United States      '  Office of Policy       EPA-230-03-89-043
            Environmental Protection    Planning and Evaluation    June 1989
            Agency          (PM-220)
oEPA     The Nature And Extent
            Of Ecological
            Risks At
            Superfund Sites
            And RCRA Facilities

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                                       EPA-230-03-89-043
       THE  NATURE AND  EXTENT OF
ECOLOGICAL RISKS AT SUPERFUND  SITES
           AND RCRA FACILITIES
               Office of Policy Analysis
        Office of Policy, Planning, and Evaluation
          U.S. Environmental Protection Agency
                  Washington,  D.C.
                                    Tn;i:~! O. Protection Agency



                             Chicago i  ฃk  60iiU4
                    June 1989

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                               ACKNOWLEDGEMENTS
      This document was developed by EPA's Office of Policy Analysis (OPA)
within the Office of Policy, Planning, and Evaluation.  Dr. Craig Zamuda was
the EPA project director, with support provided by Dr. Dexter Hinckley, Mr.
Mike Cox, and Mr. Ron Benioff.

      IGF Incorporated assisted OPA in development of this document.  The IGF
project team was directed by Bill Ward and Steve Wyngarden, and included
Margaret McVey, Scott Redman, Simon Heart, Charles Chappell, Andrea
McLaughlin, Michael Troyer, Laura Boccutl, Steve Heurung, Baxter Jones, and
Randy Freed.

      The authors of this document wish to acknowledge,  with appreciation, the
inputs, cooperation, and review provided by the many other people who
contributed to the project.  This includes numerous individuals within the
Department of the Interior (Fish and Wildlife Service and Office of
Environmental Project Review),  the National Oceanic and Atmospheric
Administration, all ten EPA Regions, EPA Laboratories, EPA Headquarters, and
several State organizations.

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                              TABLE OF CONTENTS



                                                                        Page

EXECUTIVE SUMMARY  	  i

I.    SUPERFUND SITES

      1.    INTRODUCTION	1-1

      2.    METHODS USED IN THIS REVIEW	1-3

            2.1   Identification of Sites	1-3
            2.2   Collection of Reports	1-4
            2.3   Review/Analysis of Reports 	  1-4

      3.    CHARACTERIZATION OF SAMPLES OF SITES	1-7

            3.1   Sample of All Sites Identified as Potentially
                  Posing Threats 	  1-7
            3.2   Sample of 52 Sites Analyzed in Detail	1-8

      4.    NATURE AND EXTENT OF ECOLOGICAL THREATS AT
            SUPERFUND SITES	1-13

            4.1   Amount of Documentation	1-13
            4.2   Nature of Threats at 52 Sample Sites	1-15
            4.3   Extent of Threats at 52 Sample Sites	1-16
            4.4   Analysis of Trends	1-22

      5.    DISCUSSION AND CONCLUSIONS 	  1-27

            5.1   Generalizations Across Sample of 52 Sites	1-27
            5.2   Generalizations Across All Superfund Sites 	  1-29

      PART I REFERENCES	1-35

II.   RCRA FACILITIES

      1.    INTRODUCTION	II-l

            1.1   Major Limitations and Caveats of this
                  Assessment	II-2
            1.2   Guide to the Remainder of Part II of
                  the Report	II-2

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                        TABLE  OF  CONTENTS  (continued)
      2.    APPROACH	II-4

            2.1   Program Analysis and Regulatory Development
                  Documentation	II-4
            2.2   Interviews and Meetings with RCRA Professionals .  .   II-5
            2.3   Case Study Analysis	II-5

      3.    RESULTS:  NATURE AND EXTENT OF ECOLOGICAL THREATS
            AT RCRA FACILITIES	II-7

            3.1   Subtitle C Facilities	II-7
            3.2   Subtitle D Facilities	11-17
            3.3   Mining Waste	11-18
            3.4   Oil and Gas Waste	11-22
            3.5   Coal-Fired Utility Waste 	  11-26
            3.6   Smelting and Refining Waste 	   11-31

      4.    SUMMARY AND CONCLUSIONS	11-35

            4.1   Summary of Extent and Nature of Ecological
                  Threats at RCRA Facilities	11-35
            4.2   Summary of Ecological Threat Characteristics
                  Among RCRA Program Areas	11-37

      PART II BIBLIOGRAPHY	11-40

APPENDIX A:  MASTER LIST OF SUPERFUND SITES IDENTIFIED AS
             POTENTIALLY HAVING ECOLOGICAL RISKS/IMPACTS 	    A-l

APPENDIX B:  ECOLOGICAL THREAT DATA FOR INDIVIDUAL SUPERFUND
             SITES	    B-l

APPENDIX C:  DETAILED SUMMARY OF ECOLOGICAL THREAT DATA
             FOR SUPERFUND SITES	    C-l

APPENDIX D:  REGIONAL AND STATE RCRA CONTACTS AND INTERVIEW
             SUMMARIES	    D-l

APPENDIX E:  DETAILED SUMMARY OF RCRA SUBTITLE C FACILITY
             CASE STUDIES	    E-l

APPENDIX F:  CONSTITUENTS IDENTIFIED IN RCRA PROGRAM AREAS	    F-l

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                              EXECUTIVE  SUMMARY
      The Office of Policy Analysis (OPA) within the U.S.  Environmental
Protection Agency (EPA) Office of Policy, Planning,  and Evaluation has been
conducting a study of the ecological risks posed by Superfund sites and RCRA
facilities.  In June 1989, OPA completed the first phase of this study and
published the following four reports that document the study's findings:

      •     "The Nature and Extent of Ecological Risks at
            Superfund Sites and RCRA Facilities," EPA-230-03-89-
            043 (June 1989).

      •     "Ecological Risk Assessment Methods:  a Review and
            Evaluation of Past Practices in the Superfund and RCRA
            Programs," EPA-230-03-89-044 (June 1989).

      •     "Ecological Risk Management in the Superfund and RCRA
            Programs," EPA-230-03-89-045 (June 1989).

      •     "Summary of Ecological Risks, Assessment Methods, and
            Risk Management Decisions in Superfund and RCRA," EPA-
            230-03-89-046 (June 1989).

      This report presents the results of OPA's effort to characterize the
nature and extent of ecological risks at Superfund sites and RCRA facilities.
The report is divided into two main parts; Part I addresses Superfund sites
and Part II addresses RCRA facilities.  Key findings from both of these parts
are summarized below.
I.    SUPERFUND SITES

      In this part of the study, Superfund sites with observed or projected
ecological threats were identified through a telephone survey and literature
review.  Data on the nature and extent of ecological threats at a sample of 52
National Priorities List (NPL) sites were then extracted from available site
reports.

      Roughly 90 percent of the sites reviewed are threatening fresh water
ecosystems.  Threats to terrestrial ecosystems have been observed or projected
at slightly less than 50 percent of the sites.  Soil, ground water, surface
water, and surface water sediments were all frequently observed to be
contaminated at the sample sites.  Fish or aquatic invertebrates were observed
or projected to be contaminated at approximately 70 percent of the sample
sites, with these organisms displaying a variety of toxic effects.  When
noted, adverse terrestrial effects took the form of damaged or killed
vegetation, loss of habitat, contamination or loss of food sources, and in a
few cases, projected toxic effects to birds and mammals.

      This study's data suggest that the extent of threats varies widely
across Superfund sites, both in terms of the area affected and magnitude of
impact.  From a relative standpoint, 10 percent of the sample sites present
particularly severe ecological threats, characterized by high levels of

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                                      ii

environmental contamination spread over relatively large areas with large
ecological populations that are (or could be) exposed.  Another 10 percent
present relatively minor threats,  characterized by low levels of environmental
contamination confined to small areas and relatively small numbers of
potential ecological receptors.  Therefore, 80 percent of the sample sites
pose relatively moderate threats,  characterized by potential acute threats in
small areas and possible chronic or low-level threats spread over larger
areas.

      A wide variety of waste types, waste management practices, and
environmental settings is represented in the sample.  However, the most common
scenario involves municipal/commercial/industrial waste commingled in a
landfill close to a surface water body or wetland.  Almost 40 percent of the
sites were noted have surface water onsite, most commonly drainage ditches or
small creeks that appear to act as conduits for waste constituent migration,
as well as habitat for aquatic receptors.  The most frequently encountered
contaminants in the sample are lead, cadmium, arsenic, chromium, zinc, VOCs,
PCBs, and PAHs.

      While the 52 sample sites studied in this analysis may not be
statistically representative of all Superfund sites, they are illustrative of
the various kinds of sites on the NPL.  Firm conclusions about the overall
extent and significance of ecological threats at Superfund sites cannot be
drawn because of a lack of detailed ecological data (especially data on the
extent of ecological threats), a lack of ecological toxicity reference levels,
scientific uncertainties about the response of ecosystems to chemical
contamination, and a lack of Superfund policy on what constitutes a
"significant" effect.  However, generalizations about the significance of
these effects include the following observations:

      •     Almost all of the sites in the sample have
            contaminants present that are acutely toxic to aquatic
            organisms when present in sufficient concentrations;
            however, in the sample studied, very intense (or
            acute) effects were observed or projected at only a
            small fraction of the sites or appeared to be limited
            to small areas;

      •     Contaminants present at most of the sample sites are
            persistent and bioaccumulative, and thus may present
            long-term ecological threats if not cleaned up;

      •     Slightly more than half of the sample sites appear to
            be threatening unique, vulnerable, commercially
            important, or recreationally important resources; and

      •     The threats at individual sites must be considered in
            the context of the large number of Superfund sites in
            order to assess the aggregate national extent of
            ecological threat.  Based on this study's data, a very
            rough, preliminary estimate is that as many as a third

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                                      iii

            of all Superfund sites have the potential for
            significant ecological threats.
II.   RCRA FACILITIES

      OPA analyzed the nature and extent of ecological threats at RCRA
facilities through an investigation of six RCRA program areas:  Subtitle C,
Subtitle D, mining, coal utilities, oil and gas, and smelting and refining.
OPA conducted the analysis of the extent of the ecological threats at these
facilities by investigating a number of Regulatory Impact Analyses and other
broad regulatory and policy analyses previously conducted by the Office of
Solid Waste and the EPA Regional offices.  OPA's examination of the nature of
these threats included a review of these OSW studies and was further enhanced
through the development and analysis of damage case studies developed for each
RCRA program area.

      Extent

      The extent of ecological threats at RCRA facilities has been generally
described in Regulatory Impact Analyses,  Reports to Congress, Background
Documents, and special reports prepared by OSW and the Regions.  Although few
of these sources investigate the extent of ecological impacts in great detail,
they do provide some indication of the problem.  OSW estimates that 17 percent
of all Subtitle C TSDFs will require surface water cleanup, 34 percent will
require soil cleanup, 30 percent will require ground-water cleanup, and seven
percent of the facilities will require air cleanup.  Roughly 11 million
barrels of oil and gas drilling wastes are released annually from over 9,000
spills.  In addition, an estimated 26 percent of the active mining and 32
percent of the coal utility facilities are within five kilometers of sensitive
environmental areas.  Seventy-eight percent of the phosphate mines sampled
were within five kilometers of wetlands,  and 60 percent of mining waste
management case studies reported effects on non-human biota.  Although little
is presently known concerning the characteristics of ecological damage
resulting from these releases, waste management activities conducted under all
of these RCRA program areas appear to pose a substantial potential threat to
the environment.

      Nature

      The precise nature of the ecological threats at RCRA facilities is not
well understood, but OPA identified and analyzed a number of examples of
observed and predicted ecological damages at RCRA facilities.  Exhibit ES-1
presents a summary, prepared by OPA, of the observed ecological threat
characteristics of each RCRA program area in terms of the observed ecological
damages, waste management practices, environmental settings, and principal
waste types.  Based on these examples, OPA summarizes the nature of ecological
threats posed by RCRA facilities as follows.

      •     The severity of ecological threats depends on

                  environmental setting (e.g., wetlands),

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                                                                         EXHIBIT ES-1
                                               OBSERVED ECOLOGICAL THREAT CHARACTERISTICS OF BCRA raOGBAM AREAS
Program Area        Observed Ecological Damages

Subtitle C      • Mortality - fish and vegetation
                  kills
                • Decreased species richness and
                  diversity
                • Increased body burden of
                  toxicants
                • Decreased productivity
                • Altered life cycles
                • Habitat alteration
Subtitle D      • Impaired overall health and
                  fertility of freshwater and
                  estuarine fish and macro-
                  invertebrates
                • Potential for contamination to
                  all environmental media and
                  thus widespread effects to
                  terrestrial and aquatic species

Mining          • Fish kills
                • Impairment and reduction in
                  bird, benthic and other aquatic
                  organisms population
                • Bioaccumulation in terrestrial
                  organisms
Oil and Gas     • Chronic and acute damages
                • Fish kills, benthic
                  invertebrate population
                  reductions
                • Reduced fertility and growth in
                  aquatic species
                • Vegetation damage
                • Bioaccumulation
                • Alteration of community
                  structure

Coal-Fired      • Fish kills
Utility         • Eradication of bottom-dwelling
                  organisms and other aquatic and
                  terrestrial plant and animal
                  life
                • Chronic effects also likely
Smelting        • Chronic and acute damages to
and               aquatic organisms
Refining        • Surface water contaminant
                  concentrations >400 times AWQC
  Haste Management Practices

Landfills
Surface impoundments (unlined)
Container storage
Hastewater discharge
Waste piles
Uncontalned disposal (e.g.,
dumping to surface waters) of
combustion fly ash
Storage in unlined landfills of
all municipal wastes
Tailings ponds
Haste storage piles
Haste hauling
Surface impoundment
Cyanide wash stored in drums
Drilling operations
Storage and disposal of
drilling wastes in faulty
surface impoundments
Injection or discharge of
process waters to ground
surface
Improper storage or mishandling
of waste sludges and fly ash
wastes
Illegal or improper dumping of
wastes
Failure of surface impoundments
On-site wastewater settling
ponds
Cryolite sludge lagoons
Storage and disposal of spent
potliners
	Environmental Settings

• Near surface waters
e Wetlands
e Special habitats (i.e.,
  endangered and protected
  species habitat, and wildlife
  refuge)
                                                                                                                                            Haste Types
  Limited available data
  13 percent of facilities in
  100-year floodplain
  6 percent in wetland areas
                                     • Near surface waters
  Near surface waters
  Desert or tundra environment
  Limited available data
  Predominantly near surface
  water bodies
  Over 70 percent within 2,000
  feet of surface water
Metals - Cr, As, Fb, Eg
Aromatic hydrocarbons
and substituted aromatic
compounds
Solvents
Other VOCs
Creosote
PCBs
Acids
Alkali
Pesticides

Particulates
BOO
Microbes
Heavy Metals
Pesticides
VOCs
PCDFs
PCDDs

Tailings, overburden,
leachate solution, and
mine water containing:
cyanide, arsenic,
copper, zinc, cadmium,
lead, cobalt, silver,
chromium, iron, TSS, pH

Drilling muds,
production brines,
wastewater, and oil
field effluents and
fracturing fluids
containing:  chlorides,
benzene, lead,
phenanthrene, barium,
arsenic, fluoride,
antimony

Fly ash wastes
containing heavy metals
(aluminum, arsenic,
barium, cadmium,
chromium, copper, lead,
mercury, selenium and
silicon)

Spent potliners,
cryolite slurries,
cryolite sludges, slags,
and process fluids
containing:  zinc,
copper, cyanide, lead,
cadmium and Hunrida

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                  facility size (i.e., quantity of wastes released),
                  toxicity characteristics of the constituents released, and
                  the nature of the release event itself (e.g., flooding,
                  leaching to soil).

      •     Observed ecological damages from RCRA facility releases have been
            long- and short-term in nature, and include fish kills, diseased
            or desecrated benthic habitats, chronic or behavioral effects on
            aquatic and terrestrial plant and animal species, oyster
            mortality, reduced floral and faunal species diversity, and
            reduced productivity in wetland habitats.

      •     Evidence of potential ecological effects include increased
            contaminant body burdens in aquatic species, concentrations in
            water and soil that exceed water quality criteria or other
            measures of aquatic toxicity.  Sparse vegetation and contaminated
            soils are also reported at many facilities.

      •     Host ecological damage was characterized in aquatic ecosystems.
            It is not clear whether the majority of ecological damage actually
            occurs in aquatic habitats, or it is simply easier and, therefore,
            more common to characterize impacts in this medium.

      •     Ecological damage was most often caused by the improper disposal
            or storage of wastes in unlined landfills or surface impoundments.
            Storage in waste piles and application of wastewaters to the land
            have also been noted as significant sources of damage.

      •     The contaminants associated with ecological damage include
            virtually all waste types managed at RCRA facilities.  For
            example, the heavy metal wastes found at large volume waste
            facilities have been implicated in a number of damage cases.

      Conclusions

      This analysis of facility characteristics identified some discernible
patterns concerning practices, settings, and wastes that pose the most severe
ecological threats.  However, it is questionable whether quantitative
projections of the frequency of the characteristics can be made for the RCRA
facility population as a whole based on these results.   Such extrapolations
are tenuous, mainly due to the limited nature of the available data
characterizing the RCRA facilities and the lack of representativeness (in a
statistical sense) of the sites examined.  Sufficient data to accurately
characterize the nature and extent of ecological impacts at RCRA facilities
are generally not available.   Nonetheless, this study found that many RCRA
facilities have released hazardous substances into wetlands,  floodplains,
surface waters, or in ecologically vital or sensitive habitats, and these
facilities should be considered a potential source of ecological damage.
Perhaps the most significant conclusion to be drawn from this analysis is that
the wide range of hazardous and non-hazardous substances managed at RCRA
facilities, the numerous release and ecological exposure pathways,  and the
diverse nature of the observed ecological impacts indicate that releases from
these facilities have the potential to affect all environmental media and
major ecosystem types.

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PART I:  SUPERFUND SITES

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                                   CHAPTER  1

                                 INTRODUCTION
      Hazardous substances released from sites subject to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA,  or Superfund)
have the potential to damage ecosystems and their components in addition to
the potential to adversely affect human health.   Thus far in the Superfund
program, however, EPA has focused primarily on analysis and mitigation of
human health risks rather than ecological risks.   Limited analysis and
assessment shows that ecological injury has been observed or is predicted to
occur at some Superfund sites, but the overall nature and extent of ecological
risks have not been thoroughly assessed.

      This lack of information on ecological risks appears in part to result
from a general lack of EPA policy in the areas of ecological assessment
methods and ecological risk management under Superfund.  To help fill this
gap, OPA has conducted a study of three broad topics:  (1) the nature and
extent of ecological risks at Superfund sites; (2) the ecological assessment
methods that have been used in the Superfund program; and (3) ecological risk
management decisions and issues at Superfund sites.  OPA also has studied
these same topics as they pertain to the Resource Conservation and Recovery
Act.1

      The purpose of this report is to present the results of OPA's effort to
characterize the nature and extent of ecological threats at Superfund sites.
The report provides background information on the different types of
ecological threats at a sample of 52 sites, the  frequency of occurrence and
magnitude of those threats,  and discernible patterns in key parameters that
influence ecological threats (e.g., release sources and pathways, chemical
constituents, and environmental settings and receptors).  These data provide
background information that supplements OPA's studies of ecological assessment
methods and ecological risk management issues in the Superfund program.
Collectively, the results from these reports are intended to serve as the
basis for conclusions on the adequacies of existing Superfund policies for
ecological protection, opportunities for program improvements, and needs for
further study.

      This report includes data on the nature and extent of both actual,
observed ecological impacts and predicted ecological impacts (i.e., risks) at
Superfund sites.  The term ecological "threat" often is used in the report to
refer to both observed and predicted impacts.  Contamination of and adverse
effects to biota are examined, as is media-specific contamination that may
pose a risk to biota.  The report primarily focuses on baseline ecological
threats that exist(ed) before response actions have been (were) taken, not the
ecological problems caused by a response action or the residual threats after
a response.  The report's scope also is limited to an analysis of threats
caused by hazardous substance releases subject to control under Superfund;
     1 Separate reports that analyze  ecological  assessment methods  and risk
management issues in the Superfund and RCRA programs have been prepared (see
the Executive Summary of this report for a full  cite for these other reports).

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                                      1-2

ecological threats caused by other site operations, such as construction
activities, are not covered.

      An unavoidable limitation in the scope of this analysis is that all of
the Superfund sites examined for ecological information are remedial sites,
and primarily sites that are on the National Priorities List (NPL).   Very few
removal sites or non-NPL sites were examined because the analysis is based on
information documented in available site reports, and limited documentation
was available that describes ecological issues at these kinds of sites.

      The remainder of this part of the report is divided into four chapters.
Chapter 2 outlines the methods used to conduct the study.  Chapter 3 presents
and characterizes the sample of all Superfund sites identified as potentially
posing ecological threats, including the subset of 52 sites selected for in-
depth review.  In Chapter 4, data on the nature and extent of ecological
threats at these 52 sites are summarized and, in Chapter 5, conclusions based
on the data summaries are presented.

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                                      1-3

                                   CHAPTER 2

                          METHODS  USED IN  THIS  REVIEW
      The primary goals of the data collection effort undertaken in this study
were to collect data for a reasonably large and diverse sample of Superfund
sites, to focus on sites with recognized ecological threats, and to focus on
sites where ecological threats have been studied in relative detail.  Although
another goal was to examine a representative sample of sites if possible,
several difficulties in obtaining and studying a representative sample were
encountered.  These difficulties included a lack of ecological assessment
documentation for non-NPL sites, an inability to obtain relevant documentation
for certain NPL sites, and an insufficient base of existing ecological threat
information by which to judge whether a site is "representative."

      The methods used to collect and analyze data for this study involved
three steps:  (1) identification of candidate Superfund sites with known or
suspected ecological impacts; (2) collection of relevant reports on each of
the identified sites; and (3) review and analysis of the collected reports.
The specific approach to each of these steps is described in the following
subsections.

2.1  Identification of Sites

      A telephone survey was conducted to ask people in government agencies to
identify Superfund sites that have ecological threats.   An initial list of
primary people to call for this purpose was developed by drawing from the list
of members of an interagency workgroup assembled by EPA's Office of Waste
Programs Enforcement and Office of Emergency and Remedial Response to prepare
the "Risk Assessment Guidance for Superfund--Environmental Evaluation Manual."
Additional people to call were then identified by references from the primary
contacts.  In selecting prospective contacts, an effort was made to call
people distributed in different areas of the U.S. and to call both EPA and
non-EPA personnel, in order to gain a variety of perspectives.  For example, a
point was made to contact several representatives from other agencies
designated as natural resource trustees under Superfund.  In total, more than
50 people were contacted, including representatives of EPA Headquarters and
Regions, the Department of the Interior (DOI),  the National Oceanic and
Atmospheric Administration (NOAA), and state Superfund offices.  In some
cases, follow-up meetings were held with representatives from these
organizations.

      In addition to the telephone contacts and meetings, Superfund sites with
actual or potential ecological impacts were identified through an independent
literature review.  Key sources that were examined for this purpose are
identified in the reference list at the end of this report.

      In general, a Superfund site was added to the list of sites potentially
posing ecological threats if a personal contact or a report indicated that
hazardous substance releases from the site resulted in contamination of or

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                                      1-4

adverse effects to biota, or resulted in significant contamination of
environmental media that posed a risk to biota.  Sites were not added to the
list if it appeared that they mainly have ground-water contamination that is
not near the land surface or discharging to the surface where it could
adversely affect biota.  Although no independent analysis was conducted to
verify that each site identified actually poses an ecological threat, many
sites were identified through multiple sources.  Similarly, numerous candidate
sites that were identified initially through the independent literature review
were later dropped from consideration after additional information was
obtained through telephone and personal contacts.

      Through the process outlined above,  247 Superfund sites identified as
potentially posing some level of ecological threats were identified.  This
sample of sites is identified in Appendix A and characterized in Section 3.1
below.

2.2   Collection of Reports

      Reports describing the ecological impacts and risks at the sample of 247
sites were collected for as many sites as possible, given the time available
for the project.  The primary source of these reports was EPA Regional
offices.  The type of report that was sought in particular for each site was
the remedial investigation (RI) and/or feasibility study (FS);  however,
separate risk/endangerment assessments, special environmental studies, and
records of decision (RODs; Superfund program documents that explain the remedy
selection decision for specific sites) were collected when available.  Many of
the sites were only in the RI/FS planning stage and, in these cases, RI/FS
workplans or other planning documents that summarize the site conditions were
often collected.  Site-specific reports, containing varying levels of detail,
were collected for a total of 103 (42 percent) of the 247 sites.

2.3   Review/Analysis of Reports

      A subset of the 247 sites was selected for the purpose of extracting and
compiling data on ecological threats.  This subset was selected based
primarily on the quantity and apparent quality of documentation collected for
each site.  Only those sites for which at least an RI, a detailed FS, or a
detailed risk/endangerment assessment had been obtained were selected for
review.  Using these criteria, the reports available for 52 sites were
reviewed in detail.

      Relevant information was extracted in summary form from the various site
reports through the use of a worksheet.  The worksheet included questions to
be answered by individual report reviewers in an attempt to extract consistent
and complete information on the status of ecological threats at each site.
After the worksheets were completed for all 52 sites, summary data were
compiled using data on the individual worksheets.

      There are several important caveats concerning the process used to
select reports for review and the process used to extract and compile relevant
data.  First, as described above, the 52 sites that were examined in detail
were selected primarily based on the amount and quality of information

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                                      1-5

available for the sites, not because of any particular features about the
sites themselves (such as geographical distribution, types of release sources,
or types of wastes managed).   This sample,  therefore,  was not intended
necessarily to be representative of the full universe of Superfund sites, or
even a certain category of Superfund sites.  It was intentionally biased to
include sites with known or suspected ecological threats and at least a
moderate level of site documentation.  Aspects of the "representativeness" of
the sample are discussed in Section 3.2 below.  Key caveats associated with
the process used to extract and compile data on ecological threats include the
following:

      •     The ecological threat information contained in the
            various reports was assumed to be accurate.   No
            independent analysis of the sites was conducted to
            verify the accuracy of the data contained in the site
            reports.

      •     As discussed in more detail in Section 4.1,  the
            reports reviewed varied widely in terms of the methods
            used to assess ecological threats and the detail in
            which those threats were described.  This generally
            was true even for sites that appeared to have
            ecological threats of the same basic nature.  As a
            result, the type of data and the level of detail
            extracted from individual reports were variable.

      •     Extracting data from individual site reports and then
            aggregating data across sites required putting the
            data into defined categories.   For example,  ecological
            threat data were differentiated depending on whether
            they were for actual vs.  proj ected effects and whether
            they pertained to biota vs. environmental media.
            Similarly, all the different types of environments
            potentially affected at the sites were put into basic
            categories (e.g., freshwater rivers, estuaries,
            terrestrial) for the purpose of developing summaries.
            Using such categories introduces some uncertainty
            because it results in the data being simplified, and
            considerable judgment on how to categorize the data is
            required.

      •     Several of the 52 sites studied in detail have been
            divided into two or more operable units for the
            purpose of remediation.  A few of the reports reviewed
            for those sites only address one operable unit and
            thus do not provide complete information on the
            ecological threats posed by the site as a whole.  This
            problem was exacerbated for a small number of sites
            because the available reports  covered operable units
            with little ecological impacts  (it appears that
            operable units with primarily ecological concerns may
            be evaluated and remediated on a slower schedule).

-------
                          1-6
Some of the reports reviewed were not final.  For 6
sites, only draft RI/FSs or draft risk/endangerment
assessments were available.  The ecological data
extracted from these reports, therefore, are subject
to change.

-------
                                      1-7

                                   CHAPTER 3

                     CHARACTERIZATION OF SAMPLES OF SITES
      As discussed in Chapter 2, a sample of 247 Superfund sites identified as
potentially posing ecological threats was identified.  From this sample, a
subset of 52 sites was selected and analyzed for the purpose of evaluating the
nature and extent of ecological threats.   This chapter characterizes the
sample of all sites identified (Section 3.1) and the smaller sample examined
in detail (Section 3.2).

3.1  Sample of All Sites Identified as Potentially Posing Threats

      The 247 sites identified as potentially posing ecological threats are
listed in Appendix A.  It is important to clarify that these sites do not
necessarily have significant ecological impacts/risks.   These are simply sites
that have been identified, through the methods described in Section 2.1, as
having the potential for significant ecological threats.   The threats at most
of these sites were not examined as part of this study, and it appears that
some of the sites have been examined very little, if at all, for the purpose
of characterizing ecological threats.

      The 247 sites are distributed over a broad area,  including 42 different
states and all 10 EPA Regions.  Over half of the sites are located in Regions
1,  2,  and 3, with New Jersey being the state that has by far the largest
number of sites.

      It appears that all of the 247 sites can be categorized as remedial
rather than removal sites.  However, earlier emergency or removal actions have
been taken at a number of the sites.  Roughly 190 of the 247 sites (77
percent) are currently on the NPL; most of the others are either proposed for
or recently deleted from the NPL.  Of the sites that are currently on the NPL,
13 percent are within the top 50 NPL sites, 28 percent are ranked lower than
number 500 on the NPL, and the remaining 59 percent are between numbers 50 and
500.

      Over half of the 247 sites were identified by NOAA as potentially
affecting coastal and marine resources under NOAA's trusteeship.  To identify
these sites, NOAA used a screening process that considers the proximity of the
sites to natural resources of interest to NOAA, the toxicity and persistence
of the waste constituents present, and the relative importance of resources
that are potentially affected by releases (NOAA 1987).   Slightly less than a
third of the sites were identified through conversations with EPA Regional
personnel and 13 percent of the sites  were identified by representatives from
DOI (both the Fish and Wildlife Service and the Office of Environmental
Proj ect Review).

      There is one other characteristic of this sample that should be noted.
Because of the way many of the sites were identified, it is likely that the
sample is biased toward sites that have more readily apparent or sensational
ecological effects.  Many of the sites were identified through the

-------
                                      1-8

recollection of individuals interviewed for this study, and it is likely that
those individuals were able to recall sites with particularly noteworthy
ecological problems.  Similarly,  other sites were identified by reviewing ROD
or RI/FS summaries, and it is more likely that ecological information was
documented in those summaries when the threats were relatively severe.   Thus,
sites with subtle effects or posing long-term threats are quite possibly
under-represented in the sample.

3.2  Sample of 52 Sites Analyzed in Detail

      As discussed in Section 2.3, a subset of 52 sites from the larger sample
of 247 sites was selected for the purpose of characterizing the nature and
extent of ecological threats.  The 52 sites analyzed in detail are identified
with an asterisk in Appendix A.

      The geographical distribution of this sample of sites is shown in
Exhibit 1-1.  The 52 sites are distributed over 25 states and nine EPA
Regions.  The only Region without a site in the sample is Region 7,  which also
is the Region with the fewest number of Superfund sites.  The distribution of
sites across the various EPA Regions is generally reflective of the
distribution of Superfund sites on the NPL.

       All 52 sites in the sample are categorized as remedial rather than
removal sites; however, earlier removal actions have been taken at some of the
sites.  All but two of the 52 sites are on the NPL.  Strictly in terms of
numbers of sites, therefore, the sample makes up roughly 4 percent of the
sites either currently on or proposed for the NPL.  Of the sample sites on the
NPL, roughly 70 percent are ranked higher than number 500, but only about 10
percent are ranked higher than number 50.

      The frequency of occurrence of major waste types, waste management
practices, and environmental settings represented by the 52-site sample is
shown in Exhibits 1-2 and 1-3.  The sites are comprised of a wide range of
waste types and management practices, but the most prevalent by far are sites
with mixed municipal/industrial wastes disposed in landfills.  The most
striking trend in terms of general environmental settings is that almost all
of the sites are either directly adjacent to a surface water body or drain
into a surface water body that is nearby (generally within one or two miles).
More than half of the sites are also close to wetlands, swamps, or marshes.

      Based on the above characterization, the sample of 52 sites analyzed for
this project appears to be reasonably representative of NPL sites in general.
It has a broad geographical distribution,  and it is comprised of a mix of
various waste types and waste management practices.  Given the relative
ranking of the sites on the NPL,  the sample is possibly biased toward sites
with generally higher priority human health threats (as ranked by Hazard
Ranking System scores).  Following the same rationale outlined in Section 3.1,
it is also possible that the sample is comprised of sites that have relatively
sensational or readily apparent ecological threats.

-------
                                             EXHIBIT 1-1

                       GEOGRAPHICAL DISTRIBUTION OF  52  SITES ANALYZED  IN  DETAIL a/
                                                                                                         VO
a/    Larger numbers denote EPA Region numbers;  smaller numbers represent the number of Superfund sites
      analyzed in each state for this project.

-------
          Frequency (%) of Sample Sites Where

                Waste Type Reported
                                    M

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-------
                                   1-11

                               EXHIBIT 1-3

           FREQUENCY  OF WASTE  MANAGEMENT PRACTICES AND
          ENVIRONMENTAL SETTINGS IN  THE  52-SITE  SAMPLE
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                                             Barrel  Landapraadlng
                                             Storag*
                        Waste Management Practice
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                                         faco Water-
                           Environmental Setting

-------
                                     1-12

                            EXHIBIT 3  (continued)

                 FREQUENCY OF VASTE MANAGEMENT PRACTICES AND
                 ENVIRONMENTAL SETTINGS IN THE 52-SITE SAMPLE


                                  FOOTNOTES
      a/ While several of the sites employed more than one waste management
practice, these are the practices that were principally implicated as the
sources of hazardous substance releases.

      b/ Site environments were classified as generally rural if surrounding
land uses are described in reports as being predominantly agricultural, rural,
residential, or light industrial in combination with one or more of the
preceding land uses.  Site environments were classified as generally urban if
surrounding land uses were described as commercial and/or industrial.

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                                     1-13

                                   CHAPTER 4

                   NATURE AND  EXTENT  OF  ECOLOGICAL THREATS
                              AT SUPERFUND SITES
      In this report, the term "nature" of ecological threats refers to
qualitative descriptions of the types of threats, including an identification
of the environmental media contaminated, the principal contaminants involved,
the biota or ecosystem potentially affected, and the type of adverse effects.
The "extent" of threats, on the other hand, refers to a quantitative
characterization of threats, such as estimates of areal extent of
contamination, the number of times contaminant concentrations exceed relevant
criteria, or the probability of occurrence of an effect.

      Detailed data on the nature and extent of ecological threats at each of
the 52 sites studied in this project are presented in Appendices B and C.  In
this chapter, the data are organized into summary exhibits to highlight trends
and key findings across the sample as a whole.  The chapter is divided into
four main sections.  In Section 4.1, the amount of ecological threat
documentation on which the summary data are based is reviewed.  Sections 4.2
and 4.3 summarize data concerning the nature of threats and the extent of
threats, respectively.  Finally, trends based on the sample data are analyzed
in Section 4.4.

4.1    Amount of Documentation

      The type and amount of documentation reviewed for the 52 sites is a
critical factor to consider when interpreting the results.  For example, it
would be wrong to conclude that there are no threats to terrestrial ecosystems
in the 52-site sample if very few of the sites were analyzed for terrestrial
effects.  Therefore, in this section, the documentation reviewed is analyzed
briefly in terms of the extent to which ecological threats were assessed and
the common types of ecological threats that were not addressed or addressed
only superficially.  This analysis is presented here only to help interpret
the results that are summarized in the rest of Chapter 4 and in Chapter 5.

      The extent of documentation and level of effort devoted to ecological
threat assessment varied substantially across the 52 sites included in the
sample.  In order to characterize and compare the ecological assessment
efforts at the sites, the site reports were ranked from 1 to 4 in terms of the
level of detail devoted to ecological threats.  A 1 was assigned to reports
with the least detail and a 4 was assigned to reports with the most detail.
It is important to clarify that a category 1 or 2 assessment did not always
appear inadequate.  Assessments that were put in these categories appeared
sufficient at a few sites that were in generally industrialized areas or,
based on available information, seemed to pose little ecological threat.  The
criteria used for each of these categories are summarized below.

-------
                         1-14

Site reports were put into category number 1 if one or
more of the following conditions were met:

      samples of environmental media or biota
      were not taken, or were taken only for the
      purpose of analyzing human health risks
      (e.g., only analysis of fish or livestock
      consumed by man);

      there was no analysis or discussion of
      observed or predicted effects to biota,
      except to point out that adverse effects
      might occur.

Site reports were put into category 2 if one or more
of the following conditions were met:

      contaminant concentrations in environmen-
      tal media were measured or predicted and
      compared to ecological protection
      criteria, but there was no analysis of
      contaminant levels in biota;

      contaminant levels in biota were examined,
      but primarily for  the purpose of human
      health risk assessment;

      potential effects  to biota were examined
      simply and qualitatively, but based on
      very little to no  site-specific
      information (such  as an identification or
      inventory of species actually in the
      vicinity).

Site reports were put into category 3 if the
conditions specified for category 2 plus one or more
of the following conditions were met:

      environmental media were sampled and
      limited sampling and analysis of biota was
      performed for the  purpose of ecological
      threat assessment;

      a comparison of environmental media
      concentrations to  ecological protection
      criteria was coupled with a relatively
      thorough analysis  of species actually
      present;

      a relatively detailed discussion was
      provided on the extent and magnitude of
      observed effects to biota at the site;

-------
                                     1-15
                  site-specific quantitative or qualitative
                  judgments were made at the population .or
                  community level.

      •     Site reports were put into category 4 if:

                  detailed environmental media and biota
                  sampling was conducted for the purpose of
                  ecological threat assessment (e.g., biota
                  on multiple trophic levels or potentially
                  exposed through different pathways were
                  examined); and

                  site-specific quantitative or qualitative
                  inferences were made at the ecosystem
                  level of organization.

      Based on this classification system, it was determined that ecological
threats were explicitly addressed at 46 (roughly 89 percent) of the 52 sites
included in the sample (i.e., the assessment at 6 sites was classified as
category 1).  Of these 46, the assessment of ecological threats was classified
as category 2 for 18 sites, category 3 for 19 sites, and category 4 for 9
sites.  Therefore, the ecological threat data presented in the rest of this
part of the report as well as in Appendices B and C are based on a body of
literature that, for the most part, provides a relatively detailed evaluation
of ecological threats at Superfund sites.

      However, the summary data presented in Sections 4.2 and 4.3 that follow
do not or rarely address certain types of ecological threats because those
threats were infrequently examined in the site reports (not necessarily
because those threats did not exist).  Observed effects to terrestrial
organisms were often not addressed or addressed very superficially in the site
reports.  Observed or predicted effects at the population, community, or
ecosystem levels were also usually not addressed.  Analyses of effects at
these levels was limited to approximately nine sites.  The reports reviewed
also provided little analysis of: (1) alterations of or adverse effects to
habitats; (2) effects of ecological exposures through the food chain, with
subsequent threats to organisms at higher trophic levels; (3) specific toxic
effects caused by the exposure of biota to contamination; and (4) the
probability of various adverse ecological effects (i.e., ecological risk).

4.2    Nature of Threats at 52 Sample Sites

      Data on the type and relative frequency of ecological threats at the 52
sample sites are summarized in Exhibits 1-4 through 1-7.  These exhibits
provide summaries across the sample as a whole; information on the nature of
ecological threats at individual sites is presented in Appendix B, and
Appendix C presents more detailed summaries of the data than presented in this
chapter.  Exhibits 1-4 through 1-7 are organized to show certain categories of
parameters that relate to ecological threats (e.g., type of ecosystem
affected, principal contaminants, biota contaminated, and biota exposure

-------
                                     1-16

pathways) and the approximate number of sites, out of 52, that fit into those
categories.  Because considerable judgment and uncertainty was involved in
placing each site into the defined categories, the numbers in the exhibits are
approximate and should be used only to compare the relative frequency of
occurrence of the different parameters.

      As shown in Exhibit 1-4, the general type of ecosystem most frequently
affected was freshwater systems.  Surface water, surface water sediments,
soil, and ground water (that discharges into surface waters) were all
frequently observed or projected to be contaminated.  In terms of principal
contaminants (see Exhibit 1-5), lead and volatile organic compounds were the
contaminants most frequently observed in the environment; however, they were
not necessarily the contaminants posing the greatest ecological risks at all
sites.  A variety of other inorganics and organics was also frequently
observed at these sites.   Exhibits C-l and C-2 in Appendix C provide a more
detailed summary of data on the type of ecosystem affected, media
contaminated, and principal contaminants at the 52 sample sites.

      Exhibit 1-6 identifies the biota that were observed or projected to be
contaminated at the sample sites, as well as the observed and projected
effects caused by this contamination.  As shown, the predominant types of
organisms contaminated were fish, vegetation,  and aquatic invertebrates.  A
variety of toxic effects to aquatic fauna were observed at approximately 25
percent of the sites and projected at another 45 percent.  Exhibit 1-6 also
shows that certain types of organisms,  such as mammals and birds, were rarely
observed to be contaminated, although the contamination of these organisms was
commonly projected.  Similarly, most adverse effects in general were projected
rather than actually observed, with some effects (e.g., toxicity to
terrestrial fauna) being very rarely or never observed.  Additional detail on
the biota contaminated and biological/ecological effects across the 52-site
sample is provided in Exhibits C-l and C-2 in Appendix C.

      Exhibit 1-7 focuses on actual and projected effects to "sensitive or
special" environments in the sample.  For the purpose of this exhibit,
wetlands were considered sensitive environments regardless of their size.
Estuaries were categorized as sensitive/special environments for the purpose
of this project because they are often important spawning areas.   Also, park
lands and nature study areas were grouped into a sensitive/special environment
category, not because these types of environments are necessarily sensitive
ecologically, but because they may be sensitive publicly.  A summary of the
nature of effects to these categories of environments is provided in Exhibit
C-3 in Appendix C.

4.3  Extent of Threats at 52 Sample Sites

      The reports reviewed for this project contained limited quantitative
information on the extent of ecological threats, and most of the information
that was available was limited to only a few sites.  In particular,
quantitative estimates of ecological risk (i.e., predicted impacts) were
almost non-existent.  Available information for these sites is summarized in
Exhibit 1-8 and is presented in greater detail in Exhibit C-4 in Appendix C.

-------
         Frequency (%) of Sample Sites Where

         Affected Ecosystem Observed/Projected
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-------
                                        1-20

                                    EXHIBIT  1-7

                     OBSERVED OR PROJECTED CONTAMINATION  OF
              SENSITIVE/SPECIAL ENVIRONMENTS  IN THE 52-SITE SAMPLE
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   LL
                    Wetlands  Endangered   Wildlife
                            Specie*     Refuge
                            Habitat/
                            Migration
                            Pathway
                                                  Estuary
Sensitive
Spawning/
Breeding
Areas
                                                                    Other
                                     Environment Type
      &/ This category includes state parks,  lakes adjacent to parks,  and
nature  study areas.

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                                                                       EXHIBIT 1-8

                                                             EXTEHT OF ECOLOGICAL IMPACTS a/
CATEGORY OF IMPACT
                              NO. OF SITES WITH
                            INFORMATION ON EXTENT
 CUMULATIVE
AREAL EXTENT
                                                 CONTAMINANTS/MAGNITUDE b/
Surface Hater
Contamination
    209 stream
    miles; and
    3,954 acres
    Concentrations of 8 metals,  PCBs,  and pentachlorophenol exceed AWQC 1.5
    to 414,000 times.
Contamination of
Surface Hater
Sediments
Soil Contamination
                                     15
    209 stream
    miles; and
    3,937 acres
                                                     2,240 acres
•   Observed contaminants include 7 metals, PCBs, and asbestos.

•   Concentrations frequently exceed background levels, ranging from 15 to
    820 times.

•   Volumes of 4 metals and FCB remaining in sediments range from 10 pounds
    to 229 metric tons per site.

•   Observed contaminants include 6 metals, PCBs, phenols, asbestos,
    nitroaromatics, and other organics.

•   Volumes of contaminated soil range from 17,000 to 535,000 cubic yards per
    site.

•   Concentrations frequently exceed background levels, ranging from 3 to
    2,600  times.
Fish Kills
                                                     27 stream miles
                          Severity of observed fish kills ranges from  100Z to  10Z  for  affected
                          areas.
Defoliation
                                                     2,014 acres
                       •   Observed contaminants include 3 metals  and pentachlorophenol.
Contamination/
Degradation of
Wetlands/Marshes
                                                     324 acres
                          Observed contaminants include 2 metals, oils,  and  PCBs.

                          Concentrations in sediments frequently exceed  background  levels.
a/ Explicit information was provided on the areal  extent or magnitude of  contamination for 28 of the  52  sites  in  the  sample;  information for only those
   28 sites is included in this exhibit.  See  Exhibit C-4  in Appendix C for  a more detailed presentation of  these data.

b/ Indicates degree to which contaminant levels  exceed  criteria  such as ambient water quality criteria  (AHQC).  Information on the exceedance of criteria'
   is not provided for soil and sediment contamination  because generally  applicable criteria for these media do not exist.

-------
                                     1-22

When available, information on both the areal extent and magnitude of
contamination and effects is provided.

      Based on these sample sites, there are three main observations about the
extent of ecological threats at Superfund sites.  First, the areal extent and
magnitude of contamination/effects vary significantly from site to site.  For
example, roughly 300 feet of tributary sediments at the Re-Solve site are
contaminated with PCBs, while the PCB contamination in sediments in Hudson
River extends approximately 200 miles.  The second observation is that the
ecological threats at some sites can be very intense.  For example, roughly
2,000 acres of a mountain side in the vicinity of Palmerton Zinc have been
completely defoliated.  Third, even though the extent of contamination at an
individual site may be relatively small, the cumulative extent across all
sites may be large.  For example, ignoring the magnitude of contamination, the
total area of soil contaminated across the 16 sites accounted for in Exhibit
1-8 is roughly 2,240 acres (240 acres if Palmerton Zinc is omitted).  The
significance of this point is made clearer when one considers that there are
approximately 1,200 sites on or proposed for the NPL and many of these sites
probably have soil contamination.

4.4  Analysis of Trends

      This section summarizes how ecological threats discussed above appear to
be associated with certain waste stream, waste management practice, and
environmental setting factors.  In addition, this section examines the common
characteristics of sites that appear to have the most severe ecological
threats.

      4.4.1  Waste Type, Management Practice, and Environmental
             Setting Factors

      Examining the various waste streams represented by the 52-site sample,
it does not appear that ecological threats are being caused by only a few
waste types or constituents.  In fact, Exhibits 1-2, 1-3, and 1-5 suggest that
a wide variety of waste types and constituents are contributing to ecological
threats at CERCIA sites.  The most frequently occurring waste type in the
sample (present at 33 percent of the sites) is municipal/commercial/industrial
waste commingled in a landfill, with the specific components and sources of
these wastes often being unknown.  The relatively high frequency of this waste
mixture illustrates the point that mixtures of several different chemicals,
rather than just one or two chemicals, are probably contributing to ecological
effects at most sites.  The most frequently encountered inorganics in the
sample were lead, cadmium, arsenic, chromium, and zinc; the most frequently
encountered organics were volatile organic compounds (e.g., benzene, toluene,
trichloroethylene), PCBs, and polynuclear aromatic hydrocarbons (e.g.,
naphthalene, benzo(a)pyrene).  The constituents most frequently linked with
fish kills were cadmium, copper, zinc, arsenic, chromium, volatile organic
compounds, and phenols; the constituents most frequently linked with
vegetation damage were lead, zinc, arsenic, chromium, cadmium, nickel,
polynuclear aromatic hydrocarbons, PCBs, and volatile organic compounds.

-------
                                     1-23

      The most common types of waste management practices resulting in
releases at the 52 sites were landfills/dumps and surface impoundments, which
together account for roughly 80 percent of the sample.  Insufficient
information is available to evaluate trends in the design characteristics of
these units.  As shown in Exhibit 1-9, the most commonly observed waste
migration pathway was seepage into ground water that in turn discharges to
surface water (observed at almost 65 percent of these sites).  However, at
most sites multiple release and migration pathways from multiple sources were
either observed or projected.  For example, runoff or erosion was either
observed or projected to be an important migration pathway at roughly 70
percent of the sites with landfills, direct discharges were observed to be a
source of environmental contamination at approximately 40 percent of the
surface impoundment sites, and airborne releases (dusting or volatilization)
were projected to be contributors to ecological threats at 50 percent of the
sites with landfills or surface impoundments.  The routes by which biota were
most frequently observed to be exposed were contact with/ingestion of surface
water and surface water sediments; however, contact with/ingestion of soil and
food chain ingestion also were frequently projected routes of exposure.

      In terms .of environmental setting characteristics, the factor that
appears to have the greatest bearing on reported ecological threats is the
proximity of a site to surface water.  Almost 90 percent of the sites in the
sample were either adjacent to or near (generally within one or two miles) a
surface water body.  In addition, almost 40 percent of the sites were noted to
have surface water onsite, most commonly drainage ditches or small creeks that
appear to act as conduits for waste constituent migration, as well as habitat
for aquatic receptors.  The proximity to a wetland, swamp, or marsh also
appears to be an important factor in determining ecological risks.  Roughly 60
percent of the sites were near this type of ecosystem.

      4.4.2  Common Characteristics of Sites With Relatively Severe
             Ecological Threats

      There are five sites in the sample that, based on the documentation
reviewed, appear to have particularly severe ecological threats.  These sites
are Hudson River, Iron Mountain Mine, New Bedford Harbor, Outboard Marine
Corporation, and Palmerton Zinc.  See Appendix B for a summary of the
ecological effects at these sites.

      These five sites exhibit very few common characteristics; however, there
are some noteworthy trends.  First, the media principally contaminated at each
site are surface water and surface water sediments.  The only exception to
this is Palmerton Zinc, which has significant soil and terrestrial vegetation
contamination in addition to surface water and sediment contamination.   The
surface water ecosystem contaminated at three of the sites was noted to be
habitat for commercial species or important spawning areas (such as
estuaries).   The contaminants present at all of the sites are bioaccumulative
and environmentally persistent:   PCBs are a major contaminant at three of the
sites, while three of the sites are contaminated with copper, cadmium,  zinc,
and/or lead.  The contamination at three of these sites can be traced
primarily to a single facility or source;  the exceptions are Hudson River,
which received discharges from two separate facilities,  and New Bedford

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                           EXHIBIT 1-9                            .
MAJOR RELEASE SOURCES.  MIGRATIOH PATHWAYS, AND EXPOSURE PATHWAYS^/


Release/Migration Pathways
Release Source Actual
Landfills (21)— Seepage into ground
water that
discharges to
surface water (14)

Runoff/ erosion (7)

Direct discharge
(3)^

Accidental release/
spill (3)-X

Flooding (1)



Surface Seepage into ground
Impoundments/ water that
Lagoons (16)- discharges to
surface water (10)

Direct discharge (7)

Accidental release/
spills (5)-X

Runoff/erosion (2)-/

Dusting/volatil-
ization (1)



Projected
Runoff /erosion (7)

Dusting/volatil-
ization (7)

Seepage into ground
water that
discharges to
surface water (6)

Flooding (2)






Dusting/volatil-
ization (12)

Seepage into ground
water that
discharges to
surface water (6)

Runoff /erosion (1)










Biota Exposed
Actual
Fish (8)

Aquatic or
terrestrial
vegetation (6)

Aquatic
invertebrates (5)

Amphibians/reptiles
(1)






Fish (8)

Aquatic or
terrestrial
vegetation (6)

Aquatic
invertebrates (3)

Amphibians/reptiles
(1)






Projected
Mammals/birds (17)

Aquatic
invertebrates
<1
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                                                                           EXHIBIT 1-9
                                                MAJCR RELEASE SOURCES, MKBATION PATHHAYS, AHD EJCPSOURE PATHWAYS

                                                                           FOOTNOTES
a/  The numbers in parentheses represent the approximate number of sites, out of 52, that have the given  release  sources, migration  pathways,  and biota  exposure
    pathways   Because of uncertainties  in classifying each site into the categories used in  the table, these numbers  are only  approximate  and indicative  of  the
    relative frequency of occurrence of  the release/raigration/exposure pathways.

b/  As shown in Exhibit 3,  there are 23  sites in  the  52-site sample that have landfills or dumps and  18 sites with  surface  impoundments  or  lagoons.   There are
    two sites,  however, that have both a dump area  and surface impoundments, as well as other potential release sources  (the  Sand  Creek  Industrial  Site  and the
    Velsicol Site)   Because the release/migration/exposure pathways associated with the different waste  management practices at these sites  could  not be
    differentiated based on the site information  available, the sites are not accounted for in this table.

c/  At these sites,  contaminated ground  water is  collected and then discharged to a surface water body.

d/  Accidental releases or spills from landfills  were counted for the purpose of this exhibit as surface  releases from contained wastes  prior to burial, such as
    a breach of a drum or other container.

e/  For the purpose of this exhibit,  accidental releases or spills from surface impoundments were considered overflow  events  or incidences  in which a surface
    impoundment berm was significantly breached (not  seepage into ground water that might have occurred during routine operation).

f/  Runoff and erosion was considered as a secondary  release pathway for surface impoundments at two  sites where:   (1) the  impoundments  had been closed  and
    covered, and the cover and contained residual contaminants were noted to be eroding; and  (2) residual surface soil contamination caused by a spill was noted
    to be eroding.

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                                     1-26

Harbor, which appears to have been contaminated by multiple sources.   Two of
the sites can be categorized as "special waste" sites, as defined under the
RCRA program:  Palmerton Zinc (a smelter) and Iron Mountain Mine.  Finally,
contaminants were reported to be released or migrating from most of the sites
through multiple pathways; the most common release/migration pathways are
direct discharges and runoff or erosion.

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                                     1-27

                                  CHAPTER 5

                          DISCUSSION AND CONCLUSIONS
      This chapter discusses issues related to the overall significance or
importance of the ecological threats summarized in Chapter 4.   In particular,
Section 5.1 provides generalizations across the 52 sites studied in this
project, and Section 5.2 discusses generalizations across the universe of NPL
and all Superfund sites.

5.1  Generalizations Across Sample of 52 Sites

      With respect to the nature of threats, most (roughly 90 percent) of the
sites pose a threat to surface water ecosystems, and in particular, freshwater
rivers, lakes, and wetland systems.  Threats to terrestrial ecosystems have
been observed or projected less frequently (at slightly less than 50 percent
of the sites), but this may be more a function of the extent to which
terrestrial effects were studied rather than a true indication of the
frequency of these effects.  As discussed in Section 4.1, terrestrial effects
generally were analyzed in the reports reviewed less rigorously than aquatic
effects.  Soil, ground water, surface water, and surface water sediments have
all been frequently observed to be contaminated at the sample sites.  The
biota most frequently observed to be contaminated were fish, aquatic
invertebrates, and vegetation; however, birds and mammals were projected to be
contaminated at a large number of the sites.  For example, fish or aquatic
invertebrates were observed to be contaminated at roughly 60 percent of the
sites, while birds or mammals were projected to be contaminated at
approximately 70 percent of the sites.  A variety of toxic effects to aquatic
fauna were observed at approximately 25 percent of the sites and projected at
another 45 percent.  In addition, fish kills were observed at almost eight
percent of sites, bioaccumulation within the aquatic food chain was observed
or projected at roughly a third of the sites, and decreased aquatic species
diversity was observed at 13 percent of the sites.  When noted, adverse
terrestrial effects usually took the form of damaged or killed vegetation,
loss of habitat, contamination or loss of food sources, and in a few cases,
projected toxic effects to birds and mammals.  At many sites,  the adverse
effects manifested in terrestrial fauna (if any) are uncertain.

      Based on the limited amount of quantitative information available, the
extent of threats varies widely across the sample, both in terms of the area
affected and magnitude of impact.  As discussed in Section 4.4.2, there are
five sites (approximately 10 percent) that appear to present particularly
severe ecological threats, characterized by high levels of environmental
contamination spread over relatively large areas with large populations of
organisms that are (or could be) exposed.  There is an equal number that
appears to present relatively minor threats, generally characterized by low
levels of environmental contamination confined to small areas and relatively
small numbers of potential ecological receptors.  Therefore, based on the
documentation reviewed, the majority (roughly 80 percent) of the sites can be
categorized as relatively moderate in terms of ecological threats.  It is
important to clarify that many of the sites grouped into this "moderate"

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                                     1-28

category have resulted in adverse effects and even death to some biota, or
have 'caused environmental contamination that is likely to cause adverse
effects to biota.  However, the threats at the majority of these sites were
categorized as moderate, for the purpose of relative ranking only, mainly
because:  (1) the area affected generally appears to be small to moderate in
size (usually less than tens of acres) and the biota affected generally appear
to be limited to organisms close to the site; and/or (2) contaminant levels
appear to be below acutely toxic levels in most areas and the potential for
and exact nature of effects of chronic exposures at these sites is not well
understood.

      Insufficient information is available to draw firm conclusions with
respect to the significance of ecological threats in the sample.  In
particular,  data on the extent of environmental problems are generally
lacking, it appears that the threats to terrestrial organisms are not well
known, there generally are few ecological toxicity reference levels by which
to assess the magnitude of environmental contamination, and the overall
effects to ecosystems are not well understood.  In addition, there is no
official EPA guidance or policy on what constitutes a "significant" ecological
impact or risk at Superfund sites.  Nevertheless, generalizations can be made
concerning the following four aspects that relate to the significance of
ecological effects:  the intensity of the effects, the duration of the
effects, the extent to which unique or particularly valuable resources are
threatened,  and the overall context of the threats (i.e., whether they are
local, regional, national, or global).

      As demonstrated by several sites in the sample, the adverse ecological
effects at Superfund sites can be very intense, including death to aquatic and
terrestrial organisms and complete devastation of habitat.  In addition,
almost all of the sites in the sample have contaminants present that are
acutely toxic to aquatic organisms when present in sufficient concentrations.
In the sample studied, however, very intense (or acute) effects were observed
or projected at only a small portion of the sites or appeared to be limited to
small areas.  Most sites appear to present more of a long-term threat that has
not yet resulted in adverse effects that are easy to detect.

      Based solely on the types of contaminants observed, it appears that
ecological exposures and adverse effects caused by contamination at the sample
sites could persist for long periods of time if no response action were taken.
Most of the sites are contaminated with chemicals that are persistent and
bioaccumulative (e.g., PAHs, PCBs, lead, and cadmium).

      Ecological threats may be considered by some to be more significant if
the resources at risks are particularly valuable (i.e., unique, vulnerable,
commercially significant, or recreationally important).  In that regard,
Exhibit 1-7 shows that almost 60 percent of the sample sites appear to be
threatening wetland/marsh/swamp systems, and 25 percent may be threatening
endangered species or their habitat.  In addition, roughly 10 percent of the
sites are located in or near wildlife refuges and approximately seven percent
are possibly threatening aquatic habitat noted in the site reports to be
sensitive spawning areas for fish.  The commercial resources that appear to be
at highest risk are fish and shellfish; the reports reviewed for approximately

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                                     1-29

17 percent of the sites noted observed or projected threats to fish or
shellfish that appear commercially significant.   Very little data are
available on the recreational value of the resources potentially affected,
except that roughly seven percent of the sites may have contaminated areas
likely to be used for recreational purposes (e.g., state parks, lakes adjacent
to parks, and nature study areas).

      Finally, virtually all of the sites individually pose ecological threats
that are local in nature.  The possible exception is the 200-mile stretch of
contamination at the Hudson River site, which conceivably could cause regional
effects.  However, the threats at individual sites must be considered along
with the fact that there is a large number of Superfund sites in order to
assess the aggregate national extent of ecological threat.

      There are several sources of uncertainty concerning these
generalizations.  The greatest uncertainty is associated with the amount of
ecological threat documentation on which the generalizations are based.  As
discussed in Section 4.1, the scope of many of the site-specific assessments
reviewed in this study was rather limited, often not including analyses of key
endpoints (e.g., effects to terrestrial organisms, effects on the population
or community levels of organization, and habitat alterations).  In general,
the reports reviewed also focused heavily on adverse effects that were being
exhibited at the time of study, providing less detail on chronic threats that
could result in adverse effects in the future.  Additional uncertainty is
created by limitations in the methods used to conduct this study, as described
in Chapter 2.

5.2  Generalizations Across All Superfund Sites

      The sample of 52 sites studied in this analysis may not be statistically
representative of all Superfund sites, and it certainly was not a
statistically based sample of the site universe.2  The sample was drawn from a
limited set of selectively identified sites, and probably is biased toward
sites with more obvious ecological threats (i.e., when compared to the
universe of all sites, the sample of 52 likely contains a larger fraction of
sites with more obvious ecological threats because they were recognized and
investigated).  The sample may also be biased toward sites with more severe
ecological threats, although that is less certain.  Furthermore, the
representativeness of the sample results is uncertain given the fact that
comprehensive efforts to identify sites where ecological threats exist
generally have not been made prior to this study.  For these reasons,
statistically valid extrapolations of the sample results to the general
population of Superfund sites are not possible.

      Simply for the purpose of illustration,  however, the sample results can
be generalized over the entire Superfund site universe if it is assumed that
the 52 sample sites examined here are representative of sites having the
     2 At this  time,  a retrospective  analysis  of a  statistically drawn sample
would have limited value because of severe ecological data limitations for the
sites.

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                                     1-30

potential for significant ecological threats.  Using information collected in
this study, it is possible to make very rough, preliminary estimates of the
number of NPL sites that might have significant ecological impacts or risks.
A total of 247 sites, most of them on or proposed for the NPL, were identified
through personal contacts and a literature review as having the potential for
significant ecological threats.  There are conflicting reasons, however, why
this number may overestimate or underestimate the total number of NPL sites
that have the potential for significant ecological effects.

      •     There is likely to be a smaller number of NPL sites
            that have the potential for significant ecological
            threats because the 247 sites probably include several
            sites with minor effects.   If the 52 sample sites
            examined in detail are representative of the 247,
            approximately 10 percent of the sites would present
            relatively minor threats.   Using this fraction,
            therefore, a rough lower bound estimate of the total
            number of NPL sites with the potential for significant
            ecological threats is 247 minus 10 percent, or roughly
            220 sites.  It is recognized, however, that the total
            number of NPL sites that have the potential for
            significant ecological threats may be even smaller
            than 220.  This is because the sample of 52 sites is
            probably biased toward sites with greater ecological
            threats (i.e., when compared to the 247 sites, the
            sample of 52 likely contains a smaller fraction of
            sites with minor ecological effects).

      •     A major reason why there are probably more than 247
            NPL sites that have the potential for significant
            ecological threats is that many NPL sites have not
            entered the detailed study (RI/FS) phase of the
            Superfund program.  As a result, many sites probably
            have not been evaluated in any detail from the
            standpoint of ecological threats and could not,
            through the interviews and literature review conducted
            in this study, have been identified as having the
            potential for significant ecological effects.  Based
            on the sites identified in this study, the RI/FS
            workplan phase represents a reasonable point in the
            remedial response process that must be reached before
            one can have any confidence that ecological threats
            exist at a site.  There are approximately 700 sites at
            the RI/FS workplan phase;  therefore, given the above
            logic, the 247 sites identified here are out of a
            possible total of roughly 700.  Assuming this ratio is
            valid for all 1,200 sites on or proposed for the NPL,
            a rough upper bound estimate of the total number of
            NPL sites with the potential for significant
            ecological effects is 1,200 times 35 percent (i.e.,
            247/700), or 420 sites.  It is recognized, however,
            that the total may be greater than 420 because:

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                                     1-31

            (1) many of the individuals contacted through the
            course of identifying the 247 sites gave the name of a
            few example sites, while acknowledging the presence of
            additional, unnamed sites that also have the potential
            for significant threats; and (2) it is likely that the
            247 sites represent sites that have readily apparent
            or sensational ecological effects (i.e., there are
            possibly additional sites with ecological effects that
            will become apparent only after long-term exposure).

      Therefore, weighing these conflicting factors, a. rough estimate of the
total number of NPL sites with the potential for significant ecological
threats is between 220 and 420 sites, which is between approximately 18
percent and 35 percent of all sites either on or proposed for the NPL.  For
the reasons given above, however, the actual number could be either smaller
than 220 or larger than 420.  Furthermore, based on the detailed review of 52
sites, the number of NPL sites currently exhibiting relatively severe
ecological effects is probably much smaller.  The estimated range of sites
with the potential for significant threats is consistent with an earlier
survey of 277 Superfund sites done by OPA (EPA 1985), which estimated that
approximately 22 percent of all NPL sites have the potential to cause
significant natural resource injuries.

      Although virtually all of the 247 sites identified in this study can be
categorized as NPL sites, there is little reason to believe that non-NPL sites
pose less of an ecological threat, because ecological threats are given
limited consideration when placing sites on the NPL (i.e., in the current
Hazard Ranking System).  Therefore, if it is assumed that the estimated
percentage of NPL sites potentially posing significant ecological threats is
valid for the 15,000 or so sites currently listed in CERCLIS and potentially
posing threats addressable under CERCLA,3 the total number of Superfund sites
with the potential for significant ecological threats would be between 2,700
and 5,300.  This probably overestimates the actual number because some of the
sites in CERCLIS probably involve minor or inconsequential releases; however,
the large number illustrates the potential magnitude of the problem.  Again,
the total number of sites currently exhibiting relatively severe ecological
effects is probably much smaller.

      If it is assumed that the 52 sample sites examined here are
representative of sites having the potential for significant ecological
threats, the characterization of ecological threats at the sample sites would
illustrate the nature of threats that may occur at all Superfund sites having
the potential for significant ecological threats.  Recognizing this
     3 CERCLIS  contains  approximately 31,000 sites,  of which approximately
16,000 have been classified based on a preliminary assessment or site
inspection as clearly posing no significant threats addressable under CERCLA
(i.e., categorized by EPA as "no further response action planned").   Also, it
is important to clarify that 31,000 does not represent the complete universe
of Superfund sites, but rather the Superfund sites that have been identified
to date.

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                                     1-32

limitation, the following conclusions about all Superfund sites can be made.
Many sites have probably caused soil, ground-water, surface water, and surface
water sediment contamination.  In addition, many have probably contaminated
wetlands or have damaged vegetation.  Cumulatively, this may translate into a
potentially large loss of habitat for the nation's flora and fauna, some of
which may be endangered or commercially/recreationally valuable.  Fish or
aquatic invertebrates are also probably contaminated and displaying toxic
effects at many of the sites and, while probably fewer terrestrial organisms
(birds and mammals) are contaminated and to a lesser extent, there also is
widespread potential for wildlife to be adversely affected.

      In order to make quantitative projections about the extent of ecological
threats across all Superfund sites, a number of assumptions concerning this
study's results would have to be made.  In particular, one would have to
assume that:  (1) the 52 sites studied in this project are representative of
all sites with the potential for significant ecological effects; (2) the
subset of 28 sites for which data are available on the extent of ecological
threats is also representative; (3) available data on the extent of ecological
threats are complete and accurate; and (4) the above estimates of the total
number of Superfund sites with the potential for significant ecological
threats are accurate.  If these assumptions are valid, the following
preliminary estimates can be made of the aggregate national extent of
ecological threats caused by Superfund sites:

      •     Surface water contamination:  Seventy-five percent of
            the 52-sample sites has either observed or projected
            surface water contamination.  Ignoring the magnitude
            of this contamination, the geometric mean4 of
            available data on the areal extent of surface water
            contamination is 3 stream miles contaminated per site.
            If these numbers are assumed to be valid for all 5,300
            Superfund sites estimated to have the potential for
            significant ecological threats, the national extent of
            surface water contamination caused by Superfund sites
            would be 12,000 stream miles contaminated.  This
            figure may include some double counting because
            several sites have the potential to contaminate the
            same stream miles.  Assuming the sample results are
            representative for all sites, contaminant
            concentrations over this large distance would range
            from slightly greater than AWQC in certain areas to
            more than 400,000 times AWQC in some areas.

      •     Surface water sediment contamination:  Seventy-five
            percent of the sample sites also has observed or
            projected contamination of surface water sediments;
            the geometric mean of the sample results is roughly 2
     4 A geometric mean rather than an arithmetic mean is used for this
purpose because the sample sizes are small and the arithmetic mean would be
skewed toward an unusually large value at a single site.

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                                     1-33

            stream miles of sediments contaminated above
            background levels per site.  Applying these numbers in
            the same manner as described above for surface water
            contamination, the national extent of sediments
            contaminated above background levels as the result of
            Superfund sites could be 8,000 stream miles.  Again,
            this figure may include some double counting because
            several sites may contaminate the same stream miles.

      •     Soil contamination:  Soil is observed or projected to
            be contaminated above background levels at roughly 80
            percent of the sample sites, with a geometric mean of
            approximately 15 acres contaminated per site.  If
            these figures are valid for the upper bound estimate
            of 5,300 sites that have the potential for significant
            ecological effects, the total area of soil
            contaminated by Superfund sites would be 64,000 acres.

      •     Fish kills:  Fish kills were observed or projected at
            only 11 percent of the sample sites.  At sites where
            fish kills were observed, kills occurred over areas
            ranging from less than one stream mile to 18 stream
            miles, with a geometric mean of 3 stream miles per
            site.  If these figures are assumed to be valid for
            all 5,300 sites estimated to have the potential for
            significant ecological threats, Superfund sites could
            cause fish kills in 1,700 stream miles.  Based on the
            sample results, the severity of fish kills could range
            from 10 percent to 100 percent for affected areas.

      •     Defoliation:  Vegetation was observed or projected to
            be stressed or killed at 38 percent of the sample
            sites.  When observed, the areas of defoliation ranged
            from 1 acre to 2,000 acres, with a geometric mean of
            11 acres per site.  Assuming these figures are valid
            for all 5,300 sites as done above, the total area of
            defoliation caused by Superfund sites could be 22,000
            acres.  Additional areas would be expected to have
            stressed but not killed vegetation.

      •     Contamination of wetlands or marshes:  Roughly 58
            percent of the sample sites had observed or projected
            contamination of wetlands/marshes, with the geometric
            mean being approximately 7 acres contaminated per
            site.  Applying these numbers in the same manner as
            above, the total area of wetlands/marshes contaminated
            above background levels as the result of Superfund
            sites could be 22,000 acres.

      To help put these estimates in perspective, Keup (1985) estimates that
there are approximately 3,250,000 total stream miles in the U.S.  The rough
estimates given above for surface water and surface water sediment

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                                     1-34

contamination caused by Superfund sites are less than 0.5 percent of the
nation's stream miles.  According to EPA (1987), it is suspected that severe
contamination of sediments with toxicants released from all sources might
exist in perhaps 1 percent of the nation's stream miles (not counting possible
sediment contamination in the nation's lakes, estuaries, or marine areas).
The estimate given above for fish kills caused by Superfund sites is less than
0.1 percent of the nation's stream miles.  For comparison, EPA and the Fish
and Wildlife Service (1984) have estimated that fish kills caused by all
sources have occurred in 15 percent of the nation's stream miles and that
toxic substances from all sources have adversely affected fish in roughly 10
percent of the nation's stream miles (not counting fish kills or toxic
substance contamination that may have occurred in estuaries, coastal water,
wetlands, or the Great lakes).  Moreover, the rough estimate given above for
the number of acres of wetlands and marshes contaminated by Superfund sites
represents less than 0.03 percent of the nation's total inventory of wetlands
in the 1970's in the 48 conterminous states (Fish and Wildlife Service 1983).
Roughly 20 times more wetlands are lost each year as a result of all other
stresses (Fish and Wildlife Service 1983),  with agriculture and development
alone resulting in an annual loss of roughly 10 times more wetlands than
predicted to be contaminated by Superfund sites (EPA 1988).  Assuming these
estimates are valid, therefore, the relative contribution of Superfund sites
to the nation's ecological impacts appears moderate to small.  This conclusion
generally is supported by other EPA studies (e.g., EPA 1987).  Clearly, these
numerical extrapolations are highly uncertain; they are provided only to
illustrate the possible extent of the problem, and as a quantitative point of
departure to be refined in future studies.

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                                     1-35

                             PART I REFERENCES
Booz, Allen and Hamilton, 1988, Remediation and Analysis of Potentially
      Contaminated Marine Sediments, prepared for EPA Hazardous Site Control
      Division.

Cole, H.S. and Bill Walsh, 1987, Superfund 1987:  Public Health Remains at
      Risk, A One-Year Report on EPA's Cleanup Program Under the New Superfund
      Law, National Campaign Against Toxic Hazards and U.S. Public Interest
      Research Group.

DOI, 1988, Responses to Questions from Chairman, Subcommittee on Fisheries
      and Wildlife Conservation and the Environment, House Committee on
      Merchant Marine and Fisheries, Memorandum from Donald P. Hodel to
      Honorable Gerry E. Studds dated January 29, 1988.

DOI, Fish and Wildlife Service, Preliminary Natural Resource Surveys for
      Brio Refinery Co., TX; Crystal Chemical Co., TX; Farley Street Site, TX;
      Geneva Site, TX; Highland Acid Pit Site, TX; North Cavalcade Street
      Site, TX; Sol Lynn/Industrial Transformers Site, TX; United Creosoting
      Site, TX.

Environmental Defense Fund, et. al., 1988, Right Train, Wrong Track:
      Failed Leadership in the Superfund Program, A Comprehensive
      Environmental -- Industry Report on Recent EPA Cleanup Decisions.

EPA, 1988, Final Regulatory Impact Assessment/Background Information
      Document--Wetlands.

EPA, 1987, Unfinished Business:  A Comparative Assessment of Environmental
      Problems, Appendix III, Ecological Risk Work Group, OPA, OPPE.

EPA, 1985, Assessment of the Potential for Natural Resource Claims at
      Hazardous Waste Sites, OFA.

EPA and Fish and Wildlife Service, 1984, 1982 National Fisheries Survey
      Volume I Technical Report:  Initial Findings, FWS/OBS-84/06.

EPA, 1980, Damages and Threats Caused by Hazardous Material Sites,
      EPA/430/9-80/004, Oil and Special Materials Control Division.

Fish and Wildlife Service, 1983, Status and Trends of Wetlands and
      Deepwater Habitats in the Conterminous United States, 1950's to 1970's.
      &/   Site-specific references for the 52 sites studied in the Superfund
part of this project are listed in Appendix B.

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                                     1-36

                         FART  I REFERENCES  (continued)
Indiana Department of Environmental Management, 1988, Northwest Indiana
      Environmental Action Plan:  Area of Concern:  Remedial Action Plan,
      Draft.

Keup, 1985, Flowing Water Resources, Water Resources Bulletin, American
      Water Resources Association, Vol. 21, No.2, April.

Kilkelly Environmental Associates, 1988, Ecodamage Workshop Manual for
      Hazardous Waste Sites.

NOAA, 1987, Coastal Hazardous Waste Site Review:  Site Reports, June 1987,
      Ocean Assessments Division.

NOAA, 1986, Coastal Hazardous Waste Site Review, April 1986, Ocean
      Assessments Division.

NOAA, 1985, Coastal Hazardous Waste Site Review, April 1986, Ocean Assessments
      Division.

NOAA, 1984, Coastal Hazardous Waste Site Review, Ocean Assessments Division.

Office of Technology Assessment, 1988, Are We Cleaning Up?  10 Superfund Case
      Studies, A Special Report of OTA's Assessment on Superfund
      Implementation.

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PART II:  RCRA FACILITIES

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                                  CHAPTER  1

                                 INTRODUCTION

      When introduced into the environment, the solid and hazardous wastes
regulated under the Resource Conservation and Recovery Act (RCRA) and managed
at RCRA facilities can threaten both human health and ecological receptors.
Although the regulations and policies developed and implemented under RCRA are
intended to minimize such threats to human health and the environment, the
protection of human receptors has been the main focus of the RCRA program.
Because of this emphasis on human receptors,  resource commitments for
characterizing the extent of ecological threats at RCRA sites, developing
ecological assessment methods, and addressing issues associated with the
management of ecorisk information have been limited.

      To help correct this imbalance, OPA has initiated a study of three broad
topics:  1) the nature and extent of ecological threats at RCRA sites; 2) the
ecological assessment methods that have been or could be used in the RCRA
program; and 3) past and potential future ecorisk management decisions.  This
report addresses the first topic and has three main purposes:

      •     To document the nature and extent of ecological damages and risks
            from the management of RCRA wastes;

      •     To characterize, if possible, the types of management practices,
            environmental settings,  and wastes posing the most significant
            ecological risks; and

      •     To evaluate whether ecological risks at RCRA facilities are
            adequately considered and controlled under the RCRA program.

      This report includes data on the nature and extent of both actual,
observed ecological impacts and predicted ecological impacts (i.e., risks) at
RCRA facilities.  The term ecological "threat" often is used in the report to
refer to both observed and predicted impacts.   Contamination of and adverse
effects to biota are examined, as is media-specific contamination that may
pose a risk to biota.  The report primarily focuses on baseline ecological
threats that exist(ed) before response actions have been (were) taken, not the
ecological problems caused by a response action or the residual threats after
a response.

      This report addresses most of the major RCRA program areas which
regulate or encompass activities that are expected to pose significant
ecological risks.  Specifically, we address ecological concerns of Subtitle C,
municipal and industrial Subtitle D, mining and beneficiation, oil and gas,
coal utility, and smelting and refining facilities.  Although Subtitle I
(underground storage tank) facilities may also pose ecological threats, they
were not considered in this analysis.

      The information available to characterize the ecological threats posed
by each of the RCRA program areas varies greatly.   OPA focused principally on
Subtitle C facilities, because documentation  for these facilities is both more
comprehensive and more readily available through EPA Headquarters reports and
Regional facility files.

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                                     II-2

1.1   Major Limitations and Caveats of this Assessment

      This report is limited in scope by the availability of relevant studies
for analysis, the lack of ecological risk information for most types of
facilities, the representativeness of the data collected and analyzed for this
report, and the relative youth of much of the RCRA program and its associated
data collection activities.  We nevertheless believe that the types of
ecological impacts associated with RCRA facilities are accurately depicted in
this report.  OPA, therefore, intends this report to represent the first known
attempt at summarizing the available information concerning these impacts.

      The primary factor limiting this analysis is the paucity of information
relevant to ecological threats at RCRA facilities, including the limited
number and scope of past analyses of this issue, and the lack of data
describing specific ecological impacts.  The findings of this report are based
on original material gathered specifically for this analysis as well as
previously conducted national modeling studies and damage case compilations.

      The national studies and previous damage compilations have been
conducted primarily for purposes other than assessing ecological threats.
Therefore, extrapolating the findings and data from these previous studies to
draw conclusions requires assumptions concerning their applicability to this
analysis, as discussed in subsequent sections.

      Another data limitation problem exists with respect to facility-specific
information on ecological impacts.  For example, Subtitle D and special waste
facility documentation is, for the most part, held in the States, and is not
readily accessible for compilation.  Therefore, this analysis has relied on
secondary sources to describe a limited number of damage cases.

      The limited availability of data characterizing each of the RCRA program
areas results in disproportionate attention to specific programs, geographic
locations, and facility types for which data are available.  This presents
difficulties for comparisons of ecological effects among different RCRA
programs and the national extent of the problems identified.

      Many of- the limitations mentioned above result directly from the RCRA
program's relative lack of emphasis on remedial investigation activities.
This emphasis is changing, however, as the corrective action program for solid
waste management units at hazardous waste facilities is implemented under RCRA
3004(u) and 3008(h).  The RCRA Facility Assessments (RFAs) and RCRA Facility
Investigations (RFIs) to be conducted under this program may, if properly
oriented, serve to gather information on the types of releases and ecological
effects associated with RCRA Subtitle C hazardous waste facilities.

1.2   Guide to the Remainder of Part II of the Report

      The remainder of this report is organized into four chapters.   In
Chapter 2, we briefly present the approach used to conduct this analysis,
including a discussion of the sources of information and methods of data
collection and analysis.  In Chapter 3, we discuss the results of our
analysis.  Finally, Chapter 4 summarizes our findings concerning ecological

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                                     II-3

impacts at RCRA facilities and presents conclusions about the types of RCRA
facilities posing ecological threats.  Summaries of the data collected for
this analysis are included in appendices.

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                                     II-4

                                   CHAPTER 2

                                   APPROACH
      OPA directed its efforts toward gathering information from two primary
sources.  First, we collected and reviewed program analysis and regulatory
development documents that discuss environmental effects at RCRA facilities.
Second, we contacted RCRA professionals familiar with specific facilities to
identify sites where ecological threats had been characterized and used in the
RCRA decision-making process.  We also collected and summarized documentation
for facilities identified by these personnel.

2.1   Program Analysis and Regulatory Development Documentation

      Our review of program analysis and regulatory support documentation
involved the examination of Regulatory Impact Analyses (RIAs), Reports to
Congress, comparative risk analyses., and program-specific background
information documents pertaining to the following six RCRA program areas:

      •     Subtitle C (hazardous waste);
      •     Subtitle D (municipal and industrial solid waste);
      •     Special Wastes --
                  Mining Waste,
               -  Oil and Gas Waste,
               -  Coal Utility Waste, and
                  Smelting and Refining Waste.

      For each RCRA area considered in this analysis,  OPA examined two types
of available documentation.  First, we sought data on the national extent of
the ecological threats posed by solid and hazardous waste management.
Typically, these data included the total number of facilities/sites affected
versus the number existing, total amounts of waste produced, and/or the
proximity of a typical facility to endangered or sensitive species habitats.
Next, we sought information regarding the nature of potential or existing
ecological threats at each type of facility.  For most RCRA areas, this
information was available through case study analyses contained in RIAs,
Reports to Congress, and other studies.

      Our analysis did not include an examination of threats posed by RCRA
Subtitle I (Underground Storage Tanks (USTs)) facilities.  In addition,
ecological threats from waste management activities regulated under other
statutes, such as the Toxic Substances Control Act (TSCA) or the Clean Water
Act (CWA), are not discussed in this analysis.  For example, in one previous
comparative risk analysis, ocean dumping is considered to pose a significant
(if not the greatest) threat to marine ecosystems.  Since ocean dumping is
regulated under the Marine Protection, Research, and Sanctuaries Act of 1972,
however, and not RCRA, the associated ecological threats from this source are
not within the scope of this analysis.  Furthermore, we did not attempt to
summarize information for land disposal facilities that are now being
addressed under the Superfund program.  Such facilities are described in Part
I of this report.

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                                     II-5

2.2   Interviews and Meetings with RCRA Professionals

      As a first step in our search for information describing the nature and
extent of ecological threats from RCRA sites, we implemented a telephone
interview survey with RCRA professionals in the EPA Regions and States.  We
contacted appropriate people at EPA headquarters,  all ten EPA Regional
offices, and a number of State agencies from each Region.  In addition to our
phone interview survey, we also made visits to RCRA offices in EPA Regions 3
and 4, and Georgia's Department of Natural Resources.  During our office
visits, we collected site-specific file information and met with Regional and
State personnel to discus ecological threat information and methodologies used
in the RCRA program.  A list of all Regional and State contacts is provided in
Appendix D, along with a summary of the telephone interviews.

      The information requested through the interview process focused on two
areas:  1) obtaining documentation on facilities with known or suspected
ecological damages, and 2) assessment of the role of ecological threat
information in the RCRA program.  Interviewees were asked to identify and
provide documentation on RCRA sites with known or suspected ecological
threats.

      Aside from obtaining site-specific documentation,  the interviews were
aimed at assessing the general use of ecological threat information in the
RCRA program.  The adequacy of current ecological risk methodologies was
discussed along with possible means of improving the methods.  The
interviewees were also asked to describe how ecological threat information was
being used in RCRA decision making and to identify the main barriers to the
use of this information.  The conclusions drawn from these interviews are
summarized in Chapter 3.

2.3   Case Study Analysis

      Our case study analysis of RCRA program areas is based on two sources of
information:  1) a first-hand review of original RCRA facility documentation
(Subtitle C only), and  2) a second-hand review of damage cases described in
available program analysis and regulatory development documentation.  Both of
these sources, and our approach to their analysis, are described below.

      2.3.1  Subtitle C Case Studies

      Using the information collected through phone interviews and meetings
with personnel in Regions 3 and 4, we developed case studies of RCRA Subtitle
C facilities for which ecological threat information has been collected and
used to support permitting or corrective action activities.  Although the RCRA
personnel we contacted identified 52 facilities that may have been evaluated
for ecological damage, much of this information is anecdotal.  We were able to
obtain useful documentation for 16 Subtitle C facilities at the time this
report was prepared.

      The case study descriptions present a synopsis of the facility
characteristics relevant to this analysis, including:

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                                     II-6

      •     a description of the facility's primary function, waste management
            units, and environmental setting;

      •     a brief summary of the facility's status in the RCRA program;

      •     observed or potential environmental threat characteristics,
            including environmental media contaminated, biota contaminated,
            hazardous constituents involved, and release and exposure
            pathways;

      •     observed or potential ecological impacts related to facility
            operations; and

      •     a summary of the manner in which ecological information has been,
            or may be, used at the facility.

      The information summarized in these case studies supports our assessment
of the nature of observed ecological impacts and the waste management
practices, environmental settings, and types of wastes most commonly
associated with ecological impacts.  The Subtitle C case study information is
presented in summary form in Chapter 3, and documented in full in Appendix E.

      2.3.2 Damage Cases from Reports to Congress and Regulatory Impact
            Analyses

      The damage cases prepared for Reports to Congress and Regulatory Impact
Analyses provide another source of site-specific information.  We reviewed the
program analysis and regulatory development documents described above and
compiled the information presented as damage cases for analysis as case
studies.  To the extent permitted by the level of detail provided in the
damage cases, we have characterized the types of ecological damages observed,
the waste management practices involved, ecological settings, and the waste
characteristics in order to assess the nature of ecological threats arising
from RCRA facilities.  Damage cases involving waste management at Subtitle C,
municipal Subtitle D, mining, oil and gas,  coal utility, and smelting and
refining facilities are presented as case studies in Chapter 3.

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                                     II-7

                                   CHAPTER 3

              RESULTS:  NATURE AND EXTENT OF  ECOLOGICAL THREATS
                              AT RCRA FACILITIES
      In this chapter, we present the results of our investigation of the
nature and extent of ecological threats at RCRA facilities.  This discussion
is organized around the major areas of RCRA regulation:  Subtitle C; Subtitle
D; and the large volume wastes from mining and beneficiation, oil and gas
production and development, coal utilities, and smelting and refining.  For
each major RCRA program area, we summarize the available information relevant
to ecological impacts, discuss the extent of ecological threats, discuss the
nature of ecological threats (as evidenced through case studies and general
descriptive information available in the program analysis and regulatory
development documentation), and summarize the characteristics of the
ecological threats presented by facilities in the RCRA program.

      For this analysis, the "nature" of ecological threats refers principally
to the type and severity of damages observed (e.g., fish kills, altered
community structure), and the typical release/exposure pathways.  The "extent"
of ecological threats indicates the breadth and magnitude of potential
ecological risks in terms of facility size, population of potential and/or
actual receptors, location, waste quantities generated, and number of releases
experienced and/or health-based levels exceeded.

3.1  Subtitle C Facilities

      3.1.1  Summary of Available Information

      We assessed the broad ecological threats presented by RCRA Subtitle C
(hazardous waste) activities based on an examination of the following
documents:

      •     Corrective Action RIA;
      •     Wetlands (Location Standards) Background Information
            Document/RIA;
      •     Floodplains (Location Standards) Background Information
            Document/RIA;
      •     Small Quantity Generator (SQG) RIA;
      •     Solvent Wastes RIA; and
      •     Information collected through interviews with RCRA professionals
            and searches of Regional and State files.

Although none of these documents entirely address the nature and extent of
ecological threats at Subtitle C facilities, the integration of data from
these sources yields a relatively comprehensive analysis.

      The nature of ecological threats posed by Subtitle C facilities is
characterized by the damage cases presented in the Wetlands and Floodplains
(Location Standards) Background Information Documents/RIA and the case studies

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                                     II-8

developed from site-specific documentation identified through contact with
RCRA professionals.

      3.1.2  Extent of SUBTITLE C Ecological Threats

      The projected number of hazardous waste treatment, storage, and disposal
facilities (TSDFs) expected to require cleanup was estimated in the RIA for
the RCRA Corrective Action rule.  According to the RIA,  3,487 of an estimated
5,661 (TSDFs) located in the U.S. (62 percent) are expected to require a RCRA
Facility Investigation (RFI; i.e., have experienced some level of hazardous
waste release to the environment).  Of all 5,661 facilities,  17 percent are
expected to require cleanup of surface waters, 34 percent will require soil
cleanup, 30 percent will require ground-water cleanup,  and 7  percent of the
facilities are expected to require cleanup of releases  to air.  These
estimates are based, in part, on reports of 1,248 release incidents from land
disposal facilities in the last three years.  Of these  1,248  incidents, 590
cases involved releases to ground water, 537 reported surface water
contamination, 518 reported releases to soil, and 118 cases involved releases
to air.   Many of the release incidents involved contamination of more than one
medium.   Although these data give some indication of the extent of releases
from Subtitle C facilities, they do not provide a direct indication of the
ecological damage caused by the releases.  Nonetheless,  the data do indicate a
need to assess ecological threats in Subtitle C facility investigations.

      Through our telephone interviews and meetings in Regional and State
offices, we gathered information on RCRA professionals'  general impressions of
the ecological threat posed by Subtitle C facilities.  A detailed summary of
the results of the Regional and State interviews is presented in Appendix D.
The more salient points raised by the RCRA personnel are as follows:

      •     Many RCRA facilities may pose ecological threats, but due to the
            relative youth of the RCRA program and the  relative lack of
            attention given to ecological risks, there  is little available
            documentation to support any assessments or conclusions about the
            nature and extent of ecological threats presented by RCRA
            facilities.

      •     There has been little emphasis placed on collecting ecological
            information either at the program analysis  or site-specific
            assessment level.  Therefore, when ecological information has been
            collected, it may not be truly representative of the nature and
            extent of the problem.

      •     Interviewees from six Regions stated that ecological threats at
            RCRA facilities are given inadequate consideration.  This
            inadequacy was attributed to a lack of appropriate assessment
            methods, a lack of guidance, the impression that ecological
            concerns are "too big to deal with," program emphasis on human
            health, and an inability to address terrestrial threats.   Only one
            interviewee suggested that current considerations of ecological
            threats in RCRA were adequate.

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                                     II-9

      •     The impact of contaminated ground water on wildlife in
            hydrologically connected streams has not been extensively
            evaluated, but may be a widespread problem at RCRA sites.

      •     Data collected through the corrective action RFA/RFI process may
            provide a much greater indication of the nature and extent of the
            ecological risk problem.

      •     Permitted and new Subtitle C facilities should not pose a
            significant ecological threat due to the strict technical
            permitting standards which prevent releases.

      The main conclusion drawn from these interviews is that most Regional
and State personnel believe that ecological impacts at RCRA Subtitle C
facilities may be widespread, but that sufficient data are not yet available
to accurately characterize the scope of the problem.  The following section
provides greater detail concerning the nature of the threat at RCRA Subtitle C
facilities with known ecological impacts.

      3.1.3  Nature of Subtitle C Ecological Threats

      The case studies of RCRA Subtitle C facilities illustrate, by actual
examples of ecological impacts and considerations,  the nature of the
ecological threats at these facilities.  These case studies are based on
information from two sources:  Subtitle C facility files and the damage cases
in the two Location Standards Background Information Documents/RIA.

      Subtitle C Case Studies

      Case studies for 16 Subtitle C facilities where ecological threats have
been assessed or where permitting or corrective action decisions rely on
information about ecological threats have been developed.  Exhibit II-l
presents brief descriptions of these 16 facilities.  The case studies are
listed in order of geographic location (i.e., from Region 1 to Region 10),  and
alphabetically within each Region.  Appendix E to this report presents more
detailed, one-page discussions of these case studies.

      As can be seen in Exhibit II-l, nine of the 16 cases discuss facilities
located in EPA Regions 3 and 4.  This geographic distribution reflects
variations in the level of effort in requesting, and success in obtaining,
ecological threat documentation from the Regions rather than the actual
distribution of sites presenting ecological threats in the U.S.

      Location Standards Damage Cases

      Of eight Subtitle C documents examined, only the two Location Standards
Background Documents/RIAs contain sample cases of hazardous waste releases
from Subtitle C (or comparable CERCLA) facilities.   The presentation of these
case studies in the RIA was intended to provide background information for
floodplain and wetland land disposal restrictions.   Therefore, the damage
cases emphasize impacts to surface waters and wetlands and not terrestrial
ecological effects.   All of the eight case studies involve releases to

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                                                                    EXHIBIT  II  -  1
        Facility
                                                              RCRA ECORISK SUBTITLE C CASE STUDIES
                                 Facility/Site Description
                                                                     RCRA Status
                                                                                            Nature of Environmental Threat
                                                                                                                                     Ecological Impacts and
                                                                                                                                  Use of Ecological Information
Saco Defense,
Saco, Maine
Region 1
              Inc.
             Weapons manufacturing facility
             with 12 SWMUs:   6 landfills/
             lagoons, 5 waste storage areas,  1
             wastewater treatment plant.
                                      Under  a  consent
                                      order  to conduct  an
                                      RFI.
                        Potential ground-water, soil,
                        surface water and air contamination
                        by chlorinated ethanes and ethenes.
                        Pathway is thought to be by seepage
                        from landfills and lagoons to
                        ground water, overland flow to
                        surface water, and direct discharge
                        to surface waters.
                                        Proposed identification of
                                        sensitive areas and nearby
                                        wildlife in RFI.
Wyman-Gordon
North Grafton,
Region 1
Mass.
Allied Chemical
Baltimore Works
Baltimore, Maryland
Region 3
Defense General Supply
  Center
Chesterfield, Virginia
Region 3
The waste management area of
concern is a treatment lagoon.
Nearby wetlands receive ground
water downgradient from the
lagoon.
             Chrome plating facility storing
             chrome ore tailings.   Located  in
             estuarine environment near
             Baltimore's inner harbor.
             640-acre storage facility with
             landfills, open storage areas,  a
             fire training area,  and a vehicle
             maintenance area.   Two creeks,  a
             wetland, a pond, and an elk  herd
             in the vicinity of the waste
             management areas.   Possible
             habitat for 4 endangered species.
ACL petition
included in Part B
permit application.
                                      Negotiating
                                      corrective measure
                                      selection and
                                      design.
                                     Requesting HSNA
                                     permit modification
                                     for  construction  in
                                     area of
                                     contaminated soil.
                                     Facility undergoing
                                     CERCLA field
                                     investigations as
                                     well.
Wetlands, surface water, and
ground-water contamination by
arsenic, chromium, nickel, and high
pH.  Pathway of concern is a
ground-water seep Into a wetland.
Up to 3.5 acres of the wetland area
are contaminated.
                        Surface water, sediments, ground
                        water, and soil contaminated with
                        chromium.  Releases occur via
                        wastewater discharge and fill in
                        and around harbor using chromite
                        ore residue.
                        Soil, ground-water,  and surface
                        water contamination by metals,
                        chlorinated organics,  and acetone.
                        Releases by spills and subsequent
                        transport to ground water and
                        surface water.
Wetlands assessment
demonstrates decreased species
diversity, lower productivity,
and altered life cycle in
affected wetland area.

Biological assessment of
stream demonstrates that it is
healthy.

Increased body burden in blue
crabs and other benthic
invertebrates.

Low species diversity in areas
of high chromium
concentrations.

Potential chronic effects on
aquatic life from
concentrations above threshold
criteria.

Proposed wetlands assessment
and toxicity testing.

Assumed use of proposed study
will be to assess needs for
corrective action.
Rohm and Haas Delaware
  Valley, Inc.
Briston, Pennsylvania
Region 3
Kennedy Space Center
Florida
Region 4
             Chemical manufacturing plant  with
             a landfill and storage area.
             Site borders the tidally
             influenced Delaware River and
             encompasses 120 acres of open
             woodland and marsh land.

             Container storage facility.
             Adjacent wildlife refuge is the
             proposed location for an air
             stripper to treat ground water.
                                      Subpart S
                                      corrective  action.
                                      Operating under  a
                                      corrective  action
                                      order.   Proposed
                                      corrective  action
                                      developed on  a
                                      voluntary basis.
                        Soil,  ground water,  surface water,
                        and air contaminated by chlorinated
                        organics and benzene.  Potential
                        release pathway is via leaching
                        from landfill, surface runoff, and
                        direct discharge.

                        Ground-water contamination by VOCs.
                        Potential release and exposure
                        pathway is via the proposed air
                        stripping operation.
                                        No ecological assessment
                                        documentation available.
                                        Potential exposure of wildlife
                                        to airborne contaminants.
                                        Potential effects hive not
                                        been studied,  but the issue
                                        has been discussed at recent
                                        meetings between EPA, DOI, and

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                                                           EXHIBIT  II  -  1  (CONTINUED)
                                                              RCRA ECORISK SUBTITLE C CASE STUDIES
        Facility
     Facility/Site Description
                                                                     RCRA Status
                                                                                            Nature of Environmental  Threat
                                                                                                         Ecological Impacts  and
                                                                                                      Use of Ecological Information
Monroe Auto Equipment
  Plant
Hartwell, Georgia
Region 4
Pratt and Whitney
West Palm Beach,
Florida
Region 4
Southern Dye Co.'
(SODYECO)
North Carolina
Region 4
Southern Wood Piedmont
Co.
Baldwin, Florida
Region 4
Union Carbide
Agricultural
Products Co., Inc.
Woodbine, Georgia
Region 4
Auto equipment manufacturer
landfilling sludge on-site.
Other than a recreational  fishing
pond near the site,  no other
information on the ecological
character of the site is
available.
7,000-acre facility with 1
landfill, 4 burn pits,  a
recycling center, 2 waste piles,
and 3 incinerators among other
storage areas and treatment
units.
Chemical manufacturing plant with
surface impoundments and  landfill
cells.  The ground water  below
the site is hydrologically
connected to the Catawba  River.
Wood treatment plant adjacent to
tributaries of Baldwin Bay  and
wetlands areas.
Chemical formulation and
manufacturing facility with  a 20-
acre landfill.   Estuarine
wetlands and >a commercial  oyster
bed are nearby.
Undertaking
corrective action,
comparable to RCRA
Subpart S, under
supervision of the
State of Georgia.
Under a corrective
action consent
agreement a
workplan for
conducting an RFA
has been submitted.
Part B permit
application
deficiencies have
been outlined.

Denied ACLs.
ACL petition
approved.  Ongoing
investigations to
develop workplan
prior to issuance
of a HSWA permit.
ACL petition
(denied).
Soil, ground water, and surface
water are contaminated with
chlorinated alkanes and alkenes,
aromatic hydrocarbons, and cadmium.
Release is by leaching and runoff
from the sludge landfill.
Soils and canal sediments are
contaminated with PCBs, solvents,
acid wastes, heavy metals,  and
VOCs.  Release Is via spills,
leaks, leaching, discharge,
dumping,  and exhaust.
Ground water and surface water
contaminated with metals,
chlorinated organics, aromatic
hydrocarbons, and pesticides.
Contaminants released from surface
impoundments through seepage to
ground water.
Ground water, surface water,  and
sediment contaminated with arsenic,
chromium, and a variety of aromatic
contaminants.  Release is via
seepage from waste management pits
to ground water and subsequent
migration to surface water.

Ground water, surface water,  and
soil contaminated with metals,
chlorinated organics, aromatlcs,
and pesticides.  Release via
leaching from landfill and
migration to surface water.
Toxicity criteria are not
exceeded for sensitive plant
and fish species.

No degradation of biota
observed, consequently no
additional remedial action was
undertaken.

Ho ecological assessment
documentation available.
Concentrations are above
background but below threshold
criteria.

Low body burden of pollutants
in catfish.

ACL denied based on improper
characterization of
hydrogeology.

Toxicity of ground water
measured.  Hater downgradient
from the contamination source
is somewhat toxic, but not as
toxic as an upgradient
"control" sample.
lOOt oyster mortality in the
vicinity of the site.  (Not
conclusively linked to the
site.)

Potential exposures to a
variety of animal species may
cause acute and chronic
effects.

ACL petition denied on basis
of underaonstrated protection
of aquatic life.

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                                                           EXHIBIT  II  -  1   (CONTINUED)
        Facility
                                 Facility/Site  Description
                                                              RCRA ECORISK  SUBTITLE C CASE  STUDIES
                                                                     RCRA Status
                                                                                            Nature of Environmental Threat
                                                                                                         Ecological Impacts and
                                                                                                      Use of Ecological Information
Koppers Co.,
Incorporated
Superior,  Wisconsin
Region 5
International Paper
Joplin   Treated Mood
Products Plant
Joplin,  Missouri
Region 7

National Industrial
Environmental Services
  (NIES)
Fur ley,  Kansas
Region 7
IRECO Chemicals
Tooele County,  Utah
Region 8
ARCO Prudhoe Bay-
Eastern
  Operating Area
Prudhoe Bay, Alaska
Region 10
112-acre wood treating facility
with a spray irrigation field,
surface impoundments,  ponds,  and
a drum storage area.
Mood treatment facility with
ponds, surface impoundments,  and
landfills.  Silver Creek,  near
the facility, receives ground
water from below the site.

80-acre hazardous waste treatment
and disposal facility with
treatment ponds,  evaporation
ponds, and land disposal cells.
Prairie Creek flows nearby and
there are several ponds near the
facility.  Ground water flows to
springs of Prairie Creek.

Explosives testing and disposal
area in quarry.   Remote location
that is a known breeding and
wintering area for golden eagles,
great horned owls, prairie
falcons, red-tailed hawks, and
ferruginous hawks.

Oil exploration,  production,  and
development site on the tundra of
Alaska's North Slope with
landfills, surface impoundments,
container storage areas,  tanks,
waste piles,  a recycling unit,
and incinerators.
RFA has been
completed and
recommends certain
areas and SWMUs for
closer inspection
in an RFI.

Submitted a
proposal for ACLs.
Consent agreement
and order requires
NIES to establish
ACLs.
Applied for RCRA
permit.  Subject to
a compliance order
until standards can
be set for
operation of this
type of facility.

RFA completed with
recommendations for
RFIs at reserve
pits and some other
pits at this site.
On-site and nearby off-site soils
are contaminated from wood treating
operations.  Creek also
contaminated from wastewater
outfall.
Ground water and surface water may
be contaminated with creosote
compounds, barium, beryllium,
nickel, copper, vanadium, and zinc.
Surface water and ground water
contaminated with VOCs, beryllium,
chromium (VI), cadmium, mercury,
and phthalates.  Release is via
leaching to ground water and
transport to surface water through
solution pathways.
Atmospheric disturbance caused by
detonation of waste explosives.
Surface water, soil, and tundra
vegetation of the area potentially
contaminated by oily debris and
drilling muds containing arsenic,
barium, cadmium, chromium,  lead,
nickel, benzene, toluene,
naphthalene, and fluoranthrene.
Release is by direct discharge to
the tundra, road and gravel pad
application of waste liquids,  and
seepage from pits.
One area of very sparse
vegetation.
EPA denied/revised some ACLs
to incorporate protection of
aquatic life.
ACLs for 17 of 35 constituents
are based on aquatic life
protection criteria.
U.S. Fish and Hildlife study
found successful raptor
breeding, nesting, and
fledging in the vicinity of
the detonation area.   Possible
displacement of nesting in the
quarry.

Potential ecological effects
include bioaccumulation and
toxicity of hazardous
constituents.

RFA provided no assessment of
ecological impacts.

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                                     11-13

 wetlands and/or other surface water,  resulting in potential,  if not
 documented,  aquatic  ecological effects.

       Three  case studies  describe damages  from facilities situated within 100-
 year floodplains.  In each case,  severe  flooding and surface  water releases of
 many types of hazardous constituents  resulted in ecological effects such as
 crab and fish kills,  vegetation destruction,  and chronic exposures of plant
 and aquatic  species .

       Similar effects were noted in five wetlands damage cases,  where releases
 included direct discharges such as the dumping of battery acids to wetland
 waters from  a lead recycling facility, and indirect discharges such as
 leaching to  wetlands from FOB -contaminated sludges stored in  unlined pits.
 Significant  ecological impacts may also  have  occurred at a landfill site due
 to leaching  of hazardous  constituents just upstream of a. 1,200-acre national
 wildlife refuge.

              Damages
       Of the 16  Subtitle  C cases developed for this  analysis,  actual damages
 were reported for eight sites.   Seven of the  eight Location Standards damage
 cases present at least  limited information on observed ecological effects.
 A variety of ecological impacts were  identified at these 15 case study sites.
 Impacts to wetlands,  aquatic life (including  fish and benthic  and other
 invertebrates) and terrestrial wildlife were  reported in nine,  14,  and one
 case(s),  respectively.  The most commonly observed ecological  impacts at the
 case study facilities include mortality (5 cases) , decreased species richness
 and diversity (5 cases) ,  bioaccumulation of toxics (3 cases) ,  decreased
 productivity (2  cases) , increased contaminant body burden (2 cases) , habitat
 alteration (1 case) ,  deformity (1 case) ,  stunted growth (1 case) ,  and life
 cycle alteration (1  case) .

       Potential  Threats

       The other  eight Subtitle C case studies developed for this report
 contained information on  potential ecological threats.   Additional studies
 have been initiated,  in some instances, to assess these potential threats.
 Potential chronic and acute effects have been postulated at four and five
 facilities, respectively.  The potential for  bioaccumulation (2 cases),  direct
 effects (1 case) ,  and contamination of a sensitive area (1 case) have also
 been identified.  In addition,  the cases refer to two ongoing  studies of
 species diversity and three ongoing bioassay  analyses for toxicity.

       3.1.4  Characteristics of Subtitle C Facilities Posing a  Threat

       The case studies  described above illustrate the variety  of facility
 types ,  waste management practices ,  environmental settings ,  and  waste types
 associated with  ecological threats at RCRA Subtitle  C facilities.   Eight of
~the 16 Subtitle  C facility case studies developed for this report provide
 information on the nature of observed ecological threats .   The  other eight
 cases demonstrate how potential ecological threats can introduce special
 ecological considerations to permitting and corrective action decision making.

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                                     11-14

In the following discussions of facility type, setting, and waste
characteristics, we consider all 16 of the general Subtitle C facility case
studies, as well as the eight damage cases presented in the Location Standards
Background Information Documents/RIA, in order to assess characteristics
important in determining the ecological threat potential of Subtitle C
facilities.

      Facility Types

      Of the 24 Subtitle C facilities identified as posing ecological threats,
13 are primarily waste treatment, storage, or disposal facilities (TSDFs).
The remaining 11 cases involve waste management units at manufacturing
facilities.  These manufacturing operations include three wood treatment
plants, three chemical manufacturing plants, and five plants that produce
weapons, auto equipment, chrome-plated products, and unknown products.

      The 16 case study facilities for which original documentation was
obtained (via Regional visits and telephone contacts) encompass a wide range
of RCRA Subtitle C program situations.  Six facilities have included
ecological criteria in petitions for alternate concentration limits (ACLs).
Four cases arise from some consideration of ecological threats in RFAs or
RFIs, and two others are currently undertaking or negotiating Subpart S
corrective action steps outside the RFA/RFI process to mitigate ecological
threats. One case study site became an ecological concern because of potential
ecological impacts related to its voluntarily proposed corrective measure.
Ecological threats at one case study facility were investigated under CERCLA,
but are now being addressed under RCRA authority.  One facility has had an
ecological study performed as part of permitting, and another is proposing
ecological assessments and bioassays coinciding with a request for a permit
modification.  The RCRA program status is not available for the eight Location
Standards damage cases.

      Waste Management Practices

      Landfills and surface impoundments  (including treatment and storage
ponds, pits, and lagoons) are the predominant types of waste management units
at the case study facilities.  Container storage areas are implicated as
sources of ecological threats in a few cases, as are wastewater treatment
discharges and waste piles.

      The predominant release/exposure pathway from these management practices
is by subsurface leaching from a lagoon, pit, or landfill to ground water with
subsequent migration to surface water (18 cases).  Overland flow to surface
waters occurs in 10 cases as a result of surface impoundment releases and is
an important exposure pathway, particularly for the cases illustrated in the
Location Standards documents.  Another release/exposure pathway of importance,
occurring in 8 cases, is the direct  discharge of wastes and wastewater to
surface waters.  Finally, the leaching and migration of spilled or land
applied waste was implicated in seven of the 24 Subtitle C damage cases.  The
release/exposure pathways observed in the case studies are summarized in
Exhibit II-2.

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                                     11-15
                                  EXHIBIT II-2

                    SUBTITLE  C  CASE STUDY RELEASE/EXPOSURE
                                    PATHWAYS
         20
(0

'o
3
05

(A
(0
O

"o
0)

I
         15
          10
            Lsnd Disposal Land Disposal   Direct     Spills and
            Subsurface    Overland    Discharge^ Lend Application
             Release* v    Releases v

                   Release/Exposure Pathway
                                                          Other
a/    Land disposal subsurface releases consist of leaching of wastes  or
      constituents from  landfills,  lagoons, pits, or ponds with subsequent
      migration to ecological  receptors.
b/    Land disposal overland releases consist of runoff from landfills,
      lagoons, pits, or  ponds  to ecological receptors.
c/    Direct discharge of wastes or wastewaters to ecosystems (usually surface
      water).
d/    Spills and land application releases consist of migration of  spilled  or
      land applied wastes or constituents to ecological receptors.
e/    Other release/exposure pathways include volatilization and no release of
      hazardous constituents.

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                                     11-16
      Environmental Settings
      The Subtitle C damage case studies  are  predominantly located near
surface waters.  At 20 of the 24 facilities,  nearby surface waters are
identified as exposure points of potential  concern.   Twelve facilities are
either located in, or are near, wetlands.   Special habitats, such as
endangered and protected species habitat  and  wildlife refuges,  and floodplain
environments are identified in the vicinity of five facilities.  Information
on the environmental setting for three  facilities  is not available.  The
environmental settings for Subtitle C case  study facilities are summarized in
Exhibit II-3.
                                  EXHIBIT  II-3

                  SUBTITLE C CASE STUDY ENVIRONMENTAL SETTINGS
           25
           20
       at
       V)
       o
       M
       (0
       o
       o
       .a
19
           10
                 Surface Water*  Wetland*  Special Habitata  Floodplalna
                                                           Other
                             Ecological Setting
                                                                     C, -
  a/  The ecological settings  listed are those in the vicinity of the case
      study facilities.

-------
                                     11-17

      Wastes of Concern

      The waste contaminants of concern at Subtitle C facilities are quite
varied.  Organic contaminants posing ecological threats at these facilities
include aromatic hydrocarbons and substituted hydrocarbons, chlorinated
alkanes and alkenes, other volatile organic compounds, polyaromatic
hydrocarbons, and creosote compounds.  Metals, especially chromium, cadmium,
arsenic, mercury, beryllium, barium, nickel, and lead, are quite commonly
implicated as contaminants of concern as well.  PCBs, pesticides, acids and
alkalis are also identified as contaminants of concern.  Information regarding
constituent concentrations and waste volumes present at Subtitle C facilities
was incomplete and highly variable among the case studies and regulatory
development documentation and consequently is not included in this analysis.

3.2  Subtitle D Facilities

      3.2.1  Summary of Available Information

      The ecological threats resulting from RCRA Subtitle D (Solid Waste)
facilities were assessed based on an examination of the following documents:

      •     Subtitle D Criteria for Municipal Solid Waste Landfills RIA;
      •     OSWER Ecological Evaluation of a Municipal Landfill in the
            Superfund Program;
      •     OPA, OPPE Unfinished Business Report; and
      •     EPA Region 1 Draft Comparative Risk Assessment.

     'These four documents provide little data on the actual ecological
threats at existing RCRA Subtitle D facilities.  Resource damages (i.e., the
national extent of ecological threats) attributable to Subtitle D facilities
are measured only with regard to the estimated costs of providing drinking
water to users whose supply is contaminated from municipal solid waste
landfills (MSWLFs).  Data were available, however,  depicting a predominance of
releases from facilities regulated under Subtitle D.  Though the RIA contains
a discussion of the nature of ecological threats at these facilities,  we
identified only one damage case applicable for use in this analysis.

      3.2.2  Extent of Subtitle D Ecological Threats

      An estimated 6,479 MSWLFs were in use as of May 1987.   Thirteen percent
(842) of the MSWLFs are located within designated 100-year floodplains, and
six percent (388) are situated in wetland areas.  The Subtitle D Criteria for
MSWLFs RIA estimated that ground-water contamination has occurred at 71
percent (4,600) of all MSWLFs.  No specific data is available as to the extent
of contamination from MSWLFs to soil, surface water, or air.

      Of 83,794 industrial facilities (i.e., those facilities managing less
than 50 percent household or commercial wastes) regulated under Subtitle D,
hazardous release incidents have occurred at an estimated 1,168 facilities.
In addition, 111 Subtitle D municipal combustors burn greater than 6  million
tons of waste annually.  Emissions from these incinerators and combustors have
not been investigated on a national basis with regard to ecological risks.  As

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                                    11-18

with Subtitle C facilities,  the projected incidence of hazardous releases from
Subtitle D facilities does not provide a direct indication of ecological
damage, but it does indicate the need to assess ecological threats in Subtitle
D facility evaluations.

      3.2.3  Nature of Subtitle D Ecological Threats

      From the limited documentation available describing Subtitle D
ecological threats, we identified only one damage case study illustrating the
nature of these threats.   This study involved leaching from a 300-acre MSWLF
to on-site lakes and an adjacent sensitive wetlands area separating the site
from a coastal embayment 2,000 feet away.  Releases of ammonia, arsenic,
barium, vinyl chloride,  heavy metals,  pesticides, and volatile organics
affected on-site soils,  lakes, and nearby wetlands and estuarine systems.
Though many uncertainties in the risk assessment process precluded a
quantitative risk estimate,  projected ecological damages from contaminant
releases included toxic effects (e.g., impaired health and reproduction) to
freshwater and estuarine fish and macroinvertebrates.

      The damage case study described above and the discussion of MSWLFs
contained in the RIA do not provide adequate information to present any
detailed analysis of the ecological threat characteristics of Subtitle D
facilities in terms of observed ecological damages, waste management
practices, environmental settings, or primary wastes of concern at these
facilities.
3.3  Mining Waste

      3.3.1  Summary of Available Information

      The risks posed by mining sites were assessed based on an examination of
the following documents:

      •     Report to Congress:  Wastes from the Extraction and
            Beneficiation of Metallic Ores, Phosphate Rock, Asbestos,
            Overburden from Uranium Mining, and Oil Shale;
      •     OSW Draft Risk Screening Analysis of Mining Waste;
      •     SCS Summary of Environmental Incidents from the Disposal of
            Mining Waste.

      From these sources, we obtained information on the nature of mining
waste ecological threats, including damage case studies describing typical
contamination scenarios, mining waste contaminants of concern, release
mechanisms, and documented effects on nearby ecosystems.  With regard to the
national extent of these threats, we determined the number of active mining
sites and the proximity of these sites to designated sensitive environmental
areas.  It should be pointed out, however, that these sources provide only
case studies of mining waste sites.  They do not provide a general overview of
the extent of ecological threats at mining waste facilities and should not be
interpreted to be comprehensive or entirely representative of all mining

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                                     11-19

facilities.  Furthermore, some of the ecological damage cases may have been
caused by past mining waste management practices that are no longer followed.

      3.3.2  Extent of Mining Waste Ecological Threats

      The OSW risk screening analysis of mining waste identified 292 mines for
evaluation.  Of the 292 identified mine waste sites, 162 (59 percent) were
known to be active or potentially active.  Of the 162 active sites, 26 (16
percent) were located within five kilometers of an endangered or threatened
species habitat.  Of all 292 risk screen mines, 60 (23 percent) were located
within the boundaries of a national forest.  Phosphate mines may pose the most
significant threat to sensitive areas; 58 percent were within five kilometers
of threatened or endangered species habitat, and 78 percent were within five
kilometers of wetlands.  Although these data provide an indication of the
proximity of mining waste sites to sensitive areas, this information can only
indicate the potential for impacts and does not provide a clear measure of
ecological threat.

      3.3.3  Nature of Mining Waste Ecological Threats

      Based on 68 case studies documented in the SCS Summary of Environmental
Incidents, OFA identified contaminant releases from 45 active mining waste
sites that have resulted in threats to terrestrial and aquatic plant and
animal species through soil, ground-water,  and surface water exposure
pathways.  Exhibit II-4 presents the summaries of 10 of these 45 cases that
best represent the nature of ecological threats at mining facilities.

      Observed Ecological Damages

      Adverse effects on non-human biota were reported in 41 (60 percent) of
the 68 case studies.  These effects ranged in magnitude from mere "stress on
aquatic life," to inhibition of species reproductive capabilities,  to acute
exposures resulting in fish kills, to destruction of all aquatic life.
Catastrophic events (e.g., holding pond dam failure and pipeline breaks)  have
resulted in extensive acute ecological damages, including large scale fish
kills and population impairment and reduction for birds, benthos and other
aquatic organisms.  Other ecological damages observed include bioaccumulation
of heavy metals in salmonids.

      3.3.4  Characteristics of Mining Facilities Posing a Threat

      Based on the damage case studies and discussion of mining waste sites
contained in the SCS Summary of Environmental Incidents, we have summarized
below the characteristics of mining waste management that pose ecological
threats.  We discuss mining facility types, waste management practices,
environmental settings, and primary wastes  of concern at these facilities.

      Facility Types

      Exhibit II-5 illustrates the distribution of mining waste case studies
among various industry segments.  Nearly half of the damage cases involve
copper mining.  Eighteen cases each involve the mining of silver and gold.

-------
                                                                   EXHIBIT  II  -  4
  Damage Case
                                       DAMAGE CASE STUDY IHFORMATIOU AVAILABLE DESCRIBING ECOLOGICAL IMPACTS AT MINING HASTE SITES

                                  Facility/Site  Description	    	Characterization of Ecological Impacts
AZCB
AZMM
COUD
IDBN
MOBU
MOAC
MTUL
NVRA
NMWQ
U1KC
An active open pit mine with copper leachate
operations.  Source of contamination from tailings
pond.

An active copper mine and smelter with copper
leachate operations.  Main source of contamination
from tailings pond.
                                Waste release from pond after heavy rains during  the winter of  1978-1979.
                                adjacent creek was contaminated with metals  and low pH.  Aquatic  and bird
                                populations were impaired as a result of the contamination.
                                                                                                                                                       An
An active metals mine.
contaminant source.
Tailings ponds  are  likely
An active open pit copper, aluminum,  and cobalt mine
and milling operation.  Contaminant source  from
waste piles and tailings pond.

An active lead and zinc mine with milling
operations.  Tailings pond and  mine water are  likely
contaminant sources.

An active lead, zinc  and copper mine with milling
operations.  Main sources of contamination  are
tailings pond and mine water.

An active gold and silver mine  with cyanide leachate
and milling operations.  Main contamination sources
are tailings pond and leachate  solution.

An active gold mine and cyanide leaching operations.
Cyanide stored in drums and an  unlined  holding pond
are main sources of contamination.
Active open pit and underground molybdenum mines and
milling operations.  Tailings impoundments are main
source of contamination.

An active copper mine with precipitation  plant and
concentrator operations.  Contamination from
tailings pond and hauling waste.
448,000 gallons of leachate water released from tailing pond in a 24-hour period
after heavy rains.  Ninety-eight percent of aquatic life killed in an adjacent
creek.

Leachate seepage from tailings pond and subsequent migration to surface water.
River water quality degraded with high levels of copper, zinc, lead, mercury,
and total suspended solids.

Tailings leachate contaminate surface water via runoff with copper, cobalt,
iron, and sulfate.  Adjacent creek sterile for 35 miles.


Discharge of tailings and mine water to surface water.  Water quality degraded
with metals and organics.  Benthos communities reduced in a 3 mile stretch of an
adjacent creek.

Release of tailings from holding pond after dam failure during heavy rains.
Surface water contamination with lead, zinc,  copper and cadmium.  Heavy meals
have accumulated in an adjacent lake.

Failure of pond liner integrity permitted cyanide solution to leach from pond to
ground water.  Subsequent migration of cyanide leachate to surface water
resulted in surface water quality degradation.

15,000 gallons of leachate liquor released to ground water and surface water
after dam failure.  Improper disposal of cyanide barrels contributed to the
contamination incident.   Degradation of ground water and surface water has been
observed as a result of the release.

Tailings pipeline breaks in 1977, 1979, 1980,  and 1981 released concentrations
of cadmium, chromium, copper, silver and zinc to surface water.  Reduction in
aquatic organisms and bioaccumulation in salamanders have been observed.

Tailings leachate and erosion caused degradation of adjacent creek with total
suspended solids, copper and high concentrations of arsenic.
                                                                                                                     M
                                                                                                                      i

                                                                                                                     O
Source:  Summary of Environmental Incidents from the  Disposal of Mining Wastes.  SCS Engineers, 1985.

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                                     11-21

                                  EXHIBIT II-5

                     MINING WASTE CASE STUDY FACILITY TYPES
          30
          25
      to
      .g   20

      Q)
      (0
      (0
      Q   18
      ซ*-
      o
      k>
      0)
      I   ,.
                  Copper    Gold
                                   Silver
                                           Lead
                                                    Zinc     Other
                                Facility Type
Sixteen of the 45 cases involve lead mining, and 14  of  the  cases involve zinc
mining.  Three damage cases are characterized as "hard  rock"  mining.   Other
mining industry segments identified among the damage case studies include
cadmium, cobalt, barite, indium, molybdenum, and "metals."

      Waste Management Practices

      Mining waste management units associated with  the damage cases  are ponds
(33 cases), waste piles (24 cases), and leach residue and waste rock  dumps (14
cases) .  In one damage case discharge of wastewater  from a  treatment  plant
resulted in ecological threats, and in another direct discharge of wastes to
surface water produced the threat.

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                                     11-22

      In 26 of the 45 damage cases continuous, intermittent, or seasonal
runoff from ponds, piles, or dumps to surface water provided the
release/exposure pathway.  In 18 damage cases, contaminants were released by
continuous, intermittent, or seasonal seepage to ground water with subsequent
migration to ecological receptors.  In 12 of 45 cases, spills from
catastrophic events, such as impoundment failure, produced releases resulting
in ecological threats.   In two cases, deliberate releases were implicated in
the observed ecological threats.  Exhibit II-6 illustrates the distribution of
release/exposure pathways responsible for ecological threats at the mining
facility case studies.

      Environmental Setting

      Limited data was available describing the locations of the mining
facilities cited as experiencing observed or potential ecological impacts.
However, all 45 facilities indicate damages to surface water.  In one case,
damage to soil is also indicated.

      Wastes of Concern

      As evident in the case studies, the predominant mining waste types
causing ecological damages are tailings, over burden, leachate residue, and
mine water.  The primary contaminants of concern in the 68 cases include heavy
metals such as copper,  zinc, iron, and manganese.  Seventy percent of all of
the cases also reported the presence of silver, arsenic, cadmium, mercury, and
lead.  Acidic wastewater releases from these sites contain high levels of
dissolved minerals and decrease the pH of streams.  The frequency with which
specific contaminants occur in mining wastes is dependent upon the industry
sector (e.g., copper or zinc).

3.4  Oil and Gas Waste

      3.4.1  Summary of Available Information

      The ecological risks resulting from oil and gas waste management are
well documented compared to many of the other RCRA program areas.  For this
analysis, we assessed these risks based on an examination of the following
documents:

      •     Report to Congress:  Management of Wastes from the
            Exploration, Development, and Production of Crude Oil,
            Natural Gas, and Geothermal Energy; and
      •     Ecological Impacts of Oil and Gas Waste Streams.

      These sources contained information on the national extent of ecological
threats posed by oil and gas wastes in terms of the quantities of wastes
produced  and the areal extent of resources potentially impacted.  The nature
of oil and gas ecological impacts was illustrated by damage case studies
describing observed ecological damages, typical facility waste practices,
environmental settings, and contaminants of concern.  Our review of these case
studies,  however, is based only on the information presented in the Report to
Congress, and therefore should not be interpreted to be in any way

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                                      11-23
                                   EXHIBIT II-6

                    MINING WASTE CASE STUDY RELEASE/EXPOSURE
                                     PATHWAYS
       (0
       .2
       T3
       4-*
       to
       0>
       w
       (0
       O
       0)
       .fi

       3
            30
            20
20
15
10
                   Land Disposal
                    Subsurface
                    Land Dlapoaal
                     Ovarland
                     ซ•(••••• ^
 DIraet
Discharge^
  Spill* and
Land Application ^
                         Release/Exposure Pathway
a/    Land disposal  subsurface releases consist of leaching of wastes or
      constituents from landfills,  lagoons, pits, or ponds with  subsequent
      migration to ecological receptors.
b/    Land disposal  overland releases consist of runoff from landfills,
      lagoons, pits, or ponds to ecological receptors.
c/    Direct discharge  of wastes or wastewaters to ecosystems (usually surface
      water).
d/    Spills and land application consist of migration of spilled or  land
      applied wastes or constituents to ecological receptors.

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                                     11-24

comprehensive or entirely representative of impacts from all oil and gas waste
facilities.

      3.4.2  Extent of Oil and Gas Ecological Threats

      Oil and gas operations produce approximately 20.9 billion barrels of
production waste, and 361 million barrels of drilling waste annually from
roughly 835,000 active oil and gas wells nationwide.  Approximately 9,000 oil
spills occur each year, releasing a total of over 11 million barrels of oil.
Of 190 counties in the U.S. identified as having high levels of oil and gas
exploration and production activity, 13 contain Federally-designated
critically sensitive habitats.  Federal leases have granted 25 of the 191
million acres contained in the National Forest system (13 percent) for oil and
gas exploration and/or production.  Similarly, approximately 335,000 acres
within the National Park system (roughly four percent) are under lease for oil
and gas activity.  Though little direct evidence is available on the actual
extent of ecological effects from oil and gas waste operations, the large
volume of wastes generated and the severity of the potential ecological threat
indicate a need for assessing ecological risks at these sites.

      3.4.3  Nature of Oil and Gas Ecological Threats

      The Oil and Gas Report to Congress presents 61 damage cases occurring in
13 states.  Twenty-nine of the 61 cases (48 percent) contain documented
evidence of ecological damage (not including any cases of damage solely to
agricultural resources or drinking water).   We selected 10 of these 29 cases
that we feel are representative of the diverse existing and potential
ecological impacts resulting from active oil and gas waste management
operations for presentation in Exhibit II-7.

      Observed Ecological Damages

      Ecological damages at oil and gas waste sites may occur from short-term,
acute, perhaps smaller-scale release events (e.g., from a spill) where damage
to biota in contact with the wastes occurs, or as a result of long-term,
chronic exposures (e.g., from low-concentration leaching from surface
impoundments).  The observed ecological damages from the cases presented in
Exhibit II-7 include fish kills, benthic invertebrate population reductions,
vegetation damage, elevated tissue residual levels of bioaccumulating organic
chemicals, and severe alteration of invertebrate community structure.
Different environments and varying regulatory influences also contribute to
the diverse nature of ecological damages resulting from oil and gas waste
activities.  In Alaska, for example, State law permits production reserve pits
to discharge liquid directly to roads and tundra.  An estimated 100 million
gallons is disposed in this manner, posing potentially widespread impacts on
tundra vegetation and surface water aquatic fauna.

      3.4.4  Characteristics of Oil and Gas Facilities Posing a Threat

      Based on the damage case studies and discussion of oil and gas waste
sites contained  in the Report to Congress,  we have summarized below the

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                                                                     EXHIBIT  II  -  7
  Damage Case
                   DAMAGE CASE STUDY INFORMATION AVAILABLE DESCRIBING ECOLOGICAL IMPACTS AT OIL AND GAS WASTE SITES

              Facility/Site  Description	    	Characterization of Ecological Impacts
PA 09
LA 20
LA 45
KS 03
OK 06
TX 22
CA 21
AK 08
AK 12
AK 09
                    Four county area with thousands of marginal stripper
                    wells and abandoned drill  pits in and around
                    Allegheny Forest.   81 known  improperly plugged oil
                    wells in the Allegheny Reservoir.
Oil drilling barge situated  in  a bayou within 1,300
feet of active oyster harvesting and State oyster
seeding area.

Oil production facility located adjacent to a
cypress swamp.
                    Drilling activities  near  a  farm and natural spring.
                    Highly saline produced  water injection well located
                    on a private ranch.
                    Drilling operation including a drilling muds reserve
                    pit located near residential property.
                    Oil production and drilling  fields in California
                    mountain valleys.
                    Drilling sites located  near  fish and waterfowl
                    habitat on North Slope  of Alaska.
                    Test drilling well site  in tundra environment.  Site
                    includes a drilling fluid reserve pit.
                    Drilling operations  adjacent to an arctic wetland.
Chronic low level releases of oils and oily, high-chloride produced water
directly to soils and surface waters.  "Lethal effect on trout streams and
damage to timber and habitat for deer, bear, and grouse."  Suppressed fish
population in all streams of Allegheny Forest.  Elevated levels of Ba, Fe, Mn,
Methane, Cd, TDS, and aromatic HCs.

Drilling barge discharging drill cuttings and muds into bayou.  High metal
content of discharges may have long-term effect on commercial oyster fields due
to accumulation of metals in sediments.

Discharge of high-chloride produced waters to nearby canal which empties into a
cypress swamp.  Estimated 4,088 acres of swamp "severely damaged;" 73 percent of
the trees were dead and 18 percent were stressed.  Salinity levels in canal =
32,000 ppm.

Discharge of 200-400 cubic feet of dissolved rock salt into unlined reserve pit.
Conductivity of the sprlngwater equaled 7,250 uhmos (2,000 uhmos is the accepted
level at which soil damage occurs), impeding vegetative growth.

Saltwater migration from injection zone to the ground surface.  Surface soils
and a nearby freshwater stream were contaminated, leading to aquatic and
terrestrial vegetation kills.

Spreading of drilling muds (containing high levels of arsenic, barium, chromium,
lead, sulfates, other metals, and chlorides) downhill from the site towards
residential property.  Drilling muds contaminated nearby surface soils and
entered a draw area that flows into two private stock tanks -- killing over 700
fish.

High chloride produced water discharged to ephemeral streams and diverted to
central sumps for disposal through evaporation and infiltration to ground water.
Potentially severe damage to ground water through infiltration of produced
water.  Birds and animals trapped in oily deposits in ephemeral streams.

Drilling fluids discharged to nearby fish and waterfowl habitat.
Bioaccumulation of barium, titanium, iron, copper, and molybdenum documented in
fish exposed to drilling fluids.  Reduced fertility and growth observed in fish.

Reserve pit berm wash out allowed drilling fluids to flow onto tundra.  Fluids
containing high levels of chromium, oil, and grease leached into soil
downgradient from the pit.  Vegetation kill area approximately one-half acre.
Soil contamination of drill pad with salt and hydrocarbons likely to keep area
barren for years.  Site is in a caribou calving area.

Leakage, spills, and discharge to nearby pond and arctic wetland environment led
to destruction of all invertebrate and plant life in the contaminated pond.
Contaminated pond sediments will impede repopulation of the waters and may leach
constitutents to adjacent wetlands.
                                                                                                                                              i
                                                                                                                                              to
Source:   Report to Congress:   "Management  of Wastes from the Exploration, Development, and Production of Crude Oil, Natural Gas, and Geothermal Energy,"
December, 1987.

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                                     11-26

ecological threat characteristics posed by oil and gas facilities in terms of
the waste management practices, environmental settings, and primary wastes of
concern at these facilities.

      Waste Management Practices

      The oil and gas waste management practices identified in the damage
cases as threatening nearby ecosystems include storage or disposal in surface
impoundments (13 cases), direct discharge to surface waters (12 cases), land
application (5 cases), and underground injection (1 case).

      Release of, and ecological exposure to, oil/gas contaminants occurred by
leaching and/or runoff from surface impoundments in nine cases, direct
discharge of wastes to the environment (surface water and tundra) in 13 cases,
and via spills or land application of wastes in seven cases.  Exhibit II-8
illustrates the distribution of release/exposure pathways associated with the
oil and gas damage cases.

      Environmental Setting

      The oil and gas waste sites experiencing observed or potential
ecological impacts are predominantly located near surface waters.  Sixteen of
the damage case sites are located near surface waters.  Eight sites are
located adjacent to wetland environments (including tundra).  Six damage cases
involve degradation of terrestrial vegetation.  One of the 29 sites is
adjacent to a sensitive habitat.  Exhibit II-9 illustrates the distribution of
environmental settings affected by the 29 oil and gas damage cases.

      Wastes of Concern

      The principal waste types contributing to the ecological damages at oil
and gas waste sites are drilling muds, production brines and chlorinated
wastewater, and general oil field effluents and fracturing fluids.  Heavy
metals and chlorides are the most commonly cited constituents in the damage
cases and available documentation, though many other inorganics may be
contained in the waste fluids (See Appendix F).


3.5  Coal-Fired Utility

      3.5.1  Summary of Available Information

      Only one source, the Coal Utilities Report to Congress, contained
information relevant to our analysis of ecological risks resulting from coal
utility waste management.  This report includes general data and case study
information pertaining to the nature and extent of observed and potential
threats posed by these facilities.  Our review of case studies for this
section, however, is based only on the information presented in the Report to
Congress, and therefore should not be interpreted to be comprehensive or
entirely representative of impacts from all coal-fired utility waste
facilities.

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                                     11-27
                                  EXHIBIT II-8

                    OIL AND GAS CASE STUDY RELEASE/EXPOSURE
                                    PATHWAYS
         14
         12  —
     (0
     0>
         10
     M    8
     (0
     O
     ซt-
     O    8
     JQ
     |    ซ
                   Land Disposal
                    Rซlซaa*a *
 Direct
Discharge
  Spills and
Land Application
                       Release/Exposure Pathway
a/    Land disposal releases  consist  of leaching or  overland flow of wastes or
      constituents from  landfills,  lagoons,  pits,  or ponds  with subsequent
      migration to ecological receptors.
b/    Direct discharge of wastes  or wastewaters  to ecosystems (usually surface
      water).
c/    Spills and land application consist  of migration of spilled or land
      applied wastes or  constituents  to ecological receptors.

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                                   11-28


                               EXHIBIT  II-9


            OIL AND GAS  CASE STUDY ENVIRONMENTAL SETTINGS
    20
(0   15
0>

T5

4-1

(0
CO   -in
o
0>
JD


3
             Surfcc* Water
                           Wetlands
                                        Terrestrial
                                        Vegetation

                      Environmental Setting
                                                      Sensitive

                                                      Habitats

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                                     11-29

      3.5.2  Extent of Coal-Fired Utility Ecological Threats

      In 1984, 514 coal utilities plants generated 90 percent of all fossil
fuel combustion wastes, totalling nearly 69 million tons.  The extent of
ground-water contamination resulting from these sites is illustrated by the
fact that out of 4,700 observations of well samples taken from 66 coal-fired
utility sites in 13 states, contaminant concentrations in 7 percent (329) of
the samples exceeded Primary Drinking Water Standards (PDWS), and 30 percent
(1,410) exceeded Secondary Drinking Water Standards (SOWS).  Based on data for
a sample of 100 coal-fired utility waste sites obtained from the Nature
Conservancy's Heritage Program, 12 facilities were situated within five
kilometers of a Federally designated threatened or endangered species area; 29
facilities were within five kilometers of State designated critically
endangered species areas; 32 facilities were within areas containing species
or natural communities "of concern;" and 15 did not respond to the sampling
study.  As with the information gathered for oil/gas facilities, the data for
coal-fired utility facilities was derived from summary information in the
Report to Congress and should not be regarded as comprehensive and
representative of all coal-fired utility facilities.

      3.5.3  Nature of Coal-Fired Utilities Ecological Threats

      The Coal-Fired Utilities Report to Congress presented 14 damage case
studies in eight states.  Five of these cases (36 percent) contained
documented evidence of existing or potential ecological damage (not including
any cases of damage solely to agricultural resources or drinking water).
These five cases are briefly described in Exhibit 11-10.

      Observed Ecological Damages

      Severe, large-scale contaminant-release incidents near aquatic
ecosystems have resulted in extensive kills of fish, bottom-dwelling
organisms, and aquatic and terrestrial plant life.  The existence of other,
perhaps less acute, aquatic and terrestrial effects (e.g., "visual indications
of marsh contamination") and contaminated environmental media is also evident
in the damage cases.

      3.5.4  Characteristics of Coal-Fired Utility Facilities Posing a Threat

      Based on the damage case studies and discussion of coal-fired utility
waste sites contained in the Report to Congress, we have summarized below the
coal utility facility characteristics associated with ecological threats. We
discuss waste management practices, environmental settings, and primary wastes
of concern at these facilities.

      Waste Management Practices

      Coal-fired utility waste management practices resulting in ecological
damage typically involve the improper storage or mishandling of waste sludges
and fly ash wastes.  Among the case studies,  discharge of wastes to surface
water (2 cases),  and waste storage in surface impoundments (2 cases) and a
landfill (1 case) were responsible for the observed ecological threats.

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                                                                 EXHIBIT  II  -  10
   Damage Case
           DAMAGE CASE STUDY  IHFORMATIOH AVAILABLE DESCRIBING ECOLOGICAL IMPACTS AT COAL UTILITY HASTE SITES

              Facility/Site Description	    	Characterization of Ecological Impacts
Envirosphere
PA, 1975
Envirosphere
CT, 1971
Envirosphere
VA, 1967
D&M
Hunts Brook
Watershed
D&M
Canesville Site
Private waste handler illegally disposing  fly ash to
tidal wetland.
Municipal landfill located in a marsh  accepts fly
ash.
Fly ash settling lagoon situated near  the Clinch
River.
Fly ash disposed along three tributaries of Hunts
Brook.
Disposal site for coal combustion waste.  Sludge
deposited next to fly ash pond.
Visual indications of marsh contamination from fly ash leachate.  Heavy metal-
laden ash remaining in marsh threatens numerous wetland ecosystems.  Impacts not
yet determined.

Surveys revealed numerous Secondary Drinking Water Standards (SOWS) contaminants
present in the marsh that are derived from fly ash leachate.  Potential risk to
wetland species exists from heavy metals in ash.

Collapse of a dike surrounding the fly ash settling lagoon,  releasing 130
million gallons of caustic solution (pH 12) to the river.   Fish kills extended
90 miles downstream.  Reduction in bottom dwelling organisms extended to 77
miles below the site.   All such organisms eliminated within 4 miles of site.
Recovery period greater than two years.

Sampling of surface water contamination downstream of dumping sites indicated
levels of iron, sulfate,  and dissolved solids 100 times those measured upstream.
Levels of iron and IDS in the surface water increased from less than the SOWS
upstream to over 100 and 44 times the SOWS, respectively,  downstream from the
site.  No ecological effects were measured.

Groundwater contamination -- potential for migration to nearby river.
Contaminants include:   cadmium,  chromium,  lead,  arsenic.   No ecological effects
were measured.
                                                                                                                                                               OJ
                                                                                                                                                               o
Source:   Report to Congress:   "Wastes  from the Combustion of Coal by Electric  Utility Power  Plants," February,  1988.

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                                     11-31

      Environmental Setting

      Though few data were available describing the locations of coal-fired
utility waste sites, those sites identified in the damage cases as
experiencing observed or potential ecological impacts were almost exclusively
located near wetlands (2 cases) or other types of surface water bodies (2
cases).  One of the five case studies is located in a floodplain.

      Wastes of Concern

      Fly ash wastes represent the most ubiquitous ecological threat posed by
the coal-fired utilities.  Heavy metals are the primary constituents of
concern in this waste.  The available documentation and case studies suggest
that organic compounds are not of significant concern at coal-fired utility
waste facilities (See Appendix F).


3.6  Smelting and Refining Waste

      3.6.1  Summary of Available Information

      The 1988 draft Smelting and Refining Report to Congress served as the
sole source of information relevant to our analysis of ecological risks
resulting from activities at smelting and refining facilities.   This report
includes data pertaining to the nature and extent of current and potential
ecological threats posed by these facilities.   The report describes practices
at only copper, lead, zinc, and aluminum facilities.

      3.6.2  Extent of Smelting and Refining Ecological Threats

      Smelting and refining operations generate an estimated nine million
metric tons of potentially hazardous wastes annually.  According to the Report
to Congress, 15 percent (1.35 MT) of these wastes are managed in unlined
storage and/or disposal facilities.  Contaminant concentrations in leachate
waste streams from 17 smelting and refining waste storage sites were examined
relative to Ambient Water Quality Criteria (AWQC) for eight hazardous
constituents.  All of these waste streams exceed the AWQC for at least one
constituent.  One should note, however,  that many of the waste  management
practices documented in the Report to Congress may not currently be followed
at smelting and refining facilities.

      3.6.3  Nature of Smelting and Refining Ecological Threats

      The 16 case studies contained in the Report to Congress,  indicate
releases may occur from smelting and refining facilities to all environmental
media.  Typical case studies describe devegetation and depletion of aquatic
life as a result of surface water and soil contamination from leaching and
wastewater discharge.  Of sixteen case studies identified in the Report to
Congress, ten sites that best represent the nature and extent of ecological
threats at smelting and refining waste sites are presented in Exhibit 11-11.

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                                                                    EXHIBIT  II  -  11
     Damage Case
                                      DAMAGE CASE STUDY IHFORHATIOH AVAILABLE DESCRIBING ECOLOGICAL IMPACTS AT SMELTING AND REFINING SITES

                                       Facility/Site  Description	    	Characterization of Ecological  Impacts
New Jersey Zinc
 Company
Palmerton, PA
Kaiser Aluminum and
 Chemical
Corporation
Mead, HA

Eastalco Aluminum
 Company
Frederick, MD
ASARCO Smelter
East Helena, MT
ORMET Corporation
Hannibal, OH
Reynolds Metal
 Company
Longview, WA
Eagle Mine
Belden, CO
Silver Bow Creek, MT
Bunker Hill Site
Shoshone County, ID
Anaconda Smelter
Mill Creek, MT
Primary zinc smelter and refinery that  has  been  in
operation since 1899.   Ranked number  10 on
Pennsylvania Superfund list as a result of  past
smelter stack emissions and contamination from a
slag pile approximately two miles long,  1,000 feet
wide and 400 feet high.

An active aluminum reduction facility that  has
stored spent potliners on-site since  1942.
Primary aluminum reduction facility that  disposed  of
spent potliners in a landfill and also  stored  them
on the ground.
An active primary lead and by-product  metals  smelter
and an inactive zinc smelter.   Contaminant  sources
include stack emissions,  a 30-acre slag  pile,  a  21-
acre ore storage area, and holding pond  for process
fluids.  The site is currently on the  Superfund  NPL.

This facility is a primary aluminum reduction plant.
Cryolite recovery slurry is stored in  a  lagoon,  and
residual spent potliner debris persists  on-site  from
previous landfillings.

An aluminum reduction plant that has been in
operation from 1941 to present.   The main
contamination sources are the  potliner storage piles
and the cryolite sludge lagoons.

A mine and processing facility that operated  from
1880 to 1983 and is currently  on the Superfund NPL.
Eagle River flows next to zinc roaster piles.
Superfund site influenced by historic  regional
mining, milling, and processing operations.

An inactive mine, mill, and smelter of lead,  zinc,
and other metals.  Metal processing wastes  include  a
160-acre slurry pond, slag piles,  and  a gypsum  pond.
Copper smelter in operation between 1884  and  1980,
currently listed on Superfund NPL.
Leachate and runoff from the slag pile have contaminated Aquashicola Creek
with cadmium, lead, zinc and copper concentrations approaching, and in some
cases exceeding, 300 times the ambient water quality criteria for the
protection of aquatic organisms.  Almost complete devegetation of a
mountainside near the smelter stack.


Liquids from an on-site industrial wastewater settling pond were found to
be seeping through soil and flushing contaminants from under the potliners.
The ground-water plume extends as far as the Little Spokane River
approximately two miles away.

Surface water sampling indicates that a tributary of the Tuscarora Creek
that flows past the landfill area has had concentrations of cyanide ten
times the chronic water quality criteria for the protection of aquatic
organisms and 2.4 times the acute criterion.

Sampling of surface soil, ground water, and air shows contamination with
metals.  Livestock and crops contain higher than normal levels of metal.
and there is a direct correlation of these levels with the soil
concentration.
On-site sampling data from 1983 show contamination with fluoride at 30
times the drinking water standard and cyanide of 50 times the water quality
criteria.


In 1983, fluoride and cyanide were measured in on-site monitoring wells at
concentrations 700 times drinking water standards and 500 times water
quality criteria, respectively.  Ground-water flows towards the Columbia
River.

Based on 1985 sampling data, concentrations of zinc, copper, cadmium, and
lead in the river at a point adjacent to the roaster piles are 24, 5, 4,
and 7 times, respectively, the chronic ambient water quality criteria for
the protection of aquatic organisms, and 4, 3, 1 and 3 times the acute
criteria.  The river is used along its entire length for fishing and other
recreation.

Sampling indicates both ground water and surface water are contaminated by
many metals at levels greater than drinking water standards.

Surface waters are contaminated with metals at levels greater than drinking
water standards and ambient water quality criteria for the protection of
aquatic organisms.  Fish are not able to live in the section of the Coeur
D'Alene River adjacent to the site.

Zinc and copper contamination of surface water exist at levels up to five
times the drinking water standards and 400 times both the chronic and acute
water quality criteria for the protection of aquatic organisms.
U)
S3
Source:  Report to Congress:  "Solid Waste from Selected  Metallic Ore Processing Operations," Draft July 15,  1988.

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                                     11-33

      Observed Ecological Damages

      Ecological damages may occur as a result of long-term, chronic exposure
from the continuous release of low concentration leachate.  The potential for
short-term, acute exposures also exist.  Contaminant concentrations up to 400
times both the chronic and acute water quality criteria for the protection of
aquatic organisms have been observed in surface waters adjacent to smelting
and refining sites.

      3.6.4 Characteristics of Smelting and Refining Facilities Posing a
            Threat

      Based on the damage case studies and discussion of smelting and refining
waste sites contained in the Report to Congress, we have summarized below the
smelting and refining facility characteristics associated with ecological
threats.  We discuss facility characteristics in terms of the waste management
practices, environmental settings, and primary wastes of concern at these
facilities.

      Waste Management Practices

      Smelting and refining waste management practices include the storage or
disposal of wastes in landfills (3 cases), settling or sludge ponds/lagoons (4
cases), and waste piles (5 cases).  Direct discharge of wastes to surface
waters or soils is the primary management practice in two cases.

      Exhibit 11-12 depicts the observed release/exposure pathways resulting
from smelting and refining management practices.  Seven cases involve a
continuous, intermittent, or seasonal seepage to ground water with subsequent
migration to ecological receptors.  In 4 of the 11 cases, overland releases
from ponds, piles, or dumps provided the release/exposure pathway.  Two cases
implicated deliberate releases in the observed ecological damages.

      Environmental Setting

      The proximity of smelting and refining sites to surface water may
influence the potential threat to aquatic environments.  Over 70 percent of the
sites examined in the Report to Congress were found to be within 2,000 feet of
surface water.

      Wastes of Concern

      The predominant waste types contributing to the ecological damage at
smelting and refining waste sites are spent potliners, cryolite slurries,
cryolite sludges, slags, and process fluids.  Heavy metals are the primary
constituents of concern found at these waste sites.   The frequency in which
these contaminants occur is dependent upon the industry sector (e.g.,  copper
or zinc smelting).  The available documentation and case studies suggest that
organic compounds are not of significant concern at smelting and refining
waste sites (See Appendix F).

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     (0
     0)
     (0
     (0
     o
     0)
     .n
     3
                                     11-34
                                 EXHIBIT 11-12

                       SMELTING AND  REFINING CASE STUDY
                           RELEASE/EXPOSURE PATHWAYS
                    Land Dl*po*al
                    Subsurface
                     {*•!••••• i>
Land Disposal
 Overland
 Rซl*aaซ* &
 Direct
Discharge^
                        Release/Exposure Pathway
a/    Land disposal subsurface  releases consist of leaching of wastes or
      constituents from  landfills,  lagoons,  pits,  or ponds with subsequent
      migration to ecological receptors.
b/    Land disposal overland releases consist of runoff from landfills,
      lagoons, pits, or  ponds to ecological  receptors.
c/    Direct discharge of wastes or wastewaters to ecosystems (usually  surface
      water).

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                                     11-35

                                   CHAPTER 4

                            SUMMARY AND CONCLUSIONS
      The preceding sections have discussed the available information
describing the documented and observed characteristics of ecological threats
at RCRA facilities.  The six RCRA facility-types or program areas investigated
were Subtitle C, Subtitle D, Mining Waste, Coal Utilities, Oil and Gas, and
Smelting and Refining.  The extent of the ecological threats at these
facilities has been summarized in a variety of broad regulatory and policy
analyses conducted by OSW and the EPA Regional Offices and are further
addressed in this study through OPA's interviews of RCRA professionals in the
EPA Regions and States.  The nature of these threats also has been summarized
in the various OSW studies and are further described in this paper through the
development and analysis of damage case studies for each RCRA program area.

4.1   Summary of Extent and Nature of Ecological Threats at RCRA Facilities

      Extent of the Ecological Threat

      The extent of ecological threats at RCRA facilities has been generally
described in Regulatory Impact Analyses, Reports to Congress, Background
Documents,  and special reports prepared by OSW and the EPA Regions.   Although
few of these sources investigate the extent of ecological impacts in great
detail, they do provide some indication of the problem.  For example, a high
percentage of the RCRA facilities were found to have experienced a release to
the environment; an estimated 71 percent of the Subtitle D facilities and 62
percent of the Subtitle C facilities have incurred resource damages as a
result of such releases.  OSW estimates that 17 percent of all Subtitle C
TSDFs will require surface water cleanup, 34 percent will require soil
cleanup, 30 percent will require ground-water cleanup, and seven percent of
the facilities will require air cleanup.  Roughly 11 million barrels of oil
and gas drilling wastes are released annually from over 9,000 spills.
Furthermore, an estimated 26 percent of the active mining and 32 percent of
the coal utility facilities are within five kilometers of sensitive
environmental areas.  Seventy-eight percent of the phosphate mines sampled
were within five kilometers of wetlands, and 60 percent of the mining case
studies reported effects on non-human biota.   Hence, waste management
activities conducted under all of these RCRA program areas pose a substantial
potential threat to the environment.

      OPA's interviews of 51 EPA Regional and State RCRA professionals
provided preliminary results about extent of ecological threats at RCRA
Subtitle C facilities.  Primary findings from these interviews are summarized
below.

      •     Many RCRA facilities may pose ecological threats,  but due to the
            relative youth of the RCRA program and the relative lack of
            attention given to ecological risks,  there is little available
            documentation to support any assessments or conclusions  about the

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                                     11-36

            nature and extent of ecological threats presented by RCRA
            facilities.

      •     The EPA Regional and State professionals identified 52 RCRA
            Subtitle C facilities with known, suspected, or potential
            ecological damages.  We were able to obtain documentation of the
            site conditions and history for 16 of these 52 facilities.

      •     There has been little emphasis placed on collecting ecological
            information either at the program analysis or site-specific
            assessment level.  Therefore, when ecological information has been
            collected, it may not be truly representative of the nature and
            extent of the problem.

      •     Interviewees from six Regions stated that ecological threats at
            RCRA facilities are given inadequate consideration.  This
            inadequacy was attributed to a lack of appropriate assessment
            methods, a lack of guidance, the impression that ecological
            concerns are "too big to deal with," program emphasis on human
            health, and an inability to address terrestrial threats.  Only one
            interviewee suggested that current considerations of ecological
            threats in RCRA were adequate.

      Nature of the Ecological Threat

      The precise nature of the ecological threats at RCRA facilities is not
well understood, but there are a number of examples of observed and predicted
ecological damages at RCRA facilities.  Based on these examples, we can
summarize the nature of ecological threats posed by RCRA facilities as
follows.

      •     The severity of ecological threats depends on

                  environmental setting (e.g., wetlands),
                  facility size (i.e., quantity of wastes released),
                  toxicity characteristics of the constituents released, and
                  the nature of the release event itself (e.g., flooding,
                  leaching to soil).

      •     Observed ecological damages from RCRA facility releases have been
            long- and short-term in nature, and include fish kills, diseased
            or desecrated benthic habitats, chronic or behavioral effects on
            aquatic and terrestrial plant and animal species, oyster
            mortality, reduced floral and faunal species diversity, and
            reduced productivity in wetland habitats.

      •     Evidence of potential ecological effects include increased
            contaminant body burdens in aquatic species, concentrations in
            water and soil that exceed water quality criteria or other levels
            of concern, sparse vegetation,  and contaminated soils.

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                                     11-37

      •     It is not clear whether most ecological damage actually does occur
            in aquatic habitats, or it is simply easier, and therefore more
            common, to characterize impacts in this medium.

      The wide range of hazardous substances managed at RCRA facilities, the
numerous release and exposure pathways, and the diverse nature of the observed
ecological impacts indicates that releases from these facilities have the
potential to affect all environmental media and known ecosystems.

4.2   Summary of Ecological Threat Characteristics Among RCRA Program Areas

      Our comparison of ecological threat characteristics among the identified
RCRA program areas is hindered by the representativeness of the data
describing these characteristics.  In collecting the data for this analysis,
disproportionate attention was paid to specific programs, geographic
locations, and facility types.  Nonetheless, we feel that certain trends and
distinctions are evident among the characteristics associated with ecological
threats in the various RCRA program areas.   These trends and distinctions are
discussed below.

      Management Practice

      The predominant waste management practice posing ecological  threats at
the RCRA areas is the storage or disposal of wastes in unlined surface
impoundments.  This practice has led to catastrophic releases through
containment structure failure as well as long-term leaching of hazardous
constituents to soils, ground water, and surface water bodies.   At oil and gas
facilities, the reinjection or surface discharge of high-chloride  produced
waters has posed a major threat.  Storage in waste piles at mining and
Subtitle C (and most likely other facility types as well) has caused damages
through surface runoff and leaching to the soils and ground water.  In sum, a
variety of land disposal practices have resulted in ecological damages.

      Environmental Setting

      The environmental setting of a waste management facility is  a critical
determinant of the ecological risk presented by the facility.  Environmental
setting influences ecological risk by determining the potential for receptors
to be exposed to releases.  For a setting to pose a threat, it must contain
pathways for releases to enter biologically active environments and also
contain receptors that can potentially be exposed to such releases.   Examples
of settings with high ecological risk potential based on the presence of
exposure pathways include wetlands,  floodplains,  and other locations near or
adjacent to surface waters.  Surface water contamination occurs through
numerous pathways, the most predominant being leaching of contaminants to
ground water that is hydrologically connected to surface water, and direct
discharge or surface runoff to surface water bodies.  Examples of  settings
with high ecological risk potential based on the presence of valued potential
receptors include wetlands, endangered and threatened species habitat, and
wildlife refuges.

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                                     11-38

      Waste Types

      A wide variety of hazardous constituents have been linked to ecological
damages at RCRA facilities.   Solvents,  other VOCs,  and metals have caused
damage at Subtitle C facilities.  Metals, pesticides, and biological
contaminants pose ecological threats at Subtitle D facilities.   The waste
types managed at large-volume, special waste facilities tend to be dominated
by heavy metal constituents.  In particular, heavy metals make up a high
percentage of coal utility fly ash, mining tailings, oil field effluents, and
smelting sludges.  High-chloride content process and waste waters are also a
significant threat at most RCRA facilities.

      Summary

      Exhibit 11-13 presents a summary table highlighting the ecological
threat characteristics of each of the RCRA program areas discussed in Chapter
3.  Based on the information available for each RCRA area, the table describes
the observed damages,  management practices, environmental settings,  and wastes
of concern that are most representative of the facilities which pose
ecological threats.  It is again noteworthy that the Subtitle C facility data
was obtained through first-hand analysis of available damage cases,  while for
the remaining five RCRA program areas,  the information contained in this
report is based on OPA's review of damage cases described in program analysis
and regulatory development documentation.

      Although this analysis of facility characteristics reveals some patterns
concerning practices,  wastes, and settings that pose the most severe
ecological threats, it is questionable whether these results can be
extrapolated to the RCRA facility population as a whole.  Such extrapolations
are tenuous mainly due to the limited nature of the available data
characterizing the RCRA facilities.  Over time, as more representative data is
collected, certain facility characteristics or waste management practices may
emerge as particularly severe ecological threats.  In the interim, we can
simply summarize available information and observe trends in ecological
impacts.

      One main conclusion can be drawn from this analysis, however.   RCRA
facilities are experiencing releases of a wide variety of hazardous and non-
hazardous constituents.  The severity of the ecological impact caused by these
releases is largely dependent on a facility's environmental setting.  Hence,
releases in wetlands, floodplains, surface waters,  or in ecologically vital or
sensitive habitats should be considered a potential source of ecological
damage.

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                                                                  EXHIBIT  II  -  13
Program Area
                                               OBSERVED ECOLOGICAL THREAT CHARACTERISTICS OF RCRA PROGRAM AREAS

                    Observed Ecological  Damages           Haste Management Practices         	Environmental Settings
                                                                                                                           Haste Types
Subtitle C
Subtitle D
Mining
Oil and Gas
Coal
Utility
Smelting
and
Refining
  Mortality -  fish  and vegetation
  kills
  Decreased species richness and
  diversity
  Increased body  burden  of
  toxicants
  Decreased productivity
  Altered life cycles
  Habitat alteration
  Impaired overall  health  and
  fertility of freshwater  and
  estuarine fish and  macro-
  invertebrates
  Potential for contamination to
  all environmental media  and
  thus widespread effects  to
  terrestrial and aquatic  species

  Fish kills
  Impairment and reduction in
  bird, benthic and other  aquatic
  organisms population
  Bioaccumulation in  terrestrial
  organisms
  Chronic and acute  damages
  Fish kills,  benthic
  invertebrate population
  reductions
  Reduced fertility  and growth  in
  aquatic species
  Vegetation damage
  Bioaccumulation
  Alteration of community
  structure

  Fish kills
  Eradication of bottom-dwelling
  organisms and other  aquatic and
  terrestrial plant  and animal
  life
  Chronic effects also likely
• Chronic and acute damages  to
  aquatic organisms
• Surface water contaminant
  concentrations >400 times  AWQC
  Landfills
  Surface  impoundments  (unlined)
  Container  storage
  Hastewater discharge
  Waste  piles
• Near surface waters
• Wetlands
• Special habitats (i.e.,
  endangered and protected
  species habitat, and wildlife
  refuge)
  Uncontained disposal (e.g.,
  dumping  to surface  waters)  of
  combustion fly ash
  Storage  in unlined  landfills  of
  all municipal wastes
  Tailings ponds
  Waste storage piles
  Waste hauling
  Surface impoundment
  Cyanide wash stored in drums
  Drilling operations
  Storage and disposal of
  drilling wastes in faulty
  surface impoundments
  Injection or discharge of
  process waters to ground
  surface
• Improper storage or mishandling
  of waste sludges and fly ash
  wastes
• Illegal or improper dumping of
  wastes
• Failure of surface impoundments
• On-site wastewater settling
  ponds
• Cryolite sludge lagoons
• Storage and disposal of spent
  potliners
  Limited available data
  13 percent of facilities in
  100-year floodplain
  6 percent in wetland areas
                                                                                            • Near surface waters
  Near surface waters
  Desert or tundra environment
  Limited available data
  Predominantly near surface
  water bodies
  Over 70 percent within 2,000
  feet of surface water
• Metals - Cr,  As,  Pb,  Hg
• Aromatic hydrocarbons
  and substituted aromatic
  compounds
• Solvents
• Other VOCs
• Creosote
• PCBs
• Acids
• Alkali
• Pesticides

• Particulates
ซ BOD
• Microbes
• Heavy Metals
• Pesticides
• VOCs
• PCDFs
• PCDDs

• Tailings, overburden,
  leachate solution, and
  mine water containing:
  cyanide, arsenic,
  copper, zinc, cadmium,
  lead, cobalt, silver,
  chromium, iron, TSS, pH

• Drilling muds,
  production brines,
  chlorinated wastewater,
  and oil field effluents
  and fracturing fluids
  containing:  chlorides,
  benzene, lead,
  phenanthrene, barium,
  arsenic, fluoride,
  antimony

• Fly ash wastes
  containing heavy metals
  (aluminum, arsenic,
  barium, cadmium,
  chromium, copper, lead,
  mercury, selenium and
  silicon)

" Spent potliners,
  cryolite slurries,
  cryolite sludges, slags,
  and process  fluids
  containing:  zinc,
  copper, cyanide, lead,
  cadmium and  fluoride

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                                    11-40

                             PART II BIBLIOGRAPHY

Bascietto, J.J.   Ecological Evaluation of a Municipal Landfill in the
      Superfund Program.  Office of Waste Programs Enforcement, Office of Solid
      Waste and Emergency Response, U.S. EPA.   No date.

IGF Inc.   Ecological Impacts Associated with Oil and Gas Waste Streams.
      Draft.  August 26,  1988.

IGF Inc.   Regulatory Impact Analysis/Background Information Document:
      Wetlands.   Final.   Prepared for Economic Analysis  Staff, Office of Solid
      Waste, U.S. EPA.   March 11, 1988.

IGF Inc.   Regulatory Impact Analysis/Background Information Document:
      Floodplains.  Final.  Prepared for Economic Analysis Staff,  Office of
      Solid Waste, U.S.  EPA.  March 11, 1988.

IGF Inc.   Regulatory Impact Analysis for the Proposed Rulemaking on Corrective
      Action for Solid Waste Management Units.  Volume I.  Draft.   Prepared
      for Economic Analysis Staff, Office of Solid Waste, U.S. EPA.  December
      23, 1987.

IGF Inc.   Preliminary Comparison of the Protectiveness of Human Health-Based
      Water Criteria for Aquatic Organisms.  Memorandum to Craig Zamuda,
      Office of Policy Analysis, U.S.  EPA from Robert Hegner and Margaret
      McVey.  June 22,  1988.

IGF Inc.   Availability of Ecological Criteria for Aquatic Organisms for
      Substances of Concern Under CERCLA and RCRA.  Draft.  Prepared for
      Office of Policy Analysis, U.S.  EPA.  August 3, 1988.

IGF Inc.   Risk Screening Analysis of Mining Wastes.  Draft.  Prepared for
      Office of Solid Waste, U.S. EPA.  October 15, 1987.

SCS Engineers.  Summary of Environmental Incidents from the Disposal of Mining
      Wastes.  Prepared for Office of Solid Waste, U.S.  EPA.  February 8,
      1985.

Temple, Barker & Sloane, Inc.  Regulatory Impact Analysis of Proposed
      Revisions to Subtitle D Criteria for Municipal Solid Waste Landfills.
      Prepared for Economic Analysis Staff, Office of Solid Waste, U.S.  EPA.
      December 11, 1987.

U.S. EPA Region I.  Ecological Risk Work Group.  Papers on Ecological Risks of
      RCRA Waste Sites, Superfund Sites, and Other Waste Sites (Municipal and
      Industrial Landfills).  Draft.  No date.

U.S. EPA.  Report to Congress on Solid Waste from Selected Metallic Ore
      Processing Operations.  Draft for Red Border Review.  Office of Solid
      Waste.  July 15, 1988.

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                                    11-41

U.S. EPA.  Report to Congress:   Wastes from the Combustion of Coal by Electric
      Utility Power Plants.  Office of Solid Waste and Emergency Response.
      EPA/530-SW-88-002.   February 1988.

U.S. EPA.  Report to Congress:   Management of Wastes from the Exploration,
      Development, and Production of Crude Oil, Natural Gas, and Geothermal
      Energy.  Volume 1 of 3.  Oil and Gas.  Office of Solid Waste and
      Emergency Response.  EPA/530-SW-88-03.  December 1987.

U.S. EPA.  Unfinished Business:  A Comparative Assessment of Environmental
      Problems.  Appendix III  Ecological Risk Work Group.  Office of Policy
      Analysis, Office of Policy, Planning and Evaluation.  February 1987.

U.S. EPA.  Report to Congress:   Wastes from the Extraction and Beneficiation
      of Metallic Ores, Phosphate Rock, Asbestos, Overburden from Uranium
      Mining, and Oil Shale.  Office of Solid Waste and Emergency Response.
      EPA/530-SW-85-003.   December 1985.

Versar Inc.  Ecological Risk Characterization Methodology.  Final Report.
      Prepared for Characterization and Assessment Division, Office of Solid
      Waste, U.S. EPA.  June 1988.
                       IGF Case Study Document Holdings

Allied Chemical Baltimore Works:  Baltimore. MD.

      Risk Assessment Volume of Remedial Investigation Report.

ARCO Prudhoe Bay Unit:  AK.

      Jeff Mach.  1987.  RCRA Facility Assessment.   Alaska Department of
            Environmental Conservation.  April 1987 Draft.

Defense General Supply Center:  Chesterfield. VA.

      Dames and Moore.  Work Plan for Additional Field Investigation at the
            Fire Training Area.  U.S. Army Corps of Engineers.  Norfolk
            District.  May 20, 1988.

      Dames and Moore.  Work Plan for Additional Field Investigation for Area
            50, Open Storage Area, and National Guard Area.  U.S. Army Corps
            of Engineers.  Norfolk District.  May 20, 1988.

      Dames and Moore.  Draft Request for Permit Modification:  Open Storage
            Area.  U.S. Army Corps of Engineers.  Norfolk District.  July 11,
            1988.

      EPA Region 3 Bioassessment Group (Alyce Fritz).  Review of Workplans for
            Additional Work at DGSC Richmond.  Memo to Steve Hirsch (SARA) and
            David Turner (RCRA) dated July 27, 1988.

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                                     11-42

International Paper:  Joplin. MO.

      International Paper.  Acceptable Exposure Levels:  Joplin.  Memo to Bob
            Stewart, U.S. EPA Region VII.  October 17, 1985.

      Region VII U.S. EPA.  Notice of Deficiency/Letter of Warning.  Memo to
            International Paper.  February 21, 1986.

IRECO Chemicals:  Toole County. UT.

      Compliance Order on Consent with IRECO Letter of March 15, 1983, and
            revised Part B Application.

      U.S. Fish and Wildlife Service.  Letter to Region VIII EPA about raptors
            in vicinity of IRECO site.  March 7, 1984.

      U.S. Fish and Wildlife Service.  Letter to IRECO on 1984 monitoring
            results.  February 8, 1985.

Kennedy Space Center:  FL.

      Corrective Action Order.

Koppers Company Inc.:  Superior. WI.

      RCRA Facility Assessment

Monroe Auto Equipment Plant:  Hartwell. GA.

      Permit Application - Ground Water Monitoring:  Sample and Analysis
            Document.

NIES Landfill:  Furlev. KS.

      ICF-Clement.  ACL Demonstration Document.  March 3, 1986.

      ICF-Clement.  ACL Demonstration Document.  Part 2.   June 14,  1986.

      Michigan Department of Natural Resources.  Support Document For the Rule
            57 Package.  March 26, 1984.   [Method of ACL calculation used by
            ICF-Clement in ACL determination for NIES.]

Pratt and Whitney (United Technologies Corporation):  West Palm Beach. FL.

      Outline of Deficiencies for Part B Application.

      Florida Department of Environmental Regulation.  Consent Agreement.

      Consent Agreement Update.

      Florida Department of Environmental Regulation.  Hazardous Material
            Incinerator Review.  Interoffice Memo.

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                                     11-43


      Work Plan for Conducting RFI.

Rohm and Haas. Bristol Plant:  Bristol. PA.

      RCRA Part B Permit Application Checklist.

      Cover letter and pages of RCRA Part B Permit Application.

      NUS Corporation, Superfund Division.   Hazard Ranking System for the Rohm
            and Haas Landfill.  April 23, 1984.

Saco Defense Inc.:  Saco. ME.

      Corrective Action Consent Order.  Effective June 23, 1988.

Southern Dve Company (SODYECO'):   NC.

      ACL Petition.

Southern Wood Piedmont Company:   Baldwin. FL.

      leaf, C.M.  Letter recommending ACLs.  Florida State University.

      Record of Communication between Mickey Hartnett and Bill Pettier,  EPA
            Region 4.  July 1, 1988.

Union Carbide Agricultural Products Company. Inc.:  Woodbine.  GA.

      Groundwater Quality Assessment Plan.

      Georgia Department of Natural Resources.  Notice of Deficiency on
            Hazardous Waste Permit Application.

      ACL Demonstration.

Wyman-Gordon:  North Grafton. MA.

      Planning Research Corporation.  Chapter 11, Ground-water Related Issues.
            of Part B Permit Application.  May 1986.

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           APPENDIX A

 MASTER LIST OF SUPERFUND SITES
IDENTIFIED AS POTENTIALLY HAVING
    ECOLOGICAL RISKS/IMPACTS

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                              MASTER LIST OF SUPERFOTD SITES
EPA Ration 1

 Beacon Heights Inc., Beacon Falls,  CT
 Brunswick Naval Air Station, Brunswick, ME
 Cannon Engineering/Plymouth Harbor, Plymouth, MA
 Charles George Land Reclamation,  Tyngsborough, MA
 Coakley Landfill, North Hampton,  NH
*Davis Liquids, Smithfield,  RI
 Dover Municipal Landfill, Milford,  NH
 Groveland Wells 1 & 2, GroveLand, MA
 Grugnale Waste Disposal Site, Milford, NH
 Haverhill Municipal Landfill, Haverhill,  MA
 Industri-Plex 128, Woburn,  MA
*Iron Horse Park, Billerlca, ME
 Kellogg-Deering Well Field, Norwalk,  CT
 McKin Co., Gray, ME
 Mottelo Pig Farm, Raymond,  NH
*New Bedford Harbor, New Bedford,  MA
 Norwood PCB Site, Norwood,  MA
     * Denotes sites analyzed in detail for this study.
                                                                        AS porrnrriALLT HAVBB ECOLOGICAL RISKS/IMPACTS
 Nyanza Chemical, Ashland, MA
•O'Connor Site, Augusta, ME
*01d Springfield Landfill, Springfield, VT
 O'Sullivan's Island, Derby, CT
 Peterson/Puritan Site, Lincoln/Cumberland, RI
 Picillo Farm, Coventry, Coventry, RI
*Re-Solve, Inc., Dartmouth, MA
 Savage Municipal Water Supply, Milford, NH
 Somersworth Landfill, Somersworth, NH
 Stamina Mills, Inc., North Smithfield, RI
'Sullivan's Ledge, New Bedford, MA
 Sylvester, Nashua, NH
 Tinkham Garage, Londonderry, NH
 Wells G&H, Woburn, MA
 Western Sand and Gravel, Burrillville, RI
 Yaworski Waste Lagoon, Counterbury, CT

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                                     MASTER LIST OF SUtHUUNU SITES IDENTIFIED AS HJLUUIALLT HA.V1K ECOLOGICALBISKS/IMPACTS (continued)
EPA Region 2

 Albert Steel Drum,  Newark,  NJ
 Applied Environmental Services,  Glenwood Landing, HY
 Bog Creek Farm, Howell Township,  NJ
 Brick Township Landfill,  Brick Township,  NJ
 Burnt Fly Bog, Marlboro Township, NJ
*Chemical Control, Elizabeth,  NJ
 Chipman Chemical, Middlesex,  NJ
 Chemical Leaman, Bridgeport,  NJ
 Ciba-Geigy, Toms River, NJ
 Clear Ambient Service, Catano, PR
•Clothier, Granby, NY
 Cosden Chemical Coatings, Corp.,  Beverly, NJ
 Curcio Scrap Metal, Inc., Saddle Brook Township, NJ
 DeRewal Chemical Co., Kingwood Township,  NJ
 Denzer and Schafer X-Ray, Royville, NJ
 Diamond Alkali, Newark, NJ
 Droyers Point, Jersey City, NJ
 Frontera Creek, Rio Abajo,  PR
 Fried Industries, East Brunswick Township, NJ
 Hercules, Inc., Gibbstown,  NJ
 Horstmann's Dump, Hast Hanover,  NJ
 Horseshoe Road Dump, Sayreville,  NJ
•Hudson River PCBs,  Glen Falls, NY
 Ideal Cooperage, Jersey City, NJ
 Jackson Township Landfill,  Jackson Township, NJ
 Jones Sanitation, Hyde Park,  NY
 Kin-Buc Landfill, Edison Township, NJ
 Koppers Company, Metuchen,  NJ
 Krycowaty Farm, Hillsborough, NJ
 Liberty Industrial Finishing,  Farmingdale, NY
*Lipari Landfill, Pitman, NJ
*Marathon Battery, Cold Springs, NY
 Mobil Chemical Company, Carteret, NJ
 Myers Property, Franklin Township, NJ
 N.L. Industries, Pedricktown, NJ
 Naval Air Engineering Center, Lakehurst, NJ
 North Sea Municipal Landfill, Southampton, NY
 Perth Amboy's PCBs, Perth Amboy, NJ
 PJP Landfill, Jersey City, NJ
 Pollution Abatement Services, Oswego, NY
 Port Washington Landfill, Port Washington, NY
 Price Landfill, Pleasantville, NJ
 Ringwood Mines/Landfill, Ringwood Borough, NH
 Roebling Steel Company, Florence, NJ
 Roosevelt Drive-In, Jersey City, NJ
 Rowe Industries Ground Water Cont., Noyack/Sag Harbor, NY
 Sayerville Landfill, Sayerville, NJ
 Sayerville Pesticide, Sayerville Borough, NJ
 Scientific Chemical Processing, Carlstadt, NJ
 Solvent Savers, Lincklaen, NY
 Syncon Resins, South Kearney, NJ
 T. Fiore Demolition, Inc., Newark, NJ
 Universal Oil Products Inc., East Rutherford, NJ
 Ventron/Velsicol, Wood Ridge Borough, NJ
 Vineland, Chemical, VineLand, NJ
 White Chemical Company, Bayonne, NJ
 Wide Beach, Brant, NY
 Williams Property, Swainton, NJ
 York Oil, Moire, NY

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EPA Rejtion 3
                                     MASTER LIST OF SUnOUHHD SITES IDENTIFIED AS POtERIALLY HAVlKr BCJXOGICAI. RISKS/IMPACTS  (continued)
 Aberdeen Proving Ground, Edgeworth Area,  Edgeworth, MD
 Aberdeen Proving Ground, Michaelsville Landfill, Aberdeen, MD
*Army Creek Landfill, New Castle Co.,  DE
 Atlantic Hood Ind.,  Portsmouth, VA
 Bridesburg Dump, Pennsylvania
 Butler Mine Tunnel,  Pittsburgh, FA
 C&R Battery Co. Inc., Chesterfield County, VA
*Chisman Creek, York County, VA
 Cokers Sanitation Services Landfills, Kent County, DE
 Croydon TCE, Croydon, PA
 Delaware City FVC Plant, Delaware City, DE
"Delaware Sand and Gravel Landfill, New Castle Co., DE
 Delta Quarries and Disposal/Statler Landfill, Blair Co. PA
*Douglassville Disposal, Douglassville, PA
 Dover Gas and Light Co., Dover, DE
 E.I. DuPont (Newport Plant Lf), Newport,  DE
 Enterprise Avenue, Pennsylvania
 Halby Chemical Company, New Castle, DE
 Hellertown Manufacturing Co., Hellertown, PA
 Joy Reclamation Co., Maryland
*L.A. Clarke, Fredericksburg, VA
 Maryland Sand, Gravel, and Stone, Elkton, MD
 Metal Bank of America, Philadelphia,  FA

EPA Eenion 4

*American Creosote Works, Pensacola, FL
 Bypass 601, Concord, NC
*58th St. Landfill, Tampa, FL
"Geiger (C&M Oil), Charleston County,  SC
*Harris Corporation/General Development Utilities,  Palm Bay, FL
"Mowbray Engineering, Greeneville, AL
*Munisport Landfill,  North Miami, FL
"Newport Dump, Newport, KY
 Newson Brothers/Old Reichhold, Columbia,  MS
 National Cash Register Corp., Millsboro, DE
 New Castle Spill Site, New Castle Co., DE
*New Castle Steel, New Castle Co., DE
 Old Brine Sludge, Delaware
*Palmerton Zinc, Palmerton, FA
 Paoli Rail Yards, Paoli, PA
 Pigeon Point Landfill, New Castle, DE
 Revere Chemical Company, Nockamixon, PA
 Rohm and Baas Landfill, Bristol Township, PA
 Saltvilie Waste Disposal, Saltville, VA
 Saunders Supply Co., Chesterfield County, VA
 Southern Maryland Wood Treating, Hollywood, MD
 Standard Chloring of Delaware, Inc., Delaware City, DE
 Tin!cum National Environmental Center, Darby Township, PA
*Tybouts Comer Landfill, New Castle Co., DE
"Tyson's Dump, Upper Merion TWP, PA
 Wade (ABM) Site, Chester, PA
"West VA Ordnance, Point Pleasant, WV
"Wildcat Landfill, Dover, DE
"Winchester Tire Fire Site, Frederick Co., VA
 Woodlawn County Landfill, Woodlawn, MD
"Parramore Surplus, Mount Pleasant, FL
 Peak Oil/Bay Drum Co., Tampa, FL
 Pickettville Landfill, Jacksonville, FL
"Sapp Battery Salvage, Cottondale, FL
 Sherwood Medical, DeLand, FL
*62nd Street Dump, Tampa, FL
"Stauffer Chemical Co. (LeMoyne Plant), Axis, AL
 Triana-Tennessee River, Limestone/Morgan, AL
 Wamchem, Inc., Burton, SC

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                                     MASTER LIST Cf SUfEHFUHD SITES
                                                                                  FOTERIALLY HAVUG BCOJOGICM.RISKS/IMPACTS (continued)
EPA Renioo 5

 Belvidere Landfill,  Belvidere,  IL
 Bennett Stone Quarry,  Bloomington,  IN
 Douglass Road Uniroyal,  Mishawaka,  IN
*Eau Claire Municipal Hell Field,  Eau Claire, HI
 Envirochera, Zionsville,  IN
 Fields Brook, Ashtabula, OH
 Firestone Ind. Products, Nobelsville, IN
 Fishercalo, LaPort,  IN
*Fort Hayne Reduction,  Fort Hayne, IN
*Fultz Landfill, Guerney County, OH
 G&H Landfill, Utioa, MI
 Lake Sandy Joe, Gary,  IN
 Lemaon Lane Landfill,  Bloomlngton,  IN
•Liquid Disposal, Inc., Utica, MI
*Marion/Bragg Landfill, Marion,  IN
 MIDCO 1 and 2, Gary, IN
 Neal's Dump, Spencer,  IN

EPA Region 6
 American Creosote, Hinnfield,  LA
 Anderson Clayton, Inc., Thomdale,
 Baily Haste Disposal, Bridge City,
 Bayou Bonfouca, Slidell, LA
 Bayou Sorrel, Bayou Sorrel, LA
 French Limited, Crosby, IX
 Gurley Pit, Edmondson, AR
*Mid-South Hood Products, Mena, AR
TX
TX
                                                  Neal's Landfill, Bloomington, IN
                                                  Ninth Ave. Dump, Gary, IN
                                                  Oconomowoc Plating, Aahippin, HI
                                                 •Outboard Marine, Haukegan, IL
                                                  Frestolite Battery, Vincinnes, IN
                                                  Reilly Tar Site, St. Louis Park, MN
                                                  Rose Township Dump, Rose Township, MI
                                                  Sangamo/Crab Orchard NWR (USDOI), Carterville, IL
                                                 *Schmalz Dump, Harrison, HI
                                                 *Seymour Recycling Corp., Seymour, IN
                                                  Sheboygan Harbor, Sheboygan, HI
                                                  South Branch of Shiawassee River, Shiawassee Co., MI
                                                  Twin Cities Army Arsenal, St. Paul, MN
                                                 *Velsicol Chemical, Marshall, IL
                                                  Haste, Inc., Landfill, Michigan City, IN
                                                  Hayne Haste Oil, Columbia City, IN
 Motco Corp., La Marque,  TX
 Petro Processors, Scotlandvllie, LA
 Sand Springs Petrotrochemlcal, Sand Springs, OK
 Sikes Disposal Pits,  Crosby, TX
*United Nuclear Uranium Mill, Church Rock, NM
 Vertac, Jacksonville, AR
*Wlchita Mtn. Wildlife Refuge, Comanche Co., OK

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                                     MASTS LIST OF SlUHUUHD SITES IDENTIFIED AS HJ1KI11ALLY HAVlflti mtrtttra.PTซjra/TMPAfTTS (continued)
EPA Region 7

Conservation Chemical, Kansas City,  MO
Horse Arena Sites, Missouri
Minker/Stout/Romaine Creek (Remains Creek Operable  Unit), Jefferson Cty, MO

EPA Benion 8

 Anaconda Co. Smelter, Anaconda,  MT
 California Gulch, Leadville, CO
 Central City/Clear Creek, Idaho Springs, CO
 Eagle Mine, Minturn/Radcliff, CO
*Martin Marietta Astronautic, Haterton Facility, CO

EPA Region 9

 Apache Powder Co., Benson, AZ
 Coast Hood Preserving, Ukiah, CA
 Del Norte County Pesticide Storage Area, Crescent  City, CA
*Iron Mountain Mine, Redding, CA
 Liquid Gold Corporation, Richmind,  CA
 Litchfield Airport, Goodyear/Avondale, AZ
 M3M Brakes, Cloverdale, CA
 Moffett Field Naval Air Station, Sunnyvale,  CA

EPA Ration 10

 Allied Plating, Inc., Portland,  OR
 Bunker Hill, Kellogg, ID
 Contnencement Bay, Tacoma, HA
 Gould, Inc., Portland, OR
 Harbor Island, Seattle, HA
 Martin Marietta Reduction, The Dallas, OR
 HAS Whidbey Island (Ault Field), Hhidbey Island, HA
 NAS Hhidbey Island Seaplane Base, Hhidbey Island,  HA
Minker/Stout/Romaine Creek (Stout Site), Jefferson County, MO
Rosati, Rosati, MO
 Rocky Mtn. Arsenal, Denver, CO
*Sand Creek Industrial, Commerce City, CO
 Silver Bow Creek, Silver Bow/Deer Lodge, MT
 White Hood Creek, White Hood, SD
 Montrose Chemical Corp., Torranee, CA
 Pearl City Landfill, Pearl Harbor, HI
 Phelps Dodge, Arizona
 Rhone-Poulenc, Inc./Zoecon Corp., East Palo Alto, CA
 Selma Pressure Treating, San Joaquin Valley, CA
•Southern Pacific Coalinga, Coalinga, CA
 Taputima Farm, Tutuila Island, AS
 Naval Undersea Warfare Engineering Station, Keyport, HA
*Queen City Farms, Maple Valley, HA
 Quendall Terminal, Renton, HA
 Stauffer Chemical, Co., Portland, OR
 Tacoma Landfill, Tacoma, HA
 Teledyne Hah Chang, Albany, OR
 Western Processing, Kent, HA
 Wycoff/Eagle Harbor, Bainbridge Island, HA

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        APPENDIX B

ECOLOGICAL THREAT DATA FOR
INDIVIDUAL SUPERFUND SITES

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     The pages that follow provide a summary of ecological threat information
at 46 of the 52 Superfund sites studied in this project.  Relevant information
for six sites has been withheld because it was extracted from draft reports
that are confidential or not publicly available.  The information that is
presented is based on the data contained in the documents reviewed and is
limited by the completeness and accuracy of these original sources.  The major
categories of information provided for each site are explained below.

     •    Site Name. City. State, and EPA Region.  This information
          is self-explanatory.  The sites are ordered alphabetically
          within groups for each region.

     *    Type of Site.  This identifies the general type of process
          or waste management practices used at the site.  Other
          descriptive information is given as appropriate.

     •    Principal Contaminants.  This section lists the main
          inorganic and organic contaminants observed in
          environmental media at the sites.  The listed contaminants
          are not necessarily the ones contributing most to
          ecological impacts.  In fact, at many sites,  the
          contaminants that were tested for were of concern
          primarily from a human health standpoint.

     •    Media/Biota Observed to be Contaminated.  These are
          observed environmental media and general categories of
          biota observed to be contaminated as documented in the
          reports reviewed.  Media or biota that are potentially
          contaminated are not listed in this section.

     •    Main Ecological Risks/Impacts.  This section summarizes
          available information on the nature and extent of
          ecological threats, separate from that provided earlier.
          Specifically, it provides information (when available) on
          biological effects, the areal extent of media-specific
          contamination,  the magnitude or severity of exposure to
          biota,  and sensitive environments that may be affected.
          Information on both observed impacts and predicted (or
          potential) impacts is provided,  with "potential" impacts
          explicitly noted as such.  Furthermore, the information
          provided in this section primarily is limited to observed
          or predicted effects noted by the authors of the reports
          that were reviewed.  In a few cases,  potential effects not
          accounted for by the authors are listed, and these effects
          are highlighted with an asterisk.

     •    Documents Reviewed.  The documents on which the above
          information is based are listed in this section.

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                                     B-2
                              EPA REGION  1  SITES
O'CONNOR SITE
AUGUSTA, ME
REGION 1
Type of Site:  inactive transformer recycling and salvage yard


Major Release Pathways:

     •    direct release from transformers scattered around the site
     •    drainage of lagoon water into Riggs Brook
     •    spills of transformer oils into surface water


Principal Contaminants:

     •    inorganics:  Al,  Sb,  As,  Pb
     •    organics:   PCBs


Media/Biota Observed to be Contaminated:

          onsite vegetation
          fish (Riggs Brook)
          amphibians (Riggs Brook)
          surface soil
          surface water sediments
          ground water
          lagoon waters (upper and lower lagoons)


Main Ecological Risks/Impacts:

     •    bioaccumulation of PCBs in fish range from 3X  - 21X greater  than
          background levels
     •    areas of site have discolored soil and are barren of vegetation
     •    bioaccumulation of PCBs in tadpoles
     •    potential reduced growth and altered community structure  in
          microorganisms and microinvertebrates in lagoons, marsh,  and Riggs
          Creek due to elevated PCB concentrations in interstitial  water of
          sediments
     •    concentrations of aluminum (marsh and lower lagoon) and lead (marsh,
          upper lagoon, lower lagoon, and Riggs Brook) exceed AWQC  and are
          likely to be toxic to aquatic organisms
     •    potential contamination of and toxicity to terrestrial wildlife  from

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                                     B-3
          contaminated microinvertebrates in marsh and lagoons, particularly
          birds that eat emergent aquatic insects and feed them to their young
          potential contamination of birds,  mammals,  and reptiles from
          ingestion of contaminated amphibian larvae
          potential PCB contamination of populations and communities of soil-
          dwelling invertebrates and burrowing vertebrates and subsequent
          potential contamination of terrestrial wildlife such as birds
          a fence around the site limits access of wildlife; thus onsite
          exposure of wildlife unlikely
Document Reviewed:  Endangerment Assessment; January 19, 1988.
OLD SPRINGFIELD LANDFILL
SPRINGFIELD, VT
REGION 1
Type of Site:  inactive landfill
Major Release Pathways:

     •    leachate seepage
     •    ground-water discharge
Principal Contaminants:

     •    inorganics:  Cu, Ni
     •    organics:  PCBs
Media/Biota Observed to be Contaminated:

     •    ground water
     •    soil
     •    sediments
Main Ecological Risks/Impacts:

     •    potential bioaccumulation of PCBs and subsequent effects to aquatic
          organisms; chronic effects also possible due to exposure to other
          contaminants
     •    the Bald Eagle and American Osprey (Vermont endangered species)  pass
          through the area during migration periods
     •    potential contamination of terrestrial wildlife from direct contact
          with or ingestion of contaminated soil,  sediments,  or water*

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                                     B-4
          potential for effects to organisms at higher levels in the food
          chain from consumption of contaminated organisms*
Document: Reviewed:  Endangerment Assessment Report; June 1988.
RE-SOLVE, INC.
NORTH DARTMOUTH, MA
REGION 1
Type of Site:  inactive waste chemical reclamation facility
Major Release Pathways:

     •    accidental spills and purposeful oil spreading on soils
     •    erosion/runoff of residual contaminated soil
     •    infiltration into ground water from spills and unlined lagoons;
          ground water discharges into surface water

Principal Contaminants:

     •    inorganics:  Cd, Hg, Fe, As, Mn
     •    organics: PCBs, methylene chloride, phthalates, toluene,
                    fluoranthene, benzo(a)pyrene, benzo(a)anthracene, 1,2-
                    trans-dichloroethene
Media/Biota Observed to be Contaminated:

          soil
          surface water (stream, river, and pond)
          surface water sediments
          ground water
          fish and eels
          aquatic benthic organisms


Main Ecological Risks/Impacts:

     •    although a benthic study notes a basic aquatic food chain is intact,
          there is a potential for sediment contamination to adversely affect
          benthic organisms and organisms higher in the food chain; in
          particular there are concerns about potential bioaccumulation of
          PCBs, especially in birds, with subsequent egg-shell thinning and
          decreased reproductive success

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                                     B-5
          creek sediments "highly contaminated" with PCBs to a depth of 1 foot
          roughly 300 feet downstream
          a small (roughly 0.1 acre) wetland is contaminated, potentially
          causing adverse effects to organisms that reside there (a variety of
          birds, amphibians, small mammals, and aquatic invertebrates); the
          entire wetland is contaminated with more than 1 ppm PCB to a depth
          of roughly 1.5 feet
          potential chronic toxicity effects to aquatic organisms due to
          elevated concentrations of Cd, Hg, and volatile organics
Documents Reviewed:
          Technical Memo for Determination of PCB Clean-up Criteria Re-Solve
          Inc. Site; September 24, 1987.
          Draft Remedial Investigation Report Re-Solve Site Off-Site
          Investigation; February 1985.
          Draft Preliminary Public Health Evaluation for the Re-Solve Site
          in North Dartmouth, MA; July 29, 1986.
          ICF Chart on Ecological Threats at Re-Solve Inc. Site;
          March 1988.
          Preliminary Draft Remedial Investigation Report; November 1986.
          Offsite Investigation Follow Up To Onsite Remedial Investigation/
          Feasibility Study; no date.
          Record of Decision; 1987.
SULLIVAN'S LEDGE
NEW BEDFORD, MA
REGION 1
Type of Site:
          former granite quarry and industrial waste disposal site
          four inactive pits:  two filled with automobiles, two used as
          industrial waste disposal sites
Major Release Pathways:
          seepage into ground water, which discharges to surface water
          surface runoff into surface water
Principal Contaminants:
          inorganics:  Pb, Hg, Cu, Zn, Ag
          organics: PCBs, chlorobenzene,  pentachlorophenol, bis(2-
                    ethylhexyl)phthalate

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                                     B-6
Media/Biota Observed to be Contaminated:

     •    soils
     •    surface water
     •    sediments
     •    ground water


Main Ecological Risks/Impacts:

     •    potential threats to Apponagansatt Swamp
     •    only minimal adverse impacts to the forested wetlands were expected


Document Reviewed:  Remedial Investigation Report; June 1987.

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                                     B-7
                              EPA REGION 2  SITES
CHEMICAL CONTROL
ELIZABETH, NJ
REGION 2
Type of Site:  inactive landfill


Major Release Pathways:

     •    seepage of landfill leachate directly to surface water (river)
     •    infiltration into ground water, which is observed to discharge to
          river
Principal Contaminants:

     •    inorganics:   N/A
     •    organics:  volatile organics, phthalate esters, PCBs
Media/Biota Observed to be Contaminated:

     •    ground water
     •    river sediments
     •    soil
Main Ecological Risks/Impacts:

     •    surface water (river) is polluted, but contamination cannot be
          linked directly to this site
     •    2.2 acres of soil contaminated with organics
     •    areawide studies conducted by the Fish and Wildlife Service and the
          Army Corps of Engineers concluded that sensitive species have either
          been entirely eliminated from the area, or they are present only in
          particular areas during certain times of the year
     •    food chain contamination could result if benthic organisms are
          present in the mouth of the Elizabeth River, especially
          bioaccumulation of PCBs
     •    three sensitive areas were identified in a dredging environmental
          impact assessment by the Army COE:  Shooters Island; wetlands near
          Goethals Bridge; and mudflats in Newark Bay (however, it was
          concluded that it is unlikely that contaminants in the Elizabeth
          River could adversely affect any of these areas because of the
          distance from the site and dilution by the river)

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                                     B-8
Documents Reviewed:
          Record of Decision; 1987.
          Remedial Investigation (partial); no date.
          Feasibility Study (partial); no date.
CLOTHIER
GRANBY, NY
REGION 2

Type of Site:  inactive privately-owned landfill
Major Release Pathways:

     •    discharge of leachate-contaminated ground water to surface water
     •    direct discharge to wetlands from buried drums
     •    runoff of soil to Creek
Principal Contaminants:

     •    inorganics:  Cd, Cr, Mn, Ba
     •    organics: bis(2-ethylhexyl)phthalate, 1,2-dichloroethene,
                    tetrachloroethene, 1,1,1-trichloroethane, trichloroethene,
                    xylenes


Media/Biota Observed to be Contaminated:

     •    ground water
     •    soil
     •    sediments (Ox Creek)
     •    surface water -- below AWQC levels


Main Ecological Risks/Impacts:

     •    6 acres of soil contaminated with organics and metals
     •    Ox  Creek and a New York  State designated freshwater wetland adjacent
          to  Ox Creek border the onsite waste disposal area;  Three Rivers
          State Wildlife Management Area  is located 3 miles  from the site
     •    degradation of wetlands  habitat from potential dredging  of
          contaminants
     •    potential for bioaccumulation and other chronic effects  to benthic
          organisms from  contaminated sediments*

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                                     B-9
          potential for acute toxic effects to aquatic organisms from runoff
          of soil and leachate into Ox Creek during recommended excavation of
          onsite contaminated soil
Document Reviewed:  Public Health Evaluation; June 15, 1988.
HUDSON RIVER
GLEN FALLS, NY
REGION 2
Type of Site:  PCB-contaminated river


Major Release Pathways:

     •    discharge of PCBs into river
     •    sediment release to water column
     •    PCBs present in dredge spoils located along the river banks (i.e.,
          in the floodplain)
     •    PCBs leaching via ground water
     •    air volatilization of PCBs
     •    potential erosion and re-suspension of contaminated soils and
          sediment during the future remedial activities


Principal Contaminants:  PCBs (arochlors 1221, 1254, 1016,  and perhaps others)


Media/Biota Observed to be Contaminated:

          soil
          river sediments
          surface water
          ground water
          air
          fish
          onsite vegetation


Main Ecological Risks/Impacts:

     •    potential toxic effects to terrestrial biota and aquatic biota other
          than fish;  other effects due to the potential bioaccumulation of
          PCBs*
     •    tidal estuary in lower 150 miles of river and some wilderness areas
          contaminated

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                                    B-10
Docunents Reviewed:
          HRS Panel Summary Risk Assessment for Hudson River; June 1987.
          IGF Chart on Ecological Threats at Hudson River Site; March 1988.
          Feasibility Study Vol. 1; April 1984.
          Draft Environmental Impact Statement; May 1981.
          Final Environmental Impact Statement; January 1987.
          Hudson River PCB Contamination - A 1985 Perspective.
          Contaminants in Hudson River Striped Bass:  1978-1985 (86
          supplement).
          PCB Contamination data (tables).
LIPARI LANDFILL
MANTUA TOWNSHIP, NJ
REGION 2
Type of Site:  inactive landfill
Major Release Pathways:

     •    direct release of drummed wastes through spillage
     •    leaching of ground water to surface pools and then to marsh or
          directly to Chestnut Branch
     •    flooding of Alcyon Lake and release of contaminants to soils
          (frequency of flooding not indicated)

Principal Contaminants:

     •    inorganics:  Zn, Cr, Ni, Pb, Hg, As
     •    organics:  benzene, 1,2-dichloroethane, ethylbenzene,  toluene,
          bis(2-chloroethyl)ether, xylene, chloroform
Media/Biota Observed to be Contaminated:

          soil in marsh and parks
          ground water
          surface water (Rabbit Run, Chestnut Branch, Alcyon Lake)
          sediments (Rabbit Run, Chestnut Branch, Alcyon Lake)
          vegetation
          fish

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                                     B-ll
Main Ecological Risks/Impacts:

     •    complete devastation of vegetation in leachate migration paths
     •    1,500 feet of stream surface water contaminated with bis(2-
          chloroethyl)ether, toluene, arsenic,  chromium, mercury, and lead
     •    26 acres of lake surface water and sediment contaminated
     •    700' x 200' area of marsh soil contaminated with organics and metals
     •    bioaccumulation of organics in fish
     •    potential reduction in species diversity in Alcyon Lake; common carp
          is most populous fish and constitutes greatest total biomass; this
          species is known to be tolerant of poor water quality
     •    potential chronic effects to fish in Alcyon Lake, such as stunted
          growth
     •    potential contamination of benthic organisms in streams due to
          contaminated sediments, and possible contamination of organisms at
          higher trophic levels
     •    potential contamination of and toxic effects to terrestrial wildlife
          from direct ingestion of contaminated media or through the food
          chain (e.g., raccoons, opossum, water fowl)
     •    the marsh area, streams, and parks adjacent to Alcyon Lake are
          considered important and sensitive environments by the State of New
          Jersey
Documents Reviewed:

     •    Offsite Remedial Investigation Final Draft;  June 1987.
     •    Onsite Feasibility Study; August 1985.
     •    Risk Assessment (Appendix A of RI);  June 1987.
     •    Public Health Evaluation; June 1987.
MARATHON BATTERY CORPORATION
PUTNAM CO., NY
REGION 2
Type of Site:  inactive battery production facility


Major Release Pathways:  Ni-Cd waste effluent from battery plant was
                         discharged through a storm sewer into a cove and two
                         freshwater marsh areas


Principal Contaminants:

     •    inorganics:  Cd, Ni, Co, nitrate, carbonate
     •    pH (basic: 11-12.5)

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                                     B-12
Media/Biota Observed to be Contaminated:

          sediment
          surface water
          onsite soils
          fish, shellfish, benthic invertebrates
          reptiles (turtles)
          indiums.!, s
          marsh vegetation


Main Ecological Risks/Impacts:

     •    marsh sediments contaminated up to 2 miles from the battery plant
     •    sensitive environments contaminated:  two freshwater marsh areas of
          284 acres, and a tidal flat and cove of 34 acres
     •    marsh and wetlands could be disturbed further by remedial action
     •    potential effects to fish which use the wetlands for spawning*
     •    ecological effects described as "minimal" and minor
     •    potential threats to terrestrial biota*
Documents Reviewed:

     •    ICF Chart on Ecological Threats at Marathon Battery  Site  (Only
          Area I:  Constitution Marsh and East Foundry  Cove);  March 1988.
     •    Record of Decision, Remedial Alternative  Selection for Marathon
          Battery Company Site Area I; 1986.
     •    Draft Remedial Investigation Report; April 1988.

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                                     B-13
                              EPA REGION 3 SITES
ARMY CREEK LANDFILL
NEW CASTLE, DE
REGION 3
Type of Site:
          abandoned sand and gravel pit
          pit used as a primary disposal site for municipal and industrial
          wastes
Major Release Pathways:
     •    infiltration into ground water and migration to potable water
          sources (potential human health concern)
     •    ground-water collection system directly discharges untreated water
          into Army Creek


Principal Contaminants:

     •    inorganics:  Fe, Mn, Cr, Be, Cd, Pb,  Ni, Zn, As
     •    organics: benzene; 1,2-dichloropropane; methyl chloride; 2,4-
                    dinitrotoluene; N-nitrosodimethylamine; 1,2-
                    dichloroethane; bis(2-chloroethyl) ether; 2,4,6-
                    trichlorophenol;  chlorodibromomethane


Media/Biota Observed to be Contaminated:

     •    ground water
     •    sediment
     •    actual biota contaminated include:  vegetation, fish,  benthic
          macroinvertebrates,  snails,  fingernail clams


Main Ecological Risks/Impacts;

     •    low diversity of benthic species observed
     •    "damage to flora where leachate seeps from landfill"
     •    "recent photographs ...  show normal vegetative cover with no signs
          of environmental stress"
     •    potential effects on aquatic biota include mortality,  reduction in
          reproductive success,  and diversity and weight loss
     •    bioassays indicate that change has occurred in the surface water but

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                                     B-14
          the severity of impacts on aquatic life are "not readily
          discernable"
Documents Reviewed:
          Endangerment Assessment; July 1984.
          Feasibility Study; July 1986.
          Record of Decision - Remedial Alternative Selection;
          September 30, 1986.
CHISMAN CREEK
YORK COOHTY, VA
REGION 3
Type of Site:   four abandoned sand and gravel pits that were filled with
                flyash from electric power generating station (they are now
                surface water ponds)


Major Release Pathways:

     •   surface water runoff into tributaries and creek
     •   discharge of contaminated ground water into creek

Principal Contaminants :

     •   inorganics:  As, Cd, Cu, Pb, Ni, Se, V, Zn
     •   organics :  N/A


Media/Biota Observed to be Contaminated:

     •   ground water

     Ponds

     •   vegetation
     •   surface water
     •   sediments
     •   fish
     Chisman Creek

     •    surface water
     •    sediments

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                                     B-15


     •   benthic community (especially oysters)

Main Ecological Risks/Inpacts:

     General

     •   four freshwater ponds (13.5 acres, 4.5 acres, 12.9 acres, and 5
         acres) contaminated with metals
     •   the site is a nesting area for protected bird species (e.g., osprey),
         and a heron rookery is 2.5 miles from the site; a national wildlife
         refuge is 7 miles downstream of the site
     •   surface water exceeds AWQC for lead and vanadium
     •   arsenic, copper, cadmium, lead, and selenium are being bioaccumulated
         by fish in the freshwater ponds
     •   potential for other chronic effects to fish from sediment and surface
         water contamination, including respiration and osmo- regulation
         effects
     •   contamination of birds using ponds for feeding may occur, as well as
         terrestrial wildlife*
     •   potential contamination effects to terrestrial wildlife from
         ingestion of vegetation with elevated metals concentrations*

     Chisman Creek

     •   bioaccumulation of metals in oysters has occurred, and is likely to
         occur in other benthic organisms
     •   potential for bioaccumulation and possible toxic effects to other
         aquatic organisms,  and organisms higher in the food chain such as
         birds that use the area for nesting and feeding, and terrestrial or-
         ganisms
Document Reviewed:  Remedial Investigation/Endangerment Assessment of the
                    Environmental Impacts,  Vol.  I and II;  September 1987.
DELAWARE SAND AND GRAVEL LANDFILL
NEW CASTLE COUNTY, DE
REGION 3
Type of Site:   inactive industrial waste landfill

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                                     B-16
Major Release Pathways:
     •   discharge of ground water recovery wells into Army Creek (wells in
         operation for 12 years)
     •   leachate seepage into creek
     •   contaminated ground-water discharge to creek


Principal Contaminants:

     •   inorganics:  Fe, Mn, Mg, Ba, Cr, Zn
     •   organics:  N/A

Media/Biota Observed to be Contaminated:

         surface water - - Army Creek and Army Creek Pond
         soil
         creek sediments
         ground water
         benthic organisms in Army Creek


Main Ecological Risks/Impacts:

     •   Army Creek Pond is eutrophic with low species diversity and a high
         percentage of pollution-tolerant organisms
     •   12.5 acres of soil are contaminated with various metals
     •   the number and variety of benthic organisms present in Army Creek are
         reduced
     •   potential for bioaccumulation of metals detected in surface water and
         sediments in aquatic organisms, vegetation, and waterfowl associated
         with the nearby Delaware River*
     •   potential contamination of wetlands habitat*


Documents Reviewed:

     •   Remedial Investigation; December 29, 1987.
     •   Record of Decision; 1988.

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                                     B-17
DOUGLASSVILLE DISPOSAL SITE
BERKS COUNTY, PA
REGION 3
Type of Site:

     •   former waste oil recycling and refining facility with onsite lagoons
         and storage areas
     •   currently an active waste oil reprocessing facility


Major Release Pathways:

     •   migration of contaminants from former lagoons,  sludge impoundments,
         and drum storage area via surface water runoff, flood events, and
         sediment transport in a drainage ditch at the site
     •   direct discharge from waste water treatment system of active facility


Principal Contaminants:

     •   inorganics:  Pb
     •   organics:   PCBs, toluene,  benzene,  tetrachloroethene


Media/Biota Observed to be Contaminated:

     •   surface water
     •   ground water
     •   sediments
     .   fish
Main Ecological Risks/Impacts:

     •   potential impacts to aquatic and terrestrial biota indigenous to the
         rural and riparian areas*
     •   toxicity and mortality observed in biota
     •   sensitive environments potentially affected:  the Schuylkill River (a
         state scenic river),  a historic site and state park,  and riparian
         wetlands*
Documents Reviewed:

     •   Remedial Investigation/Feasibility Study; June 1986.
     •   Record of Decision; September 27, 1985.

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                                     B-18
L.A. CLARKE AND SON, INC.
SPOTSYLVANIA, VA
REGION 3
Type of Sites:
         active wood treating company
         five waste pits containing creosote wastes
Major Release Pathways:
     •   sediment and surface water discharge into major onsite ditches that
         flow into offsite wetlands
     •   potential leaking underground storage tanks,  not in use


Principal Contaminants:

     •   inorganics:   N/A
     •   organics:  polynuclear aromatic hydrocarbons,  benzene


Media/Biota Observed to be Contaminated:

     •   surface soils
     •   surface water
     •   ground water
     •   sediments
     •   fish
     •   vegetation


Main Ecological Risks/Impacts:

         several "stressed" vegetation areas less than 1 acre in size
         deformities and cancerous growths in local fish
         acute toxic effects observed in bioassays using daphnia and minnows
         sensitive areas affected include wetlands, ponds
         other contaminated areas of concern include creeks, tributaries,
         wooded areas, and brush areas
Documents Reviewed:

     •   Bioassessment Studies; January 1988.
     •   Work Plan for Remedial Investigation/Feasibility Study;
         November 1, 1985.

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                                     B-19
         Final Remedial Investigation/Feasibility Study; February 9, 1988.
         Record of Decision; March 31, 1988.
NEW CASTLE STEEL
NEW CASTLE, DE
REGION 3
Type of Site:   open, partially inactive dumping area for steel foundry wastes


Major Release Pathways:

     •   surface water runoff/erosion into nearby marsh (tidal estuary) on
         edge of Delaware River
     •   seepage into ground water, which may discharge to marsh (this pathway
         was not investigated)
     •   mobilization of Pb particulate into air, with possible deposition of
         particulate in marsh


Principal Contaminants:

     •   inorganics:  Pb (primarily); also As, Cd, Cr, Ni
     •   organics:  N/A


Media/Biota Observed to be Contaminated:

     •   soil
     •   sediment (in marsh)
     •   surface water (in marsh)


Main Ecological Risks/Inpacts:

     •   "diminished habitat quality" of marsh noted
     •   potential for adverse effect on habitat and species of two National
         Wildlife Refuges on the opposite side of the Delaware River,
         including some endangered species and their habitat
     •   potential for inhibited growth and reproduction of aquatic species in
         marsh due to Pb contamination and bioaccumulation
     •   Pb levels in samples of marsh surface water exceeded chronic AWQC by
         2X; one sample on edge of marsh (next to land) exceeded acute AWQC by
         3X
     •   actual site contamination covers about 3 acres; marsh, which has
         potential for adverse effect on species, covers about 40 acres

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                                    B-20
Documents Reviewed:
         Final Endangerment Assessment; May 4, 1988.
         Record of Decision; March 31, 1988.
PALMERTON ZINC
PALMERTON, PA
REGION 3
Type of Site:  active zinc smelter


Major Release Pathways:

     •   water flowing across the defoliated mountain carries metal-laden soil
         into surface water
     •   air emissions
Principal Contaminants:

     •   inorganics:  Cd, Zn, Pb
     •   organics:   N/A


Media/Biota Observed to be Contaminated:

         soil
         surface water
         ground water
         vegetation
         fish
         microflora (bacteria)
         lichens
         arthropods
         amphibians


Main Ecological Risks/Impacts:

     •   2,000 acres on Blue Mountain  completely  defoliated
     •   absence of microflora  in  the  affected  area;  trees  that  fell 10-20
         years ago have not decayed
     •   richness and  abundance of lichen species reduced by approximately 90%
     •   total arthropod  density approximately  22% of that  of uncontaminated
         area

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                                     B-21
         inhibited seed germination
         absence of earthworms,  slugs,  snails,  toads and salamanders
         elevated metal concentration in fish
         potential habitat shift due to defoliation of Blue Mountain*
         cadmium, lead, and zinc concentrations in soils up to 2600X, 2000X,
         and 400X background levels, respectively; surface water run-off
         exceeds AWQC for these metals by 1-25X
         potential contamination of and toxic effects to offslte terrestrial
         wildlife from contact with or ingestion of contaminated soil or
         vegetation, or from air emissions*
         potential contamination of surface water sediments,  benthic
         organisms, and organisms at higher trophic levels (e.g., birds)*
Documents Reviewed:
         Declaration for the Record of Decision and Site Description and
         Summary of Remedial Alternative Selection for the Palmerton Zinc
         Superfund Site - Blue Mountain Operable Unit; September 4, 1987.
         Record of Decision; 1987.
         Remedial Investigation; April 1987.
TYBODTS CORNER LANDFILL
NEW CASTLE, DE
REGION 3
Type of Site:

     •   inactive municipal and sanitary landfill
     •   received industrial wastes from 1968 to 1971
Major Release Pathways:

     •   ground-water migration of percolated contaminants
     •   leachate from site enters streams and marshes surrounding the site


Principal Contaminants:

     •   inorganics:   N/A
     •   organics:  vinyl chloride, 1,2-dichloroethane,  trichloroethylene,
                    benzene

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                                     B-22
Media/Biota Observed to be Contaminated:

     •   ground water (2 aquifers)
     •   surface water
     •   sediments
     •   vegetation


Main Ecological Risks/Impacts:

     •   "vegetative stress" observed at point of leachate discharge in Red
         Lion Marsh
     •   "potential deterioration of the ecology of Red Lion Marsh is a
         concern at this site"
     •   concentrations of contaminants in surface water and sediments "are
         not sufficient to threaten human health and the ecological
         environment"
     •   potential impacts to Pigeon Run wetland, and terrestrial and aquatic
         fauna*
Document Reviewed:  Remedial Investigation/Feasibility Study Report; June
                    1985.
TYSON'S DUMP
MONTGOMERY COUNTY, PA
REGION 3
Type of Site:

     •   an abandoned septic and chemical waste disposal site
     •   several unlined lagoons constructed within an old sandstone quarry


Major Release Pathways:

     •   seepage into ground water; leachate from the site is observed to
         enter the creeks and marshes surrounding the dump
     •   potential erosion and surface runoff
Principal Contaminants:

      •   inorganics:  N/A
      •   organics:  benzene, di-n-butyl phthalate, 1,2-dichlorobenzene, 4-
         methylphenol, tetrachloroethene, 1,2,4-trichlorobenzene,
         trichloroethene,  1,2,3-trichloropropane, o-xylene

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                                    B-23
Media/Biota Observed to be Contaminated:

     •   ground water
     •   surface water
     •   soils
     •   air
Main Ecological Risks/Impacts:

     •   "it can be concluded that trichloropropane has migrated offsite to
         the floodplain area and then to the Schylkill River"
     •   potential habitats affected include creeks, the Schylkill River,
         floodplain areas,  small ponds,  and a swamp, all within approximately
         800 ft. of the site*
     •   "the site appears  to support a diverse and unimpacted flora and
         associated fauna"  (Fish and Wildlife Service site investigation)
Documents Reviewed:

     •   MRS Panel Risk Assessment; June, 1987.
     •   Risk Assessment of the Tyson's Dump Site, Final Report; no date.
     •   Final Remedial Investigation Report; July 1985.
     •   Off-site Operable Unit Remedial Investigation Report;
         December 8, 1986.
WEST VA ORDNANCE WORKS
MASON COUNTY, WV
REGION 3
Type of Site:  former TNT manufacturing facility


Major Release Fatbvays:

     •   accidental spills to soil
     •   erosion/runoff of residual contaminated soil
     •   infiltration into ground water, which discharges to surface water and
         surface seeps along escarpment
     •   direct discharge to surface water


Principal Contaminants:

     •   inorganics:  Pb, asbestos

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                                     B-24
         organics:  2,4,6-trinitrotoluene, 2,4-dinitrotoluene, 1,3,5-
                    trinitrobenzene, PAHs
Media/Biota Observed to be Contaminated:

         soil (on surface and underground along sewer lines)
         surface water (river)
         surface water sediments
         ground water
         vegetation


Main Ecological Risks/Inpacts:

     •   vegetation killed over roughly 1 acre due to nitroaromatic
         contamination; vegetation growth "inhibited" on roughly 2-3
         additional acres
     •   entrapment of animals by falling into open manholes (numerous mammal
         skeletons were observed in manholes)
     •   potential for "limited" occurrences of acute toxic effects to or
         explosion of terrestrial wildlife that come into direct contact with
         concentrated chunks of TNT; proportion of terrestrial population
         likely affected is less than 2-5 percent
     •   roughly 60 acres of the State-operated McClintic Wildlife Station now
         located onsite is contaminated to varying degrees; the wildlife
         station (which is made up of a total of 2,800 acres) contains 39
         impoundments developed for propagation of fish and waterfowl
     •   potential for acute toxicity to aquatic life caused by erosion during
         storm events; no toxic effects to aquatic life expected normally
         because water concentrations below available toxicity criteria
     •   8 endangered species potentially occur in wildlife station, but none
         have been sighted


Documents Reviewed:

     •   Remedial Investigation; September 1985.
     •   Feasibility Study for the TNT Manufacturing Area, The Burning
         Grounds and The Industrial Sewerlines; October 1986.
     •   Supplemental Remedial Investigation; November 1986.
     •   Endangerment Assessment for Sewerlines, The TNT Manufacturing
         Area and The Burning Grounds; April 1986.
     •   Endangerment Assessment for Acids Area/Yellow Water Reservoir,
         Red Water Reservoirs, and the Pond 13/West Well Area; December 1986.
     •   Summary of Remedial Investigation/Feasibility Study (from draft
         FY 87 CERCLA Report to Congress).
     •   Record of Decision; March 31, 1987.

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                                     B-25
WILDCAT LANDFILL
DOVER, DE
REGION 3
Type of Site:  inactive landfill

Major Release Pathways:

     •   direct release and spreading of drummed wastes on soil and in marshes
     •   leachate seepage to surface water
     •   discharge of contaminated ground water to surface water


Principal Contaminants:

     •   inorganics:  Ba, Ni, Pb, Zn
     •   organics:  N/A


Media/Biota Observed Co be Contaminated:

         fish
         painted turtles
         vegetation
         ground water
         onsite pond water
         onsite pond sediments
         soil


Main Ecological Risks/Impacts:

     •   increased incidence of lesions and gill inflammation in fish in
         onsite pond
     •   bioaccumulation of metals in painted turtles and in fish in onsite
         pond
     •   degradation and loss of wetlands habitat (29 acres)
     •   barren patches void of any vegetation
     •   bald eagle has been sighted near the landfill, and 6 species of
         plants at the site are listed in a rare plant draft list for the
         State of Delaware
     •   potential bioaccumulation of PCBs and metals in river fish
     •   potential contamination of benthic organisms and subsequent
         contamination of organisms at higher trophic levels from ingestion*
     •   access to site by wildlife is not restricted

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                                    B-26
Docunents Reviewed:
         Remedial Investigation; May 1988.
         Record of Decision; June 29, 1988,
WINCHESTER TIRE FIRE
FREDERICK COUNTY, VA
REGION 3
Type of Site:  inactive tire disposal company
Major Release Pathways:

     •   acute:  a plume of black smoke 3000 ft. high and 30-50 miles long
         emitted as a result of the tire fire; runoff and percolation of
         pyrolyzed liquids containing hazardous organic compounds
     •   ground water flows through overburden and highly fractured bedrock
         towards an intermittent stream
     •   surface runoff of contaminated burn rubble and ash
     •   two onsite ponds, one is unlined and potentially causing ground-
         water contamination
Principal Contaminants:

     •   inorganics:  Al, Cu, Pb, Ag, Zn
     •   organics:  alpha BHC, benzoic acid, bis(2-ethylhexl)phthalate, 4-
                    me thyIpheno1, toluene


Media/Biota Observed to be Contaminated:

         soil
         sediments
         surface water
         ground water
         fish
         benthic invertebrates
Main Ecological Risks/Impacts:

     •   acute:  an undetermined quantity of hot oil (produced from the
         melting and pyrolysis of tires) flowed into Hogue Creek, which is
         part of the Potomac River System

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                                     B-27
         acute and chronic toxic effects to daphnia and minnows "probably due
         to copper, lead, silver, and zinc:  average and maximum
         concentrations of these metals exceeded AWQC"
Docunents Reviewed:
         Management of Migration of Contamination Via Surface Water;
         May 1988.
         Remedial Investigation/Feasibility Study; March 1987.

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                                     B-28
                              EPA REGION 4  SITES
AMERICAN CREOSOTE WORKS, INC.
PENSACOIA, FL
REGION 4
Type of Site:  inactive wood preserving operation


Major Release Pathways:

     •   unlined surface impoundments are below normal water table
     •   liquid wastes allowed to overflow into area drainage ways


Principal Contaminants:

     •   inorganics:   N/A
     •   organics:  PAH's, benzene, toluene,  xylene, ethylbenzene, and other
                    VOCs
Media/Biota Observed to be Contaminated:

     •   ground water
     •   soils
     •   surface water
     •   sediments
Main Ecological Risks/Impacts:

     •   contaminant plume moving toward bay and bayou
     •   "bioaccumulation may occur [in marine biota] in the short term, but
         the PAH's in general are eliminated through metabolism and excretion
         [which] . .  .  precludes biomagnification up food chain"
     •   long-term, adverse impacts may occur to terrestrial fauna which
         consume contaminated ground water

Documents Reviewed:

     •   Remedial Investigation Report; January 1985.
     •   Record of Decision; September 30, 1985.
     •   Feasibility Study Report; April 1986.

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                                     B-29
58TH STREET LANDFILL
TAMPA, FL
REGION 4
Type of Site:  inactive landfill containing lead-cadmium batteries
Major Release Pathways:

     •   sediment transport
     •   surface water runoff
     •   soil contaminants leaching to ground water
Principal Contaminants:

     •   inorganics:  Pb, Cd, Sb, Cu, Fe, Zn, As
     •   pH
Media/Biota Observed to be Contaminated:

     •   surface water
     •   marsh sediments
     •   surface and subsurface soils
     •   shallow groundwater aquifer

Main Ecological Risks/Impacts:

     •   potential impacts to scrub-shrub palustrine wetland vegetation
     •   potential impacts to wetland and urban wildlife
Documents Reviewed:

     •   Remedial Investigation Report; May 8, 1987.
     •   Risk Assessment; June 7, 1987.
     •   Final Feasibility Study Report; June 7, 1987.
     •   ATSDR Health Assessment; July 7, 1988.

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                                     B-30
GEIGER (C&M OIL)
CHARLESTON COUNTY, SC
REGION 4
Type of Site:
         inactive waste oil recycling and incineration facility
         inactive waste oil disposal ponds
Major Release Pathways:
     •   overflow from ponds onto land and into water ponds,  surrounding
         wetlands, and stream (during storm events)
     •   seepage from ponds into ground water, which may discharge to
         surrounding wetlands


Principal Contaminants:

     •   inorganics:  Pb, Cr, Hg
     •   organics:  VOCs, PCBs


Media/Biota Observed to be Contaminated:

     •   soil (surface and subsurface)
     •   surface water (ponds; a stream)
     •   sediment (stream; wetlands)
     •   ground water


Main Ecological Risks/Impacts:

     •   potential contamination of nearby Wallace River wetlands (endangered
         species habitat) due to migration of contaminated ground water
     •   potential contamination of wildlife that visit or reside in the
         Wallace River wetlands or in the immediate area of the site
     •   area of soil contamination -2.6 acres
     •   area of ground-water contamination -4.1 acres
     •   Pb and Cr concentrations in soil exceed concentrations known to be
         phytotoxic
     •   maximum Pb surface water concentration exceeds 4-day average AWQC by
         14X
     •   maximum Cr surface water concentration exceeds 4-day average AWQC by
         3X

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                                    B-31
Documents Reviewed:
         Summary of Remedial Investigation/Feasibility Study (from draft FY 87
         CERCLA Report to Congress).
         Record of Decision; June 1,  1987.
         Remedial Investigation Report, (including PHE);  July 1, 1986.
         Feasibility Study; July 24,  1987.
HARRIS CORF.
PALM BAY, FL
REGION 4
Type of Site:  active manufacturing facility
Major Release Pathways:  NPDES-permitted discharge of ground water treated
                         with air stripper
Principal Contaminants:

     •   inorganics:  As, Cr, Pb
     •   organics:   VOCs


Media/Biota Observed to be Contaminated:

     •   onsite soil
     •   ground water


Main Ecological Risks/Impacts:

     •   potential contamination of benthic organisms in Turkey Creek due to
         possible contamination of sediments by metals, especially in the
         treated ground-water discharge area*
     •   potential effects to aquatic organisms from discharge of treated
         ground water with possible low levels of contamination
Documents Reviewed:

     •   Groundwater Studies; March-October 1982.
     •   Analysis of Potential Groundwater Withdrawal and Treatment
         Systems; March 8, 1983.
     •   Soil and Sediment Investigation; March 1984.
     •   Old Storm Sewer Investigation; May 1984.

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                                     B-32
         Groundwater Remediation Program; August 15, 1985,
         Groundwater Assessment; November 1987.
MOWBRAY ENGINEERING
GREENVILLE, AL
REGION 4
Type of Site:
         inactive transformer repair facility
         inactive dumping area for waste oils and PCBs
         contaminated swampland adjacent to facility
Major Release Pathways:
         surface runoff/erosion from swampland into nearby stream
         seepage from swampland into ground water, which discharges to stream
Principal Contaminants:

     •   waste oils
     •   PCBs
Media/Biota Observed to be Contaminated:

         soil (surface and subsurface)
         sediment (of stream)
         ground water
         vegetation
         aquatic life of stream


Main Ecological Risks/Inpacts:

     •   stressed vegetation in swampland (one plant analyzed for PCB
         contamination in root tissue; contamination was found)
     •   effect on aquatic life in stream (after 1980 overflow of facility
         holding tanks, stream found to be devoid of aquatic life for 2.5
         miles downstream; later, catfish analyzed for PCB contamination,
         which was found to be below FDA action level for human health
         protection)
     •   potential mortality and decreased reproductive success of birds and
         fish due to bioaccumulation of PCBs
     •   swampland contamination about 3 acres in size

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                                    B-33
Documents Reviewed:
         Record of Decision; September 25, 1986.
         Remedial Investigation/Feasibility Study Work Plan; June 25, 1985.

         Final Remedial Investigation/Feasibility Study Report (including
         PHE); November 3, 1986.
         Determination of Cleanup Goals for PCBs in Soils; July 10, 1986.
MUNISPORT LANDFILL
NORTH MIAMI, FL
REGION 4
Type of Site:  inactive landfill


Major Release Pathways:  migration of landfill contaminants via subsurface
                         leachate and groundwater transport


Principal (Vmt-ami riant-ซ ;

     •   inorganics:  primarily Pb, ammonia
     •   organics:   pesticides, volatile organics
     •   low dissolved oxygen


Media/Biota Observed to be Contaminated:

         ground water
         soil
         surface water
         fish
         aquatic invertebrates


Main Ecological Risks/Impacts:

     •   actual mortality and toxicity in aquatic biota
     •   potential effects to biota include:  behavioral changes, adverse
         effects on reproduction, decreased growth, hyperexcitability, loss of
         equilibrium, inhibition of photosynthesis
     •   potential sensitive environments affected:  mangrove preserve,
         wetlands,  an estuary, habitat for endangered, threatened, or
         protected species (e.g., 4 species of sea turtle, the west Indian

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                                     B-34
         manatee, the wood stork, and the bald eagle), and the Biscayne
         Aquifer
Document Reviewed:

     •   Remedial Investigation Report; March 25, 1988.
NEWPORT DUMP
WILDER, KY
REGION 4
Type of Site:  inactive municipal landfill


Major Release Pathways:  seepage of contaminants into ground water, and
                         potential discharge of contaminated ground water to
                         adjacent stream and river


Principal Contaminants:

     •   inorganics:  As, Ba, Cr, Ni
     •   organics:  PCBs (primarily); also, benzo(a)pyrene, toluene


Media/Biota Observed to be Contaminated:

         soil
         surface water (of stream and river)
         sediment (of stream and river)
         ground water
         fish


Main Ecological Risks/Impacts:

     •   occasional exceedance of FDA human health-based tolerance limits for
         PCBs in fish tissue (not conclusively linked to this site due to
         heavy industrialization in area)
     •   noted unhealthiness of fish downstream (also not conclusively linked
         to this site)
     •   no exceedances of Clean Water Act Freshwater Aquatic Life Criteria,
         similar Kentucky criteria, and other toxicity values (for
         invertebrates, coarse fish, and game fish) for indicator chemicals
     •   potential risk to endangered species whose ranges overlap site area
     •   potential risk to birds of prey due to potential for bioaccumulation
         of PCBs in surface soils

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                                    B-35
         site is about 39 acres in size; contamination beyond site boundaries
         judged negligible and not conclusively linked to Newport Dump site
Documents Reviewed:
         Summary of Remedial Investigation/Feasibility Study (from draft
         FY 87 CERCLA Report to Congress).
         Record of Decision; March 27, 1987.
         Draft Remedial Investigation/Feasibility Study Report,  Vol. I and
         Vol. II; September 1986.
         Final Remedial Investigation/Feasibility Study Report,  Vol. I and
         Vol. Ill (appendices); March 1987.
         Final Endangerment Assessment; January 1987.
PARRAMORE SURPLUS CO.
MT. PLEASANT, FL
REGION 4
Type of Site:  active government surplus store


Major Release Pathways:

     •   leaking drums of paint residue, waste oil, degreasers,  alcohols
     •   limited migration, onsite only


Principal Contaminants:

     •   inorganics:   Pb,  Zn
     •   organics:  PCB-1254, bis(2-ethylhexl)phthalate, di-n-butylphthalate,
                    ethylbenzene,  methyl ethyl ketone, and cyanide


Media/Biota Contaminated:

     .   soil
     •   vegetation onsite


Main Ecological Risks/Impacts:

     •   no ecological impacts expected
     •   potential for area wildlife contamination is limited to direct
         contact with soils and ingestion of vegetation onsite

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                                    B-36
Documents Reviewed:
         Summary of Remedial Investigation/Feasibility Study (from draft
         FY 87 CERCLA Report to Congress).
         Record of Decision; September 15,  1987.
         Modified Remedial Investigation Report; January 1986.
SAFP BATTERY
JACKSON COUNTY, FL
REGION 4


Type of Site:   inactive battery reconditioning and battery lead (Pb) recovery
                facility


Major Release Pathways:

     •   surface runoff into surrounding cypress swamps and into streams and a
         pond
     •   possible contamination of swamps and streams by horizontal migration
         of contaminated ground water from underneath site*


Principal Contaminants:  Pb (primarily), Cd,  Al, As, Sb, Mn, Ni


Media/Biota Observed to be Contaminated:

         air (sampled during remediation)
         surface water
         soil (surface and subsurface)
         sediment (pond and streams)
         ground water
         fish in river (Pb contamination)


Main Ecological Risks/Impacts:

     •   loss of species, and reduced species numbers, diversity, and
         dominance in benthic stream fauna
     •   Pb contamination in river fish
     •   death of cypress trees
     •   site is 53 acres in size, study area covers about 460 acres;
         contamination virtually throughout site, and in undefined areas
         beyond site
     •   potential risks to endangered species in vicinity of site*

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                                    B-37
Documents Reviewed:

     •   Record of Decision; September 26, 1986.
     •   Final Remedial Investigation Report, January 20, 1984.
     •   Feasibility Study Report;  January 1987.
     •   Scope of Work for Remedial Action Support; May 24, 1988.
62ND STREET SITE
TAMPA, FL
REGION 4
Type of Site:  abandoned industrial waste disposal dump
Major Release Pathways:  leaching of concrete material and battery casing
                         waste to adjacent commercial fish ponds
Principal Contaminants:
         inorganics:  Cu, Fe, Pb,  Zn
         organics:  detergents
         turbidity
         low dissolved oxygen
         high B.O.D.
Media/Biota Observed to be Contaminated:

     •   ground water
     •   soil
     .   fish
Main Ecological Risks/Impacts:

     •   potential contaminant bioaccumulation in fish
     •   severe fish kills reported in adjacent commercial fishery
     •   potential contamination of and adverse effects to "marshy grass" and
         a 37 acre lake approximately a quarter of a mile from the site*


Document: Reviewed:  Revised Remedial Investigation Report; September 10, 1987.

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                                     ฃ-38
STAUFFER CHEMICAL COMPANY
AXIS, AL
REGION 4
Type of Site:  two adjacent chemical production facilities


Major Release Pathways:

     •   process wastes were discharged to a nearby stream and swamp that
         adjoins the Mobile River
     •   10,000 gallon spill of carbon tetrachloride
     •   potential seepage into ground water from unlined landfill, ponds, and
         disposal areas


Principal Contaminants:

     •   inorganics:  Hg, As, Cr
     •   organics:  carbon tetrachloride,  carbon disulfide
     •   brine
Media/Biota Observed to be Contaminated:

     •   sediments and surface water in swamp
     •   fish
     •   vegetation


Main Ecological Risks/Impacts:

     •   "severe ecosystem damage to endangered species habitat"
     •   Cold Creek swamp received effluent consisting of 10 ppm of Hg for
         more than 15 years
     •   sensitive environments affected include LeMoyne Swamp and Cold Creek
         Swamp
Documents Reviewed:

     •   ICF Chart on Ecological Threats at Stauffer Chemical Company Site;
         March 1988.
     •   Summary Data for HRS Scoring at Stauffer Chemical Company;
         June 4, 1987.
     •   Final Remedial Investigation Report;  May 1988.

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                                     B-39
                              EPA REGION 5  SITES
EAU CLAIRE MUNICIPAL WELL FIELD
EAU CLAIRE, VI
REGION 5
Type of Site:   municipal drinking water well field (ground water)
                contaminated by unknown sources


Major Release Pathways:  possible seepage of ground-water contaminants into
                         the Chippewa River (if pumping of ground water stops)


Principal Contaminants:  1,1-dichloroethane, 1,1-dichloroethene, 1,1,1-
                         trichloroethane, trichloroethene,  tetrachloroethene
Media/Biota Observed to be Contaminated:  ground water


Main Ecological Risks/Inpacts:

     •   potential for acute and chronic toxic effects on aquatic life in
         river (fish, invertebrates, reptiles, amphibians) if pumping of
         ground water stops
     •   potential risk to waterfowl and terrestrial mammals from ingestion of
         and contact with stream water, as well as ingestion of potentially
         contaminated biota, despite tendencies of contaminants to volatilize
         rapidly and to not bioaccmulate*
     •   ecological risk from above-ground sources of ground-water
         contamination (these sources have not been positively identified)*
     •   area of contamination is not known
Documents Reviewed:

     •   Public Health Evaluation; February-26, 1988.
     •   Public Comment Draft Remedial Investigation Report (Performance of
         Remedial Response Activities at Uncontrolled Hazardous Waste Sites);
         February 26, 1988.
     •   Draft Feasibility Study Report; February 11, 1988.

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                                     B-40
FORT WAYNE REDUCTION
FORT WAYNE, IN
REGION 5
Type of Site:  inactive landfill


Major Release Pathways:

     •   contaminated ground-water/leachate discharge to river
     •   surface water runoff to river
     •   flooding (area of river adjacent to site floods fairly frequently)


Principal Contaminants:

     •   inorganics:  As, Cd, Cu
     •   organics:  toluene, xylene, 2,4-methylphenol, phenol


Media/Biota Observed to be Contaminated:

     •   ground water
     •   river sediments
     •   onsite soil
Main Ecological Risks/Impacts:

     •   35 acres of soil contaminated with organics and metal
     •   potential for acute effects to aquatic organisms in area where
         leachate seeps into river, especially benthic organisms with a small
         range of movement; leachate concentrations exceed derived acute
         safety levels for some organics and inorganics
     •   potential for bioaccumulation and possible toxic effects to benthic
         organisms from contaminated sediments, and subsequent contamination
         of organisms higher in the food chain*
     •   potential contamination and chronic toxic effects to fish due to
         contaminants in surface water (which are below AQWC; however, fish
         with lesions and tumors have been reported from the Maumee River, but
         cannot be linked directly to this site)*
     •   potential contamination of and toxic effects to terrestrial wildlife
         and waterfowl near the site from direct ingestion of contaminated
         media or through the food chain; area is "rich with wildlife due to
         minimal human access and disturbance"*
     •   potential contamination of offsite surface water

Document Reviewed:  Remedial Investigation Report; January 7, 1988.

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                                    B-41
FOLTZ LANDFILL
BYESVILLE, OH
REGION 5
Type of Site:  inactive landfill
Major Release Pathways:

     •   contaminated ground water and leachate seepage (abandoned coal mine
         tunneling system is filled with infiltrated contaminated ground
         water)
     •   soil erosion
     •   surface water runoff
Principal Contaminants:

     •   inorganics:  Cd, Cr, Cu, Fe, Pb, Ni, Zn, Mn, As
     •   organics:  cyanide, chloroform, chlordane,  4,4'-DDT


Media/Biota Observed to be Contaminated:

     •   ground water
     •   sediments -- Wills Creek

Main Ecological Risks/Impacts:

     •   potential contamination and toxic effects to benthic organisms in
         Wills Creek from exposure to contaminated sediments, and subsequent
         contamination of organisms higher in the food chain*
Documents Reviewed:

     •   Public Health Evaluation/Risk Assessment; March 11, 1988.
     •   Remedial Investigation; October 1987.

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                                     B-42
LIQUID DISPOSAL INC.
UTICA, MI
REGION 5
Type of Site:  inactive commercial incinerator of liquid waste


Major Release Pathways:

     •   erosion of lagoon caps
     •   leachate seeps from the site


Principal Contaminants:

     •   inorganics:  Pb, Cd
     •   organics:   PCBs, trichloroethene,  PAHs,  benzene,  toluene,  phenol,
         cyanide, and pesticides


Media/Biota Observed to be Contaminated:

         onsite and offsite soil
         ground water in upper aquifer
         vegetation
         crayfish
         carp


Main Ecological Risks/Impacts:

     •   acute mortality in biota
     •   other potential acute and chronic toxic effects
     •   "inorganics and PCBs appear to have bioconcentrated in certain fish"
         with little impact
     •   sensitive environments affected:  the Clinton River, a nature study
         area, and a recreation area
Documents Reviewed:

     •   Summary of Remedial Investigation/Feasibility Study (from draft
         FY 87 CERCLA Report to Congress).
     •   Record of Decision; September 30, 1987.
     •   Remedial Investigation; May 1987.
     •   Final Draft Feasibility Study; August 1987.

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                                     B-43
MARION/BRAGG LANDFILL
MARION, IN
REGION 5
Type of Site:

     •   inactive landfill containing industrial and municipal refuse
     •   formerly a sand and gravel quarry
Major Release Pathways:

     •   leachate seeps
     •   surface water runoff
Principal Contaminants:

     •   inorganics:   As,  ammonia
     •   organics:   PAHs


Media/Biota Observed to be Contaminated:

     •   surface soil
     •   onsite and offsite ponds (surface water and sediments)
     •   ground water


Main Ecological Risks/Impacts:

     •   potential sensitive environment affected may include emergent
         riverine wetlands, and backwater habitat and pools*
     •   elevated ammonia levels exceeding Indiana water quality criteria have
         been detected in the river; however, no adverse effects are mentioned
     •   no observed impact on flora and fauna
Documents Reviewed:

     •   Summary of Remedial Investigation/Feasibility Study (from draft
         FY 87 CERCLA Report to Congress).
     •   Record of Decision; September 30, 1987.
     •   Remedial Investigation Report; June 1987.
     •   Feasibility Study Report; June 1987.

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                                     B-44
OUTBOARD MARINE
WADKEGAN, IL
REGION 5
Type of Site:  contaminated harbor


Major Release Pathways:

     •   discharge of process cooling water and floor drains at Outboard
         Marine; drains closed in 1971
     •   release of contaminated soil via surface water runoff into tributary,
         and subsequent discharge into lake
     •   seepage into ground water, which discharges to surface water; it is
         estimated that contaminated ground water from Outboard Marine site
         will begin releasing about 8 Ib/year of PCBs into Lake Michigan in
         approximately 60 years


Principal Contaminants:  PCBs


Media/Biota Observed to be Contaminated:

         fish
         shellfish
         benthic organisms
         soil
         sediments
         surface water
         surface film
Main Ecological Risks/Impacts:

     •   37 acres in harbor plus 10 kilometers outside harbor contaminated
         with PCBs
     •   22 pounds/year of PCBs are released to Lake Michigan from Waukegan
         Harbor
     •   contamination of fish (and bioaccumulation) through ingestion of
         contaminated aquatic organisms,  insects and plants,  and uptake of
         contaminated water
     •   contamination of shellfish and benthic organisms
     •   decreased diversity and equitability of benthic macroinvertebrates
         due to sediment contamination
     •   relative scarcity of fish in harbor area
     •   potential reduction in elasticity of ecosystem, including increased
         vulnerability to new sources of stress

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                                     B-45
         potential inhibition of phytoplankton photosynthesis and related
         potential reduction in growth of fish that require phytoplankton for
         food
         potential fish fry mortality
         potential reduction in natural fish populations due to interference
         of high concentrations of PCBs in sediments with development of eggs
         deposited on bottom
         potential for reduced reproduction of waterfowl and viability of
         young
         potential alterations in behavior at species level
         potential decrease in immuno-suppression in birds and animals
         increased toxicity to higher trophic level organisms
         Fifteen species of birds and five species of plants classified as
         endangered by State of Illinois are known or are likely to be present
         in the site area; bald eagle has been observed in the harbor area
         during migration periods
Documents Reviewed:
         Outboard Marine Feasibility Study: Assessment of Potential Impacts;
         no date.
         IGF Chart on Ecological Threats at Outboard Marine Corporation  Site;
         March 1988.
         Summary Data for HRS Scoring at Outboard Marine Corporation;
         June 4, 1987.
SCHMALTZ DUMP SITE
CALUMET COUNTY. VI
REGION 5
Type of Site:  inactive landfill


Major Release Pathways:

     •   direct release of PCBs from demolition debris scattered over site
     •   soil runoff to onsite ponded water
     •   potential discharge of ground water to surface water


Principal Contaminants:

     •   inorganics:  Pb,  Cr
     •   organics:   N/A

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                                     B-46
Media/Biota Observed to be Contaminated:

     •   soil
     •   onsite ponded water
     •   ground water


Main Ecological Risks/Impacts:

     •   7 acres of soil contaminated with PCBs, lead, and chromium
     •   potential contamination of and toxicity to aquatic life of Lake
         Winnebago if discharge of contaminated ground water occurs
     •   site occupies approximately seven acres of wetland area
     •   potential contamination of and toxic effects to birds and other
         terrestrial wildlife or amphibians that may ingest contaminated soil-
         dwelling organisms*
     •   potential contamination of offsite surface water and sediments
Documents Reviewed:

     •   Preliminary Risk Assessment; April 12, 1985.
     •   Draft Public Health Evaluation; September 8, 1986.
     •   Record of Decision; 1987.
SEYMOUR RECYCLING CORPORATION
SEYMOUR, IN
REGION 5
Type of Site:   inactive facility that processed, stored, and incinerated
                chemical wastes
Major Release Pathways:

     •   fugitive dust
     •   volatilization from soil
     •   surface water runoff
     •   ground-water discharge to surface water and offsite soils
Principal Contaminants:

     •   inorganics:  N/A
     •   organics:  1,2-dichloroethane; benzene; vinyl chloride; 1,1,1-
         trichloroethane

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                                     B-47
Media/Biota Observed Co be Contaminated:

         sediment
         ground water
         soil
         fish
         terrestrial biota
Main Ecological Risks/lnpacts:

     •   fish kills reported
     •   potential effects to other aquatic biota in onsite ditch and off-
         site creeks*
     •   no sensitive environments identified or potentially affected
Documents Reviewed:

     •   Summary of Remeidal Investigation/Feasibility Study (from draft
         FY 87 CERCLA Report to Congress).
     •   Record of Decision; September 4, 1987.
     •   Remedial Investigation; May 12, 1986.
     •   Public Comment Feasibility Study Report; August 29, 1986.
VELSICOL SITE
MARSHALL, IL
REGION 5
Type of Site:  active pesticide (chlordane) manufacturing facility
Major Release Pathways:

     •   accidental spills
     •   seepage into ground water, which then discharges to surface water
     •   surface runoff
     •   direct discharge to surface water


Principal Contaminants:

     •   inorganics:  Cd, Pb, Zn, ammonia, chloride, sulfate
     •   organics:  chlordane, 2-methylnaphthalene, acenapthene, PAHs
         (fluorene, naphthalene, phenanthrene,  pyrene),  hexachlorocyclopen-
         tadiene,  di-n-butylphthalate, beta-benzene hexachloride

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                                     B-48
         others:  alkalinity, TDS
Media/Biota Observed to be Contaminated:

         surface soil
         surface water (stream)
         surface water sediment
         ground water
         fish
Main Ecological Risks/Impacts:

     •   potential for chronic toxic effects mainly to aquatic organisms, and
         a lesser extent to terrestrial organisms
     •   stream sediments may be contaminated for over 2 miles downstream*
     •   potential for bioaccumulation and subsequent increased toxic effects


Document Reviewed:  Remedial Investigation Report; February 19, 1988.

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                                     B-49
                              EPA REGION 6  SITES
MID-SOUTH WOOD PRODUCTS
MENA, AR
REGION 6
Type of Site:   wood treating facility


Major Release Pathways:  waste ponds overflow and surface water runoff,
                         ground-water migration, subsurface soil leachate, and
                         soil erosion


Principal Contaminants:

     •   inorganics:  As, Cr
     •   organics:  pentachlorophenol and other creosote compounds


Media/Biota Observed Co be Contaminated:

     •   onsite soil, sediment,  surface water, ground water
     •   offsite surface water
     •   vegetation
     .   fish


Main Ecological Risks/Impacts:

     •   pentachlorophenol (a potent herbicide) prevents vegetative growth
         onsite
     •   fish kill in 1976 extended 17.5 miles downstream, with the severity
         of the kill ranging from 10 to 100 percent
     •   potential chronic effects and other acute effects to the aquatic
         riverine system*


Documents Reviewed:

     •   Site Background Information; April 1986.
     •   Remedial Investigation Report: Regulatory History;
         October 24, 1984.
     •   ICF Chart on Ecological Threats at Mid-South Wood Products Site;
         March 1988.

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                                     B-50
UNITED NUCLEAR CORPORATION
CHURCH ROCK, NM
REGION 6
Type of Site:  inactive uranium mill and mill tailings pile


Major Release Pathways:

     •   accidental spill (breach of tailings pond released 93 million gallons
         of tailings solution)
     •   direct discharge to stream/river system
     •   wind erosion
Principal Contaminants:

     •   inorganics: As, Cd, Cr, Cu, Pb, Ni, radionuclides (Th, Ra),  nitrate,
                     sulfate
     •   others:  IDS, low pH


Media/Biota Observed to be Contaminated:

         stream and river banks and bottom sediments
         ground water
         soil
         air
         livestock (no other biota examined)


Main Ecological Risks/Impacts:

     •   contamination of livestock grazing in area (potential for similar
         contamination of terrestrial wildlife*)
     •   potential chronic toxic effects to aquatic and terrestrial organisms
         (organisms potentially exposed the most are benthic organisms or
         organisms residing in river bank area)
     •   although not addressed in documents available, there probably were
         acute toxic effects to aquatic and terrestrial organisms caused by
         one-time major spill*
     •   stream sediments and banks contaminated for at least 1.5-2 miles
         downstream
     •   no threatened/endangered plants or animals observed in area, although
         two plants proposed for endangered status suspected in area and the
         area is known to include the geographical range of three terrestrial
         animals that have endangered status

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                                    B-51
Documents Reviewed:
         Final Remedial Investigation/Feasibility Study; March 7, 1984.
         Endangerment Assessment;  June 1985.
         Biological Assessment After Uranium Mill Tailings Spill; December 24,
         1980.
         Technical memorandum summarizing the Phase I Field Study; October 4,
         1985.
         Ground Water Discharge Plan for UNC; no date.
         Documentation Records for HRS;  no date.
         Sampling Inspection at United Nuclear Corporation; May 4, 1983.
         Water quality Data for Discharges from Uranium Mines and Mills
         in New Mexico; no date.
WICHITA MOUNTAIN WILDLIFE REFUGE
COHANCHE COUNTY, OK
REGION 6
Type of Site:   3 isolated, primitive ore-grinding structures, also known as
                arrastras, in which Hg was added to form an amalgamate with
                gold and silver during the late 1800s


Major Release Pathways:  direct contact with potential Hg leachate from
                         arrastras; mobilization of Hg leachate to surrounding
                         terrestrial and aquatic media


Principal Contaminants:  Hg


Media/Biota Observed to be Contaminated:  soil


Main Ecological Risks/Impacts:  no media or biota contaminant levels were
         compared to ecological protection criteria; levels in soil samples
         and fish tissue samples were compared only with human health criteria


Documents Reviewed:

     •   Summary of the Lake Lawtonka Sampling Study; March 27, 1987.
     •   An Evaluation of Mercury Contamination at the Wichita Mountains
         Wildlife Refuge; September 1986.
     •   Study of Lake Lawtonka; May 21, 1984.

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                                     B-52
                              EPA REGION 9 SITES
IRON MOUNTAIN MINE
REDDING, CA
REGION 9
Type of Site:   abandoned mine (mined for silver, gold, copper, zinc, and
                pyrite)
Major Release Pathways:  acid mine drainage (of ground water) from mine
                         workings
Principal Contaminants:

     •   inorganics:  Cd, Cu, Zn
     •   organics:  N/A
Media/Biota Observed to be Contaminated:

     •   ground water
     •   surface water
     .   fish
     •   surface water sediments
Main Ecological Risks/Impacts:

     •   surface water exceeds acute and chronic AWQC for zinc
     •   an average of 423 pounds of copper, 1,466 pounds of zinc, and 10.4
         pounds of cadmium are released from the mine area into surface water
         each day
     •   surface water and sediments downstream of the mine appear to be
         contaminated for approximately 7 miles (estimate from map)*
     •   population of king salmon, steelhead, wild trout, and other aquatic
         life in the Sacramento River have experienced numerous instances of
         mortality since the 1940's (the last occurrence was in 1969 when
         200,000 salmon were killed); there are also frequent occurrences of
         sublethal heavy metal concentrations in the river that exceed safe
         levels for trout and salmon
     •   portions of creeks downstream of mine are essentially devoid of life
     •   king salmon runs in the upper Sacramento River have declined by 87%
         in the last 20 years; and winter runs of Chinook salmon have declined
         50%
     •   reduced rates of growth of aquatic species, interference with

-------
                                    B-53
         physiological processes necessary for successful migration,  and
         inhibition of gill function have been observed
         bioaccumulation of copper and cadmium in fish
         contaminated spawning grounds for Chinook salmon in Sacramento River
         potential contamination of and toxic effects to terrestrial  wildlife
         that ingest contaminated surface water or fish*
Documents Reviewed: Remedial Investigation Report;  August 1985.

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                                     B-54
                             EPA REGION 10 SITES
QUEEN CITY FARMS
MAPLE VALLEY, WA
REGION 10
Type of Site:  inactive disposal ponds


Major Release Pathways:

     •   overflow from ponds into lake and low lands during storm events
     •   seepage from ponds into ground water, which may discharge to surface
         at distance locations
Principal Contaminants:

     •   inorganics:  Cd, Cr, Cu, Pb, Zn
     •   organics:  vinyl chloride, PCBs, benzo(a)pyrene, pentachlorophenol,
         trichloroethene, 1,2-transdichloroethene, cyanide


Media/Biota Observed to be Contaminated:

         soil (surface and subsurface)
         surface water (lake)
         surface water sediment
         ground water
         vegetation


Main Ecological Risks/Inpacts:

     •   vegetation killed in isolated areas, although possibly due to
         contaminated runoff from landfill on adjacent property
     •   potential contamination of and chronic toxic effects to aquatic and
         terrestrial organisms, including bioaccumulation of PCBs (vegetation
         in margins of lake, migrating birds and waterfowl, and terrestrial
         wildlife potential receptors); maximum concentrations of cadmium,
         chromium, copper, lead, zinc, and PCB in downgradient seep of ground
         water exceed chronic AWQC by 1-5 orders of magnitude
     •   potential acute effects to terrestrial wildlife that ingest
         contaminated water in onsite disposal ponds (concentrations of
         cadmium, chromium, copper, lead, zinc, and pentachlorophenol in ponds
         exceed acute AWQC by 1-5 orders of magnitude)
     •   potential contamination and degradation of habitat in wetlands
         associated with lake*

-------
                                    B-55
Documents Reviewed:
         HRS Panel Summary Risk Assessment for Queen City Farms;  June 1987.
         IGF Chart on Ecological Threats at Queen City Farms Site;
         March 1988.
         Focused Remedial Investigation; February 7,  1985.
         Final Endangerment Assessment Report; November 1985.
         Field Investigations of Uncontrolled Hazardous Waste Sites;  March
         1981.
         Assessment of Hydrogeology and Ground Water Quality;  December 13,
         1983.

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      APPENDIX C

 DETAILED SUMMARY OF
ECOLOGICAL THREAT DATA
 FOR  SUPERFUND SITES

-------
                                        C-l
•AIURE OF UfiSKKVlfl) CCHTAMaATIOH CR UBSmVH) BICUBICAL/EOMGICAL EFFECTS*'
Type of
Ecosystem Affected-
Freshwater River/
Stream/Wetland/
Lake (44)







Terrestrial (12)







Estuary (6)








Bay /Harbor (2)






Media
Contaminated
Ground Hater (38)
Soil (35)
Sediments (34)
Surface Hater (33)
Air (5)





Soil (12)
Surface Hater (11)
Ground Hater (10)
Sedimnnts (9)
Air (2)




Sediments (6)
Surface Hater (5)
Ground Hater (4)
Soil (3)
Air (1)




Surface Hater (2)
Sediments (1)
Soil (1)
Ground Hater (1)



Principal
Contaminants
Pb (22) PCBs (9)
VOCs (22)ฃ/ PAHs O)^
As (18) HS (7)
Cd (17) Fhthalates (7)
Cr (17) Mn (6)
Zn (IS) Cyanide (S)
Hi (13) Ba (S)
Cu (11) Phenols (S)
Other Inorg. (28)-^
Other Org. (17)-X
Pb (7)
VOCs (6)
Cr (6)
As (5)
Cd (5)
Zn (5)
Other Inorg. dง>-
Other Org. (12)-'
Asbestos (1)
IDS (l)i'
Cd (3)
Pb (3)
PCBs (3)
Ni (2)
Cu (2)
VOCs (2)
Other Inorg. (7)^
Other Org. (3)&
Asbestos (1)
IDS (1)
Pb (2)
Cd (1)
Cu (1)
NH, (1)
PCBs (1)
VOCs (1)
Pesticides (1)
Biota
Contaminated
Fish (25)
Vegetation (15)
Aquatic Invertebrates (7)
Mammals (2)
Reptiles (2)
Birds (1)




Vegetation (9)
Fish (6)fi/
Mammals (2)
Amphibians (1)





Fish (5)
Aquatic Invertebrates (4)
Vegetation (3)
Manuals (1)
Reptiles (1)




Fish (2)
Aquatic Invertebrates (2)





Observed
Biological/Ecological Effect
Toxicity to Aquatic Fauna (11
(Except Fish Kill)
Toxicity to Vegetation (11)
Bioaccumulation (7)
Altered Species Diversity (6)
Fish Kill (4)
Toxicity to Terrestrial Fauna



Toxicity to Vegetation (9)
Bioaccumulation (2)
Toxicity to Aquatic Fauna (2)*
(Except Fish Kill)
Fish Kill (i)"7




Toxicity to Aquatic Fauna (2)
(Except Fish Kill)
Altered Species Diversity (1)
Bioaccumulation (1)
Toxicity to Terrestrial Fauna




Toxicity to Aquatic Fauna (2)







.)





(1)




\l










(1)












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                                                                          EXHIBIT C-l
                                           HAIURE OF UBSEHVEU CGBttMnttTIGB OR UBSmVED BICLOGICAL/BOXOGICAL KFKHLTS
a/   The numbers in parentheses represent the approximate lumber of  sites, out of  52,  at which  the particular  ecosystem has been affected,  or  at which the
~    particular medium contamination,  biota contamination, or biological/ecological  effect has  been observed.   Because  of uncertainties  in classifying each site
     into the categories used in this table, these numbers are  only  approximate and  indicative  of the  relative frequency  of occurrence of types  of observed
     contamination and effect.

b/   Because a given site may have been observed to affect more than one  type of ecosystem,  and because  a given site's  effect  on an ecosystem  may not  have been
     observed, the numbers in this column do not sum to 52.   For the same reasons, the numbers  for a given  type of contamination or effect (e.g.,  media
     contaminated) do not sum to 52, and the numbers for a specific  type  of  contamination or effect that pertain to a given "type of ecosystem affected"  (e.g.,
     terrestrial) do not sum to the total number of sites for that "type  of  ecosystem  affected."

ฃ/   Volatile organic compounds.  This category includes a variety of both aromatic  hydrocarbons (e.g.,  benzene,  toluene) and  chlorinated hydrocarbons (e.g.,
     trichloroethylene (TCE), perchloroethylene (FCE)).

d/   This category includes various contaminants that were observed  as  "principal  contaminants" at less  than five sites.

e/   Polynuclear aromatic hydrocarbons (e.g., benzo(a)pyrene, naphthalene).

f/   Total dissolved solids.

g/   Although these categories do not directly concern terrestrial ecosystems, they  are included here  because  they were noted  at some of the 11  sites  that
     affected terrestrial ecosystems,  and because aquatic fauna may  be  consumed by (and therefore contaminate) terrestrial fauna.

h/   This category includes various contaminants that were observed  as  "principal  contaminants" at only  one site.

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                                     EtHTBIT C-2
•ATORE OF EBOJECTBl BrOjOGICAL/ECClJOGICAL EFFECTS FBGH OBSERVED HEDIA CCBInKDIAnCB*'

Type of Ecosystem
Potentially Affected^'
Freshwater River/
Stream/Wetland/
Lake (33)










Terrestrial (20)









Estuary (6)










Bay /Harbor (2)







Media
Contaminated
Ground Water (30)
Soil (28)
Surface Water (27)
Sediments (27)
Air (4)








Ground Water (16)
Soil (16)
Sediments (14)
Surface Water (13)
Air (1)






Soil (4)
Surface Water (4)
Sediments (4)
Ground Water (3)







Surface Water (2)
Sediments (2)
Soil (2)
Ground Hater (1)




Principal
Contaminants
Pb (16)
VOCs (16)
Cr (16)
As (15)
Cd (13)
Zn (12)
FCBs (10)
PAHs (9)
Cu (8)
Mn (7)
Fe (7)
Hg (5)
Other Inor. (19)
Pb (11)
TOCs (9)
Zn (8)
Cd (7)
PCBs (7)
PAHs (7)
As (6)
Cr (6)
Cu (5)
Other Inorg. (17)
Other Org. -(5)
Pb (4)
VOCs (3)
Cd (3)
As (2)
Cr (2)
Hi (2)
PCBs (2)
Cu (1)
PAHs (1)
Phthalates (1)
Pesticides (1)
Pb (1)
Cr (1)
Cu (1)
PCBs (1)
VOCs (1)
PAHs (1)


Projected Biota
Contaminated
Birds (19)
Mammals (19)
Aquatic Invertebrates (16)
Fish (9)
Amphibians (8)
Vegetation (8)
Reptiles (6)






Mammals (IS)
Birds (13)
Aquatic Invertebrates (5)3/
Amphibians (5)
Fish (3)-'
Vegetation (2)
Reptiles (2)




Fish (2)
Aquatic Invertebrates (2)
Birds (2)
Vegetation (1)
Mammals (1)






Vegetation (1)
Fish (1)
Aquatic Invertebrates (1)
Mammals ( 1 )
Birds (1)
Reptiles (1)
Amphibians (1)

Projected
Biologial/Ecologial Effects-'
Bioaccvxnulation (18)
Toxicity to Aquatic Fauna (17)
Toxieity to Terrestrial Fauna (17)
Toxicity to Vegetation (4)
Altered Species Diversity (3)








Toxicity to Terrestrial Fauna (15)
Toxicity to Aquatic Fauna (10)-'
Bioaccmulation (6)
Altered Species Diversity (3)
Toxicity to Vegetation (1)






Bioacctraulation (2)
Toxicity to Aquatic Fauna (1)
Toxicity to Terrestrial Fauna (1)
Toxicity to Vegetation (1)
Altered Species Diversity (1)






Bioaccumulation (3)
Altered Species Diversity (1)
Toxicity to Vegetation (1)
Toxicity to Aquatic Fauna (1)
Toxicity to Terrestrial Fauna (1)



-------
                                                                          EXHIBIT C-2
                                       RATIIEE OF PBOJECTH) BIOLOGICAL/ECOLOGICAL EKKHL.TS FBGH (JBSKHVO) (CDIA OOHTAMLEATiaH
a/   The numbers in parentheses represent the approximate number of sites,  out of  52,  included  in  each category.   Specifically,  the numbers indicate how many
     sites:

     —  are projected to have the specified ecosystem affected;

     —  have observed contamination of the indicated environmental media;

     —  are contaminated with each of the principal contaminants;

     --  are projected to have contamination of the specified biota based on  observed  contamination;  and

     --  are projected to have the indicated biological/ecological  effects.

     Because of uncertainties in classifying each site into the categories  used  in this  table,  these  numbers  are  only approximate and indicative of the relative
     frequency of occurrence of types of media contamination and projected  biological/ecological effect.

b/   Because a given site may have potentially affected more than one type  of ecosystem,  and because  a given  site may not have potentially affected any ecosystem
     at all, the numbers in this colunn do not sum to 52.  For the  same reasons, the numbers for a given type of  potential contamination or effect (e.g., media
     contaminated) do not sum to 52, and the numbers for a specific type of potential  contamination or effect that pertain to a given "type of ecosystem
     affected" (e.g., terrestrial) do not sum to the total number of sites  for that "type of ecosystem affected."

ฃ/   This column includes the potential effects noted in site documentation as well as potential effects not  discussed in the documentation but judged to be
~    significant by site documentation reviewers.  The specific potential effects  noted  only by site  documentation reviewers are indicated by asterisks in
     Appendix B (Summary of Ecological Threat Data for Individual Sites).

d/   Although these categories do not directly concern terrestrial  ecosystems, they are  Included here because they were noted at some of the 14 sites with
     potentially affected terrestrial ecosystems, and because aquatic fauna may  be consumed by  (and therefore potentially affect) terrestrial fauna.

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               EXHIBIT C-3
THREATS TO SKHSlTlVK/srauiAL QHMlftJMUUk
Sensitive/Special.
Environment Category
Hetlands/Marsh/Swamp
Number of Sites with
Sensitive Environment
Contaminated^
18
Number of Sites Projected
to have Sensitive
Environment Contaminated^
12
Nature
Observed
• Contaminated surface
water (14)
• Contaminated sediments
(16)
of Contamination/Effect-
Projected
• Contamination of surface
water (16)
• Contamination of
sediments (14)
                                        •  Contaminated soil (16)

                                        •.  Contamination of and/or
                                           damage to and death of
                                           vegetation (9)

                                        a  Contamination of benthic
                                           organisms (3)

                                        •  Contamination of fish
                                           (11)

                                        ป  Contamination cf ether
                                           aquatic organisms (other
                                           than fish and benthic
                                           organisms) (4)

                                        •  Contamination of mammals
                                           (1)

                                        •  Fish kill (2)

                                        •  Physical deformities and
                                           growths in fish (2)
•  Uptake of contaminants by
   vegetation (5)

•  Contamination of soil (9)

•  Contamination or
   bioaccumulation of
   contaminants in aquatic
   organisms (11)

•  Contamination of benthic
   organisms (4)

•  Contamination of
   terrestrial wildlife
   (e.g., birds, small
   mammals) (IS)

•  Reduced reproductive
   success in birds (3)

•  Reduced reproductive
   success in fish (2)

•  Reduced growth of aquatic
   organisms (2)

•  Contamination of soil-
   dwelling invertebrates
   (1)

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                                                                          EXHIBIT C-3
                                                       THREATS TO SKHSlTlVE/snuiAL Env.uuMUIli> (cont'd)
Sena itive/Special
Environment Category
Endangered Species
Dumber of Sites with
Sensitive Environment
Contaminated^'
3
Number of Sites Projected
to have Sensitive
Environment Contaminated-'
10
Nature
Observed
• Decline in numbers of
of Contamination/Effect^'
Projected
• Contamination of bald
  Habitat/Migration
  Pathway
   winter run Chinook Salmon
   of 50Z in 20 years (Move
   is currently underway to
   place them on State's
   endangered species list.)
   (1)

   Contamination and limited
   numbers of Lake Hhitefish
   — State endangered
   species (1)

   Ecosystem damage to
   endangered species
   habitat (American
   Alligator) and proposed
   endangered species
   (Alabama Red-Bellied
   Turtle) (1)
eagles  (5)

Contamination of other
endangered bird species
(5)

Contamination of State-
designated endangered
plant species (2)

Contamination of aquatic
endangered species (1)

Contamination of
terrestrial endangered
species other than birds
(1)
Wildlife Refuge
•  Contaminated soil (2)

•  Contaminated surface
   water (1)

•  Contaminated sediments
   (1)

•  Contaminated vegetation
   (1)
Contamination of surface
water, sediments,
vegetation, and birds at
wildlife refuge from
sites nearby (3)

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                                                                          EtHTBIT C-3
                                                       THREATS TO SiOBlTlVli/sraJujLAL HOTBCMBUS (cont'd)
   Sensitive/Special
  Environment Category
Number of Sites with
Sensitive Environment
     Contaminated-'
Number of Sites Projected
    to have Sensitive
Environment Contaminated-
                                                                                                                         Nature  of Contamination/Effect-'
                                                                                                                                                       b/
                                        Observed
                                                                                                          Projected
Sensitive Spawning/
  Breeding Areas
                                                                   Contaminated surface
                                                                   water and sediments in
                                                                   sensitive spawning area
                                                                   (2)

                                                                   Contaminated surface
                                                                   water,  soil, vegetation
                                                                   and  aquatic organisms in
                                                                   nesting and breeding area
                                                                   of endangered bird
                                                                   species (1)
                                                                   Contamination of surface
                                                                   water in area of wildlife
                                                                   refuge designed for
                                                                   propagation of fish and
                                                                   waterfowl (1)
Estuary
                                                                •  Contaminated surface
                                                                   water (2)

                                                                =  Ccr.tsninsted surface
                                                                   water sediments (2)

                                                                •  Contaminated soil (1)

                                                                •  Contamination of
                                                                   vegetation (1)

                                                                •  Bioaccuroulation of FCBs
                                                                   in fish (1)

                                                                •  Contamination of benthlc
                                                                   community  (1)

                                                                •  Reduced reproductive
                                                                   success, species
                                                                   diversity  in aquatic
                                                                   organisms  (1)
                                                                   Contaminated sediments
                                                                   (2)

                                                                   Contflnriruit.ad soil (21

                                                                   Contaminated surface
                                                                   water (2)

                                                                   Contaminated vegetation
                                                                   (1)

                                                                   Decreased populations of
                                                                   aquatic biota due to PCB
                                                                   contamination of surface
                                                                   water and sediments (2)

                                                                   Contamination of
                                                                   terrestrial biota (1)

                                                                   Reduced growth of aquatic
                                                                   organisms (1)

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                                                                          EXHIBIT C-3
                                                       THREATS TO SEKij.TJ.ve/sn9UiAL ERVIBCBC1RS (cont'd)
   Sensitive/Special
  Environment Category
Number of Sites Kith
Sensitive Environment
     Contaminated-
Number of Sites Projected
    to have Sensitive
Environment Contaminated-
                                                                                                                          Nature  of Contamination/Effect-'
                                                                        Observed
                                                                                                          Projected
Other (State parks, lakes
  adjacent to parks, Indian
  reservation, nature study
  areas)
                                                                •  Contaminated  surface
                                                                  water  (1)

                                                                •  Contaminated  soil (2)

                                                                •  Contaminated  surface
                                                                  water  sediments  (2)

                                                                •  Low  aquatic species
                                                                  diversity  and quantity
                                                                  (1)

                                                                •  Bioaccumulation  of
                                                                  organics in fish (2)

                                                                •  Contaminated  stream and
                                                                  riverbank  (1)

                                                                •  Toxicity and mortality of
                                                                  aquatic organisms (2)

                                                                •  Contaminated vegetation
                                                                  (2)
                                                                   Contamination of surface
                                                                   water (1)

                                                                   Contamination of
                                                                   sediments (1)

                                                                   Contamination of
                                                                   terrestrial wildlife (2)

                                                                   Contamination of benthic
                                                                   organisms (1)

                                                                   Acute toxic effects to
                                                                   aquatic organisms (2)

                                                                   Acute toxic effects to
                                                                   terrestrial  organisms (1)
a/   Each site is included in only one of these columns.   Therefore, the numbers of sites with sensitive environment contaminated and the numbers of sites with
     sensitive environment potentially contaminated are additive.

b/   The numbers in parentheses represent the number of sites that have the noted observed or potential ecological effects.  Both observed and potential
     ecological effects may result from sites known to have  a sensitive environment contaminated.  Therefore, effects from one site may appear in one or both of
     these columns.  The numbers in these columns are not  additive and, because of judgments and uncertainties associated with placing each site into the above
     categories, the numbers should be considered only approximate.

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                                                                          EXHIBIT C-4
                                                                 EHERT OF ECOJOGICAL IMPACTS57
        Category of Environmental
           Impact and Site Name
            Areal Extent of Contamination
              Magnitude of Contamination-^
SURFACE HATER OQRUHHUTIGH

Chisraan Creek



Site name confidential-


Hudson River FCBs

Iron Mountain Mine


Llpari Landfill
Munisport Landfill
Site name confidential


Outboard Marine


Queen City Farms
36 acres of freshwater ponds (4) contaminated with
   arsenic, cadmium, copper, lead, nickel,
   selenium, vanadium, and zinc

1.1 miles of surface water in brook contaminated
   with lead, nickel, and zinc

200 mile stretch of river contaminated with PCBs

Up to 7 miles of surface water contaminated with
   cadmium, copper, zinc

26 acres of lake contaminated with bis(2-lead
   chloroethyDether (BCEE), mercury, and lead
                                                        l.SOO  feet  of  streams contaminated with bis(2-
                                                           chloroethyl)ether, toluene,  arsenic, chromium,
                                                           mercury,  and  lead
Inorganic contaminants in river approximately
   2,000 feet from site

Approximately 8 on-site lakes contaminated, the
largest two of which are 8.0 and A.6 acres,
respectively

6 square miles of estuary contaminated with PCBs,
   copper, cadmium, and lead

37 acres in harbor plus 10 kilometers outside
   harbor contaminated with FCBs

2-3 acres of ponds (6) contaminated with various
   organics and cadmium, chromium, copper, lead,
   zinc, and cyanide
Exceeds AWQC for lead, vanadium
Lead and nickel exceed chronic AWQC by 45x and 6x
   respectively

FCBs exceed acute and chronic AWQC up to 14.3x

Surface water exceeds chronic AWQC for zinc up to
   6x

Exceeds human health criteria for consumption of
   fish for BCEE and mercury, and chronic AWQC for
   lead 5x

Exceeds human health criteria for consumption of
   fish for BCEE, exceeds acute AWQC for lead by
   l.Sx and is equivalent to chronic AWQC for
   chromium

Exceeds acute AWQC for copper lOx and Dade County
   criterion for lead 4x.

Exceeds chronic AWQC for copper 2x and State of
   Florida criterion for zinc 5x.
Exceeds acute and/or chronic AWQC for PCBs up to
   264x, for copper up to 41x

PCBs exceed acute AWQC up to 43x
                                                                                                              Exceeds  acute AWQC  for  cadmium by up to  6,920x,
                                                                                                                  chromium by  up to  414,000x,  copper by up to
                                                                                                                  89,200x,  lead by up  to l,840x,  zinc by  up to
                                                                                                                  375x,  and pentacholorophenol by up to 273x

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                                                                           EXHIBIT C-*
                                                           ETTEBT OF EOUOGICAL IMPACTS57 (continued)
        Category of Environmental
           Impact and Site Name
            Areal Extent of Contamination
                                                                     Magnitude of Contamination-
CCBTAMHUTICH OF SURFACE HATER SEDMHTS

Hudson River PCBs




Iron Mountain Mine



Lipari Landfill
Marathon Battery
Site name confidential
Outboard Marine
Re-Solve
Site name confidential
United Nuclear Corporation
200 miles of river sediments contaminated with
   PCBs
7 miles of stream/river sediments contaminated
   with cadmium,  copper,  zinc
1,500 feet of stream sediments contaminated with
   bis(2-chloroethyl)ether,  chromium,  lead, zinc,
   and mercury

26 acres of sediments in lake contaminated with
   arsenic, mercury, lead, and zinc

34 acres of cove sediments contaminated with
   metals

6 square miles of estuary contaminated with PCBs,
   cadmium, copper,  and lead
37 acres in harbor plus 10 kilometers outside
   harbor sediments contaminated with PCBs

300 feet of unnamed tributary contaminated with
   PCBs

1,200 feet of stream sediments contaminated with
   asbestos

1.5-2.0 miles of stream sediments and river bank
   contaminated with radionuclides and metals
Approximately 229 metric tons estimated to remain
   in upper Hudson River area; concentrations of
   PCBs range up to 250 ppm; 40 PCB "hot spot"
   areas

An average of 423 pounds of copper, 1,466 pounds
   of zinc, and 10.4 pounds of cadmium are
   released from the mine area each day

Concentrations of lead and chromium exceed
   background  levels  by 820x  and 15x,  respectively
                                                                                                               Arsenic and mercury concentrations exceed
                                                                                                                  background levels in lake

                                                                                                               Contains metal contamination above cleanup levels
Maximum concentrations exceed no-observed-effects
   levels 260x for PCBs, 19x for cadmium, 6x for
   copper, 6x for lead

22 pounds/year of PCBs are released to Lake
   Michigan from Waukegan Harbor

Sediments are "highly contaminated" with PCBs to a
   depth of 1 foot

Sediments contain up to 30X asbestos
Released 93 million gallons of tailings solution
   in accidental spill; radionuclide
   concentrations now in sediment between 5 and
   50x health-based cleanup levels for surface
   soil

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                                                                          EXHIBIT C-*
                                                           UUHT OF ECOLOGICAL IMPACTS5'  (continued)
        Category of Environmental
           Impact and Site Name
            Areal Extent of Contamination
                                                                     Magnitude of Contamination—
              OF son.

Army Creek Landfill


Chemical Control


L.A. Clarke


Clothier



Site name confidential


Delaware Sand and Gravel


Fort Wayne Reduction


Geiger


Lipari Landfill




Mid-South Wood Products


F. O'Connor


Palmerton Zinc



Queen City Farms
44 acres of soil contaminated with metals and
   organics

2.2 acres of soil contaminated with organica and
   metals

Area of approximately 10 acres contaminated with
   polynuclear aromatic hydrocarbons

6 acres of soil contaminated with organics and
   metals
15 acres of soil contaminated with organics and
   metals

12.5 acres oC soil contaminated with metals
35 acres of soil contaminated with organics and
   metals

2.6 acres of soil contaminated with PCBs and
   metals

700' x 200' area of marsh soil (3.2 acres)
   contaminated with organics and metals
Approximately 5 acres of soil contaminated with
   pentachlorophenol, chromium, free oil

5 acres of soil contaminated with PCBs and metals
2,000 acres of soil contaminated with metals
N/A
Soil not sampled; landfill contains refuse ranging
   from 6-35 feet in depth over 44-acre area

18,000 cubic yards of soil contaminated
163,000 cubic yards of soil contaminated
PCB concentrations up to 92 ppm, phenols up to
   34.2 ppm, barium up to 50 ppm, and arsenic up
   to 4.4 ppm

N/Ad/
Approximately 535,000 cubic yards of conteaninate
   soil

VOCs detected up to thousands of ppra
Lead and chromium concentrations in soil exceed
   concentrations known to be phytotoxic

Contamination with several organic compounds up to
   3 orders of magnitude over background, and
   metals up to 6 orders of magnitude over
   background
N/A
PCB concentrations up to 6,205 ppm, lead up to 47x
   background, and cadmium up to 160x background

Cadmium, lead, and zinc concentrations exceed
   background levels by 2,600x, 2,000x and 400x
   respectively

17,000 cubic yards of soil contaminated with
   organics and metals

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                                                                           EXHIBIT C-4
                                                           EXTENT OF ECOLOGICAL IMPACTS*'  (continued)
        Category of Environmental
           Impact and Site Name
            Areal Extent of Contamination
                                                                     Magnitude of Contamination-
Schmaltz Dump
Site name confidential
West Virginia Ordnance Works
7 acres of soil contaminated with PCBs, lead,
   chromium

20 acres of soil covered with asbestos-laden
   tailings and ore

Up to a 60 acres of soil contaminated with
   nitroaromatlca,  lead, PAHs
PCB concentrations up to 10 mg/kg, lead up to
   1,940 mg/kg, and chromium up to 964 mg/kg

Tailings and ore contain between 5X and 40X
   asbestos

Nitroaromatic concentrations greater than 1,000
   ug/g over roughly 1 acre, and greater than 100
   ug/g over another 2-3 acres.  Maximum lead
   concentration is 1,400 ug/g and maximum PAH
   concentration is 100 ug/g
FISH DLLS

Iron Mountain Mine


Mid-South Hood Products

Mowbray Engineering


Seymour Recycling
Several fish kills have occurred extending up to 7
   miles downstream

Fish kill in 1976 extended 17.5 miles downstream

Fish kill in 1980 extended 2.5 miles downstream
Fish kill in creeks next to property extended
   1,100 feet downstream
Last fish kill occurred in 1969; 200,000 salmon
   were killed

Severity of fish kill ranged from 100Z-10X

2.5-mile length of stream virtually devoid of life
   after 1980 incident
N/A
•IKHl.TATHM

L.A. Clarke


Mid-South Wood Products


Palmerton Zinc



Site name confidential


West Virginia Ordnance
Several areas of stressed vegetation totaling less     N/A
   than one acre

5.5 acres of area devoid of vegetation due to          N/A
   pent achloropheno1

2,000 acres on Blue Mountain completely defoliated     N/A
   due to emissions containing cadmium, lead, and
   zinc

Vegetation will not grow on area of at least S         N/A
   acres

Death of vegetation on approximately 1 acre,           N/A
   vegetation growth inhibited on approximately 2-
   3 additional acres

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                                                                           EXHIBIT C-*
                                                                  OF BDCUOGICAL IMPACTS*'  (continued)
        Category of Environmental
           Impact and Site Name
            Areal Extent of Contamination
                                                                                                                             Magnitude of Contamination-
COnAMIHATIGH/DBGRADATIGB OF HETLAIDS/MAB^ES

Lipari Landfill


Marathon Battery




Mowbray Engineering



Re-Solve


Wildcat Landfill
Contamination of an 8 acre marsh with organics,
   mercury, lead

284 acres of marsh sediments contaminated with
   metals (up to 2 miles from plant)
Contamination of 3 acres of swamp with oils and
   ECBs
Contamination of 0.1 acres of wetlands with PCBs
                                                        Degradation and loss of 29 acres of wetlands
                                                           habitat
Large, dead trees in marsh potentially stressed
   from  exposure  to  leachate  and contaminated  soil

5-10 metric tons of cadmium remain in marsh;
   widespread cadmium and nickel contamination,
   comprising 1-171 of sediments on a dry weight
   basis

Bullrushes in swamp contain PCBs at 8.9 rag/kg
   (this concentration is above background
   concentrations)

Contamination in sediments of more than 1 ppm of
   PCBs to a depth of roughly 1.5 feet
                                                       N/A
a/ Explicit information was provided on areal extent of contamination for 28 of the 52 sites in the sample (for at least one environmental medium); only those 28
   sites are included in this exhibit.

b/ Indicates degree to which contaminant levels exceed applicable  criteria such as AHQC.   This information is not provided for soil and sediment contaminants
   because generally applicable criteria for these media do not  exist.

ฃ/ Name of site withheld because information reviewed is in draft  form.

d/ Additional information not available in site documentation  reviewed.

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           APPENDIX D

REGIONAL AND STATE RCRA CONTACTS
    AND  INTERVIEW SUMMARIES

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                                      D-2
                   RCRA Ecorisk Regional and State Contacts
Region

   I
Contact

George Furst1
(617) 573-574
          State Contact
            Matt Hoaglund
            (617) 573-5775

            Larry Brill
            (617) 565-3560

            Dave Lira
            (617) 573-5766
                          ME
          Stacy Ladner
          (207) 289-2651

          Jim Glasgow
          (207) 289-2651

          Scott Whittier
          (207) 289-2651

          Andy Cobb
          (207) 289-2651
            John Zipeto
            (617) 573-5744
                          MA
          Jeff Chorman
          (617) 292-5888

          Ralph Fine
          (617) 292-5888
  II
Ellen Doring
(212) 264-1362
NY
Steve Cominsky
(518) 457-9696
            Barry Tornick
            (212) 264-4479
                          NJ
          Ernie Kuhlwein, Section Chief
          (609) 292-9880

          Bill Sharpies, Engineer
          (609) 292-9880
 III
Jack Potosanak
(215) 597-8338

Diane Schott
(215) 597-8256

Jim Webb
                                      DE
          Wayne Thomas
          (302) 736-3824
    1  Names  in bold indicate  persons  interviewed.  Non-bold names  are
recommended contacts.

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                                      D-3
             RCRA Ecorlsk Regional and State Contacts (Continued)
Region      Contact

IV          Mickey Hartnett
            (404) 347-3433
            Joe Boyle
            (312) 886-4449
            Jim Brossman
            (312) 886-4447
GA
                                      FL
                                      AL
                                      KY
                                      MS
                                      NC
                                      SC
                                      TN
IL
OH
                                      MN
State Contact

Mark Smith, Proj.  Officer
(404) 656-7802

Satish Kastury, Hz. Waste Div.
(904) 488-0130

Buddy Cox, Hz. Waste Div.
(205) 271-7730       Chief

Muhammad Alauddin, Hz. Waste
(502) 564-6716  Branch Manager

Sam Maberry, Hz. Waste Div.
(601) 961-5101          Chief

Bill Meyer
Bill Hanner
(919) 733-2178

Hartsill Truesdale, Solid/Hz.
(803) 734-5200      Waste Div.
                    Chief

Dwight Hinch
(615) 741-3424

Bill Rodlinski, State RCRA
(217) 782-9898    program
                   development

Glenn Savage, Section Manager
(217) 785-7402     RCRA field
                   operations

Janis Perino, Director,
(217) 782-8700    Ecotox.
                  program

Mike Savage, Enforcement
(614) 644-2947

Ed Kitchen, Permitting
(614) 644-2963

Larry Christiansen, Perm. &
(612) 296-7784      Enforc.

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                                     D-4

                   RCRA Ecorisk Regional and State Contacts (Continued)

Region      Contact                             State Contact

                                      IN        John Hayworth
                                                (317) 232-8857
VI
Maria Daniels

Doug Ablen
(214) 655-6719
            Bernadette Yuhas
            (214) 655-6775

            Jim Sales
            (214) 655-6719

            Mark Sides
            (214) 655-6719
TX
                                      OK
                          AR
Minor Hibbs, Chief of Permits
(512) 463-8173

Robert Rabitane, Environmental
(405) 271-5338        Programs

Bill Molere, Permits Programs
(504) 342-4685       Manager
          Mike Bates, Hz. Waste Division
          (501) 562-7444
VII
Bob Stewart
MO
                                      KS
                                      IA
Frank Dolan, Permitting Div.
(314) 751-3176

John Mitchell, Permitting
(913) 296-1608

Luetta Flournoy, Section Chief
VIII
Larry Wapensky
(303) 293-2782

Lisa Reed
(303) 293-1840
UT
                                      CO
                                      MT
                                      ND
                                      SD
                                      WY
Dennis Downs
(801) 538-6170

Joan Sowinski, Section Chief
(303) 331-4930

Dwayne Robertson
(406) 444-2821

Martin Shock, Hz. Waste Div.
(701) 538-6170      Manager

Joel Smith, Engineer
(605) 773-7153

Dave Finley
(307) 777-7752

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                                      D-5
             RCRA Ecorisk Regional and State Contacts (Continued)
Region

IX
Contact

Karen Schwinn
X
Ken Feigner
(206) 442-2782
CA
                                      AZ
ID
                                      OR
                                      WA
                                      AK
State Contact

Mary Hisemer, Enforcement,
(916) 322-8046   State HQ

Jan Smith, Permitting,
(916) 324-2423    State HQ

Steve Baxter, Duty Officer,
(213) 620-2380    LA Regional
                  Office

Nestor Acedera, Assessment &
(213) 620-5052    Mitigation,
                  LA Regional
                  Office

Al Roesler, Permitting
(602) 257-2259

Cheryl Koshuta
(208) 334-5876

Jane Witworth
(503) 229-6434

Hugh O'Neill, Environmental
(206) 459-6434     Engineer

Stan Hungerford, Solid/Hz.
(907) 465-2666   Waste Div.
                 Branch Chief

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                                      D-6

                           STATE  INTERVIEW SUMMARIES

REGION I

Maine -- Andy Cobb

•     May have information available for a number of sites, but Mr. Cobb is
      unfamiliar with this area of inquiry and needs time to check into files
      and ask his coworkers about specific sites, document availability, and
      ecorisk issues.  He may contact us with more information.
Massachusetts -- Jeff Chorman and Ralph Fine

•     Identified two sites with possible ecological considerations involved in
      RCRA permitting and corrective action:

            Wyman-Gordon, North Grafton, MA:  facility in post-closure
            permitting has been studied with regard to effects on a nearby
            wetland and incorporation of ecological effects in the ACL
            process;

            GE Pittsfield:  facility is allegedly responsible for PCBs in the
            Housatonic River.

•     Documentation for the Wyman-Gordon facility may be available through
      Region I.   John Zipeto of Region I has sent a copy of Chapter 11 of the
      RCRA Part B Permit Application that was used by the Hazardous
      Waste/Groundwater Task Force.

•     Non-site-specific studies of ecological threats include work in Boston
      Harbor and New Bedford Harbor.  The relationship between these studies
      and RCRA is not clearly defined.

•     Although Mr. Chorman is aware of a number of large utility generation
      stations in Massachusetts, he could remember no studies of the
      ecological impacts of their waste management practices.

•     Ecological assessment methods used include:

            Wetlands assessment including species counts, plant density and
            height, leaf counts, and measurements of Arsenic uptake;

            Use of aquatic life water quality criteria to determine acceptable
            ACLs;

            "Microtox" work in surface waters by the Division of Water
            Pollution Control.

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                                      D-7

      Information about ecological threats is used to decide upon appropriate
      cleanup and action environmental concentrations and cleanup methods.
      Incorporation of ecological considerations in ACL petitions and review
      is new; its effects on the ACL decision process are as yet uncertain.
REGION II

New Jersey -- Bill Sharpies

•     Identified no sites with known or suspected ecological threats.

•     Suggested that we obtain copies of some facility "Health and
      Environmental Impact Assessments" to review for their incorporation of
      ecological threat information.  Mr. Sharpies also mentioned site
      evaluations and siting commission work as possible sources of relevant
      information.  (A letter requesting copies of some of these documents has
      been sent to Ernie Kuhlwein, Section Chief, Division of Hazardous Waste
      Engineering.)

•     The Hazardous Waste Division contacted the Division of Water Resources
      and the Department of Fish and Game to identify potential effects of
      RCRA facilities on ground water, surface water, trout streams,  and
      wetlands.

•     Siting commission selects potential facility sites using location
      criteria which may include ecological considerations.

•     Mr. Sharpies was aware of no measurements of effects of hazardous
      releases from RCRA facilities in the half of New Jersey for which he is
      responsible.

•     Vegetation damage has been observed at a few sites, but this information
      has not led to a more thorough study of the ecological effects, merely
      to indicate potential releases for further study.
New York -- Steve Cominsky

•     Identified the Ciba-Geigy Main Plant as an exemplary case of the
      incorporation of ecological threat studies and information in RCRA.
      However, negotiations concerning plans for required ecological studies
      in the Hudson River and another area adjacent to the plant are just
      getting underway between the State and Ciba-Geigy;  no information is yet
      available.

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                                     D-8

      No documentation is yet available, although Ciba-Geigy has apparently
      proposed some type of ecological assessment in the river and adjacent
      area.  A negotiated agreement on the proposed study will be included in
      a modified permit for the facility.

      Non-site-specific studies include river contamination studies of the
      Hudson River and Grass-St. Lawrence Rivers.  These studies may not
      relate directly to RCRA.

      Methods used to assess ecological impacts include investigations
      (specifics not clear) of fish in the river studies and body burden in
      wildlife.

      Ecological threat information will be used in determining corrective
      action requirements.

      A major problem in incorporating ecological threat information in New
      York state's RCRA program is its regulatory limitation to onsite
      investigations.  Presently, New York must defer offsite investigations
      to EPA or work out specific state orders to permit such investigations
      on a site by site basis.

      Referred to Mr. Ward Stone, 518-439-8017, of the New York Division of
      Fish and Wildlife.  Mr. Stone has assisted in developing study
      requirements for the Ciba-Geigy facility and is often called in to
      supply  expertise on ecological study methods and potential ecological
      impacts.
REGION III

Delaware -- Wayne Thomas
      Agreed that the Texaco Oil Seep Area may provide good ecological impact
      information.  We have sent him a letter requesting documentation of this
      area.
REGION IV

Alabama -- Buddy Cox

•     Chem Waste Management Site: currently gathering data on benthic
      organisms in a stream adjacent to the site to assess a potential
      ecological threat.  Many variables effecting the stream's ecosystem - it
      is difficult to determine how much RCRA contaminants have contributed to
      damage at the impacted stream.

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                                     D-9

      ILCO site: the State has identified a dead stream reach downstream  from
      this site.  Mitigation is proceeding on corrective action impart  based
      on biomonitoring data which has been used to quantify the  ecological
      impact.

      The State is sending information on the sites mentioned above.

      Problems are foreseen with risk based threshold levels, Mr.Cox is not
      confident that the human health risk levels will be protective of the
      environment.  He would like to see ground-water monitoring required even
      when sites are considered to pose no threat to human health.

      The State does not have a toxicologist to interpret ecological risk.
South Carolina -- Hartsill Truesdale

•     A hazardous waste landfill poses a potential ecological threat to a
      recreational lake adjacent to the site.   The potential threat is
      monitored with macroinvertebrate biomonitoring and fish bioassays.  Mr.
      Truesdale suggested contacting Russ Sherer for more.information on the
      biomonitoring program (Division Director of solid and hazardous waste
      Burro (803) 734-5296).
Kentucky -- Muhammad Alauddin

•     Safety Clean Corp in Ashland,  KY:   ground-water contamination poses a
      potential threat to surface water  - at present State is not conducting
      any biomonitoring or bioasssays.

•     A written request for information  of additional sites was sent August
      10, 1988.
Mississippi -- Sam Maberry

•     Information was provided on three Wood Treatment facilities:

      The first example Mr.  Maberry talked about was a SWMU's closure.  Fish
      kills have occurred in an adjacent surface water body.   PCP and  dioxin
      detected in surface water samples and fish tissue analysis  have  been
      linked to the wood treatment facility.   However,  it is  difficult  to
      assess which pathway is having the largest impact on surface water --
      the ground-water to surface water pathway or the runoff to surface water
      pathway.  The State has focused its attention on the threat to aquatic
      life rather than human health because  threshold values for PCP are
      lower for aquatic life than human health.   The State's  goal is to set
      soil concentration limits which will ensure that contaminant
      concentrations reaching the surface water body through  ground-water
      loading will not pose  a threat to aquatic life.   At present,  the  State

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                                     D-10

      has no means to predict the fate and transport of the PCP and dioxin in
      the contaminated soil.

      At the second site, surface water has been contaminated from a RCRA
      facility and a potential ecological threat exist.  An RFA conducted at
      the site identifies ground-water to surface water as a potential
      pathway.  However, the RFA focused on human health risk.   Because PCP is
      a greater threat to aquatic life than human health, the State would like
      to focus on the potential threat to aquatic life.  The problems and
      needs associated with this site are synonymous with the  first example
      discussed above.

      At the third site, ground-water monitoring has identified PCP
      concentrations in excess of Clean Water Act standards.  The State will
      attempt to tie this information into the SWMUs closure requirements.

      Texas Eastern Gas Pipeline Compression Station:  PCB contamination is
      documented at this site.  Terrestrial and aquatic animal tissue analysis
      has reveled PCB bioaccumulation.  Corrective action has been initiated
      at the site.  The company is required to undertake a risk assessment,
      however, the risk assessment will focus on human health only, because no
      guidelines exists for ecological risk assessment.
REGION V

Indiana  -- John Hayworth

•     One site: Four County Landfill

            Believes that many other sites are likely posing ecological
            threats, though is less certain about existence or availability of
            documentation;

            NFWS did a study on the Four County Landfill site; draft report
            was produced winter 1988 with ATSDR; major citizen outcry
            regarding site and many litigations ensuing; have not yet been
            able to obtain documentation from NFWS.

•     A Biological Studies Group has existed in the State office for about 20
      years - work has focused primarily around the water program (i.e.,
      identification of stream discharges & effects -- not necessarily RCRA).
      Contact person for this group is Lee Bridges (Chief, Biostandards
      Section (317) 243-5030); have not reached him to discuss available
      documentation.

•     No standard methodology has been established to examine ecorisks
      resulting from RCRA facilities.  Few or no studies have been done
      examining land-based ecological threat analysis or risk assessment --
      "easier to study a stream environment."

•     Money has not been designated for analyzing ecological aspects of risk
      assessment -- risk potential is often observed/identified during site

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                                     D-ll

      investigations, but "not going the next step (to evaluate and attempt to
      quantify threats)."
Ohio  -- Mike Savage

•     Didn't know of any sites offhand.  A letter was faxed to Mr. Savage
      (8/1) at his request outlining information we need; he plans to
      distribute it to appropriate staff, send any relevant documentation,
      including at least one sample RFI or incident-response.

      No standardized assessment criteria have yet been established for RCRA
      permitting, closure or inspection activities.

•     Ecorisk has little to no role in RCRA decision-making.

•     Recommended contacting the Division of Water Quality Management - they
      do some stream surveys, bioassays, monitoring.  DWQM is not exclusively
      RCRA.
REGION VI

Louisiana  -- Bill Molere

•     One facility: an incinerator (name unknown) for which an environmental
      risk assessment is being considered -- expected to involve dispersion
      modeling and fugitive emissions effects on nearby human health and
      wildlife.

•     No general or site-specific documentation available. There has been very
      little emphasis on ecorisk since most of the facilities requesting
      permits have been existing facilities, and thus the permitting staff has
      assumed that any species that have been coexisting with the facility
      until that point will continue to do so.  Apparently, if they were
      permitting a new facility, the facility would be forced to pay more
      attention to the surrounding areas and wildlife habitats -- new
      permitting standards will be "more stringent in all respects."

•     Unaware of any information contained in the RFAs and RFIs completed to
      date that would discuss ecorisk since no ecological assessments have
      been deemed necessary.

•     Recommends that we speak with Water Quality people - doing NPDES
      assessments.  (Water Pollution Control Division (504) 295-8904,
      Bruce Hammond - may have reports covering response activities for spills
      to surface waters).
Oklahoma  -- Robert Rabitane  (Environmental Program Administrator)

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                                     D-12

      No known or suspected incidences of ecorisk resulting from RCRA
      facilities.

      Although he's heard "rumblings" about evaluating ecorisks from the NPDES
      work groups, ecorisks have not really been an issue.   Documentation is
      therefore virtually nonexistent.

      Is aware of dangers with ecological threats and the effects of hazardous
      constituents on wildlife habitats,  etc..,  but sees ecorisk assessment as
      more of a wave of the future -- bioassays  may soon be more common, but
      now nothing is done.

      Recommended some other Regional contacts:  Karen Bond (Project Officer
      for the State RCRA program); Lorie  Burch (Permitting in Oklahoma).
REGION VII

Missouri  -- Frank DoIan

•     Schuykill Metals Corporation -- old releases from wastewater treatment
      to a creek (primarily lead);  also associated air releases.

•     Was reluctant to discuss site-specific or general ecorisk issues before
      confirming our right to the  information (e.g.  requested contract codes,
      project officers, etc.); was subsequently unavailable for an interview.
Kansas  -- John Mitchell

•     Ecological risks are not emphasized.  Identified no known sites or
      studies.

•     Feels that there is groundwater contamination to streams,  but no studies
      or assessments have been done or planned.

•     Any assessments from contaminant releases  would be human health-based.
REGION VIII

North Dakota -- Martin Shock

•     Degradation of ground water has been identified at a Gas Refinery in
      Wiliston, ND.  The site has under gone SWMU's closure and corrective
      action has been implemented to clean up the contaminated ground water.
      The ground water is hydrological connected to a surface water body and
      the contaminated plume poses a potential ecological threat.  However, at
      present the contaminant plume has been contained and contaminant loading
      to the surface water body has not occurred.  Cleanup target levels are
      currently set at background concentrations.  Mr. Shock does not believe

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                                     D-13

      that the new corrective action regulations will affect this site (new
      Subpart F regulations will set target levels based on human health
      risk).   North Dakota has a strict Ground-Water Protection Law that does
      not permit any ground-water degradation.   This ground-water protection
      law will continue to require cleanup to back ground concentrations even
      if Subpart F does not.
South Dakota -- Joel Smith

•     Identified no RCRA sites with known ecological threats.   However,  he
      suspects contaminants released from RCRA sites may have  contributed to
      ecological damage (i.e., degradation of surface water),  but any RCRA
      contaminant impact would generally be over shadowed by the impact  of
      surface water discharges.
Colorado -- Joan Sowinski

•     Identified two sites with potential ecological  threats:

            Martin Marietta
            Rocky Flats

•     Both ground water and air contamination have been identified.   A Draft
      permit has been prepared for both sites.   For additional  information Ms,
      Sowinski suggested contacting Greg Strakevum (303-331-4845).

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                                     D-14
REGION IX

California  -- Jan Smith,  Mary Misemer,  and Steve Baxter

•     Two facilities:

            BKK Landfill (Southern Cal., GW Contamination)
            Stringfellow (Entire unit of State office formed as a result of
            this  site)

            (Interviewees  were unsure of the extent of environmental or
            habitat degradation at these sites, but thought that environmental
            impacts assessments had been done.  They also felt confident that
            there were other sites of which they were unaware);

•     Site specific information is likely available from the Assessment and
      Mitigation Units of the four regional offices within the State.
      According to the Duty Officer in the Los Angeles regional office, any
      file retrieval or other assistance in obtaining or sending documentation
      would be a low priority task, and "would take many weeks."

•     RCRA site inspections include observations of vegetation and nearby
      animals, groundwater sampling, and occasional bioassays.

•     Ecological risks likely regulated primarily under California
      Environmental Quality Act (CEQA).   We received a pamphlet describing
      CEQA.

•     Attention is given to ecological threats under CEQA; interviewee felt
      that ecorisks were adequately addressed, and not neglected with respect
      to human health risks.

•     Recommended additional contacts:

                  Nestor Acedera - Unit Chief, Assessment and Mitigation Unit,
                  Los Angeles EPA office (Region 3 of California)
                  (213) 620-2380;

                  Jenny Lewis - Stringfellow Unit (916) 323-2978.

•     For other specific site info  - recommended speaking with the Technical
      Services Unit of Surveillance and Enforcement within each of the four
      Regional offices in the state:

                  1  Sacramento:   (916) 739-3374
                  2  Emeryville:   (415) 540-3347
                  3  Los Angeles:  (213) 620-2380
                  4  Long Beach:   (213) 590-5907

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                                     D-15
REGION X

Alaska -- Sam Hungerford

•     Ground-water contamination has occurred at two oil refineries - cleanup
      to background concentration is authorized by the State Oil Spill
      program.

•     Air emissions from an ammonia plant pose a potential ecological threat.
      Vegetation stress is suspected, however, there has been no attempt to
            provide any quantitative proof.

•     The State of Alaska is now in the process of adopting regulations for
      Siting Hazardous Waste Facilities.  The regulations will include
      criteria specifically aimed at protecting the environment.  These
      measurements include protection of sensitive environments (e.g.,
      critical habitat, National Wildlife refuge and wild and scenic rivers),
      and an analysis of the impact of expected maximum emission from the
      facility on fish, wildlife, water, visibility, vegetation and soils.
Washington -- Hugh O'Neill

•     The State makes use of a fish bioassay to predict potential ecological
      impacts from hazardous constituents.  Mr. O'Neill is sending the fish
      bioassay protocol and a list of sites where fish bioassay data has been
      used in regulatory decisions.

•     Fish delays (spawning salmon) have been observed in a stream adjacent to
      a RCRA facility.  The State believes that the salmon may be avoiding a
      polluted area.  The site is presently under investigation.

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                                     D-16

                       EPA REGIONAL INTERVIEW SUMMARIES

Region I -- George Furst, John Zipeto, Matt Hoaglund, Larry Brill, David Lim

•     Identified GE Pittsfield as a site with ecological impacts addressed in
      RCRA.  Facility is allegedly responsibly for PCBs in the Housatonic
      River.  Another possible site is a facility in Maine (possibly Pioneer
      Plastics) at which a bioassay with plant species has been conducted.

•     Documentation for GE Pittsfield is in the Region, but it makes a three
      to four foot long stack.  The site is still in the data collection stage
      of an ongoing enforcement action, with corrective action-type permitting
      in process.  Part of the information is in the RFI.

•     Identified Portsmouth Naval Shipyard as a site where ecological and/or
      biological monitoring may be required for permit application.

•     Region I has 8 to 10 RFI's underway -- none are completed other than a
      draft report from a Monsanto site (contains no ecological threat
      information).

•     A model corrective action order has been obtained from Mr. Furst.  This
      order was developed for the Saco Defense Inc. site in Saco, Maine.  Mr.
      Furst acknowledges that very scant attention is given to ecological
      threats in the order.  He would appreciate receiving comments on how
      ecological threat information might be better addressed in the order.

•     Methods used to assess ecological threats include a plant species
      bioassay and environmental assessment (similar to an endangerment
      assessment).

•     A major barrier to incorporating ecological threat information into RCRA
      decision making is the lack of adequate guidance in corrective action on
      this issue.

•     Non-site specific efforts related to ecorisk include:

                  Ecological Risk Work Group Issue Papers on RCRA, CERCLA, and
                  municipal and industrial landfills.  The group uses a
                  variation of the National Comparative Risk method - will not
                  rank threats to various ecosystems.  Copies of draft papers
                  obtained from Larry Brill, Region I.

                  Region X Comparative Risk Project Ecological Damages Plan of
                  Attack for Problems 13 through 17. Copy obtained from David
                  Lim, Region I.

                  ICF Incorporated Comparative Risk Project Ecological Risk
                  Assessment Methodologies.

•     Limited efforts to manage ecological risks have  included an attempt to
      prioritize the problems in each ecosystem within the Region to determine
      the  relative effects of RCRA waste sites on the  Region's ecosystems.

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                                     D-17
Region II -- Ellen Doring and Barry Tornick

•     Identified two sites with ecological threat studies and information:

            Union Carbide facility in the Caribbean:   discharge to a bay is
            potentially affecting endangered species;

            GE facility in Waterford, New York:   ACL petition.

•     Non-site-specific studies include the monitoring of fish in the Lower
      Hudson for an EIS of a proposal to landfill dredged sediments.  The
      relevance of this study to the RCRA portion of this action (permitting
      the landfill) is uncertain.

•     Methods used to assess ecological threats  include studies of body
      burdens in fish (and fish community structure?), use of ACL and other
      criteria in Subpart F and proposed Subpart S to  protect aquatic life,
      and bioassays of species related to endangered species.

•     A barrier to the use of ecological threat  information in RCRA is the
      infancy of the corrective action program.   Not much data is available
      yet.

•     Suggested contacts:     Marian Olson, Region II, Office of Policy and
                              Management.  Works on risk assessment policy
                              issues.  212-264-5682.

                              John Gorman,  Region II,  Project Manager for the
                              Caribbean facility.   212-264-9631.
Region III -- Jim Webb,  Jack Potosanak,  and Diane Schott

•     Referred by John Humphries,  Region III RCRA Section Chief,  for
      information regarding Aberdeen Proving Grounds.   Identified three areas
      of the Proving Grounds of potential interest to  this project:

            White Phosphorus Dump  Zone
            Canal Creek
            0 Field

•     We sent a letter to John Humphries requesting documentation regarding
      ecological studies and threats at  these three areas.

•     Ms. Schott suggested investigating reports  on the tar pit area,  which is
      seeping into a wetland,  of the Texaco land  treatment facility.   Contact
      is Wayne Thomas,  State of Delaware,  302-736-3824.

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                                     D-18

      Another potential site of interest is an Allentown, PA underground
      storage tank release site.

      No standard methods are used to characterize ecological threats.
      Ecorisk assessment effort has been limited.  Site-specific assessments
      are conducted at the discretion of individual permit writers.  No
      standard procedure or policy is in place to assess ecological threats at
      all sites.

      Special ecorisk-related efforts in the Region include the Regional
      Superfund Work Group.
Region IV -- Mickey Hartnett

•     Identified four sites of potential interest:

                  Plat Whit Corp, United Technology Division, West Palm Beach,
                  FL
                  Kennedy Space Center, FL
                  wood treatment facility (interviewee did not recall the name
                  at time of interview)
                  chemical plant, GA (possible Union Carbide)

•     Methods used to characterize ecological risk include:

                  Proximity to important/sensitive area
                  Key-species Biomonitoring (Adapted from a Water Program
                  Toxicity Test used for NPDES)
                  Fish Kill (example: widespread damage to river oyster beds)
                  Bioaccumulation in fish and wildlife (emphasis is placed on
                  the potential danger to human health from the consumption of
                  contaminated fish/wildlife)

•     These methods are  inadequate.  Regional staff are looking for guidance
      on how to assess ecological threat/damage.

•     Ecorisk management in the Region has generally been restricted to the
      ACL process.  In several instances ACLs were denied on the basis that
      proposed contaminant levels were potentially harmful to aquatic life.

•     Regional needs associated with ecorisk management include guidance in
      determining how to establish aquatic protection levels.

•     Special efforts in the Region include an adaptation of a Water Program
      Toxicity Test (a key-species biomonitor test used for NPDES discharge
      assessment) to assess potential ecological threat to surface waters.

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                                     D-19



Region V -- Joe Boyle and Jim Brossman

•     Identified two sites of potential interest:

                  Four County Landfill, Indiana
                  Ongoing study determining the need for corrective action.
                  Fish & Wildlife Service currently looking into site-related
                  ecological threats.  Interviewee unsure if any documentation
                  exists yet.

                  Another site mentioned (name unknown) in southern Illinois -
                  involved extensive lead contamination and resultant
                  ecological threats at a wetland.

•     Documentation of ecological impacts may be contained in permit
      applications and RFAs that have been completed under the permitting
      program -- primarily permit-seeking, but also for non-permit-seeking
      facilities.  These may have relevant information, but would depend on
      permit writer.  This documentation is probably available for inspection
      (appropriate contact for documentation availability is Augusta Bloom @
      (312) 886-4186).  Would be a "large undertaking" to have documents
      copied for us.

•     A couple of ongoing, non-RCRA site-specific Regional studies "may
      include a discussion of ecological threats":

                  Southeast Chicago Air Study
                  Northwest Indiana Grand Calumet River Basin Study

      Interviewee thought these were probably general studies,  not solely
      RCRA-oriented, and designed to cover a variety of stressors for certain
      geographic areas.  Some preliminary documentation/results may exist, but
      interviewee wasn't sure how to obtain copies.

•     Methods used to characterize ecological threats include:

                  Toxicity testing of exposed species
                  Interpolation from human health assessments

      No standardized method has yet been established

•     Interviewees think these methods and the effort committed to ecorisk
      characterization are inadequate.  Permitting process and RFAs "designed
      with no thought to ecological effects - problem essentially being
      overlooked."   At one site, the interviewee (Janis Perino, Illinois)
      stated that the ecological effects were "too big to deal with" (involved
      lead contamination at a wetland).  Technology exists to conduct far
      better studies at each site than current and previous efforts have
      allowed.

•     Ecorisk management may have entered corrective measures selection.
      Ecological threats were "probably considered" during the selection

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                                     D-20

      process of corrective action remedial alternatives.  Interviewees did not
      mention any specific barriers to the use of this information.

      Specific needs for the consideration of ecological threats include:

                  Update terrestrial ecorisk species data to a level
                  comparable to that of the aquatic species data;

                  Develop guidance for community descriptions (habitat
                  studies) to be conducted during site investigations;

                  Determine effects of mixtures of substances with regard to
                  exposure risks;

                  Resolve the "how clean is clean?" issue.

      Identified a State program in Illinois -- Ecotoxicology program set up
      within Illinois' DEP Office of Chemical Safety (headed by Janis Perino)
          as program in the Region emphasizing ecorisk.
Region VI --      Doug Ablen, Bernadette Yuhas,  Jim Sales, Mark Sides, and
                  Maria Daniels

•     Identified one site of potential interest:  surface impoundment
      releasing to surface water.  Enforcement action precludes release of
      details.

•     A special effort in the Region is the Environmental Priority Initiative
      -- a system used to prioritize regulatory attention at RCRA facilities.
      Includes identification of nearby sensitive populations and habitats.
      Uses information in RFAs (which contain little or no information on
      ecology and biology).

•     Ecological risk not commonly investigated.  Wildlife agencies are
      frequently consulted to determine nearby endangered/threatened species
      habitat.  Vegetative cover is observed during visual site inspection for
      RFA.

•     A barrier to the use ecorisk information is the lack of data
      collected/presented in RFAs.

•     Future efforts should emphasize the consideration of environmental
      threats as well as human health threats.
Region VII  --     Bob Stewart

•     Identified two sites of potential interest:

                  International Paper, Joplin, MO
                  NEIS Landfill, Furley, KS

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                                     D-21

      They rely on the ACL Guidance Document, Corrective Action Guidance, and
      the 1980 Federal Register notice on AWQC to incorporate ecorisk
      management into the RCRA program.

      In one instance of testing body burden in fish was used to characterize
      ecological threats.   This information of fish body burden was used to
      determine ground-water protection strategy.

      The primary barriers to the use of ecorisk information are inadequate
      knowledge of and inability to measure ecological effects, and the
      emphasis within RCRA on human health.

      The primary needs for improved ecorisk consideration are better guidance
      and making ecorisk a higher priority.
Region VIII --    Larry Wapensky and Lisa Reed

•     Identified a number of facilities of potential interest:

                  IRECO Chemical
                  Gary Petroleum Refining -- located on the Colorado River
                  near a rare fish habitat.
                  Highway 36 Facility --an intermittent pond collecting site
                  runoff.  Permit specifies that the runoff must not be
                  accessible to wildlife.
                  Moab UT hazardous waste incinerator -- public concerns
                  raised about effects of stack emissions on Colorado River.
                  Tooele County UT hazardous waste incinerator -- public
                  concerns raised about effects of stack emissions on antelope
                  habitat.
                  Other (unknown) site -- permit requires fence around
                  drainage ditch to keep cattle from drinking liquids seeping
                  from site.

•     Ecorisk characterization methods include the potential use of bioassays
      of stream water.

•     Ecorisk information may be used to determine permitting requirements.

•     The primary barrier to the use of ecorisk information in that the
      program does not support the use of risk analyses; it is only beginning
      to incorporate human health risk.
Region IX --      Karen Schwinn

•     No sites were identified.

•     No ecorisk characterization methods known.

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                                     D-22

      Interviewee stated that effort and methods applied to ecological
      assessments have thus far "intuitively been inadequate",  though no data
      were available to support this claim.
Region X --       Ken Feigner

•     Identified two facilities of potential interest:

                  Kalama Chemical Plant,  WA; and
                  ARCO Oil and Gas Facility, Alaska

•     Methods used to characterize ecological risk include aerial photographs
      to show vegetation damage.

•     The primary barriers to the use of ecorlsk information in RCRA are the
      emphasis on the protection of human health,  and inadequate guidance to
      assure protection from ecological risk.

•     EPA has initiated litigation for alleged violations ,at the Kalama
      Chemical Plant.  Aerial photographs showing vegetation stress will be
      presented as evidence.  However, emphasis will be placed on potential
      threat to human health rather than ecological damage.

•     A non-site-specific project of potential interest is the Dredge and Fill
      Program for the Corp of Engineering.  In this program criteria have been
      developed to assess potential ecological damage from deep water ocean
      dumping of dredged materials.  Contact in the Water Permit Section
      handling dredge/fill spoil for deep water disposal: Mr. Mochnick, 206-
      442-4817.

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            APPENDIX E

DETAILED SUMMARY OF RCRA SUBTITLE C
       FACILITY CASE STUDIES

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                                     E-2

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 1

Site Name:  Saco Defense,  Inc.
Location:   Saco, Maine                               Region:  1

Facility/Site Description

•     Saco Defense, Inc.  operates a weapons manufacturing facility that
      generates metal degreasing solvent,  waste coolants, chrome plating
      wastes, metal hydroxide sludges,  and chrome stripping salts.  This
      facility is comprised of twelve SWMUs including six landfills/lagoons,
      five waste storage  areas, and one wastewater treatment plant.
•     No information is available on the uses of neighboring land or the
      environmental setting of the plant.

RCRA Program Status

•     Saco Defense is party to a consent order with EPA Region 1 to conduct an
      RFI for this facility.  The consent order makes clear that significant
      environmental contamination exists at this facility.
•     This Consent Order  is used as the model order for Region 1.

Environmental Threats, Observed or Modeled

•     Ground water, soil,  surface water, and air may potentially be
      contaminated by 1,1-dichloroethane;  1,2-dichloroethane; 1,1-
      dichloroethene; 1,1,1-trichloroethane, and methylene  chloride..
•     Potentially contaminated biota include fish and vegetation.
•     Environmental contamination might potentially occur from seepage of
      hazardous constituents from landfills and lagoons to  ground water,
      overland flow to a  surface drainage channel and surface water, discharge
      to surface water from wastewater treatment facility,  and volatilization
      to the air.
•     The areal extent of the potential contamination is not specified.

Ecological Impacts, Observed or Modeled

•     No ecological impacts have been identified.  The consent order proposes
      an evaluation of environmental threats to include an  identification of
      nearby wildlife and sensitive areas,  and evaluation of indicator
      chemicals to be used in assessing environmental risks of estimated
      exposure point concentrations.

Use of Ecological Information

•     The proposed use of ecological threat information is  not evident in the
      consent order.

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                                     E-3

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 2

Site Name:  Wyman-Gordon
Location:   North Grafton, Massachusetts                    Region: 1

Facility/Site Description

•     The waste management area of concern at this facility is a treatment
      lagoon.
•     Ground-water flow from the lagoon area is towards a wetland that flows
      into a stream.
•     Human receptors and a fishery are sufficiently distant that the site
      presents no significant threat to them.

RCRA Program Status

•     Wyman-Gordon has submitted a Part B permit application for this
      facility.  This application includes an alternate concentration limit
      (ACL) petition.

Environmental Threats, Observed or Modeled

•     The wetlands, surface water, and ground water in the vicinity of this
      site are contaminated with arsenic, chromium, nickel, and high pH.
•     Contamination enters the environment by leaching from the lagoon to the
      ground water, migrating to springs in the wetland, and flowing into the
      stream.  (The presence of elevated levels of arsenic has not been
      conclusively linked to the lagoon).
•     3.5 acres are contaminated with elevated levels of arsenic; considerably
      smaller areas are contaminated with nickel and chromium.

Ecological Impacts, Observed or Modeled

•     Wetlands areas receiving leachate from the lagoon have been shown to be
      significantly stressed.  A comparative wetlands assessment of an area
      below the lagoon and one above it demonstrates decreased species
      diversity, decreased productivity, stunted growth, and altered life-
      cycles of the wetland vegetation downstream of the lagoon.  These
      effects have been correlated to high pH values in the degraded wetland.
•     The stream down gradient of the wetland was determined by a biological
      assessment to be healthy.

Use of Ecological Information

•     Information on the health of the wetlands and stream have been used to
      demonstrate that releases from the facility are mitigated by the wetland
      and cause no  damage to the stream.  Based on this reasoning, ACLs
      equivalent to the highest recorded contaminant concentrations are
      proposed in the permit application.
•     The wetlands  assessment recommends that the pH of the lagoon (and hence
      its leachate) be lowered to alleviate  the seep's effects on the
      wetlands.

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                                     E-4

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 3

Site Name:  Allied Chemical Baltimore Works
Location:   Baltimore,  Maryland                             Region: 3


Facility/Site Description

•     Allied Chemical operates this chrome plating facility that stores chrome
      ore tailings and other wastes meeting D007 listing requirements in
      indoor waste pile storage units.
•     This facility is located in an estuarine environment on the northwest
      branch of the Patapsco River near Baltimore's inner harbor.

RCRA Program Status

•     Region 3 is currently negotiating corrective measure selection and
      design with the owner/operator.  This facility has been investigated in
      a manner similar to a CERCLA remedial investigation.

Environmental Threats,  Observed or Modeled

•     Estuarine surface waters and sediments, on-site soil and groundwater are
      contaminated by chromium.  There is the potential for minor air
      contamination.
•     Contaminant releases enter the environment through the discharge of
      wastewater to the harbor and the use of chromite ore residue as a fill
      material in and around the harbor area.
•     17.3 acres of surface water are contaminated with chromium above the 50
      ug/L chronic effects level.

Ecological Impacts, Observed or Modeled

•     No acute effects of the contamination have been observed.
•     Blue crab and other benthic invertebrates have increased body burdens of
      chromium.
•     Areas of high chromium concentrations have low species diversity.
•     Potential impacts include chronic effects (especially to Neirus virens)
      of exposure to chromium levels above 50 ug/L, and the bioaccumulation of
      chromium in predatory fish.

Use of Ecological Information

•     The potential biological effects of high body burden of chromium are not
      discussed.

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                                     E-5

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 4

Site Name:  Defense General Supply Center (DGSC)
Location:   Chesterfield,  Virginia                          Region: 3


Facility/Site Description

•     DGSC is a 640 acre storage facility with landfills, open storage areas,
      a fire training area, and a vehicle maintenance area.
•     The surrounding land use is primarily single-family residential with a
      one-quarter mile wide wooded undeveloped area immediately down gradient
      from the site.  Two creeks border the facility and a number of wetland
      areas are present southeast of the site along Kingsland Creek.
•     Endangered species which may be found on this site include bald eagles,
      peregrine falcons, red-cockaded woodpeckers, and Delmarva fox squirrels.
      This site contains a 20-acre fenced area with a herd of five to seven
      elk and a pond which is stocked primarily with blue gill, large mouth
      bass, and catfish for recreational fishing.

RCRA Program Status

•     Areas of this facility are undergoing CERC1A remedial investigations and
      some of the waste management areas are operated under RCRA permits.
•     DGSC has recently requested a permit modification under HSWA to allow
      construction of a large waste handling building and is proposing field
      investigations to include bioassays and ecological assessments of
      surface waters.

Environmental Threats, Observed or Modeled

•     Soil, ground water,  and surface water are contaminated by metals (e.g.,
      copper, iron, mercury, and silver), acetone, and chlorinated organics.
•     Contamination is primarily the result of spills onto soil with
      subsequent transport to ground water and surface water.  Overland flow
      may introduce contaminants from the soil directly to surface waters.
•     Areal extent of contamination is not specified in the available
      documents.

Ecological Impacts, Observed or Modeled

•     A proposed field investigation will study potential ecological impacts
      of contaminant releases to the streams and wetlands.  This study will
      evaluate the species diversity and community structure of the wetlands
      and streams, and measure the toxicity of the surface waters with
      bioassays.

Use of Ecological Information

•     Although not explicitly stated, it is expected that the ecological
      information collected through the proposed field investigation will be
      used to assess the need for and extent of corrective measures.

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                                      E-6

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 5

Site Name:  Rohm and Haas Bristol Plant
Location:   Bristol, Pennsylvania                           Region: 3


Facility/Site Description

•     This is a chemical manufacturing plant with four distinct areas:  a
      landfill (contains 4,600 tons of hazardous waste), a manufacturing area,
      an ammonium sulfate storage area, and a trailer staging area.
•     The landfill area includes a wates treatment pond and borders the
      tidally-influenced Delaware River.  The landfill and pond are located in
      the 100-year floodplain.
•     This site encompasses over 120 acres of open woodland and marsh land.

RCRA Program Status

•     Undergoing Subpart S corrective action following investigation under
      CERCLA.

Environmental Threats, Observed or Modeled

•     Soils, ground water, surface water, and air are contaminated by bis(2-
      chloroethyl)ether, heptachlor epoxide, benzene, endosulfan, lindane,
      1,1,1-trichloroethane, and trichloroethene.
•     Potential release and exposure is by leaching from the landfill to
      ground water, surface runoff, or direct dumping.
•     The areal extent of contamination is not known.

Ecological Impacts, Observed or Modeled

•     Ecological investigations are ongoing.

Use of Ecological Information

•     Ecological investigations are ongoing.

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                                     E-7

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 6

Site Name:  Kennedy Space Center
Location:   Kennedy Space Center,  Florida                   Region: 4


Facility/Site Description

•     Kennedy Space Center operates a container storage facility.  Ground-
      water contamination at this  site is being cleaned up by an air stripping
      operation.
•     A proposed air stripper is located within Merritt Island Wildlife
      Refuge.
•     There are no residences within ten miles of the air stripping operation.

RCRA Program Status

•     The waste management area of Kennedy Space Center operates under a
      corrective action order.  The proposed air stripping operation at this
      facility is corrective measure developed as a voluntary corrective
      measure.

Environmental Threats,  Observed or Modeled

•     The ground water of the facility is contaminated with volatile organic
      compounds (VOCs)  -- primarily benzene, chlorobenzene,  and chloroform.
•     The air stripping operation introduces these contaminants to the ambient
      air of the wildlife refuge.
•     Wildlife on the refuge may be exposed to the airborne contaminants.
•     The areal extent of the contamination is not specified in the available
      documentation.

Ecological Impacts, Observed or Modeled

•     The potential effects of the air stripping operation on the wildlife of
      the refuge have not been investigated.
•     The potential impacts of ground-water contamination on the wildlife has
      apparently not been addressed.
•     A meeting between EPA, DOI,  and Kennedy Space Center personnel was
      recently held to discuss potential effects of the air stripping on
      wildlife.  No results of this meeting are yet available.

Use of Ecological Information

•     No ecological information has been collected.

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                                      E-8

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 7

Site Name:  Monroe Auto Equipment Plant
Location:   Hartwell, Georgia                               Region: 4


Facility/Site Description

•     This facility is an auto equipment manufacturing plant producing a
      variety of automotive parts.
•     There is no mention of sensitive areas or endangered species in the
      vicinity of the facility.
•     A pond located one-half mile northwest of the site is designated as a
      recreational water body (i.e.ป swimming, fishing, etc.)

RCRA Program Status

•     Applied for a RCRA permit to landfill sludge.  Undertaking corrective
      actions, comparable to Subpart S, under the supervision of the State of
      Georgia.

Environmental Threats, Observed or Modeled

•     The soil, ground water, and surface water are contaminated by oil,
      chlorinated alkanes and alkenes, aromatic hydrocarbons, and cadmium.
•     The air of the facility may potentially be contaminated by some of these
      volatile organic compounds.
•     Contamination apparently occurs by leaching and runoff from sludge
      landfilling operations.
•     The areal extent of the contamination is not specified.

Ecological Impacts, Observed or Modeled

•     Toxicity criteria are not exceeded for sensitive fish and plant species.
      Blue gills and fathead minnows are considered not to be affected by
      contaminant concentrations detected.  Contaminant concentrations are
      also believed to be too low to affect plant species.
•     No degradation of the biota was observed.

Use of Ecological Information

•     Ecological impacts were deemed insignificant, consequently no additional
      remedial action was undertaken.

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                                      E-9

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 8

Site Name:  Pratt and Whitney (United Technologies Corporation)
Location:   West Palm Beach, Florida                        Region:  4


Facility/Site Description

•     This 7000-acre facility contains one landfill, four burn pits, a
      recycling center, two waste piles, three incinerators, and many other
      storage areas and waste treatment units.
•     No information on the environmental setting of this facility is
      available in the available documentation.

RCRA Program Status

•     This facility is the subject of a corrective action consent agreement.
      A workplan for conducting an RFA has been submitted and deficiencies in
      the facility's Part B permit application have been outlined.

Environmental Threats, Observed or Modeled

•     The soils and canal sediments of this site are contaminated with PCBs,
      solvents, acid wastes, heavy metals, and VOCs.  PCB concentrations
      between 50 and 500 ppm have been observed.
•     The air, surface water, and groundwater of this site may be contaminated
      by these contaminants as well.
•     Contamination has resulted from spills, leaks, leaching, exhaust,
      discharge, and dumping.

Ecological Impacts, Observed or Modeled

•     No ecological impacts have been investigated.

Use of Ecological Information

•     No information available.

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                                     E-10

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 9

Site Name:  Southern Dye Company (SODYECO)
Location:   North Carolina                                  Region: 4


Facility/Site Description

•     Chemical manufacturing plant with unknown waste management operations.
•     The ground water below the site is hydrologically connected to the
      Catawba River.

RCRA Program Status

•     This facility has petitioned for alternate concentration limits (ACLs)
      for environmental concentrations of contaminants released from the
      facility.

Environmental Threats, Observed or Modeled

•     The ground water and surface water are contaminated with metals,
      chlorinated organics,  aromatic hydrocarbons,  and pesticides.
•     Contamination occurs through seepage to ground water and subsequent
      ground water discharge to surface water of Catawba River.
•     Areal extent of the contamination is not specified.

Ecological Impacts, Observed or Modeled

•     Catfish are contaminated but have only low body burdens of pollutants.
•     Observed contamination of environmental media is above background, but
      below threshold criteria.
•     There have been no investigations of ecosystem effects of the
      contamination or the studies of the toxicity of the surface water.
      Surface water toxicity may be important if pollutant effects are
      additive.

Use of Ecological Information

•     Proposed ACLs of 23 of 52 hazardous constituents are based on aquatic
      life criteria or fish toxicity test results.
•     ACLs denied on basis of improper hydrogeologic characterization.

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                                     E-ll

             RCRA SUBTITLE  C  ECORISK FACILITY CASE STUDY NUMBER 10

Site Name:  Southern Wood Piedmont Company
Location:   Baldwin, Florida                                Region: 4


Facility/Site Description

•     This facility is a wood treatment plant that discharges boiler blowdown,
      water softener backwash, and contaminated storm water runoff from an
      NPDES outfall.  The site also contains waste handling pits that have
      been dewatered and lined with plastic prior to the replacement of the
      sludge and covering with a clay cap.  The facility is adjacent to a
      tributary of Baldwin Bay that contains a wetlands area.

RCRA Program Status

•     This facility is proposing to determine alternate concentration limits
      (ACLs) based on toxicity testing results.

Environmenal Threats, Observed or Modeled

•     The ground water, surface water, and sediments of this site are
      contaminated with arsenic, chromium, and a variety of aromatic
      contaminants including phenol, cresols, toluene, pentachlorophenol,
      tetrachlorophenol, trichlorophenols, and other substituted phenols and
      cresols.
•     Contamination is the result of seepage from waste management pits to
      ground water and subsequent migration to surface water and downstream
      sediments.
•.     Areal extent of the contamination is not known.

Ecological Impacts, Observed or Modeled

•     The toxicity of environmental media (ground water and sediments) is
      being  investigated.  Preliminary results indicate that media down
      gradient from the site are somewhat toxic, but ground water from a
      control well up gradient from the waste management area was found to be
      the most toxic.

Use of Ecological Information

•     The bioassay  information collected  is intended to assist in the
      determination of ACLs  and action levels for releases from SWMUs under a
      HSWA permit.
•     The higher  toxicity of ground water from the control well greatly
      complicates this procedure.

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                                     E-12

            RCRA SUBTITLE  C ECORISK FACILITY  CASE  STUDY NUMBER 11

Site Name:  Union Carbide Agricultural Products Company, Inc.  (UCAPC)
Location:   Woodbine, Georgia                               Region: 4


Facility/Site Description

•     UCAPC is a chemical formulation and manufacturing plant containing a 20-
      acre landfill.   This landfill consists of two rectangular sites
      generally less  than fifteen feet deep.
•     The facility is located at an elevation of between 5 and 29 feet above
      MSL along the terraced coastline of Georgia.
•     Ground-water flow from the site is to the tidally influenced, brackish
      Todd Creek.   Although this creek borders the site, there is no apparent
      direct discharge to the creek.
•     Todd Creek is a tributary of the Satilla River within the St. Andrew's
      Estuary.  The estuary contains potential receptors such as shrimp, crab,
      oysters, fish,  and aquatic and wetland vegetation.

RCRA Program Status

•     Union Carbide has petitioned for and been denied alternate concentration
      limits (ACLs) for contamination at the facility's compliance point.  The
      State of Georgia has decided not to consider any discharge of toxic
      contaminants until such time as all environmental stressors in the area
      have been identified.

Environmental Threats, Observed or Modeled

•     The ground water, soil and surface waters of this site are contaminated
      with metals,  chlorinated organics, aromatics, and pesticides.
•     These contaminants enter the environment after leaching from the
      landfill to the ground water and soil, migrating with the ground water
      approximately 200 feet to Todd Creek, and dispersing throughout the
      estuary.
•     Biological receptors may be exposed to the contaminants by burrowing
      into contaminated soil,  dermal contact and ingestion with contaminated
      sediments, and  immersion in the contaminated surface waters.
•     Areal extent of contamination has not been determined; the distance from
      the site to the mouth of the estuary is  approximately four miles.

Ecological Impacts, Observed or Modeled

•     100 percent oyster mortality has been observed in the estuary in the
      vicinity of the site (this mortality is  not conclusively associated with
      the site).
•     Potential exposure of gopher tortoises (protected), indigo snakes
      (protected),  29 species  of fish, seven species of crab,  three species of
      gastropod, four species  of bivalve,  and  four  species of shrimp may cause
      acute and chronic effects.

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                                     E-13

      RCRA  SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 11  (continued)

Use of Ecological Information

•     Ecological information provided the primary impetus  for the denial of
      the ACL petition submitted for the  facility.   Georgia's Environmental
      Protection Division has stated that adequate  demonstration has not been
      made that proposed ACLs would be protective of larval and juvenile
      crustaceans and fin fish or non-motile organisms such as oysters and
      clams.
•     Detection limits for ten of the 22  hazardous  constituents exceed the
      proposed ACLs making verification impossible  and complicating the use of
      ecologically protective environmental concentrations.
•     The contribution of other sources in the area relative to the landfill
      needs to be evaluated.

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                                     E-14

            RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 12

Site Name:  Koppers Company, Inc.
Location:   Superior, Wisconsin                             Region: 5


Facility/Site Description

•     This is a 112-acre wood treating facility.  This facility contains a
      spray irrigation field for disposal of treated wastewater, surface
      impoundments, settling ponds, and a drum storage area.  The facility
      also stores treated and untreated wood products.

RCRA Program Status

•     An RFA has been completed at this facility.  The RFA recommends certain
      areas or SWMUs to be more closely inspected during an RFI.

Environmental Threats, Observed or Modeled

•     On site and nearby off site soils are contaminated from wood treating
      operations.
•     Two outfalls (treated wastewater discharge points) that drain to a creek
      are also contaminated.
•     Areal extent of contamination not specified.

Ecological Impacts, Observed or Modeled

•     One area of "very sparse vegetation" has been observed, otherwise the
      RFA does not indicate potential ecological impacts.

Use of Ecological Information

•     No information available.

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                                     E-15

            RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 13

Site Name:  International Paper Company Treated Wood Products Plant
Location:   Joplin, Missouri                                Region: 7


Facility/Site Description

•     This is a wood treatment facility with waste management areas including
      ponds, surface impoundments,  and landfills.
•     Silver Creek, near the facility, receives ground water from below the
      site.

RCRA Program Status

•     International Paper has submitted proposed alternate concentration
      limits (ACLs) for site-related hazardous  constituents migrating off
      site.

Environmental Threats, Observed or  Modeled

•     The ground water under the site and the surface water of Silver Creek
      may be contaminated with creosote compounds  and inorganics such as
      barium,  beryllium, nickel, copper, vanadium,  and zinc.
•     These contaminants may enter  the environment by leaching from the waste
      management areas to the ground water where they migrate to the surface
      water.
•     No information on the  areal extent of the contamination is available.

Ecological Impacts, Observed or Modeled

•     Potential ecological impacts  are not specified for exposures at the
      site.

Use of Ecological Information

•     Acceptable exposure levels and alternative concentration limits for four
      contaminants are based on criteria protective of aquatic life.

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                                     E-16

             RCRA SUBTITLE C ECORISK FACILITY CASE STUDY NUMBER 14

Site Name:  National Industrial Environmental Services  (NIES)
Location:   Furley, Kansas                                  Region: 7


Facility/Site Description

•     NIES operates this 80-acre site as a hazardous waste treatment and
      disposal facility.  Waste management areas at the facility include
      treatment ponds, evaporation ponds, and land disposal cells.
•     The sparsely populated area surrounding the facility consists primarily
      of farmland interspersed with oil wells.
•     Prairie Creek flows through NIES land north of the facility boundary.  A
      small intermittent drainage channel comes within 1000 feet of the
      northeast corner of the facility.  There are several ponds near the
      facility's eastern boundary.
•     Ground water in one of two distinct water bearing zones below the
      facility flows to springs of Prairie Creek.

RCRA Program Status

•     NIES has entered into a consent agreement and consent order under RCRA
      and a consent order under CERCLA.  In this agreement NIES is required to
      establish alternate concentration limits (ACLs) for certain ground-water
      constituents.

Environmental Threats, Observed or Modeled

•     The surface water and ground water in the vicinity of the site are
      contaminated with volatile organic compounds (VOCs), beryllium,  chromium
      (VI), phthalates, cadmium, and mercury.
•     Contamination enters the environment by leaching to ground water,
      flowing along solution pathways to the spring, and entering Prairie
      Creek.
•     The areal extent of the contamination is not specified.

Ecological Impacts, Observed or Modeled

•     Fish in Prairie Creek are contaminated.  Bioconcentration of DDE,
      chlordane, cadmium, mercury, and VOCs has been observed.
•     No stress of macroinvertebrates is apparent and the fish appear to be in
      good health.
•     Threshold criteria protective of aquatic life are not exceeded in the
      stream.

Use of Ecological Information

•     ACLs for seventeen of 35 hazardous constituents are based on aquatic
      life protection criteria.
•     Although no actual/expected receptors are present at the exposure point,
      conservatism requires the assumption of their presence.

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                                     E-17

             RCRA SUBTITLE  C ECORISK FACILITY CASE  STUDY NUMBER 15

Site Name:  IRECO Chemicals
Location:   Tooele County,  Utah                             Region: 8


Facility/Site Description

•     IRECO operates this site as an explosives testing and disposal area.
•     Detonation occurs in a quarry in a remote, sparsely populated area.
•     The quarry and the surrounding area are known breeding and wintering
      grounds for numerous species of raptors, including golden eagles, great
      horned owls, prairie falcons,  red-tailed hawks,  and ferruginous hawks.

RCRA Program Status

•     IRECO has submitted an application for a RCRA permit and has signed a
      compliance order to dispose of explosive wastes at this site by
      detonation.  As a requirement of the compliance order, the U.S. Fish and
      Wildlife Service has studied the effects of explosive detonation for
      testing and disposal on the breeding and nesting behavior or raptors and
      ravens in the vicinity of the site.

Environmental Threats, Observed or Modeled

•     No releases of hazardous contaminants have been observed or are expected
      at this facility.  The environmental threat posed by this site is
      associated with the atmospheric disturbance caused by the detonation.

Ecological Impacts, Observed or Modeled

•     The U.S. Fish and Wildlife Service study of raptor and raven behavior
      indicates that these birds were able to .successfully breed, nest, and
      raise and fledge young in the vicinity of the detonation site.
      Historical nest sites in the quarry are no longer used, so some
      displacement of nesting may have occurred, but a number of nests were
      identified and observed within 1.6 miles of the quarry.
•     The U.S. Fish and Wildlife Service has identified the possibility of
      direct, acute effects (e.g., death and deafening) of small birds and
      mammals living within the quarry, but these potential effects have not
      been studied.

Use of Ecological Information

•     The ecological information obtained from the study of raptor and raven
      behavior supports recommendations by the Fish and Wildlife Service to
      schedule explosive testing and disposal so as to minimize disturbances
      to the nesting wildlife in the vicinity of the quarry.
•     This information might influence the practice of explosive disposal at
      the site, but, since EPA has no jurisdiction over the testing of
      explosives, may not prevent disturbances to wildlife by testing
      practices.

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                                     E-18

             RCRA SUBTITLE C ECORISK FACILITY  CASE  STUDY NUMBER 16

Site Name:  ARCO Prudhoe Bay Unit - Eastern Operating Area
Location:   Prudhoe Bay, Alaska                             Region: 10


Facility/Site Description

•     ARCO operates this 192-square mile area of the Prudhoe Bay Unit for oil
      exploration, production, and development.  The area contains a number of
      landfills, surface impoundments, container storage areas, tanks, waste
      piles, a recycling unit, and incinerators.
•     This area is tundra with many small lakes.  Much of the surface area is
      water-saturated during summer.  Vegetation in the area includes sedges,
      grasses, mosses, lichens, and few flowering plants and low shrubs.  The
      vegetative mat is eighteen inches thick and overlays permafrost.

RCRA Program Status

•     An RFA has been conducted for this facility.   RFIs of drilling fluid
      reserve pits and some other pits are suggested in the RFA.

Environmental Threats, Observed or Modeled

•     The surface water, soil, and tundra vegetation of the area are
      potentially contaminated by oily debris and drilling muds containing
      constituents such as arsenic, barium, cadmium, chromium,  lead, nickel,
      benzene, toluene, naphthalene, and fluoranthrene.
•     Contamination might arise through direct discharge of pit contents to
      the tundra surface, road and gravel pad application of waste liquids,
      and seepage from pits.
•     No estimate of the areal extent of the potential contamination is
      provided.

Ecological Impacts, Observed or Modeled

•     Potential ecological impacts include the bioaccumulation of hazardous
      constituents from permitted and other discharges.

Use of Ecological Information

•     No ecological information collected.

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                 APPENDIX  F
CONSTITUENTS IDENTIFIED IN RCRA PROGRAM AREAS

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                                      F-2

                            Subtitle C Case Studies
Inorganic Constituents

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Copper
Cyanide
Iron
Lead
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Strontium
Thallium
Vanadium
Zinc
Organic Constituents

l.l'oxybis-2-
  chloroethane
l.l'oxybis-3-
  chloropropane
1,1,1-Trichloroethane
1,1,2 Trichlorethane
1,1,2,2-
  Tetrachloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethane
1,2-trans-
  dichloroe thene
1,4-dioxane
IH-phenalene
2,2'oxybis-
  chloropropane
2,3-dimethyl-
  naphthalene
2,4,5-T
2,4-D
2-ethyInaphthaiene
2-methyl naphthalene
Acenaphthene
Acenaphthylene
Acetone
Acetophenone
Acrolein
Acrylonitrile
Aldicarb
Aldrin
Aniline
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benz o fluoranthene s
Benzoperylenes
BHC
Biphenyl
Bis (2-chlorethyl)
  ether
Bis-2 -chloroisopropyl
  ether
Bromodichloromethane
Bromome thane
Radionuclides

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                                      F-3

                            Subtitle  G Case  Studies  (continued)


Organic Constituents        Organic Constituents        Radionuclides

                            Carbazole
                            Carbon tetrachloride
                            Carbon disulfide
                            Chlorethyl ether
                            Chlorobenzene
                            Chloroethane
                            Chloroethene
                            Chloroethoxyethano1
                            Chloroform
                            Chioromethane
                            Chloromethylbutane
                            Chlorophenol
                            Chrysene
                            Cresols
                            DDE
                            Diaminotoluene
                            Dibenzo(a,h)anthracene
                            Dibenzofuran
                            Dichlorobenzenes
                            Dichlorobenzidenes
                            Dichloromethane
                            Dichloropropane
                            Dichloropropene
                            Dieldrin
                            Dimethyl naphthalene
                            Dimethyl phenols
                            Dinitrobenzenes
                            Dinitrocresol
                            Dinitrophenols
                            Endosulfans
                            Endrin
                            Ethylbenzene
                            Flourene
                            Fluoranthene
                            Fluorene
                            Freon
                            Heptachlor epoxide
                            Heptachlor
                            Hexachlorobutadiene
                            Hexachloroethane
                            Hexane
                            Indopyrenes
                            Isophorone
                            Lindane
                            Maleic hydrazine

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                                     F-4

                     Subtitle C Case Studies  (continued)


Organic Constituents        Organic Constituents        Radionuclides

                            Methacrylonitrile
                            Methyl naphthalene
                            Methyl indene
                            Methyl ethyl benzene
                            Methyl flourene
                            Methyl styrene
                            Methyl ethyl ketone
                            Methylene chloride
                            Methyl phenanthrene
                            Methylpropyl benzene
                            Methyl pyrene
                            Naphthalene
                            Nicotinic acid
                            Nitrophenols
                            Nitrosodiphenylamines
                            Nitrosomorpholines
                            Oil
                            PCBs
                            Pentachloroethane
                            Pentachlorophenol
                            Phenanthrene
                            Phenol
                            Phenyl naphthalene
                            Phthalates
                            Propenyl benzene
                            Pyrene
                            p-benzoquinone
                            p-chloroaniline
                            p-Chloro-m-cresol
                            Styrene
                            Tetrachlorobenzene
                            Te trachloroe thene
                            Tetrachloroethylene
                            Tetrachlorophenols
                            Tetraethylpyrophos-
                              phate
                            Tetralin
                            Te trame thyIbenz ene
                            Thiourea
                            Toluene
                            Tribromomethane
                            Trichloroethene
                            Tr ichloro fluorome thene
                            Trichlorophenols
                            Trichloropropane

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                                      F-5

                            Subtitle  C Case  Studies  (continued)


Organic Constituents        Organic Constituents        Radionuclides

                            Vinyl chloride
                            Xylene

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                                      F-6

                            Subtitle D Case Studies
Inorganic Constituents

Aluminum
Ammonia
Antimony
Barium
Chloride
Iron
Manganese
Nickel
Nitrate
Nitrite
Phosphate
Sodium
Sulfate
Thallium
Zinc

Organic Constituents

1,2-Dichloroethane
1-Butanol
2-Propenol
Acetone
Dichloromethane
Methyl Ethyl Ketone
PhenolRadionuclides

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                                     F-7

                                    Mining


Inorganic Constituents      Organic Constituents        Radionuclides

Aluminum
Antimony
Arsenic
Barium Chloride
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Cyanide
Fluorine
Gold
Hexavalent chromium
Indium
Iron
Iron hydroxide
Lead
Manganese
Mercury
Molybdenum
Nickel
Nitrate
Radium
Selenium
Silver
Sulfate
Uranium
Vanadium
Zinc

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                                      F-8

                           Oil and Gas Constituents


Inorganic Constituents      Organic Constituents        Radionuclides

Aluminum                    Anthracene                  Radium
Antimony                    Benzo-pyrene                Strontium
Arsenic                     Biphenyls
Barium                      Chrysene
Benzene                     Decane
Borite                      Dodecane
Boron                       Fluoranthene
Cadmium                     Hexadecane
Calcium chloride            Naphthalenes
Calcium                     Octadecane
Chloride                    Perylene
Chromimium                  Pyrene
Copper                      Tetradecane
Fluoride
Hydrogen sulfide
Iron
Lead
Lithium
Magnesium
Manganese
Mercury
Methane
Nickel
Potassium
Silicon
Silver
Sodium
Sulfates
Zinc

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                                      F-9

                                 Coal Utility


Inorganic Constituents      Organic Constituents        Radionuclides

Aluminum
Ammonium
Arsenic
Boron
Cadmium
Calcium
Chloride
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphate
Phosphorous
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfate
Sulfate
Sulfite
IDS  (total  dissolved
solids)
Thallium
Titanium
Vanadium
Zinc

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                                     F-10

                      Smelting and Refining Constituents


Inorganic Constituents      Organic Constituents        Radionuclides

Aluminum                    Tetrachloroethene
Arsenic                     Trichloroethene
Barium
Cadmium
Copper
Cryolite
Cyanide
Fluoride
Lead
Manganese
Mercury
Nitrate
Selenium
Silver
Zinc

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