further treatment.
• Soil flushing was eliminated because of uncertainties associated with its effectiveness,
the unproved nature of the treatment, and possible regulatory complications that the
flushing agents could cause. Use of this technology in situ would be impeded by the
difficulties associated with ground water recovery at the site and the prohibition of
injection wells in the State of Wisconsin.
• Soil washing was eliminated because it would require excavation as well as substantial
pilot testing to define the proper washing and extraction agents, and would result in a
residual stream which would require additional treatment or disposal. Finally, other
options are more attractive and certain.
732
-3-
-------
• All biological treatment (in situ bioremediation, slurry bioreactor, composting) was
eliminated because chlorinated compounds, which exist within! the source area, have
been proven difficult to degrade through biological means, llie technology for
biological degradation of chlorinated VOCs is not commercially tested and its
effectiveness is not proved. In many cases, an additional substrate would be required
for microbial development which could cause additional, contamination problems. The
elevated level of inorganic within the fill could inhibit the growth of microbes. Other
technologies are better suited for this site.
• Thermal extraction was eliminated because excavation of the fill material would be
required prior to treatment and this alternative would not be considered viable.
• Ex situ solid/liquid solvent extraction was eliminated because it would not be
applicable to the entire landfill. While potentially applicable ito VOC source areas
after excavation, other options are better suited to these contaminants.
' - ' j
Innovative technologies eliminated during the screening of the three cjriteria include the
following: , ', . '

• None

Innovative technologies eliminated during the detailed analysis include the following:

• Soil vapor extraction (SVE) was originally the recommended option in the Proposed
Plan but it was not the selected remedy in the ROD based on information made
available during the public comment period and in the comments submitted. Public
comments point out that the SVE system is tied directly to grpund water quality since
its primary objective is to reduce the source of VOCs to ground water. The goal of
the SVE system would be to cleanup levels of VOCs in the v/aste to achieve protective
levels of VOCs in the ground water. A determination of cleanup levels for water
cannot take place until ground water cleanup levels are hi place. In addition,,to meet
the stated remedial action objectives, the SVE must be designed and implemented to
remove VOCs from both the vadose and saturated zones of the landfill materials,
which could require the landfill to be dewatered. SVE therefore will be considered an
integral part of the ground water remedy for this site and it will l>e reconsidered when
the ground water alternatives are evaluated.
'i .

11. Which of, the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative ware short-term
effectiveness, implementability, and cost. RAA-3 takes the shortest time to implement because
it has no substantive permit requirements, such as RAA-5's. RAA-3 [also poses minimal risk
to remediation workers and the community during the implementation period. RAA-3 is easier
to implement technically because it requires less construction, and administratively because it
requires less coordination within the Wisconsin Department of Natural Resources and EPA.
Finally RAA-3 is the least costly alternative that affords the protection of closing and capping
the site. The selected remedy is more reliable and can be implemented more quickly, with less
difficulty, and at less cost than the other treatment alternatives. „
-4- i 783
-------
12' ?2?» ofe™"P g0°k Were Jefecterf? # 'fte cfea/"^ *oa/ was based on an ARAR, what was that
AKARf What risk level was selected to establish cleanup goals?

No soil cleanup levels were established. ,
75.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

« None

Standard technologies eliminated because of cleanup goals include:

" None
14.
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Time to design/construct/operate
Waste left in place/institutional control

16. How are measures compared?

The chosen alternative Was selected because it will take the least time to implement RAA-3
will take 8 months, RAA-4 would take 12 months, and RAA-5 would take at least 12 months
but could be delayed further because of the need to conduct treatability studies. The chosen
alternative is cost effective because while RAA-2 is less expensive, it does not provide long-
term effectiveness. Furthermore, RAA-4 and RAA-5 are more expensive than the chosen
alternative and they do not provide a proportional increase in effectiveness. Institutional
controls only were not selected because they would not be as protective as capping and they
would not meet ARARs for landfill closure.
77.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative; however, the
landfill depth (20 to 40 feet) precluded the use of in situ vitrification.
734
-5-
-------
La Grande Sanitary Landfill

La Grande Township, Minnesota
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Landfill waste was not sampled. Sediments
surrounding the landfill were sampled in
order to determine if there were isolated
areas of contamination. No specific "hot
• spots" were identified; therefore, site
remediation focuses on the landfill.

Sediments/Surrounding Landfill (rag/kg)
Arsenic
Manganese
12.4
525
Site History
!'
NPL Proposed: N/A
NPL Final: ; 6/87
FS: 7/92
ROD: | 9/92
1
l
Background

EPA Fund-lead ;
PRPs: Francis C. fcosgrove, Marlin F.
Torguson, Valley Disposal Corp.
FS prepared by: Malcolm Pimie
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 500,000 cubic yards of waste

3. What type of site is this?

Municipal Landfill. A former landfill located in a rural area.
TECHNOLOGY SELECTION ,
i
I -
4, What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible.
technologies were:

Access restriction: Deed restrictions
Containment: Capping, slope stabilization
Thermal treatment: Incineration
Disposal: Excavation, on-site disposal, off-site disposal
-1-
735
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: '

No innovative technologies were identified.
«* * ^

6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Long-term gas and ground water
monitoring/construct gas vent well/seal
old Shop Well
Long-term gas and ground water
monitoring/construct gas vent well/
seal old Shop Well/slope stabilization/
institutional controls
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria

$279,000
$361,000 to
$501,000"
•Cost depends on the specific version of slope stabilization that will be used.
8. !f a standard technology was chosen, why?

RAA-3 was selected because it provides the greatest protection to human health and the
environment and long-term effectiveness of all of the proposed alternatives. Long-term
monitoring will provide a direct indication that contaminant levels remain within health-based
ground water quality standards. Monitoring combustible gas also will act to indicate changes
in health risks related to the landfill. RAA-3 provides the maximum long-term effectiveness
because it includes stabilization of the western slope of the landfill and covering of exposed
waste. This technology is likely to reduce the amount of precipitation entering the landfill
736
-2-
-------
waste and reduce the potential for failure of the existing final cover system. Toxicity,
mobility, and volume of landfill contaminants will be minimized in thp future by slope
stabilization and the covering of exposed waste. This action helps to prevent the leaching of
contaminants from the landfill into the environment. The sealing of the old Shop Well
eliminates the potential for noncarcinogenic risk posed by the well by eliminating it as a
source of potable water. The conversion of a combastible gas monitoring, well to a gas vent
well will reduce the potential for gas buildup. Institutional controls ensure that active controls
remain effective. This alternative will be easily implemented in a short time. Services are
readily available in the area and on-site materials likely can be used for slope stabilization and
cover for the exposed waste. This remedy complies with all ARARs jand it is cost effective.

9. If an innovative technology was chosen, why? j
• i '
An innovative technology was not selected. J •

10. If an innovative technology was not chosen, why not? At what stage \vqs the innovative
technology eliminated? ; '

Innovative technologies eliminated during the screening of the three criteria include the
following:

• ' • None . . • . !' ' , . . ' . ; - '

Innovative technologies eliminated during the detailed analysis include the following:

• None - ' • .. ; • . .: • • ;! • - ' • . • • •

11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine, criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Long-term effectiveness, implementability, and cost were the criteria weighted most heavily in
selecting a remedial alternative. RAA-3 ensures that the low-level risks at the site will
continue to be monitored to verify the effectiveness of the remedy's minimal construction
comppnents over the long term. Because it requires minimal construction and restoration
activities, it is easily implementable. Finally, when primary balancing criteria are compared,
the remedy is cost effective. ,
-3-
737
-------
12.
w
What risk level was selected to establish cleanup goals?
°n an ARAR'
No Cleanup levels were selected. The results of the human health risk assessment indicate that
the total potential increased cancer risk from possible exposure of residents to ground water at
tie site ,s about 9 in 100,000 for adults and 4 in 100,000 for children. These risks are wiSuV
UFA s acceptable risk range and are largely attributed to arsenic in ground water Further
arsenic is naturally occurring throughout the site and the RI indicated that the landfill did not
appear to be the a source of arsenic. Total pathway Hazard Indices for the possible exposure
of residents to ground water are 1.8 for adults and 4.2 for children. This risk is largely due to
manganese in the ground water and is based on the levels of manganese in the old Shop Well
Manganese is also naturally occurring and the landfill does not seem to be a source of elevated
manganese levels.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

. Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Waste left in place/institutional control
16. How are measures compared?

Because the site poses a low-level threat, many identified technologies that would have
required excavation or increased construction activity were eliminated. For example
technologies such as capping and off-site disposal were eliminated because their increased
snort-term nsk and additional costs could not be justified.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
758
-4-
-------
Lemberger Landfill, Inc.
OU-1

Franklin, Wisconsin
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

Aldrin
Antimony
Arsenic
Benzo(a)pyrene
Beryllium
Dieldrin
Barium
Chromium (+3)
Chromium (+6)
Copper
Cyanide
Lead
Manganese
Mercury
Nickel
Selenium
Vanadium
Zinc
0.24
0.0062
0.0085
0.092
0.006
0.2
0.118
0.104
0.104
0.0751
0.0105
0.485
0.843
0.0011
0.0328
0.00093
0.0515
0.699
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
LL site: 6/86
5/10/91
9/23/91
i •
Background

EPA Fund-lead
PRPs: Lemberger Landfill, Inc.,
Lemberger Transport &
Recycling, Inc.
FS prepared by: B&V Waste Science
and Technology Corp.
2. What volume of material is to be remediated?
' . : ' • ' - ,
The volume of contaminated soil was not determined separately from the volume of wastes
deposited in the landfill. The volume of wastes in the Lemberger Landfill, including daily
cover, but excluding the final cap, is .estimated at 479,000 cubic yard's. With the final cap, the
volume of waste is estimated at 565,000 cubic yards. [
What type of site is this?

Municipal Landfill. The site contains two closed landfills, the Lemberger Landfill, Inc. facility
(sanitary landfill) and the Lemberger Transport and Recycling, Inc. facility (hazardous waste
landfill). The site is located in a rural area. ;
-1-
789
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? •

Standard technologies considered during the identification and screening of technically feasible
technologies we-e:

Access restriction: Deed restrictions, fencing
Containment: Capping (native soil, clay, soil/synthetic membrane, asphalt, asphaltic
concrete, concrete, multilayer, chemical sealants/stabilizers), surface ,
controls (soil stabilization, revegetation, drainage controls), vertical
barriers (slurry wall, grout curtain, sheet piling, vibrating beam, rock
' grouting), horizontal barriers (grout injection, block displacement)
Chemical treatment: Stabilization
Thermal treatment: Rotary kiln, fluidized bed, multiple hearth furnace, circulating bed,
high temperature wall reactor, infrared
Disposal: Off-site RCRA disposal, on-site RCRA disposal, on-site waste piles
J
5.
Was an innovative technology considered in the FS? If so, which technology? (

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Bioreclamation/aerobic respiration, composting, landfarming
Pnys/Cnem treatment: Solvent extraction, soil washing (chemical), soil flushing, oxidation,
vapor extraction, soil washing (aqueous)
Thermal treatment: Molten salt, low-temperature thermal separation, vitrification, plasma
arc torch pyrolysis
6.
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-8
Innovative Technology
Excavation/on-site incineration (molten
salt)
Estimated Costs
3 Criteria
N/A
9 Criteria
eliminated
790
-2-
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
&
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
Standard Technology
No action
Institutional controls
Clay cap/institutional controls
Multilayer cap/institutional controls
Clay cap/slurry wall/institutional
controls
Multilayer cap/slurry wall/institutional
controls
Excavatioh/on-site incineration (rotary
kiln)
Estimated Costs
3 Criteria
N/A
N/A
-.- N/A
N/A
N/A
N/A
N/A
i
9 Criteria
$0
$0
$9,195,000
$10,795,000
$9,910,000
eliminated
eliminated
If a standard technology was chosen, why?

RAA-5 minimizes the risk of on-site receptors coming into contact with contaminants and the
migration of contamination off site as a result of wind or surface water erosion. The clay cap
and slurry wall work in conjunction to minimize the amount of water entering the waste areas
and to reduce the amount of leaching. Institutional controls such as diced restrictions and
fencing help maintain the integrity of the cap over the long run. RAA:-5 meets all ARARs,,
presents little short-term risk, and is easily implemented. In addition,: the slurry wall protects
the public and environment to a greater extent than capping alone beciause the wall prevents
ground water from flowing through the wastes and minimizes the migration of contaminants
away from the site. ., ,; '•-•'"'
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative.
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the |three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
-3-
7.91
-------
Innovative technologies eliminated during the initial screening include the following:

• Bioreclamation/aerobic respiration was eliminated because it would not be feasible for
the varied wastes found in landfills. The technology would not be effective for
treatment of metals, which might inhibit the activity of the microorganisms
" Composting was eliminated because it has not been proved on a full-scale operation
for hazardous waste.
" Land/arming was eliminated because it would be more suitable for industrial sludges
and wastewaters, not for the municipal solid wastes at the site.
• Solvent extraction was eliminated because it would be most effective in removing
organic contaminants, not municipal wastes.
• Plasma arc torch pyrolysis was eliminated because it would be applicable only to
liquid organic wastes and finely divided, fluidizable sludges.
" °xi
)
77.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Cost-effectiveness, protectiveness, and short-term effectiveness were weighted most heavily in
selecting the remedial technology. RAA-8 (molten salt destruction) and RAA-7 (rotary kiln
incineration), were eliminated because of their relatively high cost and the short-term risks
posed by excavating contaminated wastes. The selected remedy, RAA-5 (capping and slurry
wall , satisfies statutory requirements for protectiveness, poses little short-term risk, and is
highly cost-effective.
732
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (fig/kg)
ARAR or Other Basis
Carcinogens
Aldrin
Arsenic
Benzo(a)pyrene
Beryllium
Dieldrin
20
200
50
320,000
20
Risk"
Risk
Risk
Risk
Risk
Noncarcinogens
Antimony
Barium
Cadmium
Chromium (+3)
Chromium (+6)
Copper
Cyanide
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
30,000
3,200,000
30,000
65,000,000
320,000
2,400,000
1,300,000
40,000
13,000,000
20,000
1,300,000
200,000
200,000
450,000
13,000,000
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
ELisk
Risk
Risk
Risk
Tor carcinogens, an excess upper bound individual lifetime cancer risk of 10^ was
acceptable. For noncarcinogens, a Hazard Index less than or
equal to 1,0 was
acceptable.
-5-
793
-------
13.
hnolome~*
tecnnology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include

• None
- . \ •.

Standard technologies eliminated because of cleanup goals include:

• None ,
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
.75. . What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

• Cost-effectiveness
• Impact on nearby populations
• Protectiveness of human health

16. How are measures compared?
°n nearby P°PuIations> and Protectiveness of human health were
RAA'1 ^d RAA-2 would not provide .
RAA 5r , C°ntaminants- RAA'3 and RAA-4 would not be as protective as
c^tmin^d they W°U n0t ^^ a slui^ wa» Deduce ground water flow through the
contammated area thereby preventing the.migration of contaminants away from the site Site
assessors judged that RAA-6, which would employ a multilayer cap as opposed to a clay cap
would provide a greater degree of protectiveness than needed at the site and so was le s cosf

°
to° costly and potentially threatening to nearby populations
17. W}iat technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting the final remedy.
794
-6-
-------
Main Street Well Field
OU-2

Eikhart, Indiana
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil and Paint Layer Soil (mg/kg)

, • Trichloroethene (TCE) 88

Excel Property Soil (mg/kg)

Trichloroethene (TCE) 570

Durakool Property Soil (mg/kg)

Trichloroethene (TCE) 5
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
12/82
9/83
12/90
3/29/91
Background

EPA Fund-lead ;
PRPs: Excel Industries; Durakool, Inc.
FS prepared by: Donohue and
Associates, Inc.
2. What volume ~of material is to be remediated?

The volume of material to be remediated included:

" 22,000 cubic yards of soil
• 2,000 cubic yards paint layer soil !

i • " i ' '
i ,
3. What type of site is this? '''•'•,
' ' ' • ' •!
Fabricated Metal Products. A waterworks well field that serves as the primary water supply
for Eikhart, Indiana contaminated by msssufaetuiers supplying parts to the auto industry.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: _ 1 -
-1-
795
-------
Soil

Access restriction:
Containment:

Chemical treatment:
Thermal treatment:

Disposal:
Physical treatment:

Paint Layer Soil

Thermal treatment:
Deed restrictions, fencing
Slurry wall, grout curtain, sheet piling, bottom sealing, RCRA cap,
non-RCRA cap, entombment, macroencapsulation
Carbon adsorption, solidification (cement-based, pozzolanic-based,
thermoplastic-based, organic polymer-based), in situ stabilization,
sorbents, stabilization by ion exchange resins
Incineration (fluidized bed, rotary kiln, infrared, high- temperature
fluid wall reactor, blast furnaces, centrifugal reactor
Off-site secure landfill, on-site secure landfill
In situ soil flushing (water)
Off-site RCRA incineration
.1)
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: - :

Biological treatment: Aerobic treatment, anaerobic treatment, in situ biological treatment,
land treatment, white rot fungus
Chemical treatment: Solvent extraction, supercritical extraction, soil washing (surfactant),
dehalogenation
Physical treatment: In situ vacuum extraction, electroacoustical soil decontamination,
electrokinetic removal
Thermal treatment: Molten salt combustion, in situ heating, in situ vitrification, in situ
steam extraction, low temperature thermal desorption, pyrolysis,
ground freezing, high-temperature slagging
6. Wliat was the cost estimate for the innovative technology? - '

RAA-7

•"' i 11—

RAA-8

—

RAA-9

" II.—

RAA-10

"•"• i •

RAA-13
Standard Technology
—
Off-site secure landfill/maintain
interceptor wells and air stripping unit
~~~~~~~————————_________
Limited action: new interceptor wells/
maintain production well and air
stripping system
— '•
Non-RCRA cap/new interceptor wells/
maintain production well and air
stripping system
....
On-site rotary kiln incineration/new
interceptor wells/maintain production
well and air stripping system

Off-site secure landfilVnew interceptor
wells/maintain production well and air
stripping unit
Estimated Costs
3 Criteria
——•»•.

N/A

—OBV^OB.

N/A

—»——™«.

N/A

~^-^^—^—.

N/A
This RAA is one of the five alternatives retained for further screening

Va standard technology was chosen, why? '

A standard technology was not chosen
9 Criteria
—
eliminated
eliminated
9.
JO.
Van innovative technology was chosen why?
not
? At •**
Innovative technologies eliminated during the initial screening include the following:
wo"ld
Aerobic treatment, anaerobic treatment, in situ biological treatment and land
treatment were eliminated because the concentration/of site metals
798
-4-
-------
• • \
microbial growth, and products of microbial degradation would persist and be more
toxic than existing contamination.
" White rot fungus was eliminated ^ause the concentrations of site metals would
inhibit fungal growth. The fungus is not readily amenable to in situ applications
because it requires oxygen and is less mobile in soil than bacteria. The technology has
not been proved effective outside the laboratory.
• Supefcritical extraction was eliminated because the process requires a pumpable
media. !
" Electrokinetic removal was eliminated because they are not applicable for the treatment
of volatile organic compounds (VOCs).
• Dehalogenation was eliminated because they are not applicable for the treatment of
volatile organic compounds (VOCs).
• Electroacoustical soil decontamination-was eliminated because the technology is still
being evaluated and is unavailable for commercial application.
• High temperature slagging was eliminated because it is unavailable in the U.S. for
treatment of hazardous waste.
• Molten salt combustion was eliminated because the high ash content of the
combustible material necessitates continuous ash removal and change of the molten
salt. The technology is still in development and adequate performance is not
guaranteed.
• In situ heating was eliminated because it is not commercially available.
• In situ vitrification was eliminated because the configuration of the site does not make
this a viable option; volume is reduced 25% and the vitrification cannot be controlled
enough to ensure building stability; not cost effective for use iii hot spot areas.
• Pyrolysis was eliminated because it has limited full-scale demonstrated success;
available units have limited processing capacity; and costs are Mgh.

Innovative technologies eliminated during the screening of the three criteria include the
following: •
I •
I
• Solvent extraction was eliminated because it had not yet been fully developed for
hazardous waste treatment and is more effective for treating PGBs, pesticides, and
polynuclear aromatic compounds than VOCs.
• Soil washing was eliminated because it would not be applicable for soils.
• In situ soil flushing was eliminated because in situ vacuum extraction would be more
applicable for treatment of VOC-contaminated soils and is monS easily implemented
i for the treatment for soils underneath buildings. ,
• In situ steam extraction was eliminated because in situ vacuum extraction would be
more cost-effective for removing VOCs.
. . • I;
Innovative technologies eliminated during the detailed analysis include ^he follow,ing:

• Low-temperature thermal desorptwn was eliminated because it is 1) costly, 2) would
require excavation, 3) would trigger RCRA LDRs and regulations for closure that
would be difficult to implement on site because of the large volume of soil and the
restricted space at the site, 4) would disrupt business operations, 5) would require
bracing and building support, 6) implementation would be in a confined working area
and would be disruptive to surrounding residential areas, 7) once mobilized, would
have to complete all soil treatment because remobilization is costly..
-5-
799
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
t* meet one of the nine criteria result in the elimination of the innovative technology? If so,
*h criterion? Which of the criteria supported the use of a standard technology?

Cost, long-term effectiveness, and short-term effectiveness were weighted most heavily in the
selection of the technology. Cost-effectiveness and implementability were important in
eliminating low-temperature thermal desorption.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant Cleanup Level (mg/kg) ARAR or Other Basis
Carcinogens
Trichloroethene
0.1
Risk
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10J? to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
73. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: '

• None , .

Standard technologies eliminated because of cleanup goals include:

• None .--..-

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives? - '

The following measures were used to compare the alternatives:

Risk level achieved
Total cost ,
Preference for treatment (vs. containment)
Time to design/construct/operate .
Impact on nearby populations
SDO'
-6-
-------
1
16. How are measures compared? ]' '

Only alternatives that could achieve a IxlO'6 or less excess cancer risk level for either the
current or future risk scenarios were retained for evaluation during the detailed analysis. Of
those alternatives, cost-effectiveness was a primary consideration in the comparison and
elimination of alternatives. Treatment alternatives were preferred ovei; containment to control
the source of contamination and to achieve the desired risk levels. Also, contaminated soils
near the on-site buildings are not readily accessible; Therefore technologies such as low-
temperature thermal desorption would be difficult to construct and operate.
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The presence of buildings on the site was a primary technical consideration in selecting a
remedy. Innovative technologies, such as low-temperature thermal desorption that require
excavation of soil or reduce soil mass during treatment, were eliminateid because of potential
damage to building structures.
-7-
801
-------
Michigan Disposal Service
(Cork Street Landfill)

Kalamazoo, Michigan
Region 5
GENERAL SITE INFORMATION

J. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Landfill Contents (mg/kg)
2.
Arsenic
Barium
Chromium
Manganese
20
126
15
292
What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/87
8/90
4/26/91
9/30/91
Background

PRP-lead
PRPs: City of Kalamazoo, Michigan
Disposal Services
FS prepared by: Canonic
Environmental Services Corp.
The volume of material to be remediated included:

• 1.8 million cubic yards of soil and waste , '

What type of site is this?

Municipal Landfill. The site is a Type III landfill operated by the Michigan Disposal Service
(MDS). In the past, when the site was used as a municipal landfill and contained an
incinerator, incinerator ash was disposed of on the landfill. The immediate area is industrial;
the general area is mixed industrial, commercial, and residential.
TECHNOLOGY SELECTION

4. What standard technologies -were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Institutional controls (fencing, deed restrictions, zoning)
Containment: Capping (clay, multimedia), surface controls/dust controls (diversion "
channels, site regrading, revegetation, and dust suppressants),
horizontal barriers (liners, injection grouting) '
802
-1-
-------
Chemical, treatment:
Physical treatment:
Thermal treatment-
Disposal:
Lime neutralization, solidification/stabilization;
Ambient temperature aeration, aeration, solids jprocessing/size reduction
On-site incineration, off-site incineration
Excavation, on-site disposal (backfill, RCRA landfill, storage
permanent or temporary), off-site disposal in RCRA landfill
5. Was an innovative technology considered in the FS? If so, which technology?
•\
!' • •
Innovative technologies considered during the identification and screening of technically
feasible technologies were:
- 1
Biological treatment: Composting, nutrient enhancement, enhanced aerobic biodegradation
Chemical treatment: Oxidation/reduction, liquified gas solvent extraction, solvent leaching,
• • •" , in situ soil flushing . i
Thermal treatment: Vitrification, low-temperature aeration, pyrolysis, freeze crystallization,
in situ vacuum extraction/soil aeration, in situ!radio frequency heating,
steam flushing, thermal stripping
6. What was the cost estimate for the innovative technology?
• '- =..!-.*,•
1 ' I
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during a!n evaluation based on
nine criteria established by the NCP. No innovative technologies wei?e developed into RAAs.
rl '
How did the cost(s) compare to standard technologies? i

Cost Estimates for RAAs That Include Standard Technjolojjies
(selected remedial alternative is in bold)

Alternative
RAA-1
RAA-2

RAA-3

Innovative Technology
No action
Institutional actions (fencing, posting
signs, deed restrictions, 5-year reviews)/
ground water treatment/ management of
migration
Institutional actions (fencing, posting
signs, deed restrictions, 5-year
reviews)/grading with clean fill, 2-foot
clay cap, topsoil, vegetation/ground
water treatment/management of
migration
Estimated Costs
3 Criteria
Kf/A
N/A
I

" • "
N/A

9 Criteria
$0
eliminated

$6,119,5010

-2-
803
-------
Alternative
RAA-4
RAA-5
RAA-6
RAA-7
Innovative Technology
Institutional actions (fencing, posting
signs, deed restrictions, 5-year reviews)/
grading and surface water diversion/
topography development by using the
site as a Type m landfill, 2-foot clay
cap, topsoil, vegetation/ground water
treatment/management of migration
Removal (and later replacement) of
Type HLsolid wastes/excavation/on-site
high-temperature incineration (rotary
kiln used as representative)/sampling of
soil and residuals/on-site disposal of
treated soils and residuals as backfill/
stabilization of treated soils and
residuals/grading/surface water
diversion/2-foot clay cap, topsoil,
vegetation, ground water treatment/
management of migration
Removal (and later replacement) of
Type HI wastes/excavation/off-site
disposal/backfilling (with old and new
Type in wastes, inert materials, or clean
fill)/grading/surface water diversion/
topsoil and vegetation (unless Type HI
operations continue)/ground water
treatment/management of migration
Institutional actions (fencing, posting
signs, deed restrictions, 5-year reviews)/
grading/surface water diversion/topo-
graphy development by using the site as
a Type IE landfill, 3-foot clay cap, 2-
foot protective soil layer, topsoil,
vegetation/ground water treatment/
management of migration
Estimated Costs
3 Criteria
N/A"
N/A
N/A
N/A
9 Criteria
$4,646,000
$519,800,000
to
$611,600,000
eliminated
$8,418,000
S. If a standard technology was chosen, why?

RAA-3 was chosen because the technology will effectively, contain the source of the
contamination, the cap will prevent exposure by direct contact, and the cap will minimize the
production of leachate by preventing movement of precipitation down through the wa^te. The
cap will reduce ground water contaminant loading to the aquifer, allowing the restoration of
the aquifer in a reasonable time frame. This alternative is preferred over other cap alternatives
because the cap is less likely to fail as a result of the higher compaction level of clean fill over
Type III waste. Short-term risks are reduced due to the short construction time, just 1 year.
804
-3-
-------
9. If an innovative technology was chosen, why? • • :, •
• ' • ' ' r
An innovative technology was not chosen. !
•'' • • •
.1
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? :

Innovative technologies could be eliminated from/the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening includes the following:
' ,.'.!' '
i
• Solvent, leaching (extraction) was eliminated because this technology has not been
tested on a full scale for removing VOCs in'the site's soils arid the technology would
not be effective for heterogeneous waste. Hie solvent waste (Stream would require
treatment, resulting in high operational costs. ! '
. • Oxidation/reduction was eliminated because the technology would be ineffective with
the site's heterogeneous waste and the presence of decaying cirgaitiic materials might
produce undesirable oxidized compounds. ! ,
• Liquified gas solvent extraction was eliminated because the process has not been tested
on a full scale for removing the site's chemicals; the technology would not be effective
for heterogeneous waste; the process generates a waste stream, which would require
additional treatment and disposal; and the technology would be costly.
• Freeze crystallization was eliminated because the technology jis best suited for sludge
treatment, which is not needed at the site. ]
» Low-temperature aeration was eliminated because the technology would not be
applicable for treating or removing PCBs. [
• Composting was eliminated because the heterogeneous nature of the waste would not
allow oxygen to reach all parts of the waste; benzene is present at very low
concentrations and could not support microbial activities; and composting would
neither degrade PCBs nor reduce the metals in the soil matri?;.
• Nutrient enhancement was eliminated because the heterogeneous nature of the waste
would not allow oxygen to reach all parts of the waste; benzene is present at very low
concentrations and could not support microbial activities; and, nutrient enhancement
would neither degrade PCBs nor reduce the metals in the soili matrix.
" Enhanced aerobic biodegradation (in situ) was eliminated because the physical site
conditions would not be suitable for the technology, the technology would require a
fairly homogeneous waste to be implemented effectively, and the technology would
primarily treat organic waste. '..-...
• Steam flushing was eliminated because the physical site conditions would not be
suitable for the technology, the technology would require a, fairly homogeneous waste
to be implemented effectively, and the technology would treat primarily organic waste.
• Thermal stripping was eliminated because the physical site conditions would not be
suitable for the technology, the technology would require a fiiirly homogeneous waste •
to be implemented effectively, and the technology would treat primarily organic waste.
• Vitrification was eliminated because the physical site conditions would not be suitable
for the technology, the technology would require a-fairly homogeneous waste to be
implemented effectively, and the technology would treat primarily organic waste.
-4-
805
-------
• In situ soil flushing was eliminated because the process might affect the City of mmw
Kalamazoo drinking water supply wells; the heterogeneous nature of the waste would ^•^ '\
impede uniform and effective treatment; treatment of water prior to injection often V;
changes the inorganic chemical characteristics (e.g., pH, TDS, and hardness) of
extracted ground water, which might clog the injection system or the aquifer
formation; sediments, air bubbles, and microbial action might clog the injection
system; and maintenance costs are relatively high.
" In situ vacuum extraction/soil aeration was eliminated because soil aeration would not . '
remove the low levels of semivolatiles and PCBs, or the metals detected in the
leachate and soil matrix; and the heterogeneous nature of the waste would preclude
uniform treatment of the waste.
• In situ radio frequency heating was eliminated because a pilot study would be required !
to determine the applicability of this process to the site chemicals and conditions. In
addition, the technique would be too costly. j
• Pyrolysis was eliminated because rotary kiln incineration was selected to represent all
high-temperature technologies. "A

Innovative technologies eliminated during the screening of the three criteria include the _ ' •
following:

• None r
. i
Innovative technologies eliminated during the detailed analysis include the following:
'
• None

The criteria weighted most heavily in selecting a remedy include long-term and short-term J *
effectiveness. Because this alternative uses clean fill to develop acceptable grades at the site
instead of Type IH waste, handling the material during remediation poses less risk. The
heterogeneous nature of Type HI waste would impede adequate compaction of the fill layer,
which could later cause the cap to settle and crack. Furthermore, because Type HI waste, by
definition, poses a greater risk to the ground water than clean fill, RAA-3 would pose less of a "
risk if the cap did fail.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that '
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels are not determined. Successful remediation was based on preventing arsenic
from leaching into the ground water using actions which substantially reduce or eliminate the
infiltration of precipitation.
806
-5-
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
' 'I
Innovative technologies eliminated because of cleanup goals include:

• None ' I •" '

Standard technologies eliminated because of cleanup goals include: ;

• None i .

i ' '
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

15. What measures/criteria were used to compare alternatives? i

The following measures were used to compare the alternatives:

- Risk level achieved
Time to design/construct/operate
Total cost --,'.",.
Waste left in place/institutional control . |

16. How are measures compared?
i ' ' •
The time required to construct the remedy was considered with regard to risk to workers
during construction; RAA-3 requires the shortest construction time. Risk reduction-is
discussed in relation to the three capping alternatives, in that very little change in risk would
be experienced due to cap permeability. Also, RAA-4 and RAA-7 would pose a greater risk
to ground water than RAA-3 because Type HI waste has a greater possibility of releasing new
chemicals. Risk level is also discussed in relation to RAA-5 because pf exposure during
transportation and treatment, and that it will provide the maximum lei/el of risk reduction >
through incineration. During the three-criteria screening, the FS states that: "Alternatives
providing effectiveness and implementability similar to that of a another alternative ...... but at
greater cost, are eliminated." Alternative RAA-6 was eliminated partly because it would not
satisfy SARA statutory preference against off-site disposal of materials.
• •
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
' 'i
Technical considerations were not primary in selecting a technology, j
-6- ! 807
-------
Motor Wheel, Inc.
OU-1

Lansing, MI
Region 5
J
GENERAL SITE INFORMATION
7.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Fill Material (mg/kg):

Dieldrin 0.737
4,4-DDT 0.05
Bis(2-ethylhexyl)phthalate 1.308
PAHs 0.323
Heptachlor Oi059
Zinc 0.244
Site History
NPL Proposed: ,
NPL Final:
FS:
ROD:
N/A
10/4/86
5/91
9/30/91
Background

PRP-lead
PRPs: Motor Wheel Corporation, W.R.
Grace & Co., Goodyear Tire and
Rubber Company
FS prepared by: ENSR Consulting
and Engineering
What volume of material is to be
remediated?

The volume of material to be remediated included:

• 210,000 cubic yards of soil and debris
3. What type of site is this?

Industrial Landfill. An inactive industrial waste disposal site. Earlier quarrying activities
resulted in a large sand and gravel pit in the site's northern portion.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
80S
Fencing, deed restriction
Capping (multimedia, soil, synthetic geomembrane, concrete, asphalt,
and clay), surface grading, revegetation, surface diversipn and
collection systems, soil stabilization, grout injection
-1-
-------
Chemical treatment:
Thermal treatment:
Disposal:
Fixation/stabilization
Incineration
Excavation, off-site landfill, on-site RCRA cell
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: •',!'.'
• ' ''
1 ' ' . • 'i" • ' '
Biological treatment: Bioremediation I
Phys/Chem treatment: In situ soil vapor extraction, oxidation, reduction, soil flushing, solvent
extraction .
Thermal treatment: In situ vitrification, low temperature thermal clesorption
What was the cost estimate for the innovative technology? ' .

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. 'After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation, For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. The estimated costs were recalculated in the ROD.

Cost Estimates for RAAs That Include Innovative Technolo;pes
(selected remedial alternative is in bold)
Alternative
RAA-6
Innovative Technology
Same as RAA-5, .plus in situ soil vapor
extraction
Estimated Costs
9 Criteria
$21,096,400
ROD
$32,169,800
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is In bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action/ground water monitoring
Fencing/deed restrictions/ground water
monitoring
Estimated Costs
9 Criteria
$1,941,200
$2,522,600
ROD
$1,941,200
$2,522,600
-2-
809
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-7A'
RAA-7B*
RAA-8"
Standard Technology
Soil or multimedia cap/surface
grading/revegetation/surface water
diversion and collection/fencing/deed
restrictions/ground water monitoring
Same as RAA-3, plus ground water
extraction wells/ground water treatment
Multimedia cap/surface grading/
revegetation/surface water diversion
and collection/hanging slurry wall/
fencing/deed restrictions/ground
water monitoring
Excavation/off-site disposal in a RCRA
landfill/cap unexcavated fill/ ground
water extraction wells/ground water
treatment
Excavation/on-site disposal in a RCRA
cell/cap unexcavated fill
Excavation/on-site incineration/cap
unexcavated fill/slurry wall/ground
water extraction/ground water
treatment/fencing/deed restrictions/
ground water monitoring
Estimated Costs
9 Criteria
$7,768,100
$17,253,700
$19,646,900
'$160,854,400
$41,313,400
$145,552,800
ROD
$9,804,100
$26,352,600
$30,720,000
$160,854,400
$41,313,400
$154,590,100
*In addition to the excavation of all fill materials, the FS also considered the excavation of
"hot spots" and capping of unexcavated waste with a multimedia cap. The costs to excavate
"hot spots" only for RAA-7A, RAA-7B, and RAA-8 were estimated to be $32,227,300,
$31,922,900, and $22,705,500 respectively. The partial excavation of fill was not considered
in the ROD.
5. If a standard technology was chosen, why? ,

A multimedia cap (Michigan Act 64) was selected as the remedy, because 1) it would reduce
leachate generation from infiltration through the landfill and eliminate further contamination of
ground water, 2) reduces direct human contact risks, 3) cost effective, 4) treatment not
practical due to type of waste (landfill).
9. If an innovative technology was chosen, why?,

An innovative technology was not chosen.
810
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage iWs the innovative
technology eliminated? -

Innovative technologies eliminated during the initial screening include the following:

• Low temperature volatilization was eliminated because it would not be applicable for
all site contaminants.
• Solvent extraction was eliminated because it would not be applicable since all
compounds present can be treated.
• Soil flushing was eliminated because it would not be applicable. It is not possible to
effectively flush the heterogeneous subsurface of a landfill. Not all compounds can be
treated using this method. • L
• Bioremediation was eliminated because it would not be applicable. It is not possible
to effectively injeet nutrients into the heterogenous subsurface of a landfill. Not all
compounds present can be treated by this method.
• In situ vitrification was eliminated because it would not be applicable. The technology
is still in the developmental stage and has not been proved for deep applications.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None ' ' . • . • • '
.... ! • '
Innovative technologies eliminated during the detailed analysis include the following:
I '
• In situ soil vapor extraction was eliminated because the heterogeneous nature of the
waste would make it difficult to implement.
'

11. Which of the nine criteria were weighted most heavily in selecting this technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a technology were protecitiyeness of human
health and the environment, and overall cost-effectiveness. Due to the site's variable terrain,
implementability also was an important criterion.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

There are no chemical-specific ARARs provided for soil. The selected remedy, capping,
prevents human and animal exposure (dermal and ingestion) to contaminants.

The results of the human health risk assessment were within EPA acceptable levels. For
carcinogens an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6 was
acceptable. For noncarcinogens a Hazard Index less than or equal to 1.0 was acceptable.

811
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? -

Innovative technologies eliminated because of cleanup goals include:

« None

Standard technologies eliminated because of cleanup goals include:

• None '

14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. • *

75. What measures/criteria were used to compare alternatives?
• ,
The following measures were used to compare the alternatives:

Cost-effectiveness , . "
Time to design/construct/operate , 'sjgh.
Proven reliability IMF
! ','•'' '-^^^^

16. How are measures compared?

Although the chosen remedy might require more time to achieve compliance with ground
water ARARs, it is proven to be reliable. Since the risks from exposure were within EPA's ' \
acceptable risk range, containment was considered an adequate remedial option. . I
.
'
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ,

The topography of the fill mass and the amount and variety of waste contained in the fill were
factors in selecting a remedy. Quarrying activities created a sand and gravel pit, excavated to
a depth of 50 feet, with relatively steep side walls. The near vertical slope of the sand and
gravel pit might present technical challenges to cap installation. In addition, the installation of
a hanging slurry wall could be difficult due to the site's topography and geology. " !
1 ' '•'"''!
The only innovative technology considered in the FS, in situ soil vapor extraction, was • !
eliminated because the heterogeneous nature of the waste in the fill mass .would make it '
difficult to implement. Materials identified in the fill matrix are soils, railroad ties, tires,
vesicular and glassy slag, demolition debris, asphalt, plastic* and glass fragments. Along with :
the solid wastes, liquid wastes were disposed of on the site. The success of soil vapor
extraction would depend on the degree to which distinct volumes of materials containing lib 'v
volatile organic compounds could be located within the waste. ^»*^ /

812 : ;
-------
Muskego Sanitary Landfill

Muskego, Wisconsin
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

Benzene
Toluene
Ethylbenzene
Xylene
Acetone
2-Butanone
4-Methyl-2-pentanone
Isophorone
13
130
24 '
100
7.1
13
29
3.6
Site History
NPL Proposed:
NPL Final:
FS:
Interim ROD:
N/A
9/18/85
11/91
6/12/92
Background

PRP-lead J
PRPs: Waste Management of
Wisconsin j
FS prepared by: Warzyn Incorporated
Soil in Drum and Refuse Trench Areas mug/kg)

Phenol 3.2
,2-Methylphenol 0.43
4-Methylphenol . . 0.55
Benzoic acid 0.17
Naphthalene 5.6
2-Methylnaphthalene 1.3
Phenanthrene 0.11
Pyrene 0.082
Chrysene 0.081
Benzo(a)pyrene 0.14
Ideno(l,2,3-cd) pyrene 0.21
Dibenzo(a,h)anthracene 0.23
Benzo(g,h,i)perylene 0.19
Butylbenzylphthalate 1.0
Diethylphthalate 0.15
Di-n-butylphthalate 0.31
Bis(2-ethylhexyl)phthalate 0.44
Arochlor 1242 0.17
Arochlor 1248 0.2
Arochlor 1260 0.062
4,4'-DDT 0.022
4,4'-DDE 0.033
-1-
813
-------
Sediments (rag/kg)

Acetone 0.18
1,1-Dichloroethane 0.011
2-Butanone 0.053
Toluene Q.19
Phenol 0.79
4-Methylphenol 0.96
Benzoic acid 0.23
Naphthalene 0.21
2-Methylnaphthalene 0.2
Pyrene 0.11
Bis(2-ethylhexyl)phthalate 0.68
Di-u-butyl-phthalate 0.17
2. What volume of material is to be remediated?

" 2,500,000 cubic yards of waste material

3. , What type of site is this?

Municipal Landfill. A sanitary landfill occupying approximately 56 acres. The area
surrounding the site is semirural, but is zoned to permit further development in the future.
Several homes and businesses are in the vicinity of the property, and many at one time were
served by individual private water supply wells. ,
TECHNOLOGY SELECTION ' ' , . -

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: '
Containment:

Physical treatment:

Disposal:
Cover upgrade, capping (NR 504 cap), vertical barriers, horizontal
barriers
Gas collection and treatment (active extraction, ground flare, carbon
adsorption, catalytic combustor), leachate collection and treatment
(extraction wells, off-site treatment by a wastewater treatment facility,
on-site treatment)
Excavation and consolidation
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
Chemical treatment: In situ vapor extraction
814
-2-
-------
6. What was'the cost estimate for the innovative technology? |
' • : • ' J ' ' . '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs Have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, costs were calculated during an evaluation biised on nine criteria
established by the NCP.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4
Innovative Technology
Capping/landfill gas control/leachate
control/in situ vapor extraction
(ISVE)
Estimated Costs
3 Cijiteria
N/A
t
9 Criteria
$9,914,000
7. How did the cost(s) compare to standard technologies? |

Cost Estimates for RAAs That Include Standard Techmijlopes
(selected remedial alternative is in bold) i
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Institutional controls
Capping/landfill gas/leachate control
Estimated Costs
-I
3 Criteria
N/A
N/A
'N/A /
9 Criteria
$0
$17,400
$8,737,000
8. If a standard technology was chosen, why? •. . i -
' ! • •'
The remedial action chosen for the site (RAA-4) incorporates both suindard and innovative
technologies. The standard technology consists of the installation of a Wisconsin NR cap.
The cap reduces the percolation of rainwater through contaminated waste material and into the
ground water by providing an impermeable layer above the waste material. This decreased
permeability contains contamination within the fill areas and helps prevent migration off site.
In addition, the decreased permeability will increase the ISVE zone ojf influence and therefore
the effectiveness of this system (which is the innovative part of the selected remedy). The cap
also provides added protection from exposure to contaminated materials via direct contact by
utilizing added cover material. RAA-4 meets current state and fedenil landfill closure
requirements which are applicable to this site. RAA-4 reduces the toxicity, mobility, and
volume of methane and other volatile organic compounds (VOCs) in [the subsurface through
extracting and treating landfill gas. In addition, RAA-4 reduces the toxicity, mobility, and
-3-:
815
-------
volume of leachate by extracting and treating it and by constructing a low-permeability cap
Tru . lected remedy will not be difficult to implement because the chosen cap is common at
other Superfund and landfill sites. _x

9. If an innovative technology was chosen, why?

The selected remedy incorporates ISVE to treat contaminated soil specifically in the drum and
refuse trench areas at the site. RAA-4 reduces the mobility and volume of VOCs in certain
areas of the site using ISVE. VOCs in the waste and surrounding soils will be extracted
through wells screened in the unsarurated zone and treated, if necessary, above ground. The
risks of construction activities for RAA-4 will be adequately managed through dust
suppression and the use of personal protective equipment for construction workers. ISVE is
becoming a common cleanup technology at various Superfund sites and implementation will '
be technically practical. Although ISVE is a relatively new technology when specifically
being implemented in a nonhomogeneous landfill mass, this should not impede the
implementation since a similar technology is being applied at the Hagen Farm Superfund site
in Wisconsin.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at -.
three stages: during the initial screening; during the screening of the three criteria of H»
effectiveness, implementability, and cost; or during the detailed evaluation. ^iP )

Innovative technologies eliminated during the initial screening include the following:

• None

Innovative technologies eliminated during the screening of the'three criteria include the
following: ' ,

• None .

Innovative technologies eliminated during the detailed analysis include the following:

" None

Protection of human health and the environment, long-term effectiveness and permanence, and
state acceptance were weighted most heavily in selecting a remedy for this site. The selected
alternative provides greater protection to human health and the environment than the other
alternatives by upgrading the cap and providing'ISVE extraction for certain areas of the site. - JB|| \
The selected remedy adds a final element of protectiveness by periodically monitoring existing Hi" )
wells that are more likely to indicate potential ground water contamination. RAA-4 provides

BIB
-4-
-------
the greatest degree of long-term effectiveness and permanence because it allows the greatest
degree of remediation and containment of the contaminants. The selected alternative provides
additional assurance of long-term effectiveness by monitoring nearby wells. Though the state
concurred with the selected remedial action, it did not feel that RAAj-1, RAA-2, or RAA-3
were protective or would attain ARARs; therefore, these alternatives were not acceptable to the
state. • ' ;. - . '.'"'; 'j' , :

12. What cleanup goals were selected? If the cleanup goal was based on 'an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? ,

Since this interim action ROD addresses source control, site-specific cleanup standards for
soils and ground water were not considered to be necessary for the areas where containment
provides the primary source control. A performance-based cleanup sitandard, however, which
would account for and incorporate ground water standards, was to be established for soils in
the portion of the site where the source area will be treated as' well ats contained (the area
covered by the ISVE system). A cleanup standard was to be established because of the more
concentrated nature of the hazardous materials located in this specific area.
. • • . ... * > '

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
I • '
Innovative technologies eliminated because of cleanup goals include;^

• None ' • . -. • :' .

Standard technologies eliminated because of cleanup goals include:

• None j "

. _ • i '
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. 'j

75. , What measures/criteria were used to compare alternatives? - ' •

The following measures were used to compare the alternatives: |
. i
Cost-effectiveness . J
•'!''..',
1 * ' * ' • •

16. How are, measures compared? .•>'."'.
i •
The selected alternative is more costly than other alternatives because it involves both capping
and ISVE. The incremental cost of these significant additional remedial activities, however, is
.rather small relative to the environmental benefit obtained. The selected remedy, therefore, is
cost effective. i

. • '" ' '-•' ;- ' - ' '' " •'• '.-'• ' !'•'' '. , ' . ' • 817
. -5- . . .'.'."•• .
-------
17, What technical considerations were-factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedial action for this site.
818
-6-
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Pagel's Pit, OU-1
(Winnebago Reclamation Landfill)

Winnebago County, Illinois
Region 5
GENERAL SITE INFORMATION

1. , Wfiat were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Landfill wastes were not sampled and
analyzed.
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/84
6/86
3/91
6/28/91
Background

PRP-lead I
PRPs: Not listed. The site is currently
operated by Winnebago
Reclamation Services, Inc.
FS prepared by: V/arzyn, Inc.
Approximately 4.7 million cubic .
yards of waste (estimated to be approximately 6 million cubic; yards,at closure)
'3. What type of site is this?
• I' • • .,
Municipal Landfill. An active landfill on a 100-acre site. Municipal refuse and sewage
treatment plant sludge have been the primary wastes accepted at the £ite. Illinois special
wastes (industrial process wastes, pollution control wastes, or hazardous wastes, except as
determined pursuant to the Illinois Environmental Protection Act) also have been disposed of
at the facility. The site is located in a predominantly rural unincorpoirated area. The Acme
Solvent Reclaiming, Inc., CERCLA site is located east of this site.
TECHNOLOGY SELECTION
I
4. What standard technologies were considered for selection In this FS?

Standard technologies considered during the identification and screerjing of technically feasible
technologies -were:
Access restriction:
Containment:

Chemical treatment:
Institutional measures, deed restrictions, fencing
Soil cover, capping (multilayer, soil, clay, multilayer with membrane,
clay-synthetic membrane cap), vertical barriers -
Fixation
-1-
819
-------
Thermal treatment:
Disposal:
Incineration
Off-site landfill
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies were not considered during the identification and screening of
technically feasible technologies.

6. What was the cost estimate for the innovative technology?

During the initial screening process, in which'technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. No innovative technologies were incorporated into
• remedial alternatives.
7. How did the cost(s) compare, to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
820
======
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5' and
RAA-5Ab
RAA-611 and
RAA-6A
RAA-7 and
RAA-7A

Standard Technology
No action
Planned closure
Clay-synthetic membrane cap
Planned closure/off-site treatment of
ground water and leachate
Planned closure/on-site carbon
adsorption treatment of ground water
Planned closure/on-site air stripping
of ground water
Planned closure/on-site photolysis-
oxidation of ground water "
===== ======
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$0
$7,500,000
$13,100,000
$10,400,000
$11,000,000
(RAA-5)
$13,400,000
(RAA-5A)
$9,800,000
(RAA-6)
$11,000,000
(RAA-6A)
$11,400,000
(RAA-7)
$14,100,000
{RAA-7A)
-2-
-------
Alternative
RAA-8
Standard Technology
In situ landfill waste fixation
Estimated Costs
3 Criteria
N/A '
9 Criteria
$989,000,000
"U.S: EPA and Illinois EPA have selected either RAA-5 or RAA-6 as the most appropriate
remedial action for this site. The ground water treatment system will| be selected during the
system's design stage. , ;
'The "A" alternatives treat ground water and landfill leachate. ,
8. -Ifa standard technology was chosen, why?

RAA-5 and RAA-6 were chosen because they prevent further contamination of ground water
by capping, and extracting and treating leachate. Under these alternatives, the landfill will be
covered with a cap compliant with Illinois municipal landfill regulations. Capping of the
landfill reduces the production of leachate by reducing the amount of precipitation infiltration
to the wastes. The spread of highly immobile inorganic contaminants would be prevented by
reducing the amount of leachate production in the landfill. Capping iilso minimizes residual
risks associated with dermal exposure. The reliability of the landfill pap is expected to be high
if properly constructed and maintained. The selected alternatives provide a high degree of
long-term effectiveness and permanence because they use treatment to reduce hazards posed by
ground water contaminants. In addition, material and waste handling: requirements under
RAA-5 and RAA-6 are not as extensive as for other alternatives. Finally, the selected
alternatives meet all ARARs. i ,
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? • L ' .
. • , • • ' /• ' ' ' j . • . •
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the! three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening includje the following:

• None " . '
i . ' •
Innovative technologies eliminated during the screening of the three Criteria include the ,
/ following: !
' • • '"'!''
• . .. None ' •' •.-••[. •
-3-
821
-------
Innovative technologies eliminated during the detailed analysis include the following:

* None
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Long-term effectiveness and permanence, and implementability were important criteria when
selecting remedial action alternatives. The nonhomogeneous nature of the waste in the
municipal landfill, as well as the potential presence of large objects, likely would interfere with
in situ treatment processes such as fixation. As recognized by the NCP and various EPA
documents, treating the entire contents of a municipal landfill with a high volume of
heterogeneous waste can be impractical. The selected alternatives which incorporate capping
would be less complicated to implement than treatment alternatives. The State of Illinois
would not concur on this ROD. While the state agreed in principle that the selected
alternatives will address site contamination, the state will lack the necessary approval rights
over landfill closure and postclosure activities because the state will not be a party to anv
settlement that is negotiated.
12.
13.
, °ah WSre selected? Vthe cleanuP goal was based on an ARAR, what was that
What risk level was selected to establish cleanup goals?

Specific cleanup goals were not provided.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
822
Cost effectiveness
Preference for treatment (vs. containment)
-4-
-------
16. How are measures compared? ' t
• " ' I i
RAA-6 is the least costly alternative that provides a barrier to impede tiie migration of
contaminated ground water. RAA-5 is estimated to be slightly more cbstly, but might provide
some advantages treating the water. Thus, either alternative is cost-effective for providing the
protection required at the site. According to the FS, containment will be the main method of
addressing landfill wastes, which pose only relatively low, long-term treats to human health
and the environment. The use of treatment to address the contaminated ground water,
however, was significant in selecting the chosen alternatives.

The Hydrologic Evaluation of Landfill Performance (HELP) computer program was used to
estimate the rate of infiltration into the landfill waste for the final caps and grades evaluated.

17. What technical considerations were factors in selecting a remedy?, Were technical :
considerations primary in the selection of the remedy?
I ' 'i
Technical considerations were not primary in selecting a remedy for this site.
823
-5- • :!.•••
-------
Peerless Plating Co.

Muskegon, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Arsenic 14
Cadmium 11,000
Benzene 0.073
Chloroform 0.028
Trichloroethylene 16.6
Vinyl chloride 1.7
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1988
8/90
6/1/92
9/21/92
Background

EPA Fund-lead
PRP: Not identified
FS prepared by: SEC Donohue
VOC levels in soil were estimated from
ground water data using Summer's Transport Model.
2. Wliat volume of material is to be remediated?

The volume of material to be remediated included:

• 8,800 cubic yards of soil contaminated with cadmium
« 330 cubic yards of soil contaminated with arsenic
• 6,500 cubic yards of soil contaminated with VOCs

3. What type of site is this?

Electroplating. Abandoned electroplating facility.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: \ • • .
Access restriction: Deed restrictions, fencing
Containment: RCRA cap, non-RCRA cap
824
-1-
-------
Chemical treatment:
Thermal treatment:

Disposal:
Stabilization/solidification
Rotary kiln incineration, high-temperature fluid wall reactor, infrared
thermal treatment, circulating fluidized bed combustion
On-site landfill, off-site landfill i
5. Was an innovative technology considered in the FS? If so, which technology?
"" ii .
Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Aboveground aerobic biological treatment, anaerobic biological
treatment, white rot fungus, in situ biological;treatment
Chemical treatment: Supercritical extraction, dehalogenation, solvent extraction, soil
washing* in situ soil flushing ;
Thermal treatment: Molten salt combustion, in situ steam vapor extraction, in situ heating,
in situ vitrification, low-temperature thermal liesorption, pyrolysis
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs that Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action/ground water monitoring
RCRA cap/fencing/deed restrictions/
ground water monitoring
Estimated Costs
3 Criteria
$41,000
$400,000
9 Criteria
$41,000
$718,000
8. If a standard technology was chosen, why?

Part of the selected remedy is a standard technology. Solidification/stabilization with off-site
disposal was selected because 1) it produces an end product not bioacceptable by humans or
animals, 2) immobilizes inorganics and prevents future leaching, 3) off-site disposal will
eliminate institutional controls and a 5 year review, 3) off site disposal will eliminate
institutional controls and 5 year review, 3) it is the most effective and permanent alternative as
both organic and inorganic contaminants in the soil are treated and disposed of off-site leaving
no on site residuals. ' 6
9. If an innovative technology was chosen, why?

The remedy selected includes in situ soil vapor extraction of VOC-contaminated ,
soil/excavation; above ground on site stabilization of metal-contaminated soil; and off-site
landfillmg of stabilized material. This remedy was selected because: 1) it is the most effective
and permanent alternative as both organic and inorganic contaminants in the soil are treated
and disposed of off-site, leaving no on site residuals, 2) established technology used
82G
-3-
-------
extensively at a number of sites to contain VOC contaminants, and 3) operational flexibility is
high since vacuum pump speed can be modified to adjust to changes in flow rate.
, • • ' •' • , li- . :

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? !

Innovative technologies could be eliminated from the remedial technology selection process at.
three stages: during the initial screening; during the screening of the three: criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Molten salt combustion was eliminated because the technology is still being developed,
and high ash content material would require continuous ash removal and change of the
molten salt.
• Supercritical extraction was eliminated because full-scale demonstration of the
technology is limited and it is not projected to be feasible for soil matrices.
, • Dehalogenation was eliminated because it is not applicable foi; the nonchlorinated
, organic compounds at the site.
• White rot fungus was eliminated because the fungus is not as readily amenable to soil
as bacteria and this technology has been demonstrated only in the laboratory.
• In situ heating was eliminated because it has not yet been demonstrated on a
commercial scale for hazardous waste treatment; available performance data on
hazardous waste is limited; installation would require extensive .above ground area not
available at the site; and it does not treat metals.
• In situ vitrification was eliminated because this technology has few demonstrated full-
scale applications and would require, significant electricity dernands.
• In situ steam vapor extraction was eliminated because the unit cost is greater than soil
vapor extraction and it offer no advantage over soil vapor extraction.
• Solvent extraction was eliminated because it has not yet been fully developed for
hazardous waste treatment applications and variations in waste; composition can lead to
problems with process controls.
• Soil washing was eliminated because the complexity of waste material (i.e., both
organic compounds and metals) would make the formulation of suitable washing fluids
difficult. Also, recovery of the washing fluids for reuse is cornplex and necessary fbr
the economic viability of the process.
• In situ soil flushing was eliminated because implementing the technology in such a
small area would be difficult, and since only water soluble contaminants would be
removed, achieving required treatment standards would be difficult.
• Anaerobic biological treatment was eliminated because of the [extended process time
required for implementation, the low concentrations of biodegradable contaminant, the
extent of treatment is undefined, cost is greater than soil vapor extraction and
treatment time is greater than soil vapor extractions of biodegradable contaminant.
» In situ biological treatment was eliminated because the existing site conditions (e.g.,
shallow depths of contamination and the small volume of waste) limit the effectiveness
and-implementability of in situ biological treatment processes, Provides limited
process control in terms of nutrient addition. !
• ' Pyrolysis was eliminated because it does not destroy metals, and the residual char from
, the process must be appropriately treated for metals; not appropriate for low
'-4- ' -' i • •' '' •••• -827
-------
' concentrations of organics at the site; offers not specific advantage over other thermal
treatment methods.

Innovative technologies eliminated during the screening of the three criteria include the
following:
ii
Aboveground aerobic biological treatment was eliminated because pilot studies would
be required to ensure target cleanup concentrations were obtainable and to determine -
optimum operating conditions.
" Low-temperature thermal desorption of VOGs was eliminated because it provides the
same level of protection as ISVE, but is more expensive.

Innovative technologies eliminated during the detailed analysis include the following:

• None
11.
12.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Long-term effectiveness and permanence were weighted most heavily in selecting the
technology The chosen technology was the most effective and permanent because both
organic and inorganic soil contaminants are treated and disposed of off site, leaving no on-site
residuals. After remediation, the site would be returned to unrestricted use.
r
risk level was selected to establish cleanup goals?
°nan ARAR'
was tliat
Contaminant
Cleanup Level (rag/kg) ARAR or Other Basis
Carcinogens
Arsenic
Benzene
Chloroform
Trichloroethylene
Vinyl chloride
1.7
0.02
0.1
0.06
0.0004
Background
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Noncarcinogens
Cadmium
0.8
Background
The Michigan Environmental Response Act (Act 307) provides for the identification risk
assessment, and evaluation of contaminated sites within the state. EPA determined that Act

nft±S r X,U f6' CE?CLA: ^ ACt 3°7 ml6S require that remedial action be P^iv
of human health, safety, the environment, and the State's natural resources. To achieve this
standard of protectiveness, the Act 307 rules require that remedial action achieve a degree of
828
-5-
-------
cleanup under either Type A (to background levels), Type B (to risk-based levels), or Type C
(to risk-based levels under site-specific consideration) criteria. \.

Because pf the site's multiple contaminants, EPA based cleanup levels; on Type A or B
criteria, whichever values were higher. Where the cleanup standard established for a
contaminant is lower than the method detection limit for that contaminant,, the method
detection limit was used as the cleanup standard.

For carcinogens, the acceptable range of cumulative excess lifetime cajncer risk is 10"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equial to 1.0 is acceptable.
. - . ' . . • • K
' ' • ' • • '' •''.'"
13. Was the innovative technology eliminated because of the cleanup goats? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: ,

• None I . • ,
• ' I
Standard technologies eliminated because of cleanup goals include:
' ' ' '*'
. • None . ' ! .

14. Were treatability studies conducted on the innovative technology or standard technology?
'•'•••• ' - i
No treatability studies were conducted. '\
i . '
' - . . '".[••• ' •
.-'••' • , ..i
75. What measures/criteria were used to compare alternatives? |

The following measures were used to compare the alternatives: j }

Time to design/construct/operate !
Proven reliability i
Preference for treatment (vs. containment)
> r

16. How are measures compared?
• '
The chosen alternative provides a high degree of effectiveness and permanence through
treatment and disposal of treated residue off site. Treatment was preferred to containment
because local businesses wanted to develop the site immediately afteir remediation was
complete. This technology was the only alternative that would allow; the site to be returned to
unrestricted use after remediation. Proven reliability also was an important consideration since
treatability studies for unproven technologies would require too much time.

VOC levels in soil were estimated from ground water data using Surnmer's Transport Model.
6- 829
-------
17. Whnttechnical considerations were factors in selecting a remedy? Were technical
c ^(derations primary in the selection of the remedy? ~
• ' • ' • •
Some of the technologies initially considered would be effective only in a large site area. The
Peerless Plating site is small, precluding the use of these technologies.
830 W :
-7-
-------
Rasmussen's Dump
OU-1
^ .
Green Oak Township, Livingston County, Michigan
Region 5 |
GENERAL SITE INFORMATION
1.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
.contaminants were:

Soil(mg/kg)

Toluene 71.0
Xylene 9.1
Ethylbenzene 2.4
Chlorobenzene 3.7
2-Butanone 74.0
PCBs 5.2
Naphthalene 35.0
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1982
1983
1/16/90
3/28/91
Background

EPA Fund-lead
PRPs: Not listed
FS prepared by: IJIUS Corporation
(Volume I); Warzyn Engineering
(Volume II and IE)
What volume of material is to be remediated?
i

The volume of material to be remediated included:
3,600 cubic yards of soil from Drum Disposal Area
1,900 cubic yards of soil/waste from Industrial Waste Area
4,100 cubic yards of soil/waste from NE Buried Drum Area
15,300 cubic yards of soil from the top of the Municipal Lanidfill
What type of site is this? . .

Industrial Landfill. Former industrial and domestic waste disposal aijea. The site is adjacent to
the Spiegelberg landfill, another Superfund site.

The site is divided into four areas of concern: Industrial Waste Areai; Probable Drum
Storage/Leakage/Disposal Area; Northeast Burial Drum Area; and Top of Municipal Landfill
Area. Remedial action alternatives (RAAs) were determined, however, on a site-wide basis.
-1-
831
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: •

Access restriction: Fencing, deed restrictions
Containment: Capping (soil, multimedia), slurry walls, grout curtains, steel sheet
piling, block displacement grouting'
Physical treatment: Solidification
Thermal treatment: On-site incineration, off-site incineration, infrared treatment
Disposal: Excavation, on-site landfill, off-site landfill
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Aerobic biodegradation, anaerobic biodegradation, in situ
biodegradation
Chemical treatment: Dechlorination
Physical treatment: Soil flushing, soil washing, soil aeration
Thermal treatment: Vitrification, vacuum vapor extraction

6. What was the cost estimate for the innovative technology?

While some innovative technologies were considered as possible remediation alternatives for
individual areas of concern, they were not incorporated into RAAs because they did not have
site-wide applicability.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
832
Standard Technology
-2-
-------

Alternative
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
Clay cap with no further excavation/
deed restrictions
Clay cap with further excavation/deed
restrictions
Multimedia cap with no further
excavation/deed restrictions
Multimedia cap with further excavation/
deed restrictions
Estimated Costs
9 Criteria
$2,340,000
$3,780,000
$4,940,000.
$6,330,000
ROD
$2,993,290
$4,539,062
$5,146,285
$6,691, '669
8. If a standard technology was chosen, why?

A clay cap was selected because: 1) cost of treatment option, 2) preseno
action levels) which increases the short term inhalation risks to workers
alternatives involving excavation due to fugitive dust, 3) large volurre
4) no commercial landfills accept dioxin, 5) no vendors can treat dioxin
of dermal contact, 7) limits potential for further migration of contam nants
e of dioxin (below
and the community for
and variability of waste,
waste, 6) reduces risk
to ground water.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
JO. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
' . ! • '
' ' ' ' i
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during, the initial screening; during the screening of the: three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
i.
- '''I'. ' .
Innovative technologies eliminated during the initial screening include the following:
' • "' ' i-' I •-
• In situ Vitrification was eliminated because the topography of the site is not
appropriate for vitrification; the landfill is too shallow for effective electrode
; emplacement; equipment use is unproven on a large scale basis; long-term leaching of
organic contaminants is uncertain; control of volatilized organics during the process
may be difficult.
• Soil flushing was eliminated because the site's geology could impede the flushing
process and create further ground water contamination.
• Dechlorination was eliminated because testing would be required; byproducts would be1
produced by the process; and the high cost.
• Aerobic biodegradation (reactor) was eliminated because of maintenance problems and
the difficulty in controlling the process.
-3-
833
-------
• Anaerobic biodegradation was eliminated because of sensitivity to non-uniform waste
streams; long retention times and production of methane gas.
• In situ biodegradation was eliminated because pilot testing will be required to
demonstrate its effectiveness; poor process controls; contaminants are widely and
intermittently spread throughout the soil (no hot spots).
" Vacuum vapor extraction was eliminated because it is not effective for metals PCBs
dioxms and base and acid extractable organics; of the presence of high concentration'
wastes and buned drums; and it would have to be used in conjunction with other
technologies to remediate the entire site.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Soil aeration was eliminated because it would not meet RCRA treatment standards for
waste containing total halogenated organic compounds in excess of 1,000 ppma
" Soil washing was eliminated because pilot testing will be required to achieve clean-up
levels; no vendors are available to reactivate dioxin or PCB in carbon units- not in
compliance with RCRA treatment standards for wastes containing total halogenated
organic compounds in concentrations greater than 1000 ppm.

Innovative technologies eliminated during the detailed analysis include the following:

* None
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

CosMmplementability and compliance with ARARs were the determining factor in selecting a
72.
13.
, 8°al Was based on an ARAR>
? What risk level was selected to establish cleanup goals? -

No soil cleanup levels were derived once containment versus treatment was chosen for a
remedy.

For carcinogens, an excess upper bound individual lifetime cancer risk of between W4 to 10'6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? , """"'"

Innovative technologies eliminated because of cleanup goals include:

• None
834
-4-
-------
Standard technologies eliminated because of cleanup goals include:

• None • . -..'-"...••••• " ' •! - '.'•'•'

'-,..' - ' I ' ' • ' ;
14. Were treatability studies conducted on the innovative technology or'standard technology?

.'"No. ' '• • • ' ' - 'I ' •-• ' '
'• ' -'I-,1 , '
• • ' • '.' ' i ,' . ,
75. What measures/criteria were used to compare alternatives? >
. ~ ' ' ' - -I "
The following measures were used to compare the alternatives: [' . '

Cost-effectiveness j
Proven reliability
Single vs. multistep treatment

16. How are measures compared? . i

A risk-based, cleanup is necessary at Rasmussen's Dump due to the close proximity of
residential wells and the potential future use of ground water at and near the site. The chosen
alternative, a clay cap with no further excavation, adequately meets remediation goals and is a
proven reliable remedy. Although four separate areas of concern were targeted for soil
remediation, a site-wide remedy was preferable to a multistep treatment because of overall
cost-effectiveness. In addition, since ground water contamination presented greater risk than
contaminated soil and waste materials, containment of contaminated soil iind waste materials
was considered preferable to treatment. Capping will significantly reduce the mobility of
contaminants and subsequently reduce the rate of leachate generation. The selected remedy is
the most cost-effective alternative.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
• . ' i •
Technical considerations were primary in selecting a remedy. The varied geological
formations and diverse waste streams of each of the four areas of concern were fundamental in.
the choice of containment over treatment. In addition, several innovative technologies were
eliminated as a result of technical difficulties associated with implementation or maintenance.
-5-
835
-------
Savanna Army Depot Activity

Savanna, Illinois
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

2,4,6-Trinitrotoluene (TNT) 500,000
2,4-DinitrotoIuene (2,4-DNT) 94
2-amino-4,6-Dinitrotoluene 300
2. What volume of material is to be
remediated?
Site History

NPL Proposed: N/A
NPL Final: N/A
FS: 12/91
ROD: , 3/92

Background

Federal Facility
PRPs: U.S. Army
FS prepared by: Weston Services, Inc.
The volume of material to be remediated included:

" 18,230 cubic yards of soil
3. What type of site is this?

Military. An inactive ammunition washout facility and associated lagoons located in a
sparsely populated rural area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: , .
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
836'
Fencing, deed restrictions
Capping (synthetic, clay, concrete, asphalt, multilayer, RCRA)
regrading, revegetation, diversion, sedimentation pond, vertical barriers
(slurry wall, grout curtain, sheet piling), horizontal barriers (grout
injection, block displacement)
Stabilization
Incineration (rotary kiln, fluidized/circulating bed)
Excavation, disposal (on-site, off-site)
-1-
)!
-------
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
, - • . . '."•[""" ""'
Biological treatment: Landfarming, composting, in situ bioreclamation
Phys/Chem treatment: Soil washing (water, solvent), solvent extraction, critical fluid
extraction, in situ soil flushing i
Thermal treatment: In situ vitrification, pyrolysis, molten salt ;
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4
RAA-5
Innovative Technology
Composting/stabilization if necessary/
on-site disposal
Solvent extraction/stabilization if
necessary/on-site disposal
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$11,645,000
$8,778,000
7. How did the cost(s) compare to standard technologies? . • \ .
' ' ' • ' ' i • ' '"!•'
Cost Estimates for RAAs That Include Standard Technoliogies
(selected remedial alternative is in bold) !
Alternative
RAA-1
RAA-2
RAA-3
RAA-6
Standard Technology
No action
Institutional controls
Excavation of lower lagoons/transport
of excavated waste to upper lagoons/cap
On-site incineration (rotary kiln)/on-
site disposal
Estimated Costs
3 Criteria
N/;k
N/A
N/A
N/A
, i
9 Criteria
$0
$271,000
$1,875,000
$10,251,000
-2-
837
-------
Alternative
RAA-7
Standard Technology
Off-site incineration at Chemical Waste
Management (rotary kiln)/off-site
disposal
Estimated Costs
3 Criteria
N/A
9 Criteria
$24,302,000
8. If a standard technology was chosen, why?

RAA-6 was selected because it is the most protective alternative since all explosives
contamination above the cleanup levels will be removed and thermally treated. Furthermore,
no process byproducts or residual solvents will remain in soil and transportation off site is
unnecessary. It complies with all ARARs and is cost effective. This alternative results in a
significant and permanent reduction in contaminants, thereby reducing the estimated current
and potential future risk due to exposure. The leaching of naturally occurring metals from
treated soil poses limited risk; however, this is not expected. If soils do not meet Toxicity
Characteristic Leaching Procedure (TCLP) criteria, they will be stabilized prior to'disposal.
Minimal or no long-term management will be necessary following the removal of the thermal
treatment unit from the site. This alternative provides long-term effectiveness by permanently
eliminating any potential contaminant toxicity, volume, and mobility from the site. It satisfies
the statutory preference for treatment. No unacceptable short-term risk or cross-media impact
will be caused by the implementation of this alternative. The main short-term risk associated
with RAA-6 is from incinerator air emissions. Air emissions will be controlled by an offgas
treatment system. In addition, workers will be provided with personal protective equipment.
This alternative will be implemented in 10 to 14 months. A number of vendors are available
to implement on-site thermal treatment technologies. The rotary kiln incinerator has been
thoroughly tested and has a well-documented history of successful performance on treating
hazardous waste, including the treatment of explosive compounds in soil. Rotary kilns can
accept a variety of wastes with little pretreatment since the maximum soil particle size is 6
inches. In addition, the rotary kiln has been submitted for review and has been approved by
the Department of Defense Explosives Safety Board (DDESB) for treatment of explosive-
contaminated soil.
P. If an innovative technology was chosen, why?

An innovative technology was not chosen. ,

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of die three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• An initial screening was not conducted.
833
-3-
-------
Innovative technologies eliminated during the screening of the three criteria, include the
following:

• Soil washing was eliminated because its effectiveness on site sciil is; questionable and
must be determined by a treatability study. Furthermore, because most organic
compounds adhere to soil particles and are not very soluble in water, it might be
necessary to wash soil a number of times before the desired residual contaminant
concentrations are attained. Also, it might not be possible to attain these
concentrations! In addition, with each pass through the process, more waste volume is
generated. A significant elutriate waste stream that contains wash solution, explosives,
and fines would be generated that must be treated and disposed. Residual
concentrations of wash solution in treated soil also would be a poncem.
• Land/arming was eliminated because large volumes of soil woiild have to be treated
and a large area would be required. Time required for adequate degradation is
unknown and the climate might not be conducive to this treatment technology; during
the winter months, the frozen ground might decrease microbial activity. Land disposal
regulations might be prohibitive. Degradation byproducts might be; toxic.
Landfarming involves the direct application of RCRA-listed soiil on the ground, which
is not allowed under the land ban.
• In situ soil flushing was eliminated because its effectiveness would be uncertain. The
variability of the soil characteristics would limit the degree of effective contact
between solvent and soil particles. A large portion of the site iis located in a flood
plain adjacent to the Mississippi River and seasonal ground water fluctuations can
occur, making it difficult to predict ground water flow accurately sind to control the
soil flushing process. At the upper lagoons, implementing a flushing
infiltration/retrieval system would be difficult because the lagoons are located a large
distance above the water table (45 feet), allowing the flushing solution significant
opportunity to spread out horizontally, and making it difficult llo retrieve. In addition
the bedrock below the upper lagoons is fractured and the direction of ground water
flow in localized areas is difficult to predict. Again the mobilization of contaminants
and their uncertain destination is of primary concern. In addition, nitroaromatic
compounds typically exhibit low solubility in water and preferentially adhere to soil.
Finally, since the overall length of remediation effort is difficult to predict, a protracted
program would likely diminish the cost advantages.
• In situ bioreclamation was eliminated because its effectiveness is uncertain since the
biodegradation of nitroaromatic compounds has not been implemented on a full scale.
The variability of the soil characteristics would limit the degree of effective contact
between nutrients and soil .particles. Furthermore, heterogeneous sioil make adequate
flow control more difficult. The lower lagoons are located inj a floodplain in the
presence of a high water table. The in situ bioreclamation process might be difficult
to control since seasonal ground water fluctuations can occur, malting it difficult to
predict ground water flow accurately. The upper lagoons are far above the water table,
giving the nutrient rich solutions that would be applied an ample opportunity to spread
out horizontally. Furthermore, the bedrock below is fractured [making flushing solution
retrieval difficult. In addition, there might be an adverse environmental impact given
the toxicity and mobility of microbial degradation products.
• In situ vitrification was eliminated because even though it has been developed on a
large scale and is ready for commercial deployment, it does nothave a significant
commercial experience base. It is not proved for explosives-contaminated soil.
Because this technology would be implemented in situ, all afflicted soil could not be
inspected to ensure that explosive compounds "hot spots" do riot present a safety

839
-------
hazard from the potential explosions. Since the lower lagoons are located in a
floodplain within 10 feet of the water table, it is expected that an intensive energy
requirement would have to be met so that the soil's moisture would be vaporized prior
to vitrification. Otherwise, the water table could be drawn down but this would
require treatment of a large volume of water. Finally, the company exclusively
sublicensed for the commercial deployment of this technology, Geosafe, has
temporarily suspended full-scale commercial applications after a fire during an
operational acceptance test.
« Pyrolysis (Advanced Electric Reactor, AER) was eliminated because it cannot be
readily implemented and it has had limited applications. AER currently is not being
marketed by any firm and therefore is not commercially available. The cost is
expected to be high because of its energy-intensive nature and anticipated technical
difficulties.
• Pyrolysis (electric pyrolyser) was eliminated because it is in an early developmental
stage and has not been extensively tested for organic compound destruction. It is no
longer marketed by Westinghouse, it is not commercially available, and it cannot be
readily implemented. The cost is expected to be high because of its energy- intensive
nature and anticipated technical difficulties.
« Molten salt was eliminated because its effectiveness on organic compounds has not
been determined; it is in an early development stage and additional research and
development must be conducted before this technology can be implemented on a large
scale for site cleanup. This technology would not be suitable for soil with high ash
content because frequent bed recycling and replacement would be required. Site soils
typically contain high ash content and therefore they would not be amenable to this
treatment. Costs are assumed to be high because of the frequent bed recycle and
replacement. ,

Innovative technologies eliminated during the detailed analysis include the following:

" Composting was eliminated because it would not be as protective as the chosen
alternative and because it could leave process byproducts on site. Compost piles
remaining on site might pose a risk. The ability of this technology to achieve cleanup
levels is undetermined and treatability studies would be required. It would take 5 to 7
years to implement.
• Solvent extraction (ex situ) was eliminated because it would not be as protective as the
chosen alternative; it might leave residual solvent in the soil. Its ability to achieve
cleanup goals is undetermined and treatability studies would be required. It would
take 1 to 3 years to implement. There is a limited risk from leaching of residual
concentrations of explosive compounds if the solvent is not adequately removed from
treated soil and acts as a cosolvent with water. And if residual solvent is present in
the treated soil, it might increase the mobility of residual contaminants. It might be
difficult to obtain preacceptance approvals for treatment of concentrated waste streams
at an off-site facility because of limited capacity. In addition, the facility accepting the
concentrated waste stream must be in compliance with CERCLA Off-site Disposal
Policy. F
" Critical fluid extraction was considered a solvent extraction technique and was
eliminated for the same reasons as solvent extraction.
'*>
840
-5-
-------
77.
Which of the nine criteria were weighted most heavily in selecting the technology?. Did failure
to meet one of the nine criteria result in the elimination of the innovMve technology? If so,
which criterion? Which of the, criteria supported the use of a standard technology?
~ •
The criteria weighted most heavily in selecting a remedial alternativejwere long-term
effectiveness and permanence, and implementability, RAA-6 will desjtroy all of the TNT to
health-based cleanup levels and there will be no process byproducts of residual solvents in the
soil. RAA-6 does not require the transport of waste'mateijals. RAA-6 am be implemented in
a short timeframe. Rotary kiln incineration is the only method that has been approved by the
Department of Defense Explosives Safety Board (DDESB) for treatment of explosives-
contaminated soil and a number of vendors are available and permits yvill not be required.
• t . ,
Composting and solvent extraction were eliminated because their effectiveness was
undetermined, they might leave residual contaminants, by-products, or solvents on site, and
they would not be as implementable as the chosen alternative. '
72.'
What cleanup' goals were selected? If the cleanup goal was based on[an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? ' \
Contaminant
Cleanup Level (rag/kg)
ARAR j or Other Basis
Carcinogens
TNT
2,4-DNT
2-A-4.6-DNT
RDX
21.1
9.3
1,191
5.75
Risk3
Risk
Risk
Riisk
Noncarcinogens , ,->..,
TNB
l,3-DNBb
NB
2,6-DNTb
HMXb
Tetrylb
3.7 ,
. 7.4
37.2
4.2
3,722
112
, Risk
Risk
, Risk
Risk ,
! Risk
Risk
Cleanup levels are the levels to which contaminated soils must be excavated to protect
human health at a target carcinogenic risk level of 10'6 and a hazard quotient of 1.
The only exception is the cleanup level for 2,4-DNT, which is [protective of human
health at a target carcinogenicity risk level of 10'5.
Contaminants only found in ground water; however, these contaminants might be
encountered in soils during the remedial activity.
-6-
841
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? TOF \
. ' ' • . • j'
Innovative technologies eliminate'd because of cleanup goals include: ,

• None

Standard technologies eliminated because of cleanup goals include: '

* None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
• j '

15. What measures/criteria were used to compare alternatives? • '

The following measures were used to compare the alternatives:

Percentage risk reduction
Cost-effectiveness
Time to design/construct/operate
Proven reliability -

16. How are measures compared?

The chosen alternative was preferred because it would permanently eliminate site
contaminants, it can be implemented within about 1 year, and it utilizes a proven and reliable
technology. RAA-4 and RAA-5 were not selected because there was uncertainty concerning
their effectiveness, they might leave residual byproducts or solvents on site, they would take
• much longer than the chosen alternative to implement, and they would require treatability
2Stm|'A ?!? Chf^ alternative is cost effective since it is more protective and less expensive
than RAA-4 and RAA-7; though it is more expensive than others, it provides more human
protectiveness than RAA-1, RAA-2, RAA-3, and RAA-5.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedial alternative. Some
innovative technologies, however, were eliminated for technical considerations, such as
location of the lower lagoons in a floodplain, the seasonal variation in water levels the
fractured bedrock underlying the upper lagoons, and the heterogeneous soil characteristics
842
-7-
-------
South Andover Site
OU-2

Andover, Minnesota
Region 5
GENERAL SITE INFORMATION

/. What were the principal contaminants,:
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
2.
Soil (mg/kg)

Lead
Antimony
PAHs
PCBs ,
1,980
76
,30
15
What volume of material is to be
remediated?
Site IHistory
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
N/A
10/2/91
12/24/91
Background ,
I /

EPA Fund-lead I
PRPs: Not listed | • • '
FS prepared by: Dpnohue and
Associates, Inc.
The volume of material to be remediated included:

• 11,400 cubic yards of soil
3. What type of site is this?

Recycling. An auto salvaging operation.

TECHNOLOGY SELECTION

4.,' What standard technologies were considered for selection in this

Standard technologies considered during the identification and screening of technically feasible
technologies were: |

Access restriction: Deed restrictions, fencing
Containment: Slurry wall, vibrating beam, RCRA cap, non-RCRA cap
Chemical treatment: Stabilization/solidification
Thermal treatment: ' Incineration (infrared, circulating fluidized bpd, and rotary kiln)
Disposal: Excavation, off-site disposal
-1-
843
-------
5.
6.
Was an innovative technology considered in the FS? Ifso, which technology?

SST !ech°0!°gies ""leered during the identification
feasible technologies were:
and screening of technically
—

What was the cost estimate for the innovative technology
formulated, costs
implementability, and
estimated costs Ln
the NCP:
ARARs;

s are identified
costs^ **« the RAAs have been
SCreenin8 process W&ctivoess,
& m°r6 detailed evaluation- ^
f On ^^ °n nine criteria establish^ by
Ort"temi effectiveness= te™P«ance wij
mobility, toxicity or volume niem,n, T, environment; redu^ion in contaminant
community accepted' lmplementablhty' cost> state/support agency acceptance; and

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
844
Alternative
—*——«^_

RAA-2

RAA-3

-••ii .^•M

RAA-4
Innovative Technology

Excavate Area la soil/ex situ aerobic
biodegradation of Area 1 soil/cap Areas
j, 3, 4 and 7b/monitor ground water

Excavate Area 1 soil/ex situ aerobic
biodegradation/excavate and stabilize
Areas 2, 3, 4 and 7 soils/monitor
ground water

Excavate Area 1 soil/ex situ aerobic
biodegradation of Area 1, 5, and 6
soil/excavate Areas 2, 3, 4, and 7
soil/off-site disposal of Areas 234
and 7 soils ' '
* Area ] contains only PAHs

antfony.' * *' ** " ""^ *
Estimated Costs
N/A
3 Criteria 9 Criteria

N/A $2,500,000
$4,000,000
$2,470,000
°f -ntaminants including PCBs.PAHs, leaded
-2-
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology
No action
j
Estimated Costs
3 Criteria
N^A , .
9 Criteria
$0
8. If a standard technology was chosen, why?
' ' '
A standard technology was not chosen.
'
9. If an innovative technology was chosen, why?
I • . : '. ,.
The remedy selected included aerobic biodegradation of one area and excavation and off-site
disposal for all other areas. Biodegradation was selected for areas with only PAH
contamination, off-site disposal areas were contaminated with lead. Biodegradation was
selected because: 1) demonstrated as effective for a 10 fold reduction iin PAH concentrations
when the initial soil concentrations were greater than 100 ppm and theoretically feasible at low
concentrations found at the site, 2) complies with OSWER directive 9380.0-17 that encourages
the use of innovative technologies, 3) used in numerous applications 'alt a wide variety of sites,
4) preference for treatment. .
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ,

Innovative technologies eliminated during the initial screening include the following:

• Anaerobic biodegradation was eliminated because its effectiveness for low
concentrations of refractory organics (PCBs and PAHs) as substrate is not
demonstrated.
• White rot fungus was eliminated because concentrations of melals may be inhibitory to
; fungus, fungus is less mobile than bacteria thus requiring more intensive mixing, and
no demonstrations have been performed other than in the laboratory.
• Supercritical extraction was eliminated because it would not be effective for all site
contaminants or practical use for such large volumes of waste.
• In situ soil flushing was eliminated because site contaminants are not mobile in
, soil/water matrix. •. ' • .
• In situ heating was eliminated because it is not commercially available and it would
not be effective for semivolatile organics or metals.
• In situ vacuum extraction was eliminated because it would be ineffective for metals.
-3-
845
-------
• In situ steam extraction was eliminated because it would be ineffective for semivolatile
organics and metals.

Innovative technologies eliminated during the screening of the three criteria include the
following: '

• On-site vitrification was eliminated because the technology requires too much
electricity and is not readily available.
» In situ vitrification was eliminated for the same reasons as on-site vitrification.
• Soil washing was eliminated because formulation of washing fluids to limit toxicity of.
residual materials may be difficult and require constant adjustment due to
heterogeneity of wastes and it requires a separate treatment system to treat the more
concentrated waste stream.
• Solvent extraction was eliminated because there would be a lack of process control due
to variations in the waste composition and separate treatment systems would be
required to treat the more concentrated waste stream.

Innovative technologies eliminated during the detailed analysis include the following:

• Low temperature thermal desorption was eliminated because it has not been
demonstrated on a full-scale basis.
• In situ aerobic biodegradation was eliminated because of process control limitations,
and the small volumes of contamination in the vadose zone doesn't lend itself well to
in situ methods. . _ ' ,
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in the selection of an innovative technology were the
protection of human health and the environment, and long-term effectiveness and permanence.
Three alternatives, RAA-2, RAA-3, and RAA-4, offered comparable protection but only RAA-
4 proposed a permanent solution does not require long-term maintenance.
J
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
846
Contaminant
Cleanup Level (mg/kg)
ARAR ot Other Basis
Carcinogens
PAHs
PCBs
4
2 '
Risk3
Risk8
Noncarcinogens
Lead
Antimony
500
25
Blood levels'1
Risk"
-4-
-------
"Cleanup levels were based on an excess upper bound individual lifetime cancer risk of
between 2xlO'5 to 3xlO'5 |
bCleanup levels were based on a 5 percent chance of exceeding blood lead levels of 10
ug/dL. , . I ,
cCleanup levels were based on reducing noncarcinogenic risk to a Hazard Index equal
to or less than 1.0. -•''!•
13.
14.
15.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: '

• None
.- ' . •
Standard technologies eliminated because of cleanup goals include: !
•'
• None ' -• -,!,•.

•i

Were treatability studies conducted on the innovative technology or standard technology?
'• i -
No treatability studies were conducted.

What measures/criteria were used to compare alternatives? j

The following measures were used to compare the alternatives: !
- • > - i ^
Preference for treatment (vs. containment) !
Waste left in place/institutional control !
Cost/unit risk .
Capital cost versus operating cost I .
16. How are measures compared?

The chosen alternative was preferred because it emphasizes treatment over containment and
leaves no on-site residuals. The-chosen alternative treats Area 1 soil and disposes of soil from
Areas 2, 3, 4, and .7. Other alternatives that treat Area 1 soil would ha.ye contained soil in
Areas 2, 3, 4, and 7, therefore requiring long-term maintenance of residual contaminants on
site. Risk versus cost were compared under each alternative. Higher risk levels were selected
based on cost and ability to detect clean-up level. Operating costs were considered in decision
to permanently treat and dispose of the contaminated soil.
17.
What technical considerations were factors in selecting a remedy? We[re technical
considerations primary in the selection of the remedy?
' ' • - > '
The diversity of site contaminants (both semivolatile organics and metajls) was a primary factor
in eliminating innovative technologies such as soil washing and solvent extraction.
-5-
847
-------
Spickler Landfill
OU-1

Spencer, Wisconsin
Region 5
GENERAL SITE INFORMATION

7. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Waste (mg/kg)

Leachate sampling identified compounds
such as asbestos, ethylbenzene, xylenes, and
benzoic acid.

Brine Pit Sludge (ppm)

Mercury 30
Site History

NPL Proposed: , N/A
NPL Final: 7/87
FS: 11/91
ROD: 5/92

Background

PRP-lead
PRPs: BASF Corp., Weyerhaeuser Co.
FS prepared by: Warzyn, Inc.
Leachate sampling also identified contaminants such as calcium, magnesium, benzene,
ethylbenzene, toluene, xylene, chlorinated ethenes, ketones, phenols, chlorinated aromatics,
polyaromatic hydrocarbons, and phthalates. .
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 134,000 cubic yards of landfill refuse
• 2,600 cubic yards of brine pit sludge ;

3. What type of site is this?

Industrial Landfill. An inactive municipal landfill and a mercury brine pit located in a
sparsely populated rural area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?
Standard technologies considered during the identification and screening of technically feasible
technologies were: , ,
848
-i-
-------
Landfill Soil/Waste
Access restriction:
Containment:
Physical treatment:
Thermal treatment:
Disposal:
Deed restrictions, zoning restrictions ]'-.'••
Capping (clay, root zone material, topsoil, synthetic membrane, NR
504, solid waste cap, NR 660 hazardous waste cap), horizontal barriers
(slurry layer, grout layer), vertical barriers (sluiry curtain, grout
curtain, sheet piles, hydraulic barrier) ;
Stabilization/solidification ,
Incineration (rotary kiln, infrared) ,
Excavation, disposal (on-site, off-site, RCRA landfill, solid waste
landfill) . (
Brine Pit sludge

Access restriction:
Containment:
Physical treatment:
Disposal:
Deed restrictions, zoning restrictions • ' i.
Capping - . ;
Stabilization/solidification
Excavation, disposal (on-site, off-site, RCRA landfill, solid waste
landfill)
5. Was an innovative technology considered in the FS? If so, which technology?
' i "
Innovative technologies considered during the identification and screening of technically
feasible technologies were:

LandfillSoil/Waste
1

Biological treatment: Composting, in situ biodegradation .
Phys/Chem treatment: Oxidation, reduction, solvent extraction, soil Cashing
Thermal treatment: Vitrification, thermal volatilization '

Brine Pit Sludge i

Phys/Chem treatment: Solvent extraction, soil washing j
'i •

6. What was the cost estimate for the innovative technology?

Fencing/deed restrictions/NR 504 cap
over landfill/NR 660 cap over brine
pit/landfill gas control/leachate
collection and treatment/ground water
monitoring

Fencing/deed restrictions, NR 504 cap
over landfill/solidification and
stabilization of brine pit and NR 660
cap/landfill gas control/leachate
collection and treatment/ground
water monitoring
,.
Fencing/deed restrictions, NR 504 cap
over landfill/solidification and
stabilization of brine pit and NR 660
cap/landfill gas control/leachate
collection and treatment/ground water
pump and treat
S. If a standard technology was chosen, why?
Estimated Costs
3 Criteria
N/A
9 Criteria

$5,220,000
$4,590,000
N/A
$4,860,000
N/A
$6,410,000
S • rl • / aUSe " Provides Protection against direct contact with waste and
reduces mfiltrauon of precipitation and leachate production and migration to ground wateT A*

S£S£liSSSB *" T1^ ^ Ph ^^ the wite disP°sed of in the Pitt

is
effect
-ter
850
-3-
-------
The selected remedy changed after the publication of the Feasibility Study and Proposed Plan.
Originally, RAA-5 was the preferred alternative for the entire site. More recently, EPA
determined that an operable unit approach is more appropriate for the iSite because it allows a
more focused, logical approach, whereby the landfill, which is the source of ground water
contamination, is remediated first. The results of this action are needed to make an informed
decision on a final remedy. - ' . I
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
Ifan innovative technology was notchosen, why not?'At what stage wasthe innovative
technology eliminated? ' i
' |- . -'-
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tliree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
• ~ '. • • i •
Innovative technologies eliminated during the initial screening include ithe following:

Landfill Soil/Waste I

• Composting was eliminated because it would not treat the wide variety of contaminants
found at the site. i
• In situ biodegradation was eliminated because it would not trealt the wide variety of
contaminants found at the site. •
» Solvent extraction was eliminated because it would not treat the; wide variety of
contaminants found at the site. !
« Soil,washing was eliminated because it would not treat the widii variety of
contaminants found at the site. \
• Oxidation was eliminated because it is not applicable to the trejitment of refuse.
• Reduction was eliminated because it is not applicable to the treatment of refuse.
• , ' Thermal volatilization was eliminated because it is not applicable to the .treatment of
refuse. ,
• Vitrification was eliminated because it is not well suited for large quantities of refuse.
Air emissions control equipment used in the process are generally mot capable of
handling the fluctuating emissions concentrations resulting from' vitrification of
heterogeneous refuse. The lack of a sufficient water supply on site for use in offgas
scrubbers, and the ultimate treatment and disposal of scrubber liquids, also sufficiently
reduce the viability of this technology. Finally, GEOSAFE, soli3 marketer of the
vitrification process, suspended commercial use of their process pending an
investigation of a fire that occurred during a site remediation using vitrification.
' ' * •!
Brine Pit Sludge

• Solvent extraction for brine pit sludge was eliminated because, though it would remove
mercury from the excavated brine pit material, the resulting treated waste still would
have to be disposed of. i ..
-4-
851
-------
• Soil washing for brine pit sludge was eliminated because, though it would remove
mercury from the excavated brine pit material, the resulting treated waste still would
have to be disposed of.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

» None
77. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were long-term
effectiveness and permanence, and the reduction of contaminant mobility. RAA-4 was more
permanent because it permanently eliminates contaminant mobility in the mercury brine pit
with stabilization/solidification and an NR 660 cap.
72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?,

Cleanup level were not established for soil/waste or sludge.
75. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

H None ,

Standard technologies eliminated because of cleanup goals include:

" None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
832
-5-
-------
15. What measures/criteria were used to compare alternatives? i

The following measures were used to compare the alternatives: i

Risk reduction ,,!.'.
Preference for treatment (vs. containment) '; ~
- ' • - . . i . •
•"• ' • ' 'i
16. How are measures compared?

The selected remedy was preferred because it provides the greatest reduction in risk through
both treatment and containment of contaminated sources. Stabilization/ solidification in
combination with an NR 660 cap will ensure that leachate in the pit will not enter the ground
water and it will significantly reduce the production of leachate in the future. Containment
alone would not have accomplished this. \ '
17. What technical considerations were factors in selecting a remedy? Wdre technical
considerations primary in the selection of the, remedy? !

Technical considerations were not primary in selecting a remedial alternative.
853
-------
Stoughton City Landfill

Stoughton, Wisconsin
Region 5
GENERAL SITE INFORMATION
7.
2.
Wluit were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediment (mg/kg)

Only a limited waste sampling was
conducted.

Chromium 40
Bis(2-ethylhexyl)phthalate 600
Benzoic Acid 2.8
Cadmium 27
Lead 460 '
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
6/86
6/20/91
9/30/91
Background

EPA Fund-lead
PRPs: Unirqyal Plastics, Inc.,
City of Stoughton
FS .prepared by: ENSR Consulting
and Engineering
What volume of material is to be remediated?

The volume of material to be remediated included:

• 218,000 cubic yards of waste
3. What type of site is this?
/

Municipal Landfill. The site contains a 15-acre sanitary landfill, which was officially closed in
1982. It is in an urban area bordered by undeveloped land, wetlands, and a residential area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
854
Deed restrictions, fencing .
Cap repair and upgrade, single layer cap (clay, sprayed asphalt, paved
asphalt, corierete), multilayer cap (clay cap, synthetic geomembrane,
clay geomembrane), horizontal barriers (grout injection, liners), surface
-1-
-------
Thermal treatment:
Disposal:
control (grading, soil stabilization, revegetationi diversion and
collection systems) [
Incineration |
On-site RCRA landfill, off-site RCRA landfill |
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
• • - • ' • ' V ' :
Biological treatment: Bioremediation '
Chemical treatment: Solvent extraction, soil flushing, chemical oxidation, chemical
reduction
Thermal treatment: Low-temperature volatilization, vitrification, soil vapor extraction
6. What was the cost estimate for the innovative technology? !
• •'••,'• y • • , '- .
During the initial screening process, in which technically feasible technologies are identified \
(prior to the formulation of RAAs), the FS does not quantify costs. After f:he RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that rrterit a more detailed
evaluation. For this site, the estimated costs were calculated during an'evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; and community acceptance. !

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
7.
Alternative
RAA-8
Innovative Technology
Solvent extraction
Estimated Costs
3 Criteria
N/A
How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technol
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action/monitoring
Cap repair and upgrade/fencing/ground
water use/deed restrictions
9 Criteria
eliminated
ogitss
Estimated Costs
3 Criteria
N/J
Nh
\
^
9 Criteria
$2,074,000
$4,409,000
-
2 835
-------
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
Standard Technology
Subtitle D multilayer clay cap/fencing/
deed restrictions/monitoring
Subtitle D multilayer clay cap/ground
water interceptor and barrier trenches/
optional consolidation of waste/fencing/
deed restrictions/monitoring.
Subtitle D multilayer clay cap/ground
water collection and treatment/fencing/
deed restrictions/monitoring
Subtitle D multilayer clay cap/physical
barrier/optional consolidation of waste/
ground water collection and treatment/
fencing/deed restrictions/monitoring
Subtitle D multilayer cap/consolidation
of waste/optional ground water collec-
tion and treatment/fencing/deed
restrictions/monitoring
Estimated Costs
3 Criteria
, N/A
N/A
N/A
N/A -
N/A
9 Criteria
$5,237,000
$12,349,000
to
$13,8 13,000
$6,228,000
$11,031,000
to
$12,445,000
$7,546,000
to
$8,524,000
8. If a standard technology was chosen,, why?

RAA-7 was chosen because it is protective of public health and the environment and is cost-
effective. This alternative is protective through institutional controls and through excavating
waste currently exposed to ground water and disposing of it with other landfill wastes. A
Subtitle D multilayer cap reduces site risks by eliminating the potential for direct exposure and
by reducing the infiltration of precipitation. The mobility of site contaminants to ground water
is reduced because the generation of leachate is reduced. Source control treatments in
combination with the ground water treatment proposed by this alternative will reduce
contaminant levels in the aquifer to the State's standards. This alternative also was preferred
because it proposes the most effective long-term treatment, since waste in contact with ground
water will be excavated and consolidated under the cap. Implementation of this alternative
will be difficult, but technically feasible. This alternative, unlike others, minimizes short-term
risk and does not threaten nearby wetlands. Of the two alternatives that offer equal protection,
RAA-7 is less costly.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
856
-3-
-------
10. If an innovative technology was not chosen, 'why not? At what stage wtas the innovative
technology eliminated? ' , .

Innovative technologies eliminated during the initial screening include!the following:
/ l
• Bioremediation was eliminated because it would not be possible to inject nutrient
solutions into the heterogenous subsurface of the landfill. Not all compounds in the
landfill could be treated using this technology.
• Solvent extraction was eliminated because it would not be possible to excavate all soils
and waste from the landfill for treatment. I .
• Soil flushing was eliminated because it would not be possible io flush the heterogenous
subsurface of the landfill. Not all compounds in the landfill could be treated using this
technology.
• Chemical oxidation was eliminated because it would not be pcissible to flush the
heterogenous subsurface of the landfill. Not all compounds in! the landfill could be
treated using this technology. .'•[•'
• Chemical reduction was eliminated because it would not be possible to flush the
heterogenous subsurface of the landfill. Not all compounds in the landfill could be
treated using this technology.
, • Low-temperature volatilization was eliminated because it would not be possible to
excavate all soils and waste from the landfill for treatment. i
• Vitrification was eliminated, because saturated soil conditions at the landfill would
hinder implementation. j
r
Innovative technologies eliminated during the screening of the three criteria include the
following:

• Soil vapor extraction was eliminated because it would be applicable only to VOCs and
likely would not meet the goal of reducing THF. !

Innovative technologies eliminated during the detailed analysis include the following:

•' None' '_ .- . . :- • I

•. • ' • • • ' '••'!.'. ' •' •
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovattye technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
Protectiveness of human health and the environment, long-term effectiveness and permanence,
and cost were weighted most heavily in selecting the preferred technology. RAA-8 (vapor
extraction) was eliminated because it would not effectively reduce concentrations of THF, and
therefore would not provide an adequate degree of human health and environmental protection.
While RAA-7 is among the most costly alternatives, it provides a high [degree of long-term
human health and environmental protection by minimizing leaching of THF to ground water,
removing contaminated soils currently in contact with ground water, arid, if necessary, treating
ground water to meet ARARs.
-4-
857
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

No chemical-specific cleanup levels were established for soil, sediments, or wastes at the site.
Site assessors expect that the selected alternative will reduce the leaching and migration of
THF, barium, chromium, and selenium from landfill wastes and soil to ground water.
Implementation of RAA-7 will eventually reduce concentrations of these chemicals in ground
water to below Wisconsin Ground Water Standards.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? -

Innovative technologies eliminated because of cleanup goals include:

" Solvent extraction

Standard technologies eliminated because of cleanup goals include:

« Cap repair and upgrade
. ' •

14. Were treatability studies conducted on the innovative technology or standard technology?

'
No treatability studies were conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

• Cost-effectiveness
» Protection of human health

16. How are measures compared? • •
'
The chosen alternative represents the most protective alternative proposed. One other
alternate, RAA-6, would have provided equal protection, but was much more costly.
Therefore, the chosen alternative also is the most cost-effective alternative.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a final remedy. The site does border
wetlands, however, and RAA-6 was eliminated, in part because the physical barrier proposed
in this alternative could adversely affect the wetlands.
85S
-------
Sturgis Municipal Well Field

Sturgis, Michigan
Region 5
GENERAL SITE INFORMATION
1. What were the principal
contaminant levels, and
this feasibility study?

contaminants,
media addressed in

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Trichloroethene
Tetrachloroethene
Cyanide
PAHs
PCBs

99
260
0.188
61.2
5.59
.

Site History

NPL Proposed:
NPL Final:
FS:
ROD:

N/A
\ . 11982
! 5/91
9/30/91
i
Background

EPA Fund-lead
PRPs: "N/A
FS prepared by:
Inc.

; ,
k
Warzyn Engineering,
i1
, i
* ' i
What volume of material is to be
remediated? ,

The volume of material to be remediated included: '

» 10,000 cubic yards of soil to be excavated at the Kirsch property
• 890 cubic yards of soil to be excavated at the Wade property I
What type of site is this?

Fabricated Metal Products. The site was previously occupied by the Kirsch Company a former
manufacturer and cyanide-based metal plating operations and the formei; Wade Electrical
facility which has since burnt down: It is located within the City of Sttirgis.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: >
Access restriction:
Containment:

Physical treatment:
Deed restrictions, fencing
Capping (soil, clay, synthetic membrane, MDNR Act 641 Solid Waste
Management cap, MDNR Act 64 Hazardous Waste Management cap)
Mechanical soil aeration
-1-
859
-------
Thermal treatment: Incineration (rotary kiln, single chamber, teepee burner open pit,
multiple chamber, controlled air)
Disposal: Excavation, disposal (on-site, off-site)
3
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ biodegradation, ex situ biodegradation (in general), landfarming,
slurry reactor -
Chemical treatment: Soil washing, solvent extraction, flushing, oxidation, dehalogenation
Physical treatment: Soil vapor extraction (SVE)
Thermal treatment: Enhanced thermal volatilization (pn-site, off-site), in situ vitrification
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2
RAA-3
Innovative Technology
Soil vapor extraction/solid waste cap or
hazardous waste cap
Soil vapor extraction/excavation of
PCB and PAH containing soil/off-site
disposal or incineration
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$1,610,000
or
$2,970,000"
$2,310,000
or
$6,460,000b
The two costs refer to either a solid waste cap or a hazardous waste cap.
bThe two costs refer to the choice of either off-site disposal of incineration.
880
-2-
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) !
Alternative-
RAA-1
Standard Technology
No action
Estimated Costs
3 .Criteria
N/A
9 Criteria
$104,000
8. If a standard technology was chosen, why?

Off-site disposal of PAH/PCB contaminated soil was selected.
10.
If an innovative technology was chosen, why? !
•' ' • ,| '
RAA-3 was selected because it protects human health and the environment though treatment.
Implementation of this alternative eliminates the Kirsch and Wade properties as sources of
ground water contamination, thereby reducing potential risk to human heiilth and the
environment posed by possible use of contaminated ground water. RAA--3 affords a high
degree of effectiveness by treating with SVE the principal threat (VO^s) in the source area
soils, and removing the remaining PAH/PCB contaminated soil for disposal off site. This
alternative was also preferred because the permanent elimination of site contaminants will
allow for unrestricted future land use. No unacceptable short-term risk or cross-media impacts
will be caused by the implementation of this alternative. Standard safety programs, such as
fencing, use of protective equipment, monitoring, and dust control measures should mitigate
any short-term risks. This remedy complies with all ARARs and is ciost-effective. The clean
closure of the source areas will permanently reduce contamination to acceptable levels and it
does not cost significantly more than containing contaminated soil on-site.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• On-site enhanced thermal volatilization was eliminated because it would be difficult to
excavate the deep contaminated soil for treatment. Given the relatively small volume
of soil contaminated by high levels of-VOCs and the additional substantive
requirements of on-site treatment, off-site treatment is more implementable.
, • Ex situ biodegradation (general) was eliminated because its feffectiveness for
TCE/PCE-contaminated soil has not been demonstrated, and costs would likely be high
given the amount of treatability study work that would be required and given the
861
-------
length of time that biological systems typically take to degrade recalcitrant organic
compounds.
• Land/arming was eliminated because of a lack of space.
• Moving bed or rotary drum were eliminated because no applications of this sort have
been identified for soils with relatively low-level VOC contamination present in the
deeper soil. .
• Slurry reactor was eliminated because it would produce an aqueous waste stream
requiring treatment and disposal, and pilot testing would be required
• Soil washing was eliminated because it would not be very effective in treating the
relatively low levels of VOC present in the deeper levels of contaminated soil
Implementation would be more difficult than for some other options because the liquid
waste stream would need to be managed. ,
• Solvent extraction was eliminated because it would not be yery effective in treating the
relatively low levels of VOCs present in the deeper levels of contaminated soil
Implementation would be more difficult than for some other options because the liquid
waste stream would need to be managed.
" ^ situ vitrification was eliminated because of the high cost of the power requirements,
difficulties in implementation due to nearby buildings, and the availability of other
effective treatment options.
" Flushing was eliminated because its effectiveness has not been demonstrated and it
might not be implementable since it could cause further ground water contamination
In situ oxidation was eliminated because the effectiveness of chemically treating
relatively low levels of VOCs has not been demonstrated and therefore might not be
effective for the deeper levels of contaminated soil. Furthermore, the inability to
control the reaction and the potential for ground water contamination would present
problems in implementing this option.
• In situ dehalogenation was eliminated because the effectiveness of chemically treating
relatively low levels of. VOCs has not been demonstrated and therefore might not be
effective for the deeper levels of contaminated soil. Furthermore, the inability to
control the reaction and the potential for ground water contamination would present
problems in implementing this option.
• In situ biodegradation was eliminated because it might produce hazardous substances
and because identifying and maintaining a suitable environment would be difficult '
The potential for ground water contamination would limit the implementability of this
treatment. Two carbon sources and nutrients likely would have to be added to provide
a suitable environment for the microorganism.

Innovative technologies eliminated during the screening of the three criteria include the
following: .

» Enhanced thermal volatilization (off-site) was eliminated because soil vapor extraction
is a proven effective means of removing volatile compounds and this technique would
not offer any additional advantages such as the removal of PAHs.

Innovative technologies eliminated during the detailed analysis include the following:

" None
.)
8G2
-4-
-------
11.
12.
Which of the nine criteria were weighted most heavily in selecting the* technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighed most heavily in selecting a remedial alternative vtere protection of human
health and the environment, long-term effectiveness, and cost. RAA-li was eliminated because
it would not be protective of human health. RAA-2 was eliminated because it would require
long-term maintenance of the cap and permanent restrictions on the use of the contaminated
land. In RAA-3, the choice for treatment for PCB and PAH contaminated soil was
incineration or off-site disposal. Off-site disposal was selected because it was significantly less
expense than incineration. , . .',-!'.

•, • i , • •
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAB
Carcinogens .
Trichloroethene
Tetrachloroethene
Benzo(a)pyrene
Benzo(b)fluoranthene
60
14
330
330
Micl
L or Other Basis

rigan Act 307a
Michigan Act 307

MDLb
'MDL
"Michigan Act 307 Type B cleanup, based on "20 times" the ground water standard.
"Method Detection Level. . , i
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None .

Standard technologies eliminated because of cleanup goals include:

• None ,
14. Were treatability studies conducted on the innovative technology or standard technology?
... ' • I
Treatability studies were not conducted.
-5-
863
-------
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare me alternatives:

Proven reliability
Waste left in place/institutional control

16. How are measures compared?

RAA-3 was preferred over RAA-2 because it will be more reliable. Once RAA-3 is
completed, it will neither depend on institutional controls nor require perpetual maintenance.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
8G4
-6-
-------
Tar Lake
OU-1

Antrim County, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
\, _ , , . . '

Maximum concentrations of principal
" , contaminants were:
Soil/Tars (mg/kg)

Benzene
Ethylbenzene
Toluene
Styrene
Xylenes
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(f)fluoranthene
Benzo(k)fluoranthene
Chrysene
Di-n-butyl phthalate
Fluoranthene
Fluorene
Naphthalene
Pyrene
2,4-Dimethylphenol
2-Methylphenol
4-Methylphenol
1.2
100
100
2.3
280
280
280 .
280
280
280
280
280
280
100
340
280
2,000
1,100
1,400
Site Elistory
NPL Proposed:
NPL Final:
FS:
ROD:
1:2/82
9/83
21/92
9/29/92
Background

PRP-lead !
PRPs: Fifty-sixth Century Antrim Iron
Works Comptany
FS prepared by: Environmental Safety
Designs , Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:
^•-' ' - '
• 30,000 cubic yards of tar ,
• 20,000 cubic yards of soil with high levels of contamination (ail excess cancer risk
equal to or greater than 10"2)
• 20,000 cubic yards of soil with low levels of contamination (an excess cancer risk less
than 10'2 and greater than 10'6)
-1-
865
-------
3. What type of site is this? ,

Wood Charcoal Production. A large natural surface depression filled with waste materials
from a wood charcoal production operation.
I)
TECHNOLOGY SELECTION

4. What'Standard technologies were considered for selection in this FS?

Standard technologies incorporated into RAAs were;
Access restriction:
Containment:
Physical treatment:
Thermal treatment:
Disposal:
Deed restrictions
RCRA cap
Dewatering ;
Incineration '
Excavation, off-site disposal at RCRA facility, on-site disposal in
RCRA cells
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies incorporated into RAAs were:

Biological treatment: Bioremediation
Thermal treatment: Thermal desorption x

6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the .RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, no three-criteria screening was conducted and the estimated costs
were calculated during an evaluation based on nine criteria established by the NCP.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
366
Alternative
RAA-2

Innovative Technology
Deed restrictions/excavation/on-site
incineration of tar and highly
contaminated soils/bioremediation of
remaining soils/RCRA cap/interim
ground water containment
Estimated Costs
3 Criteria
N/A

9 Criteria
$51,400,000

-2-
-------
Alternative
RAA-4
RAA-7
Innovative Technology
Excavation/on-site incineration of tar
and highly contaminated soils/thermal
desorption of remaining soils/interim
ground water containment
Excavation/off-site disposal of tar and
highly contaminated soils at RCRA
facility/bioremediation of remaining
soils/interim ground water containment
Estimated Costs
3 Criteria
*
I1
I/A
/
I/A
9 Criteria
$64,200,000
$51,400,000
7. How did the cost(s) compare to standard technologies?

_' Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-3
RAA-5
RAA-6
Standard Technology
No action
Excavation/on-site incineration of tar
and highly contaminated soils/excava-
tion/off-site disposal of remaining
soils/interim ground water containment
Excavation of tar and all soils/dewater
tar/off-site disposal at RCRA facility/
interim ground water containment
Excavation and consolidation of tar
and all soils/on-site disposal in RCRA
cell/cover (cap)/interim ground water
containment
Estimated Costs
3 Criteria
i{r/A
N/A
' tf/A
N/A .
9 Criteria
$0
$58,500,000
$52,300,000
$20,100,000
' - ..-'••",
If a standard technology was chosen, why? ,

The standard technology selected includes excavation of tar and all soils; on-site disposal in a
RCRA cell; interim ground water containment. The technology was selected because: 1) it
was the most cost effective, 2) minimizes risk by eliminating exposure (ground water and
. ingestion) pathways, and 3) not subject to RCRA Land Disposal Regulations.
If an innovative technology was chosen, why?

An innovative technology was not chosen.
-3-
867
-------
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the'three criteria of
effectiveness,
-------
Contaminant
Benzo(a)anthracene
Benzo(b) fluoranthene
Benzo(k) fluoranthene
Chrysene x
Cleanup Level (ppb)
100
100
100
100
ARAR or Other Basis
•i
Michigan! Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Noncarcinogens
Ethylbenzene
Toluene
Xylenes
Acenaphthene
Anthracene
Di-n-butyl phthalate
Fluoranthene
Fluorene
Naphthalene
Pyrene
2,4-Dimethylphenol
2-Methylphenol
4-Methylphenol
1,400
16,000
6,000
2,000
40,000
14,000
6,000
6,000
800
4,000
8,000
8,000
8,000
Michigan Act 307
, Michigan Act 307
Michigan Act 307
Michigan Act 307
- Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307
Michigan Act 307 <
Michigan Act 307
Michigan Act 307
•
Michigan Act 307
Michigan Act 307
Remedial action cleanup standards were based on Michigan'Environmental Response Act 307,
Type B cleanup criteria. Cleanup levels developed by Type B criteria an; health based and
reduce risk to less than 10"6. If local background concentrations are greater than the health-
based criteria, then average local background concentrations can be used as final cleanup
goals. . i -

, . , - i
13: Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ~ •

Innovative technologies eliminated because of cleanup goals include:
/ . , " : •,._'•
• None'. .' . ..•",!• ;

Standard technologies eliminated because of cleanup goals include:
- ' " !
• None ' .
-5-
889
-------
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
Total Cost

16. How are measures compared?

The selected alternative was chosen because it is the* most, cost-effective option. The selected
alternative provides a high degree of protectiveness through the containment of contaminated
soils. All other alternatives (except RAA-1) would provide an equal degree of protection
through a variety of treatment technologies. The selected alternative provides equal
protectiveness at one-third the cost.
77.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in the selection of a remedial alternative.
870
-6-
-------
Thermo-Chein, Inc.
OU-1

Egelston Township, Michigan
Region 5
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:
Soil/Sludge (mg/kg)
Benzene
Toluene
Xylenes
Naphthalene
2-Methylnaphthalene
1 Aroclor-1254
Heptachlor
Dieldrin
4,4-DDT
Arsenic .
Chromium
Lead
Cyanide .

19
270
770 . '
.3
3 ...
1
0.2
0.2
0.03
10
978
' ' ' • '
I
Site History
I
NPL Proposed: i 10/84
NPL Final: 1 6/86
FS: ! 5/91
ROD: i 9/30/91
- i . >
Background
EPA Fund-lead
PRPs: Thermo-Chem, Thomas Solvent
Co. i ^ - •* :,
FS prepared by: Environmental
Resources Management-North '
Central, Incorporated
i

1
r
1,050 ' ••.!.'-
599 ' I
What volume of material is to be remediated?

The volume of material to be remediated included:

• 2000 cubic yards of soil and sludge
• 157,000 cubic yards of remaining contaminated soil
What type of site is this?

Recycling. An inactive solvent and chemical waste reprocessing, refining, and incineration
facility.
-1-
871
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard .technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:

Chemical treatment:
Thermal treatment:
Disposal:
Fencing, deed restrictions ,
Capping (clay, synthetic liners, concrete, asphalt, vegetative, multi-
layer), grout barriers, slurry wall, sheet piles, vertical barriers
Solidification/stabilization, neutralization
Incineration (fluidized bed, infrared, rotary kiln)
Excavation, disposal at RCRA facility/non-RCRA facility
5. Was an innovative technology considered in the FS? If so, 'which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ biodegradation (aerobic/anaerobic)
Chemical treatment: In situ soil flushing (solvent), oxidation/reduction
Thermal treatment: In situ vitrification, in situ vacuum vapor extraction, low temperature
thermal treatment
6. What was the cost estimate for the innovative technology? \

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2
RAA-3A
(RAA-3)"
Innovative Technology
Fencing/deed restrictions/in situ
vitrification of Group 1 and 2a (2 and
3)b soil/ground water monitoring
Off-site incineration of Group 1 & 2
soils/in situ vacuum vapor extraction
of remaining soil/ground water collec-
tion, treatment, and disposal at
POTW
Estimated Costs
3 Criteria
-N/A
N/A
9 Criteria
$82,700,000
$24,300,000
872
-2-
-------
Alternative
RAA-3B
RAA-4A
(RAA-4)b
RAA-4B
Innovative Technology
On-site incineration of Group 1 soil/in
situ vacuum vapor extraction of Group
2 soil/ground water collection,
treatment, and disposal at POTW
Off-site incineration of Group 1 soil/in
situ soil flushing and biodegradation of
Group 2 soil/ground water collection,
treatment, and discharge to aquifer
On-site incineration of Group 1 soil/in
situ solvent flushing and biodegradation
of Group 2 soil/ground water collection,
treatment, and discharge to aquifer
Estimated Costs
3 Criteria
N7A
' E '-
N/A
N/A
9 Criteria
$23,000,000
$24,000,000
$24,000,000
"Soils were designated as Group 1 or Group 2 soil for the purposes of [remediation,.
'Text presented parenthetically represents corresponding changes in the? ROD.
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Techno
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-5
Standard Technology
No action
Slurry wall/RCRA cap/ground water
collection, treatment, and discharge to
POTW
1
logics
Estimated Costs
3 Criteria
N;;A ••
- N/A - .
9 Criteria
$0
$32,000,000
8. If a standard technology was chosen, why?

Incineration was selected as a component of the remedy. It was selected to: 1) comply with
the Michigan Act 307 Rules for a Type A/B clean-up given the potential residential use of the
site, 2) to meet LDRs, 3) destroys organic and PCB/pesticides, 4) easy to implement because
it's been used at other Superfund sites. i
9. If an innovative technology was chosen, why?

Soil vapor extraction was selected as a component of the remedy. It wks selected 1) to reduce
toxicity, 2) it is easy to implement because it has been used at other Superfund sites, 3) it will
take less than 4 years implement and 4) cost.
-3-
873
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

* Low temperature thermal treatment was eliminated but no explanation was given.

Innovative technologies eliminated during the screening of the three criteria include the
following:

H None
v • • •
Innovative technologies eliminated during the detailed analysis include the following:

• In situ biodegradation was eliminated because it could not be performed during winter
months, because it is a relatively new technology and EPA would need to perform
treatability studies before implementing it.
" In situ soil flushing was eliminated because it would take too long to remediate the
site, cleanup levels.
• In situ vitrification was eliminated because of the technical and administrative
difficulty is uncertain because the technology has not been applied fully at any
Superfund site and the high cost.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted criteria in selecting an innovative technology were protectiveness
of human health and the environment, cost, time to implement the technology and compliance
with ARARs.. Of the three proposed innovative technologies that would offer comparable
protection, compliance with ARARs, and reduction of contaminants, the chosen alternative is
the least costly and the most rapid to implement. Thus, criteria that resulted in the elimination
of innovative technologies were cost and implementability.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
874
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Benzene
Aroclor-1254
. 10
1
Michigan Act8'0
Michigan Actb'°
-4-
-------

Contaminant
Heptachlor
Dieldrin
4,4-DDT
Arsenic -
Chromium
Lead
Cleanup Level (mg/kg)
0.00004
0.0000006
0.00005
0.0004
0.04
9
ARAR or Other Basis
Miphigan Actb
Michigan Actb
Michigan Act*1
Michigan Aetb
Michigan Actb
Michigan Actb
Noncarcinogens
Toluene
Naphthalene
2-Methylnaphthalene
Xylenes -
Cyanide
2
0.6
0.2
1
0.08
Michigan Actb
Michigan Actb
Michigan Actb
Michigan Actb:
Michigan Actb
The Michigan Environmental Response Act (Michigan Act 30[7) establishes the
criteria for three acceptable cleanup types. Under this statute, Type A cleanup
generally achieves background or nondetectable levels. Type B cleanup achieves
^ levels that protect ground water from the migration of soil contaminants into the
""" ground water; protect against unacceptable human health risks due to direct contact;
and protect surface water quality. Type C cleanup is based on site-specific criteria.
EPA selected a Type A/E cleanup given potential residential use of the site. A 10"6
risk level for carcinogens was chosen as the point of departure j for determining
remediation goals.
bBased on ground water protection. j
cBased on 10"6 carcinogen risk associated with direct contact.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:
•. ' . i.. • •
• None
i .
Standard technologies eliminated because of cleanup goals include: '
•r

'••-• None I
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. j
-5-
875
-------
n
/5. What measures/criteria were used to compare alternatives ?
• ' ''•"•'•' . • • 0
The following measures were used to compare the alternatives: •••-;'

Cost-effectiveness
Time to design/construct/operate , I
Proven reliability . • • 1 '
Preference for treatment (vs. containment)

i . •
16. How are measures compared?
,\
The chosen alternative provides a high degree of effectiveness and permanence through source '
treatment, which was preferred over containment. RAA-5 proposed no source treatment and
was considered less effective. Cost-effectiveness was also a primary factor. One alternative
(RAA-2) offered a comparable amount of protection through source treatment, but was !
eliminated because it was hot cost-effective. Other alternatives (RAA-4A and RAA-4B) were , i
eliminated because their time to operate was too long. Treatability studies would have been
required due to the unproven reliability of the treatment technology (biodegradation).
'
" ' i
17. What technical considerations were factors in selecting a remedy? Were technical \
considerations primary in the selection of the remedy? M^,
Am
No technical considerations were primary to the selection of a remedy. ^^ .
I)
876
-6-
-------
Torch Lake
OU-landOU-3

Houghton County, Michigan
Region 5
GENERAL SITE INFORMATION
.1.
wnai were tne principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Slag piles/Tailings (rag/kg)
11 Jf A: I " ' '
Metals: ,

Arsenic 118
Antimony 164
Beryllium 2
Chromium 745
Copper 13,500
Lead 113 .

Site History ,
NPL Proposed: 10/84
NPL Final: 6/86
FS: 4/92
ROD: 9/30/92

Background

EPA Fund-lead
PRPs: Universal Oil Products; Quincy
Mining Company
FS prepared by: SEC Donohue
Incorporated

PAHs:

Napthalene .17
2-Methynaphthalene .24
Acenaphthalene .037
Phenanthrene, .27
Fluoranthene .4
Pyrene .39
Chrysehe .41
What volume of material is to be remediated?

The volume of material to be remediated included:

• 81,250,000 cubic yards of tailings
• 150,798 cubic yards of slag piles
S3. What type of site is this?. .

Primary Metal Products. A copper milling and smelting facility. OU-1 includes surface
tailings and slag piles on the western shore of Torch Lake. OU-3 consists of 12 tailing and
slag locations throughout the mid-Keweenau Peninsula.
-1-
877
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Slag piles

Access restriction: Fencing, deed restrictions
Containment: RCRA cap, non-RCRA cap, soil cap, vegetation
Chemical treatment: On-site solidification/stabilization, off-site solidification/stabilization

Tailings =

Access restriction: Fencing, deed restrictions
Containment: RCRA cap, non-RCRA cap, soil cap, vegetation

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Slag piles ,

Chemical treatment: Hydrometallurgic reprocessing, heap leaching
Thermal treatment: Pyrbmetallurgic reprocessing

6. What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into remedial alternatives.
878
-2-
-------
7.
How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technplojjies
(selected remedial alternative is in bold)
Slag Piles
Alternative
RAA-S-1
RAA-S-2
RAA-S-3
RAA-S-4
Tailings
Alternative
RAA-T-1
RAA-T-2
RAA-T-3
Standard Technology
No action
Fencing/deed restrictions
Soil cover/vegetation
Excavate/off-site disposal at permitted
landfill
Estimated Costs
3 Criteria
$0
$60i,000
$116,900
$11,148,000
•' • • .-i. • .
• 1 .
Standard Technology
No action
Soil cover/vegetation/deed restrictions
Non-RCRA cap/soil cover/vegetation/
deed restrictions
9 Criteria
$0
$60,000
$116,900
$11,148,000

Estimated Costs
3 Criteria
$0
$7,200,000
$26,000,000
'•
9 Criteria
$0
$7,003,000
eliminated
' . ' I t
8. If a standard technology was chosen, why? i
' ' , ' l'K
The selected remedy included soil cover/vegetation of specified slag'piles in areas, no action
on other specified slag piles and a soil cover/vegetation/deed restrictions on the tailings pile
The primary goals is to 1) protect ingestion and breathing of dust particles and contaminants
.2) to minimize affect on ecosystems, ground water and sediments, 3) volume- of material 4)
cost, 5) avoids excavation which would stir up dust. Certain areas of tlie tailings pile were to
remain uncovered in response to public comments. !
I . ' -

For OU-3, assuming that this area will become a National Historic Park, the results of the risk
assessment showed both carcinogenic and noncarcinogenic .risks to workers and visitors were
below EPA s acceptable risk range. However, the release of tailings from this location to the
beach is ongoing. Further, if future site use is residential, unacceptable risks are attributed
primarily to ingestion of tailings by adults or children. Therefore, RAAU-i was deemed .
sufficient to address slag piles while a more protective remedy RAA-T-2 was selected for
implementation with tailings. This choice is protective of human heath and the environment
since it eliminates the risk due to inhalation and ingestion and it minimizes transport of
contaminants mto the lake. The selected alternatives also,complies,with1 ARARs and offers -
long-term effectiveness. , i
-3-
879
-------
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
L):
JO. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? •

Innovative technologies eliminated during the initial screening include the following:

• Hydrometallurgic reprocessing was eliminated because 1) the recovery of
copper as a treatment joption would be useful only if As, Be and Cr can also
be simultaneously removed and there is no performance data to indicate this is
feasible, 2) mineralogic characteristics of tailings are not favorable for efficient
copper removal, 3) process would adversely affect surrounding ecosystems
because tailings will have to be excavated, and 4) large volume to excavate
makes it impractical. , ,
B Pyrometallurgic reprocessing was eliminated for the same reasons as hydrometallurgic
reprocessing.
» Heap leaching was eliminated because 1) no performance data is available on copper
recovery, 2) potential for simultaneous removal of As, Be, and Cr is unknown, 3) As
is present as a complex compound and is not likely to be removed by extraction, 4)
effective only during warm periods (70 - 90 F), 5) heap leaching piles would cover too
extensive an area, 6) would interfere with plans to develop Quincy Smelter as a
National Historic Park, 7) cost of excavation and consolidation is too high, 8)
excavation would generate dust and affect surrounding ecosystems.

Innovative technologies eliminated during the screening of the three criteria include the
following:

ii None

Innovative technologies eliminated during the detailed analysis include the following:

• None , •

Protection of human health and the environment and cost were the criteria that supported the
choice of a standard technology. Implementability and short term effectiveness were also
important in decision making. No innovative technologies were eliminated due to these nine
criteria.
830
-4-
-------
12

Innovative technologies eliminated because of cleanup goals include:'[.

, • • . None ; • • . ' - r ', .

Standard technologies eliminated because of cleanup goals include: !

•• None , , -^ '••:!.-' ;'

14. > Were treatability studies conducted on ^ innovative technolo^ or

" I

IS..: What measures/criteria were used to compare alternatives? ]

The following measures were used to compare the alternatives- ' '
. • . " ' 'I •
Total Cost ,| .'....-

Impact on nearby populations • | • „ •
' - • - ' • '[•-'•'

16. How are measures compared? !

"' -";^zr;^;Trs,t:;y"se"carremedy? »«°^™«
/// uriury m me selection of the remedy? |
831
-------
Tri-County Landfill CoTWaste Management of Illinois, Inc.
(and Elgin Landfill)

Elgin, Illinois
Regions
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Arochlor-1242 3.0
Benzo(a)anthracene 1.5
Benzo(a)pyrene 1.3
Benzo(b)fluoranthene 2.3
Benzo(k)fluoranthene 2.3
Chrysene 1.6
Indeno(l,2,3-cd)pyrene 0.6
Trichloroethene 0.03
Arsenic 30
Beryllium 1.3
Lead 2,200
Nickel 260
Antimony 59
Chromium - 58
Copper 3,800
Magnesium 81,000
Zinc 2,300

Sediments (mg/kg)

Aluminum 14,000
Arsenic 380
Barium 2,600
Beryllium 1.1
Calcium 97,000
Chromium 27
Cobalt 44
Copper 92
Iron . 620,000
Lead 100
Magnesium 50,000
Nickel 83
Potassium 4,900
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
3/89
7/24/92
9/30/92
Background

EPA Fund-lead
PRPs: Not listed
FS prepared by: WW Engineering &
, Science
1:)
832
-i-
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Sodium
Vanadium
Zinc
2,900
70
230
2. What volume of material is to be remediated? !

The volume of material to be remediated included:
• .! ' ' ' .'
« 3.5 million cubic yards of soil |
• 1,000 cubic yards of sediment I
•••'.' J '

3. What type of site is this?

Municipal Landfill. Tri-County landfill is an inactive landfill and Elgin landfill (which is
adjacent to Tri-County landfill) once accepted residential and commercial wastes and continues
to accept construction and landscaping debris. The site is bordered by residential and
agricultural land.
TECHNOLOGY SELECTION . i
: '
4. What standard technologies were considered for selection in this FS?\ .
I '

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Soil

Access restriction:
Containment:

Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:

Sediments

Containment:
Thermal treatment:
Disposal:
Fencing, deed restrictions
Capping (clay, synthetic membrane, asphalt, concrete, multimedia),
grading, flood control dikes, soil cover/revegetation
Fixation/solidification
Aeration, slump degradation, enhanced volatilization
Incineration
Excavation, on-site landfill, off-site landfill ,
Capping (synthetic membrane, clay, asphalt, concrete)
Incineration
Excavation, dredging, on-site landfill, off-site landfill
5. Was an innovative technology considered in the FS? If so, which technology?
i i.
! !
Innovative technologies considered during the identification and screening of technically
feasible technologies were:
-2-
883
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Soil

Biological treatment: Microbial degradation
Chemical treatment: Soil flushing, soil washing, soil vapor extraction, in situ oxidation
Thermal treatment: Vitrification . -
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Soil
Alternative
RAA-SW-1
RAA-SW-2
RAA-SW-3
Standard Technology
No action
Clay cap/fencing/deed restrictions
Multimedia cap/fencing/deed restrictions
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$0
$6,500,000
$12,600,000
Sediment
Alternative
RAA-SS-1
RAA-SS-2
Standard Technology
Excavation/on-site containment
Excavation/off-site containment
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$24,000
$34,000
5. If a standard technology was chosen, why? -

RAA-SW-2 was chosen because it will decrease site risks by reducing ground water and air
contamination. This alternative will limit the amount of precipitation which percolates through
the landfill, thereby reducing leachate generation and contaminant mobility. The cap also will
eliminate exposure from the inhalation of contaminated particulates. The alternative will
provide a permanent and long-term solution, and is the most cost-effective option.
884
-3-
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RAA-SS-1 was chosen because it will decrease site risks by reducing 1;he migration of
contaminated sediments into the ground water or air. This alternative Svill 'be effective in the
long-term and will reduce contaminant mobility. j
• 1- •
- ' '" .
• " ' ' •' . ' T
9. If an innovative technology was chosen, why? I
. i
• ' • •' i
An innovative technology was not chosen. j

i .
L * ' • ' j
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? !
i . - . •.

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tlbree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
' , ..'I..'-
Innovative technologies eliminated during the initial screening include the following:

• Soil washing was eliminated because it would require excavation of waste from its
' existing location.
• Microbial degradation was eliminated because it would be difficult to implement
because of the site's size and the heterogeneity of the waste material.
• Soil flushing was eliminated because it would be difficult to implement because of the
site's size and the heterogeneity of the waste material. j
• Soil vapor extraction was eliminated because it would be difficult to implement
because of the site's size and the heterogeneity of the waste material.'
• Vitrification was eliminated because of the amount of energy required
• In situ oxidation was eliminated because it would be difficult to control because of the
site's size and heterogeneous nature.

Innovative technologies eliminated during the screening of the three criteria include the
following: ....-•
,|

• None !
! . . ' •
Innovative technologies eliminated during the detailed analysis include the following:
,. -i
• None ' ' ' . /, , i :
11. Which of the nine criteria were weighted most heavily in selecting the ^technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protectiveness of human health and the environment and compliance with ARARs were
weighted most heavily in selecting an alternative. Since all alternatives, however, offered
adequate protection of human health and the environment and complied with all relevant
ARARs, alternatives were eliminated based on cost-effectiveness.
-4- • • ' 1 ." ' ' 835
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12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Soil
Soil Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Arochlor-1242
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Indeho(l ,2,3-cd)pyrene
Trichloroethene
Benzene
Bis(2-ethylhexyl)phthalate
Dibenzo(a,h)anthracene
Tetrachloroethene
Trichloroethene '
Arsenic
Beryllium
Lead
Nickel
0.08
0.33
0.1
0.33
0.33
0.33
0.33
0.014
0.16
7.1
0.33
0.13
0.014
0.01
0.005
9
2
CRDL"
CRDL
CRDL
CRDL
CRDL
CRDL
CRDL
Ground waterb
CRDL
Risk0
CRDL
Ground water
Ground water
CRDL
Ground water
Ground water
Ground water
Noncarcinogens
Acenaphthene
Anthracene
BenzoCg.h.iJperylene
Butylbenzylphthalate
Di-n-butylphthalate
Dichlorobenzene
Ethylbenzene
Fluoranthene
86
9,100
120
4.4
8
4.1
27
1,200
Ground water
Risk
Risk
Ground water
Ground water
Risk
Ground water
Risk
836
-5-
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•',-'.
Soil Contaminant
Fluorene
Methylphenol
Naphthalene
Phenathrene
Pyrene .
Toluene
Mercury
Total xylene
Antimony
Chromium
Copper
Magnesium
Zinc
Cleanup Level (mg/kg)
1,200
4
8
3.3
910
9
45
96
5
0.01
13
15,000
1.5
ARAR or Other Basis
Risk
Ground water
Ground water
Ground water
Risk
Ground water
Ground water
Ground water
Ground water
CRDL
CRDL
Ground water
Ground water
"CRDL is the Contract Required Detection Limits. The risk-based remedial action
levels are less than conventional analytical detection limits and therefore the detection
limits are proposed as remedial action levels.
""'Ground water" refers to the maximum concentration in soil that is protective of
ground water. This estimation procedure was obtained from Determining Soil
Response Action Levels Based on Potential Contaminant Migration to Ground Water:
A Compendium of Examples (USEPA, Oct. 1989).
'"Risk" refers to human health risk assessment calculations. For carcinogens, an
excess upper bound individual lifetime cancer risk between 10"4 to 10* was acceptable.
For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
Sediments

Contaminant
Cleanup Level (mg/kg)
AFLAR or Other Basis
Carcinogens
Arsenic
Cadmium
Beryllium
8.4
6
0.9
ffiPA"
ffiPA
ffiPA
Noncarcinogens
Aluminum
Antimony
15,000
,12
ffiPA
ffiPA
••''•-'• '/ • -6- : .':' "'". :' ;: " . • £
837
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Contaminant
Manganese
Selenium
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Nickel
Potassium
Sodium
Vanadium
Zinc
Cleanup Level (mg/kg)
930
1.3
170
. 52,000
24
14
45
33,000
.70
21,000
.25
970
1,000
36
170
ARAR or Other Basis
ffiPA
ffiPA
ffiPA
ffiPA
ffiPA
ffiPA
ffiPA
ffiPA
BEPA
ffiPA
ffiPA
IEPA
ffiPA
ffiPA
ffiPA
'Proposed sediment cleanup levels were calculated by the Illinois Environmental
Protection Agency (IEPA) to account for different soil types' capacities to absorb
contaminants.
13. Was the innovative technology eliminated because of the cleanup, goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None .

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

The selected remedy included a study of the potential impacts on wetlands and a program to
mitigate, replace, and/or restore wetlands that are affected by the remedy.
838
-7-
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75. What measures/criteria were used to compare alternatives? \
'r ' ' \
• • - \
The following measures were used to compare the alternatives: _|
' • .. • •-(•-.
Cost-effectiveness ,
Percentage risk reduction I
. . ... . , • ' , 'I; • " "

16. How are measures compared? j ;

The remedial actions for soil and sediment were chosen because they adequately reduce risk
and are cost-effective. The primary concern at the site was the contamination of ground water
through leachate generation and ground water contact with the waste mass. Because the waste
mass is so large, it could not be excavated and treated. Thus containment was the only option.
Though the multilayer cap would provide a more effective barrier to precipitation, its increased
effectiveness due to reduced infiltration, would not be significant because the waste mass
would be in contact with the ground water. Also, the multilayer cap costs twice as much as
the selected alternative; Of the two proposed sediment remediation alternatives, the chosen
alternative also was cost-effective since it provides equal risk reduction! for less cost.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were primary in the selection of a remedy. Because of the site's
large size, containment was the only feasible alternative which did not iequire the excavation
. of soil and waste materials. ' .
889
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Twin Cities Air Force Reserve Base
(Sma!1 Arms Range Landfill)

Minneapolis, Minnesota
Region 5
GENERAL SITE INFORMATION
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Antimony 26
Arsenic 13
2-Butanone 25
Magnesium 10,800
Nickel 191
Selenium 161

Site History
,
NPL Proposed: N/A
NPL Final: 1987
FS: 6/91
ROD: 3/92

Background

Federal Facility
PRPs: UiS. Air Force
FS prepared by: Engineering-Science,
Inc.

2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 17,000 cubic yards of waste in landfill

3. What type of site is this?

Industrial Landfill. An inactive industrial landfill bordered by an airport and a firing.range.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Fencing, deed restrictions
Capping (single layer, multilayer)
Access restriction:
Containment:
Chemical treatment: Fixation/stabilization
Thermal treatment: Incineration
Disposal:
Excavation, disposal (on-site, off-site)
890
-1-
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Was-an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: , ,
•i •/''''
Biological treatment: In situ biodegradation, composting/windrowingl land farming, soil
slurry, liquid-soil contact digestion
Phys/chem treatment: Solvent flushing, in situ air stripping, soil washing, oxidation
Thermal treatment: In situ vitrification, in situ steam stripping
What was the cost estimate for the innovative technology? ;
• . 'i
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs are then recalculated during an evaluation based on nine criteria established by
the NCP. No innovative technologies were incorporated into remedial alternatives, s
How did the cost(s) compare to standard technologies? |

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1 •
RAA-2
RAA-3
RAA-4
RAA-5A
RAA-5B
RAA-6A
RAA-6B
RAA-7A '
RAA-7B
Standard Technology
No action
Natural attenuation/maintenance/ground
water monitoring
Natural attenuation/maintenance/site
access restrictions
Natural attenuation/maintenance/site
access restrictions/ground water
monitoring
Multilayer cap
Asphalt cap
Multilayer cap/ground water monitoring
Asphalt cap/ground water monitoring
In situ stabilization
In situ stabilization/ground water
monitoring
Estimated Costs
3 Criteria
$6
$704,000
$291,000
$737,000
$1,331,000
$442,000
$1,7615,000
$878,000
$1,958,000
$2,394,000
9 Criteria
* $0 .
$704,000
eliminated
$737,000
eliminated
eliminated
$1,766,000
.$878,000
eliminated
$2,394,000
-2-
831
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Alternative
RAA-8
. Standard Technology
Excavation/off-site disposal
Estimated Costs
3 Criteria
$10,500,000
9 Criteria
$10,492,000
8. If a standard technology was chosen, why?

The selected remedy, RAA-4, consists of natural attenuation of ground water contamination,
access restrictions, site maintenance, and monitoring. Access restrictions and site maintenance
achieve the objective of protecting public health and the environment from contact with
landfill contaminants by inhibiting the completion of exposure pathways. The baseline risk ,
assessment indicated that air, soil, ground water, and surface pathways are currently not
complete because of the lack of VOCs release, lack of surficial soil contamination, the location
of the site within a semi-restricted area, limited access to the storm water pond, no significant
surface water contamination, and no current users of ground water at the site or down gradient
of the site. The selected remedy also provides protection against future, exposure through
access and deed restrictions. Access restrictions include a physical barriers constructed around
the site perimeter to restrict public access to the landfill surface. Deed restrictions limit future
development of the site, even if the property is relinquished by the US AF. It is probably the
most effective option in the short-term because it can meet the responsiveness objectives in 1
year through natural attenuation and minimal adverse impacts resulting from implementation.
It will not require excavation or capping and therefore poses no short-term risk to site workers
due to the release of VOCs. It is the easiest alternative to implement since it requires little
site work. Site maintenance will be conducted to ensure the integrity of the existing soil
cover, the fence, and the monitoring system. It is expected to meet ARARs and is cost
effective. \
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

• Solvent flushing was eliminated because the landfill debris might retard the flow of
solvent resulting in incomplete solvent removal. Significant risks would exist from the
loss of solvents to the environment.
» In situ air stripping was eliminated because site characterization data do not indicate a
significant source of volatile organics in the landfill.
822
-3-
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• Soil washing was eliminated because the process requires excayation of all landfill
debris, much of the debris might not be amenable to treatment, and contaminated
materials might make up only a small percentage of the volume to be treated.
• Oxidation was eliminated because site characterization data indicate that organics were
detected at relatively low concentrations which posed no threatj at Ihe site and might
therefore not require treatment. Furthermore, landfill debris might inhibit the
introduction of oxidant to the subsurface, resulting in incomplete treatment.
• In situ steam stripping was eliminated because site characterization data do not
indicate a significant source of volatile organics in the landfill. '
• In situ biodegradation was eliminated because the landfill debris might impede the
flow of water and nutrient mix and prohibit complete remediation.
• Composting/windrowing was eliminated because flooding at the site precludes its use
since soils undergoing treatment could be flooded. Additionally, contaminated landfill
materials generally would not be soil only and would not be amenable to this
approach. The land ban issue might also make this applicable itp only portions of the
waste. I
• Landfarming was eliminated because flooding at the site precludes its use since soils
undergoing treatment could be flooded. Additionally, contaminated materials in a
landfill generally would not be soil only and would not be amenable to this approach.
The land ban issue might also make this applicable to only portions of the waste.
• Soil slurry was eliminated because it would require excavation] most of the debris
would hot be amenable to treatment, and contaminated materials might make up only a
.small percentage of the total volume that would be treated. The land ban issue also
might make this applicable to only a portion of the waste.
• Liquid-solid contact digestion was eliminated because the process requires make-up
water through out the process and offgases must be treated by carbon adsorption.
Additionally, contaminated landfill materials generally would not be soils only and
would not be amenable to this approach. The land ban issue may also make this
applicable to only portions of the waste.
• In situ vitrification was eliminated because landfill debris might impede penetration by
electrodes and deflect energy transfer resulting in incomplete treatment. Much of the
landfill debris might not be amenable to treatment and contaminated material and soil
might make up only a small percentage of the total volume thai would be treated.
Costs would be excessive compared to other options. ' ,

, Innovative technologies eliminated during the screening of the three criteria include the
following:

• ; None ' " - • ' . !. • • • . •

Innovative technologies eliminated during the detailed analysis include the following:

• . None !
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative v/ere protection of
human health and the environment, short-term effectiveness, and cost. jThe selected remedy
-4-
893
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was preferred because it adequately addresses the protection of human health and the
envkonment in a cost-effective manner. Furthermore, it does not pose short-term risk to site ^^ )|
workers because it does not require treatment. --*

12. What cleanup goals were selected? If the cleanup goal wds based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels were not established.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. . . ^UP |

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Cost/unit risk
Time to design/construct/operate

16. How are measures compared?

The selected alternative was preferred because it will remediate the site in the same time, or
possibly less, than other alternatives. The selected alternative also will reduce site risk in the
long-term as well as other alternatives without posing any short-term risks. .Other treatment
alternatives were not preferred because they might pose short-term risk during treatment, they
would cost more, and they would not provide any greater reduction in risk.
' .
17. Wliat technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

894
-5- . . '.
, i
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Verona Well Field
OU-2

Battle Creek, Michigan
Region 5
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

1,2-Dichloroethane 2.4
1,2-Dichloroethene (cis) 0.69
1,2-Dichlproethene (trans) 0.69
Ethylbenzene 0.75
Methylene Chloride ' 1.4 '
Tetrachloroethene 2,100
i Toluene 0.43
1,1,1-Trichloroethane 0.62
Trichloroethene 1,100
Xylenes 2.4
Site History
•i
NPL Proposed: 'j N/A
NPL Final: 7/82
FS: ' > 2/91
ROD: ] 6/91
I' '
Background

EPA Fund-lead !
PRPs: Thomas Solvent Company, Grand
Trunk Western Railroad
FS prepared by: CH^M Hill*
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• Approximately 62,000 pounds of contaminated soil
3. What type of site is this? . "

Chemicals and Allied Products. The site contains the Verona well field[ the Grand Trunk
Western Railroad (GTWRR) Marshalling Yard, the GTWRR paint shop! the Thomas Solvent
Raymond Road facility, and the Thomas Solvent Annex (the Annex) facility. The Battle
Creek River flows through the site in a southwesterly direction. The GTWIiR paint shop and
the Annex are the focus of this FS. The site is located in the northeast corner of the city of
Battle Creek and is surrounded by undeveloped land.
-1-
835
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Deed restrictions, fencing
Capping (native soil, clay, synthetic membranes, sprayed asphalt,
asphaltic concrete, concrete, multilayered, chemical sealants/
stabilizers), surface controls (surface seals, grading, soil stabilization,
revegetation, diversion/collection system), vapor suppression (foam
caps, portable dome)
Neutralization, precipitation
Excavation
Incineration .
RCRA landfill, replacement
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Slurry bioreactors, land treatment, in situ bioreclamation
Chemical treatment: Soil flushing, oxidation/reduction
Physical treatment: Permeable treatment beds
Thermal treatment: Vapor extraction, vitrification, wet air oxidation, pyrolysis
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) .
Alternative
RAA-4
RAA-6
Innovative Technology
.Soil vapor extraction/modified blocking
well system/air and soil monitoring
Soil vapor extraction/ground water
treatment/air, soil, surface water, and
ground water monitoring
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$9,300,000
$15,300,000
896
-2-
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Alternative
RAA-8
Innovative Technology
Soil vapor extraction/ground water
treatment/in situ biological treatment/
air, soil, surface water, and ground
water monitoring
Estimated Costs
3 Criteria
' N/A
I
' i
9 Criteria
$15,800,000
7. How did the cost(s) compare to standard technologies?
1 Cost Estimates for RAAs That Include Standard Technclogfes
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-5
RAA-7
Standard Technology
No action/continued operation of
existing blocking wells and air stripper
Modified blocking wells
Ground water collection and treatment
Soil excavation arid incineration/
modified blocking well system/air and
soil monitoring
Soil excavation and incineration/ground
water treatment/air, soil, surface water,
and ground water monitoring
Estimated Costs
3 Criteria
N/A ;
N/A
N/A
• N/A
N/A :-
9 Criteria
$2,500,000
$6,600,000
$11,700,000
$26,000,000
$31,100,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?
i ,
RAA-6 was chosen because it is the least costly alternative that will provide protection from
all identified current and future pathways of exposure to contaminated [soils at the site. The
proposed source treatment, soil vapor extraction (SVE), will reduce site soil contaminants.
Source treatment in conjunction with ground water treatment will permanently reduce site risks
to below 10"6. SVE was preferred because it would eliminate a greater volume of contaminants
than other alternatives; therefore, it was considered very effective in the long term. This
alternative also was preferred because it minimizes the time to reach soil and ground water
remediation levels and it minimizes short-term risk. SVE will be easily Implemented and
equipment is readily available. SVE is a proven technology and has been successfully
implemented at the Raymond Road source area, a part of the Verona \Vell Field site.
-3-
897
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10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Slurry bioreactors were eliminated because the technique would not be applicable to
sandy and VOC-contaminated soil.
• Land treatment was eliminated because it would not be applicable for VOC-
contaminated soil (anaerobic treatment is needed for tetrachloroethene).
" Permeable treatment beds were eliminated because the technique would not be
applicable to site contaminants.
• Vitrification was eliminated because the technique would not be suited for site
contaminants and conditions. .
• Wet air oxidation was eliminated because it would not be suited for site conditions.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Soil flushing was eliminated because its effectiveness in meeting the soil remediation
action objectives has not been demonstrated. Soil flushing is an emerging technology
and there are few full-scale examples where it has achieved the low-level residual
concentrations of organic contaminants reached by other process options. The cost and
technical difficulty of soil flushing were also a concern.
" Pyrolysis was not included in any RAAs but was mentioned as a process that might be
reconsidered in the design phase.
• Oxidation/reduction: was eliminated because toxic degradation products would be
formed and it would be relatively expensive. Furthermore, its effectiveness is '
uncertain because chlorinated compounds have a low oxidation reactivity and might • '
require a catalyst that would necessitate in situ soil mixing, which is not commonly '
employed. _

Innovative technologies eliminated during the detailed analysis include the following:

» Bioreclamation was eliminated because its effectiveness in treating chlorinated VOCs
has not been demonstrated on a full-scale basis. Technical problems could cause
delays or result in additional problems. Furthermore, a limited number of contractors
are available to do the work. Permission would be needed from the State of Michigan '
to inject nutrients and substrates into the aquifer. ' ,

77. Wh^h of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so, '
which criterion? Which of the criteria supported the use of a standard technology? ' !

The criteria weighted most heavily in selecting the technology were protection of human health (fife ),
and the environment, ability to meet ARARs, short-term effectiveness, implementability, and ™^

898 1
. • -4- . • • • • !'
-------
cost. RAA-4 (the preferred alternative) is protective of public health and the environment in
both the long- and short-term, meets ARARs, is easily implemented, aiid is the least expensive
of the treatment alternatives. RAA-2 uses the same soil remediation technology as RAA-4
(vapor extraction), but does not directly address ground water contamiriaticin and thus will not
meet ground water ARARs, RAA-6, which employs bioremediation, vras eliminated because
of the technical difficulty in implementing the solution and because it lias not been
demonstrated on a full-scale basis. RAA-3 is costly, does not meet ground water ARARs, and
poses potential short-term health risks due to possible fugitive VOC eniissions during soil
excavation. RAA-5 is also costly and poses potentially serious short-tejrm health risks.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? \
Contaminant
Cleanup Level (ng/kg)
ARAR or Other Basis
Carcinogens
Benzene
Carbon Tetrachloride
1,1-Dichloroethane
1 , 1 -Dichloroethene
1 ,2-Dichloroethane
Methylene Chloride
Tetrachloroethene
Trichloroethene
20
- 10
20
10
10
100
10
60
Michigan Act 307"
Federal TCLF*
Michigan Act 307
Federal TCLP
FederalTCLP
Michigan Act 307
FederalTCLP
Michigan Act 307
. Michigan Act 307
Michigan Act 307
Michigan Act 307
Noncarcinogens
1 ,2-Dichloroethene
(cis)
1 ,2-Dichloroethene
(trans)
Ethylbenzene
Toluene
1,U-
Trichloroethane
Xylenes
20
2,000
1,400
16,000
4,000
6,000
Federal TCLP
Michigan Act 307
Fedeiral TCLP
Michigan Act 307
Michigan Act 307
Michigan Act 307
Federal TCLP
Michigan Act 307
Michigan Act 307
"Concentrations in soil that
concentrations greater than
would be expected to leach into ground water at
Michigan Act 307 ground water cleanup limits.
-5-
899
-------
""Concentrations in soil that would be expected to leach into ground water at
concentrations greater than the ground water goals based on U.S EPA TCLP
procedures (40 CFR 261).
• • ' -
Cleanup levels for carcinogens would result in an excess upper bound individual lifetime
cancer risk of no more than W6. For noncarcinogens, cleanup levels would result in. a Hazard
Index less than or equal to 1.0.
/ , . '
-

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

H None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Vapor extraction has been successfully implemented at the Raymond Road facility., a part of
the Verona Well Field site addressed in a previous FS. A pilot study will be conducted prior
to design of the vapor extraction system for the GTWRR Paint Shop and Annex locations

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

• Cost-effectiveness
• Proven reliability
• Impact on nearby populations
• Time to design/construct/operate
- , ., •

16. How are measures compared?
' ' • •
RAA-6 was preferred for several reasons. First, it would minimize short-term risk. Other
alternatives, RAA-5 and RAA-7, would have had greater potential for community exposure to
VOCs because they require excavation. Second, RAA-6 would more rapidly meet ground
water cleanup levels (20-30 years) because ground water is remediated at the source. Other
alternatives, RAA-4 and RAA-5, would take more than 50 years to meet ground water cleanup
levels because the ground water would be treated downstream^ Third, SVE was preferred over
incineration because it would be more easily implemented. Incineration was expected to have
significant technical and administrative requirements for setup;! Incineration also would be very
costly. SVE was preferred over bioremediation because it is a proven technology.
Bioremediation was eliminated because it has not been shown to be effective in remediating
many of the site contaminants, it would require extensive testing prior to startup, and there

soo
-6-
-------

17.
would be numerous administrative requirements associated with injection of nutrient into the
aquifer. In addition/only a limited number of experts are available to implement
bioremediation.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
-• \. •

While none of the developed alternatives were eliminated solely for technical or site-specific
reasons, these factors did play a minor role in evaluating some of the alternatives. Site
conditions were favorable for the use of vapor extraction (RAA-4). Vapor extraction works
best in sandy soils and for treating contaminants with Henry's constants greater than 10"4
atmosphere per mole per cubic meter. Both of these conditions are met "at: the Verona site.
-7-
901
-------
Zanesville Well Field

Zanesville, Ohio
Region 5
GENERAL SITE INFORMATION
/. What were the principal contaminants,
contaminant levels, and m>
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Lead
Trichloroethylene
1,2-Dichloroethylene (total)
Barium
Copper
Cadmium
Manganese
Zinc
Mercury
minants,
addressed in

rincipal

5,660
170
16
604
384
11
1,730
4,310

NPL
NPL
FS:
ROD

Proposed
Final:

Site History
: N/A
9/8/83
7/12/91
9/30/91
Background

PRP-lead ,
PRPs

: United
Inc.
Technologies Automotive,

FS prepared by: Geraghty and

Miller,

Inc.

4,130
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 37,800 cubic yards of soil
3. What type of site is this?

Industrial Landfill. The site includes the Zanesville well field and a manufacturing facility ,
owned by United Technologies Automotive, Inc. (UTA). A former bulk solvent storage tank
and two large storm sewer basins are located on the site. >
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction: Deed restrictions, security fencing, warning signs
902
-i-
-------
Containment:

Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
,1
Capping (soil, multimedia, and asphalt), synthejtic liner, slurry walls,
grouting, sheet piling, bottom sealing .. • \
Solidification (
Mechanical aeration, soil washing (aqueous) i . • >
On-site incineration, off-site incineration '
On-site RCRA landfill, off-site RCRA Subtitle D or C landfill
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological-treatment: Anaerobic bioreclamation, treatment beds !
Chemical treatment: Soil flushing (chemical), chemical oxidation, hydrolysis, solvent
extraction !
Thermal treatment: In situ vitrification, in situ vapor extraction !
6.
What was the cost estimate for the innovative technology? \

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Afller the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness
implementability, and cost) to identify alternatives that merit a more detailed evaluation 'The
estimated costs then are recalculated during an evaluation.based on the kne criteria established
by the NCP. ^ !
, . . " i -

Cost Estimates for RAAs That Include Innovative Technologic
(selected remedial alternative is in bold)
Alternative
RAA-4
RAA-6
RAA-7
,'
Innovative Technology
In situ vapor extraction
Soil washing (aqueous)/sludge
disposal '
In situ vitrification
Es
3 Crit<
timated Costs
:ria
$896,SOO
$667,4
$29,286
00
,200
9 Criteria
$896,500
$667,400
$29,286,200
-2-
903
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2 .
RAA-3
RAA-5
Standard Technology
No action
Multimedia cap/excavation/disposal
Excavation/off-site landfill disposal
Excavation/off-site incineration
Estimated Costs
3 Criteria
$0
$210,200
$8,325,000
$10,575,000
9 Criteria
$0
$210,200
$8,325,000 '
$10,575,000
:3
8. If a standard technology was chosen, why?

A standard technology was not selected.

9. If an innovative technology was chosen, why?

The selected remedy included treatment of soil and source areas contaminated with VOCs by .
in situ vapor extraction, and; soil washing of soil contaminated with inorganic compounds.
Soil vapor extraction was selected because: 1) chemical characteristics of TCE favors use of
soil vapor extraction, 2) sand-silt soils are permeable enough for air flow for applied vacuum
conditions, 3) soil vapor extraction influences a broad area, and its effectiveness is not effected
by local concentration variations within the area, 4) although a pilot soil vapor extraction
system was unsuccessful, modifications would increase extraction rates, 5) soil vapor
extraction will reduce potential for exposure to volatile organic chemicals during excavation of
inorganics, 6) will reduce contaminants leaching into ground water, &) equipment and services
are readily available, 8) cost. .
i
Soil washing was selected because: 1) it reduces exposure by reducing waste volume and
removing the source, and 2) cost.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

" Anaerobic bioreclamation was eliminated because its effectiveness would be limited
due to the presence of chlorinated organics and inorganics, which biodegrade slowly.
Also, there has been no effective full-scale application of anaerobic bioreclamation.
904
-3-
-------
11.
» Treatment beds (walls) were eliminated because it is only suitable for shallow ground
water tables, because a trench must be excavated to the bottom of the contaminated
aquifer and ground water at this site is too deep. |
" Chemical oxidation (in situ) was eliminated because little infontnation is available
regarding the application of chemical oxidation for in situ stabilization of organic
wastes. Other treatment technologies are better suited for the cheirucals of concern at
the site.
• Hydrolysis (in situ) was eliminated because the technology is still in the developmental
stages for use at uncontrolled hazardous waste sites. .In addition, the injection of
chemicals into the potable aquifer was not recommended.
• Solvent extraction was eliminated because it would be difficult to implement and
costly to operate.
[
• ' ' I- ( ,
Innovative technologies eliminated during the screening of the three criteria include the
following: . , ,
-•.-!-
• Soil flushing was eliminated because the process could redistribute existing constituents
in soil such that a larger soil mass requires subsequent remediation. Verification of
the effectiveness of this process would require the collection of a large number of soil
samples. Flushing could cause further contamination of the ground water.

Innovative technologies eliminated during the detailed analysis include the following:

• In situ vitrification was eliminated because of the high cost to implement the
technology. Also, if the remedy fails (e.g., constituents are found which leach out of
the vitrified material), corrective measures would be extremely expensive.
[
- - ' ' • - ' i "' '
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard] technology?

The criteria weighted most heavily in selecting innovative and standard technologies included
cost, long-term effectiveness and permanence, and reduction in toxicity, mobility, and volume
of contaminated materials. In situ vapor extraction and soil washing together will reduce the
toxicity of contaminated soils at a cost far below that of the other treatment: options, off-site
incineration and vitrification.
72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens ,
Trichloroethylene
cis-1,2-
Dichloroethylene
0.0063
0.034

Leachability" Model
Leacha
bility Model
-4-
905
-------
Contaminant
trans-1,2-
Dichloroethylene
Cleanup Level (mg/kg)
0.059
ARAR or. Other Basis
Leachability Model
Noncarcinogens
Lead
Cadmium
Barium
Copper
Manganese
Zinc
12
4
77
315
771
1,410
Risk
Risk
Risk
Risk
Risk
Risk
The Summers model was used to calculate soil cleanup levels based on meeting
established MCLs.

For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
*
Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None . • . ,

14. Were treatability studies conducted on the innovative technology or standard technology?
1. . , i
A pilot vapor extraction system was previously installed by UTA near a drum storage area.
Due to the low levels of VOCs removed by this system, it was eventually shut down. Vapor
extraction is still considered a viable technology for this site because it may be possible to
increase extraction rates by installing a modified system such as one utilizing horizontal slotted
pipe, rather than well screens. Such a system could collect VOCs from a larger area than with
wells. - ,
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
\
• Cost-effectiveness

906
-------
Impact on workers and nearby populations
Preference for treatment (vs. containment)
16. How are measures compared?

Cost-effectiveness and preference for treatment over containment or disposal were the most
important measures used to select the preferred remedial alternatives. Vapor extraction (RAA-
4) in conjunction with soil washing (RAA-6) were considered the mosjt cost-effective
alternatives as a result of their ability to treat most of the organic contaminants and remove
inorganic contaminants from soils at a relatively low cost. The other :five alternatives either
did not treat contaminated soils or were not as cost-effective. RAA-4 and RAA-6 also were
selected because they would create no additional short-term risks for \yprkers and nearby
residents during implementation. j

i • •'.'•'.
17. What technical considerations were factors in selecting a remedy? W&re technical
considerations primary in the selection of the remedy? -
i •
i
Technical considerations were not primary in selecting a remedy. Some technical
considerations and site specific conditions were a factor, however, in eliminating some
innovative technologies during the initial screening of alternatives. Fcjr example, the
considerable depth of ground water at the site made the use of treatment beds infeasible, since
a trench must be excavated to the bottom of the contaminated aquifer.
-6-
907 - -
-------
Cimarron Mining Corporation
OU-2

Carrizozo, New Mexico
Region 6
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediment (mg/kg)

Lead (tank sediment) 46,400
Lead (waste piles) 18,900
Lead (surface soil) 10,409
2. What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/24/88
10/4/89
N/A
9/91
Background

EPA Fund-lead
PRPs: N/A
FS prepared by: CDM Federal
Programs Corp.
The volume of material to be remediated included:

• 43 cubic yards of tank sediment
• 182 cubic yards of material soil and rock
« 345 cubic yards of discharge pit sediment arid site soil
3. What type of site is this?

Mining. An inactive milling facility in a rural area.
TECHNOLOGY SELECTION

4. Wliat standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: «»««c

Access restriction: Fencing, deed notices, zoning ordinances, temporary resident relocation
Containment: Capping, dust control
Chemical treatment: Neutralization, solidification
Thermal treatment: Smelting
Disposal: Excavation, disposal (on-site, off-site) r

90S
-i-
-------
5.
Was an innovative technology considered in the FS? If so, which technology?
Innovative technologies considered during the identification and screening of technically
feasible technologies were: , i

Biological treatment: Biodegradation |
Chemical treatment: Soil washing, soil flushing, hydrometallurgical reprocessing
Thermal treatment: In situ vitrification, pyrolysis
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action
Institutional controls
Cement solidification/stabilization/
on-site disposal '
Cement solidification/stabilization/off-
site disposal
Off-site municipal and hazardous waste
landfill disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
9 Criteria
< $48,000 ,
$119,000
$79,000
$235,000
$344,000

If a standard technology was chosen, why?
' '' •' ' L . " , •''.''
RAA-3 was chosen because it is highly protective of human health and the environment, since
wastes will be treated to the extent practical. Stabilization of soil and waste pile material with
lead concentrations exceeding 500 ppm provides protection to human health and the
environment by reducing the mobility of lead in the soil and its potential for contaminating
ground water. Treatment also ensures that the waste will not be a "significant" ingestiori or
inhalation risk. Hazard Indices for noncarcinogens will be less than 1 upon completion of this
remedial action. Implementation of this alternative does not pose any short-term risk or cross-
media impacts. This alternative achieves compliance with all ARARsl A high degree of long-
-2-
909
-------
term effectiveness and permanence will be achieved. Stabilization is the "state-of-the-art
technology" for immobilizing metals and has been utilized effectively for many years. This
alternative reduces the toxicity and mobility of the waste through treatment. Durability test are
being conducted on the solidified material as part of the bench-scale treatability tests. This
information will be utilized to determine the necessary optimum mixture ratios to ensure the
long-term effectiveness of this option. Implementation of this alternative should provide a
reasonable degree of short-term effectiveness, provided appropriate precautions and dust
control measures are instituted during the remedial phase. Implementation of this alternative is
possible without undue technical or administrative difficulty. The selected alternative will be
readily implemented since no special technologies are required and the remedy utilizes typical
construction techniques. This alternative is cost effective.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Soil washing was eliminated because the equipment requirements to implement this
technology are substantial — greater than for other feasible soil treatments (e.g.,
fixation); a separate liquid waste stream would be created; and its effectiveness can not
be properly evaluated without bench- and pilot-scale tests. Given the relatively small
volume of material present at the site and the process's complexity and high costs, this
alternative would not be cost-effective.
• Soil flushing was eliminated because this process would not be feasible for some of the
site's waste located aboveground. Further, the remaining waste material is
characterized by relatively thin layers of surficial soil and this material is not
contiguous; thus, installation and operation of injection and extraction wells would not
be practical.
» Hydrometallurgical reprocessing was eliminated because there is an insufficient
volume of waste material to consider implementation of an on-site reprocessing option
and therefore an off-site reprocessing would be necessary.
• Biodegradation was eliminated because treatment of metal-contaminated tailing and
soils has not been proved in full-scale applications and, therefore, the long-term
effectiveness of this technology is unknown; there are currently many uncertainties
associated with this technology; and the volume of waste is small.
• In situ vitrification was eliminated because it would be difficult to, implement, would
be complex to construct and operate, has extensive equipment requirements, and would
produce gas side streams which would require further treatment. Additionally, the
availability of services, equipment, and skilled workers for this group is limited. Cost
to implement this option would be very high compared to other feasible treatment
technologies.

910
-3-
-------
I
• Pyrolysis was eliminated because it would be difficult to implement, would be
complex to construct and operate, has extensive equipment requirements, and would
produce gas side streams which would require further treatment. Additionally, the
availability of services, equipment, and skilled workers for this group is limited. Cost
to implement this option would be very high compared to other feasible treatment
technologies. '

A three-criteria evaluation was not conducted. |

Innovative technologies eliminatedr during the detailed analysis include the following:

• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

. Protection of human health and the environment, long-term effectiveness, and cost were the
criteria that were weighted most heavily in selecting a remedial alternative. L RAA-3, at the
lowest cost, provides the greatest protection and is effective in the long term.

In situ vitrification and pyrolysis were eliminated because they would be difficult to implement
and costly. !
12. What cleanup goals were selected? If the cleanup goal was based on\an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup, Level (rag/kg)
ARAR
Carcinogens <
Lead
500
1
or Other Basis

DS\yERa
"OSWER Directive 9355.4-02, EPA 1989.
13.
Was the innovative technology eliminated because of the cleanup goats? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:
1 - • .•. - - •' . i" • • • - .
• None i
•I1 - ,•'••.

Standard technologies eliminated because of cleanup goals include: !

• None
-4-
911
-------
14. Were treatability studies conducted on the innovative technology or standard technology?
• ,
Bench-scale tests for solidification were preformed on representative samples of site waste.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: .

Protection achieved
Total cost
Proven reliability
Waste left in place/institutional control

16. How are measures compared?

The chosen alternative was preferred because it provides the greatest amount of protection and
it will be effective in the long term. Institutional controls were not chosen because they would
provide less protection to human health and no protection to the environment. Off-site
disposal was eliminated because it would provide only a moderate degree of protection since
contaminated soil would not be treated. Of the most protective alternatives, the chosen
alternative is the least expensive. While solidification is a well-proven technology, soil
washing and biodegradation were eliminated, in part because their effectiveness is unknown.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial technology. The dispersed
waste (e.g., aboveground, below ground) made it impractical to implement some technologies
including soil washing and soil flushing.
912
'-5-
-------
Double Eagle Refinery Co.
OU-1 (Source Control Operable Unit)

Oklahoma City, Oklahoma
Region 6
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed In
this feasibility study?

Maximum concentrations of principal
contaminants were:

SludgeVSoil/Sediment (rag/kg)

Lead 20,000
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
87-88
3/89
6/92
9/28/92
Background

EPA Fund-lead !
PRPs: EPA has identified 17 PRPs and
is continuing the search for other
unidentified PRPs
FS prepared by: Fhior Daniel, Inc.
42,000 cubic yards of contaminated sludge, soil, and. sediment
3. What type of site is this?

Waste Oil. The Double Eagle Refinery (DER) collected, stored, and re|-refined used oils, and
distributed the recycled product. DER was active as early as 1929, and accepted waste oil for
storage until 1980. This site is bordered by vacant lots zoned for industrial land use
-I . ' " , • • -
I
"I

TECHNOLOGY SELECTION ;

4. . What standard technologies were considered for selection in this FS? I

Standard technologies considered during the identification and screening of technically feasible
technologies were:
'Waste sludges at the Double Eagle site represent over 90 percent of the contaminated media to be
remediated. Soils and sediments, therefore, will be consolidated with the waste! sludges and
remediated using a single technology rather than separate technologies for each j medium. The remedial
alternatives generated in the ROD for the waste sludges,'soils, and sediments were based on the
technologies best suited for the remediation of the sludge material.
-1-
913
-------
Access restriction:
Containment:
Chemical treatment:

Thermal treatment:
Disposal:
Deed restrictions, fencing ,
Capping (clay, synthetic membrane, concrete, multimedia), vertical
barriers, horizontal barriers, sediment control, dust control,
consolidation -
Solidification/stabilization (sorption, pozzolanic agents, encapsulation),
neutralization
On-site incineration, off-site thermal destruction
Excavation, on-site landfilling, off-site landfilling
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Slurry phase treatment, solid phase treatment (biological degradation),
composting
Phys/Chem treatment: Soil washing, chemical extraction, reduction/oxidation, soil vapor
extraction
Thermal treatment: Low-temperature thermal stripping, vitrification .'

6. What was the cost estimate for the innovative technology? . . .

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-6
Innovative Technology
Excavation/on-site biological
treatment/capping of residuals
Estimated Costs
3 Criteria
N/A
9 Criteria
eliminated
7. How did the cost(s) compare to standard technologies? "

The designation of RAAs changed in the ROD and the new designations are presented
parenthetically below.-
914
-2-
-------
Cost Estimates for RAAs That Include Standard Technologies
, (selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
(RAA-3)
RAA-5A
(RAA-4)
RAA-5B
(RAA-5)
RAA-7A
(RAA-6)
RAA-7B
(RAA-7)
Standard Technology
No action
Limited action/minor construction
activities/consolidation of off-site
wastes/institutional controls
Containment (no treatment)
In situ stabilization/capping
Consolidation/neutralization/on-site
stabilization/disposal in on-site landfill
Consolidation/neutralization/on-site
stabilization/disposal in off-site
landfill
Excavation/dn-site incineration/on-site
capping of ash
Excavation/off-site incineration/off-site
disposal of ash
Estimated Costs
3 Criteria
N/A
N/A
i
1
N/A
N/A
i -
' N/A
i
N/A
i
N}A
'i. .
.N/A
9 Criteria
$0
$300,000
eliminated
$5,100,000
$7,300,000 ,
$6,400,000
$32,600,000
$23,900,000
8. If a standard technology was chosen, why? j ,

The selected alternative, RAA-5B (RAA-5), was chosen because it incorporates stabilization
technology as a treatment process for the waste material. The stabilization process places the
inorganic contaminants, like lead and other heavy metals, in a less soluble form and, therefore,
reduces the mobility of these contaminants. Contaminant migration will be restricted under
this alternative by decreasing the surface area exposed to leaching and/or by isolating the
wastes within an impervious capsule. The lead and organic contaminants on site will be
stabilized to the extent that the waste will not be considered RCRA hazardous waste under
TCLP testing. In addition, the selected alternative involves neutralizing the contaminated
material, which reduces the RCRA corrosivity characteristic. Consequently, following
treatment the waste will not be considered hazardous and may be disposed of in a RCRA
Subtitle D facility. Although the treatment of waste under RAA-5B does not eliminate the .
contaminants of concern, removal of the waste material from the site isi effective in eliminating
the human health and environmental exposure pathways for contaminants at this site.
Implementation of RAA-5B also will minimize or alleviate the need for long-term O&M,
monitoring, application of institutional controls, and 5-year reviews. The selected alternative is
considered technically and administratively implementable. Qualified contractors to perform -
this work are available regionally. In addition, transportation of the waste materials to a
permitted off-site facility will be in compliance with the U.S. Department of Transportation
(DOT) regulations. Finally, treatability studies conducted as part of the FS (see Question 14)
indicate that stabilization is an effective technology for the wastes at thie DER site.
-3-
915
-------
The Proposed Plan identified RAA-5A (RAA-4) as EPA's preferred alternative for soil, sludge,
and sediment contamination. At the same time, EPA requested the preference of the State of
Oklahoma regarding the Proposed Plan. The Oklahoma State Department of Health (OSDH)
indicated that they preferred RAA-5B (RAA-5). OSDH cited the lower cost of the remedy and
subsequent lower state match. As a result of state and general public comments, EPA selected
off-site landfill disposal rather than on-site landfill disposal.
9. If an innovative technology was chosen, why?
'
An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:
,
" Chemical extraction was eliminated because this technology is not proven for soil or
sludges.
• Low-temperature thermal stripping was eliminated because it would not be applicable
to this site since this technology only is effective for highly volatile organics.
" Reduction/oxidation was eliminated because it would not be applicable for
concentrated organic waste streams.
" Slurry phase treatment was eliminated because it would not be applicable due to the
metal content in soil and sludge.
• Soil vapor extraction was eliminated because it would not be applicable to heavier
weight petroleum compounds.

Innovative technologies eliminated during the screening of the three criteria include the
following: . ,

• Soil washing was eliminated because it would not be effective for combined organic
and metal wastes. In addition, high organic wastes would cause problems for soil
washing systems, which would affect implementability.
• Composting was eliminated, but no specific reason was given. Although it is
potentially effective, this technology is not commonly applied to soils with
hydrocarbons and process development might be required prior to implementation.
• Vitrification was eliminated but no specific reason was given. The FS states that the
technology is not proven on a full scale and it has high capital costs. The FS also
states, however, that this technology is very effective in the destruction of organics.
• Biological degradation was eliminated because this technology would not reduce or
eliminate the toxicity or mobility of inorganic contaminants, such as heavy metals. In
fact, the presence of high concentrations of heavy metals in a waste stream would
inhibit biological activity. Considering the contaminant of concern at this site is lead,
biological treatment would not be an effective remediation alternative. In addition, this
technology would not be implementable because of the constraints of available area, at

.
. '-4- '
-------
the site to construct and conduct a land farming operation. The FS states, however,
that for wastes associated with the oil refining industry, neutralization and biological
treatment have been shown to be effective, and the ability of thus alternative to reduce
organic waste toxicity, mobility and volume has been documented.

Innovative technologies eliminated during the detailed analysis include the following:
- -. • • ' • i • - '
• None , ••'••„..• !
11.
|. '
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard\ technology?

State and community acceptance, and cost were significant criteria in selecting a remedy in the
Proposed Plan. EPA had selected an alternative involving on-site landfill disposal; however,
as a result of state and general public comments, EPA finally selected instead a remedy
incorporating off-site landfill disposal. The state of Oklahoma prefers the off-site landfill
disposal alternative because it is less costly than EPA's proposed remedy. RAA-5B also has
the advantage of saving the state the cost of perpetual operation and mziintenance of the site.
In addition, of all the alternatives evaluated for the contaminated sludge-Is, soils, and sediments,
the selected alternative provides the best overall protection to human .health and the
environment with no unacceptable short-term risks.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
, ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
Lead
PAHs
PCBs
500
30
25
OSWER3
TSCA"
Risk based0
"OSWER guidance on industrial land use.
'Toxic Substances Control Act cleanup level for industrial land iise.
The cleanup level represents a 10'5 excess cancer risk and was selected based on
regional guidance for setting remedial goals for PAHs.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None . ' .
-5-
917
-------
Standard technologies eliminated because of cleanup goals include: _

>
• None -~"[
1 j
>

14. Were treatability studies conducted on the innovative technology or standard technology?
\
The ROD states that treatability studies were conducted as part of the FS to determine if, j .
stabilization/solidification is an effective technology for the wastes' at the DER site. The,
results of these studies indicate that this treatment is effective because following treatment, 1
none of the TCLP chemicals were detected above their respective TCLP regulatory levels (40
CFR Part 261.24).

The information above on treatability studies was obtained from the ROD. The FS did not
discuss these studies.

"
' '
15. What measures/criteria were used to compare alternatives? . '

The following measures were used to compare the alternatives:

Risk level achieved
Cost-effectiveness .
Proven reliability . •
Preference for treatment (vs. containment)
.
-
16. How are measures compared?

The chosen remedy involves the "ultimate" removal of the waste material from the site,
thereby eliminating the human health and environmental pathways of exposure to contaminants
at this site. The chosen alternative is cost-effective as it offers a degree of protection similar
to on-site landfilling and incineration but at a lower cost. EPA does not believe that the
incinerator alternatives offer additional protection in line with the additional cost. The chosen
alternative was selected because it was known to be technically and administratively
implementable. Qualified contractors who perform the work required under RAA-5B are
available regionally. The selected alternative also will satisfy the preferences for treatment as
a principal element of the remedy.

•
'
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting the chosen remedy. Biological
degradation was eliminated from consideration as a remedial action alternative due in part to
technical considerations. This technology would not be implementable at this site because of
the constraints of available area to construct and conduct a land farming operation. The on-
site stabilization/capping alternative presented technical issues due to the uncertainty of treating
contaminated material on site without excavating the material. , if Hfe \
-6-
-------
Fourth Street Abandoned Refinery
OU-1

Oklahoma City, Oklahoma
Region 6
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
3/89
6/92
9/28/92
GENERAL SITE INFORMATION
___^———————.^—^——^——^

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

SludgeVSoil/Sediment (rag/kg)

Lead 15,000
What volume of material is to be
remediated? > ' •

The volume of material to be remediated
included:
40,200 cubic yards of contaminated sludge, soil, and sediment
[The ROD states that 42;000 cubic yards of material will be stabilized under Section
X. the Selected Remedy. The FS, however, estimated 40,200| cubic yards and
calculated costs based on this figure (see Question 3)].
Background
i ' [ - -
EPA Fund-lead
PRPs: The PRP search investigation is
ongoing |
FS prepared by: FJuor Daniel, Inc.
3. What type of site is this? . , | ,

Waste Oil. The Fourth Street Abandoned Refinery (FSAR) collectedi stored, and re-refined
used oils and distributed the recycled product. The refinery was active in the early 1940's
through the early 1960's. While industrial areas surround the FSAR site, the land use within a
1-mile radius is mixed industrial and residential. The FSAR and Double Eagle Refinery
(DER) sites are essentially adjacent to each other, and contain very similar waste materials
since both sites recycled used oils. Since these sites are in such close proximity and migration
of contaminants in certain cases overlap, the ROD for the FSAR site makes reference to the
DER site as necessary. ,
'Waste sludges at the Fourth Street Abandoned Refinery site represent over 95 percent of the
contaminated media to be remediated. Soils and sediments, therefore, will be consolidated with the
waste sludges and remediated using a single-technology, in lieu of separate technologies for each
medium. The remedial alternatives generated in the ROD for the waste sludge, soil, and sediments
were based on the techniques best suited for the remediation of the sludge material.
-1-
919
-------
TECHNOLOGY SELECTION . « '

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

SJudge/Soil/Sediment
5.
920
Access restriction:
Containment:
Deed restrictions, fencing
Capping (clay, synthetic membrane, concrete, multimedia), vertical
barriers, horizontal barriers, sediment control, dust control,
consolidation
Chemical treatment: Solidification/stabilization (sorption, pozzolanic agents, encapsulation),
neutralization
On-site incineration, off-site thermal destruction
Thermal treatment:
Disposal:
Excavation, on-site landfilling, off-site landfilling
an
innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically -
feasible technologies were:

Sludge/Soil/Sediment

6. Wliat was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs.. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-6
Innovative Technology
Excavation/on-site biological
treatment/capping of residuals
Estimated Costs
3 Criteria
N/A
9 Criteria
eliminated
>
-2-
-------
7. How did the cost(s) compare to standard technologies? ' •'"{ •

RAA designation changed in the ROD and the new designation is presented parenthetically
below. ',!_'• .
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA^2
RAA-3
RAA-4
(RAA-3)
RAA-5A ,
(RAA-4)
RAA-5B
(RAA-5) .
-RAA-7A ,
(RAA-6)
RAA-7B
(RAA-7)
Standard Technology
No action
Limited action/minor construction
activities/consolidation of off-site
wastes/institutional controls
Containment (no treatment)
In situ stabilization/capping
Consolidation/neutralization/on-site
stabilization/disposal in on-site landfill
Consolidation/neutralization/on-site
stabilization/disposal in off-site
landfill
Excavation/on-site incineration/on-site
capping of ash
Excavation/off-site incineration/off-site
disposal of ash
Estiimated Costs
3 Criteria
N/A
;N/A '
N(A
N/A
"t
N;[A
N/A
N/A
WA
9 Criteria
$0
$300,000
eliminated
$5,100,000
$7,300,000
$6,400,000
$32,600,000
$23,900,000
8. If a standard technology was chosen, why?

The selected alternative, RAA-5B (RAA-5), was chosen because it incorporates a stabilization
technology as a treatment process for the waste material. The stabilization process will place
the inorganic contaminants, like lead and other heavy metals, in a less soluble form and
therefore, will reduce the mobility of these contaminants. Contaminant1 migration will be
restricted by decreasing the surface area exposed to leaching and/or by [isolating the wastes
within an impervious capsule. The lead and organic contaminants on site will be stabilized to
the extent that the waste will not be considered RCRA hazardous waste under TCLP testing.
In addition, the selected alternative involves neutralizing the contaminated material, which will
reduce the RCRA corrosivity characteristic. Consequently, following treatment the waste will
not be considered hazardous and may be disposed of in a RCRA Subtitle E> facility. Although
the treatment of waste under RAA-5B does not eliminate the contaminjints of concern, removal
of the waste ,material from the site is effective in eliminating the human health and
environmental exposure pathways of contaminants at this site. Implementation of RAA-5B
also will minimize or alleviate the need for long-term O&M, monitoring, application of
921
-------
institutional controls, and 5-year reviews. The selected alternative is considered to be
technically and administratively implementable. Qualified contractors to perform this work are
available regionally. In addition, transportation of the waste materials to a permitted off-site
facility will be in compliance with the U.S. Department of Transportation (DOT) regulations.
Finally, treatability studies conducted as part of the FS indicate mat stabilization is an effective
technology for the wastes at the FSAR site.
" *
The Proposed Plan identified RAA-5A (RAA-4) as EPA's preferred alternative for soil, sludge,
and sediment contamination. At the same time, EPA requested the preference of the State of
Oklahoma regarding the Proposed Plan. The Oklahoma State Department of Health (OSDH)
indicated that they preferred RAA-5B (RAA-5). OSDH cited the lower cost of the remedy and
subsequent lower State matching cost. As a result of -state and general public comments, EPA
decided to select off-site landfill disposal rather than on-site landfill disposal for this site.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? • ,
' ' -
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. ,
•
Innovative technologies eliminated during the initial screening include the following:

• Chemical extraction was eliminated because this technology has not been proven for
soil or sludges. ,
• Low-temperature thermal stripping was eliminated because it would not be applicable
to this site as this technology is only effective to highly volatile organics.
" Reduction/oxidation was eliminated because it would not be applicable for
concentrated organic waste streams.
• Slurry phase treatment was eliminated because it would not be applicable due to the
metal content in soil and sludge. ,
• Soil vapor extraction was eliminated because it would not 'be applicable to heavier
weight petroleum compounds.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Soil washing was eliminated because it would not be effective for combined organic ,
and metal wastes. In addition, high organic wastes cause problems for .these types of
systems.
• Composting was eliminated because although it is potentially effective, this technology
is not commonly applied to soils with hydrocarbons and development could be
required prior to implementation.
922
, ,-4-
-------
h vT™ •*? eliminated tecause ^ technology is not proven 0,1 a full scale and it
has high capital costs. The FS states that this technology is ver^ e feet "e ir^fhe
des rucuon of organics and metals are encapsulated in c^stdlS mSx
Biological degradation was eliminated because this technology woukUot reduce or
ehrmnate the toxlcity or mobility of inorganic contaminants, Set The™^eSs In
fac, the presence of high concentrations of heavy metals in a waste sS £Sto
buriogicd actwuy. Considering the contaminant of concern at tlK site^sTead
. b,ologlcal treatment would not be an effective remediation alterr^e T\e FS states
however that for wastes associated with the oil refining industry1 neLu
b,ologlcal treatment have shown to be effective, and th! ability^ th^
reduce orgamc waste toxicity, mobility, and volume has beenlUentel

Innovative technologies eliminated during the detailed analysis include tile following:

• None '.!.

72.
Contaminant

Cleanup Level (Ppm) ARAR or <>ther Basis
Carcinogens
1 i
Lead

PCBs
" i.
PAHs
500

30
_OS\\'ER"
Risk biasedb
TSC!AC
(TSCA,
-5-
923
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
'3.
14. Were treatability studies conducted on the innovative technology or standard technology?

The ROD states that treatability studies were conducted as part of the FS to determine if
stabilization/solidification would be an effective technology for the wastes at the FSAR site.
The results of these studies indicate that this treatment is effective for this site because
following treatment, none of the TGLP chemicals were detected above their respective TCLP
regulatory levels (40 CFR Part 261.24). The low levels of organic chemicals of concern
(COCs) and PCBs allows the stabilization/solidification to occur, while immobilizing the lead
as well. This information on treatability studies was obtained from the ROD. The FS did
discuss these studies.
75. What measures/criteria were, used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Cost-effectiveness
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared?

The chosen remedy involves the "ultimate" removal of the waste material from the site and
therefore eliminates the human health and environmental exposure pathways of contaminants.
The chosen alternative is cost effective since it offers a degree of protection similar to on-site
landfilling and incineration at a lower cost. EPA does not believe that the incinerator
alternatives offer additional protection in line with the additional cost. The chosen alternative
was selected because it was known to be technically and administratively implemen table.
Qualified contractors who perform the work required under RAA-5B are available regionally.
The selected alternative also will satisfy the preference for treatment as a principal element of
the remedy.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the'remedy?

Technical considerations were not primary in selecting a treatment alternative for this site.
924
-6-
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Gulf Coast Vacuum Services
OU-1

Vermillion Parish, Louisiana
Region 6
GENERAL SITE INFORMATION
7.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? ..

Maximum concentrations of principal ;
contaminants were:
Sludge/Associated Soil (rag/kg)
Arsenic
Barium
Benzene
Total carcinogenic PAHs
74
47,800
529
44
Total noncarcinogenic PAHs 729

Soil/sediments (rag/kg)
Arsenic
Barium
64
22,900
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
3/89
7/92
9/92
Background

EPA Fund-lead j
PRPs: N/A .;
FS prepared by: Svjerdmp Corporation
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 15, 150 cubic yards of kludge and associated soil
• 19,500 cubic yards of soil and sediment
• - -
3. What type of site is this? !
' ' - ' J. -

Industrial Landfill. An inactive vacuum truck and oil field drilling mud plant that allowed
unpermitted disposal of organic- and inorganic-contaminated materials, primarily from the oil
industry, in several open pits. It is located in an agricultural area. '
1 ' "! '
• - i '
TECHNOLOGY SELECTION , | ..",-

4.. What standard, technologies were' considered for selection in this FS? I '..
I ' \

durfng the identificati°n and screening of technically feasible
-1-
925
-------
Sludge/Associated Soil

Access restriction:
Containment:
Physical treatment:
Thermal treatment:
Disposal:

Soil/Sediments

Access restriction:
Containment:
•Physical treatment:
Disposal:
Deed notices
Capping (clay, multimedia, RCRA, soil), vertical barriers
Solidification/stabilization (ex situ, in situ), dewatering
Incineration, cement kiln
Excavation, landfill (on-site, off-site)
Deed notices .
Capping (clay, multimedia, RCRA, soil), vertical barriers
Stabilization/solidification (ex situ, in .situ), oil extraction
Excavation, landfill (6n-site, off-site)
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Sludge/Associated Soil .

Biological treatment:' Composting, bioreactor, land treatment
Thermal treatment: Low-temperature thermal desorption '

Soil/Sediments

Biological treatment: Biodegradation
Physical treatment: Soil washing
Thermal treatment: Vitrification
Wliat was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs." After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP: long-term effectiveness and permanence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementability; cost; state/support
agency acceptance; and community acceptance.

RAAs presented parenthetically represent changes in the Proposed Plan and ROD.
926
-2-
-------
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Sludge/Associated Soil
Alternative
Innovative Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-4
Excavation/biological treatment
(undefined, possibly land treatment)
eliminated
eliminated
Soil/Sediments

No innovative technologies were incorporated into remedial alternatives;.'
7. How did the cost(s) compare to standard technologies? \
• \
Cost Estimates for RAAs That Include Standard Technologic
(selected remedial alternative is in bold)

Sludge/Associated Soil 1
Alternative
RAA-1
RAA-2
RAA-3A
(RAA-2)
RAA-3B
RAA-5
(RAA-3)
RAA-6
(RAA-4)
Standard Technology
No action •
RCRA cap
Excavation/stabilization-solidification/
on-site disposal/clay cover
In situ stabilization/solidification/clay
cover
Excavation/on-site incineration/
residue stabilization/solidification/on-
site disposal clay cover
Excavation/off-siteincineration/off-site
disposal
Estimated Costs
3 Crilieria
N/A
eliminated
N/A
eliminated
N/A
N/A
9 Criteria
$564,000
eliminated
$1,962,000
eliminated
$10,015,000
$26,605,000
Soil/Sediments
Alternative
RAA-1
Standard Technology '
No action "
Estimated Costs
3 Criteria
N/A
9 Criteria
$564,000
i- • ' ,
-' * ... -' '
-3- • " • '•'
927
-------
Alternative
RAA-2
RAA-3
RAA-4
RAA-5A
(RAA-2)
RAA-5B
(RAA-3)
Standard Technology
RCRAcap
Excavation/on-site disposal/RCRA cap
In situ stabilization/clay cap
Excavation/stabilization/on-site
disposal/clay cap
^-
Excavation/stabilization/off-site disposal
Estimated Costs
3 Criteria
eliminated
eliminated
eliminated
N/A
N/A
9 Criteria
eliminated
eliminated
eliminated
$2,445,000
$17,825,000
8. If a standard technology was chosen, why?

Sludge/Associated Soil: RAA-3 was chosen because it provides greater protection to human
health and the environment. This alternative reduces contaminant mobility, volume, and
toxicity through treatment. Organic contaminants are destroyed through treatment, and
inorganic residual is stabilized to mitigate, the risk of leaching into the ground water. This
alternative offers a great deal of long-term effectiveness and, permanence since the organics
will be destroyed and the inorganics will be stabilized. A treatability study tested the
effectiveness of thermal treatment and determined that organics are destroyed and the resulting
ash passes the TCLP test by a large margin. Potential short-term risk from excavation is
minimized by engineering controls and monitoring. This alternative does not require the
transport of materials and therefore minimizes the risk to workers and the community. This
alternative can be quickly and effectively implemented with labor and materials easily
available within the region. This alternative is cost-effective.

Soil/Sediment: RAA-2 was selected because it substantially reduces the "risk from direct
contact by stabilizing the contaminated media and covering the matrix with a clay cap.
Stabilization will immobilize inorganic contaminants, the principal contaminants in the site soil
and sediment. The inorganic material will be chemically bound, thus mitigating its leaching
potential into the ground water. Stabilization is an established and effective means of treating
inorganic contamination in soil. Existing organic contaminants in the surface soil are below
health-based levels. RAA-2 is effective in the long-term because the major site contaminants,
inorganics, are effectively treated with stabilization. Since inorganics such as barium are
elements that cannot be destroyed and, therefore, toxicity can not be reduced, stabilization
provides the most effective treatment technology. Potential short-term risk will be minimized
with engineering controls and monitoring. This alternative can be easily implemented. This
alternative is cost-effective. ...
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
928
-4-
-------
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Sludge/Associated Soil !

Innovative technologies eliminated during the initial screening include the following:

• Low-temperature thermal desorption was eliminated because it! would not be applicable
because of the presence of nonvolatile organics.

Innovative technologies eliminated during a three criteria screening of technologies include the
following: . I
- i -•-'."

• Composting was eliminated because it would not be amenable for inorganics; it would
require space that might not be available; and it would require controlled conditions,
time, large volumes of biomass, supervised labor, collection of i runoff/leachate, and
means of disposing of product. Moreover, heavy metals might1 inhibit the process.
• Bioreactor was eliminated because it would be inhibited by heavy metals, high
chlorides, and other salts. The process would require controlled conditions of pH,
temperature, dissolved oxygen, and nutrients. It is a labor intensive process that would
not degrade or remove all organics in the waste. j

'> •' • '"' - ••-' i • - >
Innovative technologies eliminated during a three, criteria screening of RAAs:
' ' ' . • ' ' I
• Biological treatment (undefined, possibly land treatment) was eliminated because some
recalcitrant organics would remain, metals would remain and cpulcl adversely affect
microbial growth, and a prolonged treatment time would be required. A preliminary
evaluation by EPA's Office of Research and Development indicated that concentrations
of hydrocarbons and metals at most locations preclude the use of bioremediation. This
evaluation indicated that heavy metals can be toxic to microorganisms, even at levels
below 1 ppm, depending on their species. Also, biodegradation of soil with total
petroleum hydrocarbon concentrations above 2,000 mg/kg typkially would not be
attempted.
I .,
Innovative technologies eliminated during the detailed analysis include [the following:

• None . • • • . . |- ..'•'••.•
• • • ' "I
Soil/Sediment

Innovative technologies eliminated during the initial screening include Ithe following:

• Biodegradation was eliminated because it would not be applicable to metals, and some
organics are recalcitrant to .biotreatment.
• Soil washing was eliminated because it would not be applicable: because of the high
clay content of the soil/sediment.
-5-
929
-------
Innovative technologies eliminated during the three criteria screening of technologies include
the following:

• Vitrification was eliminated because its process costs are grossly excessive compared
to other alternatives.

Innovative technologies eliminated during the three criteria screening of RAAs include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

" None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Sludge/Associated Soil: The criteria weighted most heavily in selecting a remedial alternative
were protection of human health and the environment and cost. -EPA preferred RAA-3
because it is the most protective to human health and the environment through the reduction of
organics and stabilization of inorganic contaminants. RAA-4 was considered to be slightly
more protective since it proposed the off-site disposal of materials; but its cost were
disproportionately high for its benefits. . • .

Soil/Sediments: The criteria weighted most heavily in selecting a remedial alternative was
protection to human health and the environment and cost. The chosen alternative provides the
greatest protection to human health at a cost proportional to its benefit. This alternative
effectively immobilizes the main site contaminant. Another alternative that would be slightly
more protective because treated media would be disposed of off site was not selected because
it would be much more costly. Further, it was pointed out that overall environmental
protectiveness would not be improved by off-site disposal because it only relocates the waste. ,
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Sludge/Associated Soil/Soil/Sediment
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Benzene
Total carcinogenic
PAHs
16
0.66
3
Background3
Risk"
EPA Region 6C
930
-6-
-------
13.
•-.... . . - ' • ";' • • . . ' • .
Contaminant
Cleanup Level (mg/kg)
ARAB: or Other Basis
Noncarcinogens
Barium
Total noncarcinogenic
PAHs
5,400
HI 1
Risk
EE'A Region 6
"Upper background limit. j
bBased on an excess upper bound individual lifetime cancer risk of 10"6 or a Hazard
Index less than or equal to 1.0. ;
•Determined by EPA Region 6, Dallas, Texas.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: i

• ' " None ''• . . , I ' ".
i . •
•..'"' i
Standard technologies eliminated because of cleanup goals include: ,
i • '
• Stabilization/solidification
• Clay cover
14.
Were treatability studies conducted on the innovative technology or standard technology?

A preliminary evaluation of the waste/media with respect to the applicability of bioremediation
was conducted by EPA's Office of Research and Development (1991)) A thermal treatability
study conducted on soil and sludge indicated that the organic contaminants are destroyed and
that the ash remaining from the incineration would pass the TCLP test by a large marsin
.(SverdrupM992) .. .. .
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

, Risk level achieved
Cost-effectiveness
16. How are measures compared? ,

In both instances (sludge and associated soil, and soil and sediment), health-based risk levels
were met. Treatment technologies were utilized to the greatest extent ppssible for reducing or
immobilizing site contaminants. Cost-effectiveness was a determining factor since the •
preferred alternatives were selected because they offer protection to huiinan health at a
proportional cost. In both cases, other alternatives that proposed off-silte disposal of treated

•••'.' . . -7- ' • :"• . i "
931
-------
materials and somewhat more protection to human health were not selected because they
would be more costly. Further, off-site disposal was not considered more protective of the
environment overall since contaminants merely would be displaced.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
References:

EPA, 1991, Potential of bioremediation at the Gulf Coast Vacuum Services, Inc. Superfund
Site. Letter memo to U.S. Environmental Protection Agency-Region 6, from U.S. EPA Office
of Research and Development, Cincinnati, Ohio.

Sverdrup, 1992, Treatability Study Report for the Remedial Investigation/Feasibility Study at
the Gulf Coast Vacuum services, Inc. Superfund Site, Vermilion Parish, Louisiana.
932
-------
Gulf Coast Vacuum Services
OU-2

Vermillion Parish, Louisiana
Region 6
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Sludge and Associated Soil (ing/kg)

Total petroleum hydrocarbon 700,000
Benzene 529
Arsenic 73.7
Barium 47,800
Total carcinogenic PAHs 44
Total noncarcinogenic PAHs 729
Site IHistory
NPL Proposed:
NPL Final:
FS:
Interim ROD:
6/88
3/89
7/92
9/30/92
Background .
I

EPA Fund-lead '
PRPs: Over 400 identified (not
specified)
FS prepared by: Sverdrup Corp.
An extensive list of volatile and semivolatile
cornpounds was detected at the site; 77 contaminants were selected as fcontaminants of
potential concern for the risk assessment.
2. What volume of material is to be remediated? !
' , .-••!"' •

The volume of material to be remediated included: i

• 7,700 cubic yards of sludge from the West Pit and Washout Pit
• 1,300 cubic yards of associated soil from the West Pit and Washout Pit

' . • . ' i- •".-.'•
3. What type of site is this? j

Industrial Landfill. An inactive vacuum truck and oil field drilling mud plant operation that
allowed unpermitted disposal of organic- and inorganic-contaminated materials, primarily from
the oil industry, in several open pits. The site is located in an agricultural area.
TECHNOLOGY SELECTION
4. What standard technologies were considered for selection in this FS?

No initial screening of technologies was conducted .for this Interim FS. Six RAAs were
developed using standard technologies and evaluated using the nine approved criteria:
-1-
933
-------
Containment:
Disposal:
Synthetic membrane .
Excavation/on-site disposal (single pre-existing pit, lined holding area,
temporary holding tank)
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: .

No innovative technologies were considered.
What was the cost estimate for the innovative technology?

During the initial screening process, in which .technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. The three-criteria screening was not carried out in this FS. For this site, estimated
costs were calculated during an evaluation based on nine criteria established by the NCP. No
innovative technologies were selected.
How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1A
RAA-1B
(RAA-l)a
RAA-2
RAA-3A
(RAA-3)
RAA-3B
(RAA-4)
Standard Technology
Pump and treat collected rainwater
(lease system components)
Pump and treat collected rainwater
(purchase system components)
Pump and treat collected rainwater/
synthetic cap
Pump and treat collected rainwater/
excavate wastes/consolidate wastes
into single, pre-existing pit/cover with
synthetic membrane
Pump and treat collected rainwater/
excavate wastes/consolidate wastes in
lined holding area,
Estimated Costs
3 Criteria
N/A
N/A ,
N/A
-N/A
N/A
9 Criteria
$653,250
$566,850
$372,800
($395,700)"
$399,800
($525,200)
$646,840
($834,150)
.)
934
-2-
-------
Alternative
RAA-3C
(RAA-5)
Standard Technology
Pump and treat collected rainwater/
excavate wastes/consolidate wastes in
temporary holding tank
Estimated Costs
3 Criteria
h
/A
9 Criteria
$713,920
($858,700)
"RAA designations that changed in the ROD are presented parenthetically. The costs of
several of the alternatives differ from those in the Proposed Plan because the estimates,have
been refined based on several factors, including public comments and 'minor changes in the
description of the alternatives. !
bCosts presented in the ROD are shown parenthetically. j
8. If a standard technology was chosen, why?

RAA-3 was selected because it is protective of human health and the environment. RAA-3
eliminates the risk of the Washout Pit leaching contaminants that can infiltrate through the
underlying soils to ground water. With Washout Pitsoils and sludges! consolidated in the
West Pit, the West Pit sludge will be more stable. Since the sludge wjill be consolidated into a
single pit, the exposed surface area of the material with the underlying soils will be reduced.
Of the three alternatives that would be most protective of human health and the environment
(RAA-3, RAA-4, and RAA-5), RAA-3 takes the least amount of time to implement and poses
the least direct threat to workers since only one pit is excavated, as opposed to two. The
resources (both labor and equipment) are readily available in the area to implement RAA-3
effectively. Conventional earthmdving equipment is used to excavate and transport the
material, and the liner system is commercially available locally. By excavating, consolidating,
and containing the contaminated sludge and associated soil, RAA-3 is "'most protective of
human health and the environment and most capable of reducing toxicity, mobility, and
volume"; RAA-3 is cost-effective and quick to implement. , |
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10.
If an innovative technology was not chosen, why not? At what stage w!as the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tljiree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
' • '. ! ' •
Innovative technologies eliminated during the initial screening include !the following:

• None
-3-
935
-------
Innovative technologies eliminated during the screening of the three criteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:

• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Note that long-term effectiveness "is not applicable to interim actions."

Protection of human health and the environment, and cost were weighted most heavily in
selecting a remedy. By excavating, consolidating, and containing the contaminated sludge and
associated soil, RAA-3 is protective of human health and the environment. Of all the
alternatives evaluated for the accumulated rainwater that included a component to excavate the
pits, the selected alternative provides the best overall protection to human health and the
environment.

The residential community's comments indicate a preference for the excavation of both the
West Pit and the Washout Pit in this interim action. RAA-3 is less costly than alternatives
that offer comparable levels of protectiveness.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic (carcinogenic
and noncarcinogenic)
Benzene
Total carcinogenic
PAHs
16
0.66
3a
Upper background limit
, Risk
Region VIb
Noncarcinogens
Barium
Total noncarcinogenic
PAHs
5,400
Hazard index of 1.0
Risk
Region VIb
"Expressed as benzo(a)pyrene equivalents.
•"Determined by EPA Region VI, Dallas, Texas.
)* L
.)
936
-4-
-------
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to 10
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ' t .
' • - '"-'..,•
Innovative technologies eliminated because of cleanup goals include:

• None j
1 - '"',','' ' ' ^°
Standard technologies eliminated because of cleanup goals include: .

' ' • '•'''!•'
• - None /
14. Were tr.eatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. '

. • - !
75. What measures/criteria were used, to compare alternatives? " !.

The following measures were used to compare the alternatives: |

Total cost i
Time to design/construct/operate ;
Proven technology ' • •

i '
16. How are measures compared? !

Of the three alternatives that would be most protective of human health and the environment,
RAA-3 is the least costly and takes the least amount of time to implement:—14 weeks.
Conventional equipment is used to implement RAA-3 and the liner system is commercially
available locally. .
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy.
937
-------
Mosley Road Sanitary Landfill

Oklahoma City, Oklahoma
Region 6
GENERAL SITE INFORMATION

7. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations bf principal
contaminants were:

Soil/Sediments (mg/kg)

Soil borings in the landfill revealed no
contaminant "hot spots" and soil/sediment
samples revealed no contaminants that
exceeded cleanup levels.
2. What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
6/24/88
11/91
6/29/92
Background

PRP-lead
PRPs: WMO, Mobile Waste Controls,
33 other PRPs
FS prepared by: Colder Associates
Incorporated
The volume of material to be remediated included:

• 10,420 cubic, yards of waste
3. What type of site is this? ' .

Industrial .Landfill. A former landfill that used to accept industrial hazardous waste.
TECHNOLOGY SELECTION

4. Wliat standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing, warning signs, security, deed restrictions
Containment: Clay cap, asphalt cap, concrete cap, composite cap, slurry wall, grout
curtain, sheet pile liners, grout injection
Physical treatment: Solidification/fixation, aeration
Chemical treatment: Neutralization, stabilization/immobilization
Thermal treatment: Incineration
Disposal: Excavation, disposal at RCRA waste facility
938
-i-
-------
5. Was an innovative technology, considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ biodegradation, ex situ biodegradation, landfarming
Phys/Chem treatment: Soil washing (waste/solvent leaching), soil flushing (in situ.waste/
solvent leaching), air sparging (in situ aeration), in situ
oxidation/reduction '•-.-! > ' .
Thermal treatment: In situ vitrification ;
6. What was the cost estimate for the innovative technology? S
I ' ;
i , •"'.,' '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Xfter the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on the nine criteria established
by the NCP, :
1 , • , '
No innovative technologies were incorporated into remedial alternatives; therefore no costs
were estimated. . ' .
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
Repair existing cap/vegetative soil
layer
Repair existing cap/clay cover over
waste pits/vegetative soil layer
Repair existing cap/RCRA type
composite cover over waste pits/
vegetative soil layer
Repair existing cap/clay cover over
entire landfill/vegetative soil layer
Addition of RCRA type composite
cover over entire landfill
Estimated Costs
3 Criteria
$3,1C)0,000
$3,3CJO,000
$4,100,000
$5,700,000
$11,6130,000
9 Criteria
$3,100,000
$3,300,000
/'
eliminated
$5,700,000
eliminated
-2-
939
-------
8. If a standard technology was chosen, why?

The selected capping remedy (RAA-1) protects human health and the environment by
eliminating the direct contact risk and reducing the potential for any contaminants to migrate !
from the waste pits to the ground water and a result of infiltration^ The NCP states that !.
containment technologies will generally be appropriate remedies for wastes that pose a
relatively low level threat or where treatment is impracticable. Removal of contaminated soil
at municipal landfills is generally limited to hot spots, or when practicable, to landfills with a . !
low to moderate volume of waste. No hot spots have been located at the site; therefore all
source control remedies were capping.

The selected remedy is the most cost-effective alternative. RAA-3 and RAA-5 were , ' "•
eliminated during the three-criteria screening process because the addition of a synthetic cover •'
(RCRA type) would cost significantly more but only minimally reduce the amount of • '
infiltration. The higher cost would not be reflected in a proportional increase in !
protectiveness. RAA-2 and RAA-4 were eliminated during detailed analysis because they were
more costly and the additional measures they contain do not provide additional protectiveness •
since it has been concluded that hot spots do not exist within the landfill.
• , .

9. If an innovative technology was chosen, why?

An innovative technology was not chosen. \
• •

10. !f an innovative technology was not chosen, why not? At what stage was the innovative ^P )l
technology eliminated? • , ~"V

Innovative technologies eliminated during the initial screening include the following:

• Ex situ biodegradation was eliminated because the metal contaminants found at the
site do not biodegrade.
• Landfarming was eliminated because the metal contaminants found at the site do not
biodegrade.
• In situ biodegradation was eliminated because adding nutrients to the landfill could be
detrimental to surface and groundwater quality. Furthermore, toxic by-products could
be produced from contaminant degradation.
" Soil washing (water/solvent leaching) was eliminated because it is only applicable to
heavily contaminated soils; placing solvents in contact with soils containing low levels
of organics (such as levels found at this site) may increase organic contaminant levels.
• Soil flushing (in situ water/solvent leaching) was eliminated because the leaching
solution would be very difficult to deliver and recover uniformly. ,
• Air sparging (in situ aeration) was eliminated because the heterogeneous waste would
be difficult to aerate uniformly. Furthermore, the process would have limited
application, since it would not remediate semi-volatile organics.
« In situ vitrification was eliminated because the methane gas in the landfill would pose
a potential explosive hazard and the technology is very expensive to implement.

940 ,
'-3- • ' •
-------
• In situ oxidation/reduction was eliminated because of the difficulty in uniformly
delivering the pxidants, recovering precipitated metal sludges, and the probability of
' unwanted by-products remaining in the soil. !

No innovative technologies were incorporated into the RAAs; therefore no innovative
technologies were eliminated during the three-criteria screening process or during detailed
evaluation. j
11. Which of the nine criteria were weighted most highly in selecting thekechnology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
' ' . : • . I'-. ' •
I • - "
For those alternatives that provided protection of human health and the environment and
attained ARARs, cost-effectiveness was the most heavily weighted criteria in selecting a ,
remedy. No innovative technologies were evaluated based on the nine criteria. ,
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
> ' • ^ i
,' *
The only threat from soil/sediment contaminants at the site is their impact on ground water.
The remedial goals for soil/sediment included the elimination of direct exposure to
contaminants and the reduction of any soil/sediment contribution to ground and surface water
contamination. Therefore, EPA's selected alternative does not address directly the content of
the landfill, but instead inhibits-the generation of leachate due to water infiltration.

For carcinogens, an excess upper bound individual lifetime cancer risjc of between 10"4 to 10~6
was acceptable. For noncarcinogens, Hazard Index less than or equal to 1.0 was acceptable.
These estimates demonstrated that the landfill soil/sediments did not pose a threat to" human
health.
13. Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was selected, could it meet the cleanup goals?

Innovative technologies were eliminated because they were not applicable to the contaminates
at the site and because the large volume of low level contamination at the site would be more
appropriately contained rather than treated. No innovative technologies were eliminated
- • because of cleanup goals. The standard technology selected could meet cleanup goals for the
site. ; '...••, . !
14. Were treatability studies conducted oh the innovative technology or standard technology?

No treatability studies were conducted. '
-4-
941
-------
75. W}iat measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
* '' '
Total cost
Risk level achieved ,

16. How are alternatives compared?

Since all source control alternatives involved various capping scenarios, they were rated
similarly for protectiveness, ARARs, long-term effectiveness, short-term effectiveness,
reduction of TMV, and implementability. The alternatives were compared based on cost. No
hot spots were found that required additional containment measures to control infiltration.
Therefore, additional containment measures beyond repair of the existing cap would not
achieve a higher level of risk protection that would justify their additional cost.
~

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ..

The landfill is in an undeveloped residential area. About 1.7 million gallons of hazardous ,
liquids were disposed of in unlined waste pits over a six month period 14 years previously; the
waste pits are now covered by up to 80 feet of municipal waste. Underlying the site is
unconsolidated sediments and a bedrock aquifer. North Pond lies north of the landfill and
South swamp lies south of the landfill. Hydrogeology did not play a primary role in source
control remedy selection. Technical considerations could not be considered primary in '
selecting a source control remedy at .this site. The volume and nature of contamination at this
site was primary in the selection of a remedy.
942
-5-
-------
Oklahoma Refining Company

Cyril, Oklahoma
Region 6
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/sediment (mg/kg)

Arsenic 236
Benzene 25
Chromium 24,020
2-MethylphenoI 1,700
4-Methylphenol 5,400
Benzo(a)anthracene 300
Benzo(a)pyrene 280
Benzo(b)fluoranthene 120
Benzo(k)fluoranthene 40
Idenp(123/c,d)pyrene 84
Pyrene 190
Dibenzo(a,h)anthracene 23
Naphthalene 350
Beryllium* L4
Lead 19,390
Chrysene 456
2-Methylnaphthalene 2,000
Phenanthrene 1,100
Phenol 4,200
2,4-Dimethylphenol 200
Site History

NPL Proposed: N/A
NPL Final 6/88
FS ';.) 12/91
ROD: 6792
i .

Background

EPA Fund-lead
PRPs: Cyril Petrochemical Company
FS prepared by: Bechtel Environmental,
Inc. i
2. What volume of material is to be remediated?

The volume of material to be remediated included:
i

• Approximately 120,000 cubic yards of contaminated soil and sediment
3. What type of site is this?

Petroleum Refining. An abandoned refinery that is located in a rural area.
-1-
943
-------
TECHNOLOGY SELECTION '

4. What standard tec/,' -logies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:

Physical/chemical:
Thermal treatment:
Disposal:
Fencing, warning signs, deed restrictions, deed notices
Capping (clay, asphalt, concrete, multimedia), surface controls, dust
controls
Neutralization, polymerization, stabilization, surface encapsulation
Incineration (rotary kiln, fiuidized bed, infrared)
Excavation, disposal (off-site, on-site)
5. Was an innovative technology considered in the F.S? If so, which technology?

Innovative technologies considered during the identification and screening of technically '
feasible technologies were:

Biological treatment: Biodegradation, composting, soil slurry reactor, prepared bed reactor
Physical/chemical: Oxidation/reduction, hydrolysis, soil venting, soil flushing, chemical
dechlorination, chemical extraction, soil washing
Thermal treatment: Vitrification (in situ, ex situ), low-temperature thermal desorption,
electric pyrolyzer
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-4
RAA-5
Innovative Technology
Containment/neutralization/biotreatment
In situ stabilization/neutralization/
biotreatment
In situ stabilization/recycling/
neutralization/in situ biotreatment/ ,
prepared bed reactor
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$10,977,563
$21,544,740
$24,044,056
m
944
-2-
-------
Alternative
RAA-6
Innovative Technology
In situ stabilization/recycling/
neutralization/low-temperature thermal
desorption
Estimated Costs
3 Criteria
N/A
9 Criteria
$52,645,422
7. How did the cost(s) compare to standard technologies? !

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action
Limited action
Estimated Costs
3 Criteria
• N(A
' . N/A
9 Criteria
$15,302
$1,918,114
8. If a standard technology was chosen, why? \
' • ," i
In situ stabilization and,a cap of the residuals were selected for some \yastes.
9. If an innovative technology was chosen, why?

The chosen alternative RAA-5 was preferred because it protects human! health and the
environment by treating 89 percent of the total waste. All contaminant media in excess of
cleanup levels are treated. In situ biotreatment is: performed in a lined 'surface impoundment
and is expected to destroy 90 to 95 percent of the organic contaminants. The biotreated
residuals and the sediment and soil remaining with inorganic contaminants in excess of
cleanup levels will be stabilized and contained on site. Through treatment, this alternative
reduces contaminant toxicity, mobility, and volume. The proposed technology has been
proved effective for the types of contaminants present at the site and is not expected to cause
any unusual problems in its implementation. No specialized equipment is necessary to
implement this alternative. Reducing contaminant levels through treatment ensures the most
-3-
This alternative meets
effective and permanent remedy for contaminated soils and sediments. „
all ARARS. Risk from excavation and material handling will be minimized by providing strict
controls. This alternative is cost-effective. The ROD also selected ex isitu biodegradation
(unspecified) before remediation of some wastes.
945
-------
10. If an innovative technology was not chosen, why not? At-what stage was the innovative
technology eliminated? I

Innovative technologies eliminated during the initial screening include the following:

• Oxidation/reduction (in situ) was eliminated because its limited applicability makes it
difficult for the reagent to contact the hazardous materials because of the low
permeability of the site's soils. .
• Hydrolysis (in situ) was eliminated because it would not be applicable since waste
materials are fully hydrolysed. . .
" Soil venting was eliminated because it would not be applicable since the permeability , :.'
of site soils would not allow adequate air flow. Soil venting is effective when the
subsurface media has a permeability of 10"4 to 10"6cm/sec, and the site soil has a
permeability less than 10~6cm/sec. ,
• Soil flushing was eliminated because it would not be applicable since site soils are not
very porous and have relatively low permeabilities.
• Chemical dechlorination (in situ) was eliminated because it would not be applicable to
the site since there are few chlorinated compounds.
• Soil washing was eliminated because it would not be applicable to the small grain size
of soil/sediment. The high silt and clay content of the site's soil could impede the .^
solid-liquid separation after washing. „ «|H
• Composting was eliminated because it has not been demonstrated to be effective for •
similar wastes. ... . .
• Soil slurry reactor was eliminated because it would not be applicable to the small
grain size of soil/sediment. The high silt and clay content of the site's soil could
impede the solid-liquid separation after washing.
• Electric pyrolyzer was eliminated because it would not be applicable to the metals
content in the site's soil. Further, this process would require extensive air pollution
controls and the large volume of ash generated would likely contain high levels of
inorganics and might need to be stabilized prior to disposal.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• In situ vitrification was eliminated because it would be difficult to implement because
of large areas of contamination on site and high cost.
» Chemical extraction was eliminated because it would not be effective in clay soils.
• Ex situ vitrification was eliminated because of the very high capital cost.

Innovative technologies eliminated during the detailed analysis include the following:

• Low-temperature thermal desorption (LTTD) was eliminated because it would not be
cost-effective compared to the chosen alternative since it would provide only 4
percent increase in contaminant removal for $28.6 million. LTTD would be more
difficult to implement than the chosen alternative because it would require more fflBh \
extensive material handling and procurement of specialized equipment. "

946
-4- • . ' '
-------
11.
Which of the nine criteria were weighted most heavily in selecting the [technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative 'iven; protection to human
health and the environment, long-term effectiveness and cost. RAA-1 jand RAA-2 were
eliminated because they would not protect human health and the environment. RAA-3 was
eliminated because it could not ensure long-term effectiveness since true caps would need to be
maintained. RAA-4 was eliminated because it would not address all site wastes and therefore
it was not protective of human health and the environment. Two alternatives would
adequately address all site contaminants. Of these, the chosen alternative was cost-effective.
12.
What cleanup goals were selected? If the cleanup goal was based on\an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Surface Soil/Sediment
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Beryllium
Cadmium
Chromium
Lead
Nickel
Benzene
Benzo(a)anthracene
Benzb(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenzo(a,h)anthracene
Indeno(123/c,d) pyrene
25 or 305"
0.5
135
1,350 or 770
600 or 865
5,400
22 or 0.2
4.1
0.33
0.69
13
46
0.33
3.2
EPAborGWc ,
Detection limit ;
Risk"
Risk or GW
Model6 or GW
Risk
Risk or GW
Risk
Etetection limit
Risk
Risk
Risk
Detection limit
Risk
Noncarcinogens •
Barium
Mercury
Zinc
13,500
81
54,000
Risk
Risk
• Risk ..'•
-5-'
947
-------
Contaminant
Ethylbenzene
Toluene
Xylenes
Acenaphthalene
Anthracene
Benzo(g,h,i)perylene
Fluoranthene
Fluorene
Naphthalene
Phenathrene
Pyrene
2,4-Dimethylphenol
2-Methylnaphthalene
2-Methylphenol
Phenol
Cleanup Level (mg/kg)
27,000 or 191
54,000 or 104
540,000 or 2,828
16,000 or 4,424
,81,000 or 55,752
1,080 * '.
10,800
10,800 or 8,888
79
1,080
8,100
5,400 or 66
1,080 or 510
13,500 or 14
162,000 or 125
ARAR or Other Basis
Risk or GW
Risk or GW
Risk or GW
Risk or GW
Risk or GW
Risk
Risk
Risk or GW
GW
Risk
Risk
Risk or GW
Risk or GW
Risk or GW
Risk or GW
"When more than one cleanup level was estimated, the lower of the two numbers was
used to determine the necessary action to address the contaminated media.
bCleanup levels were set by EPA Region VI to be protective of human health in a
residential setting., ,
cCleanup levels were estimated to prevent leaching from contaminated soil/sediment
into ground water. This method can be found in an EPA guidance document entitled
"Determining Soil Response Action Levels Based on Potential Contaminant Migration
to Ground Water: A Compendium of Examples" (EPA/540/2-89/057), October 1989.
dCleanup levels were determined by health-based risk assessment. For carcinogens, an
excess upper bound individual lifetime cancer risk of 10"6 was acceptable. For
noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
TEPA Uptake/Biokinetic Lead model.

Subsurface Soil
948
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Chromium
Lead
305 ,
770
865
GW3
GW
GW
-6-
-------
Contaminant
Benzene
Cleanup Level (mg/kg)
0.2 '
ARAR or Other Basis
GW
Noncarcinogens
Naphthalene
Phenol
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
2-Methylnaphthalene
79
125
12
14
66
510
GW
GW
GW
GW
GW
GW
Cleanup levels were estimated to prevent leaching from contaminated soil/sediment
into ground water. This method can be found in an EPA guidance document entitled
"Determining Soil Response Action Levels Based on Potential Contaminant Migration
to Ground Water: A Compendium of Examples" (EPA/540/2-89/057), October 1989.
' \

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ,

Innovative technologies eliminated because of cleanup goals include:

• None

, Standard technologies eliminated because of cleanup goals include:

• None . , ••'•.".

14, Were treaiability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
/
Risk level achieved *
Cost/unit risk
Preference for treatment (vs. containment)
-7-
949
-------
16. How are measures compared?

The chosen alternative was selected because it would destroy 90 to 95 percent of the organic
contaminants, thereby providing significant risk reduction, li was preferred over another
alternative, RAA-6, because it was cost-effective. Thus, while RAA-6 would destroy 95 to 99
percent of the organic contaminants, this 4-percent increase would cost an additional $28.6
million. The slight increase in effectiveness did not justify the increase in cost. The chosen
alternative was preferred over all of the other alternatives because it would reduce risk in a
more complete and long-term manner. Further, treatment was preferred over containment as
evidenced by the elimination of RAA-3.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The low permeability and high clay and silt content of the soil precluded the use of:
oxidation/reduction, =soil venting, soil flushing, soil washing, soil slurry reactor, chemical
extraction. This technical consideration was not primary in selecting a remedial alternative.
950
-------
Petro-Chemical Systems, Inc.
OU-2
'* .
Liberty County, Texas
Region 6
GENERAL SITE INFORMATION
1.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg):

Benzene
Lead
Naphthalene
28
24
320*
'Sample did not satisfy all QA/QC
requirements and is considered conditionally
valid. Results can be used for trending
purposes.
NPL Proposed:
NPL Final:
FS:
ROD:
Background

EPA Fund-lead
PRPs: ARCO
FS prepared by: Roy F. Weston,
Inc. (9/91); Lockwood, Andrews
& Newman, Inc. (3/91)
Site History
1984
(5/86
9/3/91
9/6/91
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• 302,800 cubic yards of soil ,

3. What type of site is this?

Industrial Landfill. Former petrochemical waste disposal area.

TECHNOLOGY SELECTION .
.^——^—M*^——«_^_^_
; f

4. What standard technologies were considered for selection in this FS? '

Standard technologies considered during the identification and screening of technically feasible
technologies were: .

Access restriction: Deed restrictions, fencing and posting warning sign;!
Containment: Capping with topsoil and vegetation, cement stabilized soil, asphalt,
concrete, clay, or clay/synthetic liner and cap, covering with a dome or
-1-
951
-------
Chemical treatment:
Thermal treatment:
Disposal:
synthetic membrane, vertical barriers (slurry wall, cement/bentonite
wall, grout curtain, sheet pile wall, or interceptor trenches)
Solidification/stabilization
Soil stripping (auger), fluidized bed, incineration, infrared incineration
Excavation, dredging, landfill (on-site or off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: .

Biological treatment: Aerobic/anaerobic biodegradation, soil/slurry bioreactor, landfarming
Phys/Chem treatment: Vapor extraction, solvent extraction, soil washing (solvent/surfactant),
soil washing (water)
Thermal treatment: Vitrification, radio frequency volatilization, supercritical water
oxidation, wet air oxidation, low-temperature thermal stripping
6. What was the cost estimate for the innovative technology?

Only estimated costs for individual technologies were presented in the FS. Present value costs
for RAAs, however, were provided in the ROD.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-4
RAA-9
Innovative Technology
Ex situ biodegradation/landfill closure,
if necessary
Solvent extraction/excavation and
storage of soils on site/use of
decontaminated soils as backfill on the
site/off-site incineration of contaminated
solvents
Vapor extraction and catalytic
oxidation of extracted vapors'/long-
term monitoring
Estimated Costs
ROD
$41,100,000
$142,200,000
$26,430,000
•Catalytic oxidation was added as a technology during the more detailed evaluation of RAAs.
952
-2-
-------
7. How did the cost compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
;
Alternative
RAA-1
RAA-2
RAA-5
RAA-6
RAA-7
RAA-8

Standard Technology
No action/monitoring of the leachate
collection system for the temporary on-
site landfill/maintaining the integrity of
the road and road side drainage ditches
Slurry walls/multilayered caps/landfill
closure/long-term monitoring of the
site and ground water/possible deed
restrictions
Incineration/excavation and storage of
soils on site
Thermal stripping/excavation and
storage of soils on site
Excavation on-site/landfilling/
multilevel cover/leachate collection
system
Excavation off site/landfilling
Estimated Costs
ROD
il, 440,000
$8,500,000
$280,200,000
$]J21,000,000
$27,800,000
$72,400,000
8. If a standard technology was chosen, why?

Two RAAs, a, standard (RAA-2) and innovative (RAA-9), were chosen
and will be
implemented together. RAA-2 was chosen to improve the efficiency of the innovative
technology, vapor extraction. The cap will reduce the amount of surface air so that air pulled
through the contaminated soil via vapor extraction will be coming primarily from the air
injection wells. The slurry walls will prevent migration of contaminated ground water.
9. If an innovative technology was chosen, why?

In situ soil vapor extraction (SVE) was selected because: 1) it would not
the contaminated soils prior to treatment, thereby reducing the short-term
emissions, 2) treatability studies of SVE have been conducted at sites in
Pennsylvania, with soils similar to those at this site, 3) cost, 4) reduces
into ground water, and 5) avoids extraction and placement of RCRA hazardous
therefor will not .need to comply with LDRs or other RCRA ARARs.
-3-
require excavation of
risk from volatile air
Florida and
contaminant leaching
waste, and
953
-------
JO, If an innovative technology was not chosen, why not? At what stage was the innovative ••••
technology eliminated? ^HF V
' •"
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

" In situ soil washing/soil flushing was eliminated because of the high clay content of
the soil and inefficiency of the method.
• Radio frequency volatilization was eliminated because the technology has not been . |
proved. . -
• Vitrification was eliminated because of its significantly higher costs with no increase in
effectiveness over other technologies. ~i
" Soil/slurry bioreactor was eliminated because of its higher costs without significant
advantages over other technologies. . !
" In situ bioremediation was eliminated because of the high clay content of the soil.
" Supercritical water oxidation was eliminated because it is not commercially available,
has not been demonstrated on similar waste to those at the site and difficulty in finding
corrosion resistant materials to be used in construction of full-scale units.
" Wet air oxidation was eliminated because treatment requires a 5 % by weight slurry f
and for the quantity of soil potentially requiring treatment, the technology would not
be technically feasible.
• Permeable treatment beds were eliminated because it is not a proven technology. J4uHi \
111 ;)
Innovative technologies eliminated during the screening of the three criteria include the
following: [

« In situ low temperature thermal stripping was eliminated because it has not been
previously demonstrated under similar site conditions and does not have significant : i
advantages over in situ vapor extraction.
* Landfarming was eliminated because of higher costs and lower effectiveness and • •- ;
implementability.

Innovative technologies eliminated during the detailed analysis include the following: -
/- , i - .
• Biological treatment (treatment bed) was eliminated due to the short term risk posed
by the mobility of the volatile contaminants as the soil is excavated. i
» Solvent extraction was eliminated because it is not cost effective and the anticipated
number of units of equipment to treat the amount of soil at the site may not be
available.
• Low temperature thermal stripping (thermal desorption) was eliminated because in the '
short term it is not cost-effective, the mobility of the contaminants will increase as the.
soil is excavated, and the anticipated number of equipment units may not be available.
954
-4-
-------
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Short term effectiveness, cost and reduction of toxicity, mobility or volume weighted most
heavily in selecting the technology. • -
12.
13.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? j
Contaminant
Cleanup Level (ppm)
ARAR <»r Other Basis
Carcinogens
Benzene
Lead
10 (at soil depths less
than 10 feet)
0.35 (at depths greater
than 10 feet)
• 500
MC!L, Model"
GSWER"
Noncarcinogens
Naphthalene
70
Risk
"Soil cleanup level is based on the potential of benzene in soil to leach into the
underlying ground water aquifer. The MCL for benzene in driiiking water used the
SESOEL model to calculate ground water levels of benzene.
bOSWER Directive on the Interim Guidance on establishing Soil Lead Cleanup Levels
at Superfund Sites, September 7, 1989.
For carcinogens, an excess upper bound individual lifetime cancer risk
was acceptable. For noncarcinogens, a Hazard Index less than or equal
of
Was the innovative technology eliminated because of the cleanup goals'.
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None " . . •
14. Were treatability studies conducted on the innovative technology or standard
Treatability studies were conducted on biological treatment and
showed that remedial levels could be achieved.
-5-
between 10"4 to 10'6
to 1.0 was acceptable.

Could the standard
technology?

solvent-extraction. Results
95
5
-------
15.
Although no treatability studies were conducted on thermal stripping at the site, treatability
studies conducted at similar sites showed that remedial goals for benzene could be achieved.
Additional treatability studies, however, might be needed to optimize the stripping process.
While no treatability studies were conducted on vapor extraction, treatability studies conducted
at similar sites in Florida and Pennsylvania showed that vapor extraction with catalytic
oxidation of the extracted vapors effectively reduce the mobility, toxicity, and volume of
contaminants in mixed clay and sand soils such as those at the site.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Impact on nearby populations
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared?

The preference for treatment of contaminants, along with the desire to leave wastes in place to
reduce fugitive air emissions during excavation, were the major measures used to distinguish
between alternatives. Vapor extraction with catalytic oxidation (RAA-9) was the only
alternative that would allow for treatment without excavation.
17. Wftat technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Shallow gravels at the site ruled out the use of sheet pile walls for containment. Clay soils at
the site reduced the potential efficiency of biodegradation and soil washing.
956
-6-
-------
Prewitt Abandoned Refinery

Prewitt, New Mexico
Region 6
GENERAL SITE INFORMATION
1.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
V
Maximum concentrations of principal
contaminants were:

Surface Soil (mg/kg)

Asbestos above background
Benzo(a)anthracene 265
Lead 129^000
Benzo(a)pyrene 215
Benzo(b)fluoranthene 146
Benzo(k)fluoranthene 146
Chrysene 220

Separator Sludge and Waste Pit Soil
(mg/kg)
Ethylbenzene
Benzene
4.2
0.23
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
8/30/90
2/92
9/30/92
Background

PRP-lead |
PRPs: Atlantic Ridhfield Company, El
Paso Naturajl Gas Company
FS prepared by: Mprriiion Knudsen
Corporation!
2.
What volume of material is to be remediated? ' \,
' ' ' I' '. ' - '

Hie volume of material to be remediated included: ;. ^
" •[->'-.

• 15 cubic yards of asbestos contaminated material !
• i.SOO cubic yards,of PAH contaminated soil
• 665 cubic yards of lead contaminated soil
• 80 cubic yards of separator sludge, contaminated waste pit soil jandl soil under the
separator . ' . ' . i
3. What type of site is this?
-i-
957
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: . .
Soil - Lead

Access restriction: •
Containment:
Chemical/physical:
Chemical treatment:
Physical treatment:
Disposal:

Soil • Asbestos

Access restriction:
Containment:

Chemical treatment:
Disposal:

Soil - Hydrocarbons

Access restriction:
Containment:
Physical/chemical: ,
Disposal:

Waste Pits

Access restriction:
Containment:
Chemical/physical:
Disposal:

Separator Sludge

Access restriction:
Containment:
Physical/chemical:
Thermal treatment:
Disposal:
Deed restrictions, fencing
Capping (clay, soil, synthetic membrane, chemical sealants)
Stabilization (ex situ, in situ)
Soil stabilization
Drainage control
Excavation, RCRA landfill
Deed restrictions, fencing
Capping (soil, clay, synthetic membrane, chemical sealants), drainage
controls
Soil stabilization
Excavation, permitted landfill
Deed restrictions, fencing
Capping (soil), drainage control
Stabilization
Off-site industrial landfill
Deed restrictions, fencing
Capping (soil), drainage controls
Stabilization
Excavation,, off-site landfill
Deed restrictions, fencing
Capping (concrete) ,
Stabilization
Incineration ••
Excavation, RCRA permitted landfill
958
-2-
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Soil-Lead "

Chemical treatment: Soil washing

Soil - Hydrocarbons

Biological treatment: Landfarming, thin spreading

Waste Pits

Biological treatment: Landfarming, thin spreading

Separator Sludge .

Biolbgical treatment: Landfarming
Chemical treatment: Solvent extraction

6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, /ifter the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on nine criteria established by
theNCP: long-term effectiveness and permanence; short-term effectiveness1; compliance with
ARARs; protectiveness of human health and the environment; reduction in contaminant
mobility, toxicity, or volume; implementability; cost; state/support agency acceptance; and '
community acceptance. In this case, some alternatives were eliminated in the detailed analyses
and reintroduced in the ROD. Information presented parenthetically refers to the ROD.

Cost Estimates for RAAs That Include Innovative Technjologies
(selected remedial alternative is in bold)

' Soil with;Hydrocarboris
Alternative
RAA-4I
(RAA-4E)
RAA-4J
(RAA-4F)
• ,
Innovative Technology
Excavation/landfarming
Excavation/thin spreading
Estimated Costs
3 Criteria
$1,286,300
$156,000
9 Criteria
eliminated
$1

56,000
ROD
$1,286,300
$156,000

-3-
959
-------
Waste Pits
Alternative
RAA-3D
(RAA-3C)
RAA-3E
(RAA-3D)
Innovative Technology
Excavation/landfarming
Excavation/thin spreading
t
Estimated Costs
3 Criteria
$1,142,400
$134,800
9 Criteria
eliminated
$134,000'
ROD
$1,142,400
$134,000
* Represents cost without a bottom liner, which could increase cost substantially.

Separator Sludge . .
Alternative
(RAA-5B)
Innovative Technology
Excavation/off-site treatment
and disposal/landfarming, soil
washing, or off-site
incineration if soil under
separator is contaminated
Estimated Costs
.3 Criteria
not
proposed
9 Criteria
not
proposed
ROD
$116,000
7. How did the cost(s) compare to standard technologies? ;

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

All Soils
Alternative
RAA-4A
Standard Technology
No action
Estimated Costs
3 Criteria
$0
9 Criteria
$0
Soil with Lead
Alternative
RAA-4B
RAA-4C
(RAA-4B)
Standard Technology
Use and access restrictions/soil cap
Excavate soil with lead/off-site
disposal in RCRA landfill
Estimated Costs
3 Criteria
$224,900
$1,605,000
9 Criteria
eliminated
, $1,605,000
960
-4-
-------
Alternative
RAA-4D
\ • •
Standard Technology
Use restrictions/in situ stabilization/soil
cover
Estimated Costs
3 Criteria
$415,200
9 Criteria
eliminated
Soil with Asbestos
Alternative
RAA-4E
RAA-4F
(RAA-4C)
Standard Technology
Use and access restrictions/soil cap
Excavate soil with asbestos/off-site
disposal in industrial facility
Estimated Costs
3 Criteria
$44,200
$9,300
9 Criteria
eliminated
$9,300
Soil with Hydrocarbons
Alternative
RAA-4G
RAA-4H
(RAA-4D)
Standard Technology
Use and access restrictions/soil cap
Excavate soil with hydrocarbons/off-site
disposal in industrial landfill
Estimated Costs
3 Criteria
$174,600
$681,300
i .
9 Criteria
eliminated
$681,300
Waste Pits
Alternative
RAA-3A
RAA-3B
RAA-3C
RAA-3F
(RAA-3E)
Standard Technology
No action
Soil cap
Excavation/off-site disposal at industrial
landfill
In situ stabilization/soil cover
Estimated Costs
3 Criteria
. $0
$27,300
$544,600
$83,400
"' '
9 Criteria
$0
. $27,300
eliminated
$83,400
-5-
961
-------
Separator Sludge
Alternative
RAA-5A
RAA-5B
Standard Technology
No action/use restrictions/fencing/
monitoring
Excavation/off-site disposal in RCRA
facility
Estimated Costs
3 Criteria
$7,200
$116,000.
r
9 Criteria
$7,200
$116,000. ,
8. If a standard technology was chosen, why?
: - '• • '
Soils with Lead and Asbestos

A standard technology was chosen to remove source contaminants completely and permanently
by excavating and disposing of soils off site. This remedy is permanent and effective in the
long term. It will completely eliminate any exposure to lead and asbestos by permanently
remediating these contaminants to cleanup levels.

9. If an innovative technology was chosen, why? *

Soil with Hydrocarbons, Waste Pits, Separator Sludge, and Potentially Soil Below the
Separator

An innovative technology was chosen for the remediation of waste pit soil, soil containing
hydrocarbons, separator sludge, and soil below the separator, if found to be contaminated.
This technology was chosen because it will reduce the concentrations of waste to remediation
levels. This is particularly important since this area is expected to be used for residential
purposes in the future. The technology was preferred because it will eliminate contaminants
thereby reducing their toxicity, volume and mobility. This reduction in contaminants will be
permanent and therefore effective in the long term. It was considered superior to containment
options as long-term maintenance will not be required to ensure its success. Landfarming also
was a reliable option. A treatability study was conducted that determined that this technology
could remediate 90 percent of the contaminants following the addition of nutrients and water,
thereby complying with cleanup levels.
10.
962
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ,

Innovative technologies eliminated during the initial screening include the following:

• Soil washing of soil contaminated with lead was eliminated because there was not a
large enough volume of soil.

-6-
-------
Innovative technologies eliminated during the screening of the three criteria include the
following:

• Landfarming for the waste pits and the soil with hydrocarbons was eliminated because
it would achieve no greater protection than thin spreading but would be more costly.
• Solvent extraction was eliminated because of its extremely high cost.

Innovative technologies eliminated during the detailed analysis include the following:

• Thin spreading was eliminated because instability studies showed that it would not'
successfully remediate site soils. Moreover, this technology might not meet RCRA
regulations to ensure the degradation of contaminants in the treatment zone prior to
their transport into ground water. i
11.
12.
Which of the nine criteria were weighted most heavily in selecting the1 technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

For all media, the criteria most heavily weighted in selecting a remedial technology were long-
term effectiveness and permanence. These criteria ensure the greatest protection to health and
the environment.
p "
In the FS, landfarming was initially eliminated because it would not bik as cost-effective as
thin spreading. When thin spreading was shown to be ineffective for Ithe iremediation of the
site s waste, landfarming was selected instead.

Solvent extraction was eliminated due to excessive cost.
W£re selected? If the cleanup goal was based on lan AFAR, what was that
What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm)
ARAB: or Other Basis
Carcinogens
Asbestos
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(a)fluoranthene
Benzo(k)fluoranthene
Chrysene
Lead
Lead
Remove all
9
0.9
0.9
0.9
90
500 .
1000
Background
Risk8*
Risk8
Risk8*
Risk8*
Risk8*
£>SWERC
OSWER"
-7-
963
-------
'Health-based risk levels correspond to an excess upper bound individual lifetime
cancer risk of 10"*. The health based risk estimates were developed by EPA Region 6.
bSince these contaminants have no slope factors, their cleanup levels are based on the
contaminants' relative potency to benzo(a)pyrene.
•EPA Office of Solid Waste and Emergency Responses Directive #9355.4-02 for soil
up to 2 feet in depth.
dEPA Office of Solid Waste and Emergency Responses Directive #9355.4-02 for soil
below 2 feet in depth.

t
13. 'Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• Thin spreading

Standard technologies eliminated because of cleanup goals include:

• Stabilization

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted to study the effectiveness of landfarming and thin •''IIP "*i
spreading for waste pit soil and hydrocarbon soil. It was determined that landfarming could "™ ;J
reduce site contaminants by 90 percent with the addition of nutrients and moisture and meet
cleanup levels. Thin spreading was shown to be ineffective for the site's waste because while
waste biodegraded rapidly initially, additional nutrients and moisture needed to be added to
complete the process. The addition of nutrients and water are not included in the thin
spreading technique. :

75. Wliat measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability
Impact on future populations

16. How are measures compared? . •
i '- -- • ' v •
Because the area is expected to be used for future residency, it was important to permanently
reduce contaminant levels for the safety of future populations. The reliability of remedies,
based on results of the treatability studies, was •also a concern. In this case, landfarming was
shown to be effective and thin spreading ineffective. Furthermore, stabilization had uncertain
reliability and effectiveness over the long term and was eliminated for these reasons.
964
-8-
-------
17.
What technical considerations were factors in selecting a remedy? VVere technical
considerations primary in the selection of the remedy? i

Analyses of composite waste samples determined that they were deficient in nitrogen and
phosphorous. Therefore, for biodegradation to occur, nutrients and water had to be added to
the waste. While thin spreading was initially proposed in the PS, it was later rejected in favor
of landfarrmng, which does not require the addition of nutrients and water
-9-
965
-------
29th and Mead Ground Water Contamination
GU-2 -.-'..•

Wichita, Kansas
Region 7
GENERAL SITE INFORMATION
1.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Trichloroethene 13
1,1,1-Trichloroethane 6.1
Tetrachloroethene 0.041
cis-l,2-Dichloroethene 0.52
1,1-Dichloroethene , 0.37
Toluene 140
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A '
2/21/90
7/2/92
9/29/92
Background

PRP-lead
PRPs: The Coleman Company and
Evcon Industries
FS prepared by: Groundwater
Technology, Inc.
What volume, of material is to be
remediated?

The volume of material to be remediated included:

• 453,000 cubic yards of soil
3. What type of site is this?

Fabricated Metal Products. The site is an industrial area occupied by two furnace and air
conditioning systems manufacturing plants and an administration and engineering building.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard'technologies considered during the identification and screening of technically feasible
technologies were: , '

Containment: Capping (low permeability, asphalt, cpncrete, synthetic liner, :
multilayered) ,
Chemical treatment: Fixation/stabilization
Disposal: " Excavation
I')
966
-1-
-------
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: :

Biological treatment: Biodegradation
Physical treatment: Soil vapor extraction (SVE) ' !
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) '
Alternative
RAA-2A
RAA-2C
RAA-3A
RAA-3B
RAA-3C
RAA-4A
RAA-4B
Innovative Technology
No further action/continued operation of
soil vapor extraction system
No further action/continued operation of
soil vapor extraction system/continue
ground water recovery/add another
recovery well
Expand soil vapor extraction system/
continue ground water pump and treat
Expand soil vapor extraction system/
south-end* enhancement of ground
water recovery system
Continue soil vapor extraction system/
enhance south-end ground water
recovery system
Expand soil vapor extraction system/
continue ground water pump and
treat/aquifer sparging
Expand soil vapor extraction system/ .
enhance south-end ground water
recovery system/aquifer sparging
Estimated Costs
3 Criteria
N/A
N/A
• • " i [•'
.1
N/A /
; N/A
•
N/A '
N/A
j
' N/A
' I •
'
9 Criteria
$772,164
$972,334
$1,450,513
$1,638,456
$2,042,339
$1,746,227
$1,799,523
-2-
967
-------
Alternative
RAA-4C
Innovative Technology
Expand soil vapor extraction system/
expand ground water recovery
system/additional south-end ground
water pump and treat/aquifer sparging •
Estimated Costs
3 Criteria
N/A .,
9 Criteria
$1,711,410
*In the southern boundary area.
7. How did the cost(s) compare to standard technologies?
* '
Cost Estimates for KAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2B
RAA-2D
Standard Technology
No action
No further action/continued ground
water pump and treat
No further action/continue ground water
recovery/additional south-end
enhancement of ground water system
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$623,310
$802,953
$983,131
D
8. If a standard technology was chosen, why?

A standard technology was not selected.
9. If an innovative technology was chosen, why?

RAA-3B was selected because it provides adequate protection of human health and the
environment by removing contaminants in the soil and ground water and thus eliminating the
risk posed by those contaminants. Overall concentrations of VOCs will decrease over time
with implementation of the preferred alternative. This alternative provides long-term
effectiveness and permanence by significantly reducing the volume and mobility of VOCs in
the soils through soil vapor extraction (SVE) and preventing future migration of VOC
contaminants into ground water. Enhanced ground water recovery assures hydraulic control,
providing permanent control of the migration of VOC contaminants. The preferred alternative
reduces soil and ground water contaminants through treatment and recovery (volume); controls
the migration of contaminants from the site by providing hydraulic controls, which prevent
contaminated ground water from escaping from the property (mobility); and provides for
treatment of contaminated ground water and soil to acceptable levels determined by EPA and
the Kansas Department of Health and the Environment (toxicity). The selected alternative
promotes the utilization of a treatment for both soil and ground water. Reducing VOC
968
-3-
-------
contaminants in soil (volume and mobility) greatly increases the overall effectiveness of
cleanup and decreases the time needed for cleanup. It was estimated that the preferred
alternative will accomplish cleanup within 10 to 20 years. The known effectiveness of SVE
supported the expansion of this technology in the chosen alternative. Pilot studies conducted
on SVE at the site demonstrated the implementability of this technology and the existing SVE
has been documented to remove 14,323 pounds of VOC contaminants in less than 5 years
This alternative might, however, pose technical difficulties given the Ideations of source areas
in relation to on-site buildings and operations. When considering the rapid and dramatic
reduction in soil and ground water contaminants provided by the inclusion! of one additional
ground water extraction well and the enhanced SVE system, the cost of this alternative is not
prohibitive when compared to the costs of implementing other alternatives. In addition the *
preferred alternative prevents further ground water contamination and migration of
contaminants for a relatively low increase in cost over less effective remedies. The selected '
remedy is cost effective because it provides the best balance among the evaluation criteria It
provides a higher degree of overall protection man the less costly alternatives because it treats
all known source areas and prevents the migration of contaminated ground water from the
area, ; • ' ,. . • . ... . .. ' . • • I • • .
10.
If an innovative technology was not chosen, why not? At what stage -was the innovative
technology eliminated? \.

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the ttiree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

" Biodegradation was eliminated because it is not well established for the remediation of
chlorinated aliphatic compounds. In addition, implementation of the technology
beneath building structures might be impractical and the process is already naturally
occurring. I . •

Innovative technologies eliminated during the screening of the three criteria include the
toilqwing:
" • ! • '
* None I
'. - ' ' - - • • -i'- ' . \ if • .

Innovative technologies eliminated during the detailed analysis include the following:

• ' None, - '•'•'' ' ' ' ' ' ''( . . . - :•
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology? '

The most heavily weighted criteria in selecting this remedial alternative were protection of
human health and the environment; the reduction of site,contaminant toxicity, volume and
mobility; and long-term effectiveness and permanence. The chosen alternative actively
-4-
969
-------
addresses contaminants in both the soil and ground water, thereby providing a very effective
and permanent elimination of site risks. _
72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
1 '
No source control cleanup goals were developed for this site. .

No specific ARARs exist for .contaminated soil. Performance criteria for the expanded SVE
system, however, will be developed during remedial design. Performance standards will be
based on monitoring data from the performance of the existing SVE system. This will both
allow for the development of the criteria for the expanded SVE system and will determine
when operation of the existing system may be discontinued.

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
tecttnology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None .
i '
14. Were treatability studies conducted on the innovative technology or standard technology?

A treatability study was conducted to investigate soil vapor extraction. This test revealed that
SVE will remove contaminants from site soils.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk reduction •
Cost-effectiveness
Time to design/construct/operate
Proven reliability
76. How are measures compared? '.'••'

The chosen alternative was preferred because it reduces site risk by eliminating the source of
ground water contamination from the soil. The treatment proposed in this alternative will meet
cleanup requirements within a moderate amount of time (10 to 20 years) because df the
addition of SVE systems and ground water treatment. Alternatives that would accomplish
cleanup in a slightly shorter time were more expensive and therefore not considered cost
970
-5-
-------
effective. The reliability of the SVE technology also supported the choice of SVE as an
appropriate technology. On-site SVE pilot studies have conclusively sho'ivn the effectiveness
of SVE on the soil contamination. The existing SVE has been documented to have removed
14,323 pounds of VOC contaminants in less than 5 years. ^ i .
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
- • . ' -I- '

No technical considerations were primary in selecting a remedial alternative.
.6- 971
-------
E.I. Dupont De Nemours & Co.
(County Road X23)

West Point, Iowa
Region 7
8,1,
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

Lead
Selenium
Cadmium
38,950
177
510
2. What volume of material is to be remediated?

The volume of material to be remediated
included:

* 14,200 cubic yards of soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
9/90
1/16/91
5/28/91
Background --

PRP-lead
PRPs: E.I. Dupont De Nemours
FS prepared by: Woodward-Clyde
Consultants
3. What type of site is this?

Chemicals and Allied Products. A paint waste disposal site.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ;

Access restriction: Fencing, deed restrictions
Containment: Cap (soil, clay, soil/synthetic membrane, asphalt, concrete, multilayer),
revegetation, slurry wall, grout curtain, sheet piling, vibrating beam, grout
injection
Chemical treatment: Stabilization/solidification
Thermal treatment: Incineration (rotary kiln, fluidized bed, multiple hearth, circulating bed,
plasma arc torch, high temperature wall reactor, and infrared)
Disposal: Excavation, off-site RCRA landfill, on-site landfill, on-site waste piles
972
-i-
-------

Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically feasible
technologies were: •
Biological treatment:
Chemical treatment:
Thermal treatment:
In situ aerobic biodegradation, anaerobic biode^adation, white rot fungus
Soil washing (solvent), soil vapor extraction, liquid gas extraction,
dehydrochlorination, dehalogenation, electronjemforane reactor process
(chelation) ,
In situ vitrification, heated air stripping, low temperature thermal
treatment, wet air oxidation '.''',.' , ,•
6. What was the cost estimate-for the innovative technology? i

During the initial screening process, in which technically feasible technologies are identified (prior
to :the formulation of RAAs), the FS does not quantify costs. After"the RAAs have been
formulated, costs are usually estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. In this
case, the estimated costs were calculated during an evaluation based on nine criteria established
by the NCP: long-term effectiveness and permanence; short-term effectiveness; compliance with
ARARs; protectiveness of human health and the environment; reduction in contaminant mobility,
toxicity, or volume; implementability; cost; state/support agency acceptance; and community
acceptance. The RAAs discussed in the ROD are presented parenthetically under the list of
alternatives. j
.' - , • ! ' '• '
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-E2
RAA-E3
RAA-E4
1. ' , - :• '
Innovative Technology
Excavation/aerobic biodegradation/
soil washing
Excavation/heated air stripping/soil
washing
Excavation/soil washing
Estimated Costs
3 Criteria
N/A
'.:N/A
- j .
" N/A '"•
9 Criteria
eliminated
eliminated
eliminated
-2-
973
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-A
(RAA-1)
RAA-B
(RAA-2)
RAA-C1
(RAA-3)
RAA-C2
RAA-C3
(RAA-4)
RAA-Dla
(RAA-5)
RAA-Dlb
(RAA-6)
RAA-D2 '
RAA-E1
(RAA-7)

Standard Technology
» :
No action
Fencing/deed restrictions/periodic .
monitoring •
Fencing/deed restrictions/periodic
monitoring/clay and soil, cap
Fencing/deed restrictions/periodic
monitoring/asphalt cap
Fencing/deed restrictions/periodic
monitoring/multimedia cap
Excavation/off-site disposal at RCRA
landfill
Excavation/on-site or off-site
treatment/off-site disposal at RCRA
landfill
Excavation/off-site incineration at
RCRA facility
Excavation/on-site stabilization and
fixation
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$0
eliminated
$1,800,000
eliminated
•'"•%!- ' .
$2,000,000
$8,000,000
$10,700,000
{
•eliminated
$1,200,000
8. If a standard technology was chosen, why?

Excavation with on site stabilization and fixation was selected because: 1) long term risks
associated with direct contact and migration would be eliminated since contaminants bond to
solidified matrix and there would be a reduction in surface area exposed to ground water and
surface water, 2) proven and reliable technology^ 3) cost, 4) preference for treatment, 5) easier
to implement administratively because it requires less coordination with relevant agencies, 6)
can be implemented quickly, and technically easy to implement. .
974
-3-
-------
9. If an innovative technology was chosen, why? ;

An innovative technology was not chosen. ;

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '[•''-
' • - . ' ' j ..---.•. (• • :
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evalujition.
1 . • '•
Innovative technologies eliminated during the initial screening include the following:

• Soil vapor extraction was eliminated because it would be ineffective due to the site
soil's low porosity. • . .
• Liquid gas extraction was eliminated because the technology has not been proved
effective.
• Dehydrochlorination was eliminated because it would not be applicable to site
contaminants. . -j
• Dehalogenation was eliminated because it would not be applicable! to site
contaminants. ,
• White rot fungus was eliminated because the technology has not been proved effective.
• Electromembrane reactor process was eliminated because the technology has not been
proved effective.
• Wet air oxidation was eliminated because the technology has mot teen proved
effective.
• In situ vitrification was eliminated because the technology has not been proved
effective, j
• Anaerobic biodegradation was eliminated because it is more effective in degrading
halogenated compounds and less proven on other compounds, and it is less reliable
than aerobic methods. ."'!'•'
• Low temperature thermal treatment was eliminated because it does not treat metals;
• Centrifugal reactor was eliminated because it is an unproven technology.
• High temperature slagging was eliminated because there is no fuel value to soils.
• Pyrolysis was eliminated because there is no fuel value to the soils.
• Vitrification was eliminated because it is an unproven technology.
' h
Innovative technologies eliminated during the screening of the three criteria include the
following:

• In situ aerobic biodegradation with soil washing was eliminated because its
effectiveness in removal of target compounds is questionable; treatability testing would
be required; implementing combination of treatment technologies is questionable; soil
washing is unproven; treatment may not meet Land Disposal Regulations; high capital
and operation and maintenance costs. '
" Heated air stripping with soil washing was eliminated because its iimplementability is
questionable; treatability studies would be necessary; leachate treatment and/or disposal
would be necessary; may not meet Land Disposal Restrictions; ijiigh capital costs of
operation and. maintenance.
• Soil washing was eliminated because it is not a proven technology for removing metals

. '' '. , • ' -4- , 'I . ' ' • '" '
975
-------
11.
12.
13.
at high enough efficiency to adequately lower metals concentrations; implementability
is questionable; treatability studies would be required; Land Disposal Regulations may
not be met; high capital and operation and maintenance costs.

Innovative technologies eliminated during the detailed analysis include the following:

• None ,

The most heavily weighted criteria in selecting a standard technology were protectiveness of
human health and the environment, long-term effectiveness, implementability and cost. No
innovative technologies were retained for detailed analysis.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Lead
Cadmium
350
20
EPA Advisory"
Risk
Noncarcinogens
Selenium
10
Risk
*A health-based cleanup level for lead was determined by utilizing an equation that
back calculates soil lead levels given a specific target blood lead level. A target blood
lead level of 8 ug/dL was selected because it is below the EPA advisory range of 10
to 15 ug/dL for warranting concern.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• Soil washing

Standard technologies eliminated because of cleanup goals include:
•' '." *
» None
976
-5-
-------
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75.
What measures/criteria were used to compare alternatives ?

The following measures were used to compare the alternatives:

Cost-effectiveness
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared? . ]

Two alternatives (RAA-E1 and RAA-Dlb) provided the greatest protection to human health
and the environment. Of these two alternatives, RAA-E1 was chosen because it is less
expensive and therefore the more cost-effective alternative. Other .proposed alternatives (RAA-
Dl, RAA-D2) were eliminated because their high costs were not paralleled by a proportional
increase in protectiveness. Proven reliability was another principal factor in the selection of a
remedy. The selected alternative was considered to be a reliable treatment Conversely
technologies such as aerobic biodegradation and soil washing were eliimnated because their
reliability was not proved for the site's contaminants. The selected alternzitive employs a
treatment technology. Several other alternatives were eliminated because lihey would not
ensure long-term protection through treatment of the source.
17.
What technical considerations were factors in selecting a remedy?
considerations primary in the selection of the remedy?
Wt re technical
The low porosity of site soils was a technical consideration in the „
extraction, an innovative technology. No technical considerations were
selection of a remedy.
elimination
-6-
of soil vapor
primary in the
977
-------
Ellisville Site
(Amendment for Bliss portion of site)

Ellisville, Missouri
Region 7
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

2,3,7,8-Tetrachlorordibenzo-p-dioxin 0.087
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

» 7,000 cubic yards of soil
3. What type of site is this? .

Waste Oil. A former waste oil disposal site.
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
10/81
7/26/91
9/30/91
Background

EPA Fund-lead
PRPs: Syntex, Northeast Pharmaceutical
and Chemical Company, Indepen-
dent Petrochemical Corporation
FS prepared by: CH2M Hill
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restrictions, warning posts, fencing
Containment: Soil cover, clay cap, synthetic membrane cap, clay geomembrane cap,
revegetation, regrading ,
Physical Treatment: Quicklime, ultraviolet photolysis
Thermal treatment: Rotary kiln incinerator, infrared incinerator, fluidized bed incinerator*
multiple hearth incinerator
Disposal: • Excavation, on-site storage, off-site storage
978
-i-
-------
6.
7.
, ' I' - '
Way an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screenim' of technically
feasible technologies were: 1 ,

Biological treatment: Biodegradation - |
Chemical treatment: APEG dechlorination, solvent washing ;|
Thermal treatment: Molten salt, supercritical water oxidation, in situ vitrification, steam
stripping, microwave volatilization, plasma pyrolysis, wet air oxidation
• ' ' " ' / • "! • >

What was the cost estimate for the innovative technology? |.

During the initial screening process, in which technically feasible technologies are identified
(pnor to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated during an evaluation based on nine criteria, established by the
.' NCP and again in the ROD: long-ierm effectiveness and permanence;1 short-term
effectiveness; compliance with ARARs; protectiveness of human health anid the environment-
reduction in contaminant mobility, toxicity, or volume; implementabiliiy; cost; state/support '
agency acceptance; and cpmmunity acceptance). '
' • • " •"* i- ••.';'
No innovative technologies were proposed for remedial alternatives.

How did the' cost(s) compare to standard technologies? !
• - , • " _ • • ' • i " - •. •
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
,\
RAA-4
.
Standard Technology
No action/fence maintenance/long-term
air monitoring
Improve vegetative cover/erosion
control .
Excavation/backfill and revegetate
site/on-site storage/fence/long-term
monitoring
Excavation/rotary kiln incineration/
ash disposal as appropriate, possibly
at RCRA facility
Estimated Costs
9 Criteria
$0
$1,130,000
$13,70p,OCK)
$17,53li),000
ROD
$0
$1,130,000
$13,700,000
$17,530,000
8. If a standard technology was chosen, why?
• . , ' ' -! . ! ' ^

RAA-4 was selected because thermal treatment is the only demonstrated technology with
proven effectiveness at destroying dioxin on a full scale. RAA-1 was eliminated because it
-2-
979
-------
would not be protective of human health and the environment. Although RAA-2 and RAA-3
are less costly than the selected remedy, they would only reduce mobility and would provide a
low degree of permanence because contaminants are not destroyed and continual maintenance
of containment systems would be required.

9. If an innovative technology was chosen, why?
i
An innovative technology was not chosen. , • I

--''-. i"'"
, . . ' i-
10. If an innovative technology was not chosen, why not? At what stage was the innovative j
technology eliminated? ' , ,

Innovative technologies could be eliminated, from the remedial technology selection process at j
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. . |

Innovative technologies eliminated .during the initial screening include the following:
* . • > • , • . >
•
• Molten salt was eliminated because the technology has not been proven effective for
dioxin, nor has it been developed for full-scale application.
• Supercritical water oxidation was eliminated because the technology has not been
demonstrated on a scale sufficient to treat the volume of contaminated soil at this site. ^.^
• In situ vitrification was eliminated because it would not be feasible for surface soil ||l|^ "\
contamination. , . : • *^, ^
» Dechlorination was eliminated because it has not been developed for full-scale use.
• Biodegradation was eliminated because it has not been proven effective for materials
• with low concentrations of contamination.-
• Microwave volatilization was eliminated because it has not been proven effective for
dioxin wastes.
• Steam strippingwas eliminated because"it would not be effective for dioxin waste. j
• Solvent washing was eliminated because it would not be feasible for such a large
quantity of soil. . j'
• Plasma pyrolysis was eliminated because it is not applicable to soils.. !
• Wet air oxidation, although considered a feasible technology, was not carried forward
from the initial screening into a remedial action alternative. No reason for excluding |
wet air oxidation was given.

No innovative technologies were eliminated during the three-criteria screening or during f
detailed analysis. ; ,

II. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The protectiveness of human health and the environment and long-term effectiveness through a
permanent solution were the most heavily weighted criteria in selecting a standard technology.
No innovative technologies were evaluated in the nine-criteria, evaluation. .

980
-------
12.
13.
14:
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppb)
ARAR br Other Basis
Carcinogens
Dioxin
1
RCRA1'and ATSDR"
•Resource Conservation and Recovery Act Land Disposal Restrictions (40 CFR
268.41). , , . • . •
"Agency for Toxic Substances and Disease Registry health consultation issued in 1986.

For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to W*
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.

Was the innovative technology eliminated because of the cleanup goals? If a standard
technology was selected, could it meet the cleanup goals? ]

Innovative technologies were eliminated because they were determined not to be feasible for
dioxm-contaming soils or had unproven effectiveness. They were not eliminated because of
the cleanup goals at the site. The standard technology selected, incineration, could meet
cleanup goals for the site. h
Were treatability studies conducted on the innovative technology or staridard technology?

Nb.treatability studies were conducted. ,
15.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability
Permanence
Cost effectiveness
16. How are alternatives compared? '' • • i

Most innovative and standard technologies were eliminated in the initial 'screening based on a
lack of proven reliability for treating dioxins in soils to required levels. The RAAs were
compared primarily on the basis of permanence. Capping and on-site storage would not
destroy dioxins and would be dependent on continued maintenance to prevent future releases
Even though the selected alternative, incineration, was the most costly remedy it was
considered more cost-effective because it provides a permanent remedy for the dioxin
contaminants destroyed. - !
-4-
981
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

The site lies in a relatively flat valley that is a groundwater recharge area. However, dioxin
was not found to be bound tightly in surface soils and was not contaminating groundwater.
Land use in the vicinity is a mixture of residential, rural, and recreational. Although
increasing residential development in nearby areas may have contributed to the emphasis oh a
permanent remedy, technical considerations do not appear to be primary in the selection of the
remedy at this site. ' .
982
-5-
-------
Containment:

Thermal treatment:
Disposal:
Capping (RCRA Subtitle C landfill cap, Nebraska sanitary landfill cap)
grading, revegetation ;
Incineration (on site, off site)
Excavation, RCRA landfill disposal (on site,! off site)
Was an innovative technology considered in the FS? If so, which technology?
- - - . j •
Innovative technologies considered during the identification and screening of technically "
feasible technologies were:
I • '»!*•• ' '

Biological treatment: In situ bioremediation i
Physical treatment: Soil vapor extraction
6.
7.
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) '
Alternative
RAA-5
Innovative Technology
Soil vapor extraction (SVE)
Estimated Costs
3 Criteria
N/A
9 Criteria
$1,095,000
How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3A
Standard Technology
No action
Access restrictions/ground water
monitoring
Access restrictions/ground water
recovery/air stripping/reinjection
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$0
$557,000
$2,013,000
984
-2-
-------
Alternative
RAA-3B
RAA-3C
RAA-3D
RAA-4A
RAA-4B
RAA-4C
RAA-4D

Standard Technology
Access restrictions/ground water
recovery/air stripping/reuse
Access restrictions/ground water
recovery/UV oxidation/reinjection
Access restrictions/ground water
recovery/UV oxidation/reuse
Access restrictions/ground water
recovery/air stripping/reinfection/
Nebraska sanitary cap
Access restrictions/ground water
recovery/air stripping/reuse/Nebraska
sanitary cap
Access restrictions/ground water
recovery/UV oxidation/reinjection/
Nebraska sanitary cap
Access restrictions/ground water
recovery/UV oxidation/reuse/ Nebraska
sanitary cap
Estimated Costs
3 Criteria
N/A
s N/A
N/A
N/A
N/A
/•• .
N/A
N/A ..
9 Criteria
$2,394,000
$3,666,000
$3,954,000
$3,006,000
$3,364,000
$4,635,000
$4,924,000
8. Jf a standard technology was chosen, why?

The exact designation of the selected alternative is never specified but it appears to be one of
the RAA-4 alternatives. The selected.alternative includes improving the existing cap as
necessary and in accordance with the Nebraska Solid Waste Management Rules (NDEC Title
132, Chapter 6) which appears to be equivalent to a Nebraska sanitary landfill cap as proposed
in RAA-4. Further, the technology for ground water treatment, while still undecided, will
consist of either UV .oxidation or air stripping, and the treated water will be either reinjected
or reused. Thus, the existing cap will be evaluated and improved as necessary. The improved
cap provides containment and minimizes infiltration through the. landfill to ground water which
will decrease the volume of contaminants. Additionally, the surface will be revegetated to
decrease erosion, and access restrictions will be implemented to maintain cap integrity. The
selected remedy will be protective of human health and the environment because the interim
actions reduce contaminant concentrations in the aquifer to levels at or below 10"4 cancer risk.
In addition, the interim actions will stabilize the migration of ground water contaminants and
prevent further degradation of the ground water through the rapid mass removal and hydraulic
plume control. Thus, the threat to private well users and the exposure from irrigation wells
will be abated. This alternative meets appropriate ARARs, is easily implementable, and is cost
effective. '• : -,

The SVE component provided for in the June 1991 Proposed Plan will not be.implemented at
this time because upon reevaluation of the site, EPA determined that insufficient information
regarding the amount of contamination in the vadose zone was available and therefore the high
-3-
985
-------
cost of SVE could not be justified. Monitoring of the vadose zone wijl be conducted during
the implementation of the interim action and EPA will reevaluate the infoirmation gained to
determine the need for SVE as an additional source control measure.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10.
11.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tliree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:
* I . •

• In situ bioremediation was eliminated because the primary conliaminants of concern are
chlorinated organics, which have a slower biodegradation rate than non-chlorinated
organics and therefore would have an increased remediation time. Furthermore,
chlorinated organics might degrade into more toxic breakdown products.

Innovative technologies eliminated during the screening of the three criteria include the
following: , j.
••.-'• • ' I •• ' :
• None - •-..-,.. " •" •' ,| ''..-'•• - .

Innovative technologies eliminated during the detailed analysis include the following:

« Soil vapor extraction was eliminated because there was insufficient information
available concerning me amount of contamination present in the vadose zone and
therefore it was not possible to justify the cost of SVE.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and cost were the criteria weighted most
heavily in selecting a remedial alternative. The selected alternative addresses the main threat
to human health posed by ground water and reduces migration of source contaminants through;
containment. Since the concentration of contaminants of concern were ;tiot well established,
the high cost of soil treatment with the innovative technology, SVE, coiild not be justified.'

12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? i
\ ' ' ' - , | •'> i • _
Cleanup levels were not established.
986
-------
f
•\
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
tecltnology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None , '

Standard technologies eliminated because of cleanup goals include:

• None •-•..'

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. ,

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: ;

Risk level achieved

16. How are measures compared?

This ROD proposes an interim action; therefore, the action was aimed at achieving an
acceptable excess cancer risk. Since the degree of underlying contamination in, the vadose
zone was uncertain, source treatment was postponed until further information could be i
attained. The selected remedy reduces risk to an acceptable level and reduces migration of
contaminants from soil to ground water.

17. What technical considerations-were factors in selecting a remedy?. Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedial alternative.
-5-
987
-------
John Deere & Company
Qttumwa Works Landfill

Ottumwa, Wapello County, Iowa
Region 7
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
i
Maximum concentrations of principal
contaminants were:

Soil and Waste Material (rag/kg)
Total carcinogenic PAHs
Total PAHs
Naphthalene
Arsenic
Beryllium
Lead
Aluminum
Zinc
Copper

Sediments (mg/kg)

Arsenic
Barium
Cadmium
Chromium
Nickel
19
84.5
1.2
26
3
810
7,500
860
- 24
0.64
8.7
1.2
'3.5
8.5
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
2/90
7/10/91
9/23/91
Background

PRP-lead
PRPs: John Deere & Company
FS prepared by: Geraghty & Miller,
Inc.
What volume of material is to be remediated?
I

• 670,000 cubic yards of contaminated soil, waste material, and sediments
3. What type of site is this?
''- ' .""I ' • '
: ' ' ' • - • ' •
Fabricated Metal Products. An active agricultural equipment manufacturing and assembly
facility. Land use in the area is predominantly residential with wetlands located within 1 000
feet of the site across the Des Moines River. All of the site lies within the 100-year, floodplain
or the Des Moines River.
988
-1-
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:

Containment: •
Institutional restrictions on land use and land access (deed restrictions),
fencing, environmental monitoring .
Capping (concrete, asphalt, solid waste cap, RCRA subtitle C cap),
grouting
Chemical treatment: In situ stabilization/solidification (kiln dust reagent, fly ash reagent,
silicate reagent, portland cement reagent, synthetic reagents)
Thermal treatment: Plasma arc incineration, on-site incineration (fluidized bed, rotary kiln)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Bioremediation (in situ, heap leaching)
Chemical treatment: Soil flushing (water solution, surfactant solution), chemical oxidation
Thermal treatment: In situ vitrification, soil vapor extraction s

6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is ira bold)
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Institutional controls/ground water
monitoring
Concrete cap/institutional controls
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$0
$103,600*
$2,667,900 >
-2-
989
-------
Alternative
RAA-4
Standard Technology
In situ stabilization/solidification/
concrete cap/institutional controls
'Estimated Costs
3 Criteria
N/A
9 Criteria
$26,470,100
The total present worth cost of implementing RAA-2 is estimated to be 354,000 in the ROD
because ground water monitoring is not included. The total present worth cost in the ROD is
based solely on the cost of lodging deed restrictions.
8. If a standard technology was chosen, why? -
. •''-.• 1'' • '
The RI shows that contaminant levels in all media are low enough to allow unlimited use of
the site and affected media with the exception of children exposed directly to the waste
material. The selected remedy, RAA-2, would be protective of human health by providing
institutional controls that require maintenance of the existing 8-foot high chainlink fence
topped with barbed wire; RAA-2 also requires lodging deed restrictions, which prevents the
development of residences or other future on-site exposures. These measures ensure that in
the long term children are not exposed to site waste, thereby preventing the only potentially
, unacceptable exposure scenario from occurring. In addition, short-term risk will not be
increased during implementation of the selected remedy because no construction activities are
required and an effective perimeter fence is" already in place. Finally, [the selected remedy is
cost-effective because its overall effectiveness is proportional to its cost, and it is the least
costly of remedies that were judged to provide equal protection of human health.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
I ,' - • • i .' -

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the tliiree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
i' .-*.. i - •» ' -
Innovative technologies eliminated during the initial screening include the following:

• In situ bioremediation was eliminated because it would be ineffective for inorganics
and it would be difficult to evenly distribute nutrients and inoculate microorganisms
throughout the fill material. In addition, in situ biological processeis are difficult to
control and nutrient additives might migrate to the, underlying siquiifer.and contaminate
ground water. .
• Bioremediation-heap leaching was eliminated because it would be ineffective for
inorganics, might create unpleasant odors, and requires the complete excavation of the
fill material, which could endanger human health and the environment.
990
-3-
-------
• In situ vitrification was eliminated because the heterogeneous nature of the fill material
might impede complete vitrification. Also, this technology is unproven for large-scale
applications and might not be readily available.
• Soil vapor extraction was eliminated because it would be ineffective for removing
inorganics and nonvolatile organics.
• Soil flushing (water solution and surfactant solution) was eliminated because of its
limited effectiveness in removing low solubility organics and inorganics, and the fill
material has not proved to be amenable to soil flushing.
• Chemical oxidation was eliminated because its effectiveness in treating inorganics is
limited, and the technology has not been proved for treating solid material.
i ' ' • ' • •
Innovative technologies eliminated during the screening of the three criteria include the
following: . "
' ' ' , • ' '•..
• None '

Innovative technologies eliminated during the detailed analysis include the following:

• None

The ROD states that the selected remedy RAA-2 represents the best balance of trade-offs
among the alternatives. RAA-2 was selected over other alternatives because of its cost and i
shbrt-term effectiveness. The selected remedy is the least costly of remedies that were judged
to provide equal protection of human health. The costs associated with RAA-3 and RAA-4
are considered by EPA to be excessive when compared with the marginal increase in ;
protectiveness these alternatives would offer compared to RAA-2. The selected remedy
provides a high degree of short-term effectiveness because no construction activities are ,
required. Risks associated with the present use of the site are not considered excessive and " '. •
will not be increased by implementation of this alternative. ,

, . . - - . • i -
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? .

Federal and State cleanup goals for the contaminants of concern were not established. '
-, • , ' ' _ , . ;„ c

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? • , .
'•
'
Innovative technologies eliminated because of cleanup goals include: ' |
. i . ' . ,]•-
• None
.4- . •" .' '. 991
-------
Standard technologies eliminated because of cleanup goals include:

• . None ' •' •' :-."•-. • '!. ..-''.-,., . - —
. • " "L .'• . - - ' •

14. W,ere treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. L

75. What measures/criteria were used to compare alternatives? [ .
'•--"' ' ,' 'f • .' . ' . ••'•..
The following measures were used to compare the alternatives: |

Cost effectiveness . ' .
Waste left in place/institutional control
>••.'•,-' ' - • '.. •• • }••.' .-. " ' '-•••••
i" ' ..
16. How are measures compared? [

The selected remedy is cost-effective because it provides overall effecitiveriess proportional to
its cost. The costs associated with RAA-3 and RAA-4 are considered by EPA to be excessive
when compared with the marginal increase in protectiveness these alternadves offer compared
to RAA-2. Data provided in the RI shows mat contaminant levels in all media are low, which
allows all but children unlimited use of the site. Results of the baseline risk assessment
indicate that site conditions do not require treatment of contaminated soil/waste if children do
not live on site or are not allowed similar exposure to the soil/waste material. Institutional
controls were considered adequate. ".•'•••
•!'• '

17. What technical considerations were factors in selecting a remedy? Were technical ,
considerations primary in the selection of the remedy? .. i.
• • •-,)'••-,
Technical considerations were not primary in selecting a remedy. Thu presence of an aquifer
underlying the site, however, was a factor. Biological treatment processes were eliminated
because of the potential migration of nutrients into the aquifer. The lieterogeneous nature of
the fill material resulted in the elimination of in situ vitrification.
992
-5-
-------
Lee Chemical

Liberty, Missouri
Region 7
GENERAL SITE INFORMATION
1.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were: ' '
Soil/Alluvial aquifer (mg/kg)

Trichloroethylehe (TCE)
1,1,1-Trichloroethane (TCA)
11
2
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
5/20/86
12/24/90
3/21/91
Background

PRP-lead
PRPs: City of Liberty
FS prepared by: Layne Geosciences,
Inc.
While the site soil is contaminated,,the FS
and ROD consider the soil and the alluvial
aquifer as a single medium throughout the
screening process and definition of process
options due to their close hydrogeologic
relationship.
2. What volume of material is to be remediated? .

The volume of material to be remediated included:

• 2.5 acres of soil .

3. What type of site is this?
/

Chemicals and Allied Products. Former water treatment plant and chemical repacking and
distributing facility.
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing, deed restrictions
993
-------
5. Was an innovative technology considered in the FS? If so, which technology?
Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: In situ bioremediation >
Physical treatment: In situ aqueous soil flushing (giavity induced) flushing with clear
" water • ./''.• ! ,'; ';
6. What was the cost-estimate for the innovative technology? j.

Cost Estimates for RAAs That Include Innovative Technologies
i (selected remedial alternative is in bold)
Alternative |
-RAA-4 I
i
' 1
RAA-5 ;
• ' S
1 •
RAA-6
RAA-7 |
i
Innovative Technology .
In situ aqueous soil flushing/fencing/
deed restrictions/ground water, air, and
surface water monitoring
In situ aqueous soil flushing/ground
water extraction/fencing/deed
restrictions/ground water, air, and
surface water monitoring
Same as RAA-4, plus in situ
bioremediation
Same as RAA-5, plus in situ
bioremediation
Estimated Costs
3 Criteria
$860,000
• t i
.i
$550,000
$950,000
. $640,000
' . • [
9 Criteria
$860,000
$550,000
$950,000
; $640,000
*" • •
994
-2-
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Fencing/deed restrictions/ground water,
air, and surface water monitoring
Same as RAA-2, plus ground water
extraction
Estimated Costs
3 Criteria
$0
$814,000
$767,000
9 Criteria
$0 ,
$814,000
$767,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9, If an innovative technology was chosen, why?

The selected alternative includes in situ soil flushing; ground water extraction; fencing; deed
restrictions; ground water, air and surface water monitoring. This technology was selected: 1)
to remediate site soils so that no further ground water contamination can occur, 2) technology
is an enhancement to the remedy already being implemented at the site under a remediation
plan currently in effect, 3) implementation time frame is substantially shorter, 4) cost, 5) state
preference (this is a state lead site).

Soil Flushing and bioremediation (RAA-7) was recommended for use in the FS, but was
changed to RAA 5 in the Proposed Plan.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? • :

Innovative technologies eliminated during the initial screening include the following:

• None

Innovative technologies eliminated during the screening of the three criteria include the
following: ,

• None
-3-
995
-------
Innovative technologies eliminated during, the detailed analysis include the following:

• In situ bioremediation was eliminated due to the cost and time; needed to implement
the treatment. 1
J
11. Which of the nine criteria were weighted most heavily in selecting the\ technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so, -
which criterion? Which of the criteria supported the use of a standard technology?

Implementability and cost-effectiveness provided the basis for the selection of in situ aqueous
'soil flushing. . , , ,

• " '. ' '• '' •• {. ' " '•.-"'
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
13.
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens _
TCE
0.005
SDWA"
Noncarcinogens :
TCA -
0.2
SDWA
Cleanup levels are based on the Safe Drinking Water Act (SDWA) because soil and
the alluvial aquifer are considered a single media throughout the FS and ROD.

For carcinogens, an excess upper bound individual lifetime cancer risk! of between 10"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ; .
• ' .'! l
. . 'i-" •.••••
Innovative technologies eliminated because of cleanup goals include: j

• ' None •.. . ' - • ' ' 1 .. • ' ' -

Standard technologies eliminated because of cleanup goals include:

• None , , !
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. '.,•"•'
996
-4-
-------
15, What measures/criteria were used to compare alternatives? ^

The following measures were used to compare the alternatives:
: /
Cost-effectiveness ' . ;
Time to design/construct/operate
Preference for treatment (vs. containment)
Proven reliability

16. How are measures compared? , .

Alternatives were compared to reliability and preference for treatment. The combination of a
new extraction well and soil washing system quickly removes contaminants, thus helping to
prevent further migration of contaminants. Cost-effectiveness and the time required to
implement an alternative were also important criteria used when comparing remedies with
similar results.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Throughout the FS and ROD, the soil and alluvial aquifer were considered as a single medium
due to their hydrogeologic relationship. Since contaminated groundwater was considered to be
the greatest threat to human health and the environment, an in situ aqueous soil washing
system to remediate contaminated soils will be installed to eliminate further ground water
contamination. ,
-5-
997
-------
Lehigh Portland Cement Co.

' Mason, Gordo County, Iowa
Region 7
GENERAL SITE INFORMATION
1.
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Cement Kiln Dust (CKD)

The kiln dust at the Lehigh site is a RCRA
special study waste, not a RCRA hazardous
waste. Contaminants included arsenic,
chromium, and lead; concentrations were not
given.
What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1988
8/90
4/91
6/28/91
Background

PRP-lead j
PRPs: Lehigh Porltland Cement
Company
FS prepared by: Layne Geosciences,
Inc., A Layhe-Western Subsidiary
ROD prepared by: (Iowa Department
of Natural Resources
The volume of CKD in the LPCC area is not given (see Question 3),
439,000 cubic yards of CKD in the LCNC area (see Question
3).,
3. What type of site is this?
Construction. The Lehigh Portland Cement Co. site is composed of two £ireas: the 150-acre
Lehigh Portland Cement Company (LPCC) cement production facility,| and the 410-acre Lime
Creek Nature Center (LCNC). From 1911 to the present, the LPCC has manufactured cement
products. Land use in the area is rural, agricultural, and industrial.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screenmg of technically feasible
technologies were: !
Containment:
Slurry walls, synthetic membranes, grout curtain,, hydraulic isolation,
surficial capping (natural or synthetic infiltration caps)
998
-i-
-------
Chemical treatment:
Disposal:
In-place stabilization
Disposal (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology?
o •• /• "•"'','•". '•

Innovative technologies were not considered.
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

CKD/LPCC ,
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action
Drainage of quarries/water treatment ,
CKD isolation capping/quarry
drainage/acid neutralization/dilution
blending water treatment/(this RAA
includes all activities of RAA-2)
Waste stabilization/(this RAA includes
all activities of RAA-2)
Pond drainage/CKD isolation in on-site
engineered landfill/french drain/ground
water extraction/water treatment/(this
RAA includes all activities of RAA-2)
Estimated Costs
3 Criteria .
N/A
N/A
N/A
N/A
N/A
9 Criteria
$0
$1,039,200-
$1,522,401
$2*076,713 -
$3,473,529
$25,223,291 -
$25,356,106
$19,041,820
L-
-2-
999
-------
CKD/LCNC
Alternative
RAA-1L
RAA-2L
RAA-3L
RAA-4L
Standard Technology
No action
Consolidation and isolation of CKD
deposits '
Waste stabilization
Disposal in an off-site engineered
landfill^
Estimated Costs
3 Criteria
N/A
N/A
" I
N/A
JWA
9 Criteria
$0
$947,000-
$1,609,000
$6,810,000
$4,779,000
J
,8. If a standard technology was chosen, why? " ' l

• LPCC - ••-••• ' ,:_ •-..-. •
. . .. '- . • • ' ' • •-. • '- • ;i , , • .
RAA-3 is a comprehensive, readily applicable, and cost-effective remedy for implementation in
the LPCC area. RAA-3 was chosen because the isolation of CKD coupled with the ongoing
treatment of contaminated ground water and surface water, would result in the alleviation of
the major ground water concerns. The hydraulic isolation of the CKD deposits will result in
an effective long-term site remedy. The process of hydraulic isolation, resulting from the
drainage of site ponds and capping, will effectively eliminate ground Water contact with the
CKD; therefore, no pathway for impacted water migration will exist. By isolating the CKD
from interaction with meteoric water, ground water, and surface water, the mobility of
contaminants derived from the CKD will be eliminated. RAA-3 is more effective in the short-
term, as it takes less time to implement than either RAA-4 or RAA-5.J Although RAA-3
requires a "difficult level of implementation," the technology is proven and the equipment is
available; therefore, it could be implemented with greater assurance of effectiveness than the
other alternatives. The cost of the selected alternative is substantially lower than for the
alternatives that address CKD on the site. Finally, RAA-3 complies with ARARs.

, - LCNC • .; •• • - - . '•'•,••'''
1 • " ! ' '
I •, '
RAA-2L "was chosen because through CKD isolation and gradual dilution, the area ground
water quality should eventually reach background or near background levels. Because LCNC is
a public access area, the capping of the CKD deposits in the area will'remove it from public
contact, thus safeguarding the public. In addition, isolating the CKD ifrom direct contact with
the water systems at the LCNC area will result in an effective and permanent remediation. By
isolating the CKD from interaction with meteoric water, ground water] and surface water, the
contaminants, which might migrate to the ground water system, will be greatly reduced.
Finally the earth moving and pumping technologies are readily available in the Mason City
area and are not complex. ,1
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
1000
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ..

Innovative technologies eliminated during the initial screening include the following:

" None -

Innovative technologies eliminated during the screening of the three criteria include the
following: ' ;

• None . . , •

Innovative technologies eliminated during the detailed analysis include the following:

• None

CKD/LPCC

Protection of human health and the environment, implementability, and cost were weighted
heavily in selecting RAA-3 for LPCC. RAA-3 was considered protective of human health and
the environment because this alternative drains the contaminated surface water (and some
ground water) as well as treats the CKD and prevents it from interacting with water on the
site, at least in a way that would cause further leaching of high pH water onto the site. In
addition, the selected alternative can be implemented with greater assurance of effectiveness,
and at a substantially lower cost than the other alternatives.

CKD/LCNC

Protection of human health and the environment, short-term effectiveness, and cost were
weighted heavily in selecting RAA-2L for LCNC. The selected remedy is protective of human
health and the environment because through its implementation the area ground water quality
should eventually improve to background or near background levels. The selected alternative
also has a greater assurance of effectiveness, without risk of adverse off-site impacts associated
with the removal of kiln dust to another location, and can be accomplished at a substantially
lower cost.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?, -

Cleanup goals were not selected.

low
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? j

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?
' ' r .
I , '
Treatability studies were not conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost effectiveness
Proven reliability
16. How are measures compared?

LPCC
The selected alternative was chosen because it uses proven technology land available
equipment. The cost of RAA-3 is substantially lower than other alternatives (RAA-4, RAA-5)
which address CKD on the site. The selected remedy is cost-effective because it is the least
expensive action alternative and yet provides a high degree of overall protection.

LCNC ' . - . •'...'. ' ., ' . • .-, '.
I
.The earth moving and pumping technologies used in the selected alternative are readily
available in the Mason City area and are riot complex. The selected alternative can be
accomplished at a substantially lower cost than RAA-3L or RAA-4L.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy for this site.
1002
-5-
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1', -1
Mid-America Tanning Company

• Sergeant Bluff, Iowa
Region 7
GENERAL SITE INFORMATION ,
\
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sediment (mg/kg)

Chromium 43,000
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

" 12,000 cubic yards of soil
• 44,500 cubic yards of sediment
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
3/89
6/91
9/24/91
Background

EPA Fund-lead
PRPs: U.S. Tanning Company
FS prepared by: U.S. Environmental
Protection Agency
3. What type of site is this?

Food and Kindred Products. A former leather tannery.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: • ~
Access restriction:
Containment:

Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Fencing, deed restrictions
Clay cap, soil cap, RCRA multilayer cap, soil-synthetic membrane,
slurry wall, sheet piling, grout injection, low permeable liner
Stabilization, fixation .
Dewatering
Incineration .
'Excavation, on-site disposal, off-site disposal
-1-
1003
-------
Mid-America Tanning Company
s '

Sergeant Bluff, Iowa
Region?
GENERAL SITE INFORMATION

1. ' What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? :_

Maximum concentrations of principal
contaminants were:

Soil/Sediment (rag/kg)

Chromium 43,000
What volume of material is to be
remediated?

The volume of material to be, remediated
included:

• 12,000 cubic yards of soil
• 44,500 cubic yards of sediment
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
3/89
6/91
9/24/91
Background
:|
EPA Fund-lead
PRPs: U.S. Tanning Company
FS prepared by: UiS. Environmental
Protection Agency
3. What type of site is this? ,

Food and Kindred Products. A former leather tannery.
\ \ - "...."

TECHNOLOGY SELECTION i.
" "~ '" , • , • i - :

4. What standard technologies were considered for selection in this FS?
( ! '
Standard technologies considered during the identification and screening of technically feasible
technologies were: .
Access restriction:
Containment:
Fencing, deed restrictions
Clay cap, soil cap, RCRA multilayer cap, soil-jsyrithetic membrane,
slurry wall, sheet piling, grout injection, low permeable liner
Chemical treatment: Stabilization, fixation
Dewatering
Incineration
Excavation, on-site disposal, off-site disposal
Physical treatment:
Thermal treatment:
Disposal:
-1-
1003
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Inn .-e technologies considered during the identification and screening of technically
feas echnologies were:

Biological treatment: Landfarming, biodegradation, composting
Chemical treatment: Solvent extraction, soil flushing (solvent), soil washing (solvent),
chemical reactions, oxidation
Thermal treatment: In situ vitrification, thermal volatilization, thermal desorption
What was the cost estimate for the innovative technology?

No innovative technologies were incorporated into remedial alternatives.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action
Excavation/off-site disposal/soil
cap/long-term ground water- monitoring
Excavation/on-site disposal/installation
of liner and leachate system/soil cap/
long-term ground water monitoring
Excavation/immobilization/on-site
disposal/soil cap/long-term ground
water monitoring
In situ immobilization/soil cap/
long-term ground water monitoring
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
*
N/A
9 Criteria
$0
$6,675,000
$7,018,000
$8,900,QOO
$4,875,000
8. If a standard technology was chosen, why? • ,

The selected remedy requires immobilization (using cement and additives) of contaminated
soils, sediment and trench sludge on-site followed by either on-site or off-site disposal;
1004
-2-
-------
removing and disposing of debris off-site, and; discharging impoundniient water through an
NPDES permitted outfall or treatment, if needed, with off-site discharge to a publicly owned
treatment works; capping contaminated areas; and implementing institutional controls. The
remedy was selected because 1) it involves treatment of contaminants! in addition to
engineering controls, 2) mobility of the contaminants,will be reduced through bonding to the
solidified matrix and through reduction in the surface area exposed to ground or surface water,
3) direct contact will be prevented through the use of soil/clay caps in th« less contaminated
areas, 4) dewatering involved in other alternatives would create odors[ 5) depends on
conventional immobilization technologies that are proven and reliable; 6) cost was the least
expensive. ,; .

, " ' . • •'[•'/".
P. If an innovative technology was chosen, why? I
-. , ' "•!""'; •
An innovative technology was not chosen. ! /

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
' " ' i
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the liiree criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:
• " , ' •. I' • • ' ' '' '
• Landfarming was eliminated because it would not be effective for remediating
inorganic compounds.
, • Solvent extraction was eliminated because it would not be effective for remediating
inorganic compounds.
••••... Soil washing was eliminated because it is only effective for soiils that are
predominantly sand and gravel.
• Thermal volatilization was eliminated because it would not be effective for remediating
:• inorganic compounds.
• Thermal desorption was eliminated because it would not be effective for remediating
inorganic compounds. . ,
• Biodegradation was eliminated because it would not be effective for remediating
inorganic compounds.
• Chemical reaction (oxidation) was eliminated because it would not be effective for
remediating inorganic compounds. r
• Composting was eliminated because it would not be effective for remediating inorganic
compounds. . •
' ' ' . • ' . - ' i . -
Innovative technologies eliminated during the screening of the three criteria include the
following: i ,
• " . ~ ' :i . ' ' • '
• In situ vitrification was eliminated because implementation would be too expensive
• Soil flushing was eliminated because the solvents could transport contaminants into the
underlying aquifer.
-3-
1005
-------
Innovative technologies eliminated during the detailed analysis include the following:

• None .
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The most heavily weighted criteria in selecting a standard technology were protectiveness of
human health and the environment, long-term effectiveness through treatment, and cost. Of
the two alternatives, RAA-4 and RAA-5, that were comparable with respect to providing
permanent and long-term protection through treatment, RAA-5 was selected based on cost.

No innovative technologies were incorporated into remedial alternatives.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to, establish cleanup goals?
Contaminant
Cleanup Level (mg/kg) ARAR or Other Basis
Carcinogens
Chromium
2,000
Risk8
*Since no federal or state cleanup levels for chromium exist, the cleanup goal is the estimated
concentration that is associated with an excess upper bound individual lifetime cancer risk
level of 10-4. .
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None , ,

Standard technologies eliminated because of cleanup goals include:

» None , • '

14. Were treatdbility studies conducted on the innovative technology or standard technology?

No treatability studies were conducted. ,
1006
-4-
-------
15. What measures/criteria were used to compare alternatives? !
" ' . j - - ' ""
The following measures were used to(compare the alternatives:

Cost-effectiveness ;
Preference for treatment (vs. containment) I

16. How are measures compared? l •• • j

The selected alternative was the most cost-effective. One other alternative (RAA-4) was as
protective of public health and the environment as the selected alternative, but it would be
more expensive to implement. The degree of permanence offered by the selected alternative
through a treatment technology was considered superior to the protection provided by other
alternatives (RAA-2, RAA-3) that did not employ treatment.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations printary in the selection of the remedy? i

No technical considerations were primary in selecting a remedial alternative.
-5-
1007
-------
Peoples Natural Gas Co.
OU-1

Dubuque, Iowa
Region 7
GENERAL SITE INFORMATION
L
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? , .

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Benzene 55
Total PAHs . 8,000
Total Carcinogenic PAHs . 1,800
Ethylbenzene 110
Toluene 29 ,
Cyanide 1,100 .
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
8/30/90
5/15/91
9/16/91
Background

PRP-lead
PRPs: Midwest Gas, Iowa Department
of Transportation, City of
Dubuque
FS prepared by: Barr Engineering
What volume of material is to be
remediated?

The volume of material to be remediated included:

• 24,200 cubic yards of contaminated soil
3. "What type of site is this?

Coal Products. The site is a former coal gasification plant. The City of Dubuque currently
maintains a public works garage on the site. The Iowa Department of Transportation-plans to
build a highway across the western portion of the site. The site is located 300 feet from the ,
Mississippi River. •
TECHNOLOGY SELECTION .

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: •

Access restriction: Deed restrictions, fencing
1008
-i-
-------
Containment:
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Capping (soil, clay, flexible membrane, RCRA type), vertical barrier'
(bent-soil slurry wall, bent-cement .slurry wall, grout curtain, sheet
piles, vibrating beam) |
Stabilization , " • '' ';•:,'
Soil washing - i .
Incineration I ' '
On-site disposal, sanitary landfill, RCRA vault
5. Was an innovative technology considered in the FS? If so, which technology? • '.
• ' ' • • ' ' ~:\ " ' ' ' . ' '
Innovative technologies considered during the identification and screening of technically
feasible technologies were: i ,

Biological treatment: Land treatment, biological reactor, in situ biodegradation
Phys/Chem treatment: Soil flushing, in situ vapor extraction, in situ chemical treatment, in
situ electroacoustic soil decontamination, soil! washing
Thermal treatment: In situ vitrification, low temperature thermal stripping
6. What was the cost estimate for the^innovative technology? !
• • - - -i' - '' '
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on tlhe nine criteria established
by theNCP. . ;

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-4
RAA-5
Innovative Technology
Limited soil removal and incineration,
disposal, or biological treatment/ground
water extraction and treatment/monitoring
Limited soil removal and incineration,
disposal, or biological treatment/ground
water extraction and treatment/capping
and slurry wall containment of source
soils/in situ bioremediation of silty
sands/monitoring .
/Limited soil removal and incineration,
disposal, or biological treatment/ground
water extraction and treatment/source soil'
removal and incineration/monitoring
Estimated Costs
3 Criteria
$6,300,000.
$7,3(K),000
$10,000,000
9 Criteria
$6,200,000
to
$6,300,000
$7,200,000
to
$7,300,000
$10,000,000
to
$10,600,000
• • fl - , •
. '• . :• *••' :•.-•• •-;•• ' l
1009
-------
Alternative
RAA-4&5
Innovative Technology
Soil removal and incineration/ground
water extraction and treatment/in situ
bioremediation of silty sands/
institutional controls/monitoring
Estimated Costs
3 Criteria
not evaluated
1
9 Criteria
$8,000,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
Standard Technology
No action
Soil removal and incineration/
monitoring/institutional controls
Estimated Costs
3 Criteria
$0 :
$3,900,000^
9 Criteria
$0
$3,900,000
8. If a standard technology was chosen, why?

RAA-6 incorporates both a standard technology (off-site incineration) and an innovative
technology (in situ bioremediation). The alternative provides the greatest degree of human
health and environmental protection by excavating and incinerating soils exceeding cleanup
gpalSj excavating and incinerating contaminated soils in contact with ground water sources and
bioremediating contaminated soils in the silty sands area. In situ bioremediation in the silty
sands area is expected to reduce ground water contaminant levels much faster than with just
ground water extraction and treatment and will permanently eliminates residual risk. The
alternative maximizes long-term effectiveness and reduces the toxicity, mobility, and volume
of wastes to the greatest extent practicable. The alternative also poses minimal short-term
risks. RAA-1 is not protective of human health and the environment. RAA-2 reduces the
toxicity, mobility, and volume of contaminated soils, but does not treat ground water and
therefore neither provides adequate" protection of human health and the environment nor attains
chemical specific ARARs for ground water.. RAA-3 is protective of human health and the
environment but does not involve the excavation and treatment of source soils and therefore
would not permanently eliminate residual risk at the site. RAA-4 is similar to RAA-3, but
, uses a combination of in situ bioremediation and capping to reduce risks associated with silty
sands not addressed by RAA-3. RAA-4, however, leaves a large Volume of source soils
untreated that could potentially leach chemicals of concern into ground water. RAA-5
addresses the source soil area through excavation and incineration, but relies on ground water
extraction and treatment to remove contaminants from the silty sand area. Without in situ
bioremediation of the silty sands area, RAA-5 is expected to require a much longer period to
reduce contaminant levels in ground water to acceptable levels.
1010
-3-
-------
9. If an innovative technology was chosen, why? |
" • " • ' " . " " • • '' •' ' , - '
As discussed above, RAA-6 employs both standard and innovative technologies.
Bioremediation of the silty sands area was incorporated into RAA-6 because it is expected to
accelerate ground water restoration. Ground water extraction and treatment by itself (as in
RAA-3 and RAA-5) will not restore ground water quality as quickly in the absence of
enhanced bioremediation. i
' ' '
.10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

• In situ vitrification was eliminated because it would not be effective in treating soils
with relatively high permeability and moisture content. In addition, the depth of
contamination and the presence of ground water at the site make this technology
infeasible. A lack of sufficient demonstration was also cited.
• In situ vapor extraction was eliminated because it is only applicable to, organic
compounds that are highly volatile at ambient temperatures. Many^of the, PAHs in
coal tar have low volatility. Vapor extraction also is not effective in treating
contaminated soils below the water table with relatively low permeability at the site.
» In situ chemical treatments (other than soil flushing and stabilization, including solvent
extraction and oxidation-reduction) were eliminated because Ihey are not considered
demonstrated treatment technologies for treating soils containing coal-tar derived
contamination.
• In situ electroacoustic soil decontamination Was eliminated because it is in the
evaluation stage and has not been applied in situ. Its potential is greatest for treating
fine grained clay soils containing inorganic contaminants. ',•'..
" Low temperature thermal stripping was eliminated because it is not effective in
treating PAHs with relatively low volatility.
• Soil washing was eliminated because of the presence of fine Drained soils, which make
post-treatment of the wash solution difficult and strong adsorptive bonds between clays
and SVOCs. Success in treating soils containing PAHs is not well documented.

innovative technologies, eliminated during the screening of the three criteria include the
following: . - I- .
' ' •• ' - .- ! " '• i '
• Soil flushing was not included in the RAAs, though no explicit reason was stated. The
FS states that not all technologies that survived the screening process are included in
RAAs. The RAAs were assembled to highlight technologies; for individual operable
units that enhance the effectiveness of other remedial technologies. .
- ' ' . " ' • _ I •-'
Innovative technologies eliminated during the detailed analysis include the following:
••".'. ' • ' • •}• •• • • ,- '.:
• Land treatment was eliminated because they have not been demonstrated to effectively
reduce concentrations of all PAHs to environmentally acceptable levels for the
10.11
-------
quantities of excavated soils which would be generated at the site. Residual
contamination may be present after treatment. .
Biological reactor was eliminated because they have not been demonstrated to
effectively reduce concentrations of aU^PAHs to environmentally acceptable levels for
the quantities of excavated soils which would be generated at the site. Residual
contamination may be present after treatment.
ll.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so, •
which criterion? Which of the criteria supported the use of a standard technology?

Protectiveness of human health and the environment, long-term effectiveness and permanence,
and reduction of toxicity, mobility, and volume of contaminants were weighted most heavily in
selecting the preferred alternative. RAA-4 & 5 addresses all sources of ground water
contamination and therefore offers the greatest reduction in toxicity, mobility, and volume of
site contaminants, maximizes long-term effectiveness, and protects human health and the
environment to the greatest extent practicable.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup. Level (mg/kg)
ARAR or Other Basis
Carcinogens
Benzene
Total Carcinogenic
PAHS
850
100
Risk8
Risk"
•« • '
Noncarcinogens
Total PAHs
Ethylbenzene
Toluene
Cyanide
500
68,000
200,000
3,400
Risk0
Riskc
Risk6
Risk0
"Cleanup level, is based on achieving an excess upper bound individual lifetime cancer
risk of 10"6.
""Cleanup level is based on achieving an excess upper bound individual lifetime cancer
risk of 5.8 x ID"4.
cCleanup level is based on achieving a Hazard Index less than or equal to 1.0.

t™
1012
-5-
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? i

Innovative technologies eliminated because of cleanup goals include: , ,

• Land treatment ' I
• Biological reactor
I • • . . - , •. ,
Standard technologies eliminated because of cleanup goals include:

• None
r standa
14. Were treatability studies conducted on the innovative technology or standard technology?

While no treatability studies were conducted, a pilot study of in situ bioremediation of the silty
sands area will be conducted prior to full-scale implementation. The study will determine the
types and amounts of nutrients and engineered organisms needed to stimulate natural
biological degradation at the site. s , |
75. What measures/criteria were used to compare alternatives? .
' ' • I - '
• The following measures were used to compare the alternatives: >'\
. - - - • ' 1 ", ," - ' •
Risk reduction i
- Time to design/construct/operate , :

16. How are measures compared? ' ,

RAA-4 & 5 was selected primarily on the amount of risk reduction achieved and the amount
of time needed to restore ground water quality to acceptable levels, i Because RAA-4 & 5
addresses both source soils and the silty sands area, it is expected to achieve the greatest
'. reductionin site risks by permanently destroying virtually all site contaminants.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? !.

" Technical considerations were not a primary factor in selecting a final remedy. The nature of
site soil conditions (high permeability and moisture content), however, .were a factor in
eliminating a number of innovative technologies during the initial screening phase. These
technologies were: j
. .1 " •
' ' '' ! • . ' - '•('•'. • • '
• Vitrification
• Vapor extraction : •' *• \ j,
• In situ electroacoustic soil decontamination. | •
• Low temperature thermal volatilization.
1013
-------
Pester Refinery Co. (Burn Pond)
01

El Dorado, Kansas
Region 7
GENERAL SITE INFORMATION

1. "What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Sludge (mg/kg)

Benzo(a)anthracene 78
Chiysene 150
2-Methylnaphthalene '75
Naphthalene 7 .
Phenanthrene 220
Pyrene 160
Xylenes 4
Chromium 121
Lead - 157
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
'N/A
1/31/89
6/17/92
9/30/92
Background

EPA Fund-lead
PRPs: Fina Oil and Chemical
Company
FS prepared by: Metcalf & Eddy,
Incorporated
What volume of material is to be remediated?

The volume of material to be remediated included:

» 20,000 cubic yards of sludge
» 70,000 cubic yards of soil
3. What type of site is this?

Petroleum Refining. A pond adjacent to a refinery where petroleum waste products were
deposited. '• . . .s • .
I-,.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: " , '
Access restriction:
Deed restrictions
1014
-i-
-------
Containment:

Chemical treatment:
Thermal treatment:
Disposal:
!
Clay cap, asphalt cap, vegetation, slurry walls, interceptor trenches,
cutoff walls . ,
Solidification/stabilization, refining, detergents
Incineration, waste fuel recovery in cement kiln
Excavation, on-site disposal, off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?
.1 .'-,/•'.
Innovative .technologies considered during the identification and screening of technically
feasible technologies were:
• - • " . " ' i'" - • .
Biological treatment: Bioremediation
Phys/Chem treatment: In situ soil flushing, oxidation
Thermal treatment: Thermal desorption
r
6. What was the cost estimate for the innovative technology? 1

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. j\fter the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives thai: merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP: long-term effectiveness and pemianence; short-term
effectiveness; compliance with ARARs; protectiveness of human health and the environment;
reduction in contaminant mobility, toxicity, or volume; implementabil ity; cost; state/support
agency acceptance; and community acceptance. j
''••' \ ':'''• ~ '"'.
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2A2
RAA-2B2
RAA-5B
Innovative Technology
Excavate sludge/dewater/off-site
solidification of sludge/in situ soil
flushing/bioremediation of soils
Excavate sludge/dewater/off-site re-
refining of sludge at RCRA refinery/
in situ soil flushing/in situ bioreme-
diation of soils and recirculated water
Excavate sludge/off-site use of sludge
as a hazardous waste fuel for
incineration/in situ soil flushing and
bioremediation of soils
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$2,160,000
$2,374,800
$5,402;iOO
-2-'
1015
-------
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That In. ide Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-1A
RAA-2A1
RAA-2B1
RAA-3
RAA-4
RAA-5A
Standard Technology
No action
Deed restrictions/pump interceptor
trench
Excavate sludge/dewater/off-site
solidification of sludge/cap soils
Excavate sludge/dewater/off-site re-
refining of sludge at RCRA refinery/cap
site soils
Dewater sludge/RCRA cap over sludge
and soils/leachate collection and
treatment
On-site solidification of sludge/cap
soils/leachate collection and treatment
Excavate sludge/off-site use a hazardous
waste fuel for incineration/clay cap over
remaining soil
Estimated Costs
3 Criteria
N/A ' ,
N/A
N/A ,
i
N/A
N/A
N/A "
N/A
9 Criteria
$0
$238,300
$2,572,900
$2,787,720
$2,646,200
$3,353,600
$5,815,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why? • '

The selected remedy includes removing and dewatering sludge from a RCRA regulated sludge
pond; sludge processing at an off site refinery; in situ soil flushing of contaminated soils
through the use of interceptor trenches with accompanying bioremediation; and bioremediation
of pond waters. The remedy was selected because 1) it would mitigate migration of
contaminants into the river with an interceptor trench, 2) treatment in an asphalt plant would
require delisting of the material while reuse through recycling provisions provides exclusions
for certain recyclable materials from most of the RCRA regulations, 3) anticipated to attain
clean-up goals, 4) will permanently remove contaminants in the soil, and 5) is cost effective.
1016
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .|.: .

• , Thermal Desorption was eliminated because they have no significant effect pn most
metals and it is not cost effective. 1 . '• v-

Innovative technologies eliminated during the screening of the three criteria include the
following: , .._-'- i

• None !

Innovative technologies eliminated during the detailed analysis include the following:

• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The permanent reduction of site contaminants and cost were the criteria weighted most heavily
on selecting an innovative technology,
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant ,
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens |
PAHs
13
! Risk2
"Cleanup levels were based on the concentration of total PAHs which would result in
an excess upper bound individual lifetime cancer risk of 10"6,;
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? . .. .
. " ' . ' - ' ' ! .' .
Innovative technologies eliminated because of cleanup goals include:
.. ' - ' I
• None --•'•• ' . ' -. '••.':•'•!
-4-
1017
-------
Standard technologies eliminated because of cleanup goals include:

• None '
14. Were treatability studies conducted on the innovative technology or standard technology?

A treatability study was conducted to determine the feasibility of solidification/stabilization as
a treatment technology for the remediation of sludge. The study determined that the process
produces a stabilized material that achieves the leachability objectives.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Cost-effectiveness
Preference for treatment (vs. containment)
Waste left in place/institutional control
16. How are measures compared?

The chosen alternative reduces site risk to 10* through the implementation of an innovative
treatment technology. The preference for treatment was a factor and, several alternatives
(RAA-2A1, RAA-2A2, RAA-2B1, and RAA-3) were eliminated because they did not propose
source treatment. In addition, since off-site treatment of site contaminants was preferred,
solidification/stabilization techniques were eliminated because contaminants would have '
remained on site. Of the two alternatives that included soil treatment technologies, the chosen
alternative was the most cost-effective option. '
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in the selection of a remedial alternative.
1018
-5-
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Shaw Avenue Dump
OU-1

Charles City, Iowa
Region 7
GENERAL SITE INFORMATION
2.,
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Chemical fill/soil (mg/kg)

Arsenic 264,000
Ortho-nitfoaniline . 95,000
.PAHs 200
What volume of material is to be.
remediated? '

The volume of material to be remediated
included:

• 370 cubic yards of chemical fill and soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
7/87
9/21/91
9/26/91
Background •

PRP-lead j
PRPs: Charles City, Solvay Animal
Health, Inc. j
FS prepared by: Conesltoga-Rovers &
Associates
3. What type of site is this?

Municipal Landfill. An'active waste site located in a residential area.
TECHNOLOGY SELECTION
4. What standard technologies were considered for selection in this FS?
• . \ . • '• •
Standard technologies considered during die identification and screening of technically feasible
. technologies were:
Access restriction:
Containment:
Physical treatment:
Thermal treatment:
Disposal:
Deed restrictions, access control
Capping (RCRA, non-RCRA) , :
Stabilization/fixation
Incineration
Excavation, disposal at RCRA landfill (on-site, off-site)
-1-
1019
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Bioremediation
Chemical treatment: Solvent extraction
Physical treatment: ° Soil washing, soil vapor extraction
Thermal treatment: Low-temperature thermal extraction, in situ vitrification
6*. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-6
Innovative Technology
Deed restrictions/ground water
monitoring/in .situ vitrification
Estimated Costs <
3 Criteria
N/A
9 Criteria
eliminated
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Deed restrictions/ground water
monitoring
Cap/deed restrictions/ground water
monitoring
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$34,800
eliminated
$145,250
1020
-2-
-------
• . ..- -. • • • ; ^ :; •• : . • '--; • iv;.- • ;. . ".
Alternative
RAA-4
RAA-5
Standard Technology
Excavation/off-site disposal at RCRA
facility
Cap/deed restrictions/ground water
monitoring/solidification/fixation
Estimated Costs
3 Criteria
N/A
M/A ' ,
9 Criteria
$845,000
$513,400
8. If a standard technology was chosen, why? - >f
' ' • ' '[
The chosen alternative was selected because it protects human health and the environment
through the containment and treatment of contaminated soil. Stabilization/fixation binds and/or
entraps the contaminants, thereby immobilizing them and preventing future releases.
Stabilization/fixation also eliminates any threat posed by direct contact with the chemical fill
or contaminated soil as well as threats posed to future users of the site. A cap placed on the
solidified material prevents direct contact and protects the solidified mass. Implementation
involves conventional techniques that are readily available, proven, arid reliable. This
alternative imposes no short-term impacts. Stabilization/fixation techniques reduce site '
contaminants to cleanup levels and prevent the leaching of contaminants to ground water.
The chosen alternative is cost-effective.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? . !

Innovative technologies could be eliminated from the remedial techno log],' selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Soil washing was eliminated because its effectiveness is questionable for some
contaminants and implementation costs could escalate dramatically if several wash
i stages are necessary.
• Soil vapor extraction was eliminated because it would not address inorganic
contaminants. i
• Solvent extraction was eliminated because it would be ineffective in addressing
inorganic contaminants. j
• Low-temperature thermal extraction was eliminated because it would be ineffective for,
inorganics and impractical since there is only a small volume of soil.
• Bioremediation (ex situ) was eliminated because it would not be effective for
inorganics, degradation of a mixture of contaminants is uncertain, and degradation
products could be toxic.
-3-
1021
-------
12.
Innovative technologies eliminated during the screening of the three criteria include the
following:

• In situ vitrification was eliminated because it is still in experimental stages and its
effectiveness is unclear. Moreover, the cost of this technology at such a small site
would be prohibitive. This technique was described as most useful at sites were
remediation techniques would pose a short-tern risk to site workers or the community
and this is not the case at Shaw Avenue.

Innovative technologies eliminated during the detailed analysis include the following:

» None
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria that were weighted most heavily in selecting a remedial alternative were protection
to human health and the environment and cost. The chosen alternative provides a great deal of
protection through the utilization of both capping and stabilization techniques. In addition, it
costs much less than off-site disposal or vitrification.

In situ vitrification was eliminated, in part due to excessive cost.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens .
Arsenic
Cadmium
50
20
Risk8
Risk
"For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"*
to 10"6 was acceptable, For noncarcinogens, a Hazard Index less than or equal to 1.0
was acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include: .

• None

1022 '
-4-
-------
14. Were treatability studies conducted on the innovative technology,or standard technology?

Treatability studies were not conducted. |

15. • What measures/criteria were used to compare alternatives? |
''• . . • . ' . t'' •','•'
, *! • .
The following measures were used to compare the alternatives: i
' . - ' , i ' '" ,
Cost-effectiveness '
Proven reliability , . ;
•• - . • • - - '-.!'"'" ' ',
•-..-' .' ' • • ' ' • • .!-•'.
16. How are measures compared?- i '

The chosen alternative was preferred because it offers the greatest benefits! for the cost. An
alternative proposing off-site disposal was not chosen because it would have cost more and the
benefits would not have increased significantly. The chosen alternative also utilizes proven
and reliable technologies. One innovative technology, in situ vitrification, was eliminated
because its effectiveness is uncertain and its cost would be excessive. |

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

.Technical considerations were not primary in selecting a remedial alternative.
-5-
1023
-------
Anaconda Co. Smelter
OU-11

Anaconda, Deer Lodge County, Montana
Region 8
GENERAL SITE INFORMATION
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Flue Dust (rag/kg)
Aluminum
Antimony
Arsenic
Beryllium
Bismuth
Cadmium
Calcium
Chromium
Cobalt ,
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Silver
Silicon dioxide
Selenium
Zinc

6,300
2,120
80,00
0.35
3,22 ,
3,59
78,000
30

Site History

NPL Proposed: N/A
NPL Final: 9/8/83
FS Phase I: 5/25/89
RI/FS: 6/4/91 '
ROD: 9/91
Background

PRP-lead ,
PRPs: Atlantic Richfield Co. (ARCO;
Cleveland Wrecking Co.)
FS prepared by: Dames and Moore
•

71.6
244,000
175,000 ',.•'•
32,300
500
218 •..-,."
1,150 . ' - •
110 .
290 :
265,000
49 . \ . . .- - ' ' ••'•• - "
49,000
2. What volume of material is to be remediated?

The volume of material to be remediated included:

* 316,536 cubic yards of flue dust

3. What type of site is this?
Primary Metal Products. An abandoned smelter located in and adjacent to the community of
Anaconda.
1024
-i-
-------
TECHNOLOGY SELECTION i

4.' What standard technologies were considered for selection in this FS?

Standard technologies considered during the original [FS I] identification and screening of
technically feasible technologies were:
''"..' '' • • L .' ' ' ' ' '-
Access restriction: Restrictive covenants, land use zoning restrictions, drinking water bans
Containment: Single-layered soil cap, multilayered soil/synthetic membrane cap,
establishing grassy vegetation, compacted soil liners, synthetic
membrane liners
Chemical/physical Thermoplastic stabilization, surface encapsulation, cement7based
treatment: stabilization/fixation (HAZCON, MSE, Inc.){ cement-and fly-ash-
based stabilization/fixation (Dames and Moore), silicate-based
stabilization/fixation (CHEMFDC Environmental Services), gravity
separation
Thermal treatment: Rotary kiln, flame reactor, electric arc furnace
Disposal: Excavation, permanent on-site disposal, off-siite disposal, interim on-
site storage • j
", - - • ' " "1 • j" • •

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: ;
I
" • -. • } - ' ' "' V ' "
Biological treatment: In situ biological treatment
Chemical treatment: In situ chemical treatment, hydrometallurgical processes (Dowa,
Cashman, Kenneeott, Shenyang, ammonium leach, Bureau of Mines
alkaline leach, Metallhute Carl Fabusch, Anaconda Research,
Anaconda Modified Dowa, chloride leach, sulfur dioxide leach, Con
Mine, sulfide precipitation, and ambient acid leach) , '
-Thermal treatment: Vitrification, pyrometallurgical processes (PLASMADUST, arsenic
volatization)

Processing at commercial hydrometallurgical/pyrometallurgical facilities also was considered
under two representative processes, A and B, at the following facilities (the processes are not
described): - ,, i
Option A:
Koaka Smelter, Dowa, Japan
Nercb Con Mine Arsenic Plant, YeHowknife, Northwest Terptory, Canada
Falconbridge, Ltd., Kidd Creek, Timmins, Ontario^ Canada
Option B:
Falconbridge, Ltd., Kidd Creek, Timmins, Ontario, Canada
Metallurgy Hoboken-Overpelt, Olen, Belgium
Norddeutsche Affinerie, Hamburg, Germany
Outokompu Oy, Harjavalta, Finland
2 1025
-------
6. Wluit was the cost estimate for the innovative technology?

RAA designations that were changed in the ROD are presented parenthetically.

Cost Estimates for RAAs That Include Innovative Technologies .
(selected remedial alternative is in bold)
Alternative
RAA-6A-1
RAA-6A-2
RAA-6B-1-A
(RAA-5A)
RAA-6B-1-B
(RAA-5B)
RAA-6B-2
RAA-6C-1
(RAA-6)"
RAA-6C-2
Innovative Technology
Excavation/on-site hydrometallurgical
treatment using Dowa process/possible
stabilization/fixation/on-site disposal
Excavation/on-site hydrometallurgical
treatment using Dowa process/possible
stabilization/fixation/off-site disposal
Excavation/on-site hydrometallurgical
treatment using Cashman process/
stabilization/fixation/on-site disposal
Excavation/on-site, hydrometallurgical
treatment using Cashman process/on-site
disposal
Excavation/on-site hydrometallurgical
treatment using Cashman process/
possible stabilization/fixation/off-site
disposal
Excavation/on-site hydrometallurgical
treatment using ambient acid leach
process/possible stabilization/fixation/
on-site disposal
Excavation/on-site hydrometallurgical
treatment using ambient acid leach
process/possible stabilization/fixation/
off-site disposal ,
Estimated Costs
3 Criteria
N/A
N/A
N/A
- N/A
N/A
1 N/A
N/A
9 Criteria
eliminated
eliminated
$50,200,000
$40,100,000
eliminated
$19,189,569
eliminated
I r
'Includes stabilization/fixation.
1026
-3-
-------
7. How did the cost(s) compare to standard technologies? \. ~

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) |
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-3C
(RAA-2)
RAA-4
(RAA-3)
RAA-5A-1
(RAA-4)
RAA-5A-2
RAA-7AC
RAA-7BC
Standard Technology
No action
Institutional controls .
Excavation/on-site disposal in existing
FDS facility/cap/vegetatibn/institutional
controls
Excavation/on-site disposal in upgraded
existing FDS facility (to RCRA Subtitle
C TSD design standards)/cap/
vegetation/institutional controls
Excavation/on-site disposal in new
repository facility (constructed to
RCRA Subtitle C TSD design stan-
dards)/cap/vegetation/institutional
controls
Excavation/off-site disposal in RCRA
Subtitle C TSD facility
Excavation/separation and on-site
disposal of debris/cement- or silicate-
based stabilization/fixation/on-site
disposal in an engineered repository
Excavation/separation and on-site
disposal of debris/cement- or silicate-
based stabilization/fixation/off-site
disposal in a RCRA Subtitle C TSD
facility
Excavation/on-site pyrometallurgical
treatment using electric arc furnace
(Elkem)
Excavation/on-site pyrometallurgical
treatment using rotary kilri
1 . • . *
Estimated Costs
3 Criteria
N/A
N/A
N/A
• '!
N/A '
l
'
[N/A
• - -i
:i
- ',!
1
IN/A
|N/A .'
;i ..
i
'i
NA
i
eliminated
.1
.a
eliminated .
9 Criteria
$0
eliminated
eliminated
eliminated
$6,911,000
$71,933,000
$21,866,000
eliminated
eliminated
eliminated
Eliminated after being considered but before three criteria screening.
-4-
1027
-------
& If a standard technology was chosen, why?

RAA-4 was chosen because it would p-ovide the greatest overall protection through the
containment of the stabilized waste. an effective long-term material and in a timely manner (3
years). Stabilization/fixation provides a high degree of long-term effectiveness and
permanence by immobilizing the hazardous constituents through stabilization. Also, since it is
a proven technology, the uncertainties associated with long-term effectiveness and permanence
are less than for the hydrometallurgical technologies. Treatability testing indicated that the
stabilized materials would immobilize arsenic, cadmium, and lead to meet regulatory limits and
provide for long-term stability as determined from leaching test used by the American Nuclear
Society. By having the least number of untreated flue dust handling and transportation steps,
risks to workers and the environment are less than for any other option. The technology is
demonstrated, uses standard equipment, and would be easily implemented.
•• • . -' i •••

9. If an innovative technology was chosen, why?

An innovative technology was not chosen.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
i I -
Innovative technologies eliminated during the original initial screening [FS I report] include |
the following: -

« Hydrometallurgical process (Kennecott) was eliminated because the level of
development of the technology is questionable. The technology produces a solid i
residue that would contain arsenic and lead in oxidized, mobile forms; thus, the
process would not be effective in reducing the mobility or toxicity of flue dust ;
contaminants. ,, . •
« Hydrometallurgical process (ammonium leach) was eliminated because the level of . "\
development of the technology is questionable. The technology potentially produces a
solid residue that might contain arsenic in oxidized, mobile forms; thus the process
would not be effective in reducing the mobility or toxicity of flue dust contaminants. !
" Hydrometallurgical process (U.S. Bureau of Mines alkaline leach) was eliminated !
because the level of development of the technology is questionable. The technology
potentially produces a solid residue that might contain arsenic in oxidized, mobile t
forms; thus, the process would not be effective in reducing the mobility or toxicity of '
flue dust contaminants. I
" Hydrometallurgical process (Metallhute Carl Fabusch) was eliminated because of
potential incompatibilities With the chemical characteristics of flue dust. Flue dust is ;
predominantly sulfate-based, rather than chloride-based, and thus the initial
dechlorination step would be inappropriate. Additionally, the flue dust contains T
arsenic. Since the reaction pathways for arsenic are uncertain, this process might not 4|lk \
be effective. - ^[Jr ./

1028 1
t : \'
-5- • . ' - . .. • • .;""
-------
• Hydrometallurgical process (chloride leach) was eliminated because it would produce
a metal residue byproduct that contains arsenic and lead in potentially mobile forms.
The metal residue would not be saleable because of its elevated arsenic concentrations.
• Pyrometallurgical process (PLASMADUST) was eliminated bescause the technology has
not been demonstrated to be effective for the treatment of copper smelter flue dusts.
• Pyrometallurgical process (cyclone smelting) was eliminated because the technology
generates a byproduct dust that contains arsenic, cadmium, and lead in potentially
mobile, oxidized forms. The dust constitutes nearly 40 percent of the original volume
of material treated. - I . •
• In situ leaching was eliminated because the characteristics of the flue dust locations
would limit control of in situ leaching treatment; and the physical characteristics of the
flue dust (i.e., degree of compaction), and chemical characteristics of the flue dust
(such as extent of compositional variation) might limit its applicability.
• In situ biological treatment was eliminated because the flue dust locations would limit
control of in situ leaching treatment; and the physical characteristics of the flue dust
(degree of compaction), chemical characteristics of the flue dust (extent of
compositional variation), and the lack of an organic matrix acid a nutrient base to
support the biosystem would limit its applicability. .

Innovative technologies eliminated during the 'second initial screening; criteria include the
following: :
•"-.''' . • i'
• Hydrometallurgical process-(Dowa) was eliminated because pilot tests at the facility
could not be secured. ,
• Hydrometallurgical process (sulfide precipitation) was eliminated, but no explanation
was given. The technology is confidential business information (CBI).
•' Pyrometallurgical process (arsenic volatization) was eliminated because treatability
testing indicated insufficient arsenic removal through volatization.
• Commercial hydrometallurgical/pyrometallurgical processing was eliminated because,
though Falconbridge, Ltd., responded favorably, testing at the Kidd Creek facility
would take up to 10 years because of limited facility capacity. Additional reasons
include: (1) the lack of process-specific data on flue dust trealability; and (2) treatment
of flue dust at Kidd Creek would require transporting hazardous materials across •
international boundaries. No other facilities reported, favorably to inquires regarding
the processing of the flue dust.
• Vitrification was eliminated because of the volatization of arsenic: during the process.
• -i-
The treatability tests were followed by a summary stating: "Based on the results of ... tests ...,
three treatment technologies ... will be subjected to detailed technical analyses. CementTbased
stabilization/fixation was selected as being representative of the stabilization/fixation
technology type, while the Cashman process and the ambient acid leach process were selected
as being representative of the hydrometallurgical processing technology type. Pyrometal-
lurgical processing and commercial processing did not indicate promising results relative to
treating Smelter Hill flue dust."

Representative technologies were chosen because the remaining hydrometallurgical and
Pyrometallurgical options and stabilization/fixation technologies were! similar. Following the
treatability studies, the selection of representative technologies were modified, resulting in the
elimination of the following hydrometallurgical processes prior to the> three-criteria screening:

• Shenyang . •-.''•

• •• .'.'',:"' ' • •'-- . . " •-•.' '"."• 1029
-------
• Anaconda Research
c Anaconda Modified Dowa .,.,-. /
c Sulfur Dioxide Leach
• Con Mine . '

Innovative technologies eliminated during the screening of the three criteria include the
following: . , -

• None.' .

Innovative technologies eliminated during the detailed analysis include the following:

• Hydrometallurgical process (Cashman) was eliminated because it would take longer (7
to 10 years) to achieve the same level of protection as stabilization/fixation; its success
would be less certain than with stabilization/fixation; short-term risks could be posed
that could affect workers and the environment, including the production of additional
waste streams; a relatively complex processing facility would have to be built, which
would require exceptionally expensive construction materials; maintenance of the
facility would be more difficult than stabilization/fixation; the technology has not been
proved on a full scale; its implementability is considered uncertain; and, based on a
. sensitivity analysis, the cost could vary greatly ($27 million to $88.4 million ) with
additional stabilization.
« Hydrometallurgical process (acid ambient leach) was eliminated because it would take
longer (7 to 10 years) to achieve the same level of protection as stabilization/fixation;
its success would be less certain than with stabilization/fixation; short-term risks could
be posed that could affect workers and the environment, including the production of
additional waste streams; a relatively complex processing facility would have to be
built, which would require exceptionally expensive construction materials; maintenance
of the facility would be more difficult than stabilization/fixation; the technology has
not been proved on a full scale; its implementability is considered uncertain; and,
based on a sensitivity analysis, it has a high degree of cost variability ($6.5 million to
$34.7 million).
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Three criteria were important in selecting the technology. First, stabilization/fixation has been
demonstrated to provide the greatest overall protection through containment of stabilized Waste
in a timely manner. While the alternatives that included hydrometallurgical treatment might
provide the same degree of protection, hydrometallurgical treatment would take longer to
complete than stabilization/fixation. Second, stabilization/fixation provides a high degree of
long-term effectiveness and permanence by immobilizing the hazardous constituents: Also, it
is a proven technology. The long-term effectiveness and permanence are less certain for the
chosen technology than for the hydrometallurgical technologies. And three, it provides the
greatest short-term effectiveness by having the least number of untreated flue dust handling
and transportation steps.
1030
-7-
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? ••!.-•'
,...'•'•' - ',.,.!•.-

Cleanup goals were not provided. The flue dust will be treated to render the material
nonhazardous by meeting RCRA TCLP regulatory limits (Maximum Concentration of
Contaminants for the Toxicity Characteristic, ARM § 16.44.324, as detennined by the Toxicity
Characteristic Leaching Procedure). -
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? :
•\ • •' ''"' ' • - ' ''"' " • - ' "• . :l v- •••••'
Innovative technologies eliminated because of cleanup goals include:
• •" I ' '••".-.
• None |
i • ' ' ! • •
~ . -' ••' ' • 1 ...-'
Standard technologies eliminated because of cleanup goals include: |
1 ' ',*•.-
• None
O
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were performed on die following technologies: ;
''"'.".' - ' . !'•'.•
Cement-based stabilization/fixation (HAZCON and MSB, Inc.)
Cement- and fly-ash-based stabilization/fixation (Dames and Moore)
Silicate-based stabilization/fixation (CHEMHX Environmental Services)
Hydrometallurgical process: Cashman
Hydrometallurgical process: Sulfide precipitation
Hydrometallurgical process: Ambient acid leach
Pyrometallurgical process: Arsenic volatization
Commercial processing (Falconbridge, Ltd.)
Gravity separation process (PASAR)
75. What measures/criteria were used to compare, alternatives?

The following measures were used to compare the alternatives:

Time to design/construct/operate
' - Proven reliability ,
- Single vs. multistep treatment

16. How are measures compared?

Stabilization/fixation would be completed in 3 years compared to the hydrometallurgical
processes which would take between 7 and 10 years. The treatability j studies showed that there
were uncertainties concerning hydrometallurgical processes' success and implementability;
these uncertainties do not exist for stabilization/fixation. For short-teitn effectiveness,
-8-
1031
-------
stabilization/fixation has fewer steps involving transportation of untreated flue dust than any of.
the other options; this process, therefore, minimizes the hazards associated with flue dust
transportation.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Treatment considerations were not primary in selecting a remedy. The site is capable of
accommodating on-site disposal. Since the transportation of flue dust presents hazards to
workers and the environment, on-site disposal was preferred. The physical characteristics of
flue dust locations also were factors. The applicability of in situ treatment was limited because
only two of the nine flue dust locations are lined. Of the remaining seven locations, one has a
low-permeability cap, which would limit the extent to which leaching solution could be
brought into contact with the flue dust. Since the remaining six flue dust locations are not
lined, maintaining the control of in situ leaching treatment would be extremely difficult.
103?
-9-
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Broderick Wood Products
OU-2

Adams County, Colorado
Region 8
GENERAL SITE INFORMATION , ,

1. What were the principal contaminants,
' contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal '
contaminants were: ,

Soil (surface/subsurface in ing/kg)

Carbazole 21.4/77.3
Naphthalene 11,000/2,500
Phenathrene 14,000/680
Pyrene 7,800/306
Benzo(a)anthracene 1,200/72
Chrysene . 2,200/99.5
Benzo(b)fluoranthene 200/11.1
Benzo(k)fluoranthene 500/100
Benzo(a)pyrene 500/100
Dibenzo(a,h)anthracene 500/100
Indeno(l,2,3-cd)pyrene 500/100
Benzene 0.33/0.625
Toluene 4.7/25
Xylene , 21.4/160
Pentachlorophenol 8,600/380
2,3,7,8-Tetrachloro-
dibenzo-p-dioxin ,
Pentachlorodibenzo-p-dioxin
Hexachlorodibenzo-p-dioxin
Heptachlorodibenzo-p-dioxin 5.65/0.9596
Octachlorodibenzo-p-dioxin 42.7/3.0066
Arsenic 187/11.4
Cadmium 193/2.4
Lead 7,140/208
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
9/83
9/84
6/91
3/92
Background
PRP-lead ;
PRPs: Brodericl; Investment Company
FS prepared by: N/A
0.00155/0.0007
0.0079/0.001
0.31/0.0269
Sediment (mg/kg)

PAHs
0.00665
-1-
1033
-------
2. What volume of material is to be remediated? ,

The volume of material to be remediated included:

• 59,100 cubic yards of organics-contaminated soil ,
• 120 cubic yards of organics-contaminated sediment .
• 800 cubic yards of metal-contaminated soil

3. What type of site is this? .

Lumber and Wood Products. A former wopd treatment facility located in an industrial area.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restrictions, fencing
Containment: Capping (clay, multilayer, asphalt, concrete)
Chemical treatment: Fixation
Physical treatment: Size separation, dewatering
Thermal treatment: Incinerator (infrared, rotary kiln, fluidized bed, circulating bed, process
kiln)
Disposal: • Excavation, land disposal, raw material use (asphalt blending)

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biological treatment (in situ, ex situ), composting, liquid/solid slurry
Phys/Chem treatment: In situ chemical flushing, in situ air stripping, soil washing, solvent
extraction (RCC's BEST Process, CF System's Supercritical
. Extraction)
Thermal treatment: Thermal desorption
6. What was the cost estimate for the innovative technology?

Innovative Technology
In situ surface biological treatment of soils with ,
organics above lO^/excavatibn and in situ biological
treatment of sediment/off-site landfill for metal-
containing soil above 1 (^/institutional controls for soil
between ICT* and W6
Excavation/ex situ biological treatment of soil
containing organics above 10"Vexcavation/fixation of
metal-containing soil above lO'Vinstitutional controls
for soil between 10"4 and 10"6
9 Criteria
.eliminated
eliminated

Estimated
Costs
9 Criteria
$4,551,000
$5,350,000
-3-
1035
-------
Alternative
RAA-4a
RAA-4b
RAA-5
RAA-6
RAA-7a
RAA-7b
RAA-8
RAA-9
Innovative Technology
Excavation/on-site theraial desorption and on-site
landfilling of soil containing organics/excavate
sediment above 10"4 and chemical fixation of soil
containing metals above lO^/institutional controls for
soils between IV4 to 10"6
Excavation/on-site thermal desorption and off-site
landfilling of soil containing organics/excavate
sediment above 10"4 and chemical fixation of soil
containing metals above 10~Vinstitutional controls for
soils between W4 to 10'6
In situ surface biological treatment of soils with
organics above lO^/excavation and in situ biological
treatment of sediment/chemical fixation of soil
containing metals above lO^/institutional controls for
soils between 10"4 and W6
.Ex situ surface biological treatment with organics
above lO^/excavation and in situ biological treatment
of sediment/chemical fixation of soil containing
metals above lO^/institutional controls for soils
between 10"4 and
Excavation/on-site thermal desorption and on-site
landfilling of soil containing organics/excavate
sediment above 10"4 and chemical fixation of soil
containing metals above KTVinstitutional controls for
soils between 10"4 to
Excavation/on-site thermal desorption and on-site
landfilling of soil containing organics/excavate
sediment above 10"4 and chemical-fixation of soil
containing metals above KTVinstitutional controls for
soils between 10"4 to 10'6
In situ surface biological treatment of soils with
organics above KTVexcavation and in situ biological
treatment of sediment/chemical fixation and on-site
landfilling of soil containing metals above 10"4/
institutional controls for soils between 10^ and 10*
Ex situ surface biological treatment of soils with
organics above ICTVexcavation and in situ biological
treatment of sediment/chemical fixation and on-site
landfilling of soil containing metals above 10"4/
institutional controls for soils between 10"4 and 10"6
Estimated
Costs
9 Criteria
$10,515,943
$12,509,818
$11,675,000
$12,474,000
$17,639,733
$19,633,609
$12,870,000
$13,669,000
1036
-4-
-------
7.
Alternative
RAA-lOa
RAA-lOb
ROD
Alternative
RAA-2
RAA-3
RAA-4
,i
Innovative Technology
Excavation/on-site thermal desorptiori and on-sitfe
landfilling of soil containing organics/sediment aibove
lO^/excavation and chemical fixation and off-site
landfilling of soil containing metals above 10"
"/institutional controls for soil between 10"4 to
10"6 (same as 7a except additional groundwater
treatment)
Excavation/on-site thermal desorption and on-site
landfilling of soil containing organics/excavate
sediment above W4 and chemical fixation of soill
containing metals above lO^/institutional controls: for
soils between W4 to W*
Estunated
Costs
9 Criteria
$17,639,733
$19,633,609

r .
Innovative Technology
Thermal desorption of organics-contaminated soil-
sediment/fixation of soil contaminated with metals/
off-site disposal
In situ bioremediatiqn of organics-contaminated soil-
sediment/fixation-of soil contaminated with/off-sile
disposal '.••'•'.
Ex situ bioremediation of organics-contaminatf ;d
soil-sediment/Hxation of soil contaminated with
metals
Estimated
Costs
ROD
$32,388,000
$3,039,000
$4,493,000
How did the cost(s) compare to standard technologies? j
' - - •"['•*.'

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) *
Organics-contaminated Soil/Sediment Above ID"4 Cleanup Level
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Institutional controls
Multilayer cap
Estimated Costs
3 Criteria
$6
$51JOOO
$7,053,000
9 Criteria
$0
. eliminated .
eliminated
-5-
1037
-------
Alternative
RAA-7
RAA-8
Standard Technology
Fixation/on-site landfill
Off-site incineration ,
Estimated Costs
3 Criteria
$3,242,000
$26,857,000
9 Criteria
eliminated
eliminated
Metals-contaminated Soil/Sedinient Above W4 Cleanup Level
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Standard Technology
No action
Institutional controls
Multilayer cap
Fixation/on-site landfill
Fixation/off-site landfill
.Estimated Costs
3 Criteria
$0
N/A
$1,814,000
$219,000.
$171,000
9 Criteria
retained
eliminated
eliminated
eliminated
retained
Organics-contaminated Soil/Sediment Above 10"5 Cleanup Level
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action
Institutional controls
Multilayer cap
Off-site incineration
Estimated Costs
3 Criteria
$0
$51,000
$30,140,000
$481,621,000
9 Criteria
retained
retained '
eliminated
eliminated
Detailed Analyses
Alternative
RAA-1
Standard Technology
No action
Estimated
Costs
9 Criteria
$0
ROD
Alternative
RAA-1 ,
Standard Technology
No action
Estimated
Costs
ROD
$0
1038
-6-
-------
8.
!f a standard technology was chosen, why? ' .

Fixation of metals-contaminated soil and off-site disposal of residuals were selected.
9.
If an innovative technology was chosen, why?
- protect human hea1 a.id the environment by
t , if1"' ™!S {dteraative reduce* contaminant toxicity,, mobility, and volume
treatment via bioremediation of organics contaminated soil/s^iment, and fixation of
* ^ Provideslon^nn effectiveness because treated soil/s^ment
™nl H , *nsin?re* waste management units and institationai controls will be
employed. Following the implementation of these treatments the contaminated levels of the
d ^anics-contaminated soil/sediment will be reduced to c,r below the 10" cancer
P "u *" mdUStnal USe SCenari°- ^ rcmedv Complies witib ARARs and is cost
Ex situ bioremediation is a relatively simple treatment technology that will be «£?

~ '
°d ^ ide"tified RAA-3 (in situ bioremediation) as he preferred alternative
"nd excavation volume based 0" a 10"4 action level for all soil
s, but-only presented a cost and excavation volume for the lO'5 action level for ex
smi bioremediatipn. In the ROD, the EPA analyzed all soil remediation levels at ^ for
easons of comparison. EPA has determined that the increased cost of implementing a lO'5
°reVat i JUStified by *e '***** ™ lon^nn effectiveness and'
S ! reSUlt °f greater SOUrce «*"«ion, for I^und water. In
voWP f - r°dUCeS a greater reductiori in the toxicity, mobility, and '
volume of contaminants through treatment. The only criteria that favcired a .iff* ^ti?n level
were cost and short-term effectiveness. Short-term effectiveness is notia significant factor
however, because it can be easily addressed. The cost between the two iSonSSb
selected remedy was not substantial. When considered in terms of the selected remedy
increase in cost of using the 10'5 action level is accompanied by a proportional i

e°ffect ve6 " "*"* ""*" " ^ C°ndUSi°n ^ US6 °f ^ 10 '
10.

Innovative technologies could be eliminated from the remedial technology selection process at

SStitfess ±1 " ^^ SCTing; dUrfng *e SCreeninS °f ** *™ criteria of '
effectiveness, implementabihty, and cost; or during the detailed evaluation.
" . '' '. I - •,-','
Innovative technologies eliminated during the initial screening include ihe following:

• In situ air stripping was eliminated because it would be most appropriate for VOC
± b'T n°t1S18niflCant «iinants at the site. Furthermore it would co t more
than biological treatment and it would not be effective for shallow, relatively
impermeable surface and subsurface soil. !
« In situ chemical flushing Was eliminated'because it would result1 in ground water
contamination from flushing chemicals and the technical implementability of this ,
-7-
1039
-------
process at theTTte is uncertain. If surfactant flushing was utilized the resulting
emulsions of ;wafer, surfactant and contaminant would be difficult to treat on the
surface. In addition, surfactant tends to disperse and suspend clay and silt particles,
which eventually might result in the formation of a plug decreasing the local
permeability. In turn, this might lead to channeling, decrease the process control, and
threaten the aquifer. Alkaline and alcohol flushing are not as well studied and were
deemed not sufficiently developed to consider further. Alkaline flushing might alter
the soil chemistry and other aspects of the local ecosystem.
• Soil washing was eliminated because it is not a demonstrated, full-scale technology.
Furthermore, the volume of residuals is higher than with solvent extraction.
• Composting was eliminated because it has not been demonstrated on creosote
contaminated soil. Furthermore, surface biological treatment is the most appropriate
biological treatment for this site.
• Liquid/solid slurry was eliminated because.it has been demonstrated on creosote
contaminated soil but it has most often been applied as an in situ process for closure
of surface impoundments containing wastewater and sludge. In at least one case,
residuals had to be further treated in a surface treatment system.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Solvent extraction for organics-contaminated soil/sediment was eliminated because its
effectiveness would need to be verified in treatability tests, and it might not be easily
' implemented because it is an innovative untested alternative which would require
specialized equipment and personnel. Furthermore, it would not provide greater
overall protection than other alternatives and it would be more expensive.

Innovative technologies eliminated during the detailed analysis include the following:

• Thermal desorption was eliminated because it would be more expensive to implement
than the chosen remedy. It also would pose the greatest short-term risk of the
proposed alternatives due to the threat of air emissions.
• In situ bioremediation was eliminated because it would not provide as much
protection, long-term effectiveness, or reduce contaminant toxicity, mobility and
volume as well as the chosen alternative. It would address only surface soil and
treated soil which might contain residuals would not be contained.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment, long-term effectiveness, reduction in
contaminant toxicity, volume and mobility, and cost were the criteria weighted most heavily in
selecting a remedial alternative. RAA-4 was preferred over RAA-3 because it would be more
protective since surface and subsurface soil/sediment would be excavated, treated and isolated
in an engineered containment structure. RAA-3 also would not treat subsurface soil and
therefore could not reduce contaminant toxicity, mobility and volume or provide long-term
effectiveness as well as the chosen alternative. The chosen alternative was the cost-effective
option. RAA-2 also would pfovide high overall effectiveness but it would be much, more
expensive than the chosen alternative. RAA-3 would be much less expensive than the chosen
1040
-8-
-------
12.
alternative but it would not provide as great a degree of long-term effectiveness or reduction in
contaminant toxicity, volume and mobility.
What cleanup goals were selected? If the cleanup goal was based en an ARAR, what was thai
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels were derived for both the excavation of soil/sediment and the treatment of
soil/sediment.
Excavation of Soil/Sediment
Contaminant
Carcinogens
Carbazole (soil)
Carbazole(sediment)
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Dibenzo(a,h)anthracene
Indeno(l ,2,3-cd)pyrene
Benzene
Pentachlorophenol '
Pentachlorodibenzo-p-dioxin
Hexachlorodibenzo-p-dioxin
Heptachlorodibenzo-p-dioxin
Octachlorodibenzo-p-dioxin
Arsenic
Cleanup Level (mg/kg)

2,222.22
23.2
1,250
5,988.02
146.41
117.51
15.02
13.91
578.03
2,557.54
1^90.36
0.000303
0.001517
0.015175
0.151745
6.134969
AKAR or Other Basis

Risk"
Ecologicalb
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
i Risk
Risk
Risk
"Health-based cleanup levels ensure that a cumulative cancer risk' level of 10'5 is
achieved in unexcavated soil.
'The cleanup level for carbazole in sediment is-based on ecological risk factors.

Treatment of Excavated Soil
Contaminant
Cleanup Level (mg/kg)
AIIAR or Other Basis
Carcinogens
Benzo(a)pyrene
15.2
Risk8
-9-
1041
-------
Com liant
Dibenzo(a,h,onthracene
2,3,7,8-TCDD equivalent
Pentachlorophenol
Lead (K001 Constituent)
Arsenic
Cadmium
Lead
Cleanup Level (rag/kg)
13.9
0.0006
90-99%
99-99.9%
5
1
5
ARAR or Other Basis
Risk
Risk/treatment level"
LDRsc
LDRs
TCLP"
TCLP
TCLP
Noncardnogens
Naphthalene
Phenanthrene
Pyrene
Toluene
Xylene (Total)
95-99%
95-99%
95-99%
0.5-10
0.5-10
LDRs
LDRs
LDRs
LDRs
LDRs
These treatment levels fall within the 10"6 to 10'7 risk range for an industrial use
scenario. .
"Laboratory detection limitations may not allow measurement to this level. In that
case, the detection limit will be the treatment level. The currently recognized detection
level of 1 ug/kg corresponds to a cancer risk level close to 10"5.
"Remedy will comply with LDRs through a Treatability Variance. Treatment levels or
percent reduction ranges that ex situ bioremediation will attain are presented.
•"Action levels are based on non-wastewater TCLP (mg/L).
75. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? •

Innovative technologies eliminated because of cleanup goals include: ,

" None

Standard technologies eliminated because of cleanup goals include: , ,
t • ' • *
• None ' •
14, Were treatability studies conducted on the innovative technology or standard technology?
The efficiency of several technologies'was evaluated for the screening of alternatives. .
Technologies evaluated include: in situ surface biological treatment, ex situ surface biological
treatment, solvent extraction, chemical fixation, and thermal desorption;
1042
-10-
-------
15. What measures/criteria were used to compare alternatives? i
' • - ' X* . : | '. ' "
The following measures were used to compare the alternatives: i
• ' !
Risk level achieved I
Cost-effectiveness i .-.-•
Proven reliability
Waste left in place/institutional control

16. How are measures, compared?

Ex situ bioremediation was preferred over thermal desorption because it would be more easily
implemented. Ex situ bioremediation is a relatively simple treatment technology, easy to
construct and operate, and has been successfully implemented at other sites Thermal
desorption is a new and more complex technology and requires specialized equipment and
knowledge which makes it more difficult to procure, construct, and operate. In addition air
quality matters in the Denver Metropolitan area might make thermal desorption more difficult
to implement. In situ bioremediation was not preferred because it would not treat subsurface
soils and control of residual risk would be more dependent on institutional controls The
chosen alternative is cost effective. RAA-2 also would provide high Derail effectiveness but
it would be much more expensive than the chosen alternative. RAA-3 would be much less
expensive than the chosen alternative but it would not provide as great a degree of long-term
effectiveness or reduction in contaminant toxicity, volume, and mobility
17.
What technical considerations were factors in selecting a remedy? Were technical •
considerations primary in the selection of the remedy? ,

Technical considerations were not primary in selecting a remedial alternative. Impervious site
soil, however, would preclude the use of in situ air stripping.
-11-
1043
-------
Central City-Clear Creek
OU-3

Gilpin and Clear Creek Counties, Colorado
RegionS
GENERAL SITE INFORMATION
7.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? .

Maximum concentrations of principal
contaminants were:

Tailings/Waste Rock (mg/kg)
Arsenic
Lead
630 ,
2,810
2.
What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/83
9/91
9/30/91
Background

PRP-lead .
PRPs: not yet determined
FS prepared by: Camp Dresser &
McKee Inc.
• . 1,170,800 cubic yards of taijings/waste rock piles

3. What type of site is this?

Mining. An ore mine.. , .

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: •

Access restriction: Inspection, resident relocation, fencing, deed restrictions
Containment: Retaining walls, recontouring, grout stabilization, synthetic liners,
pavement cap, soil cap, cement cap, clay cap, RCRA cap, vegetative
cap ,'•••••
Chemical treatment: Neutralization
Thermal treatment: Incineration
Disposal:
.U * W* A* V*. Mfc* v» - • ^
Excavation, on-site disposal, off-site disposal at RCRA landfill
1044
-i-
-------
5.
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: ;
,- i

Biological treatment: Biodegradation

Chemical treatment: Soil washing, soil flushing, hydrometallurgical njprocessing-chemical

leaching, hydrometallurgical reprocessing-froth flotation

Thermal treatment: Pyrolysis, in situ vitrification, pyrometallurgical reprocessing
" ' - I
: - ... .._-•• • j
~! - ' ' ' ' ! ' -"' '

What was the cost estimate for the innovative technology? '••. '

During the initial screening process, in which technically feasible technologies are identified

(pnor to the formulation of RAAs), the FS does not quantify costs. After me RAAs have teen

formulated costs are estimated as part of a three-criteria screening proceiss (effectiveness

implementabihty, and cost) to identify alternatives that merit a more Detailed evaluation The

KCaICUlated during M Cation based on the nine criteria established
No : innovative technologies were incorporated into remedial action allernatives and no cost
estimates were made.
7.
How did the cost(s) compare'to'Standardtechnologies? '

Media-specific remedial alternatives (i.e., tailings/waste rock) were developed for the three-
cntena screening process, and site-wide remedial alternatives were developed for the detailed
analyses. The results of these two processes are presented separately.!

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Tailings/Waste Rock Alternatives
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action/annual inspection
Access restrictions/slope recontouring/
sediment traps/on-site disposal of
collected sediment
Excavation/hydrometallurgic
reproces$ing-froth flotation/ on-site
disposal
Recontouring/installation of retaining .
walls/soil cap/sediment traps/use
restrictions
Estimated Costs
3 Criteria
$110,000
$3,590,000
$33,3(K),000
$3,780,000
- ••• v" " • . -2- -. V ; . ; \. :' ',.
9 Criteria
retained
retained
eliminated
retained
1045
-------
Alternative
RAA-5
RAA-6
RAA-7
Standard Technology
On-site consolidation/disposal cell
development/land acquisition/
excavation/transport/on-site disposal/use
restrictions

Excavation/transport/off-site disposal/
use restrictions
• .. i.^u^^-*m
Fixation of tailings and waste rock/use
restrictions
Estimated Costs
3 Criteria
$15,490,000
$23,350,000
$5,570,000
9 Criteria
retained
eliminated
eliminated
Site-Wide Alternatives: these combine the Tailings/Waste Rock Alternatives and the Surface
Water Alternatives and were the only alternatives that, underwent detailed evaluation.
Alternative
••—^p*—«—•
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
Standard Technology
No action/annual inspection/ground and
surface water monitoring
_^^^—^•^•••^•^^••^^^••^^•••^•'''•^—
Access restrictions/slope recontouring/
sediment traps/oh-site disposal of
sediment/passive discharge and water
treatment in artificial wetlands
Estimated Costs
3 Criteria
N/A
N/A
Recontouring/installation of retaining
walls/soil cap/sediment traps/use
restrictions/passive water treatment
Recontouring/installation of retaining
walls/soil cap/sediment traps/use
restrictions/active discharge and water
treatment
N/A
Recontouring/installation of retaining
walls/soil cap/sediment traps/use
restrictions/passive discharge and water
treatment in artificial wetlands/pump
and treat ground water
N/A
N/A
On-site consolidation/disposal cell
development/land acquisition/
excavation/transpqrt/on-site disposal/use
restrictions/discharge water treatment/
pump and treat ground water
N/A
9 Criteria
$550,000
$23,890,000
$24,080,000
$33,400,000
$28,630,000
$50,820,000
4»
1046
-3-
-------
5.
Alternative
Selected
Alternative
Standard Technology
Institutional controls/soil cap/passive
treatment of some discharge water/
active treatment of some discharge
water/pump and treat ground water
Estimated Costs
3 Criteria
N/A
9 Criteria
$23,510,000a
The selected alternative and associated costs were developed and presented in the ROD.
'

If a standard technology was chosen, why?
critical components
-5 and RAA-6. /The selected alternative combines institutional controls and runoff
barriers for mine waste piles at active mill sites, soil capping of the olher mine wastTpUes
active treatment^ one tunnel, passive treatment of one tunnel, and a grounTater p^mp wd-
treat system, Tins provides the greatest protectiveness of human health and the enSoTmeT
complies with ARARs, reduces mobility of waste contaminants, reduces toxicity of wateT
contaminants, minimizes implementation time, and is the most cost-effective RAA-1 was not
chosen because lt would not provide adequate protection of human health and aquatic
of I± T TPlyATh. A^ARS- RAA'2 WaS 6liminated because * would not be
life RAA ^"L ' ^ f^-4 W^ diminated beCaUSe they WH^1 ^t protec
hfe. RAA-5 was eliminated because it would not be cost-effective. RAA-6 was eliminated

to five times longer
9.
. . -
If an innovative technology was chosen, why?

An innovative technology was not chosen to remediate tailings and waste rock. An innovative
10.
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the thSe criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include tljie following:

• Biodegradation was eliminated because it^^ would not be effectivib for inorganic
contaminants such as arsenic and lead. [
• Soil flushing was eliminated because solvent loss during the recovery process
potently could contaminate the environment. In addition, regiilatory agency
approval would be difficult to attain * CI^aSency
-4-
1047
-------
1L
• Pyrometallurgical reprocessing was eliminated because no space exists to build a
smelter, and disposing of generated slag would be difficult.
• Hydrometallurgical reprocessing (chemical leaching) was eliminated because of
potential implementation difficulties. Site metals are present in an insoluble sulfide
form, which would require oxidation prior to leaching, and oxidation technologies for
sulfides have not been developed fully. j-,
• Pyrolysis was eliminated because the technology would be expensive and not readily
available, and implementation would be difficult due to site topography.
• ' In situ vitrification was eliminated because the technology would be expensive and not
readily available, and implementation would be difficult due.to site topography.
• Soil washing was not incorporated into an RAA for detailed analysis, even though it
was not eliminated explicitly during initial screening. Its effectiveness was questioned
because the leaching process would be inhibited if metal contaminants were
incorporated into crystal matrices.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Hydrometallurgic reprocessing (froth floatation) (RAA-3) was eliminated because it
would not be cost-effective in comparison to other alternatives that provide similar
levels of protectiveness (on-site consolidation and removal and off-site disposal).
^ '
No innovative'technologies were eliminated during the detailed analysis.

The most heavily weighted criteria used to select a standard technology were cost-effectiveness
and protectiveness of human health and the environment. One innovative technology,
hydrometallurgic reprocessing (froth flotation), was eliminated because it would not be cost-
effective.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish .cleanup goals?
1048
Contaminant,
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Arsenic
130
Risk8,
Noncarcinogens
Lead
500
OSWERb, Model0
The action level for arsenic was determined based on a target cancer risk level of 10'5.
Remediating arsenic to a level that reflects a cancer risk level of 10"6 (11 mg/kg) was
proposed initially, but this level was expected to be impossible to reach, since the
geometric mean background levels were greater (13 mg/kg).
-5-
-------
•- .

'Office of Solid Waste and Emergency Response Directive No. 9355 4-02

esdmates *)»* lead Iev^ in children
reSUlt of ^ "odel was in accordance
technohgy eiimin^^ Va
technology was chosen, could it meet the cleanup goals?

No innovative technologies were eliminated because of cleanup goal Tie standard
technology selected could meet cleanup goals. • •! ' sranaaM
14.
Were treatability studies conducted on the innovative technology or standard technology?
various fixative alternatives and reprocessing technologies. These
ic ,nH i « Otatl°n W3S ^ best suited reProcessirig technology for use on a
is and several fixation treatments remove metals from leachates.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Permanence
Time to design/cbnstruct/operate

16. How are alternatives compared?
.
longer implementation time and much higher cost. ™*f*a. oecause ot its
17.

-6-
1049
-------
Chemical Sales Co., OU-1
Leyden Street Location

Denver, Colorado
RegionS
GENERAL SITE INFORMATION.

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

1,1,1-Trichloroethane 1 ,
Trichloroethene 0.95
Tetrachloroethene 80

Table 5-1 presented on page 5-2 of the FS
provides a list of contaminants detected in
soils. The units, however, are presented as
ug/L and the contaminants do not coincide
with those listed in the ROD as
contaminants of concern.
Site .History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
8/90
2/91
6/28/91
Background

PRP-lead
PRPs: Chemical Sales Co., Interstate
Distribution Center Associates
(ICDA), Ltd.
FS prepared by: Engineering-Science,
Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• Approximately 225,000 cubic yards of soil
What type of site is this?

Chemicals and Allied Products. This site was used as a product warehouse. The site
contained warehouse, tank farm, and fenced yard, and is located in an industrial area.
•Previous land use may have included landfilling activities between the mid-1950s and the early
1970s. .
1050
-i-
-------
TECHNOLOGY SELECTION !

4. What standard technologies were considered for selection in this F&?
, - . | • '"
Standard technologies considered during the identification and screening of technically feasible
technologies were: . i

Access restriction: Fencing, land use controls (deed restrictions~"Industry Only Use",
removal/relocation of structures, excavation restrictions)
Containment: Clay cap, asphalt/concrete cap
Physical treatment: Soil spreading (evaporation)
Thermal treatment: Incineration
Disposal: Excavation, off-site hazardous waste facility
6.
. .
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification, and screening of technically
feasible technologies were:
i, •
Biological treatment: Biological slurry reactors, in situ aerobic degradation, in situ anaerobic
degradation
Phys/Chem treatment: Soil washing with chemical oxidation, in situ surfactant-enhanced soil
washing, vapor extraction
Thermal treatment: Low-temperature thermal ,desorption, in sito radio frequency heating
,. • -- • • • •-
What was the cost estimate for the innovative technology? ' '
. • . . : . . , • . |

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. ^e:r the RAAs have been
formulated, costs are estimated as part of a three-criteria screening prbcesis (effectiveness
implementability, and cost) to identify alternatives that merit a more detailed evaluation ' The
Stl GOStS theD m recalculated during an evaluation based on npe criteria established by
' ' • '
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-4
RAA-5
Innovative Technology
Soil vapor extraction/ground water
extraction and treatment
Soil vapor extraction/ground water
extraction and treatment
Soil vapor extraction/ground water
collection and treatment
Estimated Costs
3 Ciiteria
$2,886,400
$3,391,000
$2,452,0)0
•'•'•, - -2- ' - ' ';:
9 Criteria
$1,922,000
eliminated
$2,031,000
•f '-r\
1051
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-6
Scenario 1
RAA-6
Scenario 2
.Standard Technology
No action
Institutional actions (fencing, land use
control, well restrictions, public ,
awareness)/point-of-use ground water
treatment
Additional ground water treatment
Additional ground water treatment
Estimated Costs
3 Criteria
, $769,210, %
$605,000
$1,763,000
$769,469
9 Criteria ;
$301,000
eliminated
j
eliminated
eliminated
8. If a standard technology was chosen, why?

No standard technology was chosen
9. If an innovative technology was chosen, why?

RAA-5 reduces the toxicity, mobility, and volume of contaminants in soil through vapor
extraction. Soil vapor extraction pilot tests were carried out at the site. Based on the high
VOC removal rates, large radius of influence, and homogenous nature of the soil, the results of
these tests indicated that vapor extraction is extremely effective in removing site contaminants.
Release of emissions from this treatment would be negligible and would pose minimal risk.
Vapor extraction was selected to eliminate the need for excavation. Excavation would cause
disruption to buildings at the site. All RAAs proposed the same soil treatment technology:
vapor extraction. Therefore, an RAA was selected based on ground water treatment
technology effectiveness.
Id. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

H Soil washing with chemical oxidation was eliminated because the technology has not
been proved.
1052
-3-
-------
11.
• Biological slurry reactors were eliminated because the technology has not been proved
for chlorinated contaminants. ,
• In situ surfactant enhanced soil washing was eliminated because it requires very coarse
soils and additional ground water treatment to remove/separate surfactants. Also the
technology has not proved on a full scale.
• , In situ aerobic biodegradation was eliminated because it has been proved only in an
aqueous laboratory reactor. It has not been proved for soils applications and would
not degrade tetrachloroethene.
• In situ anaerobic biodegradation would degrade tetrachloroeithene and would produce
vinyl chloride as a degradation product. It also would be difficult to maintain
anaerobic conditions in situ.
• Low-temperature thermal desorption was eliminated because: large quantities of soil
would be excavated. Excavation would disrupt existing buildings and structures and
volatile contaminants could lead to unacceptable worker exposures.
•. In situ radio frequency heating was eliminated but no explanation was provided.

Innovative technologies eliminated during the screening of the three criteria include the
following:
• ' ' -'•;•'•'..••. : •. ',[.-. •'. • •
• . None- / •''-.' . . • ' '• • - i- • • '•'-..'
• 'i '' -.",'',

Innovative technologies eliminated during the detailed analysis include the following:
' i * '' l . " '
• None •"'•"• i -
Which of the nine criteria were weighted most heavily in selecting tfie technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Soil vapor extraction was the only remaining soil technology. Therefore, the nine-criteria
screening had no impact on the choice of technology.
12.
, , ? Ifth£ CleaWP 8°al WOS based <^ an ARAR, what was that
risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm)
Carcinogens
Tetrachloroethene
Trichloroethene
1,1,1 -Trichloroethane
Noncarcinogens
1,1 -Dichloroethene
1,1 -Dichloroethane
Vinyl Chloride
0.150
0.115
4.400
0.105
0.090
0.012
-4-
ARAR or Other Basis
; MCL
MCL
MCL
MCL
10I6 risik level
MCL
1053
-------
13.
ARAR or Other Basis
Cleanup Level (ppm)
Note- Soil remediation cleanup levels were determined based on the leaching of soil
contaminants into the underlying ground water. Cleanup levels were calculated by
multiplying the acceptable concentration of leachate from the soil by the site-specific
partition coefficient for the soil (based on batch and column adsorption studies for OU-
2 at the site). ':'.-'•

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• In situ anaerobic biodegradation

Standard technologies eliminated because of cleanup goals include:

• None -.'"'•
14. Were, treatability studies conducted on the innovative technology or standard technology?

Successful pilot tests were conducted for soil vapor extraction. VOCs were rapidly removed
from the subsurface. .
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability
Time to design/construct/operate
Capital costs vs. operational costs
Impact on nearby populations
16. How are measures compared? •

The lack of proven reliability was used to eliminate a number of technologies during the initial
screening. The time taken to reach cleanup levels using RAA-5 (less than 10 years) versus
RAA-3 (30 years) was a primary factor in choosing RAA-5. Operational and maintenance
(O&M) costs and capital costs are compared for RAA-3 and RAA-5. It is noted that RAA-3
has lower capital and O&M costs, however, because of the longer implementation time of
RAA-3, present worth costs are similar. The impact on local populations (and site workers) is
mentioned as a benefit of in situ technologies such as vapor extraction.
1054
-5-
-------
17.
What technical considerations were factors in selecting a remedy?, Were technical
considerations primary in the selection of the remedy? "cnnical

.1 . •

Pilot tests on soil vapor extraction at the site indicated that the soils Within the test area
rda^y homogenous and that there is a large radius of influence (due ,o Sati

ZL 8 f f ?B?ae**aX* Soil vaP°r extra<*°" is therefore extremely sui Tte
dominance of sand and permeable soils on the site, and the relatively low organic content of
the soils are both factors which improve vapor recovery. I

Consideration was given to preserving existing structures located on the site For th« r^™
*
-6-
1055
-------
Denver Radium Site
OU-8

Denver Colorado
Region 8
GENERAL SITE INFORMATION
1, What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?
Maximum concentrations of principal
contaminants were:
Soil(mg/kg)
Equivalent radium-
226 cone. 570 pCi/g
Arsenic 598
Lead 1,260
Molybdenum 48,800
Selenium 7,980

Site History
NPL Proposed: N/A
NEL Final: 9/8/83
f\ //\1
FS: 9/91
ROD: 1/28/92
Background
PRP-lead
PRPs: N/A
FS prepared by: Colorado Dept. of
Health1

2. What volume of material is to be
remediated? ,

The volume of material to be remediated included:

• 49,000 cubic yards of soil , .

3. What type of site is this? ,

Mining. The site is a former minerals processing facility located in an urban area. The land
use around the site is commercial/industrial.
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: -

Access restriction: Fencing, deed restrictions ,
Containment: Capping, subsurface barriers • .
Chem/Phys treatment: Stabilization (bitumen or asphalt, cement, resins), mechanical
separation, physical concentration
'ft-,
1056
-i-
-------
5.
Thermal treatment: Incineration
Disposal: Excavation, off-site disposal, on-site disposa
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: N

Biological treatment: Biological treatments (unspecified)
Phys/Chem treatment: In situ solution mining, sulfuric acid leachinji/sulfate conversion soil
gas extraction i '
Thermal treatment: Ex situ vitrification (electric furnace fusion, lotaiy kiln), in situ
vitrification
6.
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
fcTl t H fT ' rf*AA»>. the FS does not quantify costs. Met the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness implementability, and cost) to identify alternatives that merit a more detailed
evaluation. A three-criteria screening of the RAAs was not carried out in this FS. Estimated
costs were calculated during an evaluation based on nine criteria established by the NCP.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
======
Alternative
RAA-4
RAA-7
'
Innovative Technology
Facility removal/excavation/on-site
consolidation/vitrification/compacted
soil cap
Facility removal/excavation/mechanical
separation/on-site chemical leaching/
backfilling with decontaminated soil/
off-site disposal
. ' •
. ' • • ' '
Estimated Costs"
3 Criteria
N/A
i
1
N/A
i •
•
9 Criteria
$38,300,000
($42,400,000)
$43,300,000
($47,400,000)
"Costs in parentheses are for costs presented in the Proposed Plan.
1057
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-5
RAA-6

Standard Technology
No action
Restrict site access (fencing, deed
restrictions)/excavation/on-site
disposal/off-site disposal/monitoring
Facility removal/excavation/on-site
consolidation/clay cap/institutional
controls
Facility rempval/excavation/stabiliza-
tion/on-site disposal/compacted soil
cap
Facility removal/excavation/off-site
disposal/backfilling with clean soil
Estimated Costs*
3 Criteria
N/A
N/A
N/A
N/A
N/A
9 Criteria
$323,000
($400,000)
$6,300,000
($6,300;000)
$15,000,000
($19,100,000)
$26,600,000
($30,700,000)
$36,800,000 to
$48,800,000
($40,900,000)
•Costs in parentheses are for costs presented in the Proposed Plan.
8. If a standard technology was chosen, why?

In the Proposed Plan, RAA-6 was the selected remedy. Following public comment on the
statutory preference of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) for onsite remedies and for remedies that reduce toxicity, mobility, or
volume through treatment, a reevaluation of alternatives was initiated. Following the
reevaluation, RAA-5 was selected. Both alternatives attain the threshold criteria; however,
stabilization appears, based partially on new information, to be preferred given the balancing
criteria The selected remedy protects human health and the environment through excavation
and removal of contaminated soils at part of the site, and consolidation and stabilization of
these soils and other contaminated soils at the site. The selected remedy reduces site risks to
potentially exposed populations by stabilizing and capping the contaminated soils. The site
will not pose a threat to nearby residents and workers after remediation is completed. The
selected remedy attains the health protection requirements of CERCLA and the National
Contingency Plan (NCP). The selected remedy immobilizes the source of ground water
contamination. Restoration of ground water quality is expected to occur through attenuation
over time Of all the alternatives, the selected remedy provides the best overall effectiveness
proportional to its cost. The selected remedy provides long-term effectiveness and permanence
by reducing the radon emanation of the contaminated soils, shielding gamma radioactive
material to near background levels, and reducing the potential for contaminants to leach to
ground water. The selected" remedy utilizes treatment to reduce contaminant mobility. The
1058
-3-
-------
selected remedy effectively reduces the hazards posed by all of the contaminants at the site at
a lower cost than the other alternatives. i
-•'•-. .'_'•' •' , '•- | . ' . : •
' , ' : - - . . ; -_^ . ,
9. If an innovative technology was chosen, why? I

An innovative technology was not chosen.
• .._-." ' " |., - . .
-'•.•. ' - . i '. ',."'".'••
10. If an innovative technology was not chosen, why[not? At what stage v?as the innovative
technology eliminated?

- Innovative technologies could be eliminated From the remedial technology selection process at
three stages: during the initial screening; during the screening of the iW criteria of
effectiveness, implementability, and cost; or during the detailed evaluajtiorii.

Innovative technologies eliminated during the initial screening include the following:

• Biological treatments were eliminated because although certain aromatic organic
compounds are biodegradable at dilute levels, heterocyclie organics and polycyclic
aromatics (such as those observed in contaminated soil at the siite) are generally less
biodegradable or essentially non-biodegradable. Furthermore, high concentrations of
heavy metals might adversely affect biodegradation of some contaminants.
• In situ solution mining was eliminated for the following reasorls: Bench-scale
chemical extraction treatability studies performed in support of this FS showed
removal efficiencies of greater than 90 percent for uranium; however, removal
efficiencies were lower for many of the contaminants present on the site, e.g., thorium-
230. While the studies indicate that the extraction process can be modified to attain
greater than 90-percent removal of thorium-230, the process studied involves in-plant
treatment of the soil after particle size reduction rather than in situ treatment. Further
the treatability study proposed is a staged, sequential treatment technology requiring
, the use of many hazardous reagents. !
• Ex situ vitrification was eliminated because the two. processes (electric furnace fusion
and rotary kiln) are considered to be technically unfeasible because: of the lack of a
suitable facility, uncertainty with environmental control of the process, plus problems
of dismantling and disposing of a potentially radioactively contaminated process
facility.
• Soil gas extraction was eliminated for the following reasons: This technology would
not be successful for treating semivolatile contaminants at the site (e.g., anthracene
chrysene, and phenanthrene). These polynuclear aromatic compounds are relatively
nonvolatile, having minimal vapor pressures at temperatures of less than approximately
200 C. Accordingly, insignificant concentrations of these species are present in soil
gas at ambient temperatures (i.e., approximately 20°C) and, therefore, soil gas
extractionis not an(effective technology for such contaminants.! Preliminary field
measurements indicate that VOCs are present over some relatively large subsurface
soil areas on the property. Additionally, windrowing and aerating VOC-contaminated
soil can be accomplished during the removal/disposal alternative. Lastly, the
technology would not eliminate radioactive contaminants.
-4-
1059
-------
Innovative technologies eliminated during the screening of the three criteria include the
following: . • . .

• None

Innovative technologies eliminated during the detailed analysis include the following:

• In situ vitrification was eliminated because the longer time period required to
implement RAA-4 would allow for exposure of workers to gamma radiation., This
concern stems from the length of exposure and the proximity to the gamma radiation
sources. The technical feasibility of adequately dewatering the site to facilitate in situ
vitrification was of "significant concern." In addition, the implementability of the
technology on a large scale is uncertain since the technology is innovative and
experience with large-scale implementation is very limited. Further, stabilization is
expected to achieve the same results for less cost.
• Sulfuric acid leaching/sulfate conversion was eliminated because RAA-4 (excavation
and off-site disposal) would achieve similar results for less cost and without the added
uncertainty of operating a chemical process facility on the site.
J iL
11 Which of the nine criteria were weighted most heavily in selecting the technology? .Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of,a standard technology?

The reduction of toxicity, mobility, or volume through treatment, and the cost balancing
criteria were weighted most heavily in selecting a technology. RAA-5 (stabilization) is more
feasible than RAA-4 (vitrification) because similar results are expected for less cost; and RAA-
6 (excavation and off-site disposal) is more feasible then RAA-7 (onsite chemical leaching)
because similar results are expected for less cost arid without the added uncertainties of
operating a chemical process facility. RAA-5 satisfies the statutory preference for treatment by
reducing mobility. RAA-6 would not satisfy this preference. RAA-6 is estimated to cost
$10.2 million to $22.2 million more than RAA-5, the range indicating the uncertainty
associated with the disposal cost at a location which is currently the only commercially
available facility. RAA-6 may not be cost effective in proportion to its overall effectiveness
and it does not appear to be as cost effective as RAA-5.
12. What cleanup goals were selected? If the cleanup goal was basedfon an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level
ARAR or Other Basis
Carcinogens
Radium-226
Gamma radiation
Radon progeny
Uranium-natural •
5/15 pCi/g"
20 microRoentogens/hr
(above background)
0.02 working levels
75 pCi/g
40 CFR 192.12(a)
40 CFR 102.12(b)(2)
40 CFR 192.12(b)(l)
U.S. DOE 5480.1
1060
-5-
-------
Contaminant
Thorium-230 in soil
Arsenic
Cleanup Level
42 pGi/g
160 mg/kg
ARAR or Other Basis
Calculated from radium
levels
Risk
Noncarcinogens
73.
For carcinogens, an excess upper bound individual lifetime cancer risk of between 1Q-4 to lO"6
was acceptable. For noncarcinogens, a Hazard Index less than or equiil to 1.0 was acceptable.
of the cleanup goal>? Could ^standard
Innovative technologies eliminated because of cleanup goals include: \

• None • " ' . •,...••' !
- i

Standard technologies eliminated because of cleanup goals include:

•' None " , '.'.'• • -•
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted on'the following standard technologies:

" TTeay>Mty sto&es of physical separation were conductedto test the technical
feasibility of screening the soils to reduce the volume of radioactive soils. The results
obtained (by both Colorado Department of Health and Shattuck|Chemical Company a
prev10us owner of a portion of the site), indicate significant vokme reduction might be
technically feasible. The studies showed that for some of the contaminated soils wet
.screening separates the contaminantssuch that only theTine particlesrequire '
management as contanunated material, thereby reducing the volume of contaminated
matenals. Since the treatability studies were not extensive enough to definitively
detennme the overall cost, effectiveness, and implementability oif screening, the
ootential volume reduction that screening could account for was not factored into the
Treatability testing of stabilization of site soils vvas conducted bir the Shattuck
Chemical Company. The tests showed that stabilization immobilized the contaminants
reduced radon emanation (to below the 40 CFR 192 Subpart A'topa-1 stSoS
pCi/m /s) and resulted in a concrete-like stabilized mass. Large-scale pilot testing
-6-
1061
-------
would be necessary prior to full scale implementation in order to refine design
parameters and as additional verification of the implementability of the technology.

Treatability studies were completed on the following innovative technologies:

• Bench-scale chemical extraction treatability studies performed in support of in situ
solution mining for this FS obtained removal efficiencies of greater than 90 percent for
uranium, however, -less than that for many of the contaminants present on the site, e.g.,
thorium-230. While the studies performed indicate that the extraction process can be
modified to attain greater than 90-percent removal of thorium-230, the process studied
involves in-plant treatment of the soil after particle size reduction rather than in situ
treatment. Further, the treatability study proposed is a staged; sequential treatment
technology requiring the use of many hazardous reagents. The physical character of
the contaminated soil in place at the site is not suitable for the type .of contact required
to achieve appropriate removal efficiencies for all target contaminants. There are
significant uncertainties with respect to the ability to intercept the hazardous solutions
bearing dissolved contaminants with drawdown recovery wells. The inability to
intercept such solutions could result in increased ground water degradation.
• A bench-scale test of vitrification was conducted. The test showed that over a period
' of about 6 hours the soils melted. After cooling, the mass assumed a glass-like
structure, which effectively immobilizes heavy metals and radioactive contaminants.
Larger scale pilot testing would be necessary prior to full-scale implementation in
order to refine design parameters and as additional verification of the implementability
of the technology. , ,, . .,
• Treatability studies were performed to explore the feasibility of utilizing sulfuric acid
leaching/sulfate conversion to remove radioactive contaminants from site soils.
Chemical treatment was demonstrated as a means of removing the contaminants from
the soils, enabling the bulk of the contaminated soils to be placed back on the site.
The contaminants would be concentrated, resulting in a smaller volume of higher
toxicity materials, which would be disposed of off site.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Preference for treatment (vs. containment)
Waste left in place/institutional control

16. How are measures compared?

RAA-5 (stabilization) satisfies the statutory preference for treatment by reducing mobility
through treatment. RAA-6 (excavation and off-site disposal) would not satisfy this preference.
In comparing RAA-5 and RAA-6, it was discussed that stabilization wastes would remain on
site, limiting future land use and requiring long-term monitoring and maintenance.
1062
-7-
-------
17.
What technical considerations were factors in selecting a remedy?
considerations primary in the selection of the remedy?
'
Were technical
d Selecting a rcmedy- * silu soluti°« "Amg was
ehimnated, however, because the physical character of the contaminated! soil in olace at the
s^ ,s not suitable for the type of contact required to achieve "iWR^^SSSiL
for aH target contarmnants. Further, there are significant uncerSnties with respect to ie
abihty to mterceprthe hazardous solutions bearing dissolved contaminants with drawdown

^ l° '* C°uld resullt fa -creas - g-unTwater
-8-
1063
-------
Denver Radium Site
GU-9

Denver, Colorado
Region 8
GENERAL SITE INFORMATION
L
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

Lead
Arsenic
Zinc
35,800
490
32,050
2.
What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
1983
7/31/91
12/31/91
Background

EPA Fund-lead
PRPs: U.S. Bureau of Mines
FS prepared by:. URS Consultants,
Inc.
The volume of material to be remediated included:

• 16,540 cubic yards of soil

3. What type of site is this?
e
Mining. An abandoned brick plant located in an industrial area.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Chemical treatment:
Disposal:
Deed restrictions, zoning
Capping (clay, soil, asphalt, concrete, multimedia synthetic membrane)
Solidification/stabilization
Excavation, disposal (off-site, on-site)
1064
-i-
-------
5.
Was an innovative technology considered in the FS? If so, which technology?
Innovative technologies considered during the identification and screening of technically
feasible technologies were: ! ••
Thermal treatment: Vitrification i .
6.
7.
What was the cost estimate for the innovative technology?
'' ' - . - - !
During the initial screening process, in which technically feasible tecllnologies are identified
foZM H6 fT °n °f R^As)'.the FS does not I™*"? costs. After the RAAs have been
formulated costs are estimated as part of a three-criteria screening process (effectiveness
implementabihty, and cost) to identify alternatives that merit a more detailed evaluation 'The
estimated costs then are recalculated during an evaluation based on nine criteria established by
I? ff long-term effectiveness and permanence; short-term effectiveness; compliance with
ARARs; protectiveness of human health and the environment; reduction in contaminant
state/suPP°« ^ncy acceptance; and
RAAs were renumbered in the ROD; these changes are presented parenthetically below.
No innovative technologies were incorporated into remedial alternativels

How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA.l
RAA-2
\
RAA.-3
(RAA-2)
>
RAA-4
(RAA-3)
RAA-5
(RAA^4)
RAA-6
(RAA-5)
11
Standard Technology
No action
Demolish existing structures/clay-soil
cap
Utilize concrete floor and asphalt
parking lot as cap/clay cap surrounding
areai
Utilize concrete floor and asphalt
parking lot as cap/soil cap
surrounding area
Excavatiori/off-site disposal/institutional
controls
Excavation/solidification-stabilization/
on-site disposal/institutional controls
Estimated Costs
3 Criteria
$174;300
$9,330,200.
$2,65<),000
| . •
$1,701,900
•- • i
$10,392,200
-- i
$9,912^000
9 Criteria
$174,300
eliminated
$2,656,000
$1,702,000
$10,392,200
$9,912,000
1065
-------
8. If a standard technology was chosen, why?

RAA-4 was chosen because it eliminates direct contact with, and inhalation or ingestion of
contaminated soils at the site through a combination of engineering, capping, and institutional
controls. Long-term maintenance is required to ensure long-term effectiveness. The chosen
alternative was preferred because it takes the least amount of time to implement and involves
the least disturbance of contaminated materials, thereby presenting the least nsk to on-site
workers and the surrounding communities. The preferred alternative utilizes standard
technologies and is readily implementable. The chosen alternative complies with all ARARs
and is cost-effective.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
JO. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .

Innovative technologies eliminated during the initial screening include the following:

• In situ vitrification was eliminated because it would not be as available or
implementable as stabilization/solidification. Also the cost would be much greater
than for stabilization/solidification. Further, laboratory and pilot testing would be
necessary to demonstrate its effectiveness.

Innovative technologies eliminated during th& screening of the three criteria include the
following: •

• None

Innovative technologies eliminated during the detailed analysis include the following:

» None • , '
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Short-term effectiveness and cost were the criteria weighted most heavily hi selecting a
remedy. While all other action alternatives offered comparable protection and long-term
effectiveness, the chosen alternative provides the best short-term effectiveness and is the lowest
in cost.
1066
-3-
[,,.
-------
12.
13.
75.

/ WaS bon an ARAR, what was that
risk level was selected to establish cleanup goals? . •
Contaminant | Cleanup Level (mg/kg) j ARAR or Other Basis
Carcinogens
Noncarcinogens
••^

Zinc
Tor carcinogens, an excess upper bound individual lifetime
to 10 was acceptable. For noncarcinogens, a Hazard Index
was acceptable.
"Interim Guidance on Establishing Soil Lead Cleanup Level'
OSWER Directive 9355,4-02, September 7, 1989. . ' '
cancer risk of between 10"4
less man or equal to 1.0

at Superfiind Sites,
Was the innovative technology eliminated because of the
technology meet the cleanup goals?
cleanup goals? Could the standard
Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or,

Treatability studies were not conducted.
What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness - .
-; .-.'. Time to design/construct/operate

16. How are measures compared?

The chosen alternative was preferred because it is comparable in pr
and long-term protection with all the other action alternatives but it p
term effectiveness and is the least costly. Containment was preferred
-4-
Risk*
OSWER"
Risk
.Si andard technology?
protqction, implementability
provides the greatest short-
over treatment
1067
-------
-tfl
u
(solidification) because treatment would only reduce mobility without changing toxicrty, it
would increase volume, and it would cost five times as much. The soil cap was preferred over
the clay cap since it is less costly. While excavation and off-site disposal was preferred by the
City and County of Denver and a vicinity landowner, this option was dismissed since off-site
disposal without treatment is the least preferred option under CERCLA. Finally the chosen
alternative posed the least short-term risk and could be implemented in the shortest time.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative;
•!,'
1068
-5-
-------
Hill Air Force Base
OU-3

Davis and Weber Counties, Utah
Region 8
GENERAT. srrc

L ^m^^L^^(.^^^
°f
Soil(mg/kg)

Sodium hydroxide migration through soil was
indicated by the nH *it r
„„ j • • pii> alkalinity, and
conductivity of the soil.
2.
of material is to be remediated?

of material to be remediated
Sit« History
NPL Proposed:
NPL Final:
FS:
Interim Action
ROD:
Backgrciund
Federal Facility
PRPs: Hill Air Force Base
FS prepared by: James M.
Montgomery
No voiurne was provided, however, the site area is

type of site is this?
28,900 square feet.

technologies were:

Cbntainment:
Physical treatment:
during the identification and
screening
Asphalt cap
Tank removal
-1-
N/A
1987
9/91

9/92
£ind maintaining aircraft.
of technically feasible
1069
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically feasible
technologies were:

No innovative technologies were identified!.

6. What was the cost estimate for the innovative technology?

. V
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) v
Alternative
RAA-1
RAA-2
Standard Technology
Underground storage tank removal
Underground storage tank
removal/capping
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$0
$55,343
8. If a standard technology was chosen, why?

RAA-2 was selected because it protects human health and the environment since it prevents
exposure of receptors to contaminated soil by eliminating human dermal and inhalation contact.
Capping also reduces the rate at which sodium hydroxide migrates to the water table. Reducing
vertical migration will not reduce the concentration of sodium hydroxide, but it will reduce the
volume and mobility of leachate reaching the water table. This provides long-term protection as
long as the cap is kept intact. A substantial reduction in contaminant mobility will be achieved
by reducing infiltration to the site, the driving force for downward contaminant migration. The
equipment required for construction is readily available and reliable. This is an interaction;
therefore, the chosen alternative provides a preliminary step in achieving action-specific ARARs
for soil, which will be addressed more fully in the final remedial action for OU-3. A waiver will
be invoked for RCRA closure requirements since this is an interim action. It is the most cost-
effective option.
9. If an innovative technology was chosen, why?

An innovative technology was hot selected.
1070 .2.
-------
ive technology was not chosen, why not? At what stage was the innovative technology

itjve technologies could be eliminated from the remedial technology selection process at
stages: during the initial screening; during the screening' of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

." • '• * None - - ' . • • -•'-,. :|.. .. • • • •

Innovative technologies eliminated during 'the screening of the three crilleria include the following:

• None |
• \
• - ' - - ' . ' "I" , ...
Innovative technologies eliminated during the detailed analysis include the following:

• None, , '.'•.'-..' • .-••"!' • • -. " ' •" '

Cleanup levels were not established. No contaminant-specific ARARs eiist for sodium hydroxide
•mwl and potential ground water ARARs will be addressed in the final remedial alternative for

' ' • ' ' ' • I '
• • ' i'
1 ' • «•'.'!••' .' '• i ' -
• Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? . wnaara

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
3 1071
-------
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conduct? 1

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives: ,

Risk level achieved .
Cost-effectiveness ,

16. How are measures compared? !

RAA-2 was preferred over RAA-1 because it would provide greater protection. RAA-2 eliminates
human dermal and inhalation exposure to contaminated soil and it prevents the downward
mobilization of contaminants. RAA-1 would not provide as great protection since it would not
reduce the mobility of contaminants. RAA-2 also represents the cost-effective option because if
interim action is not taken, contamination will continue to migrate into soil and/or ground water,
probably increasing the ultimate remediation cost of OU-3. .

77. Wliat technical considerations were factors in selecting a remedy? Were technical considerations
primary in the selection of the remedy?

No technical considerations were primary in selecting a remedial alternative.
D

1072
-4-
-------
Idaho Pole Company

Bozeman, Montana
Region 8
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Pentachlorophenol (PCP) 380
Fluoranthene 12
Benzo(a)pyrene 4.8
Anthracene 8.1
Pyrene 10
Benzo(a)anthracene 5.8
Benzo(b)fluoranthene 13
Benzo(k)fluoranthene 6.7
Benzo(g,h,i)perylene 2-2
Chrysene 10
Indeno(l,2,3-cd)pyrene 2.7
Phenanthrene 46
TCDD TE 0.00179

Sediments (mg/kg)

Pentachlorophenol 25
Fluoranthene 1.7
Benzo(a)pyrene 0.72
Anthracene 0.52
Pyrene 20
Benzo(a)anthracene 4.6
Benzo(b)fluoranthene 1.2
Benzo(k)fluoranthene 1.9
Benzo(g4i4)perylene 0.27
.Chrysene 7.1
Indeno(l,2,3-cd)pyrene 0.26
Phenanthrene 2.3
TCDD TE 0.0342
; jSite JHislory

NPL Proposed: 1984
NPL Final: 1986
FS: I 4/92
ROD: I 9/92
i " "
Background

EPA Fund-lead !
PRPs: The Idaho Pole Company,
Burlington Northern Railroad
FS prepared by: MultiTech Services,
MSE,Inc.
-1-
1073
-------
•
2. What volume of material is to be remediated?

The volume of material to be remediated included: • -J\

• 2,683 cubic yards of sediment
» 39,304 cubic yards of soil '' \

I
I •
3, What type of site is this? '-•.'..',.

Lumber and Wood Products. An active wood treating facility in a light industrial area.

• i.
•
TECHNOLOGY SELECTION ;

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible '
technologies were: •.-••'

Soil/Sediment

Access restriction: Fencing, land use control
Containment: Capping (asphalt, clay and soil, concrete, revegetation)
Chemical treatment: Fixation/stabilization
Thermal treatment: Incineration (rotary kiln, fluidized bed, plasma fusion, infrared)
Disposal: Excavation, disposal (on-site, off-site)
• . , !

5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically feasible
technologies were:

Soil/Sediment

Biological treatment: Aerobic, anaerobic, land treatment, slurry phase, white rot fungus, in situ
bioremediation .
Phys/Chem treatment: Dechlorination, oxidation/reduction, solvent extraction, soil washing,
steam stripping, air stripping, in situ soil flushing, vacuum soil venting
Thermal treatment: Pyrolysis, in situ vitrification ;

6. What was the cost estimate for the innovative technology?

1074
-2- • - . • • • •
-------
the nine-criteria analysis, RAA designations changed. These changes are presented parenthetically.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) | •
Alternative
RAA-5
(RAA-4)
RAA-7
(RAA-5)
RAA-6
RAA-8
RAA-9
RAA-10
.' ' . • ' /
Innovative Technology
Excavation/oily wood treating fluid'
recovery/solid phase (surface land)
biological treatment or slurry phase
biological treatment
Excavation/oily wood treating fluid
recovery/critical fluid solvent extraction
In situ soil flushing/in situ biological
treatment of residuals/land treatment
unit
Excavation/soil washing/ dechlorination
In situ soil flushing
In situ bioremediation
Estinnated Costs
3 Criteria
N/A
1
i •
• ' i
''\
N/A1
N/A
- i
i
, N/A
N/A
• • f
N/A
9 Criteria
$8,164,357 to
$12,816,185
$82,232,520
$10,841,429
eliminated
incorporated
into RAA-6
eliminated
7. How did the cost(s) compare to standard technologies? - >,
'- ' - - • f

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) |
Alternative
RAA-1
RAA-2
RAA-3
(RAA-2)
RAA-4
1 (RAA-3)
RAA-1 1
RAA-12
Standard Technology
No action
Institutional controls .
Capping
Excavation/incineration (on-site or off-
site)
Excavation/on-site landfilling
Excavation/off-site landfilling
Estimated Costs
3 Criteria
N/A!
N/A
N/A
N/A
N/A
N/A
9 Criteria
$0
eliminated
$1,329,577
$63,000
to
$211,900,000a
eliminated
eliminated
"Costs were developed for both on site and off site incineration options.
-3-
1075
-------
8. If a standard technology was chosen, why?

A standard technology was not selected. ,
\

9. If an innovative technology was chosen, why? ,

A combination of two innovative alternatives were selected to address contaminated soil and
sediment. In situ soil flushing and in situ biological treatment (RAA-6) were chosen for treatment
of soil and sediment under plant structures and excavation and biological treatment (RAA-5) were
selected for treatment of accessible soil and sediment. . Solid phase biological treatment was
selected over slurry phase biological treatment because it has been proved at other hazardous
waste sites. RAA-6 is the only soil alternative that can be implemented in the active plant area
since it does not require demolition of existing structures and excavation of contaminated soils.
Furthermore, it is the only alternative that allows continued operation of the plant while reducing
exposures to within an acceptable risk range. RAA-6 also will remediate soil under Interstate 90
without the impractical replacement of the highway. RAA-5 was selected to treat the excavatable
site soil and sediment. Solid phase biological treatment is a proven remediation technology that
has met community acceptance at other sites, and is relatively inexpensive,. In addition, biological
treatment is readily implementable in a surface land treatment unit. Biological treatment of the
contaminated soiysediment converts contaminants to nontoxic compounds and eliminates the threat
of exposure through direct contact with or ingestion of contaminated soil/sediment. The remedy
will be effective in the long-term because of the significant reduction in contaminant toxicity and
mobility achieved through biological treatment of the soil/sediment. All short-term risks can be
readily controlled and no adverse cross-media impacts are expected from the remedy. These
alternatives comply with all ARARs and are cost-effective. Implementation of these alternatives
will result in long-term effectiveness by reducing residual carcinogenic risks to within the
acceptable risk range through permanent treatment.

10. If an innovative technology was not chosen, why not? At what stage was the innovative technology
eliminated?

Innovative technologies eliminated during the initial screening include the following:

» Air stripping was eliminated because it would not be effective given the low volatility of
the contaminants of concern. ,
" Pyrolysis-was eliminated because.it would not be effective for the contaminants of
concern.
H Vacuum soil venting was eliminated because it would not be effective for the
contaminants of concern.
a In situ vitrification was eliminated because it would not be effective or implementable
given the site's shallow ground water.

Innovative technologies eliminated during the screening of the three criteria include the following:

« Dechlorination was eliminated -because "there would be a potential for the highly

1076
-------
11.
chlorinated dioxins to be reduced to lesser chlorinated but more; toxic compounds."
Furthermore, these technologies would be very costly and would not address PAHs that
would remain in the waste stream and require further treatment.
• In situ bioremediation (as a stand alone technology) was eliminated because it is most
successful for use in porous soil and the site's contaminated soil includes low porosity
clay and silt layers. Further, the activity microorganisms are veiy sensitive to changes in
soil temperature, which varies seasonally at the site. j
: '•••-. ' i '
Innovative technologies eliminated during the detailed analysis include the following:

• Critical fluid extraction was eliminated because it would not reduce the toxicity, mobility,
and volume of site contaminants as effectively as the chosen alterative and it would be
more expensive. This alternative also was deemed the most difficult to implement
• because it would require a specially designed and constructed unit to contain waste
material during treatment. A vendor is available, but there might be delays in optimizing
the processing. This alternative would require planning with the local government. The
fate of extracted hazardous substances would be uncertain because contaminants are
concentrated in the extract, but are not destroyed and may pose; residual risk.,
• Slurry phase bioremediation was eliminated because it has not beein proved as effectual
as solid phase bioremediation.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Whichof the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were cost, implementability,
and short-term effectiveness. While the chosen technologies are not as protective and do not offer
as much long-term effectiveness and permanence as incineration and critical fluid solvent
extraction, they are preferred because they offer appropriate protection and permanence and are
less expensive, pose less short-term risk, and are more easily implemented. Furthermore, only in
situ technologies could be implemented since it is not practical to excavate soil/sediment.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
PCP
Total B2 PAHs
TCDDTE
48
15
0.001
Risk8
Risk
Risk
Noncarcinogens .
Total D PAHs
145
Risk
Tor carcinogens, an excess upper bound individual lifetime cancer, risk of 10"6 was
acceptable. For noncarcinogehs, a Hazard Index less than or equal to 1.0 was acceptable.
1077
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include: '

• None

Standard technologies eliminated because of cleanup goals include:

* None , '

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness . ,
Proven reliability
Preference for treatment (vs. containment)
Impact on nearby populations

16. How are measures compared? '

Short-term risk and cost-effectiveness were factors in selecting a remedial alternative. Incineration
and critical fluid extraction were eliminated for these reasons. Incineration was not selected
because it would have posed the greatest opportunity for impacts to site workers and nearby
populations from air emissions. Furthermore, there would have been a risk associated with off-site
incineration from the transportation of large quantities of hazardous substances over public roads.
Critical fluid solvent extraction was not selected because it would also pose a threat to on-site
workers if not properly designed or operated from air emissions and the use of pressurized solvent.
Workers also might encounter risks from concentrated extract and treatment residuals.
Incineration and critical fluid extraction were not preferred because they would be more expensive
than the chosen alternative and would not offer a proportional increase in benefit. Proven
reliability also played a role in selecting a remedial technology. Solid phase biological treatment
was selected over slurry phase biological treatment because it has been proved at other hazardous
waste sites. The choice of a remedial alternative also reflects a preference for treatment over
containment; capping was not chosen because it is less protective of human health and the
environment and would not reduce contaminant toxicity, mobility, and volume.
t'i
r
1078
-6-
0);
-------
17. What technical considerations were factors in selecting a remedy? Were technical considerations
primary in the selection of the remedy? I .
•'' . ' " ' i - ' " -
One technical consideration that was primary in selecting a remedial alternative was the inability
to excavate all contaminated soil/sediment. Contaminated soil/sediment was located in several
areas which could be excavated but also under buildings and Interstate 90, which could not be
excavated for practical reasons. Furthermore, it was preferable to Keep the facility operating.
Because it was decided that it would be impractical to excavate soil/sediment under existing
structures and under Interstate 90, in situ technologies were selected to address these soils. Ex
situ technologies were chosen for soil/sediment that couldbe excavated.
-7-
1079
-------
Ogden Defense Depot
0U-1

Ogden, Utah
Region 8
GENERAL SITE INFORMATION
L
2.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

PCBs
2,3,7,8-TCDD
Lead
Zinc
3.6
0.000026
1,000
11,000
What volume of material is. to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
1984
7/87
5/11/92
,6/26/92
Background

Federal Facility
PRPs: Defense Depot Ogden, Utah
FS prepared by: James M.
Montgomery Consulting
Engineers Inc. ,
The volume of material to be remediated included:

" 4,000 cubic yards of soil

3. What, type of site is this? . . :

Military. The site is a defense distribution depot., The operable unit of this site consists of
two burial units and a backfilled canal. The site is located in a semirural setting bordered by
several small communities.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Access limits
Containment: Capping (clay, synthetic, multilayer, pavement) grouting, slurry wall,
block displacement . . .
Chemical treatment: Fixation/stabilization
Thermal treatment: Incineration (plasma, infrared)
1050
-------
Disposal:
Excavation, RCRA landfill
5. Was an innovative technology considered in the FS? If so, which technology?
' ' ' •- • • ' : ' - ' ' ' * ^
Innovative technologies considered during the identification and screening of technically
feasible technologies were: ;

Biological treatment: Biodegradation (aerobic, anaerobic, in situ, ex| situ)
Chemical/Physical: Washing/extraction (in situ, ex situ), oxidation (in situ, ex situ),
dechlorination, electrical/acoustical (in situ, ex situ) •
Thermal treatment: Vitrification (in situ, ex situ), low-temperature deisorption, in situ steam
stripping ' -
What was the cost estimate for the innovative technology? ,

During the initial screening process, in which technically feasible teclinologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. JVfteir the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that' merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCR ;

In the FS, only soil technologies were evaluated during, the three-criteria analyses, and site-
wide alternatives were developed to include ground water remediation at the detailed analyses
stage. The RAA designations for the alternatives developed in the deitailcd analyses and the
ROD are presented parenthetically.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-5
RAA-6
.Innovative Technology
Excavation/dechlorination or
incineration/off-site RCRA landfill
In situ vitrification
,1 . .
Estimated Costs
3 Criteria
N/A
i.
N/A
9 Criteria
eliminated
eliminated
7. How did the cost(s) compare to standard technologies?
t : -. . • l
Cost Estimates for RAAs That Include Standard Technologies
. (selected remedial alternative is in bold) i
Alternative
1 RAA-1
.Standard Technology
No action
Es timated Costs
3 Criteria
N/A
9 Criteria
$254,000
••••'•• .'• '•: •'•- "; •'".': ' -2- - ••••'• ';'.•:.;, • ' '' 10
-------
Alternative
RAA-2
RAA-3
RAA-4
(RAA-3)
(RAA-2)
(RAA-4)
(RAA-5)
Standard Technology
Institutional controls
Containment/cap/slurry wall/or RCRA
landfill
.Excavation/incineratlon/off-site
disposal/ground water treatment with air
stripping.
Excavation/off-site (disposal/ground
water treatment with air stripping
Excavation/off-site disposal/ground
water treatment with spray aeration
Excavation/incineration/off-site
disposal/ground water treatment with
spray aeration
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
eliminated
eliminated
$15,000,000
$2,200,000
$2,200,000
$15,000,000
8. If a standard technology was chosen, why?

Off-site disposal (RAA-2) was selected because it reduces the site risk by removing the
potential source of contamination observed in the ground water and it eliminates the potential
for exposure to site contaminants in soil. RAA-2 complies with ARARs; is the easiest action
alternative to implement; provides long-term effectiveness since contaminated soil will be
disposed of off site; reduces contaminant mobility, toxicity, and volume through proposed
ground water remediation; and is cost-effective. It will not pose any short-term risk and it will
minimize cross:media impacts.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? '

Innovative technologies eliminated during the initial screening include the following:
1 . "•,-.- - . '
• Washing/extraction (ex situ) was eliminated because treatability testing would be
required for dioxin/furan removal and the process/technology would be expensive.
1082
-3-
-------
• Washing/extraction (in situ) was eliminated because precise jp-ound water control
would be required and its effectiveness would be difficult to measure and the
process/technology would have high cost. i
• Oxidation (in situ, ex situ) was eliminated because extensive Streatability testing would
be required for dioxin/furan removal and the process/technology would have high cost.
• Electrical/acoustic (in situ, ex situ) was eliminated because extensive treatability
testing would be required, it is unproven, effectiveness is not; exacted, and the
process/technology would have high cost.
• Ex situ vitrification was eliminated because incineration produces a more acceptable
waste product for replacement on site and high cost.
• Biodegradation (aerobic, anaerobic, in situ, ex situ) was eliminated because it would
not be as effective on low levels of contamination.
• Low-temperature desorption was eliminated because the temperature would be
insufficient for dioxin/furan destruction.
• In situ steam stripping was eliminated because it would be difficult to prove
effectiveness, it would not be suitable for dioxin/furans, and ^he process/ technology
would be expensive. \

Innovative technologies eliminated during the screening of the three criteria include the
following: i
• - - [. '
" . In situ vitrification was eliminated because there was spme concern that it might cause
contaminants to migrate to deeper soils producing a zone of partially vitrified and
contaminated soil surrounding the vitrified mass. In addition}, vitrification becomes
cost-effective when the depth of soil to be treated is greater ithan 8 feet and the
maximum depth of contaminants in site soil is only 6 to 7 fe^et. Furthermore, because
the process would not be efficient in saturated soil, it could Ijecome necessary to
install a dewatering system at the site making the economic viability of the treatment
questionable.
• Dechlorination was eliminated because it would not be cost-effective compared to off-
site landfilling, it would have administrative difficulties since it is an innovative
technology, and it would require treatability testing to optimize its effectiveness and
costs. . ,

Innovative technologies eliminated during the detailed analysis include the following:
''''".-' . - !- ".*••
• None r
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of 'a standard technology?
•l - .
- . • j ' •- ' ~ ~, •
, Implementability was-weighted most heavily criteria in selecting a remedial alternative. The
chosen alternative was preferred because it was the most implementable of the action
alternatives. RAA-3 and RAA-5 would have provided greater protection and long-term •
effectiveness but were eliminated because they were not implementable. RAA-3 and RAA-5
were not implementable because an incinerator permitted for dioxin and furan destruction is
currently not, available. In addition, the proven technology employed for ground water
remediation in RAA-2 is more technically implementable than the less proven technology
proposed in RAA-4.
-4-
1083
-------
In situ vitrification and dechlorination were eliminated in the three-criteria analyses, in part,
because they would not be cost-effective and their effectiveness was uncertain.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Trichloroethene
Vinyl chloride
Arsenic
PCBs
2,3,7,8-TCDD
490
3.2
35
25
0.001
Risk"
Risk
Risk
FJPA*
DDAGC
Noncarcinogens
cis-l,2-Dichloroethene.
Zinc
700
1,500
Risk
Risk
Tor carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4
to W6 was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0
was acceptable. , ,
"EPA Directive 9355.4-01 FS, "A Guide on Remedial Actions at Superfund Sites with
PCB Contamination."
TDioxin Disposal Advisory Group Regarding Penta-Chlorophenol Waste (also PCBs),
by P. des Rosiers, Nov. 1988.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

" , None -

Standard technologies eliminated because of cleanup goals include: . •

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
1084
-5-
-------
17,
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability
- • Waste left in place/institutional control
- . Implementability

16. How are measures compared?

The choice of a remedial alternative appeared to be based mainly on irnplementability. It was
chosen over RAA-3 and RAA-5 because these alternatives were not implementable. It was
chosen over RAA-4 because the ground water technology proposed in RAA-4 was not as
proven and therefore would not be as easily implemented. In addition,' containment was not
earned to detailed analyses because it would require high maintenance and restrict future site
use. Two innovative technologies were eliminated in the three-criteria [screening because they
would require treatability studies to optimize their effectiveness and costs. It was stated that
treatability studies would not be done unless alternatives employing proven technologies were
found to be unacceptable.
1
What technical considerations were factors in selecting a remedy?
considerations primary in the selection of the remedy?
Were technical
No technical considerations were primary in selecting a remedial alternative. The shallow
depth of the contamination was a consideration in the elimination of in s,itu vitrification.
1085
-------
Ogden Defense Depot
OU-3

Ogden, Utah
Region 8
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and met
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Arsenic
Barium
Lead '
Mercury
n-Nitrosodiphenylamine
Trichloroethene
1,1,2 ,2,-Tetrachloroethane
Zinc
Mustard
Adamsite
Thiodiglycol
Chloroacetophenone
linants,
addressed in

ncipal

559
248
44
9.8
0.75
OJ51
0.13
74.5

NPL

Site History
Proposed: 1984
NPL Final: 7/87
FS:
ROD

N/A
: 8/21/92
Background

Federal Facility
PRPs
: Defense Depot Ogden
FS prepared by: James M.

5,000
134 ' ' '
120
3
Montgomery Consulting
Engineers, Inc.

What volume of material is to be remediated? ' "

The volume of material to be remediated included:

• 530 cubic yards of soil and debris

What type of site is this?

Military. The site is a defense distribution depot. The operable unit consists of several burial
sites and a water purification table burial area.
TECHNOLOGY SELECTION .

4. , What standard technologies were considered for selection in this FS? .'•

Standard technologies considered during the identification and screening of technically feasible
technologies were:
1086
-------
Access restriction:
Containment:

Chemical treatment:
Thermal treatment:
Disposal:
Fencing, deed restrictions
Capping (clay, synthetic membrane, multilayer
grout injection
Solidification/stabilization, fixation, immobiliaation
Incineratipn (DOD, plasma, infrared)
Excavation, disposal (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
Biological treatment:
Physical/chemical:

Thermal treatment:
Biodegradation (aerobic, anaerobic, in situ, ex
Oxidation (in situ, ex situ), electrical/acoustic (in
washing/extraction (in situ, ex situ)
Vitrification (in situ, ex situ), steam stripping
desorption
•, pavement), slurry wall,

ion, lime neutralization*
situ)
in situ, ex situ),

low-temperature thermal
What was the cost estimate for the innovative technology?

Some alternatives were developed in greater detail in the detailed ansjlyses. The RAA
designations for these changes are presented parenthetically in the table l«low. No innovative
technologies were incorporated into remedial alternatives.
How did the cost(s) compare to standard technologies? i .

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) j
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
(RAA-3A)
Standard Technology
No action
Institutional controls
Clay cap
Excavation and debris separation/
transport contaminated soil off site/
stabilization if necessary /off-site
disposal
Estimated Costs
3 Criteria
N/A;
N/A
isr/A
N/A
9 Criteria
$11,300
$201,000
eliminated
$362,000

2- 1087
-------
Alternative
(RAA-3B)
RAA-5
(RAA-4A)
(RAA-4B)
Standard Technology
Excavation and debris separation/trans-
port contaminated soil off site/incin-
eration if necessary/off-site disposal
Excavation/transport all soil off site/
stabilization/off-site disposal
Excavation/transport all soil off site/
incineration/off-site disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A , •
9 Criteria
$570,000
$420,000
$1,792,000
8. If a standard technology was chosen, why?

Because the nature of the items and the chemical contaminants present in burial areas varies,
no single RAA was suitable for all of the burial areas. The selected remedy consists of two
RAAs. RAA-3A was chosen for the chemical warfare agents (CWA) Identification Kit and
the Riot Control and Smoke Grenade burial areas, and RAA-4 A was chosen for the
Miscellaneous Items, Water Purification, Tablet, and the Compressed Gas Cylinder burial
areas. At all areas, CWAs will be taken to a licensed DOD chemical munitions disposal
facility. The major difference between these two alternatives is that RAA-4A removes all area
soil for disposal off site and RAA-3A will first sort soil and debris and remove only
contaminated soil for disposal off site.

These alternatives were deemed protective of human health and the environment since
contaminated soil will be disposed of off site, removing the potential for direct
exposure to contaminants in soil and the potential source of ground water
contamination. In both instances, short-term risk will be minimized by utilizing
specially trained individuals to implement the remedy. These alternatives will achieve
long-term effectiveness and permanence through off-site disposal. While greater
permanence would be achieved through incineration the extra cost associated with
incineration was not deemed justifiable. Both alternatives reduce contaminant
mobility. These alternatives are technically and administratively implementable and
cost-effective. ,''.-.•

RAA-3A was the most appropriate alternative for the Riot Control and Smoke Grenade burial
areas because there is less than 1 cubic yard of contaminated materials in these areas and the
contaminants in the soils are not known to be above health-based levels. RAA-3A, therefore,
was selected for these areas because it is the least expensive action option. RAA-3A provides
greater long-term effectiveness and permanence for the CWA Identification Kit burial area
because this area is contaminated with arsenic which would not be destroyed by incineration.
Incineration could lead to uncontrolled release of arsenic.

RAA-4A was more appropriate for the Miscellaneous Items burial area since this alternative
provides greater long-term effectiveness and permanence in an area that is a threat to ground
water quality. RAA-4B would have provided more protection but because there is no direct
health threat at this area, the increased cost of RAA-4B could not be justified.
I"1
)
1088
-3-
-------
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage
technology eliminated?
Innovative technologies could be eliminated from the remedial technology
three stages: during the initial screening; during the screening of the
effectiveness, implementability, and cost; or during the detailed evaluation
was the innovative
selection process at
three criteria of
Innovative technologies eliminated during the initial screening induce the following:

• Oxidation (in situ) was eliminated because it would not be suitable for site
contaminants.
• Electrical/acoustical (in situ) was eliminated because it would riot be suitable for site
contaminants.
• Washing/extraction (in situ) was eliminated because it would not be suited, for
conditions at OU-3. j !,
• Vitrification (in situ) was eliminated because it would be significantly more expensive
than other technologies. •''•'..
• In situ biodegradation (aerobic, anaerobic) was eliminated because it would not be as
effective oil metals. '
• Steam stripping was eliminated because it is not expected to1 be effective, it would be
expensive and its effectiveness would be difficult to prove. .
• Washing/extraction (ex situ) was eliminated because it would be ineffective on buried
materials at OU-3. ,
• Oxidation (ex situ) was eliminated because it would be ineffective on buried materials
. . ' ' at OU-3., ' ' •"•'...'. ' •- | "
• Electrical/acoustical (ex situ) was eliminated because it is umproven and extensive
treatability studies would be required. .
• • Vitrification (ex situ) was eliminated because it would produce more unacceptable
, waste product on site. . _
• Ex situ biodegradation (aerobic, anaerobic) was eliminated because it would not be
suitable for contaminants and concentrations at OU-3. I,
• Low-temperature thermal desorption was eliminated because it would not be effective
on contaminants at OU-3. In addition, it would be expensive and it would not be a
practical solution. _ j

A very generalized statement was made in the FS that stated that nci innovative technologies
were selected for developing RAAs because they would not offer significant benefit in terms
of effectiveness, implementability or fewer adverse impacts over proven technologies. In
addition, some innovative technologies would not comply with ARARs (none specified),
especially with respect to the possibility of CSM (riot defined) or Chemical Warfare Agents
contamination. Finally, no cost savings would be realized through implementation of
innovative technologies at this,site. • - '
-4-
1089
-------
11.
12.
Innovative technologies eliminated during the screening of the three criteria include the
following: v

• None . , „

Innovative technologies eliminated during the detailed analysis include the following:

• None
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the'criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were cpst and protection
to human health and the environment. The chosen alternative provides adequate protection to
human health and the environment for the least cost. Other alternatives that employed
incineration would have provided greater protection and long-term effectiveness; however,
these alternatives were eliminated because of their much greater costs. .

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant.
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Trichloroethene
1 , 1 ,2,2-Tetrachloroethane
n-Nitrosodiphenylamine
35
490
30
1,250
Risk8
Risk
Risk
Risk
Noncarcinogens
Mercury
2
Risk
'For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4
to 10- was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0
was acceptable.
I
)
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? .

Innovative technologies eliminated because of cleanup goals include:

• Not specified ,
1090
-5-
-------
14.
Standard technologies eliminated because" of cleanup goals include:

• • None' - . ' . • • | '. ' , ' -
v I" ' -

Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted, i . .'•
15. ' What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
16. How are measures compared? • '!''-.'

RAA-3A was preferred because it is the least expensive action alternative. Even though RAA-
4B would offer greater reductions in contaminant toxicity, mobility, ibd volume through
incineration, RAA-4A was preferred over RAA-4B for the Miscellaneous Items burial area.
RAA-4B would have been six to seven times more expensive to implement. Further, because
the major threat to the-Miscellaneous Items burial area is cross-media contamination rather
than a direct health hazard, the additional cost associated with RAA-4B was not justifiable.
I : ' • , • • : • '" ' I''-'.'.'.

17. What technical considerations were factors in selecting a remedy"? V^ere technical
considerations primary in the selection of the remedy?

The potential for a burial area to be a source of ground water contaniination was a primary
technical issue that was primary in selecting a remedial technology. [Thus,.if there was -a threat
of ground water contamination RAA-4A was preferred over RAA-3A because it would be
> more protective.
-6-
1091
-------
Ogden Defense Depot
OU-4

Ogden, Utah
Regions
GENERAL SITE INFORMATION
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Lead 1,400
VOCs 193 .
PCBs 15
Hydrocarbons . 43,000
Dioxins/furans 0.067s
Toxicity Equivalency Factor.

Siie History ; ;

NPL Proposed: 1984
NFL. Final: ,7/87
FS: 12/91
ROD: 8/3/92

Background
1 •
Federal Facility
PRPs: Defense Depot Ogden
FS prepared by: James M.
Montgomery

2. What volume of material is to be remediated?

The volume of material to be remediated included:

* 4,500 cubic yards of soil
3. What type of site is this? . "

Military. The site is a defense distribution depot. The operable unit consists of two burial
units. The site is located in a semirural setting bordered by several small communities.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: , •

Access restriction: Restricted entry .
Containment: • Capping (clay, synthetic, multilayer, pavement), grouting, slurry wall,
block displacements RCRA liner and cap
Chemical treatment: Fixation/stabilization
1092
-1-
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Thermal treatment: Incineration (plasma, infrared)
Disposal: Excavation, off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: - . v

Biological treatment: Biodegradation (aerobic, anaerobic, ex situ, iiii situ)
Chemical treatment: Washing/extraction (ex situ, in situ), oxidation (ex situ, in situ),
dechlorination ;
Physical treatment: Electrical/acoustical (ex situ, in situ) !
Thermal treatment: Vitrification (ex situ, in situ), low-temperature desorption, in situ steam
stripping
What was the cost estimate for the innovative technology? .:\

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) -
Alternative
RAA-5A
(RAA-4A) ,
RAA-6
(RAA-7A)
Innovative Technology
Excavation/dechlorination/ground water
treatment with air stripping and GAC
(granular activated carbon)
In situ vitrification
Excavation/dechlorination/ground water
treatment with UV/ozone
Estimated Costs
3 Criteria
•N/A
eliminated
9 Criteria8
$6,800,000
or
$7,600,000
$6,900,000
or
$7,600,000
"Present worth is given for 5 years or 10 years.
-2-
1093
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
1
Alternative
RAA-1

RAA-2
RAA-3A
__
RAA-3B
(RAA-2)
(RAA-3A)
RAA-4A
(RAA-3B)
RAA-5B
(RAA-4B)
(RAA-5)
(RAA-6A)
(RAA-6B)
(RAA-7B)
Standard Technology
No action
Institutional controls
Excavation/slurry wall/cap
Excavation/on-site landfill/cap/ground
water treatment with air stripping and
GAG
Excavation/off-site landfill/ground
water treatment with air stripping
and GAC
Excavation/off-site incineration/off-site
disposal/ground water treatment with air
stripping and GAC
Excavation/on-site incineration/ground
water treatment with air stripping and
GAC
Excavation/on-site landfill/cap/ground
water treatment with UV/ozone
Excavation/off-site landfill/ground water
treatment with UV/ozone
Excavation/off-site incineration/off-site
disposal/ground water treatment with
UV/ozone
Excavation/on-site incineration/ground
water treatment with UV/ozone
Estimated Costs
3 Criteria
.N/A
eliminated
eliminated
N/A
—
N/A
N/A '.
— -
, — , . •
—
• — —
9 Criteria11
$113,000 or
$186,000
- . .

$3,000,000
or
$3,900,000
$3,800,000
or
$4,500,000
$18,000,000
or
$19,000,000
$7,000,000
or
$7,800,000
$3,100,000 1
or
$3,900,000
$3,900,000
or
$4,600,000
$18,000,000
or .
$19,000,000
$7,100,000
or
$7,800,000
"Present worth is given for 5 years or 10 years.
8. If a standard technology was chosen, why?
The chosen alternative, (RAA-3A), will excavate contaminated soil and transport it off site for
disposal. During excavation, TCLP testing will be preformed periodically to confirm the
1094
-3-
-------
characteristics of the soil and its suitability for land disposal. If "a soil sample fails the TCLP
criteria, the soil volume represented by this sample will be treated with stabilization/fixation
techniques. If treatment is unsuccessful for dioxins, the failing material will be transported to
an incineration facility. While no permitted incineration facilities exist for dioxin destruction,
storage will be undertaken until permitting is completed. The chosen alternative protects
human health and the environment because it removes all contaminatixl soil and thereby
eliminates the source of ground water contamination with organics and eliminates the potential
for exposure to these contaminants in soil. This alternative will not pose any short-term risk
to human health, the environment, or endangered species and their habitats nor will the site
present any unacceptable risks after completion of the remedy. The selected remedy also
minimizes cross-media impacts through the use of air emissions controls if necessary. The
proposed alternative satisfies all ARARs. The selected remedy is cost effective because it
provides maximum effectiveness proportional to its cost compared to the other alternatives
analyzed. The selected alternative costs less than the off-site incineration alternative, and
provides a greater degree of protectiveness to human health and the environment when
compared to the on-site remediation alternatives. The selected remedy will be protective in the
long term because it removes the source of ground water contamination from the site, and
allows clean closure of the site in a cost-effective manner. 1
9. If an innovative technology was chosen, why?
• - _ ,."-•.• •[•"• •
An innovative technology was not selected. j .
,1 • ' ' . * "-

10. If an innovative technology was not chosen, why not? At what stage vyas the innovative
technology eliminated? , >

Innovative technologies eliminated during the initial screening include the following:
" , ' • f '•»•.*•
• Washing/extraction (ex situ) was eliminated because treatabilily studies would be
required for dioxin/furans. -
• Oxidation (ex situ, in situ) was eliminated because extensive treatability studies would
be required for dioxin/furans. I ;
• Electrical/acoustical (ex situ, in situ) was eliminated because extensive treatability tests
- would be required and the technology has not been proved. • ,
• Vitrification (ex situ) was eliminated because incineration would produce a more
acceptable waste product on site.
• Biodegradation (aerobic, anaerobic, in situ, ex situ) was eliminated because it would ,
not be effective on low levels of contamination. i
• Law-temperature desorptidn was eliminated because the temperature would be
insufficient for dioxin/furan destruction.
• Washing/extraction (in situ) was eliminated because precise ground water control
would be required and it would be difficult to measure effectiveness.
• In situ steam stripping was eliminated because it would be difficult to prove its
effectiveness and it would not be suitable for dioxin/furans.
-4- ,. j 1095
-------
11.
* , ' -•
Innovative technologies eliminated during the screening of the three criteria include the
following: '
1 ' .
« Vitrification (in situ) was eliminated because implementation could potentially cause
the contaminants to migrate to deeper soils. This could produce a zone of partially
vitrified and contaminated soil surrounding the vitrified soil mass. The technical
implementability of the process is poor because pf the questions regarding contaminant
migration, the shallow depth of contamination, and the high water table conditions
These technical difficulties put the technology's ability to comply with ARARs in
question when compared to other remedial alternatives. In addition, vitrification
becomes cost effective when the depth of soil to be treated is greater than 8 feet and
the water table is below the contaminated zone (Geosafe Corporation, 1989). The
contaminated soil in OU-4 extends to a depth of only 9 to 10 feet and the water table
is also at this depth. The economic viability of this process is questionable.

Innovative technologies eliminated during the detailed analysis include the following:

• Dechlorination was eliminated because it would require a treatability study to confirm
the ability of this technology to treat PCB, dioxin, and furan-contaminated soil.
Furthermore, "the administrative difficulties associated with pn-site dechlorination as
an innovative technology make implementation of this alternative more difficult."

t '
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria that were weighted most heavily in selecting a remedial alternative were
implementability and cost. While alternatives that utilize technologies such as incineration or
dechlorination would provide greater long-term effectiveness and greater reduction in
contaminant mobility, toxicity, and volume, these alternatives were not chosen because of
implementation problems and cost.

In situ vitrification was eliminated because of implementation difficulties and because it would
not be cost-effective.
12.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? ,
1096
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Benzene
Vinyl chloride
Lead
PCBs
35
210
• 3.2
500
25
Background8
Riskb
Risk
OSWERC
EPA"
-5-
-------
Contaminant ,
Dioxin/furans
Cleanup Level (mg/kg)
0.001
ARAR or Other Basis
! DDAGe
Noncarcinogens • - .
cis- 1 ,2-Dichloroethene
700
1 Risk
"Cleanup levels correspond to a 10"4 cancer risk as concentrations corresponding to a
lO"5 cancer risk are below naturally occurring background levels.
bCleanup levels correspond to a cancer risk of 10"5 under a future residential soil
ingestion scenario. . [
°Cleanup level was chosen because it "is a typical remediation criterion for residential
soils at CERCLA sites", j.
"EPA Directive 9355.4-01FS "A Guide on Remedial Actions at Superfund Sites with
PCB Contamination:"
"Cleanup levels derived from the "General Approach Used by the Diqxin Disposal .
Advisory Group (DDAG) Regarding Pentachlorophenol Waste (also PCBs)," by P. des
.Rosiers, November 1988. .
13. Was the innovative technology eliminated because of the cleanup gotils? Could the standard
technology meet the cleanup goals? ~ !

Innovative technologies eliminated because of cleanup goals include:

• In situ vitrification

Standard technologies eliminated because of cleanup goals include:

• Slurry wall and cap
14. Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Total cost
Proven reliability, . .
16. How are measures compared?

Incineration was not chosen because no U.S. facilities were permitted for dioxin and furan
destruction. Furthermore, alternatives that incorporated incineration had much higher costs.
Dechlorination was eliminated because it would require treatability studies to determine its
effectiveness for contaminants at OU-4 and the suitability of treated spil for replacement in
-6-
1097
-------
excavated areas. If treatability studies were not satisfactory, or treated soils could not be
S^ackfilled on site, the alternative would not achieve any greater reduction in mobility, toxicity,
or volume, or long-term effectiveness than the selected remedy.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
\ • '. • • . ' •
No technical considerations were primary in selecting a remedial alternative. In situ
vitrification was eliminated because of the depth of the contamination and the shallow water
table. . .
References:

Geosafe Corporation. 1989. Application and evaluation considerations for in situ vitrification
technology: A treatment process for destruction and/or permanent immobilization of
hazardous waste materials. GSC 1901 (April). ,
109S
-7-,
-------
Portland Cement Company (Kiln Dust 2 & 3)
•••••- -OU-2 ... - - .; • '• •;. •
I
'" \ -
Salt Lake City, Utah
Region 8 !
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

Arsenic 13.92
Cadmium 1.9
Total chromium 27.5
Chromium VI 1.25
Lead 772
Molybdenum 43 '
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:

• 488,000 cubic yards of soil, of which
levels for lead
• 120 cubic yards of chromium-bearing
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
9/84
6/10/86
11/91
3/31/92
Background
PRP-lead
PRPs: Lone Star Industries, and Site
landowners: Williamsen
Investment ipo., L.D. Williamsen,
S.M. Hormjln, V.H. Horman,
Horman Family Trust,
C.B.Brown,'and Southwest
Investment, Inc.
FS prepared by: Tejtra Tech
27,000 cubic yards exceed health-based cleanup
I •
!'.„•,. ,
bricks (coated with cement Iciln dust)
3. What type of site is this? ,
' * ' ' • I . "
Construction. A former cement plant located in an industrial area that fis bordered by low-
density residential and vacant or agricultural land. I

TECHNOLOGY SELECTION ,! .
"..•'-. -.'-.•'}'. ' , ' '
4. What standard technologies were considered for selection in this FS? \

Standard technologies considered during the identification and screening of technically feasible
technologies were: _ ;
. - i ' .
Access restriction: Property deeds, land use restrictions, zoning ordinances
-1-
1099
-------
Containment:
Chemical treatment:
Physical treatment:
Disposal:
Soil cover . '
Chemical fixation, solidification
.Recycling
Disposal (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: ,

Chemical treatment: Dissolution and recovery of chromium, soil washing with precipitation
and recovery of lead
Thermal treatment: Batch vitrification '
6, What was the cost estimate for the innovative technology? •

During the initial screening process, in which technically feasible technologies are identified .
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been '
formulated, costs ate typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a, more detailed
evaluation. For this site, estimated costs were calculated during an evaluation based on nine
criteria established by the NCP. No innovative technologies were incorporated into remedial
alternatives.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3

RAA-4

• Standard Technology
No action
On-site fixation of chrome-bearing
bricks/off-site disposal/soil cover/
institutional controls
On-site solidification of soil/disposal
off-site/on-site fixation of chrome-
bearing bricks/off-site disposal/soil
cover
On-site solidification of soil/on-site
fixation of chrome-bearing bricks/on-
site disposal/soil cover
Estimated Costs
3 Criteria
N/A
N/A
N/A

N/A

9 Criteria
$0
$2,935,799
$6,418,434

$5,653,956

1100
-2-
-------
8. If a standard technology was chosen, why? !
" ' ' • . ' '.!-'•
RAA-3 was chosen because it offers long-term effectiveness and the greatest protection to
human health and the environment. The proposed treatment addresses site; soil and chromium-
beanng bricks. Cleanup levels will be reached; lead and arsenic contaminations will be
reduced to 500 and 70 ppm, respectively, and chromium will be reduaid to 5 mg/L or less as
measured by TCLP analyses. Stabilization/fixation eliminates site risk from direct contact with
sodlor chromium-bearing bricks. Further, treatment of site soil and bricks reduces contaminant
toxicity and mobility permanently by removing a source of ground water contamination This
alternative also provides the greatest long-term effectiveness and permanence since site
materials would be treated and disposed of off site in a controlled solid waste landfill
Disposal in an off-site solid waste landfill was preferred because it provides greater long-term
effectiveness since the release of contaminants can be prevented since it is a more controlled
environment and does not rely on institutional controls. This alternative complies with all
ARARs. Short-term risk posed by die implementation of this alternative is; comparable to that
of other alternatives. Fugitive dust generation during brick crushing arid excavation and soil
treatment can be minimized by dust suppression measures, air monitoring, and appropriate
personal protective wear. This alternative can be implemented within the year. The
equipment for treating the contaminated soil and chromium-bearing bricks is readily available
from several vendors and the treatment technology is well demonstrated, tiquipment for
crushing brick is available from several vendors. Presently there is sufficient capacity at
existing off-site solid waste landfills to accommodate the anticipated amounts of treated and
solidified soil and brick. This alternative was the most accepted by the community and is
cost-effective.
' ' • . • •• r , -.-•..•-.'-
The preferred alternative for the proposed plan was on-site treatment arid on-site disposal
During the public comment period several factors were brought out thai influenced the
decision to change the preferred alternative to on-site treatment and off-site disposal These
factors included: treated material would be subject to changing environmenfal conditions at the
site; the proposed alternative would rely heavily on institutional control!?; off-site disposal
provides greater permanence and assured effectiveness; and the cost difference between on-site
and off-site disposal is relatively small.
9.
10.
If an innovative technology was chosen, why?

An innovative technology was not chosen.
If an innovative technology, was not chosen, why not? At what stage wai the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technoloiJy selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

fonovative technologies eliminated during the initial screening include th'e following:

• Batch vitrification was eliminated because it could not be used oh site by the same
vendor to treat both chromium-bearing bricks and lead contaminated soil. Further
"vitrification involves technical problems due to the high melting temperature of the
-3-
1101
-------
furnace." Off-site vitrification was not desirable since shipment of chrome-bearing
bricks off site as a hazardous waste would be expensive because of DOT regulatory
requirements, would cause additional short-term risks, and would be contrary to RCRA
Land Disposal Restrictions. Some vendors do not have crushing facilities and bricks
would need to be crushed prior to shipping. This was considered highly undesirable
since it would increase short-term risk.
• Soil washing was eliminated because compared to stabilization, it could not address
chromium- and lead-contaminated materials simultaneously, it would not be as well
suited to treat large volumes of waste and it would be more expensive.
• Dissolution with precipitat ion and recovery of chromium was eliminated because it
could not be used on site by the same vendor to treat both chromium-bearing bricks
and lead-contaminated soil. '•

Innovative technologies eliminated during the screening of the three criteria include the
following: .•'.' .

• None , . f

Innovative technologies eliminated during the detailed analysis include the following:

• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology? -.

Protection to human health- and the environment and long-term effectiveness and permanence
were the criteria weighted most heavily in selecting a remedial alternative. RAA-3, the
selected alternative, was preferred over RAA-1 and RAA-2 because it is more protective since
it treats both lead-contaminated soil and chromium-bearing bricks. RAA-3 was preferred over
RAA-4 because.it disposes of treated materials off site in a landfill as opposed to on site. This
was considered better in the long term because the landfill is a controlled environment that can
prevent the release of contaminants in the event that the treatment breaks down (e.g.,
breakdown of stabilized mass). ;

No innovative technologies were eliminated due to these criteria.

i ,
12. What cleanup' goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup levels were presented both in the ROD and the FS. •
... . .. . . 3
1102
-4-
-------
Feasibility Study
Contaminant
Cleanup Level (mg/kg)
ProduceVNonproduceb/
Total6
ARAR or Other Basis
Carcinogens
Arsenic
130/190/77
Risk"
Noncarcinogens . \ .
Lead
Cadmium
Chrome (ffl)
Chrome (VI)
Molybdenum
500
38/1,100/37
640,000/NA/410,000
3,200/5,600/2,000
130/4,500/120
Blood6
Risk
Risk
Risk
Risk
The action level calculated for a future use scenario in which a residential popu
is exposed to produce grown in site soils. .
The action level calculated for a future use scenario in which a residential population
is exposed to site soils. .
The action level calculated for a future use scenario in which a residential population
is exposed to site soils and produce grown in site soils. '
"teased on an acceptable cancer risk of 10"4. ' '
•Basedon IU/BK Model prediction of 10 ug/dL blood lead concentration.
' ' ! ' '
.'ROD , ' ' * . '•••,'.•••• \ . ; ,. '..;
~ Contaminant
Cleanup Level (mg/kg)
ARAIL or Other Basis
-' • . - •
Carcinogens '
Arsenic
70
F^isk"
Noncarcinogens K
Lead
500
Blood"
Cleanup level is health based. For carcinogens, an excess upper bound individual
lifetime cancer risk of 10"4 was acceptable,
"Cleanup level is based on IU/BK Model prediction of 10 ug/dL blood lead
concentration. . j
-5-
1103
-------
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

' Innovative technologies eliminated because of cleanup goals include:

• None .

Standard technologies eliminated because of cleanup goals include:

• • None
1
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. .

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Preference for treatment (vs. containment)
Impact on nearby populations
Waste left in place/institutional control

16. How are measures compared?

In an effort to ensure the protection of human health and the environment, treatment of site
soil and bricks was preferred over containment. Further, following public comment, RAA-3
was preferred over RAA-4 because stabilized materials would be disposed off site. The public
preferred this option because of the potential for breakdown of the stabilized materials and
because site use would be restricted. Impact of nearby populations was a concern and
vitrification was eliminated because of the risk associated with the transport of waste materials
off site. . . •
if
77.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? .

No technical considerations were primary in selecting a remedial alternative.
1104
• -6-
-------
U.S. Department of Energy Rocky Flats Plant
OU-2

Golden, Colorado
Region 8
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

VOCs
Plutonium (Pu)
Americium (Am)
Aluminum
Arsenic
Barium
Cadmium
Calcium
Iron
Mercury
Manganese
Lead
Antimony
Vanadium
Zinc
1.700
457 pCi/g
lOOpCi/g
25,300 /
30.8
216
6.2 .
175,000
42,700
0.33
1,080
22.8 .
115
50.5
65.8
Site History .
';!
NPL Proposed: i N/A ' ..
NPL Final: N/A
Interim Measures/
Interim Remedial |
Action Plan/ j
Environmental J
Assessment :
(IM/IRAP/EA): 9/10/92
• ' '. i
Background
'• [ -
i -
Federal Facility j
PRPs: U.S. Department of Energy
FS prepared by: EG&G Rocky Flats,
Inc. i
2. . What volume of material is to be remediated?

The volume of material to be remediated included:
i
• Volume of soil to be remediated was not given.
What type of site is this? i
- •. • . - '•' • '!••'''
Department of Energy.- The site is part of a nationwide nuclear weapons research,
development, production, and plutonium reprocessing complex. .A government-owned,
contractor-operated facility on the site has been in operation since 1951 and manufactures
components for nuclear weapons and conducts plutonium reprocessing;. Plant buildings are
located within an area of approximately 400 acres, which is surrounded by a buffer zone of
approximately 6,150 acres. The site is located in a rural area. }
-1-
1105
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies were not considered in the IM/ERAP/EA.
5. Was an innovative technology considered in the FS? If so, which technology?

The following innovative technologies were considered in the IM/IRAP/EA:

Biological treatment: Bioremediation ' - ,
. Phys/Chem treatment: Dehalogenation, oxidation, steam stripping, vacuum-enhanced vapor
extraction
6". What was the cost estimate for the innovative technology?
}
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process (effective-
ness, implementability, and cost) to identify alternatives that merit a more detailed evaluation;
Estimated costs are recalculated during an evaluation based on nine criteria established by the
NCP. For this site no costs were given for any of the technologies discussed.

Cost Estimates for RAAs. That Include Innovative Technologies
(selected remedial alternative is in bold)
y
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
Innovative Technology
In situ dehalogenation
Chemical oxidation
Steam stripping
Bioremediation
Vacuum-enhanced vapor extraction
Estimated Costs
IM/IRAP/EA
N/A
N/A
N/A
N/A
N/A
1106
-2-
-------
7.' How did the cost(sj compare to standard technologies?

Cost Estimates for RAAs That Include Standard Techno logiies
(selected remedial alternative is in bold)
. Alternative
RAA-6
\
Standard Technology
No action .
Estimated Costs
IM/IRAP/EA
N/A
5. If a standard technology was chosen, why?

A standard technology was not chosen.

9. • If an innovative technology was chosen, why?

In situ vacuum-enhanced vapor extraction was chosen for removing volatile organic
compounds (VOCs) from vadose and saturated zones at three different OU-2 subsurface
environments. This technology coupled with water table depression satisfies the following
criteria: it achieves the IM/IRAP/EA objective; it addresses the source of the dissolved-phase
ground water plume; and it minimizes the risk of spreading contamination. The primary
objective of the IM/IRAP/EA is to collect information that will aid in {selecting and designing
. final OU-2 remedial actions that address subsurface residual free-phase VOC contamination.
The selection of in situ vacuum-enhanced vapor extraction will provide data that will be useful
in selecting and designing of a final action as it is potentially applicable at all OU-2 solvent ,
spill or burial sites.' This technology addresses the source of the dissolved-phase ground water
plume and reduces the likelihood of additional contaminants migrating from the vadose zone
to the saturated zone. Since this technology does not involve subsurface injection of liquid
reagents,' there is; little probability of spreading the VOC contamination. In addition,
mobilization of radionuclides that might be present is not expected because no change in _
ground water pH is expected. Subsurface IM/IRAP/EA operations and maintenance activities
would be performed in accordance with Operational Safety Analysis (OSA) procedures.
Considering the unconfmed nature of the work areas and administrative controls, potential
worker exposures to airborne VOCs would be very low. Airborne VOC concentrations would
be lower, which reduces the potential for exposure of odier on-site personnel and the general
public because of their greater distance from the source. h

In situ steam stripping is also being considered for investigation as part of the IM/IRAP/EA
because it has the potential to recover both VOCs and radionuclides, and the technology is
currently being tested by DOE. An additional project phase might, therefore, be added to the
selected remedial action at the site to conduct an in situ steam stripping pilot test after, the
results of treatability studies currently being conducted on this technology are assessed.

The Colorado Department of Health (CDH) expressed concerns regarding the IM/IRAP/EA
analysis. DOE expects to resolve all ARAR issues prior to finalizing the IM/IRAP/EA.
-3-
1107
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? -

For this site innovative technologies were discussed and eliminated in the IM/IRAP/EA.

Innovative technologies eliminated during the initial screening include the following:

• None ,

Innovative technologies eliminated during the screening of the three criteria include the
following: .. ..

* None . .

Innovative technologies eliminated during detailed analysis in the IM/IRAP/EA:

• In situ dehalogenation was eliminated but no specific reason was given for its
•elimination. Process uncertainties are associated with this technology, however, with
respect to uncontrolled mobilization of radionuclides that-might be present in the
subsurface. The dehalogenation solutions might, for example, lower the pH of the
ground water or degrade subsurface humic materials, potentially increasing
radionuclide mobility.
• In situ chemical oxidation was eliminated but no specific reason was given for its
elimination. Process uncertainties are associated with this technology, however, with
respect to uncontrolled mobilization of radionuclides that might be present in the
subsurface. , ,
• In situ bioremediation was eliminated but no specific reason was given for its
elimination. Bioremediation has successfully treated many nonhalogenated
hydrocarbons, but has been less successful with halogenated compounds. At this time,
inclusion of bioremediation investigations at this site was considered premature.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Implementation weighed heavily in selecting an interim action for this site. The simplicity of
design, fabrication using commonly available materials, ease of maintenance and potential for
cost-effective operation made in situ vacuum-enhanced vapor extraction an attractive remedial
technology. Vapor extraction is a proven technology that has been successfully applied at
many sites. Regeneration services for the GAC adsorption units are readily available, and
special labor skills are not necessary to construct and operate the vapor extraction and
treatment equipment. .,
1108
-4-
-------
12. What cleanup goals were selected? If the cleanup goal was based on
ARAR? What risk level was selected to establish cleanup goals?

Cleanup goals were not selected for this site.
an ARAR, what was that
•? Could the standard
13. Was the innovative technology eliminated because of the cleanup goals
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability .

16. How are measures compared?

Vapor extraction was chosen because it is a proven technology that has been successfully
applied at many sites.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting an alternative for this site.
-5-
1109
-------
Silver Bow Creek/Butte Area
Warm Spring Pond Inactive Area Operable Unit
1 OU-12

Upper Clark Fork River Basin, Butte, Montana
Regions ,
GENERAL SITE INFORMATION

L What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Sediments, Tailings Deposits, and
Contaminated Soils (rag/kg)
2.
Arsenic
Cadmium
Copper
Lead
Manganese
Zinc
1,850
66
9,390
1,920
9,320
7,900
What volume of material is to be
remediated?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
1983
10/89
6/30/92
Background

PRP-lead
PRPs: Atlantic Richfield Company
(ARCO)
FS prepared by: Montana Department
. .' of Health and Environmental
Services (MDHES) and CH2M
Hill
The volume of material to be remediated included:

» About 3.4 million cubic yards of contaminated sediments, tailings, and soils.

3. What type of site is this? ,
i , '
Mining. A mining operation which covers the largest geographic area in the nation being
addressed under Superfund. This site has been impacted by over 100 years of mining and
processing operations in the Butte and Anaconda areas. Mining operations stopped in 1982,
and mining and milling operations resumed in 1986. This ROD addresses the Inactive Area
Operable Unit, Pond 1,, the area below Pond 1, and the downstream portion of the Mill-Willow
bypass (lower bypass). The site covers approximately 2,500 acres, 1,000 of which are taken up
by open water associated with the pond system, tailings deposits and contaminated soils cover
about 420 acres, the remaining acreage is characterized by grasslands and marshes.
1110
-1-
-------
TECHNOLOGY SELECTION
4. What standard technologies were considered for selection in this FS? !:

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Sediments, Tailings Deposits, and Contaminated Soils
Access restriction: '

Containment:

Chemical treatment:

Physical treatment:
Disposal:
Institutional controls (zoning ordinances, easements and covenants,
land use restrictions, regulations and legal barriers,, permits), fences
Capping (native soil, clay), surface controls (surface sealing, grading,
revegetation), dust suppression, berm protection, berm stabilization
Soil/sediment stabilization (sorption, pozzolanic agents), solidification,
fixation, water leaching, neutralization . •' j • .
Solids dewatering s |
Excavation, land disposal (RCRA landfill, non-RCRA landfill, surface
impoundments)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: | ,

Biological treatment: Aerobic and anaerobic biodegradation, new biotechnologies, land
. treatment '
Chemical treatment: Chemical reduction, oxidation, solvent extraction, «x situ soil vapor
, extraction, soil washing, ex situ reduction, electrochemical,
dechlorination , t
Thermal treatment: Low temperature thermal desorption, ex situ steam extraction,
crystallization, pyrolysis, wet air oxidation, in siitu vitrification
6. What was the cost estimate for the innovative technology? ;
I ' -
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Alter lihe RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementabilityrand cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an!evaluation based on
nine criteria established by the NCP. Innovative technologies were not incorporated into
RAAs for this site.
7. How did the cost(s) compare to standard technologies?

The RAAs developed for this site changed in the ROD. These changes
separate box below. - '
are presented in a
1111
-------
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
Standard Technology
Solidify pond sediments/remove soils
from bypass/construct a new treatment
pond and a flood impoundment/
excavate contaminated soil with pond
disposal and solidification/ground water
treatment ,
Stabilize pond berms against a PMP
and the MCEb/remove soils from
bypass/upgrade treatment system/add
flood impoundment/excavate
contaminated soil with off-site
disposal/ground water treatment
Stabilize pond berms against a partial
PMP and the MCEVremove soils from
bypass/upgrade treatment system/add
settling basin/excavate contaminated soil
with Pond 1 disposal/cap Pond I/ground
water treatment
Stabilize pond berms against a partial
PMP and the MCEb/remove soils from
bypass/upgrade treatment system/add
settling basin/cap and revegetate con-
taminated soil/ground water treatment
Stabilize pond- berms against a partial
PMP and the MCEb/remove soils from
bypass/modify treatment system/add
settling basin/cap and revegetate
contaminated soils/ground water
collection with wetlands treatment
Stabilize pond berms against a partial
PMP and the MCEVremove soils from
bypass/modify treatment system/flood
contaminated soils and cap Pond I/
ground water collection with wetlands
treatment
No action
Estimated Costs
3 Criteria
N/A
N/A
N/A
' N/A
N/A
N/A
N/A
9 Criteria
$1,191,000
\
$241,000,000
$71,000,000
$77,000,000
$66,000,000
$55,000,000
$0
"Probable Maximum Flood
"Maximum Credible Earthquake
1112
-3-
-------
ROD
5.
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
RAA-8
RAA-9
RAA-10
RAA-11
Standard Technology
Dry close Pond I/removal below Pond 1
Dry close Pond I/wet close below Pond 1
Dry close Pond I/dry close below Pond 1
Wet and dry close Pond I/remove tailings
below Pond 1 '
Wet and dry close Pond I/wet close below
Pond 1
Wet and dry close Pond I/dry close below
Pondl
No action
Removal of Pond 1 and area below Pond 1
to East Hills Repository
Removal of Pond 1 and area below Pond 1
to Pond 3 Repository
Removal of Pond 1 and area below Pond 1
to Opportunity Ponds Repository
Removal of Pond 1 and area below Pond 1
to Anaconda Ponds Repository
Estimated Costs
ROD
$29,100,000
$27,500^000
$28,000,000
$21,200,000
$18,100,000
1 ' ,
$18,800,000
$0
. $50,500,000
,$50,000,000
$49,500,000
$50,700,000
If a Standard terhnnlnpv wtix rhn*t>n whv? . • . " ~ .
RAA-5 was selected because it prevents human and environmental contact, and decreases
migration of the contaminated material to ground water. No significant risks will remain
relative to the potential for migration of the contaminants. The wetclosure proposed under
RAArS will substantially eliminate the tailings as a source of contamination by providing a
reducing environment, to immobilize the metals. Toxicity will be reduced by chemically fixing
.dissolved or soluble metals in a less soluble state through lime treatment iind maintenance of a
high pH environment. In addition, RAA-5 includes dry closure below Pond 1, which will
result in less risk of recontamination from floods in Silver Bow Creeks than the other
alternatives. RAA-5 will leave contaminants within the historic flood plain below Ppnd 1 but
will protect them up to the 0.5 PMF and the MCE through construction of flood protection
dikes along the Mill-Willow Bypass. RAA-5 will have the least impact because it does not
require the removal of materials. In addition, RAA-5 can be fully implemented over a 2-year
construction period. RAA-5 also will have the least impact on the existing wetlands below
Pond 1. In fact, RAA-5 maximizes the area of enhanced wetlands both, within and below Pond
1, The wet closures associated with this alternative in the eastern third! of Pond 1 and in the
area below Pond 1 will result in an expansion of waterfowl habitat. RAA-5 also is supported
by the public.
1113
-------
9. If an innovative technology was chosen, why?

AJI innovative technology was not chosen.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Oxidation was eliminated because it is not applicable to the waste characteristics.
• Solvent extraction was eliminated because it is not applicable to inorganics or to sites
conditions and volumes of water are too large.
• Low temperature thermal desorption was eliminated because it is not applicable to
inorganics.
• Ex situ steam extraction was eliminated because it is not applicable to waste
characteristics and site conditions and volumes of .water are too large.
• Ex situ soil vapor extraction was eliminated because it is not applicable to waste
characteristics. .
• Crystallization was eliminated because it is not applicable to waste characteristics and
site conditions. .
« Soil washing was eliminated because it is not applicable to inorganics.
" Ex situ reduction was eliminated because it is not applicable to site conditions and
volumes of water are too large.
" Electrochemical was eliminated because it is riot applicable to site conditions and
volumes of water are too large. .
» Dechlorjnation was eliminated because it is not applicable to inorganics and aqueous
wastes.
• Aerobic and anaerobic biqdegradation was eliminated because it is not applicable to -
inorganics and is not technically implementable. '
• New biotechnologies was eliminated because it is not applicable to inorganics and is '
not technically implementable.
» Land treatment was eliminated because it is not applicable to inorganics and is not
technically implementable.
• Pyrolysis was eliminated because, it is not applicable to inorganics and is not
technically implementable. .
» Wei air oxidation was eliminated because it is not applicable to inorganics and is not
technically implementable. .
• In situ vitrification was eliminated because it is not applicable to site conditions and
volumes of water and waste are too large.
1114
-------
Innovative technologies eliminated during the screening of the three criteria include the
following: i

» Chemical reduction was eliminated because it would not be implementable. Soil
concentrations are too low for effective recovery. The recovery operation might
present greater hazards than the soils-do now and--this treatment is costly.
•' " - - . • r . , ' -
. .- .. , . • • • . . _ ^ ..-..,.
Innovative technologies eliminated during the detailed analysis include the following:

• None • •'..;'
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
- ' - ' - i ' - • I
Protection of human health and the environment, implementability, anti cost were weighted
most heavily in selecting the chosen alternative. RAA-5 provides protiictiveness that equals or.
exceeds the other alternatives considered, offers the .potential for being a permanent remedy, is
implementable, is cost effective, and provides the greatest environmental Isenefits that can be
practically achieved. RAA-5 is the most easily implemented alternative because construction
equipment and services required to implement RAA-5 are readily available. The selected
alternative is also the most cost effective, both in initial construction costs; and from a total
present-worth standpoint. * {
, • • '' • ' - '
-• - ' • • P \ . '
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? :
• N ;' i ' -
-" ' ' ' - " ' , |- -'
Cleanup levels were not established for this site but remediation goals were established by
EPA and MDHES as part of the FS process.
13. . Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?
*•• • • ' ' - ].'".'•:•.
Innovative technologies eliminated because of cleanup goals include: I ,

• ' ' ' i " , . '
- .•. None ."•••'' • . • • - ,!,•,,'•
- - * -• • j ...'-,.'•
-..--. , - ' - ( !:•/',
Standard technologies eliminated because .of cleanup goals include:
. , ^ .. ^ '' ; J. " . j : • " ..'•'.
« • None ' ' '- , . . • 'i ' . _ • ; •

' ' • ' '..•'[' '.'"'.•
14. Were treatability studies conducted on the innovative, technology or standard technology?

Treatability studies were not conducted. , \ '• .
1115
-6- ' '• '•"".. I • v .' : - -

-------
15. What measures/criteria were used to compare alternatives? ,

The following measures were used to compare the alternatives:

Cost effectiveness ,
Proven reliability
Preference for treatment (vs. containment)

16. How are measures compared?

The selected alternative is the lowest cost alternative examined in the Proposed Plan, except
• for the no action alternative. Alternatives involving total removal of contaminants (RAA-8
through RAA-11) cost significantly more than the selected alternative, and yet did not provide
significant additional overall protection of human health and the environment* The
* components of the selected remedy are well-developed technologies and are expected to be
easily implementable. The selected alternative utilizes lime addition to many areas of
contamination within the inactive area. Lime addition, followed by wet closure, reduces the
" mobility of contaminants. The remedy utilizes treatment. „ ' ' •
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in The selection of the remedy?

Technical considerations were not primary in selecting a remedy.
1116
-7-
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Wasatch Chemical Co. (Lot 6)

Salt Lake City, Utah
Region 8
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
.this feasibility study? '

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)
' 4,4',-DichlorodiphenyIdichloro-
ethane (4,4',-DDD)
4,4',-Dichlorodiphenyldichloro-
ethene (4,4',-DDE)
4,4',-Dichlorodiphenyltrichloro-
ethane (4,4', DDT)
Alpha-Chlordane
Gamma-Chlordane
Heptachlor
2,3,7,8 Tetrachlorodibenzodiosdn
Hexachlorobenzene (HCB)
Trichloroethene (TCE)
Tetrachloroethene (PCE)
2,4-Dichlorophenoxyacetic acid
Pentachlorophenol (PCP)
2,4,5<-Trichlorophenoxyacetic acid

Sludge (mg/kg)

4,4',-Dichlorodiphenyldichloro-
ethane (4,4',-DDD)
4,4' ,-Dichlorodipheny Idichloro-
ethene (4,4',-DDE)
4,4' ,-Dichlorodipheny.ltrichloro-
ethane (4,4', DDT)
Alpha-Chlordane
Gamma-Chlordane
Heptachlor
2,3,73 Tetrachlorodibehzodioxin
Hexachlorobenzene (HCB)
Trichloroethene (TCE)
Tetrachloroethene (PCE)
2,4-Dichlorophenoxyacetic acid
2,4,5-Trichlorophenoxyacetic acid
0.4

4.5

8.1
520
890
5.3
0.011
66
1.8
22
30.768
250
1.111
0.28

6.3

2.8
520
680
26
0.013
49
440
200
0.634
0.3
Site! History
NPL Proposed:
NPL Final:
FS:
ROD:
1/87
2/11/91
8/22/90
3/29/91
Background
i ' '
PRP-lead ' '••'.'•
PRPs: Entrada Industries, Inc., Mountain
Fuel Supply Co., Inc., Interstate
x Brick Co., ^and Quester Corp. (the
Entrada Group); McCall Oil and
Chemical Co., and d/b/a Great
Chemical Co. ([the Great Western
Group); Hiintsman-Christensen
Corp., Ladid E. Christensen, and
A. Elaine Huntsman, Jr. (the
Huntsman-Christensen Group);
Lawnlife Corp.; and Peter Ng
FS prepared by: Elarding Lawson
Associates
-1-
1117
-------
2. What volume of material is to be remediated? ,

The volume of material to be remediated included: '

• 2,370 cubic yards of waste sludge
• 2,328 cubic yards of soil .

3. , What type of site is this?

Agricultural Chemicals. The site has been used for the formulation/blending, and repackaging
of cleaners, acids, caustics, herbicides, pesticides, and fertilizer. The site is located in an
industrial area.
•I
TECHNOLOGY SELECTION .

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing, warning signs, deed restrictions, access restrictions
Containment: Capping, surface sealing
Chemical treatment: In situ stabilization, stabilization/solidification (cement-, asphalt-,
pozzolan-, polymerization-based), neutralization, sorbent addition
Thermal treatment: Incineration (fluidized bed, rotary kiln, infrared), plasma torch
Disposal: Excavation, on-site/off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: . , ,

Biological treatment: In situ biodegradation, slurry phase biodegradation, solid phase
biodegradation, rotating biological contractors, white rot fungus,
landfarming
Phys/Chem treatment: On-site chemical extraction (Best Extraction Sludge Treatment, or
BEST), glycolate dechlorination (APEG), critical fluid extraction,
oxidation, soil washing, in situ soil flushing, reduction (iron, zinc^ and
aluminum metal powers reduction), in situ vacuum extraction
Thermal treatment: In situ steam stripping, vitrification (electric pyrolyzer), pyrolysis, low-
temperature thermal stripping, molten salt, molten glass, in situ
vitrification (Geosafe process was referenced in the FS)
1118
-2-
<*)
-------
^v
6. What was the cost estimate for the innovative technology? |

During the initial screening process, in which technically feasible technologies are identified
- (prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify-alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. j

Cost Estimates for RAAs That Include Innovative Technjoloj'ies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-4
RAA-5
RAA-6
RAA-8
'
Innovative Technology
Excavation/vacuum extraction/off-site
incineration/landfarming
Excavation/vacuum extraction/in situ
vitrification/landfarming
Excavation/vacuum extraction/on-site
glycolate dechlorination/off-site
incineration
Excavation/vacuum extraction/ , •
landfarming
Excavation/vacuum extraction/off-site
disposal/landfarming/off-site
incineration
Estimated Costs
3 Criteria
N/A
• . • r
N/A
N/A ;
, , ij-
-1
N/A
N/A
[ - ,
9 Criteria
eliminated"
$3,300,000
$4,100,000
•eliminated
$1,700,000
7. How did the cost(s) compare to standard technologies? ,,

Cost Estimates for RAAs That Include Standard Techijiologies
(selected remedial alternative is in bold) |
8.
If a standard technology was chosen, why?

A standard technology was not chosen.
Alternative
RAA-1
RAA-2
RAA-7
Standard Technology
No action
Institutional controls
Capping/off-site incineration
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$24,000
eliminated
$660,000 '.
-3-
1119
-------
P. If an innovative technology was chosen, .why?

The selected alternative RAA-4, which incorporates in situ vitrification (ISV) is the most
protective alternative (in terms of overall protection of human health and the environment)
because the site contaminants will be destroyed permanently and rendered harmless applying
this technology on site. Landfarming soils contaminated with xylene and toluene provides an
extra measure of protection by reducing the levels of these hydrocarbons through biological
degradation and volatilization. The long-term effectiveness criteria would be achieved and
health risks would be reduced substantially. The ISV process is permanent and irreversible
and best meets the criterion of reduction of toxicity, mobility, or volume through treatment.'
Thus, the SARA (Superfund Amendments and Reauthorization Act) preference for innovative
permanent treatment technologies is met. The Geosafe ISV process is an innovative
technology that provides a permanent treatment remedy. Wastes are permanently destroyed
with high destruction removal efficiencies. Through permanent treatment, the use of ISV will
result in residual carcinogenic risks of 10'6 based on continued industrial use of the site The
selected alternative would exceed all ARARs. Note that a waiver for the relevant and
appropriate LDRs (Land Disposal Restrictions) during staging of the waste materials prior to
treatment would be required. Upon completion of treatment, LDR requirements would be met
The ISV process would equal or exceed the destruction and removal.efficiency of any other
treatment process, including incineration. Contaminants removed by the off-gas treatment
system are subject to treatment in a subsequent ISV melt, thus increasing the destruction and
removal efficiency (DRE). Treatability studies for ISV showed removal efficiencies of
between 99.9997 and 99.99995 percent of all organic contaminants of concern "considered
together," and, in particular, is expected to destroy or remove 99.9999 percent of dipxins.
RAA-4, although using an innovative technology, is the most readily implemented overall
The processing of contaminated materials below grade is inherently safer than handling and
treating materials above ground. Unlike the availability of an off-site incinerator, there is no
facility problem associated with ISV. This is the only alternative with the potential to
reembody the former evaporation in place," which would substantially minimize materials
handling concerns, such as dust generation. When considering these benefits, the ISV'process
is safer than competing treatment processes for occupational, public, and environmental
exposure risk. In addition, the total cost of ISV compared favorably with the total costs of
competing treatments. Finally, ISV has the potential to enhance ground water remediation by
removing and treating possible source areas.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

" Critical fluid extraction was eliminated because the technology is primarily applicable
to high-oil-content waste. . -
• Oxidation was eliminated because of problems with incomplete oxidation and reagent
consumption byproducts. This technology also was eliminated as a result of limited
test data, and reagent delivery and recovery problems.
1120
-4-
-------
Pyrolysis was eliminated becauseof limited test data. ;
Vitrification (electric pyrolyzerjv/as eliminated because of limited test data.
Molten glass was eliminated because of limited test data. j
Molten salt was eliminated because of limited test data. .
In situ biodegradation was eliminated because the effectiveness of the technology is
questionable given the existence of multiple sources of TCL chemicals, heterogeneous
geology, and the presence of inhibitory heavy metals and pesticides. Given the
difficulty in effectively delivering the materials and controlluiig the overall process in
soils with substantial TCL chemical concentration variances, in situ biodegradation is
not well suited to the site. | •
• Solid phase biodegradation was eliminated due to the relative resistance of dioxin, •
ehlordane, and other pesticides to biodegradation. The process currently is in a
developmental stage and the majority of tests have been perfornwjd only at bench
scale. Full-scale implementation of this process is, therefore, not feasible at this time.
• In situ vacuum extraction was eliminated because the technology is not applicable UK
the indicator chemicals in site soils, except for the VOCs and the more volatile BNAs.
• In situ steam stripping was eliminated because the increased costs of this technology
would not provide increased effectiveness as compared to vacuum extraction.
• On-site chemical extraction (BEST process) was eliminated because the current policy
of the company that developed the technology (Resource Conservation Company) does
not allow treatability bench-scale testing of dioxin containing materials exceeding 1
ppb and treatability testing is necessary to evaluate the attainment of treatment goals.
• Low-temperature thermal stripping was eliminated because the ttschnology is not
applicable to the indicator chemicals in site soils, except for the VOCs and the more
volatile BNAs. "
• Soil, washing was eliminated because this technology is not capable of addressing the
very fine particle size range found at the site, thus precluding the treatment of the
waste sludge material. Additionally, soil washing as applied to soils containing
, , pesticides and dioxin would not be effective and probably would be applied as a
volume-reduction technology concentrating the soil fines for further processing by a
second technology. ' j .
• Slurry phase biodegradation was eliminated because of the relative
nonbiodegradability of dioxin, ehlordane, DDT and other pesticides in site soils. In
addition, full-scale treatment applications are limited.
• White rot fungus -was eliminated because the technology has not been developed to the
point where an assessment of large-scale feasibility is possible.
• In situ soil flushing was eliminated because of limited test data gind reagent delivery •
and recovery problems. ,
• . Reduction (iron, zinc, aluminum metal powders) was eliminated because of limited test
data and reagent delivery and recovery problems.

Innovative technologies eliminated during the screening of the three Criteria include the
following: , .

• None - ~ ; • '

innovative technologies eliminated during the detailed analysis include tide following:

• Glycolate dechlorination (APEG process) was eliminated because the alternative that
includes this technology, RAA-5, while it provides high overall effectiveness, costs
more than the selected alternative. The cost of the APEG treatment is higher than that
-5-
1121
-------
of any other alternative evaluated during the detailed analysis of remedial action
alternatives. The effectiveness of this technology in treating some herbicides has not
been confirmed, and treatment of material with high concentrations of herbicides might
require off-site incineration. Although the probability of traffic accidents and spills is
small, such incidents potentially could involve a large population and unknown
environmental risks. APEG treatment residuals could require a delisting step prior to
remediation. Finally dust generation associated with crushing the oversized materials
to 4-inch size, as required by the APEG process, poses potential short-term risks to
workers. , -
11.
12.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
•which criterion? Which of the criteria supported the use of a standard technology?

Long-term effectiveness and permanence, implementability, and reduction of toxicity, mobility,
or volume were weighted most heavily in selecting the technology. The in situ vitrification
process ranks highest in terms of reducing toxicity, mobility, and volume through thermal
reduction of all organic contaminants. ISV ranks highest in terms of long-term effectiveness
and permanence since there would be no residuals after treatment. Problems with
implementability were identified for all the alternatives that were subjected to detailed analysis
except RAA-4. ISV is implementable, the required equipment and support services are
available, treatability studies have shown it to be technically feasible at the site, and, it would
be the easiest to implement.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level
(ppb)*
ARAR or Other
Basis
Carcinogens
4,4' ,-DichlorodiphenyIdichloroethane
4,4' ,-Dichlorodiphenyldichloroethene
4,4',-Dichlorodiphenyltrichloroethane
Alpha-Chlordane
Gamma-Chlordane
Heptachlor
Tetrachlorodibenzodioxin (Total)
Hexachlorobenzene
Trichloroethene
Tetrachloroethene
26,000
19,000
19,000
7,000
7,000
2,000
20
7,000
103,000
22,000
Risk .
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
1122
•_*>;
1 -6-
-------
'Cleanup levels are for soils only; no cleanup levels were developed for waste sludges.
For carcinogens, an excess upper bound individual lifetime risk of between 10"" to 10"*
was acceptable. ;

" '' " ••'' ' !•'• ' •' •
73. ! Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ^ •... •;

Innovative technologies eliminated because of cleanup goals include:!

' •, None -• •• ••","•,.•'

Standard technologies eliminated because of cleanup goals include:

' • None '• • . - . • , - • •! •'-..-.
1 ' " - . ' , • ' '• ' '

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted on the following standard technologies:
-' • - , • "j. *"•'•,.'
• " " • "" i
-• • None' . • ' . -j ' ' . ' .

Treatability studies were completed on the following innovative technologies
j ' , . • ' - •
• Treatability studies were conducted for ISV. The tests performed on site media
demonstrated that destruction and removal efficiencies in the range of 99.9997 to
99.99995 percent can be achieved for all site contaminants including dioxins.
• Treatability studies were performed on glycolate dechlorinatibn (APEG process). The
tests performed on soils and sludges showed a destruction and removal efficiency of
99.96 percent for dioxin. Substantial reductions in the level of other highly
chlorinated compounds, such as pesticides, also were observed. The effectiveness of
glycolate dechlorination in treating some herbicides has not been confirmed, and
treatment of material with high concentrations of herbicides might require off-site
incineration.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare,the alternatives:

On-site vs. Off-site treatment

76. How are measures compared?
. t . - . , | ' ' .
On-site vs. off-site treatment is discussed particularly in comparing RAA-4 (ISV) and
RAA-5 (APEG). The APEG process would require materials to be trailsported off site for
- incineration possibly posing risks during handling and transportation:! less handling and no offr
site transport is required for ISV. c !
-7-
1123
-------
17.
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting the chosen alternative. Because of the
existence of multiple sources of TCL chemicals, the site's heterogeneous geology, and the
presence of inhibitory heavy metals and pesticides on site, the effectiveness of in situ
biodegradation was considered questionable. Additionally, soil washing was eliminated
because it would be inappropriate for the very fine particle size range found at the site, and
also is not effective for soils containing pesticides and dioxin.
1124
-8-
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Advanced Micro Devices 901
(combined with Signetics and TRW Microwave)
Sunnyvale, California
Region 9
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Dichlorobenzene (DCB) 242
Trichloroethene (TCE) 80
Tetrachloroethene (PCE) 35
Dichloroethene 0.072
2. What volume of material is to be
remediated?,

The volume of material to be remediated
.included:

• 37 cubic yards of soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/84
6/86
3/91
9/91
Background
'-•V '. •'
PRP-lead i
PRPs: Advanced Micro,Devices
FS prepared by: Harding Lawson
Associates, Engineering-
Science, Inc., Emcon
Associates, Weiss Associates
3. What type of site is this? .. .•
• ,1 •

Electrical Equipment. A semiconductor manufacturing facility located in an industrial park
surrounded by, commerciaVlight industrial and residential areas, i
TECHNOLOGY SELECTION
. ' f .,'"..„,',, •--,'.'.
4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Thermal treatment: Incineration
Disposal: Disposal (off-site)
-1-
1125
-------
5, Was an innovative technology considered in the FS? If so, which technology?

Ii.- ' /alive technologies considered during the identification and screening of technically
feasible technologies were: .

Biological treatment: Biodegradation (enhanced, in situ)
Chemical treatment: Soil flushing
Physical treatment: Vacuum extraction
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2
RAA-4
RAA-5
RAA-6
Innovative Technology
Soil flushing
Vacuum extraction
Heated air-assisted vacuum extraction
Steam-assisted vacuum extraction
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$2,828,000
$2,829,000
$2,931,000
$3,547,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs Thai Include Standard Technologies
(selected remedial! alternative is in bold)
Alternative
RAA-1
RAA-3
RAA-7
*
Standard Technology
No action >
Soil aeration
Excavation/ofT-site disposal/
incineration
Estimated Costs
3 Criteria
N/A
N/A :
N/A •
9 Criteria
$1,515,000
$2,700,000
$2,651,000
L 1

j
1126
-2-
-------
8. If a standard technology was chosen, why? !

RAA-7 was selected because it offers the greatest protection of human health and the
environment in a reasonable time frame. Furthermore, it is the only ipmedial alternative that
complies with all pertinent ARARs in a reasonable amount of time. It provides the greatest
reduction in toxicity, mobility, and volume of soil contaminants through excavation and
incineration. This alternative provides the greatest long-term effectiveness because the soil
contaminants are removed from the site and eventually destroyed at aik off-site treatment
facility. Removal prevents the soil from acting as future source of ground water
contamination and prevents soil contaminants from volatilizing.
9.
If an innovative technology was chosen, why?

An innovative technology was not selected.
•10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? I
". ' - • ! • • ' '
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Enhanced biodegradation (ex situ) was eliminated because it wfould not be an effective
technology for the site since chlorinated aliphatic hydrocarbons, are; volatile at ambient
temperature.
» In situ biodegradation was eliminated because the anaerobic process' for chlorinated
aliphatic hydrocarbons results in the accumulation of undesirable end products (vinyl
chloride) and the aerobic process is less effective for highly halogenated compounds
such as those in the study area.

Innovative technologies eliminated during the screening of the three criteria include the
following: .

A three-criteria screening was riot conducted. i
•••''• , ' . ... ' ' " ' h -
Innovative technologies eliminated during the detailed analysis include the following:

• Soil flushing was eliminated because it might not effectively reinove PCE and DCB
from the soil. , t
» Vacuum extraction was eliminated because it would not effectively eliminate PCE and
DCB since they are tightly bound to the soil.
• Heated air-assisted vacuum extraction was eliminated because ii would take hundreds
of years to reach cleanup levels given the physical properties of DCB and PCE.
Furthermore, this is an evolving technology and pilot tests at the site would be needed
to determine its effectiveness. There was concern that the techiiology_would remove
volatile organics but might leave elevated levels of DCB in the soil
-3-
1127
-------
n
Steam-assisted vacuum extraction was eliminated because it would take hundreds of
years to reach cleanup levels given the physical properties of DCB and PCE.
Furthermore, this technology is evolving and pilot tests at the site would be needed to
determine its effectiveness. There was concern that it would remove volatile organics
but might leave elevated levels of DGB in the soil. ,
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment and compliance with ARARs were the criteria
weighted most heavily in selecting a remedial alternative. The selected remedy is the only
alternative that would remove site contaminants permanently in a reasonable amount of time.

Soil flushing, soil aeration, vacuum extraction, heat-assisted vacuum extraction, and steam-
assisted vacuum extraction were eliminated because their compliance with cleanup level was
questionable. Moreover, if they could reach cleanup levels, it would require hundred of years.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm) ARAR or Other Basis
Carcinogens
Total VOCs
1
RWQCB*
'Since there are no ARARs for soil, target cleanup levels were based on guidance
provided by the Regional Water Quality Control Board (RWQCB) and the Department
of Health Services (DHS) for the protection of ground water from leaching chemical-
bearing soils.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

" Soil flushing •
» Vacuum extraction . .
B Hot air-assisted vacuum extraction
" Steam-assisted vacuum extraction . , , .

Standard technologies eliminated because of cleanup goals include:

" None
1128
-4-
-------
77.
14. Were treatability studies conducted on the innovative technology or standard technology?
1 . - , ,.,.,.:•'•
•'•-.'' . ' - ' , . ' ' . ' ! 1 • "
\ "- IN '
Treatability studies were not conducted. •!.-'.'

75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:
Percentage risk reduction
Time to design/construct/operate
76. How are.measures compared? '}.•''

RAA-7 was preferred because it will immediately prevent the soil from acting as a source of
ground water contamination and will prevent soil contaminants from volatilizing and
eventually migrating into confined spaces of dwellings at the surface. Other alternatives were
not preferred either because their effectiveness was uncertain or they would require hundreds
of years to reach cleanup levels. ! -
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
' . ' - ' ' • : ' , VV
Technical considerations were not primary in selecting a remedial alternative.
-5-
1129
-------
Atlas Asbestos Mine

Coalinga, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
.contaminants were:

Tailings and waste ore (mg/kg)

Asbestos 1,000,000

Soil/Sediment (mg/kg)

Asbestos 60,000
2. What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
9/84
3/90
2/14/91
Background

EPA Fund-lead
PRPs: The Atlas Minerals Division of
the Atlas Corporation, Vinnell
' ' Mining and Minerals
Corporation, Wheeler Properties,
Inc., California Mineral Corp;,
The U.S. Bureau of Land
Management
FS prepared by: Woodward-Clyde .
Consultants
3 million cubic yards of asbestos
ore, asbestos mine and mill tailings, and contaminated soil
3. Wliat type of site is this?

Mining. An inactive asbestos mine located in a rural area.
TECHNOLOGY SELECTION "

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
Fencing, personal protective wear, suspend private development
Vegetative cover, capping (soil, asphalt, soil-cement, gunite, RCRA),
containerization, sediment retention dams
Chemical treatment: • Fixation (plant processing, pressure grouting, deep soil mixing, area
mixing) ;
1130
-i-
-------
Physical treatment:
Disposal:
Slope stabilization, reprocessing, dust suppression
Disposal (off-site) !
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Thermal treatment: In situ vitrification, plant processing vitrification
6. What was the cost estimate for the innovative technology?
• ' *- • -, • 4-<. , . - •
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. No innovative technologies wen; incorporated into
RAAs. - !
7.
How did the cost(s) compare to standard technologies? . „
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) [
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
RAA-5
RAA-6
RAA-7
RAA-8
RAA-9
Standard Technology
No action ,
Access restrictions
Stream diversion/sediment trapping
dams/access restrictions/revegetation
Stabilization/stream diversion/sediment
trapping dams/access restrictions/
revegetation
. Capping/access restrictions/stream
diversion
Chemical fixation/access restrictions/
stream diversion
Off-site disposal '
Construction of a dam ,
Enlarge pond basin
"»•«.
Estimated Costs
3 Criteria
N/A
N/A
. , N/A -
N/A
N/A
N/A
N/A
N/A
N/A
9 Criteria
$833,200
$561,200
$4,228,900
$9,401,800
$14,620,500
$103,473,200
$234,326,000
,$16,500,000
eliminated
-2-
1131
-------
S. If a standard technology was chosen, why?

RAA-3 was chosen because it protects human health and the environment by reducing site risk
from inhalation of asbestos-containing air at the mine and nearby areas and by restricting
access to the mine area. The stream diversion and sediment retention dams minimizes the
release of asbestos from the mine into -local creeks. RAA-3 does not disturb the protective
crust on the stock piles to a great extent. The revegetative element of this alternative, if .
successful, will help stabilize disturbed areas, minimize erosion, and reduce future releases of
contaminants. Minor, regrading improves surface drainage and increases the Stability of the .
mines and stockpile areas. RAA-3 provides long-term effectiveness since it reduces asbestos
release to air and surface water and restricts access to those areas where asbestos has been
transported. This alternative minimizes short-term risk and can be implemented in the shortest
amount of time. The selected remedy is cost-effective because it provides, overall effectiveness
commensurate to its cost.
9. . If an innovative technology was chosen, why?

An innovative technology was not selected.

; ' .'..-. i
JO. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ,
••'''•' •
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ vitrification was eliminated because its technical implementability for asbestos-
containing waste ore and mill tailings is open to question given their relatively high
proportion of non-asbestos minerals. In addition, vitrification is not implementable
because of the extremely high volume and highly variable depth of the tailings
materials, the large areas of rugged and possibly unstable terrain of the site that would
potentially be inaccessible to the nominally mobile yet ponderous vitrification
equipment, and the extremely high electric energy demands of the vitrification
equipment at a site remote from sources of power.
• Plant-processing vitrification was eliminated for the same reasons as in situ
vitrification.

Innovative technologies eliminated during the screening of the three criteria include the
following: ' ,

• None ' - , • ••

Innovative technologies eliminated during the detailed analysis include the following:

» None ' , •'•-..;
*
' " • . - ' ' . •
1132 . ;. . • : ;•. . '•• -/ " • • '. ....
- ' • -3- ' " ' ' ••'•-..-
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were protection to human
health and the environment and cost. RAA-3 provides as much protection as cither alternatives
but at a much lower cost.
72. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
. . ' ' • . :r • • . .
No cleanup levels were established.
13. Was the innovative technology eliminated because of the cleanup goah? Could the standard
technology meet the cleanup goals? . i ,

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

. • Construction of a dam
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

_ ' . _ / • :.*'_,
75. What measures/criteria were used to compare alternatives? j
..' • ' """ ' • • " '!•
The following measures were used to compare the alternatives:
-i,
Cost/unit risk
Time to design/construct/operate j
. , - Preference for containment (vs. treatment) |
Impact on nearby populations i

16. How are measures compared? , ; •
"... • • .' i , . • '
Implementation time was a factor in selecting an alternative. The chosen alternative only takes
4 months to implement, while RAA-6 and RAA-7 would have taken 4 and 10 years,
respectively. The selected remedy was chosen because it is cost effective since its cost is one-
half that of RAA-4 and one-third the cost of RAA-5; RAA-4 and RAA-5 offer only a
comparable level of public health and environmental protection. Treatment was not possible
because there is currently no known cost-effective, permanent treatment that would control the
1133
-------
release of asbestos from soil at the site. Fixation was considered in RAA-6; however, it was
eliminated because of difficulties associated with implementation and high cost.

17. What technical considerations were factors in selecting a remedy? Were technical
• considerations primary in the selection of the remedy? -

No technical considerations were primary in selecting a remedial alternative.
1134
-5-
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FMC (Fresno Plant)

Fresno, California
Region 9
GENERAL SITE INFORMATION
What were the principal contaminants,
contaminant levels, and
this feasibility study?

media addressed in

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

Aldrin -
Dieldrin
Toxaphene
DDT"
Chlordane
Endosulfans*
EDB
Heptachlor
Disyston
Phorate
Dimethoate

170
100
15,000
1,700
8.7.
3.000 • • , .'
6.7
',.-', '\
Site History
••''.- 1
NPL Proposed: ! 10/15/84
NPL Dropped: 10/4/89
FS: 5/91
ROD: 6/91
' ' 1 ' • • • •
Background
1 ' ' '
PRP-lead
PRPs: FMC ' 1 ' ' .
FS prepared by: Bechtel
Environmental, Inc.
•;1 ' • '
i
1.3 '"- . , •• '' ' ••
280 j
2,000 x
24 . • ••''-. •'•- ' ;.. .. . , :>
"includes DDE and ODD
Includes endosulfan I and endosulfan
2. What volume of material is to be remediated?

The volume of material to be remediated included:

• ' 19,000 cubic yards of soil :

' ' - • ' • ' .

3. What type of site is this?

Agricultural Chemicals. A pesticide formulation facility located in an urban area.

» . 'i -'-_...

TECHNOLOGY SELECTION ' i - '
' 'i ' ' ' '
~ . . . ' , i.
4. What standard .technologies were considered for selection in this FS? \
J ' ''"".-' ' ! • '"

Standard technologies considered during the identification and screening of technically feasible
technologies were:
1135
-------
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Deed restrictions .
Capping (clay, asphalt, soil, multimedia, soil cement/asphalt)
Stabilizatior 'fixation, enhanced photodegradation, hydrolysis
Incineration trotary kiln, circulating bed, infrared)
Excavation, RCRA landfill (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Enhanced biodegradation
Phys/Chem treatment: Soil washing (B.E.S.T., MTARRI AEMC), oxidation/reduction,
*• enzymatic degradation, KPEG dechlorination, soil flushing, solvent
extraction
Thermal treatment: Vitrification, wet air oxidation , .
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-6
RAA-7
RAA-8
Innovative Technology
Excavation/soil washing/stabilization/
capping/institutional controls
Excavation/solvent extraction/ . .
institutional controls/capping
Excavation/vitrification/capping/
institutional controls
Estimated Costs
3 Criteria
$7,700,000
$12,300,000
$19,900,000
9 Criteria
$10,103,654
$15,660,298
$25,649,695
7).
1136
-2-
-------
7. How did the cost(s) compare to standard technologies? ,

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-4
i.
RAA-5
RAA-9
Standard Technology
No action
Institutional controls
Institutional controls/capping
Excavation/on-site RCRA landfill/
capping/institutional controls
Excavation/stabilization/institutional
controls/capping
On-site incineration/capping/
institutional controls
I Estimated Costs
3 Criteria
$0
$95,000
$1,300,000
$7,600,000
' l
$4,-[00,000
$21,ikOO,,000
• r
9 Criteria
$0
$93,192
$1,498,027
$9,747,198
$5,806,139
$27,721,216
8. If a standard technology was chosen, why?

Stabilization and capping were selected for residuals.
If an innovative technology was chosen, why?

RAA-6 was selected because it will be protective of human health arid the environment. This
alternative addresses the threat of exposure to contaminated soil in seiveral ways. First, by
capping the site and implementing institutional controls, .the threat caused by ingestion and
direct contact is removed. By eliminating the soil exposure pathway,! the: remedy attains a
carcinogenic risk of 10"* and a noncarcinogenic Hazard Index of less than one. By excavating
and treating surface soil to risk-based cleanup levels, the remedy also provides long-term
protection from ingestion and direct contact with soil, should capping ami institutional controls
fail. By implementing institutional control, capping, and the associated {(round water remedy,
the threat of exposure to deep subsurface soil that could potentially migrate to ground water
also is addressed. The selected remedy uses soil washing and stabilization treatment
technologies to reduce the volume of contaminated soil. Additionally, a cap will be placed
over the site to reduce the mobility of soil contaminants left in place, It offers a high level of
long-term effectiveness since it achieves contaminant destruction, complies with ARARs, and
is cost-effective. , ,'.!
-3-
1137
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? , \

Innovative technologies eliminated during the initial screening include the following:

• Wet air oxidation was eliminated because it requires an aqueous media, therefore, soil
would have to be mixed with large amounts of water to form a pumpable slurry that
could be fed into the reactor. The resulting waste stream would be far more difficult
to handle than the soil. In addition, the water would ultimately have to.be separated
from the soil and might require further treatment prior to disposal. Second, the
quantity of inert solids, such as sand,, in the soil might cause an erosion .problem in the
oxidation of a conventional wet air oxidation system. These systems are not designed
to handle waste containing large quantities of inert solids such as sands. Finally, the
concentrations of oxidizable organics in the soil are tod low to be economically treated
with this process. .
« Enhanced biodegradation was eliminated because the organochlorine pesticides are
very resistant to biodegradation, as well as being toxic to microorganisms. While they
are susceptible to partial transformation, most of them are not mineralized. There
appears to be some limited potential for dechlorination under anaerobic conditions, and
oxidative degradation under aerobic conditions. Furthermore, while there has been
some success with the biodegradation of specific pesticides in the laboratory, it is ^pr---,
. unknown whether biodegradation would be effective in a soil that contains a variety of V
pesticides at a wide range of concentrations. It would be difficult to develop and
optimize a biodegradation treatment system that would effectively degrade all of the
site contaminants. In addition, compounds with a high octanol-water partition
coefficient tend to sorb onto soils and might remain unavailable to microorganisms.
Under such conditions, the time needed for effective degradation is uncertain.
• Oxidation was eliminated because it has not yet been proved to be effective for the
range of site contaminants. Furthermore, oxidizing agents are nonspecific and. might
oxidize all organics and inorganics including those that comprise the soil, reducing
natural organic matter in the soil and resulting in decreased sorption capacity for some
organics. Ozonation (an oxidizing agent) has been shown to transform some
pesticides into other compounds that are more resistant to oxidation. In addition,
oxygenated degradation products are expected to be more polar and therefore more
mobile than the parent compound. Byproducts might be more toxic than the parent
compound.
• Enzymatic degradation was eliminated because the enzymes necessary for the
breakdown of organophosphorus pesticides are not widely available. Furthermore,
producing specialized enzymes to address the range of pesticides on site would not be
feasible. , .
• Hydrolysis was eliminated because it would not be effective and it is unproved for
halogenated pesticides.
• KPEG dechlorination was eliminated because vendors and researchers expressed
uncertainty about its ability to detoxify chlorinated cyclic alphatics, such as dieldrin j|i,
and aldrin. This technology would not effectively treat nonchlorinated pesticides (eg., 111)
organophosphorus, carbamate pesticides) or volatile organics found in the soil. Other' >
technical concerns associated with the KPEG process include washing the soil after the

1138
-4- . ' •
-------
m
treatment and recovering the reagent at the end of the process! Galston Research
Corp. has a newly emerging technology process which incorporates the use of DMSO
into the KPEG process. However, there is concern that DMSO is dangerous to handle
and might decompose to H2S under increased temperature conditions.
• In situ vitrification for subsurface soil was eliminated because the contaminants are
located too deep for the process which is capable of treating soil only up to 30 to 50
feet. The soil also is located too close to the water table and the high moisture content
would greatly increase the electric power requirement. |
.'• Soil flushing for subsurface soil was eliminatedbecause it is ain emerging technology
(which has not been tested in full-scale studies. The permeability of the site soils (10"4
to 10"5 cm/sec) is not optimal for this process since permeabilities of 10"3cm/sec are
'best. Additionally, site contaminants are at best sparingly soluble and adsorb very
strongly to the soil matrix. Finally, there would be a risk that the flushing solution
might mobilize the contaminants and transport them to previously clean soils or
aquifers.. ' ,
' " , " J
Innovative technologies eliminated during the screening of the three ciriteria include the
following:

• None

Innovative technologies eliminated during the detailed analysis include the following:
,' . : ' "' " ' . . ....'• i : i
• Solvent extraction was eliminated because of the high cost associated with its
implementation, the required equipment was not immediately available, and off-site
transportation might pose a threat in the event of an accident.
• In situ vitrification was eliminated because of the high cost associated with its
implementation, it would only be available through one vendor, arid the technology has
not been commercially demonstrated.

. . , ' • • - .'• / •
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were protection of
human health and the environment, long-term effectiveness, and cost. [The selected remedy
provided greater protection and long-term effectiveness than RAA-1, Ep\A-2, RAA-3, and
RAA-4. Of the options that would provide long-term effectiveness and protection (RAA-6,
RAA-7, RAA-8, and RAA-9), the chosen alternative was the least expensive.
' . /'.•'• • •''.'••_._ ' . •'': . • •
Solvent extraction and vitrification were eliminated due to their high cost and difficulties in
implementation.
**
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
Aldrin
Dieldrin
Toxaphene
DDT"
Chlordane ,
EDB
Heptachlor
21.8
23.2
337
1,092 ,
285
2.2 .
82.6
Risk1
Risk
Risk
Risk
Risk
Risk
Risk
Noncarcinogens .
Aldrinc .
Dieldrin
DDT"
Chlordane
Endosulfansd
Heptachlor
Disyston
Phorate
Difnethoate
2.4
•4
43.2
4.8
4.0
40
3.2
8
16
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
Risk
"Health-based cleanup levels were derived based on an excess carcinogenic risk of 10"4
and noncarcinogenic health-based cleanup levels were based on a hazard index of 1.
The selected health-based cleanup level is the most conservative value.
'Includes DDE and DDD.
"Carcinogenic and noncarcinogenic health-based cleanup levels were developed in the
ROD for five chemicals. .' ''. .
Including endosulfan I and endosulfan H.
13.
Was the innovative 'technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None .•'.'".
1140
-6-
•(*-..
-------
Standard technologies eliminated because of cleanup goals include:

^. •' None ' , •-.- ' '• '' '•" - ; ' "I" ....... '• '•'...
. .' • '. •- •• i"
. . • • . •' •• ' •. •;_•-.- - l: •••" • - . '.
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. j

' " •" '-" • • "'"• ; "• ' . \ - • •
15. What measures/criteria were used to compare alternatives? }

The following measures were used to compare the alternatives:

r Cost-effectiveness
, Preference for treatment (vs. containment) 1
Impact on nearby populations
_.--•• Waste left in place/institutional control ii
-"•"'' .i- '

16. How are measures compared? , I -
"•--•'' '
RAA-2 was not selected because it offered a low level of protection since there is no
guarantee that institutional controls will be maintained over time and it: would not meet
ARARs. RAA-3 and RAA-4 were not preferred because they did not "incorporate treatment
and would not be as protective. RAA-5 was not preferred because it would not provide a
greater reduction in contaminant tbxicity, mobility, and Volume than the chosen alternative.
RAA- 7, RAA-8, and RAA-9 were not selected because of their high cost. EPA felt that it
could not justify the high cost of these alternatives given some soil contaminants would still be
left in place. Furthermore, there was some concern over the implementability of RAA-7 and
RAA-8. RAA-7 would not have been immediately available though it was expected some
time in 1992, and RAA-8 is only available through one vendor. The state was concerned
about residual solvent associated with RAA-7 which could increase the; mpbjlity of remaining
site contaminants. Finally, it was anticipated that the community would have objected to
RAA-9. ,

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
• ' , i-j'
Technical considerations were not primary in selecting a remedial alternative. The site's low
soil permeability, however, precluded the use of soil flushing.
-7.
-------
Hassayampa Landfill

Maricopa County, Arizona
Region 9
GENERAL SITE INFORMATION

1. What were the principal, contaminants,
contaminant levels, and met
this feasibility study?

Maximum concentrations of principal
contaminants were:

Waste/soil (rag/kg)

o,p-Dichlorobenzene
1,1-Dichloroethane
Benzene
1,1-Dichloroethene
Dichloromethane
1,2-Dichloropropane
Total xylenes
Acetone
Ethylbenzene
Toluene
Methyl ethyl ketone
Tetrachloroethene (PCE)
1,1,1-TrichIoroethane
1,1,2-Trichloroethane
Trichloroethene (TCE)
Trichlorotrifluoroethane
linants,

addressed in Site History
NPL Proposed:
ncipal NPL Final:
FS:
ROD:
N/A
7/87
5/92
7/92
Background
97
47 PRP-lead
1 PRPs: N/A
1,630 FS prepared by:
990 Associates, Inc.,
207 and Associates
350
2,540
57 •
510
405
600
23,000
20
590
12,000

Enrol L, Montgomery *& "
Conestoga- Rovers

'}
What volume of material is to be remediated? .

The volume of material to be remediated included:

» 12,670 cubic yards of waste
• 91,400 cubic yards of soil

* f --- i • ' • • ' •
What type of site is this?

Industrial Landfill. The hazardous waste area of an active landfill in a rural area.
J!
1142
-1-
-------
TECHNOLOGY SELECTION j
, - ' - ',-!.' '
-" '! ' :
4. What standard technologies \vere considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ", \
Access restriction:
Containment:
Chemical treatment:
Thermal treatment:
Disposal:
Deed restrictions
Capping (RCRA, soil) |
Fixation/stabilization
Incineration (rotary kiln, circulating bed, off site, on site)
Excavation, disposal at RCRA landfill ,
-5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Bioremediation (ex situ, in situ)
Phys/Chem treatment: Soil washing, soil flushing j
Physical treatment: ' Soil vapor extraction, steam injection and spjirging
Thermal treatment: Vitrification, thermal desorption
6. What was the cost estimate for the innovative technology? !

7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
(RAA-2)
RAA-6
Standard Technology
No action
Deed and access restrictions/ground
water extraction, treatment, and
reinjection
Deed and access restrictions/cap/ground
water extraction, treatment, and
reinjection
Deed and access restrictions/cap/
removal/incineration/ground water
extraction, treatment, and reinjection
.
Estimated Costs
3 Criteria8
$0
$3,200,000
to
$6,300,000
$3,700,000 .
to
$6,900,000
$7,600,000
to
$10,700,000
==^==-_=
9 Criteria
$0
eliminated
$3,700,000
to
$6,900,000
eliminated
=^=
The range of costs is due to the type of ground water treatment to be chosen.

1" •

8. If a standard technology was chosen, why?

A standard technology was not selected as the primary remedy. Treatment residuals will be
capped.
9. If' an innovative technology was chosen, why? -

RAA-3 was selected because it will employ soil vapor extraction until soil cleanup levels that
are protective of ground water quality are met, thereby ensuring that vadose zone contaminants
1144
-3-
-------
will not migrate to ground water. This alternative addresses the threat of ingestion and contact
with contaminated waste and soil through the use of a cap and access and! deed restrictions.
The cap also minimizes infiltration and limits the migration of vadose zone contamination to
ground water. This alternative complies with all ARARs and is cost effective. The selected
remedy permanently reduces contaminant volume and mobility through soil vapor extraction
and treatment, and capping. No short-term risks are posed by this remedy. It is easily
implemented since it relies on demonstrated technologies and proven, effective methods and
equipment. . ; •
10. If an innovative technology was not chosen, why not? At what stage \fyds the innovative
technology eliminated? i.

• In situ bioremediation was eliminated because it would be better suited for low-level
contamination areas where nutrients might be introduced into the contaminated matrix
with infiltrating water. The water can be collected following the introduction of
nutrients and the production of leachate. This technology would not be readily applied
to hazardous waste areas in situ. '
• Ex situ bioremediation was eliminated because it would only Ibe able to treat a small
. portion of the waste targeted for remediation, there is a low probability of success for
some significant contaminants (1,1,1-TCA, 1,1,2-TCA, TCE, PCE), waste waters from
the process would require treatment and/or disposal, and the desert environment would
cause extensive evaporation, thus requiring constant irrigation,;
• Vitrification was eliminated because it has not yet been fully demonstrated oh a wide
range of wastes; moreover, the depth of ground water and the extent of ground water
contamination would drastically increase energy requirements because of the large
volume of soil required for treatment. This technology would be more suitable for
inorganics and metals stabilization where migration through leaching is a concern.
Vitrification volatilizes VOCs, which necessitates a complex vapor collection system
and fugitive losses can occur.' Since the site contaminants are mainly organic and
thermal treatment can be done more cost effectively through incineration or thermal
desbrption, vitrification was considered impractical for this application. '
• Thermal desorption was eliminated because it is still in developmental stages, the
technology would be more expensive than other available technologies, volumes that
are located over a large number of. small, isolated pits of waste require treatment, and
collected organics would require further remediation. Furthermore, fugitive air
emissions would potentially affect on-site personnel and off-site areas. Open
excavation could result in the leaching of contaminated liquids to the ground water if
precipitation entered the excavated area and contacted the waste materials or
contaminated soil. . |' .
• Steam injection and sparging was eliminated because without a confining layer,
condensed steam could migrate into the ground water or away from the hazardous
waste area. The technology is applicable to depths of 30 feet [(contamination reaches
to 60 feet), below which high temperatures are difficult to maintain and condensation
. of steam might occur. This would cause infiltration of the condensed steam through
1145
-------
77.
the contaminated zone possibly increasing the level of ground water contamination.
This factor could make the process difficult to control and monitor. The pressure of
both a fine-grained and coarse-grained unit in the saturated zone makes injection of
steam difficult to implement and control ultimate flows. In addition, construction and
startup costs of steam injection/ sparging are higher when compared to soil vapor
extraction due to the requirement for an on-site steam-generating facility.
• Soil flushing was eliminated because it could promote contamination of underlying
ground water.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• Soil washing as a stand alone technology was eliminated because it would not address
soil gas contamination. Furthermore, it would not address soil beneath Pit 1 or in
Special Pit areas and the proposed excavation process might result in the release of
VOC emissions.

Innovative technologies eliminated during the detailed analysis include the following:

• Soil washing in conjunction with soil vapor extraction was eliminated because it would
provide only a slightly greater reduction in toxicity, mobility, and volume through
treatment than the selected remedy and at a significant increase in cost.

The criteria weighted most heavily in selecting a remedial alternative were protection to human
health and the environment; reduction of contaminant toxicity, mobility, and volume; and cost.
RAA-3 was selected over RAA-1 or RAA-2 because it is more protective since it reduces soil
vapor contamination to levels that protect ground water quality. RAA-4 would have provided
a slight increase in protection of human health and the environment and reduction of toxicity,
mobility, and volume through treatment; however, EPA did not believe these marginal benefits
were necessary or justified the additional costs.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
1146
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
1 , 1 -Dichloroethene
1 ,2-Dichloropropane
Tetrachloroethene
1 , 1 ,2-Trichloroethane
Trichloroethene
140
12
14
60
64
Risk0
Risk
Risk
. Risk
Risk
O
-5-
-------
... ' •-..'.- ' . .... ' - • •
Contaminant
Noncarcinogens
o,p-Dichlorobenzene
Dichloromethane
Total xylenes
Acetone
Ethylbenzene
Methyl ethyl ketone
1 , 1 , 1 -Trichloroethane
Trichlorotrifluoroethane
Toluenfc
Cleanup Level (mg/kg)
AIIAR or Other Basis

1,500
94
200,000
14,000
14,000
3,400
4,000
4,200,000
20,000 -
Risk
Risk
Risk
, Risk
Risk
Risk
Risk
Risk
Risk
"Cleanup levels were developed using the results of the human health risk assessment,
For carcinogens, an excess upper bound individual lifetime cancer risk of 10"4 to 10"6
was acceptable. For noncarcinogens, a Hazard Index"iess thaii or equal to 1.0 was
acceptable. !
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? \ ' .
• ' , • ' ! "
Innovative technologies eliminated because of cleanup goals include:

..•-•; None •; ' ' _ • . .; .' •.--•''

Standard technologies eliminated because of cleanup goals include:

• Capping
14. Were treatability studies conducted on the innovative technology or standard technology?
' ' - * I-
Treatability studies were conducted to evaluate several remedial technologies: soil washing,
bioremediation, soil vapor extraction, and thermal desorption.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Time to design/construct/operate
Preference for treatment (vs. containment)
-6-
1147
-------
16. How are measures compared? '

Of the two soil treatment alternat- proposed, the selected alternative was preferred because
it is protective>since waste/soil wiu be treated cost-effectively. It is the most cost-effective
option because, although it offers slightly less protection than RAA-4, it also is less expensive.
RAA-4 would require more construction time because a larger soil vapor extraction system
would be needed. It also was deemed the least implementable alternative given the excavation
of waste and the startup and trail tests involved in a soil washing system. Capping as a stand-
alone remedy was not preferred because it would not address waste/soil contaminants.
* • -

77; ' What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? '

Technical considerations were not primary in selecting a remedial alternative. The mixture of
fine- and coarse-grained soil and the lack of a confining layer, however, precluded the use of
steam injection and sparging.
1148
-7-
-------
Indian Bend Wash Area
OU-1,4,5, 6

Scottsdale and Tempe, Maricopa County, Arizona
Region 9
GENERAL SITE INFORMATION

.1. What, were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Vadose Zone1 mg/kg

Trichloroethylene 10
Tetrachloroethene 4.9
1,1-Dichloroethene 1.6
Trichloroethane 0.14,
1,1,1-Chloroform 0.6
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
9/82
9/1/83
4/91
9/12/91
Background
-1
PRP-lead
PRPs: Advanced Auto Supply, Beckman
Instruments, Diclcson Electronics,
Marro Plating, Motorola,
PlainvUle West, Salt River
Project, Sieniens Corporation, and
Strip Joynt
FS prepared by: CH2M Hill .
What volume of material is to be
remediated?

The volume of material to be remediated
included:

The specific volume of soil to be remediated is not given; the ROD states estimates from soil
and soil gas concentrations indicate trichloroethylene is present in the vadose zone at some-of
the potential source areas in quantities from tens to hundreds of pounds. .
t • ' . •
The FS estimates between 270 and 1,100 kg of trichloroethylene are present in soils in Area 7,
and 20 to 30kg of trichloroethylene are present in Area 8 (see Question 3).
3. What type of site is this?

Electrical Equipment. This ROD addresses North Indian Bend Wash (NffiW), the northern
portion of the Indian Bend Wash Superfund site. Various electronics manufacturing and metal
plating facilities, as well as other industries, have been active at NIBW since at least the
1950s. Operations at many of these facilities have included the use and disposal of organic
solvents. In many of the potential source areas, buildings and other structures covering large
portions of the areas continue to be used for industrial and commercial, operations.
'Vadose zone includes soil matrix, soil gas, and liquid adhering to the soil matrix.
• - ' • ! •
. -"'',." •.-. -i- - -i1- "• •
1149
-------
The NIBW study area encompasses 10 square miles; 8 square miles of NIBW are. within the
City of Scotl.-.lale, while approximately 1 square mile is within the City of Tempe and another
square mile i.1 -.Art of the Salt River Pima-Maricopa Indian Community: Approximately 70
percent of NI* W is residential, 23 percent is commercial/industrial, and 7 percent is developed
open space. ,

Thirteen areas for possible soil remedial action have been identified at NIBW.

TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS? ,

Standard technologies considered during the identification and screening of technically feasible
technologies were: .....'•-
Access restriction:
Containment:
Chemical treatment:
Physical treatment:

Disposal:
Institutional controls (deed restrictions, use restrictions)
Capping (native soil, clay cap, synthetic membranes, sprayed asphalt,
asphaltic concrete, concrete cap, multilayered cap), vertical barriers
(soil-bentonite slurry wall, cement-bentonite "slurry wall, vibrating
beam, grout curtains, sheet piling), horizontal barriers (grout injection,
liners), surface controls
Neutralization, precipitation, ion exchange
Solids processing (crushing and grinding, shredding and chopping,
screening, classification), flotation
Removal (excavation)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Biological treatment: Aerobic processes, anaerobic processes, bioreclamation
Phys/Chem treatment: Soil'washing, solvent leaching, oxidation, chemical reduction, in situ
oxidation .
Thermal treatment: Soil vapor extraction (SVE)

6. What was the cost estimate for the innovative technology?

The no action alternatives (RAA-1 and RAA-1 A) were chosen for Areas 1, 2, 4, and 10
because few or no VOCs were detected in these areas.

Based upon available information, Areas 3, 5, 6, 9, 11, and 12 do no* appear to pose
significant risks due to direct exposure to contaminated soil and soil gas. For these areas,
however, more information is needed to estimate the amount of VOGs that are present and to
evaluate their potential impacts.
9. If an innovative technology was chosen, why?

RAA-2 was chosen as the selected remedy for Areas 7 and 8. This alternative was. chosen
because SVE will reduce the mobility of most of the contaminant mass by sorbing it onto
activated carbon. RAA-2 will also meet chemical-specific, location-specific, and action-
specific ARARs. Past performances of SVE systems indicate that the! use of this system will
significantly, reduce VOC contaminants present in unsaturated soils diiring the useful life of
equipment and wells. Several case histories of SVE are available. Extraction rates from 20 to
more than 300 pounds of VOCs per day have been documented. Extraction rates of VOCs
usually decrease with time, generally removing up to 50 percent of the contamination gases
-3-
1151
-------
during the first 10 percent of operating time. At a site in Puerto Rico, which combined
remedial actions consisting of concrete capping, groundwater extraction, and SVE, contaminant
concentrations in nearby ground water monitoring wells dropped over 99 percent. Based upon,
extraction rates cited in these studies the SVE alternative would be expected to remove the
bulk of the vadose zone contaminant mass within several years. As a result, the threat to
ground water quality would be reduced significantly faster than under RAA-1. SVE is useful
since much of the contamination is beneath buildings or structures. Whereas excavation would
require demolition or exposure of structural support of buildings and structures, SVE could
remove contaminants from beneath a building without the major effects of demolition and
exposure of structure supports. A pilot study was performed at the Phoenix-Goodyear Airport
(PGA) site in Phoenix, Arizona, in 1988. The PGA site is similar to NIBW in the type of
contaminants, and shallow vadose zone lithology. The depth to ground water at the NIBW site
is greater than at PGA, but the results of the PGA pilot study generally are applicable to
NIBW. ,

For both Areas 7 and 8, the VLEACH model, or a similar analytical tool determined
acceptable by EPA, will be used to evaluate the continued threat to ground water and,
therefore, the need to continue operation of the SVE system and/or install additional soil vapor
monitoring wells.
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ' ,

Innovative technologies eliminated during the initial screening include the following:

• Soil washing was eliminated because soil removal would not be feasible.
» Solvent leaching was eliminated because it would not be applicable given the waste
characteristics.
• Oxidation was eliminated because it is an unproven technology with possibly
hazardous by-products. . .
• Chemical reduction was eliminated because it is unsuitable for removal of a wide
variety of inorganics and organics.
• Aerobic processes were eliminated because this process is unproven for eliminating the
contaminants of concern. Also, soil removal would not be feasible.
" Anaerobic processes were eliminated because this process is unproven for eliminating
the contaminants of concern. Also, soil removal would not be feasible.
• In-situ oxidation was eliminated because it is a theoretical, unproven technology for
eliminating the contaminants of concern.
• Bioreclamation was eliminated because it is an unproven technology for the major
waste constituents at the site. •

Innovative technologies eliminated during the screening of the three criteria include the
following: .

« None .

-------
Innovative technologies eliminated during the detailed analysis include the following:

• None ,
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the. elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
• - - ' . - ' -
Overall protection of human health and the environment, implementability, and state and
community acceptance were weighted most heavily in selecting the remedy for the site. The
SVE alternative offers greater overall protection since uncertainty regarding the fate of vadose
zone contamination is reduced. At NTOW, the principal risk to human health is through
contact with and ingestion of contaminated ground water. By removing VOCs from the
vadose zone and by carefully monitoring the fate of VOCs currently in the Upper Alluvial
Unit (UAU), which is overlain by the vadose zone, the selected alternatives will help to ensure
that the ground water underlying NffiW is returned to levels acceptable for drinking water use
in a reasonable timeframe. SVE has also been implemented successfully l:o remove VOCs
from soils. The state supports the RAA-2 over RAA-1 for vadose zonies that present a
potential threat to ground water quality. Finally community members jit the public meeting
expressed a strong preference that potential threats from all possible source areas should be
cleaned up. _ [
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? !

Cleanup levels for soils were not given in the ROD. The following cleanup levels were
presented in the FS. ' .
Contaminant
Cleanup Level (fig/kg)
ARAR or Other Basis
Carcinogens
Trichloroethylene
Tetrachloroethylene
Noncarcinogens
1 , 1 -Dichloroethene
320
67
Health-based*
Health-based

700
Health -based
'Arizona Department of Health Services (ADHS) suggested health-based cleanup levels
for contaminants in soils. \,.
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? !

Innovative technologies eliminated because of cleanup goals include:

• None , -
-5-
1153
-------
. Standard technologies eliminated because of cleanup goals include:

:- " •'•-• ' '-'-••"
• None '

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

' ' "' - ' ' ' ' '
.' ' ('.-•"'
15. What measures/criteria were used to compare alternatives?
* - • : ' ' '

The following measures were used to compare the alternatives:

Cost effectiveness
Proven reliability > , .

16. How are measures compared?
• • -••'••' '
EPA considers the costs for the vadose zone treatment to be proportionate to their
effectiveness in removing the potential for hundreds of years of ground water contamination
and avoidance of the substantial monitoring and cleanup costs that such contamination would
entail. The performance of SVE systems in the past indicates that the use of this system
results in a significant reduction of VOC contaminants. The results of a pilot study at a site | ~'\
similar to NIBW are generally applicable to NIBW. , i)f

77. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy for this site.
.* f
1154
-6-
-------
Iron Mountain Mine
Boulder Creek Operable Unit

Shasta County, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

, Maximum concentrations of principal
contaminants were:

Waste Piles

Samples from four of the waste piles
exceeded regulatory levels for arsenic,
cadmium, lead, and zinc in California Total
Threshold Limit Concentration (TTLC) and
Soluble Threshold Limit Concentration
(STLC) tests.
Site History
NPL Proposed:
NPL Final:
FS:
Interim ROD:
N/A
9/8/83
5/92
9/30/92
Background

FJPA Fund-lead
PRPs: Rhone-Poulenc Basic Chemicals,
Iron Mountain Mines, Inc., T. W.
Arman .
FS prepared by: CH2M Hill
2. What volume of material is to be
remediated?

The volume of material to be remediated included:

• 30,000 to 50,000 cubic yards of wastes
3. What type of site is this?

Mining. The Iron Mountain Mine (IMM) site includes the inactive mines on Iron Mountain
(including the Richmond, Lawson, and Hornet mines) and areas when; hazardous substances
released from the mines are now located. The site covers approximately 4,400 acres of land
that is predominantly forested. The adjacent land is largely undeveloped wilderness This
interim ROD addresses the Richmond and Lawson portal Acid Mine Drainage (AMD)
discharges and seven waste piles on site. The waste piles include tailings from beneficiation
activities at the mine, the dumping of mine cars with sulfide contents below processing
facilities, and rock wasted during mining operations. Collectively these waste piles are the
third largest source of AMD at the site, contributing an estimated 3 to120 percent of the metals
to Boulder Creek. '••":!'.
-1-
1155
-------
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ' .•''.'.-'•

Containment: Capping (shotcrete, clay, geosynthetic membrane), grading, diversion
systems • . ,
Phys/Chem treatment: Stabilization (pozzolanic agents), resource recovery (neutralization,
flotation) A.
Disposal: Excavation (backhoes and bulldozers), RCRA landfill, non-RCRA
landfill
5. Was an innovative technology'considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Phys/Chem treatment: Acid leaching
6. What was the cost estimate for the innovative technology?

Innovative technologies were not incorporated into remediation action alternatives.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

Waste Piles' ,,'.''-,
1156
Alternative
RAA-WO
RAA-W1
RAA-W2
Standard Technology
No action
Capping waste piles in place
Waste pile removal, treatment, and
'disposal
Estimated Costs
3 Criteria
N/A
N/A •>
N/A
9 Criteria
$0
eliminated
$5,918,000
-2-
-------
Alternative
RAA-W3
Standard Technology
Consolidating and capping waste piles
on site -
I Estimated Costs
3 Criteria
I'N/A
. r i
'',' f
9 Criteria
$2,970,000
aAlthough RAAs were developed in the FS for. contaminated seeps land tributaries, and for
sediments, these RAAs were not addressed in the interim ROD. '
8. If a standard technology was chosen, why? : /
. • • • . ' ,!-'',
RAA-W3 was selected because consolidating and capping the seven waste piles, with proper
remedial design and maintenance, essentially will "eliminate" the current discharge of AMD
from this source. By excavating the waste piles, the selected alternative will be "very
effective" at reducing the long-term metals loading to Boulder Creek. The exact amount that
metals loading to Boulder Creek will be reduced is unknown, but if implemented with other
source control alternatives, RAA-W3 might provide a measurable incremental reduction in
metals concentration in downstream surface waters (RAA-W3 will provide at least by the next
rainy season, an estimated 1 to 10 percent reduction in metals loading to Boulder Creek). The
process of consolidating and capping the wastes will effectively eliminate both the processes
currently mobilizing the metals: the leaching action of infiltrating precipitation and ground
water as it travels through the waste piles, and the erosion of material from the surface of the
piles. This alternative will involve limited risk to workers during construction. The dust
suppression measures during waste hauling are less stringent than for RAA-W2 because
hauling distances are shorter, and all waste materials remain within the Superfund site
boundaries. Excavation of some of the waste piles would be technically challenging; however,
the equipment and techniques required have been successfully employed on other earth moving
projects. The technical implernentability of the cap design is well proven. The equipment and
work force necessary for implementing RAA-W3 are readily available in Northern California,
and the specialized materials for constructing the cap are available from several commercial
vendors in the United States. " ',.'-.' ,

All of the RAAs fall short of meeting ARARs in the receiving waters because the Boulder
Creek Operable Unit does not contain all of the contaminant sources and these alternatives
address only a part of the sources in the Boulder Creek Operable Unit. The RAAs are interim
measures with a best case expectation of making a significant contribution toward final
cleanup. The small anticipated reduction in metal discharges resulting from RAA-W3 is a
significant contribution to final cleanup standards on the site. Because the Boulder Creek
Operable Unit is an interim remedy, it can qualify for ARAR waivers. The ARARs that are
being waived for the purposes of this operable unit are the water quality objectives/standards
established by California in the Central Valley Basin Plan and Fish and Game Code Section
5650.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
-3-
1157
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? •

Innovative technologies eliminated during the initial screening include the following:

• Acid leaching was eliminated because of the lack of demonstrated effectiveness; if data
become available that indicate adequate resource recovery is economically possible, the
FS stated the technologies would be reconsidered. The FS states that the removal
efficiencies of these processes are expected to be low because the in situ metals
concentrations in the piles are relatively low. The implementability and effectiveness
of these treatment options could not be evaluated; laboratory or bench-scale testing is,
required to provide sufficient information to conduct these assessments.
I,,;
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Cost and overall protection of human health and the environment were the criteria weighted
most heavily in selecting RAA-W3. The selected remedy was chosen over RAA-W2, which
includes off-site treatment and landfilling of the waste, because RAA-W2 would cost nearly
twice as much as on-site landfilling of untreated waste. The selected remedy will "essentially"
eliminate the environmental threats posed by the waste piles and is therefore protective of
human health and the environment. , • >
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? . .

Cleanup goals were not selected for this interim ROD. ,
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? .

Innovative technologies eliminated because;of cleanup goals include:

• None •

Standard technologies eliminated because of cleanup goals include: '

" None • ,
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

1158
v
-4-
-------
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
- Proven reliability

16. How are measures compared?

The selected remedy was chosen because it will cost substantially less
RAA-W2 and is therefore^more cost-effective. RAA-W3 also was chosen
can be performed with existing technology, and landfilling is a well
to implement than
because excavation
established technology.
17. What technical considerations were factors in selecting a remedy?
considerations primary in the selection of the remedy?
Were technical
Technical considerations were not primary in selecting the chosen remedy
eliminated, however, because capping would not be very effective wii
for ground water infiltrating into the piles as a result of the high
and surface-water runoff that occur near many of the waste piles. In
remote and steep locations of the waste piles, capping the piles in pi;
extremely difficult. New road construction to many of the piles would,
ground
lace
-5-
RAA-W1 was
ithout additional controls
water levels, springs,
addition, because of the
was. considered to be
1 be required.
1159
-------
Jasco Chemical Corp.

Mountain View, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and met
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil (mg/kg)

1,1-Dichloroethane
1,1-Dichloroethene
• 1,2-Dichloroethene
1,1,1-Trichloroethane
Acetone
Benzene
Diesel or Kerosene Mixture
Ethylbenzene
Methanol
Mcthylene chloride
Tetrachloroethene
Toluene
Trichloroethene
Xylene
ninants,
addressed in

incipal

3
1.7
0.015
61
100
3
6,700

Site History
NPL Pi-oposed:
NPL Final:
FS:
ROD:
6/4/88
10/4/89
5/21/92
9/30/92
Background
i
PRP-lead
PRPs: Jasco Chemical
FS prepared by: OHM
Services Corp..

.
1.2
60
21 ••••-::••
4
110
0.05
37

Corp.
Remediation

•

2. What volume of material is to be remediated?

The volume of material to be remediated included:

" 2,159 cubic yards of soil
3. What type of site is this?

Chemicals and Allied Products. A chemical repackaging and solvent manufacturing facility
located in an urban area. ,.-•'.,
1160
-i-
-------
TECHNOLOGY SELECTION
4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ;
Access restriction:
Containment:
Physical treatment:
Thermal treatment:
Disposal:
Deed restrictions
Capping (clay, synthetic liner)
Carbon adsorption, resin adsorption
Incineration (on-site, off-site)
Excavation, disposal at RCRA facility
5. Was an innovative technology considered in the FS? If so, which technology?,
. ' • : ' : i
Innovative technologies considered during the identification and screeining of technically
feasible technologies were:
1 -. " " ' - j ' ;
Biological treatment: Biodegradation (enhanced bioremediation, X-19 bioremediation
process) |
Phys/Chem treatment: Spil washing (Excaliber treatment), dechlorinatioia, neutralization,
vapor extraction
Thermal treatment: Thermal desorption, heat stripping, in situ vitrification
What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
/*
Standard Technology
No action
Excavation/off-site treatment,
probably incineration
Estimated Costs
3 Criteria
N/A
N/A
9 Criteria
$0
$1,683,000
5. If a standard technology was chosen, why? "

A standard technology was not chosen as the primary remedy. Off-site disposal of residuals, if
necessary, was selected. '

9. If an innovative technology was chosen, why?

A combination of two alternatives, RAA-2 and RAA-3, was selected for site remediation. Site
soils will be cleaned using the enhanced bioremediation treatment proposed in RAA-3. If site
cleanup levels are not achieved by this method, treated soils not meeting cleanup levels will be
sent to the appropriate off-site RCRA treatment and/or disposal facility. If the backup method
of off-site incineration is required, the soil will likely have to be transported out of the state
since there are "no incinerators" in California. Treatability studies have shown that RAA-3
would most likely meet ARARs. Organic hydrocarbons are more biodegradable than
chlorinated hydrocarbons, but the chlorinated hydrocarbons are very volatile and will be
absorbed in carbon beds. These alternatives ensure long-term effectiveness since chemicals of
concern will be permanently degraded. Furthermore, contaminant toxicity, mobility, and
volume will be reduced. Implementation of this alternative will not pose short-term risk since
any potential short-term risk can be mitigated by a health and safety plan. The technology
proposed in these alternatives is easy to construct and operate. The alternatives are cost
effective. / . .
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? -

Innovative technologies eliminated during the screening of the three criteria include the '
following: . '

• Thermal desorption was eliminated because of the high energy, requirements for a
relatively small volume of soil and because it would not be practical or publicly
acceptable to operate a volatilizer in a residential community. Thermal treatment
processes are comparably more expensive than ex situ vapor extraction or enhanced
bioremediation, which would be equally effective. -
• Heated stripping was eliminated for the same reasons as thermal desorption; the
energy and cost requirements would be high compared to other options.
• In situ vitrification was eliminated because it does not appear |to be implementable at
the site. This technology is expensive, designed for larger sites where no other option
is feasible. It is most appropriate for inorganic waste and mixed waste as organics
volatilize from soil. The area to be treated is located near the Southern Pacific
Railroad tracks. The melt would extend to the tracks and any soil volume loss would
damage the structural integrity of the tracks. The vent hood, which is 50 feet by 50
feet, could not be extended over the active tracks. '
• In situ bioremediation was eliminated because the contaminants 'are in clay soils and
treatability tests would be needed.
• In situ vapor extraction was eliminated because of the clay and silt content of the soil.

Innovative technologies eliminated during the detailed analysis include: the; following:

• Soil washing with Excaliber treatment was eliminated because! its effectiveness is not
as well proved as that of the chosen technology. !
• Biodegradation with X-19 treatment was eliminated because its effectiveness is not as
well proved as that of the chosen technology and a treatability study must be
conducted.

Long-term effectiveness and cost were the criteria weighted most heavily in selecting a
remedial alternative. .The chosen technology was the only on-site treatment expected to meet
ARARs without treatability tests. The effectiveness of enhanced bioremediation will be
supported by off-site incineration. While off-site incineration also would have to meet «.
ARARs, it was not preferred as a stand alone option because it would be more expensive.
1163
-------
12. Wliat cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Benzene
1 , 1 -Dichloroethane
1 , 1 -Dichloroethene
1 ,2-Di :hloroethane
Methylene chloride
Pentachlorophenol
Tetrachloroethene
Trichloroethene
Vinyl chloride
0.3
0.6
2
0.03
0.2 .
200
7
3
0.02
Model8
Model .
Model
Model
Model
Model
Model
Model
Model
Noncarcinogens
c-1 ,2-Dichloroethene
Ethylbenzene
Toluene
1,1,1 -Trichlorqethane
Xylenes
Acetone •
Chloroethane
Diesel or kerosene
mixture
Methanol
Methyl ethyl ketone
1
3,000
1,000
100
2,000
30
4,000
10,000
200
9
Model
Model
Model
Model
Model
Model
Model
Model
Model
/ Model
"Cleanup levels were developed for the protection of ground water and were estimated
using MCLs and the Summer's Leachate model (EPA, 1989)., For carcinogens, an
excess upper bound individual lifetime cancer risk between 10"4 to 10"6 was acceptable.
For noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable.
1164
-5-
-------
13, Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? I

Innovative technologies eliminated because of cleanup goals include:

- • •' ., None • . . f ". ' : p..-.'

Standard technologies eliminated because of cleanup goals include: !

* None^, ... • . ' - '- , • _!•'..'•,

14. Were treatability studies conducted on the innovative technology or standard^technology?

Treatability studies were not described in the Feasibility Study; however, «he ROD states that
"treatability studies have shown that Alternative 3 would most likely comply with ground
water ARARs." !

'. - ' - / •' i -.''.-•
15. What measures/criteria were used to compare alternatives? j

The following measures were used to compare the alternatives: i

- Cost/unit risk
Proven reliability j

16. How are measures compared?

Treatability tests have shown that the chosen alternative will most likeliy comply with ARARs.
The Excaliber process is being demonstrated under EPA's SITE program and initial results.are
encouraging, however, it has not been extensively demonstrated and testability studies would
be required at the Jasco site. The Excaliber process also was deemed llhe most difficult to
operate since a full-scale system has not yet been built. The Excaliber soil washing process is
a new technology and its effectiveness has not yet been established, therefore it also would
require additional testing prior to implementation at the site. Off-site ijicineration was not
selected as a stand-alone option because it would be too expensive.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? i
'i -
-' - - ' .' il •- ' . *
Technical considerations were not primary in selecting a remedial alternative, however, in situ
vitrification was eliminated in part because its implementation was limited by physical
constraints (railroad tracks). !
• ' ' - \ • ' . -

References: . ' • .
EPA. 1989, U.S. Environmental Protection Agency. Determining soil response action levels
based on potential contaminant migration to ground water: a compendium of examples.
-6-
1165
-------
Lawrence Livermore National Laboratory
U.S. Department of Energy

Livermore, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Sediments (mg/kg)

Trichloroethene 6
Fuel hydrocarbons (FHCs) 11,000
Aromatic hydrocarbons 4,800
2. "What volume of material is to be
remediated? •

The volume of material to be remediated
included:
Site History

NPL Proposed: N/A
NPL Final: 7/87 •
FS: 12/90
ROD: 7/92

Background

Federal Facility
PRPs: Department of Energy '
FS prepared by: Lawrence Livermore
National Laboratory, Weiss
Associates, Inc., Science
Applications International Corp.,
Woodward-Clyde Consultants
• 2.94 million cubic yards of sediment contaminated with volatile organic compounds
(VOCs) •
« 11,200 cubic yards of sediment contaminated with benzene, ethylbenzene, toluene, and
xylene isomers (BETX) . • '_ .
• 4,500 cubic yards of sediment contaminated with total fuel hydrocarbon (TFH)

3. What type of site is this? .

Department of Energy. A U.S. Department of Energy research and development facility that is
surrounded by industrial, urban, and agricultural areas.
•):
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:
1166
Permit restrictions, land use restrictions
Capping (asphalt, clay, synthetic liners), slurry wall, grout curtain
-1-
-------
Disposal:
Excavation, off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?
'i - .

Innovative technologies considered during the identification and screening of technically
feasible technologies were:
',••'' " !
Biological treatment: Bioremediation (in situ, ex situ)
Chemical treatment: Oxidation (thermal, catalytic)
Physical treatment: Vacuum extraction, radio frequency enhanced extraction, sorption
granular activated carbon (GAC) j
Thermal treatment: Steam enhanced extraction, in situ vitrificatioiu
6. What was the cost estimate for the innovative technology? |

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, v^fter the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during ail evaluation based on
nine criteria established by the NCP. .

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Innovative Technology
Vacuum extraction/vapor treatment
via catalyzed oxidation/GAC if
necessary
Estimated Costs
3 Criteria
•' : N/A
1 - -
9 Criteria
$1,114,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Techn clones
(selected remedial alternative is in bold)
Alternative
RAA-2
Standard Technology
Deferred action/monitor/extract and treat
ground water
i- • •- . '
Estimated Costs
3 Criteria
N/A
l
9 Criteria
$852,000
-2-
1167
-------
8. If a standard technology was chosen, why?

A standard technology was not selected,
,9. If an Innovative technology was chosen, why?

RAA-1 was selected because it reduces risk by actively removing contaminants from the
sediment, which is a potential source of ground water contamination. It was determined that
site sediment did not pose a direct threat to human health except through the migration of
contaminants to ground water. Vacuum-induced venting of the unsaturated zone removes
subsurface VOCs.and FHCs and prevents contaminant migration to ground water.
Implementation of this remedy poses no unacceptable short-term risk and does not adversely
affect the adjacent subsurface media. It complies with alllARARs and is cost effective.
Although the selected remedy is more expensive than the other alternative, cleanup will be
• more rapid. The remedy permanently .removes contaminants from the sediment and thereby
provides long-term effectiveness. The selected remedy immediately and permanently removes
and breaks down contaminants, thereby reducing contaminant toxicity, volume, and mobility.
It is technically and administratively feasible and supported by available services, materials
and skilled labor. ' ..' '
10.
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
» " :
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• In situ vitrification was eliminated because it is considered experimental, would be
very intensive, and would not be likely to have any advantages at the site.
« In situ bioremediation was eliminated because chlorinated solvents are less amenable
to biological destruction, and efficient destruction has not yet been demonstrated for
halogenated compounds. Bioremediation of FHCs was not considered because of the
depth of the FHCs and the sensitivity of microorganisms to in situ conditions, which
are difficult .to control and introduce substantial uncertainties in the applicability of the
process.
" Ex situ bioremediation (slurry ,phase) via a bioreactor was eliminated because it would
require complex operations.
• Steam enhanced extraction was eliminated "because heat would not be required."
• Radio frequency enhanced extraction was eliminated "because heat would not be
required."

Innovative technologies eliminated during the screening of the three criteria include the
following: • '

• None ,
•'IE.
1168
-3-
-------
Innovative technologies eliminated during the detailed analysis include the following:
- 'i '
• None . ' f.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
• • N • :• • •'-. / . •-.•-.• ' - • i , •. • • -':-.,'
The criteria weighted most heavily in selecting a remedial alternative were reducing
contaminant mobility and short-term effectiveness. The chosen alternative permanently
reduces contaminant mobility in sediment, thereby preventing contaminant migration to ground
water. This alternative was preferred over deferred action (RAA-2) because it requires 10
years to achieve the remediation goals while RAA-2 would have taken 90 years.
,' ; i
l'i -
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
. ARAR? What risk level-was selected to establish cleanup goals?

Cleanup levels for sediment were not established. The decision of whether or not an area
requires cleanup will be based on unsaturated zone monitoring and ground water modeling. If
modeling indicates that hazardous materials will affect ground water iln concentrations above
an MCL, remediation will be implemented.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ,

Innovative technologies eliminated because of cleanup goals include:
'-'''..,'•'• !
• 'None - - ••-''. ' T '•..''"•'
• " ' ' ' , • - .'••" -. ' • ' ' •
Standard technologies eliminated because of cleanup goals include: :

• - None _ ; •: ' •'. ' L • • .

14. Were treatability studies conducted on the innovative technology or standard technology?

" Treatability studies were not conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost/unit risk .
Time to design/construct/operate
1169
-4- ,. . ' . : • ' '
-------
16. How are measures compared? ,*

RAA-1 was considered cost effective even though it is more costly than RAA-2 because it
would enable a more rapid cleanup. It also was preferred because it reaches remediation goals
in 10 years while RAA-2 would take 90 years.
17. "What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ,

Technical characteristics were not primary in selecting a remedial alternative. Given the depth
of the contaminants (FHCs) in the vadose zone (up to 100 feet), excavation is impractical.
';,!*
1170
-5-
-------
Monolithic Memories
(National Semiconductor Corp. and Advanced Micro Devices—Arques)
'.'..'-.•.•' .'• . OU-1 •''.-••••• •,; - . •' -,..' "••
Sunnyvale and Santa Clara, California
Region 9 :
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? ,

Maximum concentrations of principal
.contaminants were:

Soil/Subunit 1 (National Semiconductor
Corp. Facility) (mg/kg) ';..'•

Tetrachloroethene (PCE) 9.6
1,2-Dichloroethene 0.93
1,1,1-Trichloroethane 159
Trichloroethene 4.6
Xylenes 3,300
Ethylbenzene 18,000

Soil/Subunit 2 (Monolithic Memories
Facility) (mg/kg)

Solvents (PCE, xylenes, TCE,
chlorobenzene, 1,2-DCE) 400
PNAs (naphthalene, pyrene,
phenol) 270
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/15/84
7/27/87
6/14/91
9/91
Background

PRP-lead /
PRPs: National Semiconductor
Corporation, Advanced Micro
Devices-Argues, Hewlett Packard,
United Technologies Corporation
FS prepared by: Harding Lawson
Associates
2. What volume of material is to be remediated?
', . ' I ...

The volume of material to be remediated included:
- ' ' ' " '" . t - • ,
"I , ' ;•
• There is no reference in the FS or the ROD to the quantity of soil to be remediated in
Subunit 1. The FS states that the soil remedial unit at the Natiomd Semiconductor
Corp. (NSC) and former United Technologies Corporation (UTC) sites is comprised
of: •...,;, ,/ •- , |. • :

— "shallow" (less than 5 feet bgs) vadose zone soils that require remediation of
-,-.'•' volatile organic compounds (VOCs), and

— "deeper" vadose zone soils, from approximately 5 feet!bgs to the historical
surface of the water table at approximately 12 feet bgsj, that require
remediation of VOCs.
-1-
1171
-------
There is no reference in the FS or the ROD to the quantity of soil to be remediated jn
Subunit 2 (Monolithic Memories).
3. WJiat type of site is this?

Electrical Equipment. The two sites, although listed separately on the NPL, contaminate the
same ground water; for this reason, the investigation and evaluation of, cleanup options was
combined. Operable Unit 1 has been divided into three subunits for ease of description.

Subunit I/National Semiconductor Corporation (NSC)

NSC is a semiconductor manufacturing operation that occupies approximately 60 acres of land.
This facility has been in operation since 1967 and is located in an industrial park setting. The
NSC site also includes the former UTC facility, which adds another 10 acres to the site.

Subunit 2/MonoIithic Memories, Inc., Advanced Micro Devices (AMD-Arques)

AMD-Arques is a semiconductor manufacturing operation that ceased production in 1989.
Operations were begun at the facility by Monolithic Memories, Inc., in 1970. The facility is in
the same industrial park as NSC.

Subunit 3 •

Subunit 3 consists of the areas downgradient from Subunits 1 and 2, and extends to the
leading edge of the ground water contaminant plume. Subunit 3 does not contain any facilities
that are known sources of the solvent ground water plume that emanates from Subunits 1 and
2. The selected remedial action for this site only includes treating contaminated soil in
Subunits 1 and 2.
TECHNOLOGY SELECTION '

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening pf technically feasible
technologies were: '
Containment:

Chemical treatment:

Physical treatment:

Thermal treatment:

Disposal:
Vertical barriers (grout curtain, slurry wall, steel sheet piling),
horizontal barriers (grouting, block displacement), capping (clay, soil,
asphalt, concrete, synthetic liner), surface water controls
Precipitation, asphalt batching, solidification (cement based, silicate
based, pozzolanic based, thermoplastic, surface microencapsulation)
Distillation, dewatering, filtration, screening, ion exchange, membrane
separation
Incineration (rotary kiln, multiple hearth, fluidized bed, circulating bed,
infrared, mobile, advanced electric reactor, flare, catalytic)
Source soil excavation, on-site disposal, off-site disposal (landfill)
1172
-2-
-------
5. Was an innovative technology considered in the F$?Ifso, which technology?
,.r '
Innovative technologies considered during the identification and screening of technically
feasible technologies were: -"-..'.
• '•!'••'
Biological treatment: Aerobic and anaerobic biodegradation
Phys/Chem treatment: Oxidation, reduction, hydrolysis, dechlorination, vacuum extraction,
soil flushing/soil washing, solvent extraction, supercritical extraction
Thermal treatment: Pyrolytic combustion, wet ah- oxidation, thermal desoiption, steam
, stripping, in situ vitrificatipn, in situ radio heating
I ' ' •• '

6. What was the cost estimate for the innovative technology? I
i i
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NGP.

The RAAs developed in the FS changed in the ROD and, therefore,1 tijiese are discussed
separately below. ."...',' .,."'.-.

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) j

FS/Soil/Subunits 1 and 2 !
Alternative
RAA-4a
RAA-4b
Innovative Technology
Enhanced interim Remedial Measure
(IRM)a [ground water treatment]/soil
remediation (soil vapor extraction, SVE)
to proposed cleanup standards
Enhanced IRM (ground water treat-
ment)/soil remediation (SVE) to 10"6
risk levels
Estimated Costs
3 Ciitetia
N/A ' ; '
N/A
9 Criteria
$5,900,000
$5,900,000
This site has existing on-site and off-site ground water extraction arid trezitment systems,
which were the IRM for this site.
1173
-------
ROD/Soil/Subunits 1 and 2
Alternative
RAA-2
RAA-3
Innovative Technology
Ground water extraction and
treatment/SVE in Subunit 2
Ground •water extraction and treat-
ment/SVE in Subuiiits 1 and 2/with
contingency to excavate and aerate
shallow soils unresponsive to SVE
Estimated Costs
ROD
$5,500,000
$8,400,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

FS/Soil/Subunits 1 and 2
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action/monitoring/institutional
controls
Current IRM (ground water treatment)
Enhanced IRM (ground water treatment)
Estimated Costs
3 Criteria
, N/A f
N/A
. N/A '
9 Criteria
$2,400,000
$3;500,000
$4,300,000
ROD/Sbil/Subuhits 1 and 2
Alternative
RAA-1
Standard Technology
No action/monitoring/institutional
controls .
Estimated Costs
ROD
$3,200,000
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?
The selected alternative RAA-3 incorporates the use of SVE to treat contaminated soils. SVE
was selected because it is reliable for achieving long-term reductions in soil with chlorinated
1174
-4-
-------
solvent concentrations, is generally easy to implement, and causes only minimal disturbance of
site activities. SVE treatment systems are durable and require replacement of few components,
with the exception of the catalytic incineration or vapor phase carbon equipment used to treat
off-gas. SVE effectively reduces the toxicity, mobility, arid volume of soil containing VOCs
by removing the VOCs from the soil. The nature of the VOCs and properties of the on-site
soils together with experience with this technique on other similar sites in the area indicate that
SVE will be effective in achieving the soil cleanup standards at the NSC/MM site. The
ultimate performance of this technology at the site, however, only can be reliably predicted
based on full-scale operation. RAA-3 will contain migration of contaminants in the polluted
aquifers. Under RAA-3, the soils in Subunit 1 will be treated in addition to those in Subunit
2. This difference significantly reduces cleanup time from greater than 100 years (when soils •
in Subunit 1 are left untreated, they will remain above acceptable risk levels for greater than
100 years) to a 50-100 year range for Operable Unit 1. The selected alternative can provide a
cleanup that achieves an acceptable risk level within a reasonable time period (50-100 years).
If proposed cleanup standards are achieved, the residual carcinogenic [risks for this alternative
are 3.1 x 10"6 and a hazard index of 0.87. The selected alternative will attain all pertinent
ARARs for this site. The state's antiklegradation policy, Resolution (58-16 (which is an
ARAR for these sites), is met because further degradation of a potential drinking water supply
will be prevented. If certain shallow soils that are contaminated with lower volatility
compounds do not respond well to SVE, there is a contingency plan ijnder RAA-3 to excavate
and aerate these soils at the surface. If this occurs, air emissions during excavation and
aeration will be regulated under the Bay Area Air Quality Management District (BAAQMD)
Regulation 8, Rule 40. If meeting the BAAQMD permit levels requires emissions control such
as activated carbon, disposal of spent carbon will have to be managed in accordance with
RCRA Land Disposal Restrictions. Thermal carbon regeneration risks associated with this
process will be mitigated through proper engineering controls and hazardous waste
management practices.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the;three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:
•' - I - '
• Pyrolytic combustion was eliminated because incinerators would not be readily
available or permitted in California for treatment of hazardous waste-contaminated
soils containing the chemicals of potential concern at the NSC/UTC sites. Incinerators
that are available for soil treatment are located outside Califojrnia. and soil excavation
and transportation costs would be very high relative to other treatment processes.
• Wet air oxidation was eliminated because it would not be applicable to soils.
- • Reduction was eliminated because it would not be applicablej to organic constituents in
the soil. , . L
• Hydrolysis was eliminated because it would not be applicable toorganic constituents in
the soil.
" Dechlorination was eliminated because it would not be applicable to organic
constituents in the soil.
• Steam stripping was eliminated because it would not be applicable to soils.
-5-
1175
-------
Thermal desorption was eliminated because it would not be applicable to soils.
Soil flushing/soil washing was eliminated because it would not be effective for the
organic constituents in NSC soil.
Solvent extraction was eliminated because it would not be applicable to soils.
Supercritical extraction-v/as eliminated because it would not be applicable to soils.
Aerobic and anaerobic biodegradation were eliminated because these technologies
would not be effective for the constituents found in NSC soil. Biological treatment is
not considered effective or implementable for NSC or UTC soil because of the
refractory nature of the chemicals. That is, some of the chlorinated chemicals (e.g.,
trichloroethene) present in NSC and UTC soils are difficult to biologically degrade.
Practical bioremediation techniques for these compounds has not yet been
demonstrated. Furthermore, some degradation pathways lead to the production of
other, sometimes more hazardous, intermediate products such as vinyl chloride.
» In situ radio heating was .eliminated because it is a new technology that has not been.
fully developed. . •
• Oxidation was eliminated but no reason was given.
• In situ vitrification was eliminated but no reason was given.

Innovative technologies eliminated during the screening of the three criteria include the
following:

" None

Innovative technologies eliminated during the detailed analysis include the following:

• None • ' ;
1L
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment was weighted heavily in selecting
RAA-3 as the remedial alternative for this.site. Under RAA-2, only soil contamination in
Subunit 2 would be addressed. Without additional soil remediation, contaminated soils in
Subunit 1 would continue to serve as an ongoing source of contamination to the affected
aquifers, extending the cleanup time to longer than 100 years. The selected alternative goes
further than RAA-2 in that it would treat soils in both Subunits 1 and 2.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Total VOCs ._
Polynuclear Aromatic
Hydrocarbons "(PNAs)
Cleanup Level (ppm)
1
10
ARAR or Other Basis
Risk"
Risld1
1176
-6-
-------
"Site-specific health protective standards were set considering ARARs and calculated
cancer risks and hazard indices. For carcinogens, an excess upper bound individual
lifetime cancer risk of between 10"4 to 10"6 was acceptable. For noncarcinogens, a
Hazard Index less than or equal to 1.0 was acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? •'••'-. !

Innovative technologies eliminated because of cleanup goals include: I

; * None " i / . • .- .

Standard technologies eliminated because of cleanup goals include:

- :• . .None ; •. - -I • "'•...'.

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. ••':'&'
' . ••• ' 'i- ; '
. • • " > . -i- > .
- ' ' • I'','-'
75.. What measures/criteria were used to compare alternatives?,

The following measures were used to compare the alternatives: |
• . ' '.','.'',.''.. i- ' .
Cost-effectiveness ,
- Proven reliability , ,..-.•
, - Preference for treatment (vs. containment)
i ' " ,
• '!" • • •'

16. How are measures compared? • j

An evaluation of the alternatives considered shows the selected remedy to be a cost-effective
response. Although the cost of the selected remedy is $.1.7 million more than that of RAA-2,
the other active remediation alternative considered in the ROD, that additional cost reduces the
time necessary to achieve cleanup standards from more than 100 years to a 50-100-year time
frame. SVE is a proven technology for effectively removing VOCs frorn soil. Experience with
SVE on similar sites in the area indicate that this technology would be effective in achieving
the soil cleanup standards at the NSC/MM site and influenced its selection for this site.
Through treatment, RAA-3 actively addresses both soil and ground water contamination at the
sites, thus satisfying the statutory preference for permanent solutions an!d remedies that employ-
treatment as a principal element, i
-7-
1177
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedy for this site. The ability of
the SVE technology to achieve soil cleanup standards, however, is dependent upon site specific
factors that include chemical distribution in soil, soil lithology, and soil moisture content.
1178
-8-
-------
National Semiconductor Corp.
(Monolithic Memories and Advanced Micro Devices, Site #149)
OU-1
Sunnyvale and Santa Clara, California
Region 9
GENERAL SITE INFORMATION
1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil/Subunit 1 (National Semiconductor
Corp. Facility) (rag/kg) _

Tetrachloroethene 9.6
1,2-Dichlorqethene 0.93
1,1,1-Trichloroethane 150
Trichloroethene 4.6
Xylenes 3,300
Ethylbenzene 18,000

Soil/Subunit 2 (Monolithic Memories
Facility) (mgVkg)

Solvents (PCE, xylenes, 400
TCE, chlorobenzene,
1,2-DCE)
PNAs (naphthalene, 270
pyrene, phenol)
Site History
NPL Proposed:
NPL Final:
F$:
ROD:
10/15/84
7/27/87
6/14/91
9/91
, Background
I "
PRP-lead !
PRPs: National Semiconductor
Corporation, Advanced Micro
Devices-Arques, Hewlett Packard,
United Technologies Corporation
FS prepared by: Harding Lawsdn
Associates
2. What volume of material is to be remediated?
. ' •••''!.•'
The volume of material to be remediated included: . ;
. . . • _ , ....
• There is no reference in the FS or the ROD to the quantity of soil to be remediated in
Subunit 1. The FS states that the soil remedial unit at the National Semiconductor
Corp. (NSC) and former United Technologies Corporation (OTC) sites is comprised
.' . of-. ... • '. ' ''..'•;: i.. ••'• .-.'••'
• • '
— "shallow" (less than 5 feet bgs) vadose zone soils thiat require remediation of
volatile organic compounds (VOCs), and . j
— "deeper" vadose zone soils, from approximately 5 fe^t bgs to the historical
surface of the water table at approximately 12 feet bgs, that require
remediation of VOCs. ,
-1-
1179
-------
There is no reference in the FS or the ROD to the quantity of soil to be remediated in
Subunit 2 (Monolithic Memories). ,
3. What type of site is this? • • - .

Electrical Equipment. The two sites, although listed separately on the NPL, contaminate l:he
same ground water; for this reason, the investigation and evaluation of cleanup options was
combined. Operable Unit 1 has been divided into three subunits for ease of description.

Subumt I/National Semiconductor Corporation (NSC)

Subunit 2/MonoIithic Memories, Inc., Advanced Micro Devices (AMD-Arques)

AMD-Arques is a semiconductor manufacturing operation that ceased prpduction in 1989.
Operations were begun at the facility, by Monolithic Memories, Inc., in 1970. The facility is in
the same industrial park as NSC.

Subunit 3

Subunit 3 consists of the areas downgradieht from Subunits 1 and 2, and extends to the
leading edge of the ground water contaminant plume. Subunit 3 does riot contain any facilities
that are known sources of the solvent ground water plume that emanates from Subunits 1 and
2. The selected remedial action for this site only includes treating contaminated soil in
Subunits 1 and 2.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technolbgies considered during the identification and screening of technically feasible
technologies were: '-.;•'• .
Containment:

Chemical treatment:

Physical treatment:

Thermal treatment:

Disposal:
Vertical barriers (grout curtain, slurry wall, steel sheet piling),
horizontal barriers (grouting, block displacement), capping (clay, soil,
asphalt/concrete, synthetic liner), surface water controls
Precipitation, asphalt batching, solidification (cement based, silicate
based, pozzolanic based, thermoplastic, surface microencapsulation)
Distillation, dewatering, filtration, screening, ion exchange, membrane
separation . . .
Incineration (rotary kiln, multiple hearth, fluidized bed, circulating bed,
infrared, mobile, advanced electric reactor, flare, catalytic)
Source soil excavation, on-site disposal, off-site disposal (landfill)
0
11SO
-2-
-------
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically,,
feasible technologies were: ;
".,""' ' . , 'I
Biological treatment: Aerobic and anaerobic biodegradation
Chemical treatment: Oxidation, reduction, hydrolysis, dechlorination, steam stripping, soil
. ' flushing/soil washing, solvent extraction, supercritical extraction
Thermal treatment: . Pyrolytic combustion, wet air oxidation, thermal desorptioh, vacuum
extraction, in situ vitrification, in situ radio heating
6. What was the cost estimate for the innovative technology?

The RAAs developed in the FS changed in the ROD and, therefore, these are discussed
separately below. j
' • ' ' ' .I'"''''
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)

FS/Soil/Subunits 1 and 2 i
Alternative
RAA-4a
RAA-4b
Innovative Technology
Enhanced Interim Remedial Measure
(IRM)8 [ground water treatment]/soil
remediation (soil vapor extraction, SVE)
to proposed cleanup standards ,
Enhanced IRM (ground water
treatment)/soil remediation (SVE) to 10"
6 risk levels
Estimated Costs
3 Criteria
N/A
N/A '.
9 Criteria
$5,900,000
$5,900,000
This site has existing on-site and off-site ground water extraction and treatment systems,
which were the IRM for this site.
-3-
1181
-------
ROD/Soil/Subunits 1 and 2
Alternative
RAA-2
RAA-3
Innovative Technology
Ground water extraction and'
treatment/SVE in Subunit 2
Ground water extraction and
treatment/SVE in Subunits 1 and
2/with contingency to excavate and
aerate shallow soils unresponsive to
SVE
Estimated Costs
ROD
$5,500,000
$8,400,000
7. How did the cost(s) compare to standard technologies? .

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)

FS/SoiySubunits 1 and 2 . ,
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action/monitoring/institutional
controls
Current IRM (ground water treatment)
Enhanced IRM (ground water treatment)
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$2,400,000
$3,500,000
$4,300,000
ROD/Soil/Subunits 1 and 2
8. If a standard technology was chosen, why?

A standard technology was not chosen.
Alternative
RAA-1
Standard Technology
No action/monitoring/institutional
controls
Estimated Costs
ROD
$3,200,000
.'It
•'''it
1182
-4-
-------
9. If an innovative technology was chosen, why?
'••'-.' ': ' '
The selected alternative RAA-3 incorporates the use of SVE to treat contaminated soils. SVE
was selected because it is reliable for achieving long-term reductions iin soil with chlorinated
solvent concentrations, is generally easy to implement, and causes only minimal disturbance of
site activities. SVE treatment systems are durable and require replacement of few components,
with the exception of the catalytic incineration or vapor phase carbon equipment used to treat
off-gas. SVE effectively reduces the toxicity, mobility, and volume of soil containing VOCs
by removing the VOCs from the soil. The nature of the VOCs and properties of the onsite
soils together with experience with this technique on other similar sites in the area indicate that
SVE will be effective in achieving the soil cleanup standards at the NSC site. The ultimate
performance of this technology at the site, however, vonly can be reliably predicted based on
full-scale operation. RAA-3 will contain migration of contaminants in the polluted aquifers.
Under RAA-3, the soils in Subunit 1 will be treated in addition to those in Subunit 2. This
difference significantly reduces cleanup time from greater than 100 years (when soils in
Subunit 1 are left untreated, they will remain above acceptable risk levels; for greater than 100
years) to a 50-100 year range for Operable Unit 1. The selected alternative can provide a
cleanup that achieves an acceptable risk level within a reasonable time period (50-100 years).
If proposed cleanup standards are achieved, the residual carcinogenic risks for this alternative
are 3.1 x W6 and a hazard index of 0.87. The selected alternative .will attain all pertinent
ARARs for this site. The state's anti-degradation policy, Resolution 68-16 (which is an
ARAR for these sites), is met because further degradation of a potenlial drinking water supply
will be prevented. If certain shallow soils that are contaminated with lower volatility
compounds do not respond well to SVE, there.is a contingency plan under RAA-3 to excavate
and aerate these soils at the surface. If this occurs, air emissions during excavation and
aeration will be regulated underthe Bay Area Air Quality Management District (BAAQMD)
Regulation 8, Rule 40. If meeting the BAAQMD permit levels requires emissions control such
as activated carbon, disposal of spent carboff'will have to be managed in accordance with
RCRA Land Disposal Restrictions. Thermal carbon regeneration risks associated with this
process Will be mitigated through proper engineering controls and hazardous waste
management practices. i .

-!'• ' ' '
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? i /

Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the: three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening induce the following:

• Pyrolytic combustion was eliminated because; incinerators would not be readily
available or permitted in California for treatment of hazardous waste-contaminated
soils containing the chemicals of potential concern at the NSC/UTC sites. Incinerators
that are available for soil treatment are located outside California and soil excavation
and transportation costs would be very high relative to other treatment processes.
• Wet air oxidation was eliminated because it would not be applicable to soils.
• Reduction was eliminated because it would not be applicable to organic constituents in
the soil. •
1183
-------
Hydrolysis was eliminated because it would not be applicable to organic Constituents in
the soil. .
Dechlorination was eliminates because it would not be applicable to organic
constituents in the soil. . ,
Steam stripping was eliminated because it would not be applicable to soils.
Thermal desorption was eliminated because it would not be applicable to soils.
Soil flushing/soil -washing was eliminated because it would not be effective for the
organic constituents in NSC soil. ''.',.
Solvent extraction was eliminated because it would not be applicable to soils.
Supercritical extraction was eliminated because it would not be applicable to soils.
Aerobic and anaerobic biodegradation were eliminated because these technologies
would not be effective for the constituents found in NSC soil. Biological treatment is
not considered effective or implementable for NSC or UTC soil because of the
refractory nature of the chemicals. That is, some of the chlorinated chemicals (e.g.,
trichloroethene) present in NSC and UTC soils are difficult to biologically degrade.'
Practical bioremediation techniques for these compounds has not yet been
demonstrated. Furthermore, some degradation pathways lead to the production of
other, sometimes more hazardous, intermediate products such as vinyl chloride.
» In situ radio heating was eliminated because it is a new technology that has not been
fully developed.
» Oxidation was eliminated but no reason was .given. .
• In situ vitrification was eliminated but no reason was given.

Innovative technologies eliminated during the screening of the three criteria include the
following:

* None .

Innovative technologies eliminated during the detailed analysis include the following:

• None .
1L
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment was weighted heavily in selecting
RAA-3 as the remedial alternative for this site. Under RAA-2, only soil contamination in
Subunit 2 would be addressed. Without additional soil remediation, contaminated soils in
Subunit 1 would continue to serve as an ongoing source of contamination to the affected
aquifers, extending the cleanup time to longer than 100 years. The selected alternative goes
further than RAA-2 in that it would treat soils in both Subunits 1 and 2.
1184
0
-,6-
-------
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected tp establish cleanup goals? \'
Contaminant
Total VOGs
Polynuclear Aromatic
Hydrocarbons (PNAs)
Cleanup Level (ppm)
1
io
,
ARAR or Other Basis
Risk"
; Risk1
"Site-specific health protective standards were set considering ARARs and calculated
cancer risks and hazard indices. For carcinogens, an excess upperbound individual
lifetime cancer risk of between W4 to 10"6 was acceptable. For noncarcinogens, a
Hazard Index less than or equal to 1.0 was acceptable.
13.
14:
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None
.' •' . • V „ '•;[:-.• - . .

Standard technologies eliminated because of cleanup goals include:

« . None • ' "-.•-."..'-.- 1 . .' '
Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared? i

An evaluation of the alternatives considered shows the selected remedy to be a cost-effective
response. Although the cost of the selected remedy is $1.7 million more than that of RAA-2,
the other active remediation alternative considered in the ROD, that ildditional cost reduces the
time necessary to achieve cleanup standards from more than 100 years to a 50-100ryear time
frame. SVE is a proven technology for effectively removing VOCs from soil. Experience with
SVE on similar sites in the area indicate that this technology would be effective in achieving
the soil cleanup standards at the NSC/MM site ,and influenced its selection for this, site.
-7-
1185
-------
Through treatment, RAA-3 actively addresses both soil and ground water contamination at the
sites, thus satisfying- the statutory preference for permanent solutions and remedies that employ
treatment as a principal element.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ...

Malaga, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?.

Maximum concentrations of principal
contaminants were:

Soil/Buried Waste/Sediment (rag/kg)
Lead
Ethylbenzene
Chlorobenzene
Toluene
Trichloroethylene
Tetrachloroethylene
Xylene
2-Butanone
4-Methyl-2-pentanone
Methylene chloride
.34,000
19
2.9
20
0.01
3.2
120
8.7
9.1
0.62
Site History
NPL Proposed:
NPL Filial:
FS:
ROD:
N/A
12/82 ..
4/12/89
9/30/92
Background

EPA Fund-lead
PRPs: EPA issued! General Notice
letters to 146 FRPs
FS prepared by: CH2M Hill, Black &
Veatch, ICF, PRC, Ecology and
Environment
2.. What volume of material is to be remediated?

The volume of material to be remediated included:

• . 172,000 cubic yards of buried wastes and contaminated soil and sediment

3. ' What type of site is this? ;
' • ; ' '. • - . '•••'.• -V • ' ••
Waste Oil. An abandoned oil recycling facility .located in an industrial area and surrounded by
a mixture of agricultural, industrial, and commercial land.
'.*',. "I" ' '
; ' ' • ' -' .• • ' ' : •••' \- ' ' • '. .

TECHNOLOGY SELECTION '

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restriction, fences
-1-
1187
-------
Containment:
Chemical treatment:

Physical treatment:
Thermal treatment:
Disposal:
Capping (native soil, clay, synthetic membranes, sprayed asphalt,
concrete, multilayer, chemical sealants/stabilizers), vertical barriers,
horizontal barriers, grading ,
Solidification, fixation, stabilization (encapsulation), neutralization,
precipitation
Water leaching, flotation, oil-water separation, filtration
Incineration
Excavation, off-site RCRA landfill, non-RCRA landfill, on-site
disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically •
feasible technologies were: .
! ' '

Biological treatment: Aerobic processes, anaerobic processes, bioreclamation
Chemical treatment: Solvent extraction (SVE), soil vapor extraction, oxidation, chemical
reduction
6. What was the cost estimate for the innovative technology? >
* I .
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. For this site, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. . .

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) ,
Alternative
RAA-S2
RAA-S3
RAA-S4
RAA-S7
RAA-S8
i
Innovative Technology
Soil vapor extraction/capping
Excavation/on-site incineration/soil
vapor extraction/capping
Excavation/off-site RCRA facility/
soil vapor extraction/subsurface
capping
Excavation/off-site incineration/soil
vapor extraction/capping
Excavation/on-site solvent
extraction/soil vapor extraction/
capping
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
9 Criteria
$6,901,000
$46,390,000
$54,199,000
$126,225,000
$22,450,000
1188
-2-
-------
The RAAs presented in the ROD differed from those presented in the FS and are shown
separately below. : , , •
Alternative
RAA-R3
RAA-R4
RAA-R5
RAA-R6
RAA-R7
RAA-R8
Innovative Technology
Soil vapor extraction (SVE)/RCRA
equivalent cap with slurry walls
Excavation/on-site incineration (0 to 14
feetySVE/capping
Excavation/solidification (0 to* 10
feet)/SVE/capping
Excavation/solidification (0 to 14
feetySVE/capping
Excavation/solidification (500 ppm
leadySVE/capping
Excavation/off-site treatment and
disposal (0 to 14 feet)/SVE/capping
Estimated Costs
ROD
$36,254,000
$74,756,000
$41,918,000
$53,073,000
$55,861,000
$63,659,000 .
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) .
Alternative
RAA-S1
RAA-S5
RAA-S6
Standard Technology
No action
Excavation/on^site incineration/capping
Excavation/off-site RCRA facility
Estimated Costs
9 Criteria
$0
$103,516,000
$110,995,000
The RAAs presented in the ROD differed from those presented in the FS and are shown
separately below. •
Alternative
RAA-R1
RAA-R2
-. • i **
Standard Technology
,No action
RCRA equivalent cap
Estimated Costs
ROD
$0
, $24,686,000

-3-
1189
-------
8, If a standard technology was chosen, why? >

A RCRA cap was chosen in addition to an innovative technology under RAA-R3, These are
discussed below.

9. If an innovative technology was chosen, why?

Under the chosen alternative RAA-R3, soils from 0 to 14 feet will be covered by a RCRA .
equivalent cap, and soils from 14 feet to the water table will be treated with SVE. Soil from 0
to 14 feet is contaminated witlroil and grease which would greatly inhibit the effectiveness of
SVE wells. Therefore, SVE wells will Heat soils from 14 feet to the water table. A significant
amount of the VOCs in soil deeper than 14 feet (approximately 24,387 pounds) will be
removed by the SVE system. Approximately 25 percent, or 17,950 pounds, of VOCs in soil
from 0 to 14 feet are expected to be drawn into the lower layers of soil and treated by the
SVE system. Thus, the treatment will reduce the toxicity, mobility, and volume of
contaminants in the upper and lower layers of soil. The SVE system will be drilled through
the RCRA cap and will operate in place underneath the cap. The selected alternative leaves
waste in place in the upper layers of soil; however, the waste will be^ isolated by the cap and
slurry walls, thus eliminating direct contact with the waste material and minimizing leaching to
ground water. RAA-R3 will undergo a review every 5 years to ensure protection of human
health and the environment. The selected alternative employs a treatment technology that has
been proven effective in the field. Where the technology has been applied, it has proved.very
effective in removing large quantities of contaminants. The FS states that SVE is a technology —t
gaining rapid acceptance for the removal of VOCs from soils. In addition, RAA-R3 complies llw ••-„'
with all ARARs. - "I™, J

10. If an innovative technology was not. chosen, why not? At what stage was the innovative
technology eliminated?
, ' , • • ' - , 1*

Innovative technologies eliminated during the initial screening include the following:' ':''.[
. ' ' : \
• ' !:
• Oxidation (in situ) was eliminated because this is a theoretical, unproven technology
for removing the contaminants of concern. , i
• Chemical reduction (in situ) was eliminated because this is an unproven technology for
removing the contaminants of concern. ,
» Bioreclamation was eliminated because the inorganics present in the waste may be
toxic to microorganisms, and subsurface debris would make bioreclamatipn difficult.
« Aerobic processes were eliminated because they would be unsuitable for the waste
characteristics. Aqueous wastes do not have sufficient organic content to support
biological treatment. .
• Anaerobic processes were eliminated because they would be unsuitable for the waste
characteristics. • • • •
1190
-4-
-------
Innovative technologies eliminated during the screening of the three criteria include the
following: ' : I

' •. None" "'.•'".•/ . . -: ' [ '.''''.'"
•..••-. •.'''• j • • ' "•'' '
Innovative technologies eliminated during the detailed analysis ineludfe the following:
- • • ' "i ' '
• Solvent extraction was not considered in the ROD but was evaluated under RAA-S8 in
the FS. No specific reason is given for its elimination. The FS states that air
emissions^from the solvent extraction process would have to tfe controlled if RAA-S8
were implemented and an off-site facility would have to accent the concentrated oil
waste for treatment, disposal, or recycling, the FS also states! thatt further evaluation
including bench- and/or pilot-scale studies of the process would be necessary to
determine the effectiveness of solvent extraction at the site, i
11.
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment, state acceptance, and cost were weighted
heavily in selecting RAA-R3. The selected remedy protects human health and the
environment through treatment of VOCs in soil deeper than 14 feet, thereby eliminating them
as a source of ground water contamination. Also, approximately 25 percent of the VOCs in
the upper 14 feet of soil will be drawn down to the lower layers by this action of the SVE
system and be treated. The California Department of Toxic Substances supports the preferred
alternative. RAA-R3 also provides overall effectiveness proportionate .[to its costs. This
remedy will cost less than treatment of all the soil layers or off-site disposal .
12.
What cleanup goals were selected? If the cleanup goal was based on kn ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? i
-• " - . . - • " i:
Cleanup goals were not selected for this site in the ROD. I
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? i ,

Innovative technologies eliminated because of cleanup goals, include: !

« None

Standard technologies eliminated because of cleanup goals include:

• None "
-5-
1191
-------
14. Were treatability studies conducted on the innovative technology or standard technology?

The ROD states that treatability studies performed on site waste showed that incineration and
stabilization were effective in treating contaminated soil. The FS based its evaluation of the
.SVE-technology on information gained from the SVE pilot test at the Phoenix-Goodyear
Airport Superfund site in Goodyear, Arizona.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost effectiveness
Proven reliability
Preference for treatment (vs. containment)
16. How are measures compared? . ,

The selected remedy provides overall effectiveness proportionate to its costs, such that it
represents a reasonable value for the money that will be spent. By treating the contaminated
soils by SVE, the selected remedy addresses one of the principal threats posed by the site.
, Selecting a remedy that treats the contaminated*soil is consistent with program expectations
which indicate that highly toxic and mobile wastes are a priority for treatment. Such treatment
is often necessary to ensure the long-term effectiveness of a remedy. Lead, the other principal
threat at the site will not be treated; however, the cap and slurry wall will prevent direct
contact with contaminated soil, thereby eliminating the exposure pathway for lead.
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? . ,

Technical considerations were not primary in.selecting an RAA for this site.
1192
-6-
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Rhone-Poulenc, Inc. (Zoecen) Sandpz
OU-1

.East Palo Alto, California
Region 9
GENERAL SITE INFORMATION
1.
2.
3.
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil(mg/kg)

Arsenic
Cadmium
Lead
Mercury
Selenium
54,000
1,500
13,000
1,900
1,000
Site History
'"
10/15/84
NPL Proposed:
NPL Dropped: 10/SJ9
FS: j 11/91
ROD: 3/92
Background
i
PRP-lead !
PRPs: Rhone-Pouleiic, Inc.
FS prepared by: Geomatrix
Consultants, Inc.
What volume of material is to be !
remediated? , • '. ' |

The volume of material to be remediated included: '
, ' ' i - . • . •
• 91,000 cubic yards of soil i
• '. ' , '. ' '• '! : ...'..
• .- . ." . ' • • - •' ' ' '' i '''""' •
What type of site is this? j

Agricultural Chemicals. A former herbicide manufacturing and packaging facility located in
an industrial park adjacent to residential areas and wetlands. '
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restrictions, local ordinances, fencing
Containment: Capping (soil, concrete, asphalt), revegetation
Chemical treatment: Solidification/stabilization
Physical treatment: ..Evaporation, dust suppressants, wind screens, aeration
Disposal: Excavation, disposal (on-site, off-site)
-1-
1193
-------
5. in innovative technology considered in the FS? If so, which technology?

L we technologies considered during' the identification and screening of technically
feaiiDie technologies were:

Biological treatment: Biodegradation (in situ, ex situ)
Phys/Chem treatment: Soil washing (in situ, ex situ), solvent extraction, vacuum extraction
Thermal treatment: Vitrification (in situ, ex situ), steam stripping

\ - - , : * ^ '
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Standard Technologies
(selected,remedial alternative is in bold)
Alternative
RAA-A
RAA-B
RAA-C
RAA-D
Standard Technology
No action
Removal of all soil containing arsenic
concentrations greater than 5,000
mg/kg/paving/excavation/deed
restrictions/slurry wall/ground water
monitoring/surface cap
Removal of all soil containing arsenic
concentrations greater than 5,000
mg/kg/paving/excavation/deed
restrictions/ground water extraction
system and treatment
Removal of all soil containing arsenic
concentrations greater than 5,000
mg/kg/excavation/fixation of soil
containing arsenic contamination greater
than 1,000 mg/kg /slurry wall/deed
restrictions/surface cap : ,
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
9 Criteria
$900,000
$5,800,000
$6,200,000
$7,800,000
1194
-2-
-------
Alternative
RAA-E
RAA-F
RAA-G
- - -
Standard Technology
Removal of all soil containing arsenic
concentrations greater than 5,000
mg/kg/excavation/fixation of soil
containing arsenic contamination
greater than 500 mg/kg/slurry
wall/deed restrictions/surface cap
Removal of all soil containing arsenic
concentrations greater than 5,000 ,
mg/kg/excavation/fixation of soil
containing arsenic contamination greater
than 500 mg/kg/grpund water extraction
and treatment/deed restrictions/surface
cap
Removal of all soil containing arsenic
concentrations greater than 5,000
mg/kg/excavation/removal of soil
containing arsenic contamination greater
. than 20 mg/kg
Estimated Costs
3 Criteiria
, N/A
N/A
N/A
9 Criteria
$9,100,000
$9,500,000
$85,000,000
8. If a standard technology was chosen, why?

RAA-E was selected because it protects human health and the environment from threats due to
ingestion and inhalation of metals in contaminated soil. Under the selected remedy, treated
soil is returned to the ground only once it lias been stabilized and meets the performance '
criteria. The selected remedy addresses the threat of exposure to contaminated soil in several
ways. First, capping the site and implementing institutional controls removes the threat caused
by ingestion and direct Contact with contaminated soil. By eliminating this exposure pathway,
it attains acceptable carcinogenic risk. Treatment of soils to health-based cleanup levels also
provides long-term protection from ingestion and inhalation should capping and institutional
controls become ineffective at some point in the;future. The selected remedy provides, long-
term protection within the acceptable risk range and long-term effectiveness since it utilizes
treatment. It will result in significant reduction in the mobility, and volume of contaminated
soil by binding the contaminants in the soil. Implementation of RAA-E results in the
treatment of 84 percent of the total mass of arsenic remaining after concentrations greater than
5,000 mg/kg are removed. Results of the treatability studies indicate TCLP standards will be
met. It complies with all ARARs and is cost effective.
If an innovative technology was chosen, why?

An innovative technology wasn't selected.
-3-
1195
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

" Ex situ soil washing was eliminated because it would have limited effectiveness based
on bench-scale studies, which showed it to be ineffective for the arsenic concentration
and soil type at the site. .
• Ex situ biodegradation was eliminated because it would be incompatible with site
contaminants. . .
• Ex situ vitrification was eliminated because of high costs and hazardous arsine gas
production.
• In situ vitrification was eliminated given the site's high ground water table and
because it would require high rates of electrical power input to vaporize the moisture
in the soil, and would produce large volumes of steam and arsine gas, both possibly at
unsafe levels.
« In situ soil washing was eliminated because the technique Would be ineffective given
the site's impermeable shallow soil and the high concentrations of chemicals in the
soil. In addition, the results of bench-scale testing showed it to be ineffective for
reducing arsenic concentration in the site soil.
• Vacuum extraction was eliminated because of incompatibility with the site's chemicals
since they are not volatile. ,
• Steam stripping was eliminated because of incompatibility with the site's chemicals
since they are not volatile. .
» Solvent extraction was eliminated because of incompatibility with the site's chemicals
since arsenic cannot be extracted using immiscible solvents.
• In situ enhanced biodegradation was eliminated because of incompatibility with the
site's chemicals and because it would not meet remedial action goals since arsenic
cannot be degraded: . .

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None ,

Innovative technologies eliminated during the detailed analysis include the following:

« None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
The criteria weighted most heavily in selecting a remedial alternative were long-term .
effectiveness, short-term effectiveness, implementability, and cost. RAA-B and RAA-C were
not selected because they would not provide long-term protection. RAA-G was not preferred
1196
-4-
-------
12.
because it would be very costly, implementation would be difficult aiid lengthy, and it would
pose short-term risk to the community. RAA-F was not preferred because it would not include
a slurry wall and therefore would require more maintenance. RAA-E was selected over RAA-
D because it is the most cost-effective option. ,,j ' .. ' ,

: •.-•• ' i ' ' ,. 'I
What cleanup goals were selected? If the cleanup goal was based'on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

On-site ;
Contaminant
Cleanup Level (mg/kg)
I • (
ARAR or Other Basis
Carcinogens
Lead
Arsenic ,
Cadmium
450 •
. 500
1,000
i Model8
! Risk"
Risk
Noncarcinogens
Mercury
Selenium
300
6,000
I Risk
Risk
I
"Based oh EPA's preferred method, Lead Uptake/Biokinetic Model (Version 0.5, April
1991).
bBased on commercial/industrial use. For carcinogens, an excess upper-bound
individual lifetime cancer risk of between 10"4 to W6 was acceptable. For
noncarcinogens, a Hazard Index less than or equal to 1.0 was acceptable. :

Off-site .
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Lead . .
Arsenic
Cadmium
120
70
250
Model"
Risk"
Risk
Noncarcinogens . i •
Mercury
Selenium
100
2,000
Risk
Risk
"Based on EPA's preferred method, Lead Uptake/Biokinetic Model (Version 0.5 April
1991). . ; ... •'-'.'•] .'"•.
bBased on future residential use. For carcinogens, an excess uppeir bound individual
lifetime cancer risk of between IV4 to W6 was acceptable. For noncarcinogens, a
Hazard Index less than or equal to 1.0 was acceptable.
-5-
1197
-------
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• Bioremediation
• Soil washing (in situ, ex situ) , .

Standard technologies eliminated because of cleanup goals include:

« None . ,
14. Were treatability studies conducted on the innovative technology or standard technology?

Tr .liability studies were conducted to evaluate the effectiveness of soil washing and five
fixation technologies. ,
75. What measures/criteria were used to. compare alternatives?

The following measures were used to compare the alternatives:

Time to design/construct/operate
Impact on nearby populations
Waste left in place/institutional control

16. How are measures compared?

RAA-B and RAA-C, which proposed institutional controls, were not preferred because they
would not be protective of human health since they would not eliminate potential exposure to
contaminated soil and ground water above cleanup levels. Furthermore, they would not offer '
long-term effectiveness since they would rely on continued and proper maintenance. While
RAA-G would have provided the greatest protection and long-term effectiveness, it was not
preferred because it would be very expensive and difficult to implement, and would not
provide short term effectiveness. It would be ineffective in the short-term since it would
require closure of businesses, extensive excavation, and transport of contaminated materials.
RAA-G also would take the longest time (6 years) to implement.
17. What technical considerations were factors in selecting a remedy? Were technical .
considerations primary in the selection of the remedy?
While technical considerations were not primary in selecting a remedial alternative,
impermeable site soil and the high ground water table did preclude the use of in situ soil
washing and in situ vitrification respectively. ' \ ,

" '
IfU
1198
-6-
-------
Sacramento Army Depot Oxidation Lagoons
. :• • • OU-3 , ' ' • . •- j •

Sacramento, California
Region 9 [
GENERAL SITE INFORMATION

1.,, What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal'
contaminants were:

Soil (mg/kg)

Ethylbenzene 2,100
Xylene 11,000
Tetrachloroethene 39 /
2-Butanone 15
2. What volume of material is to be
remediated?
The volume of material to be remediated included:

• 1,000 cubic yards of contaminated soil
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
8/21/87
8/2/91
12/9/91
Background/

Federal Facility \
PRPs: U.S. Army
FS prepared by: IQeinfelder, Inc.
3. What type of site is this? r ,

Military. A U.S. Army depot in a commercial/light industrial area. Until approximately 1980,
Tank 2 was a 1,000 gallon underground storage tank used to store waste solvents. Soil around
the tank has been contaminated with VOCs. The Tank 2 Operable iWt encompasses
approximately 875 square feet.
TECHNOLOGY SELECTION J.
• - • ' ' > • I . ' , -' ' r '
4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
, technologies were: " j

Access restriction: Deed restrictions ..'••- ,
Containment: Capping, liner • ,
Chemical treatment: Silicate pozzolan stabilization, asphalt-based jmicroencapsulation
Thermal treatment: Incineration '
-1-
1199
-------
Disposal:
Excavation, disposal (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and .screening of technically
feasible technologies were: .

Biological treatment: Aerobic degradation, surface aerobic biodegradation, slurry phase
biodegradation
Phys/Chem treatment: Vapor extraction, steam stripping, soil flushing, soil washing, oxidation
Thermal treatment: Low temperature thermal desorption, thermal vapor treatment,
pyrolysis, in situ vitrification
6, What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
1200
Alternative
RAA-2
(RAA-2b)
RAA-3
(RAA-3b)
RAA-4
(RAA-2a)
RAA-5
(RAA-3a)
Innovative Technology
In situ treatment by soil venting/ .
treatment of extracted vapor by
activated carbon/treatment of
entrained water
In situ treatment by soil venting/
treatment of extracted vapor by
activated carbon/off-site disposal of
entrained water
In situ treatment by soil venting/
treatment of extracted vapor by thermal
vapor treatment/treatment of entrained
water
In situ treatment by soil venting/
treatment of extracted vapor by thermal
vapor treatment/off-site disposal of
entrained water
Estimated Costs
3 Criteria
$614,000
$615,000
1
$483,000
$483,000
9 Criteria
$599,000
($614,000)
$599,000
($615,000)
$483,000
$763,000
($483,000)
-2-
-------
>. • ' '
Alternative
RAA-6
(RAA-2c)
RAA-7
(RAA-3c
RAA-8
(RAA-4
RAA-10
(RAA-6a
RAA-11
(RAA-6)
RAA-12
(RAA-7a) V
RAA-13
(RAA-7b)
RAA-14
(RAA-8)

Innovative Technology
In situ treatment by soil venting/vapor
recovery/Xcondensation of .extracted
vapor/treatment of entrained water
In situ treatment by soil venting/vapor
recovery/condensation of extracted
vapor/off-site disposal of entrained
water
Excavation/on-site soil washing/vapor
treatment by activated carbon/off-site
disposal of wash liquid/backfill
Excavation/on-site low temperature
desorption/vapor treatment by activated
carbon/liquid stream treatment/backfill
Excavation/on-site low temperature
thermal desorption/vapor treatment by
incineration/liquid stream
treatment/backfill
Excavation/low temperature thermal
desorption/vapor treatment by activated
carbon/off-site disposal of liquid
stream/backfill
Excavation/low temperature thermal
desorption/vapor treatment by
incineration/off-site disposal of liquid
stream/backfill
Excavation/on-site surface aerobic
biodegradation/backfill
Estimated Costs
3 Criteria
$763,000
•' i
$766,000
$666,000
$764,000
$771,000
i ,( •
$786,000
$775,000
.-$701,000.
9 Criteria
$763,000
$766,000
$666,000
$764,000
$771,000
$786,000
$775,000
$701,000
7. How did the cost(s) compare to standard technologies?
Cost Estimates for RAAs That Include Standard Technioloj»ies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-9
(RAA-5)
Standard Technology
No action
Excavation/on-site incineration/backfill

Estimated Costs
3 Criteria

$2,f
. •-. . ••.'.'
$0
Q7,
-------
8. If a standard technology was chosen, why? s

A standard technology was not selected. ' '. , *

P. If an innovative technology was chosen* why?

The selected remedy will remove contaminants from the soil so that the carcinogenic risk to
future on-site residents will be reduced from 4.5E-4 to 4.5E-6. The noncarcinogenic HHI will
be reduced to approximately 1. By removing the contaminants from the soil, the selected
remedy permanently prevents direct exposure to harmful concentrations in the soil or in the
ground water. In fact, the selected remedy will remove and destroy 99 percent of volatiles in
the zone of maximum contamination. The technology utilized in the selected remedy is well
developed. The results of a treatability study suggest that a soil ventilation rate of 200 cfm
can meet cleanup levels over a period of 6 months. The extracted vapor will be treated by gas
phase adsorption, the typical organic destruction efficiencies of which are 90 percent. As an in
situ process with treatment not limited to a specific volume (as with alternatives involving ;
excavation), soil ventilation has the advantage of potentially affecting contaminants outside the
area of concern. Soil ventilation does not require long-term maintenance or controls. The
selected remedy complies with all ARARs for the site.

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
' ' . ltWF-""\
Innovative technologies could be eliminated from the remedial technology selection process at , V
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation. .

Innovative technologies eliminated during the initial screening include the following:

• In situ aerobic degradation was eliminated because of effectiveness and
implementability constraints. The low permeability and heterogeneity of the soils on
site could reduce effectiveness. Low natural microbial activity and some toxicity was
indicated in,sample analyses. Additionally, uniform infiltration and recovery of
nutrient solutions would be difficult because of soil conditions. Transport of
contaminants to ground water would be possible without complete control of nutrient
solutions.
• Slurry phase biodegradation was eliminated because of the cost of this technology.
• In situ vitrification was eliminated because of the cost of this technology and, once
solidified, the treated mass would be difficult to handle and would require placement
at a site.
• Steam stripping was eliminated because of cost and implementability concerns. This
technology would generate a contaminated water stream, which would require ~
treatment or disposal. Recovery of condensate might be difficult given the low
permeability and heterogeneity of the soil. Demonstrated applications use auger
equipment, which would not be practical for this site, given its access constraints. -
" Soil flushing was eliminated because of effectiveness and implementability constraints. *m*.
The effectiveness of this technology is reduced in low permeability and heterogeneous Wm V
soils. This technology would be difficult to implement given the heterogeneity, of the /
site's soils. Ground water contamination also would be possible if flushing reagents

1202
-------
are not effectively captured. Recovered flushing solvent requires treatment prior to
reuse or discharge. | '
• Pyrolysis was eliminated because of the cost of the technology^
-' ' - - ' i" ' • ' . .
Innovative technologies eliminated during the screening of the three criteria include the
following: ''•..••"•'.
" " ' ' ' • ' ' ' - ' 4 " '
1 . ' -.'•[•
..;• • . ; .None, •. ; . ..' • ... • ,-,'•''! ' •- .'
' •.'.,• .1 ..-• ••'''.
Innovative technologies eliminated during the detailed analysis include the following:
, - . " • !
• Low temperature thermal desorption was eliminated because this treatment technology
is less readily available than other specified technologies.
• Soil washing was eliminated because, according to the results pf treatability studies,
the commercially available wash reagents and wash procedures employed during the
treatability testing did not reduce the leachate levels of the chemicals of concern in the
soil below the maximum levels allowed under Land Ban regulations.
• Surface aerobic biodegradation was eliminated because it mig,ht not meet Land Ban
requirements.
11 Which of the nine criteria were weighted most heavily in selecting ite technology? Did failure
tb meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
\ . • J
Protection of human health and the environment, short-term effectiveness, and implement-
ability were weighted heavily in selecting the chosen remedy. RAA-2b will meet the cleanup
levels set for this site, thereby reducing the estimated total carcinogenic risk posed by the site
by more than 90 percent to 4.5E-6 and reducing the estimated Hffl tcj approximately 1.0. In
addition, soil ventilation is anticipated to have the greatest short-term jefftsctiveness. This
technology presents the least amount of risk to workers and to the environment. As an in situ
process, it minimizes contact with the soil and produces little to no emissions during the well
installation process. By minimizing excavation, this process releases jless dust and fewer odors
to the atmosphere than the other alternatives. The chosen remedial alternative also will be the
simplest to construct and operate. Placement of extraction wells is a simple process and the
soil ventilation system requires little monitoring or maintenance. By [constructing additional
wells at the site, treatment of additional soil areas can be incorporated easily.
12. What cleanup goals were selected? If the cleanup goal was based off. an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals? \
Contaminant
Carcinogens
Tetrachloroethene
Noncarcinogens
Tetrachloroethene

Cleanup Level (mg/kg)

0.2

ARAR or Other Basis

Risk-based

1203
-------
Contaminant
Ethylbenzene
Total xylenes
2-Butanone
Cleanup Level (rag/kg)
6
23
1.2
ARAR or Other Basis
Risk-based
Risk-based
Risk-based
For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4
and 10"6 was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0
was acceptable. ' , .. , , _<_.."
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? .

Innovative technologies eliminated because of cleanup goals include:

• None

Standard technologies eliminated because of cleanup goals include:

• None

14. Were treatability studies conducted on the innovative technology or standard technology?

A treatability study using a computer modeling approach was conducted to assess the soil
ventilation system of RAA-2b. The results of this testing suggest that a soil ventilation rate of:
200 cfm can accomplish the remediation over a period of 6 months.

A treatability study indicated that 75 percent of volatiles and 99 percent of semivolatiles would.
be removed from contaminated soils using soil washing. These studies also indicated that this
technology would not meet Land Ban requirements if the same wash liquids and procedures
used in the treatability study were employed on the site.

A treatability study indicated that using low temperature desorption would remove 99.9 percent
of volatiles from the soils.

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost effectiveness
Proven reliability . .
Preference for treatment (vs. containment)
4»
1204
-6-
-------
16. How are measures compared? " • i
• . i " • I' - ' . •
\ The selected alternative is cost effective in mitigating the principal risk posed by the presence
of contaminants in soil that could migrate to ground water in the future. The estimated cost of
the selected alternative is less than that of any other alternative except RAA-2a and RAA-3a.
The costs of RAA-2a and RAA-3a, however, might increase as a result of stringent
requirements for monitoring dioxin emissions. These two alternatives also were not selected
because of potential difficulties in implementation since the treatment 'specified (extracted
vapor is treated by thermal vapor treatment) in these alternatives is an innovative technology.
Low temperature thermal desorp'tion was eliminated during the detailed analysis of alternatives
because it is less readily available than other technologies. Soil washing was eliminated
because commercially available wash reagents and wash procedure employed would not reduce
the leachate levels of chemicals of concern to the required levels. The selected remedy
satisfies the statutory preference for treatment as a principal element sjince it will remove
contaminants from the soil at the Tank 2 operable unit. !
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?' ,
.'••,:.'..... . ' I -••.-.
The low permeability and heterogeneity of the soils on site resulted in the; elimination
of aerobic degradation, steam stripping, and soil flushing from consideration as *
possible remedial technologies. Although some concern existed regarding the
effectiveness of the selected alternative given the relatively low pernujability of site
soils, careful design of the chosen system should overcome this concern. Technical
considerations, therefore, were not primary in selecting a remedy.
-7-
1205
-------
Sacramento Army Depot Oxidation Lagoons
OU-4

Sacramento, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
Silver
Zinc
397
40
1,960
2,340
23
1,230
1,460
3.46
416
54
10,900
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
8/21/87
3/13/92
9//30/92
Background

Federal Facility
PRPs: U.S. Army
FS prepared by: Kleinfelder, Inc.
What volume of material is to be remediated?

The volume of material to be remediated included: '

• 12,000 cubic yards of soil in the lagoons
• 3,500 cubic yards of soil in the drainage ditches and Old Morrison Creek soil
3. What type of site is this? .

Military. "The site consists of four inactive oxidation lagoons that received most of the
industrial and domestic wastewater generated at the site. Most of the wastewater appears to
have been generated by electroplating operations at the Depot. The site also includes
associated soil in the drainage ditches and Old Morrison Creek soil. These are located within
the army depot in a commercial/light industrial area. '
- fir
1206
-1-
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TECHNOLOGY SELECTION
. ' • "i •
4. What standard technologies were considered for selection in this FS?
•- "- .,•'.-'' ' ! / , , '
Standard technologies considered during the identification and screening of technically feasible
technologies were: '
' • • ." . • • ~ | •'' '
Access restriction: Deed restrictions, fencing
Containment: Capping (clay, asphalt, concrete, geomembrane), liner (clay,
geomembrane, composite, RCRA) !
Chemical treatment: Stabilization/fixation '
Thermal treatment: Incineration
Disposal: Excavation, disposal (on site, off site) !
Was an innovative technology considered in the FS? If so, which technology?
• • • . - • • . • • - : ' \ . ', n . •
Innovative technologies considered during the identification and screening of technically
feasible technologies were: , [

Biological treatment: Bioremediation, vegetative uptake •
Chemical treatment: Soil flushing, oxidation, soil washing >
Physical treatment: Vapor extraction
Thermal treatment: Heat-enhanced aeration, vitrification (in situ, eic sito)
6. What was the cost estimate for the innovative technology?
f
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case the estimated costs were calculated during an evaluation based .on nine
cntena established by the NCP. Many alternatives were eliminated following the three-criteria
analyses and their designations were changed for the detailed analyses and the ROD. These
designation changes are presented parenthetically.
. • , ' - • • i ' '
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4 «..
(RAA-2)
RAA-5
Innovative Technology
Excavation/on-site soil washing/on-site
treatment of wash liquid/backfill with
washed soil/off-site disposal of metals
Excavation/On-site soil washing/on-site
treatment of wash liquid/relocate
washed soil on site/off-site disposal of
metals

Estimated Costs
3 Criteria
N/
N/J
^
V
9 Criteria
$5,020,000
eliminated
-2-
1207
-------
Alternative
RAA-6'
JtV/V/V" •
(RAA-3) ,
RAA-8 •
RAA-9
Innovative Technology
Excavation/on-site soil washing/on-site
treatment of wash liquid/off-site
disposal of washed soil/off-site disposal
of metals
Excavation/on-site soil washing/off-site
treatment of wash liquid/backfill with
washed sbil/off-site disposal of metals
Excavation/on-site soil washing/off-site
treatment of wash liquid/relocate
washed soil on site/off-site disposal of
metals
Excavation/on-site soil washing/off-site
treatment of wash liquid/off-site
disposal of treated soil/off-site disposal
of metals ' .
Estimated Costs
3 Criteria
N/A
N/A
N/A.
t •
N/A
9 Criteria
eliminated
$4,556,000
eliminated
eliminated
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-10
(RAA-4)
RAA-1 1
RAA-12
RAA-13
(RAA-5)
RAA-14
Standard Technology
No action
Excavation/RCRA cap
Excavation/off-site disposal
Excavation/stabilization/backfill with
stabilized soil
Excavation/stabilization/relocate
stabilized soil on site
Excavation/stabilizalion/off-site disposal
of stabilized soil
Excavation/stabilization/backfill with .
stabilized soil/cap
Excavation/stabilization/relocate
stabilized soil on site/cap
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A
.9
N/A
N/A
9 Criteria
$0 '
eliminated
eliminated
$2,547,000
eliminated
eliminated
$3,800,000
eliminated
1208
-3-
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If a standard technology was chosen, why?

Off-site disposal of residuals in sediment was selected.
9.
10.
If an innovative technology was chosen, why? j

tolrTb^* *? °TShe ^Iamati°n C6nter- ^ *e selected ^medy redtS
^nfdZ "?' T6 °f Contaminants through treatment Fuithermore, me^wi!! be
removed from me site resulting in a permanent and long-term solution;; While riste oosed bf

"
coed ca
controlled. This alternative meets all ARARs. This alternative is implemented through a
process that has been proved in the laboratory and is believed to be fLSelSTaf
sponsored pilot studies to evaluate the performance of certain soil washing realms ™d to

TterS- A Pll0t StUdy WiU to ^ducted ^heltefo
m ^f *e Prt«ess Prior to ^-ale -plantation. The selected remedy
hehh nH roost expensive option, but is more effective ta prdtecting human
health and the environment, and is more permanent that the other options
s , no0 Sieon process at
stages, during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:
aeration was eliminated because it would not be effective with metals
Vapor extraction was eliminated because it would not be effective with metals

^
In situ vitrification was eliminated because it is an experimental Itechnolosv
Oxidation was eliminated because it would not be effective with metals
Bioremediation was eliminated because it would not be effective with metals
teChn0l08ieS elimin^d during the screening of the three criteria mclude the
Soil flushing was eliminated because its effectiveness would be decreased in tight soils
as are found in the oxidation. lagoons or in heterogeneous zones of vi
-4-
1209
-------
permeabilities. Furthermore, the even application of permeant soil flushing solution
can be difficult and could spread contamination to a much larger mass of soil.

Innovative technologies eliminated during the detailed analysis include the following:

• None
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were protection of
human health and the environment, long-term effectiveness, and short-term effectiveness.
RAA-2 and RAA-3 were deemed-to be more permanent and provide greater long-term
protection since the contaminants would be removed from the site. RAA-2 will provide better
short-term effectiveness than RAA-3 because RAA-3 involves transporting hazardous rinsate
off site for treatment, which could temporarily increase human health and environmental risks.
RAA-2 was preferred over RAA-4 and RAA-5 because it provides greater permanence since
the contaminants will be removed from the site.
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
Arsenic
Cadmium
5 •
40
Risk3
Risk
Noncarcinogens , '
Lead
174
DTSC"
"Cleanup levels were established from the health-based risk assessment. For
carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4 to
10'6 was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0 was
acceptable. .
bThe Department of Toxic Substances Control developed health-based soil lead levels
(174 ppm for 1- to 6-year old children; 275 ppm for women of child bearing age;.and
3,000 ppm for development construction workers).
75. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? ,

Innovative technologies eliminated because of cleanup goals include:

• None .
1210
-5-
-------
Standard technologies eliminated because of cleanup goals include: !

• None ;
' • '• ,! - ' " ' '
:. ' ' , . .'...'. I '• . ,
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted for two technologies: soil washing| and stabilization.

Soil Washing. Because the first treatability study conducted on soil washing demonstrated low
removal efficiencies for cadmium and lead, additional testing was conducted using two
different processes. The test results obtained by Process #1 suggest a J99.5 percent removal for
cadmium and 97 percent removal for lead using a chelating agent as the leach solution and a
reaction time of 2 hours (test run 2). The test results obtained by Process #2 suggest a
removal efficiency of 99 percent for cadmium and 95 percent for lead using strong acids as the
leach solution, low operating pH, and a reaction time of 1 hour (test run 2). The results of
these tests indicate that both processes can attain the cleanup levels required in the ROD. Due
to differences between laboratory testing and full-scale testing, however, pilot testing was
recommended prior to implementing remediation. . !

Stabilization. Treatability testing of the stabilization process was conducted using a 20%
cement:soil ratio and 10% sodium silicate (by weight). The performance standards for the
stabilized soil included compressive strength, permeability, and teachability. The results of
treatability testing suggest that the stabilized soil did not pass the compressive strength
criterion. The permeability and soluble concentration by TCLP analysis were met. However,
the solubility criterion for cadmium by WET analysis was not achieved. The test results
reflect partial effectiveness of the stabilization process for the treatment of Oxidation Lagoon
site. Should stabilization be considered as the remedial alternative of choice, testing with new
fixating agents (composition and/or concentration wise) will be required. • .' •
.. t . ,

75. What measures/criteria were used to compare alternatives? I "

The following measures were used to compare the alternatives: • I

,-. Preference for treatment (vs. containment) !
Impact on nearby populations !
- Proven reliability
'~. . • ••.'.."•"••' ' ]•' •' ' ', '^

16. How are measures compared? >

The selected remedy satisfies the statutory preference.for treatment as ia principal element.
Soil washing will reduce heavy metals concentrations through treatment.
RAA-3 was not selected because it would pose greater short-term risks; to nearby populations
since soil washing fluid would be transported off site. Soil washing was chosen because it has
been used effectively for the removal of heavy metals from some soils
6 1211
-O- -v
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting, a remedial alternative. One
innovative technology, soil flushing, was eliminated because its effectiveness would be
decreased in the tight soils found in the oxidation lagoons or in the heterogeneous
zones of varying permeabilities. ,
1212
-7-
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Signetics
(combined with Advanced Micro Devices and TRW JMici-owave)
.' . - •' • '" '• .[•
Sunny vale, California
Region 9 i
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil contaminants were not provided;
however, trichloroethene, 1,2-dichloroethene,
Freon 113, and 1,1,1-trichloroethane were
detected in the underlying aquifer.
2. What volume of material is to be
remediated? -: • .

The volume of material to be remediated
included:, , -

• A volume was not provided.
Site History
NPL Proposed:
NPL Dropped:
FS:
ROD:
10/84
10/89
3/91
9/91
Background
"'•.'.-' i
PRP-lead |
PRPs: Signetics Company
FS prepared by: Harding Lawson
Associates,! Engineering-
Science, Inc., Emcon
Associates,! Weiss Associates
3; What type of site is this? • _, " i

' ' /•''': '\
Electrical Equipment. A semiconductor manufacturing facility located in an industrial park
bordered by light industrial and residential areas. ,
TECHNOLOGY SELECTION
' • • ^ -
.4.. What standard technologies'were considered for selection in this FS1'

Standard technologies considered during the identification and screening of technically feasible
technologies were: .
Access restrictions:
Thermal treatment:
Disposal:
Deed restrictions
Incineration
Excavation, disposal (off-site)
-1-
1213
-------
5. Way an innovative technology considered in the FS? If so, which technology?

Innovative technologies cons'dered during the identification and screening of technically
feasible technologies were:

Biological treatment: Biodegradation (enhanced, in situ)
Phys/Chem treatment: Soil flushing, vacuum extraction
6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-2
RAA-3
RAA-4
Innovative Technology
Deed restrictions/continue on-going
ground water extraction and soil-vapor
vacuum extraction
Deed restrictions/enhance ground water
extraction/continue on-going vacuum
extraction •
Deed restrictions/enhance ground
water extraction and vacuum soil-
vapor extraction
Estimated Costs
3 Criteria
N/A
N/A
" N/A
9 Criteria
$3,943,000
$3,946,000
$4,113,000
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
Standard Technology ...
No action
Estimated Costs
3 Criteria
N/A
9 Criteria
$1,439,000
1214
-2-
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8. If a standard technology was chosen, why? |

A standard technology was not selected. j .

ri- ' . • . . ' /
^ •' ~ • ' . I • . ' • '-
9. If an innovative technology was chosen, why?

RAA-4 was selected because it will protect human health and the environment by removing
soil contaminants with vacuum extraction techniques and through the extraction and treatment
of ground water. Ground water extraction prevents the further migration of the plume. Deed
restrictions protect against use of the aquifers before the cleanup is completed. This cleanup
will result in a reduced cancer risk range of 3/7 X 10"4 to 6 X 10* and a reduced Hazard Index
of 0.44. This alternative attains all ARARs. It reduces the toxicity, mobility, and volume of
contaminants that could volatilize into soil gas and eventually into surface air. Therefore, it
also eliminates the potential for long-term exposure to volatilized contaminants that would be
emitted from the soil and accumulate inside buildings. The selected remedy utilizes proven
technologies and implementation is expected to be relatively easy. The selected alternative is
cost effective and meets rapid cleanup requirements and accelerates tike remediation of hot
spots.. '" ' ' . , -.''-•'•''•..'.'-"-.,.

10. If an innovative technology was not chosen, why not? At what stage i!ww the innovative
technology eliminated? -.

Innovative technologies could be eliminated from the remedial technology selection, process at
three stages: during the initial screening; during the screening of the three criteria of .
effectiveness, implementability, and cost; or during the detailed evaluation. .

Innovative technologies eliminated during the initial screening include the following:

: • Enhanced biodegradation was eliminated because it would not be an effective
. technology for the site since chlorinated aliphatic hydrocarbons are volatile at ambient
temperatures.
• In situ biodegradation was eliminated because the anaerobic process for chlorinated
aliphatic hydrocarbons results in the accumulation of undesirable end products (vinyl
chloride) and the aerobic process is less effective for highly tialogenated compounds
such as those in the study area.

Innovative technologies eliminated during the screening of the three criteria include the
following: [ ,.
'. ' • " " ' I ' ' ' :
A three-criteria screening was not conducted.

Innovative technologies eliminated during the detailed analysis include the following:

• Soil flushing was eliminated because the 811 Arques building; and the three basement
dewatering systems would prevent the implementation of an effective flushing system.
The basement dewatering systems control the flow of ground water near the source
areas and would prevent ground water from flowing through soil where flushing would
be desired. The addition of water beneath the buildings also 'might adversely affect
. . - - • • ; • " . • .' • i . ' r - \

•"• :. .' '*'. - ' " • "- • '""•••-• '• '-I':" '-•'. 1215
•/ - •-.-•. . • - '-3--. . I . ' - " . ' ' • .
-------
building foundations that were designed with dewatering systems to mitigate the effect
of saturated soil.
11.
12.
• Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative were protection of
human health and the environment, reduction of contaminant toxicity, mobility, and volume,
and cost-effectiveness. The selected alternative was preferred because it effectively addresses
soil and ground water contamination and because it is the most cost-effective alternative since
it most rapidly meets all cleanup requirements for only a small additional cost.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level \vas selected to establish cleanup goals?
Contaminant
Cleanup Level (ppm) ARAR or Other Basis
Carcinogens
Total VOCs
RWQCB*
'Since there are no ARARs for soil, target cleanup levels were based on guidance ||||l
provided by Regional Water Quality Control Board (RWQCB) and the Department of
Health Services (DHS) for the protection of ground water from leaching of chemical-
bearing soils. . ,
13.
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None , •

Standard technologies eliminated because of cleanup goals include:

* None .
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. • •
1216
-4-
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15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Percentage risk reduction
Cost-effectiveness .
- Time to design/construct/operate

16. How are measures compared?

RAA-4 was preferred because it reduces site risk to acceptable levels!. Furthermore this
alternative was selected because it is the most cost-effective since it rapidly meets all cleanup
, requirements for a present worth cost of $4.1 million as compared to the $3.9 million present
with cost of RAA-2 and RAA-3. Essentially, the additional $0.2 million cost of RAA-4
supports the accelerated remediation of hot spots.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? [ -,

Technical considerations were not primary in selecting a remedial alternative. The on-site
buildings and dewatering systems, however, did preclude the use if soil flushing as a remedial
technology.
-5-
1217
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Spectra-Physics (Teledyne Semiconductor)

Mountainview, California!
Region 9
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
6/88
N/A
11/26/90
3/22/91
Background

PRP-leao*
PRPs: Spectra-Physics, Inc.
FS prepared by: Levine-Fricke
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Soil(mg/kg)

Tetrachloroethylene (PCE) 0.5
Trichloroethene (TCE) 18
1,2-Dichloroethene (DCE) 2.2
Toluene 1
2. What volume of material is to be
remediated?
The volume of material to be remediated included: '

" Approximately 6,000 cubic yards of soil containing concentrations of TCE above 2.5
ppm will be treated.
What type of site is this?

Electrical Equipment. The Teledyne Semiconductor site comprises two Superfund sites: the
Teledyne semiconductor site, a semiconductor manufacturing facility, and the Spectra-Physics
site, a laser and related components manufacturing facility; The contaminated medium at the
Teledyne Semiconductor site is ground water. This analysis addresses the Spectra-Physics site
since the contaminated media are soil and ground water. V
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in^this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Deed restrictions, fencing, zoning restrictions
Containment: Capping (clay, asphalt, concrete)
Physical treatment: Air stripping
',*"-;
1218
-1-
-------
Disposal:
Excavation, RCRA landfill (on site, off site)
Was an innovative technology considered in the FS? If so, which technology?

.Innovative technologies considered during the identification and screening of technically
feasible technologies were: ! „

Biological treatment: Enhanced biodegradation, soil aeration (composting)
Phys/Chem treatment: Soil flushing, soil vapor extraction, steam extraction and ELF radio
frequency heating <
Thermal treatment: Vitrification i
-
What was the cost estimate for the innovative technology? ! .•."-.

During the initial screening process, in which technically feasible teclinologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Mies the RAAs have been
formulated, costs are typically estimated as part of a three-criteria-screening process
(effectiveness, implementability, and cost) to identify alternatives thatj merit a more detailed
evaluation. For this site, the estimated costs were calculated during ah evaluation based on
nine criteria established by the NCR !
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-4
RAA-5
RAA-6
Innovative 'Technology
Expansion of existing soil vapor
extraction system* and continued
operation of existing ground water
extraction system
Expansion of existing soil vapor
extraction system and additional ground
water extraction
Expansion of existing soil vapor
extraction system8 and continued
operation of existing ground water
extraction system to achieve
background levels in ground water
Estimated Costs
3 Criteria
N/A
KT/A
N/A
9 Criteria
$2,729,595
$4,882,162
. $2,676,845
"In 1987, Spectra-Physics installed a soil vapor extraction system as ail interim removal action
to reduce VOCs in the soil.
-2-
1219
-------
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
Standard Technology
No action
Institutional actions
Soil excavation with existing ground
water extraction
Estimated Costs
3 Criteria
N/A
N/A
N/A ,
9 Criteria
N/Aa '
$794,811
$6,723,538
"The present worth cost of RAA-1 was not given. According to the FS, the total direct and
indirect costs for this alternative are $1,280, and the annual operation and .maintenance costs
are $53,160.
8. If a standard technology was chosen, why?

A standard technology was not chosen.
9. If an innovative technology was chosen, why?

The proposed plan recommended RAA-5 as the selected alternative because of the additional
ground water extraction wells required under this alternative. Based on comments provided by
Spectra-Physics during the public comment period, and a review of the information contained
in the administrative record for the sites, the California Regional Water Quality Control Board
(RWQCB) and EPA selected RAA-4 with a requirement that the effectiveness of the system be
evaluated in 2 years. , •

The selected alternative, RAA-4, was chosen because this alternative provides soil treatment by
expanding the existing soil vapor extraction system. This technology will reduce the volume
of volatile organic compounds (VOCs) in site soils and reduce the risks associated with
contaminants leaching out of soils into the ground water. The soil vapor extraction system
will be designed to remediate VOCs in the upper .10 feet of soils in excess of 2.5 ppm TCE
and soils in excess of 0.5 ppm TCE below 10 feet. This technology removes the threat of
migration and exposure to VOCs in soil. Soil remediation under RAA-4 will reduce toxicity,
mobility, and volume of contaminants through treatment. Since a vapor extraction system has
operated at the site since February 1989, the technology under the selected remedy is already
partially implemented and the construction of additional soil vapor extraction wells is reliable
and easily implemented. The existing system his proved effective at removing VOCs from
soils; the removal to date represents most of the estimated total VOCs in soils in the area of
the site where the system has been installed. Vapor extraction also has relatively low capital
and operating and maintenance costs compared to other removal technologies. In addition, this
alternative complies with all ARARs.
1220

-3-
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10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? :
" *" . - ' ' ; t v. ,.",....
Innovative technologies could be eliminated from the remedial technoloj?y selection process at
three stages: .during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Chemical reduction was eliminated'becaus'e it would not be applicable for inorganic
metals. This technology has not been utilized successfully for removing metals or
treating soils (U.S. EPA, 1988); chemical extraction has been u«ed primarily for
. treating sludges contaminated with hydrocarbons. I
• In situ vitrification was eliminated because it would not be applicable to the site given
the presence of ground water and variable soil conditions at this site. In addition, this
technology is considered impractical when applied over large areas because of the
heterogeneity of the mass to be vitrified, maintenance of process control over large
areas, and the presence of shallow ground water (U.S. EPA, 1985).
• Pyrometallurgical reprocessing was eliminated during the mitial screening stage for
. tailings in the Smelterville Rats and the CIA because it would krt be feasible with
low-concentration wastes and would be applied more appropriately to higher
concentration materials.

Innovative technologies eliminated during the screening of the three criteria include the
following: ;
- .-*- ' . *i . f > \
• In situ leaching for metals was eliminated based on its anticipated lack of
effectiveness, problematic implementation, and/or high costs relative to other equally
( effective options. The history of using this technique for uranium recovery suggests
that aquifer protection and restoration could be long-term problems due to the
potentially hazardous nature Of the solvents used. Treatability studies conducted by
.the University of Idaho using site samples showed that a strong oxidant is required to
dissolve the amounts of metals at the site, and acceptable metals extraction occurred
only under extreme acidic conditions. The recovered leach solution would produce a
waste sludge that probably would be contaminated with the mejtals of concern and
would require treatment and disposal. !
• Hydrometallurgical reprocessing was eliminated because metals' mobility in the
processed tailings would increase substantially because of grinding and classification
during processing. Additionally, neither suitable milling or refining facilities are
currently available to handle site materials nor is a suitable disposal site available for
subsequently produced materials. This process .also would have a high capital cost.

Innovative technologies eliminated during the detailed analysis include the following: '

• None i
-4-
1257
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12. Wliat cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (ug/kg)
ARAR or Other Basis
Carcinogens
Tetrachloroethylene
(PCE)
Trichloroethene (TCE)
5
5
State*
State8
Noncarcinogens
Toluene
100
State8
"State of California's maximum contaminant level.

J3. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

" None .

Standard technologies eliminated because of cleanup goals include: -

• None :
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. ' .

15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost-effectiveness
Proven reliability
Preference for treatment (vs. containment)

16. tiow are measures compared?

The ROD states that the selected remedy is cost effective. An effective vapor extraction
system has been operational at the site since 1989. The decrease in VOC removal rate after 5
weeks of operation shows that the system effectively removed the majority of VOCs in soils in
a relatively short time period. The chosen remedy utilizes permanent treatment technologies to
1232
-5-
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the maximum extent practicable and satisfies the statutory preference for remedies that employ

treatment as a principal element. .
• ' ~ . i ' ' '

17. What technical considerations were factors in selecting a remedy? Were technical

considerations primary in the selection of the remedy? j

• ' • , ' ' " • ' •• •' .f: ' • ' •
Technical considerations were not primary in selecting a remedy for this; sits.
-6-
1223
-------
Valley Wood Preserving, Inc.

Turlock, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface Soil (mg/kg)

Arsenic 140
Hexavalent chromium 30

Subsurface Soil (mg/kg)

Arsenic . 232
Hexavalent chromium 68
Site History

NPL Proposed: 6/88
NPL Final: 3/89
FS: 6/91
ROD: 9/91

Background

PRP-lead
PRPs: Valley Wood Preserving, Inc.
FS prepared by: Geosystem
Consultants, Inc.
What volume of material is to be remediated?

The volume of material to be remediated included:

• 15,000 cubic yards of soil
3. What type of site is this? • . . , ;

Lumber and Wood Products. An inactive wood preserving facility located in an agricultural
and residential area. '.'•..'
TECHNOLOGY SELECTION ''.-..'•

4. What standard technologies were considered for selection in this FS? ., '
i

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing
Containment: Capping (synthetic membrane, bentonite, asphalt arid/or concrete,
multilayer), vertical barriers, hydraulic barriers
Chemical treatment: Fixation
Thermal treatment: Incineration (flame-reactor)
1224
-1-
-------
Disposal:
Excavation, off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were:

Surface and Subsurface Soil

Chemical treatment: In situ soil flushing, soil washing
Thermal treatment: In situ vitrification
6. What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies
(prior to the formulation of RAAs), the FS does not quantify costs.
formulated, costs are typically estimated as part of a three-criteria
(effectiveness, implementabittty, and cost) to identify alternatives that merit
evaluation. In this case, the estimated costs were calculated during an
nine criteria established by the NCP.
Alter 1
are identified
(the RAAs have been
screening process
a more detailed
evaluation based on
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
Innovative Technology
In situ soil flushing of soil with
hexavalent chromium/excavation and
fixation of soil with arsenic
Estimated Costs
3 Criteria
N/A
I
I - • •
9 Criteria
$332,000 to
$1,323,000*
*The range of costs depends on the volume of arsenic containing soil.
-t
7. How did the cost(s) compare to standard technologies? L K

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) !
Alternative
RAA-1
RAA-2
Standard Technology
No action
Capping
Estimated Costs
3 Criteria
N/A
N/A
. 9 Criteria
$0
$216,000
-2-
1225
-------
Alternative
RAA-4
Standard Technology
Excavation/fixation
Estimated Costs
3 Criteria
N/A
9 Criteria
$1,119,000
to
$1,853,000*
'Cost depends on the volume of soil remediated.
8, If a standard technology was chosen, why?

RAA-4 was selected because it provides the greatest overall protection to human health and, .
the environment. Fixation of contaminated soil reduces direct contact and inhalation risks, and
protects ground water, thereby reducing site risks to 10"6. This alternative will be effective
since fixed soil will either meet leaching criteria or be placed in lined cells. Fixation
eliminates the teachability and mobility of hexavalent chromium and arsenic in soil. It
complies with all ARARs. The long-term effectiveness of fixation will be dependent on long-
term maintenance and monitoring of the fixed soil mass and liner system. If the technique is
implemented properly and institutional controls are maintained, fixation is expected to provide
long-term effectiveness. It is implementable and all equipment and services are readily
available through several companies.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .

Innovative technologies eliminated during the initial screening include the following:

• In situ vitrification was eliminated because the technology is still in the developmental
stage and widespread application has not been reported. In addition, the near-surface
soil at the site consists of fine-grained sands to silty sands which are likely to have
high permeability and the ground water table is at depths of 4 to 8 feet which is too
shallow for implementing in situ vitrification. Field testing has not shown the ;.
technology to be effective in either high permeability soil or where the ground water
table is shallow. • ;
• Soil washing was eliminated because of the degree of site disturbance, the need to
recondition the soil following treatment and prior to backfilling, and the associated
higher cost., ,

1226
1
-3-
-------
Innovative technologies eliminated during the screening of the three criteria include the
following:
i "
' • ' ' : '• i '
• None , ; |

Innovative technologies eliminated during the detailed analysis include the following:

• In situ soil flushing was eliminated because site conditions might limit the feasibility
and effectiveness of the technology. This technology might not comply with all
ARAR.S if site conditions limit its ability to achieve ground water cleanup standards.
Its long-term effectiveness would be uncertain since the technology is unproved and
would require treatability studies. It would not be acceptable jto the state or the ,
community until its effectiveness is proved.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedial alternative jwere protection of
human health and the environment, compliance with ARARs, long-term effectiveness, and
state and community acceptance. RAA-4 was selected because it best! protects human heath
and the environment, is the only alternative that complies with all ARAKs;, is more effective,
and is acceptable to the state and community because it is a proved technology.
' i ' ^ ' -
RAA-3, in situ soil flushing was eliminated because its overall protection, effectiveness, and
ability to comply with ARARs is uncertain. '
12. What cleanup goals were selected? If the cleanup goal was based on\ an ARAR, what was that
ARAR? What risk level was selected to establish Cleanup goals? l
... -i *
Surface Soil .
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
Arsenic
Hexavalent chromium
2 . '-
- "- 4 ' -•

Risk*
Risk
"Surface soil cleanup levels are based on potential health risks from inhalation and
direct contact and correspond to a 10"6 excess cancer risk. i.. .
•• -. . ", . • i' •' •
Subsurface Soil !
Contaminant
Cleanup Level (ppb)
ARAR lor Other Basis
Carcinogens
Arsenic
Hexavalent chromium
: 5
5
i DIM*
DLM
•;'.-•'• '• -4- . .-. > ;. : . ! ' . '.-. •
1227
-------
"Subsurface soil cleanup levels are based on the Designated Level Methodology for
characterizing waste in soil adopted by the Central Valley Regional Water Control ^"^ \
Board in June 1989. The levels are established to protect ground water from - *
contaminated leachate from the soil. .

73. Was the innovative technology eliminated because of the cleanup, goals? Could the standard
technology meet the cleanup goals? * ,' .

= Innovative technologies eliminated because of cleanup goals include:

" In situ soil flushing ,

Standard technologies eliminated because of cleanup goals include:

» Capping

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. .

75. What measures/criteria were used to compare alternatives? '•'.',
• " ' • ' • ^Hf \
The following measures were used to compare the alternatives: )

Proven reliability
Preference for treatment (vs.. containment) , . ,
Community acceptance

16. How are measures compared?

The selected technology was preferred because it is proven and reliable. In situ soil flushing
was not acceptable to the state or community because its effectiveness was unproved at the
site. Treatment was preferred over containment because capping would be only partially '
protective of ground water, it would leave contaminants on site, it would not attain ground ,
water ARARs, and it would not be acceptable to the state or community. - ,

17. What technical considerations were factors in selecting a remedy?. Were technical
considerations primary in the selection of the remedy?

Technical considerations were primary in selecting a remedial alternative. In situ soil flushing
was not selected because site conditions (not specified) might limit its feasibility and thereby
make its overall protection and effectiveness uncertain. ,
1228 . . " - . v. -.,
-5-
-------
Van Waters & Rogers
San Jose, California
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
' contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were: •

Soil (mg/kg) '

Tetrachloroethene (PCE) 250
Trichloroethene (TCE) 37
1,1,1-Trichloroethane (TCA) 997
Acetone 500
1,1-Dichloroethene 24
1,2-Dichloroethene 7.5
Methylene chloride 210
Vinyl chloride 1
Site History
'
NPL Proposed: i 10/84
NPL Dropped: 10/89 .
FS: 2/91
ROD:
9/91
Background
PRP-lead
PRPs: Univar Coiporation
FS prepared by: Gieosystem
Consultant!!, Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:
8,100 cubic yards of soil containing greater than 10 mg/kg PCpE, TCE, and TCA-
46,000 cubic yards of soil containing 1 mg/kg volatile organic compounds (VOCs)
3. What type of site is this? i
- ' ' ' . " - . r~ ,.-•'-.
Chemicals and Allied Products. A commercial chemical storage, handling, and distribution
facility located in a commercial and industrial area. .
TECHNOLOGY SELECTION i
-'• ; '~r~- ] ' ' , . • . Jr.. ..••.•.•:
4. What standard technologies were considered for selection in this FS? •

Standard technologies considered during the identification and screeniing of technically feasible
technologies were: ^ •''.-[

Access restrictions: Deed restrictions
-1-
1229
-------
Containment:
Physical treatment:
Thermal treatment:
Disposal:
Capping (synthetic membranes, low-permeability soil, bentonite,
asphalt, concrete, multilayer), slurry wall, grout curtain, sheet pile wall,
hydraulic containment . ,
Aeration
Incineration
Excavation, disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: -

Biological treatment: Bioremediation .
Chemical treatment: Soil flushing, soil washing
Physical treatment: In situ vapor extraction
Thermal treatment: In situ air/steam stripping, on-site steam stripping, low-temperature
thermal desorption
6. What was the cost estimate for the innovative technology? '

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
RAA-4
RAA-5B
Innovative Technology '
In situ vapor extraction (ISVE) of soil
containing greater than 10 ppm PCE,
TCE or TCA/ground water remediation
Capping of soil containing greater
than 1 ppm VOCs/in situ vapor
extraction of soil containing greater
than 10 ppm PCE, TCE, or TCA/
ground water remediation
Excavation of soil containing greater
than 1 ppm total VOCs/low-temperature
thermal desorption/ground water
remediation ,
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria
$4,931,000
$4,997,000
, *
$17,699,000
to
$17,756,000a
1230
-2-
-------
Alternative
Innovative Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-5C
In situ vapor extraction of soil
containing greater than 1 ppm VOCs/
ground water remediation ,
M/A
$11,012,000
"Range of costs is dependent on indirect capital costs.
7. How did the cost(s) compare to standard technologies? \
•• " ' . ' . • ' ' • • i
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) .1 • .
8.
Alternative
RAA-1
RAA-2
RAA-a
Standard Technology
No action
Capping of all soil containing greater
than 1 ppm VOCs/ground water
treatment
Excavation of all soil containing greater
than 1 ppm VOCs/on-site aeration/
ground water remediation
Estimated Costs
3 Criteria
N/A -
• '3
•. ' "]
If a standard technology was chosen, why?
N[/A
VA
9 Criteria
$2,309,000
$4,335,000
$11,876,000
to
$11,934,000

. A cap to enhance soil vapor extraction was selected.
9.-, If an innovative technology was chosen, why? - , • ,! -- ', v

RAA-4 was selected because it will be protective of human health and die environment by
reducing the potential excess cancer risk associated with the ingestion or inhalation of organic-
containing ground water to less than 1 X 10"4. The selected alternative provides a greater '
degree of protection since it combines capping which will prevent direct contact with site soil
and leaching of VOCs from soil to ground water and ISVE, which will reduce VOC
concentrations in soil. It complies with all ARARs and is cost-effective. Through capping
this alternative results in reduced contaminant volume, toxicity, and mobility and thereby
provides permanence, and long-term effectiveness. It will be easily implemented as the
construction of the ISVE system is straightforward. The implementation of this alternative
, will not create any unacceptable short-term risk. ,| ,
-3-
1231
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

" Bioremediation was eliminated because most of the contaminants of concern requiring
remediation are chlorinated organic compounds that are generally toxic to most
microorganisms and have not been proven to be amenable to bioremediation.
Additionally, the low permeability of the native vadose soil would make installation of
a system capable of uniformly delivering oxygen and nutrients difficult. This process
is therefore unlikely to be successful at this site. •
• Soil flushing was eliminated because it was not considered technically implementable
at the site because the low permeability of the site soils might preclude the installation
of an adequate solvent delivery system. '
• In situ air/steam stripping was eliminated because it was not considered technically
implementable at the site as the technology is relatively unproven for most of the
chemicals of concern. Additionally, the degree of site disturbance is relatively high as
compared to other, lower cost in situ remediation technologies. Accessibility of die
soils to be remediated also was a limitation to the application of the technology due to
the depth of soil and surface obstructions. The maximum depth that .can be remediated
is 30 feet and soil beneath surface structures can not be accessed.
• On site steam stripping was eliminated because it is relatively unproven. Additionally,
the cohesive, fine-grained nature of the soils at the site would require considerable
effort and energy (fuel) to be expended to effectively strip the organic chemicals from
the soil and then dry out the treated soil.
• Soil washing was eliminated because it is not well proven for treating fine grained soil
containing organic chemicals.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• None
»
Innovative technologies eliminated during the detailed analysis include the following:

" Low-temperature thermal desorption was eliminated because it would require
excavation, which would pose short-term risk. Additionally, it would not be practical
to implement this technology at an operating facility and it would not be cost-effective.
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
t • . . ._
Protection of human health and the environment, short-term risk, and implementability were
the criteria weighted most heavily in selecting a remedial alternative. RAA-4 was preferred
because it would provide greater protection than RAA-2 and RAA-3. RAA-4 was preferred
1232
-4-
-------
over RAA-5 because it will be more easily implemented and will not create an unacceptable
short-term risk. s - • j • -
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Due to inaccessibility problems in the area of the underground tanks, soil will be remediated in
two phases. Both interim and final soil cleanup requirements were established. Interim soil
cleanup levels will minimize the potential for migration of contaminants to ground water. The
final soil cleanup levels will be accomplished after the underground tanks are removed.
Interim soil cleanup levels /
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens
Tetrachloroethene
Trichloroethene
1 , 1 , 1 -Trichloroethane
10
10
10
Model8
Model
Model

aARARs are not available for soil and therefore the objective j of soil remediation was
to minimize the potential impact of contaminated soil on ground water. The SESOIL
model was used to determine an acceptable concentration of contaminants at which no
leaching of chemicals to ground water could occur. ; ,
• I : • . -
Final soil cleanup levels !
Contaminant
. Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens ' ^
Total volatile organic
compounds
1

Model8
"ARAKs are not available for soil and therefore the objective] of isoil remediation was
to minimize the potential impact of contaminated soil on groiimd water. The SESOIL
model was used to determine an acceptable concentration of contaminants at which no
leaching of chemicals to ground water could occur.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? j . >

Innovative technologies eliminated because^ of cleanup goals include:;

• None , :
-5-
1233
-------
Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted for aeration, low-temperature thermal desorption, and in
situ vapor extraction. , . ,,
15. What measures/criteria were used to compare 'alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Cost-effectiveness
Impact on nearby populations
Preference for treatment (vs. containment)
16. How are measures compared?

The preferred alternative was selected because it incorporates two soil remediation
technologies and therefore provides greater protection than RAA-2 and RAA-3. .RAA-5 was
eliminated because it would pose short-term risk to nearby populations and workers since it
would involve open excavation during which significant quantities of organic vapors would be
expected to volatilize particularly if aeration of soils was used as a principal means of
remediation. RAA-5 also was not. preferred because it would be the most difficult to
implement and would involve extensive site modifications which would not be practical at an
operating facility. Finally, RAA-5 would not be cost-effective.
ill"1
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?

Technical considerations were not primary in selecting a remedial alternative. The low soil
permeability and fine-grained nature of the soil, however, precluded the use of several
innovative technologies including bioremediation, soil flushing, air/steam stripping, and soil
washing.
1234
-6-
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Westinghouse Electric Corp. (Sunnyvale Plant)
• ; ''••-."' ' :' . i •
Sunnyvale, California I
Region 9
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant .levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (rag/kg)

PCB
42,000
2. What volume of material is to be
remediated?

The volume of material to be remediate^ -
included:

• 400 cubic yards of soil
Site1 History
NPL Proposed:
NPL Final:
FS:
ROD:
10/15/84
6/1/86
12/90
10/91
Background
j
PRP-lead |
PRPs: Westinghoiiise Electric Corp;
FS prepared by: E1MCON Associates
3. What type of site is this? , !

Electrical Equipment. A manufacturing facility that previously manufactured and stored
transformers. The facility is located in a light industrial, commercial^ and residential area.
TECHNOLOGY SELECTION . . I
' ' • .'-,-- ' ' !~ •
4. ~ What standard technologies were considered for selection in this FS?
, • ' - - '! ".''''•".'
Standard technologies considered during the identification and screening of technically feasible
technologies were:
' " i • - '
Access restriction: Deed restrictions '. • !- .
Containment: Capping (RCRA, asphalt, concrete, soil) |
Chemical treatment: Fixation ' ' \
Thermal treatment: Incineration (rotary kihi, circulating bed, infTiared) ;
Disposal: Excavation
1235
-i-
-------
Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: . ,

Biological treatment: Biodegradation (ex situ, in situ)
Chemical treatment: Solvent extraction (in situ, ex situ), dechlorination, oxidation
Thermal treatment: In situ vitrification
6. What was the cost estimate for the innovative technology?

The volume of contaminated media to be remediated was changed for two alternatives in the
ROD. These changes are presented in a separate table below.

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative-
RAA-1
RAA-2
RAA-3
RAA-4
Standard Technology
No action/monitoring
Soil cap/ground water hydraulic .
containment
Soil excavation to 10 inches/off-site
incineration or disposal/capping/ground
water containment
Soil excavation to 4 feet/off-site
incineration or disposal/capping/ground
water containment
Estimated Costs
3 Criteria
N/A
N/A
N/A
' •*-,
N/A
9 Criteria
$3,555,000
$5,838,000
$5,887,000
• , or
$6,148,000a
$6,060,000
or
$7,367,000
-------
ROD
Alternative
RAA-1
RAA-2
RAA-3A
RAA-3B
RAA-4A
RAA-4B
Standard Technology
No action .
Soil capping j
Excavation to 8 feet/off-site disposal/capping/
ground water containment
Excavation to 8 feet/off-site incineration/ [
capping/ground water containment *
Excavation to 32 feet/off-site disposal/capping/ j
ground water containment
Excavation to 32 feet/off-site incineration/
capping/ground water containment
Estimated Costs
: ROD
$3,744,000
, , $6,474,000
$6,874,000
$8,263,000
$7,840,000
$12,882,000
&• If a standard technology was chosen, why? !

RAA-3B was selected because it protects human health and the environment since it addresses
soil with greater than 25 ppm PCB, which represents a lO"6 risk in the! industrial setting. This
soil will be removed to a depth of 8 feet and incinerated off-site. Eiglit feet of clean soil, an
asphalt cap, and land use restrictions will further prevent potential contact with the surface or
subsurface soils. Subsurface soil will be remediated because it would pose a potential risk to
future site workers. Land use restrictions for excavation or future development in the area
where contaminated soils remaining at depths greater than 8 feet will prevent future excavation
and therefore exposure to buried contaminated soil. Soils left in-place do not represent a
principal threat since they are located at depths greater than 8 feet and do not significantly
affect ground water. The decision to choose the more expensive option of incineration is
based on the strong statutory preference for treatment. Additionally, these soils are classified
as principal threat soils and such wastes are to be treated rather than kind (disposed wherever
practical [NCP, 40 C.F.R. 300.430(a)(l)(iii)]. Incineration reduces toxicity, mobility, and
volume by destroying the PCBs in the excavated soil. Incineration, therefore, is the more
permanent option for excavated soil since PCBs are destroyed. This alternative is technically
and administratively feasible. The technologies are practical and provein. No short-term risk
of exposure will be posed to nearby residents and proper health and safety procedures can
mitigate the risk posed during excavation. This remedy complies with ARARs and is cost
effective. - •
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
1237
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .

Innovative technologies eliminated during the initial screening include the following:

• Biodegradation (ex situ, in situ) was eliminated because the PCB in the study area,
Aroclor 1260, is considered nonbiodegradable as a result of its high degree of
chlorination.
• Oxidation (ex situ, in situ) was eliminated because it has not been developed for PCB-
contaminated soil and its effectiveness would be uncertain.
• In situ vitrification was eliminated because it would be appropriate only for
undeveloped areas since it would vitrify utilities and cause soil settling, which would
damage adjacent structures.

Innovative technologies eliminated during the screening of the three criteria include the
following: v

• In situ solvent extraction was eliminated because it might not be effective at the site
since the heterogeneous soils could cause "short circuiting" and the solvent could
bypass the most heavily affected low-permeability material and potentially promote
PCB migration across the aquitard. It has not been developed commercially and
reliable cost estimates are not available.
• Ex situ solvent extraction was eliminated because it would require preprocessing of .the
heterogeneous soil to produce uniformly sized material, and the heterogeneous soil
would require excessive amounts of solvent that would require careful handling and •
treatment. Even after preprocessing, the process would require several stages and the
PCB removed by the treatment would have to be transported off site and incinerated.
This process has not been commercially developed.
» Dechlorination (in situ, ex situ) was eliminated because it would not be implementable
or cost effective. Suitable processing equipment would need to be developed based on
an extensive treatability program. According to contractors with experience using
these .technologies, this remediation program is too small for such options to be cost
effective; that is, the contractors would charge Westinghouse the same amount they
would charge for a project many times greater, resulting in a cost of perhaps as much
as $1,200 per cubic yard; Furthermore, at least some of the treated soil would have to
be disposed of off site because the total volume would be too large to backfill. The
disposal costs present an additional cost. .

Innovative technologies eliminated during the detailed analysis include the following:

• None . .
:1
1238
-4-
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of"the criteria supported the use of a standard technology?

The criteria weighted most heavily in selecting a remedy were protection of human health and
the environment; permanent reduction of contaminant toxicity, mobility, and volume; and cost
effectiveness. Excavation to 8 feet and incineration was preferred ovejr capping because they
were more protective since site contaminants are permanently removed. The selected
alternative was preferred over excavation to 32 feet and incineration (RAA-4) because it is
more cost effective. i .
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
13.
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens \
PCBs
. 25
. OSWERa
"OSWER Directive No. 9355.4-01, Guidance on Remedial Actions For Superfund Sites
With PCB Contamination, August 1990. |
Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? • < ,

Innovative technologies eliminated because of cleanup goals include: .

•• None .

Standard technologies eliminated because of cleanup goals include:

• None. ' . ,
14v- Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted. • i
75. ' What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

- Risk level achieved
- Cost-effectiveness
. - Preference for treatment (vs. containment) -
Waste left in place/institutional control
-5-
1239
-------
16. How are measures compared?

The selected alternative was preferred because it provides a protective and cost-effective
remedy. Containment through capping was not preferred necause relying on land use
restrictions and fencing to prevent any potential exposures to soil below the cap would pose a
much higher risk. Furthermore, it is the least permanent solution of all of the options.
Excavation to 32 feet and soil removal would not be cost-effective because it would not reduce
risk significantly more than the selected remedy but it would cost much more. The decision to
remove soil in this area to a maximum depth of 8 feet, rather than capping it was deemed
reasonable because shallow excavation activities might occur on this industrial property in the
future. Removing all soil to the depth of the water table (32 feet), however, does not achieve
a measurable reduction in risk due to direct contact exposure because there is no plausible
expectation that subsurface work would occur below the 8-foot level. Therefore, the additional
costs for the 32-foot excavation is not justified since land use restrictions preventing
subsurface work would provide adequate protection in these circumstances. The selection of
incineration over off-site disposal is based upon the statutory preference fot treatment and
permanent solutions.

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? '

Technical considerations were not primary in selecting a remedial alternative.
t;_-

I|, Hi
1240
-6-
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Bangor Ordnance Disposal
Naval Submarine Base
QU-1

Bangor, Washington
Region 10
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
N/A
7/22/87
12/18/89
12/10/91
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? -

Maximum concentrations of principal
contaminants were:

Soil (rag/kg)

2,4,6-Trinitrotoluene (TNT) 300
Dinitrotoluene (DNT) 20
Hexahydro-l,3,5-trinitro-
1,3,5-triazine (RDX) 1.3
Lead 2,400
2. .What volume of material is to be
remediated?
The volume of material to be remediated included:
7,100 cubic yards of soil
What type of site is this?
'! '
, - - - - . -t v
- ' - - " . I --.'•/
Military. A former explosive ordnance detonation and disposal site located in a rural and
lightly residential area. The site includes a burn area that was used to detonate and incinerate
various ordnance materials and two debris areas where inert solid wasite nnaterial from the burn
area was deposited. i
Background

Federal Facility
PRPs: U.S.Navy'|
FS prepared by: Hartcrowser Earth
. and Environmental
Technologies .
TECHNOLOGY SELECTION ,

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
' technologies were:
i
Access restriction: Fencing, warning signs, deed restrictions, zoning changes,
fishing/hunting restrictions, health and safety (equipment
-1-
1241
-------
Containment:
Chemical treatment:
Physical treatment:
Thermal treatment:
Disposal:
Capping (revegetation, synthetic membrane, clay, asphalt, asphalt
concrete, portland cement, multimedia), dust control, liner (synthetic
membrane, clay, multimedia, grout injection)
Sorbent stabilization, surfactant stabilization, solidification
Sieving/screening
Incineration (rotary kiln, infrared) •
Excavation, off-site landfill (RCRA, solid waste, demolition debris)
>
•~»S"
5. Was an innovative technology considered in the FS? If so, which technology?
\ .

Innovative technologies considered during the identification and screening of technically
feasible technologies were: - . . ,
* *.=
Biological treatment: Composting, in situ biodegradation, slurry phase treatment,
landfarming
Chemical treatment: In situ vitrification, stabilization
Physical treatment: Soil washing, in situ soil washing, in situ vacuum extraction, leach
basin (introduced in an RAA)
Thermal treatment: In situ vitrification, molten salts, pyrolysis
6. What was the cost estimate for the innovative technology?
' / \
During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, estimated costs were calculated during an evaluation based on nine
criteria established by the NCP. The bum area soil and the debris area soil were incorporated
into sitewide alternatives for the detailed analyses and in the Proposed Plan and ROD;
therefore, they are presented separately...
Burn Area
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-1
RAA-2
RAA-3
RAA-5
RAA-6
RAA-7
Innovative Technology
Soil washing/natural photolysis
Soil washing/UV oxidation
Soil washing/carbon adsorption
Leach basin/natural photolysis
Leach basin/UV oxidation
Leach basin/carbon absorption
Estimated Costs
3 Criteria
N/A
N/A
N/A1
N/A
N/A
N/A
9 Criteria
eliminated
eliminated
eliminated
—
, ' —
— •
1242
-2-
-------
Debris Area: No innovative technologies were"developed for debris area soil.
' ' , • ,' . • !' .
Sitewide for Detailed Analyses j
Alternative
RAA-5
RAA-6
RAA-7
Innovative Technology
Leach basin/natural photolysis/off-site disposal of
debris area soil
Leach basin/UV oxidation/of f-site disposal of
debris area soil -. ^ ..
Leach basin/carbon adsorption/off-site disposal of
debris area soil ,
Estimated Costs
9 Criteria
$918,000
$1,428,000
'.-*' N/A
Sitewide Alternatives for the Proposed Plan and ROD
Alternative
No number
Innovative Technology
Soil washing in a leach basin/natural photolysis
or UV oxidation or carbon adsorption/off-site
disposal of debris area soU
Estimated Costs
PP & ROD
$890,000"
This cost estimate does not include treatment costs since .the treatment methods will address
both soil and ground water remediation. If ground water remediation is not conducted the cost
of this alternative might range from $1.2 million to $1.6 million. | ,
7. How did'the cost(s) compare to standard technologies? [

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold) \
Burn Area v i
Alternative
RAA-4
RAA-8 ,
RAA-9
RAA-10
RAA-11
RAA-12
Standard Technology
Incineration
Limited action
Synthetic membrane cover
Off-site disposal
Solidification • • ,
No action
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
N/A
N/A '
9 Criteria
eliminated
—
• —
eliminated
' • — •
•' • . —
-3-
1243
-------
Debris Area
Alternative*
RAA-1
RAA-2
RAA-3
Standard Technology
Off-site disposal in RCRA landfill ,
Off-site disposal in solid waste landfill
No action
Estimated Costs
3 Criteria
N/A
N/A
N/A
Sitewide for the Detailed Analyses, the Proposed Plan, and ROD
Alternative
RAA-8
RAA-9
RAA-1 1
RAA-12
Standard Technology
Limited action
Cover
Solidification
No action
Estimated Costs
9 Criteria
$497,000
$671,000
$866,000
N/A
ROD
& PP
$800,000
$1,530,000
$1,850,000
$670,000
8. If a standard technology was chosen, why?

Off-site disposal was selected for debris-area soil.
9. If an innovative technology was chosen, why?

Soil washing in a leach basin was selected because it is protective of human health and the
environment-through the extraction and treatment of contaminants in soil and ground water. It
reduces site risk due to direct contact, inhalation, or ingestibn of soil and removes the potential
threat of ground water contamination. The contaminants will be permanently removed from
the soil. Laboratory test have shown that water is effective at irreversibly leaching at least 95
percent of TNT from soil. Treatment of collected water with UV oxidation will reduce
toxicity by destroying over 99.99 percent of contaminants in water. It provides long-term
effectiveness and permanence since it reduces contaminant toxicity, mobility, and volume.
The soil washing alternative provides the most reliable long-term performance because it uses
treatment to reduce risk permanently from site contaminants. No long-term maintenance is
required. This alternative complies with all ARARs. The selected alternative is cost-effective
because its effectiveness is proportional to its costs. The selected remedy is comparable in cost
to many other alternatives; however, it uses an innovative technology, results in the on-site
destruction of contaminants, and recharges the extracted and treated ground water to replenish
ground water supplies. It can be implemented in a short time. Soil washing will contain
contaminated soil within about 3 months and the treatment will be completed within about 1
year. Short-term risk to the community is negligible because the site is located on a high
security facility. The risk to on-site workers during implementation can be eliminated by
standard control and monitoring activities.
1244
-4.
-------
The alternative utilizes soil treatment technologies with a sound, theoretical base and ;
demonstrated laboratory performance. The soil treatment system is innovative since it has
rarely been used in full-scale operations and unforeseen operational problems might occur that
require system modifications. Soil materials can be obtained from on-site or nearby sources.
Other materials such as synthetic membrane can be obtained from suppliers in the state.

- •' ' , ' i
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

• In situ vitrification as a solidification technique was eliminated because it would not
be feasible for organic contaminants. :
• Molten salts were eliminated because it would not be feasible for materials with high
ash content. , '\/~ .
B Pyrolysis was eliminated because it would not be applicable to compounds containing
nitrogen. i -
• In situ biodegradation was eliminated because it would not be feasible given the low
permeability of the near-surface soils.
• In situ soil washing was eliminated because it would not be feasible given the low
, permeability of the near-surface soils. ."('"'
• In situ vacuum extraction was eliminated because it would not l>e feasible given the
low permeability of the near-surface soils. i ,

Innovative technologies eliminated during the screening of the three criteria of technologies
include the following: j .

• In situ vitrification as a thermal technology was eliminated because a commercial
facility is not yet available, its effectiveness is unproven, and it would have high costs.
• Composting was eliminated because it has not been proved, breakdown products might
be toxic, it might require many years to implement, and it is expensive.
B Slurry phase treatment was eliminated because it has not been proved, breakdown '-.
products might be toxic, and it is expensive. j -.
• Landfarming was eliminated because it has notbeen proved and breakdown products
might be toxic. . k

Innovative technologies eliminated during the screening of the three criteria of RAAs include
the following:

" Soil washing was eliminated because of the questionable reliability of the washing
process together with the high cost.
-5-
1245
-------
Innovative technologies eliminated during the detailed analysis include the following:

• None
11.
* *. . .
Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

The criterion that were most heavily weighted in selecting a remedial alternative was long-term
effectiveness and permanence. The chosen RAA provides the greatest long-term protection to
human health and the. environment since it permanently reduces site contaminants. Other
alternatives that proposed capping or institutional controls were not preferred because they
would require maintenance or compliance to be effective in the long term. Further, the
elimination of site contaminants permanently through soil washing was preferred over the
immobilization of contaminants through stabilization.
12.
13.
What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis
Carcinogens
.TNT
DNT
RDX
Lead
33
1.5
9.1
2,500
MTCAa
MTCA
MTCA
MTCA
"Washington State Model Toxics Control Act, which utilized risk-based criteria and
applicable state and federal laws to derive site-specific cleanup levels.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup-goals?

Innovative technologies eliminated because of cleanup goals include:

• None ,

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?
Treatability studies were not conducted. '

1246
-6-
"V T
-------
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Preference for treatment (vs. containment) |
- Waste left in place/institutional control } ,

i
16. How are measures compared?
- - - • - . x • i -.
The selected alternative was preferred because the treatment it will permanently reduce site
contaminants. This was preferred over containment since containment would require long-term
maintenance to ensure protection. Further, treatment was preferred over institutional controls
that would require compliance and cannot address ecological risk. ; .
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ' ,
' ' , -.'" i" '",'.''.
No technical considerations were primary in selecting a remedial alternative. In situ
biodegradation and in situ soil washing, however, were eliminated in the initial analysis
because they would not be feasible given the low permeability of the near-surface soils.
-7- 1247
-------
Bunker Hill Mining and Metallurgical
OU-1

Shoshone County, Idaho
Region 10
GENERAL SITE INFORMATION
1.
2.
What'were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
SoU (rag/kg)

Lead
Arsenic
17,800
267
What volume of material is to be
remediated?

The volume of material to be remediated
included:
Site History

NPL Proposed: N/A '
NPL Final: 9/83
FS: 4/91
ROD: 8/91

Background

EPA Fund-lead
PRPs: Gulf Resources and Chemical
Corporation ,
FS prepared by: CH2M Hill
640,000 cubic yards of soils (for the selected alternative, which includes removing the
top one foot of contaminated soils).
3. What type of site is this?

Mining. An inactive mining and smelting facility located in a residential area.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?
i
Standard technologies considered during the identification and screening of technically feasible
technologies were: .
Access restriction:

Containment:
Deed notices, fences, sod/grass requirements, excavation regulations,
health intervention program , .
Capping (soil, clay, synthetic membrane, sprayed asphalt, concrete,
multilayer, chemical sealants), horizontal barriers, surface controls, dust
suppression
Chemical treatment: Stabilization/solidification, pH adjustments
Physical treatment: Deep tilling ,
1248
-1-
-------
Disposal:
Debris removal, .excavation, sod removal, solids processing, waste
storage, deep mine disposal, waste repository I
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification arid screening of technically
feasible technologies were: !
1
Chemical treatment: Ex situ soil washing, in situ soil leaching i
Thermal treatment: In situ vitrification !
i
6. What was the cost estimate for the innovative technology?

The chosen alternative, RAA-3, was preferred because it provides protection to human health
through the elimination of lead-contaminated soil in residential areas. Lead absorption by
small children is the most significant health risk posed by the site. In order to reduce lead
exposures, the selected remedy will replace lead-contaminated soil with clean fill. Modeling
scenarios estimate that the established soil cleanup level will result in a site wide mean blood
lead level of 2.7 to 3.9 ug/dL. In the ROD, excavation was extended to 24 inches in areas
where produce gardening will occur thereby reducing the exposure associated with the
consumption of garden produce. Household dust also has been identified as a significant lead
exposure pathway. In residential areas, the installation of a soil and sod barrier over the clean
fill will help reduce direct exposure to contaminated soil and the generation of contaminated
dust. This alternative will provide a degree of permanence because it will remove surficial
layers of contaminants. The layer of clean fill that is added prior to the sod also improves the
long-term effectiveness. The remedy will be effective in the long-term as long as institutional
and maintenance controls are upheld. Continued blood lead monitoring and residential soil
monitoring will measure the success of the selected remedy. This alternative can be
completed in 4 to 6 years. It will minimize short-term risk because only the top 12 inches of
soil will be excavated unless it is a garden area where excavation will be to a depth of 24
inches. This alternative will employ well-developed, reliable technologies that are technically
feasible and require moderate effort. The chosen alternative is cost-effective.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
1250
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? ,!'
• , • , - • . i • ' - - •
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following;

• Ex situ soil washing was eliminated because it has not been proved effective for
relatively low concentrations of inorganics. i
• In situ vitrification was eliminated because it would be aesthetically unacceptable, it is
still in research stages, its implementability is uncertain, and strong negative public
reaction would be expected as treatment takes place and land use is restricted.
• In situ soil leaching (soil flushing) was eliminated because reseiarch is currently lacking
and its ultimate effectiveness would be uncertain, implementability has not been
. proved, arid strong negative public reaction would be expected as treatment takes place
• and land use is restricted. _

Innovative technologies eliminated during the screening of the three criteria include the
following: ..-:'

- ' • « ". None ' ' - •' / "••' 'i '

Innovative technologies eliminated during the detailed analysis include the following:

" •• ••- . None' ' •" --••-. .'•.'.- ' ' •''.•: \' ;
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
. ':.."!•

The criteria that were weighted most heavily in selecting a remedial technology were long-
term effectiveness and cost-effectiveness. Long-term effectiveness was the primary reason for
selecting RAA-3 over RAA-5. Twelve inches of soil and sod provide a much more permanent
barrier to potential exposure than a simple sod barrier. Further, while an in situ soil treatment,
such as solidification proposed in RAA-8, would have been optimal, solidification would not
be appropriate for use within a residential yard and no other in situ technologies are known to
be effective in removing metals from soil. Cost-effectiveness was the main reason for
eliminating both RAA-6 and RAA-8. Both of these alternatives would provide only marginal
increases in benefit over the chosen alternative but would cost much more. In situ vitrification
and smelting were eliminated because they would be too expensive. !
1251
-------
12. What cleanup goals were selected? If the cleanup goal was based on anARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (rag/kg)
ARAR or Other Basis
Carcinogens
Lead
1,000
Health"
The cleanup level for lead is intended to decrease the exposure of lead-contaminated
residential soils such that 95 percent or more of children in the area have blood lead
levels below 10 ng/dL and that less than 1 percent have blood lead levels greater than
15 ug/dL.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

" None

Standard technologies eliminated because of cleanup goals include:.

• None •

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.

75. What measures/criteria were used to compare alternatives? -

The following measures were used to compare the alternatives:

Cost-effectiveness . '
Time to design/construct/operate
Impact on nearby populations , .
16. How are measures compared?

The principal difference between the chosen alternative and two other alternatives is
excavation depth. RAA-5 proposes sod excavation and replacement and though it would be
less expensive, it was eliminated because it would not be protective in the long-term. RAA-6
proposed excavating 7 feet, but it was eliminated because it was considered excessive,
providing only marginal benefit but at a substantially higher cost. RAA-8 proposed excavating
12 inches followed by stabilization, thereby immobilizing contaminants. Because contaminants
would be adequately immobilized when disposed of in a properly contoured landfill, as is
proposed in the chosen alternative, RAA-8 was determined to be excessive and not cost-
1252
o
-------
effective. The chosen alternative also was preferred over RAA-6 andjRAA-8 because it
requires less time to implement. , ,

Impact on nearby populations also was considered in selecting a remedial alternative. OU-1
encompasses the populated residential areas. Both in situ vitrification and stabilization were
eliminated because they would not be appropriate for residential areas!. Further, excavation
depth was carefully evaluated because of the close proximity of peoplle to the contaminated
soil. And the final remedy presented in the ROD was amended from the proposed plan to
extend excavation depths in garden areas to 24 inches.
17. What technical considerations were factors in selecting a remedy? W}ere technical
considerations primary in the selection of the remedy? • • j

No technical considerations were primary in selecting a,remedial altematjve.
1253
-6-
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Bunker Hill Miming and Metallurgical
OU-2
Shoshone County, Idaho
Region 10
GENERAL SITE INFORMATION
L
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)

Arsenic
Cadmium
Lead
Zinc
Carbonate
Sulfate
Sulfur-Total
PCBs
160,000
127,000
860,000
754,000
6,190
405,000
164,000
218
2. What volume of material is to be
remediated?

The volume of-material to be remediated
included:

• 18,000,000 cubic yards of tailings
3. What type of site is this?
Site History
NPL Proposed:
NPL Final:
FS:
ROD:

Background
N/A
9/83
5/1/92
9/22/92
PRP-lead
PRPs: Asarco Inc., Callahan Mining
Co., Coeur d'Alene Mines Corp.,
Hecla Mining Co., Stauffer
Management Co., Sunshine
Mining Co., Sunshine Precious
Metals Co., Union Pacific
Railroad, Gulf USA Corp.,
Pintlar Corp., Bunker Hill Mining
Co. (U.S.) Inc., BH Properties,
Inc., Syringa Minerals Corp.,
Highland Surprise Consolidated-
Mining Co., Silver Bowl, Inc.
FS prepared by: McCulley, Frick .&•'
Oilman, Inc. :
Mining. An inactive mining and smelting facility .located in a residential area. The site
encompasses a 21-square-mile area. The ROD addresses contaminated nonpopulated areas of
the site and those aspects of the populated areas not covered in the residential soil ROD
(August 30, 1991). Five areas of the site have source contamination: Hillsides, Smelterville
Flats, Central Impoundment Area (CIA), Smelter. Complex, and Mine Operations Area (MOA),
1254
-i-
-------
TECHNOLOGY SELECTION I

4. What standard technologies were considered for selection in this FS? \
' ' - ' ' ' \ ' ' ' • ' '
Standard technologies considered during the identification and screenmg of technically feasible
technologies were: . v . •
Access restriction:

Containment:
Deed notices,.legal restrictions of access and cm hind use, fencing or
other barriers i
Revegetation, capping (soil, sawdust or rock barriers, soil/clay cover,
geosynthetic, asphaltic or geotextile systems) dust control (surface
armoring, polymeric/chemical surface sealers,'neutral or artificial wind
breaks), general decontamination, surface runoff/erosion controls,
(detention/sedimentation basins, retaining walls, revegetationj,
impoundment liner, systems J
Chemical treatment: Stabilization/fixation (grout injection, polymeric/chemical surface
Thermal treatment:
Disposal:
sealers)
Incineration (infrared, fluidized bed) !
Excavation and removal, on-site/off-site disposal
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screenling of technically
feasible technologies were: , . .
' \"-
Phys/Chem treatment: In situ leaching for metals extraction, chemical extraction
Thermal treatment: In situ vitrification, on-site/off-site reprocessinjj/reuse
1 (hydrometallurgical reprocessing, pyrometallurgical reprocessing)
What was the cost estimate for the innovative technology?

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs. Aifter the RAAs have been
formulated, costs are estimated as part of a three-criteria screening process (effectiveness,
implementability, and cost) to identify alternatives that merit a more detailed evaluation. The
estimated costs then are recalculated during an evaluation based on nine criteria established by
the NCP. Innovative technologies were not incorporated into RAAs.
7, How did the cost(s) compare to standard technologies?

-2-
1255
-------
Alternative
RAA-2
RAA-3
RAA-4
Standard Technology
Source and institutional controls
Source controls (in-place caps and
institutional controls/treatment .
(materials will be reprocessed,*
recycled, or treated via cement-based
stabilization)/umovative treatment of
ground water and surface water
(wetland treatment)
Removal (disposal in engineered reposi-
tories)/source control (conventional
engineering and institutional controls)/
treatment of ground water and surface
water
Estimated Costs
3 Criteria1
N/A
N/A
N/A
9 Criteria
$31,549,000
$52,035,000"
$120,291,000
'Under this alternative, some of the higher concentration-wastes might be sold as recycled
materials or shipped off site for reprocessing. The method of reprocessing was not specified
in the FS or the ROD. J -
'The total present worth (5 percent discount rate) for the selected remedy also was estimated in
the ROD at $47,049,000. ,
8. If a standard technology was chosen, why? . ,

RAA-3 was selected because actions specified under this alternative are expected to have
significant water quality benefits, limit direct exposure to the most contaminated soils on site,
and re-establish vegetative cover over the exposed areas of the site. This alternative, therefore,
will reduce and/or eliminate the mobilization of soil/source materials. The principal difference
between the selected remedy and the other alternatives is the amount of treatment involved in
RAA-3. The other alternatives call for source containment that provides a less effective means
. of protecting human health and the environment since no water treatment is included as is the
case for RAA-3. RAA-3 removes, controls, or treats significant contaminant sources and
effectively addresses site-wide Remedial Action Objectives. The toxicity, volume, and
mobility of source materials available for transport is effectively reduced. RAA-3 addresses
human health and environmental concerns without significant threats to Workers and the
community and is considered effective in the short term. RAA-3 also is readily implementable
using standard construction/remediation techniques. Additionally, RAA-3 focuses on ,
reprocessing/recycling or treatment of the principal threat materials from the Smelter Complex,
therefore, RAA-3 goes further toward satisfying the statutory preference for reduction of
toxicity. Finally, this alternative will meet ARARs dealing with soil/source materials.
Relevant and appropriate requirements of RCRA Land Disposal Restrictions (LDRs) for
cement-based stabilization or principal threat waste are expected to be obtained.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
-3-
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? I

Innovative technologies could be eliminated from the remedial technoloigy selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include Ihe following:

a Chemical reduction was eliminated because'it would not be applicable for inorganic
metals. This technology has not been utilized successfully for removing metals or
treating soils (U.S. EPA, 1988); chemical extraction has been used primarily for
. treating sludges contaminated with hydrocarbons.
• In situ vitrification was eliminated because it would not be applicable to the site given
the presence of ground water and variable soil conditions at this site. In addition, this
technology is considered impractical when applied over large areas because of the
heterogeneity of the mass to be vitrified, maintenance of procesis control over large
areas, and the presence of shallow ground water (U.S. EPA, 1985).
• Pyrometallurgical reprocessing was eliminated during the initial screening stage for
tailings in the Smelterville Flats and the CIA because it would not be feasible with
low-concentration wastes and would be applied more appropriately to higher
concentration materials. !
* • , ' .".-_' , -
Innovative technologies eliminated during the screening of the three criteria include the
following: , .1
•'. . ' • , - I
• In situ leaching for metals was eliminated based on its anticipated lack of
effectiveness, problematic implementation, and/or high costs relative to other equally
effective options. The history of using this technique for uranium recovery suggests
that aquifer protection and restoration could be long-term problems due to the
potentially hazardous nature of the solvents used. Treatability studies conducted by
the University of Idaho using site samples showed that a strong oxidant is required to
dissolve the amounts of metals at the site, and acceptable metajis extraction occurred
only under extreme acidic conditions. The recovered leach solution would produce a
waste sludge that probably would be contaminated with the metals of concern and
would require treatment and disposal. i .
• , Hydrometallurgical reprocessing was eliminated because metals' mobility in the
processed tailings would increase substantially because of grinding and classification
during processing. Additionally, neither suitable milling or refiming facilities are
currently available to handle site materials nor is a suitable disposal site available for
• subsequently produced materials. This process also would, have a Mgh capital cost.
Innovative technologies eliminated during the detailed analysis include

• None
the following:
-4-
1257
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so, j
which criterion? Which of the criteria supported the use of a standard technology? '

Protection of human health and the environment, long-term effectiveness, and cost were
weighted most heavily in selecting RAA-3.' By combining containment, treatment, and , '
institutional controls, RAA-3 addresses all on-site pathways and is protective of human health
and the environment. In addition, it effectively improves downstream water quality. This
alternative provides a high level of protectiveness, minimizes exposure pathways identified for
soils and source material, and obtains site-wide soil RAOs for human health protection. The
overall long-term effectiveness of RAA-3 is expected to be high based on the degree to which 1
it addresses site-wide RAOs and the reliability and permanence of the prescribed controls. ,
RAA-3 provides enhanced long-term effectiveness relative to the other alternatives through .!
treatment of principal threat wastes. Long-term effectiveness was the primary reason for '
selecting RAA-3 over,RAA-2. The treatment included in the selected remedy provides more '
permanent controls. Finally, the cost of removal in RAA-4 was too high compared to RAA-3,
considering the associated incremental improvement in performance.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Cleanup goals were not established. . •

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
teclmology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None .. ' '....'' ','.,'•''

Standard technologies eliminated because of cleanup goals include:

» None . '

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted by the University of Idaho on the potential use of in situ
leaching for metals recovery at the site. Based on the results, this technology was eliminated
from consideration.

Treatability tests for cement-based solidification of one of the major principal threat material
accumulations on site (copper dross flue dust moved to the Smelter Complex) indicated that
attainment of percent reduction goals based upon TCLP protocols is likely under RAA-3. Due
to the varying solubilities of contaminants of concern through a range of pH values, EPA has
determined that the acid leaching aspects of the TCLP test protocol are not appropriate for
wastes consolidated in the smelter closure, and elected to design a stabilization mixture that
will achieve LDR treatment goals at a pH reflective of actual on-site conditions. A rainwater
leach test has been determined to be more appropriate than an acid leach test.

1258 .
-------
11. Which of the nine criteria were weighted most heavily in selecting the technology? Didfailu
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?

Protection of human health and the environment, long-term effectiveness, and cost were
weighted most heavily in selecting RAA-3. By combining containment, treatment, and
institutional controls, RAA-3 addresses all on-site pathways and is protective of human healtf
and the environment. In addition, it effectively improves downstream water quality. This
alternative provides a high level of pSrotectiveness, minimizes exposure pathways identified fo
soils and source material, and obtains site-wide soil RAOs for. human health protection. The
overall long-term effectiveness of RAA-3 is expected to be high based on the degree to whicl
it addresses site-wide RAOs and the reliability and [permanence of the prescribed controls.
RAA-3 provides enhanced long-term effectiveness relative to the other alternatives through
treatment of principal threat wastes. Long-term effectiveness was the primary reason for
selecting RAA-3 over RAA-2. The treatment included in the selected remedy provides more
permanent controls. Finally, the cost of removal in! RAA-4 was too high compared to RAA-;
considering the associated incremental improvement in performance.

12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was thi
ARAR? What risk level was selected to establish cleanup goals?
• i •' '
Cleanup goals were not established. '
1

13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? !
. ' • ' i ' • " •
Innovative technologies eliminated because of cleanup goals include:
' i .
i ' •
• None .

Standard technologies eliminated because of cleanup goals include:

• None
14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were conducted by the. University of Idaho on the potential use of in situ
leaching for metals recovery at the site. Based on tlhe results, this technology was eliminated
from consideration. .•].-.'

Treatability tests for cement-based solidification of one of the major principal threat material
accumulations on site (copper dross flue dust moved to the Smelter Complex) indicated that
attainment of percent reduction goals based upon TCLP protocols is likely under RAA-3.
tonhe varying solubilities of contaminants of concern through a range of pH values, EPA n
determined that the acid .leaching aspects of the TCI.P test protocol are not appropriate for
wastes consolidated in the smelter closure, and elected to design a stabilization mixture that
will achieve LDR treatment goals at a pH reflective !of zictual on-site conditions. A rainwater
leach test has been determined to be more appropriate than an acid leach test.

1258 ' • .'• " . ; j.-::: • " " .' '-
. ' • • . -5- ... --. •',. • • . '
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Chemical reduction was eliminated because it would not be applicable for inorganic
metals. This technology has not been utilized successfully for removing metals or
treating soils (U.S. EPA, 1988); chemical extraction has been used primarily for
. treating sludges contaminated with hydrocarbons.
• In situ vitrification was eliminated because it would not be applicable to the site given
the presence of ground water and variable soil conditions at this site. In addition, .this
technology is considered impractical when applied over large areas because of the
heterogeneity of the mass to be vitrified, maintenance of process control over large
areas, and the presence of shallow ground water (U.S. EPA, 1985).
• Pyrometallurgical reprocessing was eliminated during the initial screening stage for
-tailings in the Smelterville Flats and the CIA because it would not be feasible with
low-concentration wastes and would be applied more appropriately to higher
concentration materials.

Innovative technologies eliminated during the screening of the three criteria include the
following:

• In situ leaching for metals was. eliminated based on its anticipated lack of
' effectiveness, problematic implementation, and/or high costs relative to other equally
effective options. The history df using this technique for uranium recovery suggests
that aquifer protection and restoration could be long-term problems due to the
potentially hazardous nature of the solvents used. Treatability studies conducted by
the University of Idaho using site samples showed that a strong oxidant is required to
dissolve the amounts of metals at the site, and acceptable metals extraction occurred
only under extreme acidic conditions. The recovered leach solution would produce a
waste sludge that probably would be contaminated with the metals of concern and
would require treatment and disposal.
• Hydrometallurgical reprocessing was eliminated because metals' mobility in the
processed tailings would increase substantially because of grinding and classification
during processing. Additionally, neither suitable milling or refining facilities are
currently available to handle site materials nor is a suitable disposal site available for
subsequently produced materials. This process also would have a high capital cost.

Innovative technologies eliminated during the detailed analysis include the following:

• None ' '
1257
-4-
-------

75. What measures/criteria were used to compare alternatives? 'i
• • . . ' " • . • ' • i •" ' '-'.'•-
The following measures were used to compare the alternatives: j

- Cost-effectiveness i
Total cost 1 ,
Preference for treatment (versus containment) •. ', , .

. . • • ~ _""'". ~ ~ , '',.'' r '
16. How are measures compared? ;

The selected alternative RAA-3, while significantly lower in cost than RAA-4, provides
comparable net protection due to innovative surface and ground water treiltmeht methods ;and
the use of reprocessing/recycling technologies. Although RAA-4 would remove more
contaminated materials for consolidation on site, the associated cost of $120.3 million was
substantially higher than the cost of the selected remedy; the added effectiveness would be
marginal with respect to the additional cost. RAA-3 therefore was determined to be more
cost-effective. Because RAA-3 proposes treatment of principal threat!! in soils and source
materials, it satisfies the statutory preference for treatment of hazardous wastes.
• ' • '. - i ,. - '. t • •
' • - -""*,. i- •

17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? | .

Technical considerations were not primary in selecting a remedial alternative.

References: i

U.S. EPA. 1985. U.S. Environmental Protection Agency. Remedial iaction at waste disposal
sites (revised). EPA/625/6-85/006. , ],

U.S. EPA. 1988. U.S. Erivironmental Protection Agency. Technology screening guide for
treatment of CERCLA soils and sludges. EPA/540/2-8/004.
6 1259
-------
Joseph Forest Products

Wallowa County, Oregon
Region 10
GENERAL SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Surface Soil (mg/kg)
Arsenic
Chromium
Copper
26,120
11,300
22,200
Subsurface Soil (mg/kg)
Arsenic
Chromium
Copper
104,000
46,100
34,400
Site History

NPL Proposed: 6/88
NPL Final: 3/89
FS: 7/92
ROD: 9/92

Background

EPA Fund-lead
PRPs: Joseph Forest Products and the
Estate of Clifford Hinkley
FS prepared by: ICF Technology, Inc.
2. What volume of material is to be remediated?

The volume of material to be remediated included:

» 2,796 cubic yards of soil
5. What type of site is this? '. .

Lumber and Wood Products. A former wood treatment facility located outside the City of
Joseph in a rural area. ' .
TECHNOLOGY SELECTION , .

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: ,

Access restriction: Fencing, deed restrictions „
Containment: Capping (clay, synthetic membrane), slurry wall, grout curtain, sheet
piling, bottom sealing
1260
-1-
-------
Chemical treatment: Solidification, fixation, precipitation, chelation'-soiption, ion exchange
Thermal treatment: Incineration •'!''•
Disposal: Excavation, disposal (on site, off site)- j
Was an innovative technology considered in the FS? If so, which teciinology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: < '' | .

Biological treatment: Biological treatment (in situ, ex situ) !
Phys/Chem treatment: Oxidation, reduction, soil washing, solvent extraction, air stripping,
" electrokinetics < • . j
Thermal treatment: Vitrification .'•'., \
6". . What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-5
Innovative Technology
Excavation to background/soil
washing/on-site disposal
Estimated Costs
3 Criteria
N/A
9 Criteria*
N/A
'Net present worth costs were not calculated. Only cpsts for total capital zmd O&M were
7 How did the cost(s) compare to standard technologies? [

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
•- ' - '
Alternative
RAA-1
RAA-2
Standard Technology
No action
Excavation to background/off-site
disposal
• , • . • •:
Estimated Costs
3 Criteria
N/
N/
A
A
9 Criteria*
N/A
N/A

-2-
1261
-------
Alternative
RAA-3
RAA-4
RAA-6
Standard Technology
Excavation to background/fixation/ oh-
site disposal
Excavation of surface soil to 10"5
cleanup level and subsurface soil to
W* cleanup level/off-site disposal
Excavation of all soil to 10"4 cleanup
level/off-site disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A
9 Criteria*
N/A
N/A ,
N/A
"Net present worth costs were not calculated. Only costs for total capital and O&M were .
given. . .
8. If a standard technology was chosen, why?

RAA-4 was selected because it provides long-term protection to human health and the
environment by removing the contaminated soil, thereby eliminating it as a potential source of
ground water contamination. These measures also eliminate exposures via inhalation and
ingestion of contaminated soil particles, dermal contact with contaminated soil, and ingestion
of contaminated ground water. No unacceptable short-term risk or cross-media impacts will be
caused by implementation of the remedy. Exposure during soil excavation will be eliminated
through the use of air monitoring, proper dust control during implementation, and by
implementing a strict site-specific health and safety plan. It complies with all ARARs. The
selected remedy provides a permanent solution with a proven technology. It poses minimal
uncertainty and long or short-term risk. The selected remedy was more reliable, cost-effective,
and could be implemented with less difficulty than other alternatives.
9. If an innovative technology was chosen, why?

An innovative technology was not selected.
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies could be eliminated from the remedial technology selection process at •
three stages: during the initial screening; during the screening of the three criteria of
effectiveness,- implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:

• Solvent extraction was eliminated because it would not be applicable to metals.
• Air stripping was eliminated because it would not be applicable to metals.,
• Biological treatment (in situ, ex situ) was eliminated because it would not be
applicable to metals.
1262
-3-
-------
1 ' •
Innovative technologies eliminated during the screening of the three criteria include the
following:
• Electrokinetics was eliminated because it might not be effective given the coarse low
moisture content soil found at the site. i
• Vitrification was identified as a technology to be considered for remedial alternatives;
however, it was never incorporated into an RAA and no explanation was given.
• Oxidation was identified as a technology to be considered for jrenitedial alternatives; .
however, it was never incorporated into an RAA and no explanation was given. It was
noted that it would only be feasible for the treatment of arsenic.
• Reduction was identified as a technology to be considered for remedial alternatives; '
however, it was never incorporated into an RAA and no explanation was given. It was
noted that it would only be feasible for the treatment of chromium.
' " I
I- .
Innovative technologies eliminated during the detailed analysis includes the following:
• ' - - ' i' : ' ,-''•'-..
• Soil washing was eliminated because it is an unproven technology and offers less
certain long-term effectiveness than other alternatives. Furthermore, it would be the
least implementable since it would require treatability tests. The long-term
effectiveness of this alternative also would depend on more ccjntrols than the other
options since it involves on-site disposal and relies on the* use of treatment
technologies to separate contaminants for off-site disposal. Sciil washing was expected
to pose greater short-term risk given the potential for contaminant release during
washing. Finally soil washing would be costly.

11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
*. t • • • ' .. "'h • _ ,. =. . -
Protection of human health and the environment, long-term effectiveness and permanence, and
cost were the criteria weighted most .heavily in selecting a remedial alternative. The selected
alternative will be protective since health-based cleanup levels estimated for residential use
will be attained. This option also was preferred because it uses a proven technology-and its
long-term effectiveness is certain. This option will attain cleanup levels at the lowest cost.
1 - • . -' ' i '•.••'•
Soil washing, an innovative technology was eliminated because it is costly and its
effectiveness is uncertain, as it is an, unproven technology.
72.
Whatch
ARAR?
mnup goals were selected? If the cleanup goal was based on
What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
Surface Soil/
Subsurface Soil
ARAR
Carcinogens .
Arsenic
Chromium
36/336 V
1,135/1,135

an ARAR, what was that
or Other Basis

Risk8
Risk

-4-
1263
-------
Contaminant
Cleanup Level (mg/kg)
Surface Soil/
Subsurface Soil
ARAR or Other Basis
Noncarcinogens
Copper
10,000/10,000
Risk
*For carcinogens, an excess upper bound individual lifetime cancer risk of between 10"4
to 10"6 was acceptable. For noncarcinogens, a Hazard Index less than or equal to 1.0-
was acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

« None

Standard technologies eliminated because of cleanup goals include:

• None. . . • - .

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
75. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved '
Cost-effectiveness
Proven reliability
16. How are measures compared? <

The selected alternative was chosen because, except for RAA-2, it provides the greatest
reduction in risk. RAA-5 was eliminated because it utilizes an unproven technology and offers,
less certain long-term effectiveness than other alternatives. Furthermore, it would be the least
implementable since it would require treatability tests. The long-term effectiveness of this
alternative also would depend on more controls than the other options since it involves on-site
disposal and relies on the use of treatment technologies to separate contaminants for off-site
disposal. Soil washing was expected to pose greater short-term risk given the potential for
contaminant release during washing. Finally, soil washing would be costly.
1264
-5-
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy?
Technical considerations were not primary in selecting a remedial alternative
and chelation-sorptibn, however, were eliminated because they woqld
soil type found at the site. ,
. Electrokinetics
not be effective in the
-6-
1265
-------
Umatilla Army Depot
OU-1

Hermiston, Oregon
Region 10
GENERAL SITE INFORMATION
1.
2.
Wliat were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:
Soil (mg/kg)
87
0.66
2,4,6-Trinitrotoluene
Hexahydro-l,3,5-trinitro
-1,3,5-triazine (RDX)
Octahydro-l,3,57,-tetranitro-
1,3,5,7-tetrazocine (HMX) 0.1
1,3,5-Trinitrobenzene 0.047
2,4-Dinitrotoluene (2,4-DNT) 0.016
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
10/15/84
7/22/87
4/92
9/92
Background

Federal Facility - !
PRPs: U.S. Army
FS prepared by: CH2M Hill and
Morrison Knudsen
Environmental Services
"What volume of material is to be remediated?

The volume of material to be remediated included:

» 30,000 cubic yards of soil • -
What type of site is this? ' v

Military. An active U.S. Army munitions storage facility that previously functioned in
ammunitions demolition, renovation, and maintenance. It is located in an agricultural/rural
area. , • ' ,
TECHNOLOGY SELECTION
• .. '•

4. What standard technologies were considered for selection in this FS? ,

Standard technologies considered during the identification and screening of technically feasible
technologies were:

Access restriction: Fencing, warning signs, deed restrictions
Containment: Capping (soil, revegejation, single-layer, multilayer), surface controls
Chemical treatment: Solidification/stabilization
,}
1266
-i-
-------
Physical treatment:
Thermal treatment:
Disposal:
Sieving/screening
Incineration (rotary kiln, infrared)
Excavation, disposal (on-site, off-site)
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: i ,

Biological treatment: Composting, in situ biodegradation, slurry phase treatment
Phys/Chem treatment: Oxidation, reduction, aqueous soil washing, solvent extraction, in situ
vacuum extraction
Thermal treatment: Vitrification (in situ, ex situ), low-temperature thermal decomposition

.. • ' . • • ' -/' --I-' . . ' '
6. . What was the cost estimate for the innovative technology? j

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does riot quantify costs. After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that merit a more detailed
evaluation. In this case, the estimated costs were calculated during an evaluation based on
nine criteria established by the NCP. ,
. '' I v .-
Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold) j
Alternative
RAA-3
Innovative Technology
' Excavation/composting/on-site
disposal
Estimated Costs
3 Criteria .
N/A
9 Criteria
$1,900,000
to
$8,2000,000°
"Cost is dependent on the depth of excavation and the specific type of composting used.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
Standard Technology
Estimated Costs
3 Criteria
9 Criteria
RAA-1
No action
N/A
$0
-2-
1267
-------
Alternative
RAA-2
Standard Technology
Excavation/incineration
Estimated Costs
3 Criteria
N/A
9 Criteria
$4,100,000
to
$12,800,000
8. If a standard technology was chosen, why?

A standard technology was not selected as the primary remedy. A clean soil cover will be
used after treatment.
9. If on innovative technology was chosen, why?

RAA-3 was selected because it reduces excess cancer risk in treated soil to 7 X W6 (industrial
use scenario) and reduces site concentrations of systemic toxicants to levels at which no
adverse effect would be expected'considering factors of uncertainty. It reduces plant stress
associated with high concentrations of explosives. Following treatment, the soil will be
disposed of on site and the provision for a clean soil cover will minimize direct contact with
underlying treated soil that might contain residual contaminants. This remedy is expected to be
consistent with future ground water remediation since it provides a substantial reduction in
near-surface soil concentrations and a cover of clean soil. In combination with low
precipitation and high evaporation rates in the region, negligible leaching of residual
contaminants is expected. This alternative provides long-term effectiveness and a permanent
reduction in contaminant toxicity, volume, and mobility. Composting has been demonstrated
in site-specific pilot-scale treatability studies in which it has degraded and immobilized 97 to
99 percent of the explosives. It can be readily implemented. RAA-3 is an innovative
application of an existing technology, and site-specific treatability studies have been
completed. A final optimization study is nearing completion and will allow implementation of
the remedy in about 1 year. The equipment and materials required to implement RAA-3 are
readily available from local sources and national vendors. The alternative is cost effective.
10.
1268
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?

Innovative technologies eliminated during the initial screening include the following:

• Vitrification (in situ, ex situ) was eliminated because it has hot been tested for the
site's soil contaminants, and it has not been demonstrated on a full-scale basis.
• Low-temperature thermal decomposition was eliminated because it was found to be
ineffective in U.S. Army Toxic and Hazardous Materials Agency (USATHAMA)
treatability studies at the site to reduce explosives contamination in soil (IT 1987- Rov
F. Weston, Inc., 1991). ' •
-3-
-------
• In situ biodegradation was eliminated because it has been relatively unsuccessful in
vadose zone applications at other sites due to difficulties in maintaining a relatively
uniform and constant distribution of nutrients, moisture, and oxygen. At the site,
nutrient distribution would be a primary limiting'factor. Further, soil handling and site
disturbance would require mixing large volumes of amendment into the soil, thus
negating two of the primary benefits of in situ treatment. Finally, it may not be
effective at low explosive concentrations. !
• Slurry phase treatment was eliminated because in treatability studies to date, less than
90-percent destruction and removal efficiency has been achieved 0\rgonne National
Laboratory, 1991). :!
• Aqueous soil washing was eliminated because treatability studies indicate explosives
removal efficiency is low, ranging between 49 to 99 percent in one study (ARCO,
1982) and 23 to 83 percent in another study (EPA, 1992, references not listed in FS).
• In situ vacuum extraction was eliminated because it would not be feasible given the
low vapor pressure and low volatility of explosives. -
• Oxidation was eliminated because explosives are not susceptible to abiotic oxidation
(IT, 1987).
• Reduction was eliminated because it has not been demonstrated for these contaminants
and soils and it might produce toxic byproducts (IT, 1987).

Innovative technologies eliminated during the screening of the three criteria include the
following: j

• Solvent extraction was eliminated because it would not be a final treatment and there
would be difficulty eliminating the final extract. It was suggested that the extract
could be incinerated; however, mis would be unacceptable to the ,&rmy because of the
stringent requirement imposed on facilities that process detonatable concentrations. In
addition, it is unlikely that a commercial incinerator would be willing to accept a
potentially explosive mixture. This process would not be easily implemented
technically or administratively. Considerable equipment would be needed for
remediation, and the design of the fractionation system would have to incorporate
potentially costly explosion safety controls. Administratively, the^ process is unproven
for explosives, Treatability studies would be necessary to demonstrate viability. Cost
would be high because of the additional treatability studies, the design and
mobilization of expensive equipment, and the need to have process equipment for each
of the several phases. ,

Innovative technologies eliminated during the detailed analysis include thb following:

'. • • None '
> * ' ' ' ~ • '
, * • . • ' i , •
' - • i, . « •
11. Which of the nine criteria were weighted most heavily in selecting the technology? .Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard tischnology?

The criteria most heavily weighted in selecting a remedial technology weire protection of
human health and the environment, long-term effectiveness, and cost. Of the two alternatives
that were protective and reduced site risk permanently and to acceptable levels, the most
inexpensive option was chosen.
• • . ' ' - • . •' ' '. , • ..I-'"- • ' '.'.-•• „

1269
-4- ' ' - ' ...;..'". ' • , .
-------
12. What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level
(mg/kg)a
ARAR or Other Basis
Carcinogens •
2,4,6-TOT
2,4-DNT
RDX
Noncarcinogens
1,3,5-TNB
1,3-DNB
HMX
NB
RDX
4/8,4
0.17/0.37
6.2/33

0.96/6.7
1.9/13
946/6,669
10/67
217/5,723
Risk"
Risk
Risk

Risk
Risk
Risk
Risk
Risk
*Cleanup levels are risk based and correspond to residential land use scenario/industrial,
land use scenario.
"For carcinogens, an excess upper bound individual lifetime cancer risk of 10"6 was
acceptable, and for noncarcinogens, a Hazard Index less than or equal to 1.0 was
acceptable.
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? . •

Innovative technologies eliminated because of cleanup goals include:

« None

Standard technologies eliminated because of cleanup goals include:

» None •
14. Were treatability studies conducted on the innovative technology or standard technology?

Since the early 1980s, USATHAMA has performed bench-scale arid pilot-scale studies on
composting. Studies conducted using contaminated site soil indicated that the extractable
concentrations of the explosives in the soil were significantly reduced (by 90 to 99 percent) by
aerobic microorganisms (Roy F. Weston, Inc., 1991).
1270
-5-
'„*
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15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Risk level achieved
Cost-effective
- Proven reliability

16. How are measures compared? '<

RAA-3 and RAA-2 were determined to reduce excess cancer risk to 1 X 10"6 and 7 X
ID"6, respectively. A Hazard Index (HI) of less than 1 will be reached for all explosives except
1,3,5-TNB in RAA-3, which could have an HI as high as 7. While itjis telieved that
substantial degradation of 1,3,5-TNB will occur, the elevated HI for 1,3,5-TNB in RAA-3 was
acceptable because of uncertainty regarding its biodegradation; this estimzite assumes no
degradation. Further, RAA-2 would result in the permanent destruction of 99.99 percent of
site explosives while RAA-3 has been demonstrated to degrade or immobilize 97 to 99 percent
of explosives. While RAA-2 would provide slightly greater protection and long-term
permanence than RAA-3, RAA-2 was not chosen because it would cost twice as much to
implement. . i

Proven reliability was an influencing factor in selecting an appropriate! technology. The
chosen technology (composting) was determined to be effective in a site-specific treatability
study. Other technologies (low-temperature thermal decomposition, slurry phase treatment,
aqueous soil washing, oxidation, and reduction) were eliminated because they had been shown
to be ineffective for the remediation of explosives.

17. What technical considerations were factors in selecting a remedy? Ware technical
considerations primary in the selection of the remedy? ''' •
' ' • ' • ' •' '.''•• | '•• ' ••••••''
No technical considerations were primary in selecting a remedial technology.

References
' , i
ARCO. 1982. Engineering and development support of general decon technology for the U.S.
Army's Installation/Restoration Program. Prepared for the U.S. Army Toxic and Hazardous
Materials Agency.- DAAK 11-80-C0027. |

Argonne National Laboratory. 1991. Evaluation for the feasibility of biodegrading
explosives-contaminated soils and groundwater at the Newport Army Ammunition Plant.
Prepared for the U.S. Army Toxic and Hazardous Materials Agency. ipElHA-TS-CR-9200
(June)., | ......

IT. International Technology Corporation. 1987. Interim response action feasibility study,
Area P Lagoons, Louisianan Army Ammunition Plant, final report. Prepared for the U.S.
Army Toxic and Hazardous Materials Agency. DACA45-87-C-0103 (August).
-6- 1271
-------
Roy F. Weston, Inc. 1991. Optimization of composting for explosives contaminated soil,

final report. Prepared for the U.S. Army Toxic and Hazardous Materials Agency (November).
1272
-7-
' , ff,,-

; i'
. ,t,

i it'
|,.E(,,l'i
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Union Pacific Railroad Co.

• Pocatello, Idaho
Region 10
GENERAL SITE INFORMATION

7. . What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

Maximum concentrations of principal
contaminants were:

Sludge/Soil (mg/kg)
\ . -•..'.•'
.. Benzo(k)fluoranthene 33
Benzo(a)anthracene 23
Chrysene , '23
Benzo(a)pyrene 17
Indeno(l,2,3-cd)pyrene 12
Arsenic 27.4
Beryllium 1.2
Tetrachoroethene 56
1,1-Dichloroethene 8.3
Methylene chloride 86
Trichloroethene 51
n-Nitrosodiphenylamine 54
1,4-Dichlorobenzene 10
1,1,2,2-Tetrachloroethane 0.99
Chloromethane 2.5
Cadmium 40.2
Chromium 136
Copper 242
Zinc ~ -. • 1,530
Antimony 3.3
Vanadium 45.8
1,2-Dichloroethene .. 107
Lead 1,460
2.-.-'- What volume of material is to be remediated?

The volume of material to be remediated included:

• 2,500 cubic yards of soil
• 1,700 cubic yards of soil ,
NPL Proposed:
NPL Final:
FS:
ROD:
Background

PRP-lead
PRPs: Union Pacific Railroad
FS prepared by: Applied
Geotechnology Inc.
Site Hisltory
9/83
9/21/84
4/91
9/91
-1-
1273
-------
3. What type of site is this?

Transportation. An active rail yard located in a mixed commercial and light industrial area
with some residential areas.
TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were: . .
Access restriction:
Containment:
Chemical treatment:

Physical treatment:
Thermal treatment:

Disposal:
Deed restrictions, fencing
Capping (clay, asphalt, concrete, multimedia), slurry wall, grout curtain
Neutralization, precipitation, polymerization, solidification,
microencapsulation
Recycling, dewatering, soil venting , ' • .
Incineration (rotary kiln, fluidized bed, multiple hearth, high-
temperature fluid wall reactor, plasma arc)
Excavation, off-site disposal, on-site disposal .','-.•
5. Was an innovative technology considered in the F.S? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: •

Biological treatment: Biodegradation (aerobic, anaerobic, in situ, ex situ)
Phys/Chem treatment: Oxidation (in situ, ex situ), reduction (in situ, ex situ), dechlorination
(in situ, ex situ), soil flushing, hydrolysis (in situ, ex situ), ex situ
solvent flushing
Thermal treatment: In situ vitrification, steam injection, radio frequency heating, ground
. freezing, pyrolysis, molten salt incineration
*
6. What was the cost estimate for the innovative, technology?

For this site, alternatives were renumbered in the detailed analyses and are presented
' parenthetically below. • ,
1274
if;
-2-
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Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
RAA-3
(RAA-4)
RAA-4
(RAA-9)
RAA-5
(RAA-11)
(RAA-5)
(RAA-6)
RAA-10
Innovative Technology
Off-site disposal/excavation/backfilling/
soil flushing/ground water treatment with
dissolved air flotation (DAF)
Off-site disposal/excavation/backfilling/
soil flushing/ground water treatment with
carbon adsorption
On-site incineration/excavation/
backfilling/soil flushing/ground water
treatment with DAF
Off-site incineration/excavation/
backfilling/soil flushing/ground water
treatment ,
Off-site disposal/excavation/backfilling/
asphalt cap/soil flushing/ground water
treatment with DAF
Off-site disposal/excavation/backfilling/
asphalt cap/soil flushing/ground water
treatment with carbon adsorption
Ex situ bioremediation/excavation/
solidification/backfilling/capping/on-site
disposal
Estimated Costs
3 Criiteriia
$5,443,590
to
$7,731,390
N/A-
t
1 • '-
$8,365,590
tb .
$18,38!6,790a
$8,409,240
to
$27,218,790"
N/A
- N/A
$1,553,450
to
$1,780,150"
9 Criteria
$3,073,150
to
$7,731,390*
$6,333,250
to
$69,819,563a
$8,121,750
to
$24,865,250*
$8,198,050
to
$40,287,150a
$3,192,950
to
$3,797,550'
$6;452,850
to
$6,984,750°
eliminated
"Cost depends on specific amount of sludge excavated and disposed/treated.
bCost depends on choice of either asphalt or multimedia cap.
7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
-3-
Alternative
RAA-1
RAA-2
RAA-6
RAA-7
Standard Technology
No action
Institutional controls
Asphalt cap
Multimedia cap

Estimated Costs
3 Criteria
$635,300
$840,350
$1,011,150
$1,218,850
9 Criteria
$635,300
$669,850
eliminated
eliminated
1275
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Alternative
RAA-8
(RAA-7)
RAA-9
(RAA-7)
RAA-8
Standard Technology
Silicate-based solidification/excavation/
backfilling/on-site disposal/ground water
treatment with DAF
Chemical fixation/excavation/backfilling/
capping/on-site disposal/ground water
treatment with DAF
Solidification/excavation/backfilling/
capping/on-site disposal/ground water
treatment with carbon adsorption
Estimated Costs
3 Criteria
$1,287,450
to
$1,514,150"
$1,247.600
i,,-
$1,474,300"
N/A
9 Criteria
$8,054,350
, $8,054,350
$11,345,500
8. If a standard technology was chosen, why? .

Off-site disposal of some soil was selected as a primary remedy. An asphalt cap was selected
to cover residuals in treated soil on site.
9. If an innovative technology was chosen, why? '' >

The selected remedy was preferred because it will be protective of human health and the
environment. Excavation and off-site disposal of contaminated soil will significantly reduce
the threat of exposure from ingestion, dermal contact, and inhalation of site contaminants. Soil
flushing and extraction and treatment of ground water will -eliminate the threat of exposure
from ingestion or inhalation of contaminated ground water. This alternative meets all ARARs.
Short-term risks will be low and are not expected to increase significantly during remedial
activities since control strategies such as dust suppression, air monitoring, and protective
clothing will be implemented. The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its costs for the remediation of
contaminated sludge, soil, and ground water. Since the technical feasibility of excavating
through soils is uncertain, it is assumed that only 4,200 cubic yards will be excavated.
Additional protection will be necessary for contaminants remaining in unexcavated soil. The
asphalt cap over the sludge pit provides added protection against contaminants leaching from
infiltration of the rain or snow melt. Additionally, it will reduce the lateral and vertical
migration of contaminants possibly remaining after excavation of the contaminants in soil both
downgradient of the sludge pit and near areas of highest ground water contamination. The risk
from ground water contamination is permanently reduced through soil flushing and treatment
to acceptable exposure levels without transferring the risk to another media. This alternative is
easily implemented technically since excavation of 4,200 cubic yards of sludge and soil, its
transportation and disposal at the RCRA landfill, and capping of the excavated pit are routine
operations. '-.... •''.'.
1276
. -4.
-------
10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated?
' - - - i ' . . ' ."•-'"/!,: •' ' •
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.
* ' ' - , ' •
Innovative technologies eliminated during the initial screening includes the following: - *

• In situ oxidation was eliminated because sludge constituents would not be amenable to
the process ,_ ....... , _ .." . j
• In situ reduction was eliminated because sludge hardness might make the addition of
reducing agents difficult, the technology would be more appropriate for liquid waste
, Streams, and the permanence of reduction in unknown. '
• . In situ dechlorinatioh was eliminated because contact between sludge constituents and
solvent would be difficult to ensure. .
• In situ hydrolysis was eliminated because it would not be applicable for sludge
constituents. ,
• In situ soil venting was eliminated because it would not be applicable for sludge
constituents.
• Ex situ oxidation was eliminated because it would be more appropriate for a
wastewater stream, ,
• Ex situ reduction was eliminated because it would be more appropriate for a
wastewater stream.
:« Ex situ dechlorination was eliminated because it would be more appropriate for a
wastewater stream. ' .
• Ex situ solvent washing was eliminated because the dense nature of the sludge would
not permit adequate contact with the sludge. i
•'.,.• Ex situ hydrolysis was eliminated because it would be more appropriate for. very
specific wastes such as esters, amides, and carbamates. | :
• Ground freezing was eliminated because it would not be a peirmaiient solution.
• Radio frequency heating was eliminated because it is an experimental technology still
being tested in pilot studies. In addition, it would not be effective for heavy metals. -
» Steam injection was eliminated because it is an experimental technology still being
tested in pilot studies. Li addition, it would not be effective for heavy metals.
- • • • ' i- -'•
Innovative technologies eliminated during the screening of the three cntena include the
following: j /

• In situ anaerobic biodegradation was eliminated because treatment might not be
possible since the range of organic contaminants capable of degradation through an
anaerobic process is limited. • "
• In situ vitrification was eliminated because it is a relatively new technology requiring
special equipment and significant electrical supplies. It is in developmental stages and
is costly. ]
• Ex situ anaerobic biodegradation was eliminated because treatment might not be
possible since the range of organic contaminants capable of degradation through an
anaerobic process is limited. .
• Molten salt was eliminated because it would not be particularity effective for sludges of
high ash content (UPRR sludge ash content approaches 50 percent). Further, it is a
1277
-------
11.
12.
new technology, it would be costly, and it is used mainly for liquids and might not be
as effective for solids.
• Pyrolysis was eliminated -Because it is a new technology in the developmental stages.

Innovative technologies eliminated during the detailed analyst include the following:

" Bioremediation (aerobic, ex situ) was eliminated because low concentrations of
contaminants would not be readily or practically addressed by the bioremediation
technology. A variety of reasons were given including: PAHs and chlorinated
hydrocarbon concentrations might not be reduced below acceptable risk levels; metals
toxicity and teachability might increase following bioremediation; metals might inhibit
microbiological activity or even prove toxic to microbes; additional treatment
technologies would be needed to.address remaining problems (e.g., solidification and
capping); initiating and propagating (i.e., blending oxygen arid nutrients)
bioremediation would be difficult to achieve given the consistency of the sludge; the
effectiveness of bioremediation on benzo(a)pyrene and potential bacterial toxicity is
unknown; time required for site remediation is unknown because of the character of
the sludge, type of bacteria required, soil matrix, and the adaptability of bacteria to the
site's contaminants; and the availability of the treatment technologies might be limited.
(It was noted that these issues were discussed with EPA, and that EPA said that
bioremediation could be eliminated.)
• In situ aerobic biodegradation was not explicitly eliminated.

Protection of human health and the environment and long-term effectiveness were the criteria
weighted most heavily'in selecting a remedial alternative. Solidification was not preferred
because its effectiveness over time was uncertain. Incineration was not preferred because it
produces ash as a byproduct and metals might become more mobile in the ash, necessitating
further treatment. Further, because of the high contaminant concentrations in the sludge, the
effectiveness of incineration at reaching cleanup levels was uncertain. Finally, the asphalt cap
proposed in the selected remedy was preferred because it will act to immobilize any residual
contaminants.

Bioremediation was eliminated because it might not meet cleanup levels and it might be
difficult to implement.

What cleanup goals were selected? If the cleanup goal was based on an ARAR, what was that
ARAR? What risk level was selected to establish cleanup goals?

Chemical-specific cleanup levels were not finalized, with the exception of lead, as a result of
incomplete data regarding the background concentrations of contaminants. Final cleanup
levels will be based on background concentrations, lowest practical quantitation limit, or risk-
based cleanup levels, whichever is highest. Health risk-based cleanup levels will be based on
a 10* cancer risk or a Hazard Index of less than or equal to 1.
„[,„:„
1278
IF
>"',(
'::if
-------
13.
Contaminant
Cleanup Level (ppm)
ARAR or Other Basis
Carcinogens \.
Lead
500
OSWR/ModeP
•OSWER directive #9355.4-02 and the EPA Lead Uptake Bic|kinistic Model were used
to determine this cleanup level.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:;

• Bioremediation

• ' '!
Standard technologies eliminated because of cleanup goals include, j

• None ~ !
14.
Were treatability studies conducted on the innovative technology or standard technology?

No treatability studies were conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Proven reliability
Single versus multistep treatment
- Impact on nearby populations

/6.- How are measures compared?
[„,:
The impact on nearby populations was a concern. It was noted that short-term compliance
with air quality standards could be more difficult with alternatives thai: proposed incineration
and solidification because of the air process emissions associated with Ithose treatment options
Proven reliability also was a factor in selecting a remedial alternative., Solidification was
eliminated because the successful implementation and maintenance of the solidified mass was
uncertain given the oily consistency of the sludge. Further, elevated metal concentrations
found in the sludge present significant uncertainty in the incineration tischnology's ability to
achieve target cleanup levels, The preferred alternative was selected because it offers greater
protection and ensures effectiveness through a multistep treatment. Thus, ;after the upper levels
of sludge and soil are removed and disposed off site, lower levels of soil are treated with soil
flushing to remove any remaining contaminants. Further, an asphalt cap will be placed over
the excavated pit to inhibit infiltration and the mobility of any remainiing contaminants.
-7-
1279
-------
17. What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? . ,

The nature and depth of the contaminated media was primary in selecting a remedial
alternative. While many alternatives assumed that sludge and soil would be excavated to
cleanup goals, it was suggested in the ROD that excavating soil beneath the "visible" sludge
may be technically impracticable, if not impossible, because of its extremely coarse nature
(i.e., dense mixture of gravel, cobbles, and boulders ranging up to 9 feet in diameter).
Excavation, therefore, would likely be limited to practical depths, resulting in the removal of
approximately 4,200 cubic yards of sludge and soil. Thus, the chosen alternative is the most
effective and protective because it will best address all contaminants by excavating to a
practical limit, treating remaining soil via in situ soil flushing, and implementing a cap.
", It:
fit-
1280
-8-
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Wyckoff Company/Eagle Harbor
West Harbor Operable Unit, OU-3

Bainbridge Island, Washington
Region 10
GENERAL.SITE INFORMATION

1. What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study? .

Maximum concentrations of principal
contaminants were: ' , s

Intertidal and Subtidal Sediments (mg/kg)
Mercury
95
Maximum concentrations of principal
contaminants besides mercury were not
given in the FS or the ROD. Other
contaminants detected include: LPAH,
Naphthalene, Acenaphthylene,
Acenaphthene, Fluorene, Phenanthrene,
Anthracene, 2-Methylnaphthalene, HPAH,
Fluoranthene, Pyrene, Benzo(a)anthracene, Chrysene, Total benzofluoranthenes,
Berizo(a)pyrene, Ideno(l,2,3-c,d)pyrene, Dibenzo(a,h)anthracene, and Benj!io(g,h,i)perylene.
Site History
NPL Proposed:
NPL Final:
FS:
ROD:
9/85
7/87
11/91
9/29/92
Background

EPA Fund-lead
PRPs: Wyckoff Company (now Pacific
Sound Resources), 10 parties
were notified of potential liability
FS prepared by: CH2M Hill
2. What volume of material is to be remediated? !

The volume of material to be remediated included: , ' .
• ' ' . ' •• r
• 5,355 cubic yards of intertidal mercury contaminated sediments
• 67,320 cubic yards of subtidal mercury contaminated sediments
• 7,650 cubic yards of intertidal PAH contaminated sediments
- ' . • \ '

3. (What type of site is this? i ;

Lumber and Wood Products. This site includes Eagle Harbor and the Ifbnner Wyckoff wood
treating facility. This ROD addresses the west harbor operable unit, onle off three operable units
at the site. Ship building, maintenance, and repair activities have been conducted at this site
since the turn of the century. Land use in the vicinity of the site is principally residential, with
some commercial and industrial use. . :, • -
1281
-i-
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?

Standard technologies considered during the identification and screening of technically feasible
technologies were:
Access restriction:
Containment:

Physical treatment:
Thermal treatment:
Disposal:
Institutional controls, hazard education programs
Capping (active materials, inert materials, synthetic or manufactured),
lateral containment (isolation barriers)
Dewatering, solidification/stabilization
Incineration, thermal extraction
Excavation, dredging (mechanical, hydraulic, specialty), confined,
unconfined
5. Was an innovative technology considered in the FS? If so, which technology?

Innovative technologies considered during the identification and screening of technically
feasible technologies were: \

Biological treatment: In situ biological treatment, land treatment, slurry treatment
Chemical treatment: PCB dechlorination
Physical treatment: Soil washing, solvent extraction

6. What was the cost estimate for the innovative technology?

Cost Estimates for RAAs That Include Innovative Technologies
(selected remedial alternative is in bold)
Alternative
J
K
M
Innovative Technology
Removal/treatment by soil washing
(viable for PAH only)/disposal
Removal/treatment by solvent extraction
(viable for PAH only)/disposal
Removal/treatment by biological slurry
(viable for PAH only)/disposal
Estimated Costs
3 Criteria
N/A
N/A
N/A •
9 Criteria
eliminated
eliminated
$303,000,000
s>
1282
-2-
-------
Estimated costs for this site were recalculated in the PP. Except for Alternative N, costs for
each RAA were not presented in the ROD.
7.
Alternative
M
Innovative Technology
Removal/treatment by biological slurry
(viable for PAH only)/disposal
f - L
Estimated Costs
PP
$100,800,000
to
$204,900,000
How did the cost(s) compare to standard technologies? '
Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
Alternative
A
B
C
D
E
-F
G
H
I
M

Standard Technology
No action/natural recovery
Institutional controls/natural recovery
Capping
Removal/consolidation/confined
aquatic disposal
Removal/consolidation/near-shore
disposal
Removal/consolidation/upland disposal
on site
Removal/consolidation/upland disposal
at off-site commercial RCRA landfill
(viable for mercury only)
Removal/treatment by incineration
(viable for PAH only)/ disposal
Removal/treatment by solidification or
stabilization (viable for mercury
only)/disposal
In situ treatment by
solidification/stabilization (viable for
intertidal areas with mercury only)
Estimated Costs
3 Criteria
N/A
N/A
N/A
N/A
MA
N/A
MA
N;A
MA
N/A
9 Criteria
$1,370,000
$1,760,000
$31,900,000
$65,800,000
$145,000,000
eliminated
$103,000,000
$420,000,000
$33,760,000
$3,500,000
-3-
1283
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Alternative
A
B
C
D
E
G
H
I
M
N
Standard Technology
No action/natural recovery
Institutional controls/natural recovery
Capping
Removal/consolidation/confined aquatic
disposal
Removal/consolidation/near-shore ;
disposal •
Removal/consolidation/upland
disposal at off-site commercial RCRA
landfill (viable for mercury only)
Removal/treatment by incineration
(viable for PAH only)/ disposal
Removal/treatment by solidification
or stabilization (viable for mercury
only)/disposal
In situ treatment by solidification/
stabilization (viable for intertidal areas
with mercury only)
Low-impact capping
Estimated Costs
PP
$800,000
to
$1,200,000
$1,200,000
$15,200,000
to
$25,100,000
$22,700,000
to
$48,600,000
$73,600,000
to
$110,700,000
$50,000,000
to
$104,000,000
$174,500,000
to
$274,100,000
$17,400,000
to
$34,500,000
$4,500,000
$2,100,000
to
$3,600,000'
"Estimated costs for Alternative N were recalculated in the ROD. Using computer modeling the
U.S. Corps of Engineers developed a type of low-impact capping defined as Thin-Layer
Placement in March 1992. Thin-Layer Placement is the basis for the revised costs for
Alternative N presented in the ROD, which are $2.2 million.
8. If a standard technology was chosen, why? .

The selected remedy combines the following remedial alternatives B, C, G or I, and N. The
estimated total present worth costs for the entire remedy are $6.2 million to $16 million.

This remedy combines upland source control, removal of hotspot sediments, capping of
contaminated sediments, low-impact capping of marginally contaminated

-4. - .
-------
sediments, and institutional controls. Upland source control is intended to reduce or eliminate
future contaminant discharges which could recontaminate sediments. Removal of hotspot ..._
sediments will eliminate a significant source of mercury contamination to the marine
environment. Capping large areas of subtidal sediments with clean materials is an effective
means of quickly protecting the environment with minimal short-temt effects. Within areas to
be capped, use of a meter-thick cap will limit potential redistribution of mercury and address
more significant environmental risks. Low-impact capping in marginzilly contaminated areas
will reduce surface sediment chemical concentrations to levels protective of human health and
the environment without unnecessary cost. Under the selected remedy mercury source
sediments will be solidified before landfill disposal. Solidification and appropriate landfill
selection will be "relatively" permanent. Finally, the capping component of the preferred
alternative involves no dredging, storage, dewatering, or processing of contaminated sediment,
arid removal of the mercury source sediments can be done from land at extreme low tide.
These options are more readily implementable than most of the other active cleanup
alternatives.
9. If an innovative technology-was chosen, why?
' ! - " .-.''. ',[•"_
An innovative technology was not chosen. j

10. If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .
- ' ' - " , ' I- ' - -
Innovative technologies could be eliminated from the remedial technology selection process at
three stages: during the initial screening; during the screening of the^ three criteria of
effectiveness, implementability, and cost; or during the detailed evaluation.

Innovative technologies eliminated during the initial screening include the following:
" '• - > ,•'"•!''*
• In situ biological treatment was .eliminated for the intertidal land subtidal mercury areas
because this technology would not be applicable for use with mercury-contaminated
, sediments; mercury is not biodegradable. ,
• Land treatment was eliminated for the intertidal arid subtidal mercury areas because
this technology would not be applicable for use with mercury-contaminated sediments;
mercury is not biodegradable. j
• PCB dechlorination was eliminated because at this tirne, known PCS contamination of
sediments in Eagle Harbor has not been demonstrated to be a direct threat to either
human health or the environment; therefore, sediment remediation will not specifically
target PCBs. Process options were not carried forward for the PCB technology type
screening. , - t
» Slurry treatment was eliminated for the intertidal and subtidd mercury areas because
this technology would not be applicable for use with mercury-contaminated sediments;
mercury is not biodegradable. J
• Soil washing was eliminated for the intertidal and subtidal nsercury areas because this
technology is not proven for use with metal-contaminated sediments. -
• Solvent extraction was eliminated for the intertidal and subtidal mercury areas because
this technology is not proven for use with metal-contaminatejd sediments.
} 1285
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Innovative technologies eliminated during the screening of the three criteria include the
following: Y

• Soil washing was eliminated for the intertidai PAH area because the effectiveness of
this alternative is not known for marine sediments and treatability studies would be
required. It might be technically feasible to implement soil washing at this site, but .
there are uncertainties associated with its ability to treat the heterogeneous sediment i
consistently. After soil washing, the concentrated waste stream would have to be
disposed of or treated. This treatment alternative was not carried forward because of
the uncertainties mentioned above and because other available treatment alternatives
accomplish a comparable level of treatment with fewer uncertainties.
• Solvent extraction was eliminated for the intertidai PAH area because this treatment
has not been used to treat soils or sediments, and the likelihood its success at the site
is uncertain. The process equipment is complex, and its suitability for use at,the site is
uncertain. Other treatment alternatives appear capable of achieving comparable results
with less uncertainty.

Innovative technologies eliminated during the detailed analysis include the following: '' t

• Biological slurry treatment Was eliminated because long-term protectiveness would be
contingent on effective source control. If additional PAH inputs were mot controlled,
removal might not provide effective protection of the environment because of the
possibility-for recontarnination of jemediated area. Removal and disposal of ^llk
contaminated sediments also could temporarily increase levels of contamination in the lj|lr
ah-, thus there would be potential public contact with contaminated sediment during -
excavation/dredging, and storage because disturbed sediments might be transported J
onto beaches. Treatment could produce air emissions. In addition this treatment
alternative should meet ARARs, although possibly with more difficulty than other ,, •
alternatives. Finally, although biological slurry treatment is a proven technology it is "*
subject to site-specific variation in destruction efficiency. '. • '[

11. Which of the nine criteria were weighted most heavily in selecting, the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
'' • '; •••'•' .' v :il
The criteria weighted most.heavily in selecting a remedy were protection of human health and
the environment, long-term effectiveness, and cost. The preferred remedy is protective of both
public health and the environment. It removes source metals, addresses-human health risks
from consumption of contaminated seafood by continuing the existing advisory until
contaminants are below levels of concern, and isolates sediment from adversely affected
marine organisms. Upland disposal of the mercury hotspot sediments is appropriate for
reasons of long-term effectiveness and permanence, because it permanently removes the most
concentrated mercury contamination from the marine environment. This important criterion
outweighed the advantages of in situ solidification/stabilization and other alternatives. In
addition the selected remedy is cost effective. By tailoring the remedy so that removal and
any necessary treatment are applied to small-volume, high-concentration sediments, and by
using lower-cost containment alternatives for the large areas of moderate to marginal
contamination, the selected remedy cost-effectively provides an appropriate level of protection
for each area. Allowing natural recovery in areas where cleanup objectives will be achieved in

1286
' . . -6- • .' • .
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12.
10 years, and allowing biological testing to modify the selected remedy and perhaps eliminate
cleanup areas, avoids costly and unnecessary remedial actions.

' - '• •-'•••• i "
What cleanup goals were selected? If the cleanup goal was based on}an ARAR, what,was that
ARAR? What risk level was selected to establish cleanup goals?
Contaminant
Cleanup Level (mg/kg)
ARAR or Other Basis '
Carcinogens .
HPAH
Benzo(a)anthracene
Chrysene
Total
benzofluoranthenes
Benzo(a)pyrene
Ideno(l,2,3-c,d)pyrene
Dibenzo(a,h)
anthracene
5,300
270
460
450
210 ':.
88 -
33
MC:ULm
" MCUL
MCUL
MCUL
MCUL
MCUL
MCUL
Noncarcinogens ,
Mercury
LPAH
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
2-Methylnaphthalene
Huoranthene
Pyrene
Benzo(g,h,i)perylerie
Q.59 mg/kg (dry weight)
780
170
66
57
, 79 -
480
1,200
64
1,200
1,400
78
•- MCUL
MCUL
MCUL
MCUL
MCUL
MCUL
MCUL
MCUL
; MCUL
MCUL
MCUL
MCUL
The sediment cleanup objective for this site combines an ovejrall site-specific cleanup
objective develojped according to the State of Washington Sedimesnt Management
Standards with supplemental objectives developed by EPA to address specific
concerns. The measurable site-specific objective is the MCUll (Minimum Cleanup
1287
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Level), and achievement of the MCUL is the primary focus of remedial action in this
operable unit. ,
13. Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals?

Innovative technologies eliminated because of cleanup goals include:

• None , ' ' .-...-

Standard technologies eliminated because of cleanup goals include: "

• None . ,

14. Were treatability studies conducted on the innovative technology or standard technology?

Treatability studies were not conducted.
15. What measures/criteria were used to compare alternatives?

The following measures were used to compare the alternatives:

Cost effectiveness
Proven reliability
Impact on nearby populations
,.l!
16. How are measures compared? •

The selected remedy is cost effective as it provides overall protection proportional to its costs.
By tailoring the remedy so that removal and any necessary treatment are applied to small-
volume, high-concentration sediments, and by using lower-cost containment alternatives for the
large areas of moderate to marginal contamination, the selected remedy cost-effectively
provides an appropriate level of protection for each area. Allowing natural recovery in areas
where cleanup objectives will be achieved in 10 years, and allowing biological testing to
modify the selected remedy and perhaps eliminate cleanup areas, avoids costly and
unnecessary remedial actions.Only one treatment alternative, stabilization/solidification, was
carried forward for detailed evaluation for mercury-contaminated sediments, because of
technical uncertainties associated with other treatment alternatives". Biological sludge treatment
was eliminated in part because the removal and disposal of contaminated sediments could
temporarily increase levels of contamination in the air, thereby affecting nearby populations
17.
1288
What technical considerations were factors in selecting a remedy? Were technical
considerations primary in the selection of the remedy? ..

Technical considerations were not primary in selecting a remedy for this site. Soil washing for
PAH removal for sediments was eliminated in part because the heterogeneous grain size
.*>
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problems. ' • ' ,
I . , ' _'-'!"• .
1289
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Yakima Plating Co.

Yakima, Washington
Region 10
GENERAL SITE INFORMATION
1,
What were the principal contaminants,
contaminant levels, and media addressed in
this feasibility study?

• •

Maximum concentrations of principal
contaminants were:

SoU (mg/kg)

Arsenic
Total Chromium
Chromium VI
Lead
Nickel
DDD
DDT
DDE
Dieldrin
Copper
Barium
Cadmium
Selenium
Cyanide

32.7
7,870
7.04
7,580
218,000
4.3 - • . : ' .
19.4

Site History
if '
NPL Proposed: 6/88 ,
NPL Final: 3/89
FS: , 8/91
ROD: 9/91

Background

EPA Fund-lead
PRPs: Yakima Plating, Robert Mastell
FS prepared by: Ecology and
Environment, Inc.

18
0.9
46,700
595 . •,,/''
14.6
10.1 • , .
495
2. What volume of material is to be remediated?

The volume of material to be remediated included.

• 540 cubic yards of soil • :

3. What type of site is this?

Electroplating. An inactive nickel-chrome automobile bumper replating facility. It is located
within a mixed lightly commercial and residential area.
I
1290
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TECHNOLOGY SELECTION

4. What standard technologies were considered for selection in this FS?\

Standard technologies considered during the identification and screening of technically feasible
technologies were: - .; '
• . ' ' • 'i •
Containment: Capping (single-layer, multilayer, asphalt, cement, concrete). >
.Physical/Chemical: Immobilization, solidification/stabilization
Thermal treatment: Incineration (rotary kiln, multiple hearth, fluiclized bed, infrared)
Disposal: Landfill (on-site, off-site) .

'" * i" • • " - -

5. Was an innovative technology considered in the FS? If so, which technology?
' -i •
Innovative technologies considered during the identification and screening of technically
feasible technologies were: . -j •''-.'.
L ' '
Physical/Chemical: Soil washing, in situ soil flushing }
Thermal treatment: Wet air oxidation, vitrification (in situ, ex situi), molten salt
6. What was the cost estimate for the innovative technology? | .

During the initial screening process, in which technically feasible technologies are identified
(prior to the formulation of RAAs), the FS does not quantify costs, After the RAAs have been
formulated, costs are typically estimated as part of a three-criteria screening process
(effectiveness, implementability, and cost) to identify alternatives that [merit a more detailed
evaluation. The estimated costs then are recalculated during an evaluation based on nine
criteria established by the NCP. RAAs presented parenthetically represent changes in the
Proposed Plan and the ROD. >
' • • '.i • ' ' .
, i . ...
Cost Estimates for RAAs That Include Innovative Technologies '
,, (selected remedial alternative is in bold) i
v, . - •
Alternative
RAA-4
RAA-5
(RAA-2)
Innovative Technology
Excavation/on-site vitrification/off-site
disposal at RCRA landfill
Excavation/on-site soil washing/on-site
disposal •--•'"•

Estimated Costs
3Ci
$5,i:
•iteiia
36,000
$322,000
9 Criteria
eliminated
$322,000
-2-
1291
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7. How did the cost(s) compare to standard technologies?

Cost Estimates for RAAs That Include Standard Technologies
(selected remedial alternative is in bold)
$
Alternative
RAA-1
RAA-2
(RAA-1)
RAA-3
RAA-6
(RAA-3)
RAA-7
Standard Technology
Capping '
Excavation/off-site treatment and
disposal at RCRA landfill
Excavation/stabilization/splidification/
off-site disposal at RCRA landfill
In situ stabilization/solidification
No action/ground water monitoring
==r!=^====^======
Estimated Costs
3 Criteria
$126^000
$330,000
$285,000
$208,000
$109,000
9 Criteria
eliminated
$265,000 to
$330,000
eliminated
$208,000
eliminated
8. If a standard technology was chosen, why?

RAA-2 was chosen because it provides long-term protection to human health and the
environment by removing the contaminated soil and eliminating it as a potential source of
ground water contamination. These measures also eliminate exposures via inhalation and
mgestion of contaminated particles, dermal contact with contaminated soil, and ingestion of
contaminated ground water. Off-site treatment and disposal restricts contaminant mobility.
This alternative presents no unacceptable short-term risks or cross- media impacts. Air
monitoring and dust control measures eliminates any potential exposure caused by excavation
This alternative complies with all ARARs. It provides a permanent solution with a proven
technology. It provides minimal uncertainty and minimal long- and short-term risk. It is the
most reliable option and. can be implemented with less difficulty and no greater short-term
impacts than the other treatment alternatives.. It can be readily implemented since there are
two suitable landfill sites in the Pacific Northwest and licensed haulers are readily available for
transport of the waste. It is the cost-effective option since other treatment options require
treatabihty testing which could significantly increase costs.
9. If an innovative technology was chosen, why?

An innovative technology was not chosen.
70.
1292
If an innovative technology was not chosen, why not? At what stage was the innovative
technology eliminated? .

• In situ soil flushing was eliminated because the upper unit of the overburden presents a
complex geologic system of silts and clays that could .direct flushing solutions into the
underlying aquifer. ' • .' ••'....
• Wet air oxidation was eliminated because volatile metals could vaporize, a significant
concentration of metals would remain in the byproducts requiring disposal in a secure
landfill or further treatment, and costs would be high.
• Molten salt was eliminated because volatile metals could vaporize, a significant
concentration of metals would remain in the byproducts requiring disposal in a secure
landfill or further treatment, and costs would be high. i

Innovative technologies eliminated during the screening of the three criteria include the
following: ,

• Ex situ vitrification was eliminated because its effectiveness is uncertain. Contaminant
mobilization could occur during excavation. The technology has not been widely
adapted from the nuclear waste industry to the hazardous waste industry. Also,
because of the small volume of waste, using an on-site waste unit would be most
efficient. According to Horsehead Resource Development Company, who have
developed a flame reactor that is presently being studied under the EPA Superfund
Innovative Technology Evaluation (SITE) demonstration program, it would not be
cost-effective to construct a unit on site to treat such a small volume of waste.

Innovative technologies eliminated during the detailed analysis inclucje the following:

• On-site soil washing was eliminated because its effectiveness and reliability are
uncertain and it would require treatability studies. The studies would increase the time
to implement the alternative and increase the costs. This alternative would l?e the most
difficult to implement. The technology requires that mobile iequipment be transported
to the site. The reliability of this process is not well- known, a Mi-scale study has not
been completed and it is not considered widely available for use. The equipment and
personnel would have to be highly specialized. This alternative would pose
considerable short-term risk due to dust generation because of the required soil
handling. .
' ' ' ' * ' • ' l - .
11. Which of the nine criteria were weighted most heavily in selecting the technology? Did failure
to meet one of the nine criteria result in the elimination of the innovative technology? If so,
which criterion? Which of the criteria supported the use of a standard technology?
' '.
The criteria that were weighted most heavily in selecting a remedial alternative were protection
of human health and the environment, impiementability, and cost, llie chosen alternative
protects human health through treatment of site soil and is readily ithplementable. Other
alternatives, RAA-2 and RAA-3, would provide as great or greater protection but would be
more difficult to implement due to uncertainty associated with their reliability and
effectiveness and both would require treatability testing prior to implementation. Treatability
studies in turn could lengthen the time required for these alternatives or increase their costs.
Soil washing was eliminated due to difficulty in implementation and potentially high costs.
1293
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12.
,, based on an ARAR- what was
What risk level was selected to establish cleanup goals?
=======:
Contaminant
Carcinogens
Arsenic
Chromium
Lead
Nickel
DDT
Noncarcinogens
Barium
Cadmium
Selenium
Cyanide
"""" —
1
Cleanup Level (mg/kg)
T========s:
ARAR or Other Basis

20
400
250
1,600
2.9
MCTA"
. Riskb
MCTA
Risk
MCTA .

4,600
40
240
1,600
===^===
Risk
Risk
Risk
Risk
'
'Cleanup levels were set at natural background as determined by Washington State
Toxics Control Act (MCTA) Method A. .
••Risk was calculated by Ecology and Environment, according to MCTA Method B
. cleanup standards for residential sites. An acceptable range of risk includes for
carcinogens, an excess upper bound individual lifetime cancer risk of between lO"4 to
10 and for noncarcinogens, a Hazard Index less than or equal to 1.0.

Was the innovative technology eliminated because of the cleanup goals? Could the standard
technology meet the cleanup goals? • ««««««*

Innovative technologies eliminated because of cleanup goals include:

" None

Standard technologies eliminated because of cleanup goals include:

• Capping .
14. Were treatability studies conducted on the innovative technology or standard technology? •

Treatability studies were not conducted.
1294
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15. What measures/criteria were used to compare alternatives? i '

The following measures were used to compare the alternatives:

. - Proven reliability i
Impact on nearby populations
.•-•.. .'•.'•' ,\

16. How are measures compared? .'..--
; • l
Proven reliability played a major role in selecting a remedial alternative. The chosen
alternative removes site contaminants and treats and disposes of them off site. This alternative
utilizes readily implementable and reliable technologies. The chosen alternative was preferred
over treatment on site, either with stabilization or soil washing, because these technologies
would require treatability studies. Treatabijity studies could in turn significantly increase the
time and cost to complete these alternatives. The community was another factor in selecting a
remedial alternative: Dust generated during soil washing was a source: of concern-due to .the
potential for worker or community inhalation exposure. And on-site stabilization was not
preferred because it would restrict future site use. I

17. What technical considerations werefactors in selecting a remedy'!'Were technical
considerations primary in the selection of the remedy?,

The complex geological system of clay and silts precluded the use of soil flushing due to the
potential for flushing solutions into the aquifer. This factor, however, jwas not primary in
selecting a remedial alternative.
1295
V : • ' - '
-6- ' • "• .•-.', ... . ' ' •.•• ',
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i-a.
'.It
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