6970
FISCAL YEAR 1990
RECORD OF DECISION
FORUM
REGIONAL PACKAGE
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
OFFICE OF WASTE PROGRAMS ENFORCEMENT
401 M STREET S.W.
WASHINGTON, D.C. 20460
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FISCAL YEAR 1990
RECORD OF DECISION
FORUM
REGION V
MAY 17, 1990
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, II 60604-3590
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
OFFICE OF WASTE PROGRAMS ENFORCEMENT
401 M STREET S.W.
WASHINGTON, D.C. 20460
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JS .Cab^W
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FY'9O HDD Ftarum Agertia
Overview of Final NCP 9:00 - 10:00
FY'90 ROD Ttaols 10:30 - 11:30
Presentation of ROD Tools
o Compendium of Good ROD Examples
o Revised ROD-related Short Sheets
- RODs
- Proposed Plans
- Special RODs (No Action, Interim Action, Contingency)
o Selection of Remedy Short Sheet
o ROD and Proposed Plan Checklists (Handout)
Ground Water ROD Language
Role of the Baseline Risk Assessment
Lard Disc>as3a Restri>:t:vjre IV.Jate 1,1; 30 - i?;00
Discussion with Regional Manaaars 1:00 - 3:00
Region-specific ROD Issues
LDR ROD Analysis Results
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TABLE OF CONTENTS
I. NATIONAL CONTINGENCY PLAN
a. Overview of the NCP
b. NCP Questions and Answers
c. NCP Outline (Region X)
II. FY'89 ROD ANALYSIS
a. Overview of FY'89 ROD Analysis Results
1. National Findings
2. Regional Findings
III. FY'90 TOOLS
a. Compendium of Examples From FY'89 RODs
1. Declaration
2. Site Description, Site History,
Community Relations
3. Scope and Role of Operable Unit
4 . Summary of Site Characteristics
5. Summary of Site Risks
6. Description of Alternatives
7. Comparative Analysis
8. Selected Remedy
9. Statutory Determinations
10. Responsiveness Summary
11. State Letter of Concurrence
b. ROD Short Sheets
1. Record of Decision
2. Proposed Plan
3. Special RODs (Draft)
c. Selection of Remedy Short Sheet
d. ROD and Proposed Plan Checklists
e. Overview of Ground Water Extraction Remedies
f . Ground Water Directive
g. Role of Baseline Risk Assessment
h. Exposure Assumptions
IV. LAND DISPOSAL RESTRICTIONS
a. LDR Update
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
February 1990
QUESTIONS AND ANSWERS REGARDING THE 1990 NCP
INTRODUCTION
What is the National Contingency Plan (NCP)?
o The NCP is the major framework regulation for the federal
hazardous substance response program. The NCP includes
procedures and standards for how EPA, other federal
agencies, states, and private parties respond under the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) to releases of hazardous substances
and under the Clean Water Act to discharges of oil.
What is the purpose of the revisions to the NCP?
o CERCLA, originally enacted in 1980, was amended by the
Superfund Amendments and Reauthorization Act of 1986
(SARA), which mandates that the NCP be revised to implement
the requirements of SARA, particularly with regard to
procedures and standards for remedial actions.
o The revisions also clarify 1985 NCP language, reorganize the
1985 NCP to describe more accurately the sequence of
response actions, and incorporate changes based on program
experience since the 1985 revisions to the NCP.
What is the relationship between the revised NCP and the
Management Review of tne Superfund Program (the 90-day Study)?
o The 1990 (or final) NCP is consistent with, and embodies the
spirit of, the 1989 Management Review of the Superfund
Program. Both documents describe what the program
realistically can accomplish and emphasize the need for
taking action — rather than prolonged investigation and
analysis — at sites. The documents also recognize the
importance of increased state participation and public
involvement in the Superfund program. The documents differ
in that the Management Review focused on EFA's internal
management of the program and left certain national policy
decisions, e.g., the process of deciding on cleanups, to be
addressed in the NCP. EPA believes that together the 1990
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NCP and the Management Review provide a firm basis for
progress in cleaning up the nation's worst toxic waste
problems.
What are the major areas of change from the 1985 NCP to the 1990
NCP?
Note; More detail on each of these major changes is provided
below.
o Subpart E (Subpart F in the 1985 NCP) which addresses the
elements of hazardous substance response is significantly
revised. EPA's process implements the requirements of
CERCLA 121 and focuses on selection of treatment
technologies, uses nine specified criteria when evaluating
and selecting remedies, provides for conducting early
actions, and encourages streamlining of remedial activities.
o Subpart F on state involvement is a new subpart added to
implement the 1986 statutory mandate to promulgate
regulations for substantial and meaningful state involvement
in CERCLA response actions. The major new concepts are
Superfund Memoranda of Agreement (SMOAs) between EPA regions
and states and EPA/state concurrence in remedy selection.
o Sxlbpart I is a new subpart added to implement the 1986
statutory requirements for the establishment of an
administrative record. The record contains documents that
form the basis for the selection of a remedy at a CERCLA
site.
What sections from the 1985 NCP have generally remained unchanged?
o Subpart A, the introduction, defines key terms
and states the purpose, authority, applicability,
and scope of the NCP. Some definitions have been added,
e.g., "source control maintenance measures," and some
definitions have been revised, e.g. "CERCLIS" and
"cooperative agreement," but most definitions remain
unchanged.
o Subpart B describes the organization and responsibility of
federal agencies regarding response activities. For
example, roles and responsibilities of the National
Response Team (NRT) and the Regional Response Teams (RRT)
are described. The revised Subpart B combines the 1985
NCP's Subparts B and C without major revisions.
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o Subpart C addresses preparedness activities,
federal and regional contingency plans, and planning
responsibilities of state and local agencies. The revised
Subpart C contains information from the 1985 NCP's Subpart D
and adds information on SARA Title III.
o Subpart D sets forth the phases of response to discharges
of oil and contains no major revisions from the 1985 NCP.
o Subpart G contains the designations of federal trustees to
act on behalf of the President in assessing damages to
natural resources from discharges of oil or releases of
hazardous substances. Subpart G also outlines in general
the responsibilities of trustees under the NCP.
o Subpart H is a new subpart that consolidates 1985 NCP
language on participation by other persons in response
activities and recovery of their costs. Persons conducting
a cleanup may recover their costs from a party liable under
CERCLA 107 if they substantially comply with requirements
of the NCP and conduct a "CERCLA-quality cleanup."
o Subpart J on use of dispersants for oil spills is similar to
the 1985 NCP's Subpart H; only minor clarifying revisions
have been made.
Why was the NCP on a court-ordered schedule?
o In the fall of 1988, the Natural Resources Defense
Council and several other national environmental groups
sued EPA for failure to meet the statutory deadline
(April 17, 1988) for revising the NCP. EPA's response
indicated that because of the magnitude of the project,
the number of interests involved, and the Agency's
efforts to achieve consensus among all parties, the
process was taking longer than anticipated to complete.
To resolve the litigation, the parties agreed to a
schedule for completion of revisions to the NCP that
would result in the delivery of the 1990 NCP to the
Federal Register by February 5, 1990.
How does the Hazard Ranking System (HRS) relate to the NCP?
o The HRS is Appendix A to the NCP (40 CFR Part 300). The
HRS is the mechanism used to evaluate whether releases
should be listed on the National Priorities List (NPL).
The NPL is a list of releases that appear to warrant
long-term evaluation and response. EPA proposed
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revisions to the HRS in a separate rulemaking on
December 23, 1988 (53 FR 51962).
What are some of the common abbreviations used in the NCP?
ARARs — Applicable or relevant and appropriate
requirements.
FS — Feasibility study.
HRS — Hazard Ranking System.
NPL — National Priorities List.
OSC — On-scene coordinator.
O&M — Operation and maintenance.
PRP — Potentially responsible party.
RA -- Remedial action.
RD — Remedial design.
RI — Remedial investigation.
ROD — Record of decision.
RPM — Remedial project manager.
SMOA — Superfund Memorandum of Agreement.
TBC — Criteria, advisories or guidance to-be-considered.
REMOVAL PROGRAM
How is the removal program modified under the 1990 NCP?
o The NCP codifies the increase in the statutory time and
dollar limits for Fund-financed removal actions from 6
months and $1 million to 12 months and $2 million.
o The NCP also codifies a statutory exemption from these
limits: where continued response is otherwise appropriate
and consistent with the remedial action to be taken. EPA
expects to use the exemption primarily for proposed and
final NPL sites, and only rarely for non-NPL sites.
o The NCP confirms EPA's policy that removal actions will
comply to the extent practicable with applicable or
relevant and appropriate requirements under other federal or
state environmental laws
o Requirements relating to community relations and
administrative record are discussed in other sections
below.
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PKMFDTAL PROGRAM
What changes does the 1990 NCP make in the remedial response
program?
o The final rule implements the statutory requirements to
select remedies that:
Protect human health and the environment.
Comply with applicable or relevant and appropriate
requirements (ARARs) under federal environmental or
state environmental or facility siting laws (or invoke a
waiver).
— Are cost-effective.
Use permanent solutions and treatment to the maximum
extent practicable.
— Satisfy the preference for remedies in which treatment
that permanently reduces the toxicity, mobility, or
volume of hazardous substances, pollutants, or
contaminants is a principal element.
What are some of the features of the final remedy selection
process?
o In the remedy selection process, a range of alternatives
should be developed, representing distinct, viable
approaches to managing the site problem. For source control
response actions, a range of alternatives involving
treatment as a principal element should be included, as well
as containment and no-action alternatives, as appropriate.
For ground-water response actions, alternatives should be
developed that restore usable ground water to beneficial
uses within a timeframe that is reasonable given particular
site circumstances.
o When selecting the preferred approach, the following nine
criteria are used to compare relative advantages and
disadvantages of the alternatives under consideration:
Threshold
1. Overall protection of human health and the
environment.
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2. Compliance with applicable or relevant and
appropriate requirements (or invoke a waiver).
Balancing
3. Long-term effectiveness and permanence.
4. Reduction of toxicity, mobility, or volume through
treatment.
5. Short-term effectiveness (e.g., environmental impacts of
the cleanup itself).
6. Implementability (e.g., whether technology being
considered is available within the necessary timeframe).
7. Cost.
Modifying
8. State acceptance.
9. Community acceptance.
How does EPA intend that these categories of criteria be used?
o An alternative must meet the threshold criteria in order to
be selected; these requirements are taken directly from
CERCLA and cannot be compromised.
o The balancing and modifying criteria were developed to
encompass other CERCLA requirements. One requirement is to
use permanent solutions and treatment to the maximum extent
practicable. By including practicability, Congress appeared
to acknowledge that not all of the waste at a site may be
treated and that judgments would be required on whether or
to what extent permanent solutions and treatment would be
used (and the extent to which waste is left on-site). EPA
believes that these judgments are dependent upon site
conditions and technological, economic and implementation
constraints. By evaluating and comparing the alternatives
by means of the balancing and modifying criteria, the
decision-maker can make the site-specific judgments
necessary to select the most appropriate approach.
o State and community concerns, encompassed by the modifying
criteria, generally are considered in altering an otherwise
viable approach rather than in deciding between very
different approaches, e.g., treatment versus containment.
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How does this process differ from the process outlined in the
proposed NCP?
o The 1990 NCP process has been revised from what was
proposed in order to encourage selection of more treatment
remedies (and to comply with the CERCLA preference for
remedies that employ treatment as a principal element). The
two criteria of "long-term effectiveness and permanence" and
"reduction of toxicity, mobility or volume through
treatment" are given the most weight in the balancing
process.
o Also, the threshold, balancing, and modifying labels have
been removed from the discussion of the nine evaluation
criteria during the detailed analysis of alternatives.
During the detailed analysis, each alternative approach
should be evaluated using each of the nine criteria, without
assigning greater weight to any of the criteria. The
categories of criteria are now part of the remedy selection
step.
What is the meaning of a "bias for action" stated in the NCP?
o Bias for action means that actions should be taken, as
early as possible, when necessary or appropriate to achieve
significant risk reduction quickly, when phased analysis and
response is necessary or appropriate given the size or
complexity of the site, or to expedite the completion of
total site cleanup.
What is "streamlining?"
o Streamlining means tailoring site-specific data needs, the
evaluation of alternatives, and the documentation of the
selected remedy to reflect the scope and complexity of the
specific site problems being addressed. For example, a
streamlined RI/FS can be used when site problems are
straightforward such that it would be inappropriate to
develop a full range of alternatives.
To what extent does EPA intend to clean up ground water?
o The goal of EPA's Superfund ground-water approach is to
return usable ground waters to their beneficial uses within
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a timeframe that is reasonable, given the circumstances at
the site.
o EPA intends to restore contaminated ground water that is a
current or potential source of drinking water to levels that
are safe for drinking. EPA intends to attain such levels
throughout the contaminated plume, except directly below any
waste that is left in place.
What is a "risk range" and how does it relate to selection of
remedial actions?
o Contaminants that are considered carcinogenic are thought to
pose a risk at any level of exposure. This risk may be
small or large depending on the amount and duration of
exposure and the type of carcinogen involved. When
Superfund cannot entirely eliminate potential exposure to a
carcinogen, it determines that a remedy protects human
health when the amount of exposure is reduced so that the
risk is very small, i.e., at an acceptable level.
o The 1990 NCP states that generally acceptable levels fall
within a range of 10~4 to 10~^. This means that an
acceptable exposure is when the excess risk to an individual
of contracting cancer due to a lifetime exposure to a
certain concentration of a carcinogen falls between 10~4 to
10"6.
o The proposed revisions to the NCP had included a risk range
of 10~4 to 10~7. The risk range for Superfund cleanups
included in the final rule is consistent with the accepted
de minimis level used by other EPA programs and other
federal agencies. It also reflects currently available
analytical and detection techniques.
o The point of departure when using the risk range is 10~6.
The point of departure is the starting point for acceptable
exposure levels when analyzing various approaches to
cleaning up a site. This 10~° risk level may be revised
based on exposure, uncertainty, or technical factors.
What actions are interpreted to fall under the 10-year provision
regarding the remediation of ground water?
o CERCLA section 104(c)(6) defines remedial action to include
the operation of measures to restore contaminated ground or
surface water for a period of up to 10 years after the
commencement of operation of such measures. The practical
effect is that federal funds will be used to pay 90 percent
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(or 50 percent for a publicly operated site) of the cost of
ground or surface water restoration for up to 10 years. The
state will pay the difference. This provision, however,
does not apply:
To source control maintenance measures initiated to
prevent contamination of ground or surface waters.
— To ground or surface water measures initiated for the
primary purpose of providing a drinking water supply,
not for the purpose of restoring ground water.
How does EPA define "on-site" for purposes of the CERCLA section
121(e) exemption from obtaining federal, state, or local permits
for activities conducted entirely on-site?
o EPA defines "on-site" as the "areal extent of contamination
and all suitable areas in very close proximity to the
contamination necessary for implementation of the response
action." Flexibility in defining "on-site" is necessary in
order to provide expeditious response to site hazards.
What are the requirements for deleting sites from the NPL?
o Sites may be deleted from or recategorized on the NPL where
no further response is appropriate and any of the following
criteria has been met:
Responsible parties or other persons have implemented
all appropriate response actions required.
All appropriate Fund-financed response under CERCLA has
been implemented, and no further response action by
responsible parties is appropriate.
The remedial investigation has shown that the release
poses no significant threat to public health or the
environment and, therefore, taking of remedial measures
is not appropriate.
o EPA must obtain state concurrence in order to delete a site
from the NPL. Also, EPA must provide the opportunity for
public comment on a proposed deletion.
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What is the "Construction Completion" category.
o EPA has established a new "category" as part of the NPL,
the "Construction Completion" category. Sites may be
categorized as "construction complete" only after remedies
have been implemented and are operating properly. These may
be:
-- Sites awaiting deletion.
Sites awaiting five-year review and/or deletion (see
next question on five-year reviews).
Sites undergoing long-term remedial actions (LTRAs).
LTRAs are taken at sites where activities over a
relatively long duration are necessary in order to
attain cleanup levels identified in the ROD (e.g., pump
and treat of ground water for many years).
How does EPA ensure that sites remain safe after the remedial
action has been completed?
o The NCP requires a review of a site where waste is left
behind at least once every five years to ensure that the
site remains safe. No site will be deleted from the
National Priorities List (NPL) after completion of the
cleanup until at least one five-year review has been
conducted.
What contractor conflict of interest requirements are in the 1990
NCP?
o For Fund-financed remedial design/remedial action (RD/RA)
and operation and maintenance (O&M) activities, the NCP
requires the lead agency to include appropriate language in
solicitations requiring potential prime contractors to
submit information about their status, as well as the status
of their subcontractors, parent companies, and affiliates,
as potentially responsible parties at a site.
o Prior to contract award, the lead agency must evaluate the
information to determine if a conflict of interest exists
that could significantly impact the performance of the
contract or the liability of the prime contractors or
subcontractors.
o The purpose of this evaluation is to decide whether more
oversight of the performance of the contract is appropriate
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or whether a contractor has an unresolvable conflict of
interest such that it should be declared nonresponsible or
ineligible for contract award.
DEFERRAL POLICIES
The preamble to the proposed NCP solicited public comment on the
possible expansion of the Agency's policy for deferring the
listing of sites on the National Priorities List for response
under other authorities. What was EPA's decision on expanding the
policy?
o EPA decided not to establish an expanded deferral policy at
this time. EPA is still evaluating the complex issues
involved and believes that any changes in this policy are
best decided within the context of CERCLA reauthorization.
Current policies with regard to what sites are appropriate
for inclusion on the NPL will remain in effect.
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
What are applicable requirements?
o Applicable requirements are cleanup standards, standards of
control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under
federal environmental or state environmental or facility
siting law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstance found at a CERCLA site.
What are relevant and appropriate requirements?
o Relevant and appropriate requirements are cleanup
standards, etc. that, while not applicable, address
problems or situations sufficiently similar to those
encountered at a CERCLA site that their use is well-suited
to the particular site.
How does the 1990 NCP change the role of ARARs?
o Prior to the 1986 amendments, EPA required compliance with
all federal ARARs, but only consideration of state
requirements. The 1990 NCP incorporates the new statutory
requirement that remedies must comply not only with ARARs
under federal laws, but also with promulgated standards,
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requirements, criteria, or limitations under state
environmental or facility siting laws that are more
stringent than corresponding federal standards. The 1990
NCP defines "promulgated" state requirements as those laws
or regulations that are of general applicability and are
legally enforceable.
The 1990 NCP provides that the lead and support agency
identify their respective federal and state ARARs in a
timely manner. "Timely manner" is defined in Subpart F as
sufficient time for the lead agency to consider and
incorporate ARARs into the remedy selection process without
inordinate delays and duplication of effort.
The 1986 amendments establish six limited exceptions or
waivers to the general mandate that remedial actions attain
all ARARs. The NCP specifies the six waivers:
The alternative is an interim measure and will become
part of a total remedial action that will attain ARARs.
Compliance with ARARs will result in greater risk to
human health and the environment than other
alternatives.
Compliance with ARARs is technically impracticable from
an engineering perspective.
Another alternative that does not comply with the ARAR
will result in an equivalent standard of performance.
The state ARAR has not been consistently applied in
similar circumstances.
— Attainment of ARARs will not provide a balance between
the need for protection of human health and environment
at the site and the availability of Fund monies to
respond to other sites. The preamble to the 1990 NCP
suggests a threshold for routine consideration of this
waiver at four times the average cost of an operable
unit.
Can non-promulgated criteria, such as advisory levels or guidance,
be considered when determining cleanup standards?
o Criteria, advisories, or guidance that do not meet the
definition of ARARs but that may assist in determining what
is necessary to be protective or that are otherwise useful
in developing Superfund remedies are described as
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information to-be-considered (TBC). Three general
categories of TBCs are: (1) health effects information with
a high degree of creditability, e.g., reference doses; (2)
technical information on how to perform or evaluate site
investigations or response actions; and (3) policy, e.g.,
EPA's ground-water policy.
o The proposed NCP's description of TBCs was revised in the
1990 NCP to emphasize that they should be used on an "as
appropriate" basis and that TBCs are intended to complement
use of ARARs, not to be in competition with ARARs.
When are MCLs or MCLGs considered relevant and appropriate in the
selection of ground-water restoration levels?
o Maximum contaminant levels (MCLs) are enforceable standards
under the Safe Drinking Water Act for specific contaminants
in public water supplies. Maximum contaminant level goals
(MCLGs) are non-enforceable goals on which MCLs are based.
o Consistent with CERCLA's direction to use maximum
contaminant level goals (MCLGs) as cleanup levels, the NCP
states that ground water that is or could be used for
drinking generally will be restored to MCLGs that are above
zero. When the MCLG equals zero (generally for
carcinogens), the corresponding maximum contaminant level
(MCLs) generally will be used as the cleanup level.
o The NCP explains that a cleanup level of zero is not
appropriate for Superfund because CERCLA does not require
the complete elimination of risk and because it is
impossible to detect whether "true" zero has actually been
attained.
o The proposed NCP had stated that MCLs generally will be used
as the cleanup level and stated that MCLGs would be used
only in cases where multiple contaminants or pathways posed
a risk in excess of 10~^.
Has the role of ARARs changed significantly in going from proposed
to final revisions?
o The role of ARARs in the 1990 NCP is essentially the same
as in the proposed rule. New language was added to the
rule, however, to clarify that requirements that are
promulgated or modified after the ROD is signed will be
attained only when determined to be ARAR and necessary to
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ensure that the remedy protects human health and the
environment.
o The preamble to the 1990 NCP also states that best
demonstrated available technology (BDAT) standards under the
RCRA land disposal restrictions (LDR) generally will not be
appropriate for contaminated soil and debris at a Superfund
site. This revised policy will allow Superfund sites to
attain alternative levels of cleanup to those required by
the BDAT standards.
COMMUNITY RKT.ATTONS AND ADMINISTRATIVE RECORD
What community relations activities are specified in the 1990
NCP?
o In the 1985 NCP, all community relations requirements were
set forth in section 300.67. In the 1990 NCP, community
relations requirements are incorporated into each of the
sections relating to the different phases of response, i.e.,
removal actions, remedial investigation and feasibility
study (RI/FS) and selection of remedy, and remedial design
and remedial action (RD/RA). Further, in the 1990 NCP, new
community relations requirements are added to implement 1986
CERCLA requirements under sections 113 (administrative
record) and 117 (public participation).
1. Removal Actions
What are the administrative record and public participation
requirements for removal actions?
o These requirements depend upon the type of removal action
conducted. The three categories of removal actions are:
— Emergency, which generally refers to a release or
threat of release that requires that removal activities
begin on site within hours of the lead agency's
determination that a removal action is appropriate.
Time-critical, where based on the site evaluation, the
lead agency determines that a removal action is
appropriate and that there is a period of less than six
months available before removal activities must begin on
site.
Non-time-critical. where based on the site evaluation,
the lead agency determines that a removal action is
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appropriate and that there is a planning period of more
than six months before on-site removal activities must
begin.
What are the primary public participation requirements that apply
to all types of removal actions?
o The lead agency shall designate a spokesperson to provide
information and to respond to inquiries regarding the
action.
What are the primary administrative record and public
participation requirements that apply to: (1) emergency and (2)
time-critical removal actions? ("New" indicates a requirement not
stated in the 1985 NCP):
o (New) The administrative record shall be made available to
the public no later than 60 days after initiation of on-site
removal activities. The notice of availability shall be
published in a major local newspaper of general
circulation. The record shall be available at the office of
the lead agency or other central location and at or near the
site. The record for emergency cleanups lasting less than
30 days need only be available at the central location.
o (New) The lead agency shall, as appropriate, provide a 30-
day public comment period to begin at the time the
administrative record is made available to the public and
respond to comments received.
What are the primary administrative record and public
participation requirements that apply to: (1) all non-time-
critical actions and (2) time-critical actions where on-site
removal activities are expected, to last longer than 120 calendar
days?
o (New) Conduct interviews with state and local officials,
residents, public interest groups, or other interested or
affected parties, as appropriate.
o Develop a community relations plan specifying the community
relations activities that the lead agency expects to
undertake.
o (New) Establish at least one information repository at or
near the site to contain items made available for public
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inspection. The administrative record shall be available in
at least one of the repositories.
What additional administrative record and public participation
requirements apply to non-time-critical actions?
o (New) Publish a notice of availability and brief
description of the decision document, i.e., the engineering
evaluation/cost analysis (EE/CA).
o (New) At the same time, make the administrative record
available for public inspection.
o (New) Provide a public comment period on the EE/CA and the
administrative record of not less than 30 days after the
EE/CA is made available. Upon timely request, the lead
agency will extend the comment period by a minimum of 15
days.
o (New) Prepare a written response to significant comments.
2. Remedial Actions
What are the primary administrative record and public
participation requirements for remedial actions?
o (New) Conduct interviews with state and local officials,
residents, public interest groups, or other interested or
affected parties, as appropriate.
o Develop a community relations plan (CRP) specifying the
community relations activities that the lead agency expects
to undertake.
— In a revision to the proposed NCP, the 1990 NCP more
clearly states that the purpose of developing the CRP
is to provide the public opportunities to participate in
decision-making at the site and to learn about the site.
o (New) Establish information repositories at a central
location and at or near the site and inform the public of
its availability.
o (New) Inform the community of the availability of technical
assistance grants.
o (New) Make the administrative record available for public
inspection when the remedial investigation (Rl) starts
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(generally when the RI/FS workplan is available) and publish
a notice of availability.
o (New) Prepare a proposed plan that briefly describes the
remedial alternatives analyzed, proposes a preferred
remedial action alternative, and summarizes the information
relied upon to select the preferred alternative.
o (New) Publish a notice of availability of the proposed plan
and RI/FS in a newspaper of general circulation.
o (New) Make the proposed plan and supporting analyses and
information available in the administrative record.
o (New) Provide a comment period of not less than 30 days for
submission of written and oral comments (comment period in
the 1985 NCP is 21 days).
In a change from the proposed NCP, the 1990 NCP states
that, upon timely request, the comment period may be
extended a minimum of 30 days.
o Provide the opportunity for a public meeting during the
public comment period.
o (New) Keep a transcript of the public meeting.
o Prepare a response to comments, to be a part of the record
of decision (ROD).
o (New) Include in the ROD a discussion of any significant
changes from the proposed plan with respect to scope,
performance, or cost.
o (New) Solicit additional public comment on a revised
proposed plan if the significant changes from the proposed
plan could not have been reasonably anticipated based on
existing information.
o (New) Publish a notice of availability of the ROD and make
the ROD available for public inspection and copying.
o (New) Prior to remedial design, review the community
relations plan and, when appropriate, revise the community
relations plan to describe public involvement opportunities
during remedial design/remedial action.
o (New) If, after adoption of the ROD, the remedial action
differs significantly from the ROD with respect to scope,
performance, or cost, publish and make available an
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explanation of significant differences. If the changes
fundamentally alter the ROD, propose an amendment to the
ROD, issue a public notice, solicit public comment, and
comply with other community relations requirements, such as
public meetings, transcripts, comment response summaries,
etc.
o (New) Issue a final engineering design fact sheet and
provide, as appropriate, a public briefing prior to the
initiation of the remedial action.
How does a significant change to a remedy differ from a
fundamental change?
o Significant changes are generally incremental changes to a
component of a remedy that do not fundamentally alter the
overall remedial approach selected in the ROD (e.g.,
compliance with a newly promulgated requirement so that the
remedy remain protective but that does not change the
selected technology). A significant change requires an
explanation of significant differences. Fundamental changes
alter the ROD with respect to scope, performance, or cost in
such a manner that the proposed action, is no longer
reflective of the selected remedy in the ROD (e.g., a change
from an innovative technology to a more conventional one).
Fundamental changes require ROD amendments.
What changes were made in response to public comments on the
proposed NCP's community relations requirements?
o The purpose of developing the community relations plan is
to provide the public opportunities to participate in
decision-making at the site and to learn about the site.
o Upon timely request, the public comment period will be
extended a minimum of 30 days for remedial actions. For
non-time critical removal actions, the comment period will
be extended a minimum of 15 days, upon timely request.
o Prior to remedial design, the lead agency is required to
review the CRP to determine if it should be revised. The
proposed NCP provided for revision of the CRP in cases where
community concerns were not already addressed.
o Before initiation of remedial action, a fact sheet on the
final engineering design will be distributed and an
opportunity for a public briefing will be provided, as
appropriate.
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o The preamble to the 1990 NCP describes other public
participation activities in addition to the minimum
requirements that may be implemented at a site.
What is a technical assistance grant (TAG)?
o SARA section 117(e) provides that technical assistance
grants of up to $50,000 may be made available to community
groups that may be affected by a release or threatened
release at a site listed on the NPL. The grants must be
used to obtain assistance in interpreting technical material
related to site cleanups.
What changes were made in the 1990 NCP in response to public
comments about TAGs?
o The 1990 NCP requires the community to be informed of the
availability of TAGs and that information about the TAG
application process be placed in the information repository
located at or near the site.
ADMINISTRATIVE RECORD REQUIREMENTS
What is the purpose of the administrative record?
o The two primary purposes of the record are to:
Serve as the record for judicial review concerning the
adequacy of a response action.
Provide interested parties, including potentially
responsible parties (PRPs), an opportunity to
participate in selection of the response through review
of and comment on documents in the record.
What documents typically are included in the administrative
record?
o All documents which form the basis for the selection of a
response action. Such documents typically include: factual
information/data; analysis of factual information; policy
and guidance documents; public participation documents,
including public comments; decision documents and responses
to public comments; and some enforcement documents.
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Where must the administrative record be located and how will the
public be notified of its availability?
o The record must be located at or near the site (in an
information repository) and at an office of the lead agency
or another central location. The record need not be
available at or near the site, however, for emergency
removal actions that are concluded within 30 days of
initiation.
o Certain information need not be located at or near the site
where it would pose a substantial administrative burden,
e.g., sampling and testing data, guidance documents not
generated specifically for the site, publicly available
technical literature. The index to the record, however,
shall indicate the availability of such items.
o The availability of the record must be announced in a major
local newspaper of general circulation.
What documents may be added to the administrative record after the
ROD is signed?
o Documents relating to remedy selection issues that the ROD
reserves or does not address, explanations of significant
differences, and ROD amendments.
How does the administrative record differ from the information
repository?
o Information repositories include documents that relate to a
Superfund site and to the Superfund program in general, such
as documents on site activities, information about the site
location, and background program and policy guides. The
administrative record is the body of documents that forms
the basis of the Agency's selection of a particular response
at a site, such as site-specific data and public comments.
Documents in the administrative record may overlap with
those found in the information repository.
STATE INVOLVEMENT
Which NCP requirements apply to state-lead response actions?
o The NCP applies to federal agencies and states that take
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response actions pursuant to the authorities under CERCLA
and section 311 of the Clean Water Act.
How does the 1990 NCP implement the new CERCLA requirement to
provide for substantial and meaningful state involvement in
remedial planning and remedial actions?
o The 1990 NCP introduces the Superfund Memorandum of
Agreement (SMOA) and the process of EPA/state concurrence in
remedy selection. SMOAs are voluntary agreements that are
intended to ensure equitable relationships between EPA and
states and to reduce misunderstandings by clarifying the
expectations of both parties. The SMOA may be used to
establish the general framework for the EPA/state working
relationship, to define the roles and responsibilities of
the lead and support agencies, and to provide general
requirements for EPA oversight.
o The NCP provides that the state may be the lead agency for a
Fund-financed site. This allows the state to conduct the
investigation and analysis leading up to selecting the
remedy. The state may also conduct the remedial
design/remedial action phases of the response.
o The process of concurrence, which reflects the evolution of
the EPA/state partnership in recent years, enables a state
that demonstrates certain capabilities to prepare the
proposed plan and recommend the remedy for EPA adoption for
Fund-financed actions. EPA retains the authority to select
Fund-financed remedies and sign the record of decision
(ROD), with the state's concurrence.
Also under the concept of concurrence, a state will
select the remedy and may request EPA concurrence for
state enforcement actions not using the Superfund (i.e.,
non-Fund-financed actions).
One advantage to concurrence by EPA and a state on a
remedy is that it results in a unified position when
EPA and the state negotiate with PRPs.
o A state may recommend a remedy for EPA concurrence even
when no SMOA is established. EPA anticipates that the
concurrence process will increase EPA involvement in state
enforcement actions and provide for greater state
involvement in the selection of remedial actions at Fund-
financed sites.
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What happens if a SMOA is not established?
o The 1990 NCP sets forth minimum requirements in the absence
of a SMOA regarding annual EPA/state consultations, review
by the support agency of lead agency documents, and
identification of ARARs.
FF.DF.RAL FACILITIES
Which NCP requirements apply to federal facility response actions?
o Requirements of the NCP apply to federal agency response
actions at NPL and non-NPL sites, except where specifically
noted that the requirements apply only to Fund-financed
activities. The requirement for joint selection of remedy
by a federal agency and EPA applies only at NPL sites.
o Subpart K of the 1990 NCP is specifically reserved for
federal facilities. EPA is currently drafting Subpart K,
which will provide a roadmap of the NCP requirements that
apply to federal facility response actions.
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April 1990 EPA Region 10 - HW Policy Office
Judi Schwarz (206) 442-2684 (FTS) 399-2684
THE REVISED FINAL NCP
INTRODUCTION
Previous final NCP - November 1985
Draft revised NCP published December 21, 1988
Final revised NCP published March 8, 1990 (40 CFR 300,
40 CFR 8666)
to reflect changes required by SARA
to reflect how EPA actually does business
The new NCP is very different from the 1985 NCP; not very
different from the 1988 draft or existing guidance or the way we
currently do business. This handout focuses on changes from the
1988 proposed NCP and/or positions that may affect the way we do
business.
Compliance with the NCP:
NCP Section 300.700(c)(i)
- Requires "substantial compliance" with the
requirements.
Immaterial or insubstantial deviations are not
important.
Today's topics:
Page
Introduction and Organization of the NCP 1
Remedial Program Expectations and Goals 3
Early Actions 4
State Roles 6
Remedy Selection 7
ARAR Issues 11
RCRA ARARS 14
Risk Assessment and Remediation Goals 15
Groundwater and Surface Water Issues 17
Community Relations 19
Removals 20
Out-of-State Transfer of CERCLA Wastes 20
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GENERAL ORGANIZATION OF THE NCP
Subpart A - Introduction
300.5 Definitions
Subpart B - Responsibility and Organization for
Response
Subpart C - Planning and Preparedness
Subpart D - Operational Response Phases for Oil Removal
Subpart E - Hazardous Substance Response**
Subpart F - State Involvement in Hazardous Substance
Response*
Subpart G - Trustees for Natural Resources
Subpart H - Participation by Other Persons*
Subpart I - Administrative Record for Selection of
Response Action*
Subpart J - Use of Dispersants and Other Chemicals
Subpart K - Federal Facilities (Reserved)
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REMEDIAL PROGRAM EXPECTATIONS AND GOALS
NCP Section 300.430(a)(1) - page 8846
Preamble - pages 8700 - 8703
Program Goal:
- Nothing much new - except that it's in the NCP proper
"The national goal of the remedy selection process is to
select remedies that are protective of human health and the
environment, that maintain protection over time, and that
minimize untreated wastes."
- The nine criteria determine the extent to which this goal
is satisfied.
Expectations:
- Now in the NCP proper.
- NOT binding requirements.
- Designed to guide the development of cleanup options.
There are 6 expectations:
a. Use treatment to address the principal threats wherever
practicable. Principal threats for which treatment is
most likely to be appropriate include:
liquids
areas contaminated with high concentrations of
toxic compounds
highly mobile materials
b. Use engineering controls, such as containment, for
waste that poses a relatively low long-term threat
(E.g. waste contaminated at low levels) or where
treatment is impracticable.
-Treatment is less likely to be practicable when
sites have large volumes of low concentration of
hazardous substances, or in wastes with widely
varying composition.
c. Combine methods as appropriate.
d. Institutional controls shall not substitute for active
response measures as the sole remedy unless such active
measures are determined not to be practicable. (See
the remedy selection section for a discussion of
"practicable.")
- Use institutional controls to supplement
engineering controls during the RI/FS and
implementation of the remedy, and where necessary,
as a component of the completed action.
e. Innovative technology will considered when:
-the technology offers the potential for
comparable or superior treatment performance or
implementability
-fewer or lesser adverse impact than the
alternatives
-or lower costs for similar level of performance
than demonstrated technologies
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f. Groundwater
-Usable groundwater will be returned to their
beneficial uses wherever practicable, within a
timeframe which is reasonable given the site.
-If restoration is not practicable, further
migration of the plume will be stopped, exposure
to the contaminated groundwater will be prevented
REMEMBER: THESE ARE EXPECTATIONS - NOT RULES. THE GOAL IS
FLEXIBLE, SITE-SPECIFIC DECISION-MAKING. THESE EXPECTATIONS DO
NOT SUBSTITUTE FOR SITE SPECIFIC ALTERNATIVES DEVELOPMENT AND
SCREENING - ONLY ASSIST IT.
HOW TO DO EARLY ACTIONS
Preamble: pages 8703 - 8706
Removals
We have been doing early actions at NPL sites under the
removal program since the beginning of the SF program. No
major changes.
Remedial Actions
Operable units - nothing much new.
- Use operable units to do early actions when necessary
or appropriate; to do phased analysis or response; to
deal with the size or complexity of the site; or to
speed the cleanup of the site.
- Operable units should not be inconsistent with the
expected final remedy
Let the paperwork fit the site and the action.
- All sections in the NCP describing the RI/FS include
the phrase "as appropriate."
- Focus on alternatives that show promise in achieving
the goals of the SF program.
A streamlined RI/FS may be particularly appropriate
when:
- site problems are straightforward with a limited
number of ways to address it.
- prompt action is needed
- ARARs limit the range of alternatives
- many alternatives are clearly impracticable
- no further action or only limited action is
required (esp. after a removal)
Act as soon as there is sufficient information
YOU DO NOT NEED TO FINISH AN RI/FS TO DO A REMEDIAL
ACTION - esp. an interim remedy.
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So what do you need (at a minimum) to do an interim action
as an operable unit under the remedial program?
- Extract data to support decision from the on-going
RI/FS or other source
- Develop few alternatives. (Sometimes only one
alternative need be developed.)
- Qualitative risk information to show that the
remedial action is necessary.
- Consider ARARs. (Waiver is available.)
- Involve the support agency.
- Involve the public.
- Involve the natural resource trustees.
- Document data and information in a focused
feasibility study, or, just in the proposed plan.
- Publish the Proposed plan and respond to public
comments.
- Prepare and sign the ROD.
You do NOT need:
- A baseline risk assessment
- A full RI/FS
- A definitive site characterization
For simple, straightforward interim actions, the total
documentation could be accomplished in just a few pages.
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STATE ROLES IN SUPERFUND j»
NCP Sections 300.500 - 300.525 - pages 8853-8857
Preamble - pages 8775 - 8786
Cooperation and coordination between agencies are encouraged.
States and Indian Tribes are encouraged to undertake all actions
that EPA is allowed to do under Section E.
Exceptions:
Emergencies and time-critical removals cannot be
state lead.
EPA must sign the ROD when Fund moneys are involved.
Superfund Memorandum of Agreement (SMOA):
- Voluntary agreements.
Can establish review and comment periods between lead and
support agency. Such periods must be also documented in
site-specific cooperative agreements or Superfund state
contract.
- SMOAs are no longer a prerequisite for any action.
Review and Response Periods when there is no SMOA:
- These NCP review periods apply to both the state and EPA
when they are operating as support agencies. (NCP Section
300.515 (c) and (h))
NPL listing - 30 working days, to the extent feasible
ARAR identification - 30 working days
RI/FS, ROD, RD, ARAR/TBC determinations - 10 to 15
working days
Proposed plan - 5 to 10 working days
Institutional controls:
- State must provide assurances of institutional controls at
Fund-financed sites. (NCP section 300.510(c)(1), page 8854;
preamble page 8778.)
ROD preparation, concurrences, and selection of remedy:
(preamble 8782-8783)
- Agreements can provide for either agency to prepare the
proposed plan and ROD.
- Only EPA can sign the ROD/select the remedy, except when
the state is acting under state law instead of CERCLA.
- At Fund-financed sites, EPA can publish a proposed plan
without state concurrence; state cannot publish a proposed
plan without EPA concurrence.
- EPA approval requires written concurrence.
- At non-Fund financed state-lead sites:
- EPA is not bound by state action.
- EPA retains the right to act under its own CERCLA
authorities if needed.
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SELECTION OF REMEDY
"....A pragmatic and flexible valuation of potential
remedies at a site while still protecting human health and the
environment."
Development of alternatives
NCP Section 300.430(e) - pages 8848 - 8849
Preamble - pages 8714 - 8715
- Alternatives should be developed, as appropriate for the
particular situation at the site.
- Program expectations can help focus this development.
- If treatment is not practicable for all wastes at the
site, then complete treatment need not be included as
an alternative.
- If it is clear that treatment will be part of the
remedy, alternatives that rely solely on containment or
institutional controls and that do not include
treatment need not be considered.
- Innovative technologies - (p. 8714) See "Expectations"
section above. Eliminate from consideration only those
innovative technologies that have little potential for
performing well at specific sites.
Screening of Alternatives
NCP Section 300.430(e)(7), page 8849
Preamble pages 8714 - 8715
- To eliminate those alternatives that are not effective,
not implementable or whose costs are grossly excessive for
the effectiveness they provide.
- Cost is used in two ways to eliminate alternatives:
- When alternatives vary significantly in their
effectiveness, some alternatives are inordinately
costly for the effectiveness, e.g. total treatment of a
large municipal landfill.
- Where two or more alternatives provide similar levels
of effectiveness and implementability (using a similar
method of treatment or engineering control) but their
cost vary significantly.
Detailed Analysis of Alternatives
NCP Section 300.430(e)(9) - pages 8849-8850
Preamble - pages 8719 - 8723
- To present relevant information for the decision-making
step.
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Nine criteria
NEW - The three categories have been eliminated for
purposes of the detailed analysis.
Few changes to the nine criteria themselves:
1. Protection of human health and the environment -
draws on the assessments conducted under other
evaluation criteria, esp. long-term effectiveness and
permanence, short-term effectiveness, and compliance
with ARARs.
2. Compliance with ARARS - Either the PRP or a state
may perform the ARAR analysis and recommend the
applicability of ARAR waivers, but EPA determines
compliance with ARARs (and the applicability of ARAR
waivers) when it selects the remedial action, (p.8720)
3. Long-term effectiveness and permanence. Any
residual risk site after the response objectives have
been met.
- Permanence is judged along a continuum, with
remedies offering greater or lesser degrees of
long-term effectiveness and permanence.
4. Reduction of toxicity, mobility or volume through
treatment OR RECYCLING.
- EPA IS ESTABLISHING, AS A GUIDELINE, THAT
TREATMENT AS PART OF CERCLA REMEDIES SHOULD
GENERALLY ACHIEVE REDUCTIONS OF 90 TO 99 PERCENT
IN THE CONCENTRATION OR MOBILITY OF INDIVIDUAL
CONTAMINANTS OF CONCERN.
5. Short-term effectiveness
6. Implementability
7. Cost - Evaluates and compares the cost of the
alternatives. To include direct and indirect capital
and O&M costs, as well as certain replacement costs.
DOES NOT MAKE ANY CONCLUSION RE THE COST-EFFECTIVENESS
OF THE ALTERNATIVES. COST-EFFECTIVENESS IS DETERMINED
AT THE SELECTION OF REMEDY STAGE.
8. State acceptance
9. Community acceptance.
Procedure:
- Assess each alternative individually assessed against
the nine criteria.
- Comparative analysis to identify the key tradeoffs
(relative advantages and disadvantages) among the
alternatives with respect to the nine criteria.
Remedy Selection
NCP Section 300.430(f) - page 8851
Preamble - pages 8723 - 8731
8
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Flexibility: Each SF site presents a different set of
circumstances. Many different ways to fulfill each statutory
mandate.
Same nine criteria but used differently.
Threshold:
1. Protection of human health and the
environment
2. Compliance with ARARS
Primary Balancing:
Balancing is the key concept during the selection
of remedy.
3. MORE IMPORTANT: Long-term effectiveness and
permanence
4. MORE IMPORTANT: Reduction of toxicity,
mobility or volume through treatment or recycling.
5. Short-term effectiveness
6. Implementability
7. Cost (See below)
Modifying:
8. State acceptance
9. Community acceptance.
Modifying criteria: Generally considered in altering an
otherwise viable approach rather than in deciding between
very different approaches.
Statute, and now NCP, has a bias against off-site land
disposal of untreated waste. Neither has a bias for or
against off-site remedies involving treatment.
Statutory Determinations and The Role of Cost in Remedy Selection
Cost is considered in making two statutory determinations
required for selected remedies: (p. 8728 - 8731)
- That the remedy is cost-effective (i.e. the remedy
provides effectiveness proportional'to its cost); and
- That the remedy utilizes permanent solutions and treatment
to the maximum extent practicable.
COST-EFFECTIVENESS:
- Are costs proportional to the effectiveness
achieved?
- Overall effectiveness includes long-term
effectiveness and permanence; reduction of
toxicity, mobility or volume through treatment;
and short-term effectiveness.
"Proportional" includes:
the cost and effectiveness of each alternative
individually. (What is the relative magnitude of cost
to the effectiveness of the alternative?) and,
the cost and effectiveness of alternatives in
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relation to one another. (What is the incremental cost
difference in relation to the incremental differences
in effectiveness?)
- Best professional judgement is used.
Strict mathematical proportionality is not
intended. Incremental differences is the key.
More than one alternative may be cost-effective.
COST AND PRACTICABILITY:
-Uses the same criteria as cost-effectiveness, plus
implementability of the remedy, and state and community
acceptance.
The two statutory determinations are separate findings that
result from balancing conducted during the remedy selection
process.
Changes to the ROD after its adoption
NCP Section 300.435(c) - pages 8852
Preamble pages 8771- 8773
(Also, see section below on post-ROD ARAR changes.)
Three types of changes:
1. Non-significant changes -
- Examples:
- changes in the cost or type of materials,
equipment, etc.)
- Document in the post-ROD file.
2. Significant changes - incremental changes to a
component of a remedy that do not fundamentally alter the
overall remedial approach.
- Examples: -timing changes
- cost increases (more volume, cost up 50%)
- some technology changes ( carbon adsorption
instead of air stripping)
- Requires an explanation of significant differences to
be published. No formal public comment period
required, but comments that present substantial new
information must be considered.
3. Fundamental changes - the proposed action, with respect
to scope, performance, or cost, is no longer reflective of
the selected remedy in the ROD.
- Example: Innovative technology will not achieve
remediation goals, so a different technology will be
used.
- Requires a ROD amendment, including a proposed plan,
full public comment period, and response to comments.
ROD amendment public comment period can be concurrent
with public comment periods on consent decrees.
- ESDs and ROD amendments require consulting with support
agencies.
10
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ARAR ISSUES
NCP - Identification of ARARs; Factors to determine
relevant and appropriate: Section 300.400(g), page
8841
- Waivers and post-ROD ARAR changes: Section
300.430(f)(1), page 8850
Preamble - pages 8741 -8766
(Also see Groundwater Issues section below.)
General Points
No major changes:
- Federal, state, (and tribal) ARARs must be attained
for on-site actions.
- ARARs do not apply to off-site actions. All
applicable rules, including obtaining permits, apply to
off-site actions.
- ARARs apply to removals "to the extent practicable
considering the exigencies of the situation."
- A variance or exemption provision in a regulation can
be a potential ARARs as well as the basic standard.
(e.g. Treatability variances under LDR for soil and
debris.)
- ARARs must be attained during the implementation of
the remedial action, where the ARAR is pertinent to the
action itself, as well as at the completion of the
action.
- In general, state regulations under federally
authorized programs are considered federal
requirements.
- Need only meet ARARs within the scope of an interim
action.
Definition of on-site: the areal extent of contamination and
all suitable areas in very close proximity to the contamination
necessary for implementation of the response action. (Section
300.400(e), page 8841)
Relevant and Appropriate Determination:
(Preamble pages 8742 - 8744)
Eight factors are used. (No major changes.)
No single factor alone sufficient.
- May find parts of a regulation to be relevant and
appropriate.
To be Considered (TBCs):
Identification of all possible TBCs is not longer
necessary.
TBCs to be identified and used "as appropriate."
TBC are meant to complement the use of ARARs, not
to be in competition with ARARS.
11
-------
Timely identification of ARARs:
(preamble page 8746-8747)
When there is a SMOA, the SMOA will identify the
deadlines for identifying ARARS.
When there is no SMOA, potential ARARs must be
sent to the lead agency within 30 WORKING
DAYS of the receipt of a request from the
lead agency.
ARARs are requested at two steps in the process.
Points of compliance:
Preamble - page 8713
- Air - The selected levels should be established for
the maximum exposed individual, considering reasonable
expected use of the site and surrounding area.
- Surface water - the selected levels should be
attained at the point or points where the release
enters the surface water.
- Groundwater - see below.
Soil - silent
Compliance with ARARs during RIs (and pre-remedial work);
NCP Section 300.410(i) - page 8843
Preamble - pages 8755 - 8756
- Studies are removal actions undertaken pursuant to
CERCLA section 104(b), but are not subject to the
statutory limits on removals.
- Like removals, ARARs need to be complied with during
RIs "to the extent practicable, considering the
exigencies of the situations."
- Will involve the use of best professional judgement.
ARAR Waivers
NCP Section 300.430(f)(1)(ii)(C) - page 8850
Preamble - pages 8747 - 8750)
Nothing much new, except as noted.
- Interim measures. Interim measure are expected to be
followed by remedial actions which attain ARARs within
a "reasonable time." Reasonable time is not pre-set,
but is a site-specific decision. Factors to consider
include funding and priorities.
- Greater risk to health and the environment.
- Technical impracticability. From an engineering
perspective. Includes engineering feasibility and
reliability. Cost plays a subordinate role.
- Equivalent standard of performance. Not based on a
comparison of exposure risk, unless the original
standard is risk-based. Based on equivalent degree of
protection, level of performance and future
reliability.
- Inconsistent application of state requirements. A
12
-------
standard is presumed to have been consistently applied
unless these is evidence to the contrary.
- Fund balancing. New policy. EPA will routinely
consider, not necessarily invoke - the Fund-balancing
waiver at a threshold point. Threshold point - a
single action that would be four times the cost of an
average operable unit. Fund balancing could also occur
at a lower cost as well, if necessary.
ARARs identified after the ROD is signed;
NCP - Section 300.430(f) (ii), page 8850
Preamble - page 8747 and 8757 - 8758
ARARs are basically frozen when the ROD is signed.
- Two exceptions:
1. If a component of a remedy is not identified
a the time of ROD signing, requirements in effect
when the component is later identified (e.g.
during remedial design) will be used to determine
ARARS.
2. Compliance is necessary to necessary to
maintain protectiveness. Primarily done as part
of the five year review.
Requirements applicable to off-site actions are
never frozen.
13
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RCRA ARARS A
Preamble pages 8758 - 8764
Placement:
- The definition of "placement" has not changed.
- Treatment and placement is considered "placement."
CERCLA Area of Contamination (AOC):
- Can include widespread areas of generally dispersed
contamination.
- Not identical to a RCRA "unit," but generally
analogous.
- Consolidation or movement of material within an AOC
not subject to any applicable RCRA regulation.
- Consolidation from different AOCs are subject to
applicable RCRA requirements.
LDR Treatability Waivers for soil and debris:
"EPA has determined that, until specific standards for soils
and debris are developed, current BDAT standards are generally
inappropriate or unachievable for soil and debris from CERCLA
response actions and RCRA corrective actions and closures.
Instead, EPA presumes that, because contaminated soil and debris
is significantly different from the wastes evaluated in
establishing the BDAT standards, it cannot be treated in
accordance with those standards and thus qualifies for a
treatability variance from those standards under 40 CFR 268.44."
(page 8760)
- No case-by-case demonstration of inappropriateness or
unachievability needed.
- Contaminated soil and debris should meet the
percentage reduction out-lined in Superfund LDR
Guidance #6A, "Obtaining a Soil and Debris Treatability
Variance for Remedial Actions. EPA OSWER Directive
9347.3-06FS, July 1989, to be revised shortly.
- Some exceptions, especially with soils with high
levels of combustible organics, and, maybe, soils and
debris with dioxin. In these cases, EPA may determine
that the existing BDAT standards are appropriate for
that particular site and would require such treatment
(e.g. combustion.)
NOTE: Even though we have guidance stating so, the NCP
never says that the LDR are never relevant and appropriate to
soil and debris.
14
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RISK ASSESSMENT AND REMEDIATION GOALS
NCP Section 300.430(e)(2)(i) - page 8848
Preamble - pages 8709 - 8711, 8713, 8715 - 8718
Risk Assessment - Two objectives:
1. Baseline risk - the risks that exist if no
remediation or institutional controls are applied to a
site.
ie. Is remediation necessary?
Which exposure pathways need to be remediated?
2. Help establish acceptable exposure levels
Exposure scenarios:
- Use "reasonable maximum exposure scenario".
- A "part of a lifetime" exposure duration can be used.
Remediation goals;
- A subset of remedial action objectives
- Medium-specific or operable unit specific protective
chemical concentrations
- Serve as goals for remedial action.
Preliminary remediation goals:
- Used to focus the development of, and to limit the
number of, alternatives, during the RI/FS.
- Developed based on readily available information
(e.g. environmental or health based ARARS like MCLs).
- modified, as necessary, during the RI/FS.
- Alternatives that attain other risk levels can be
developed.
Final remediation goals:
- Determined when the remedy is selected.
- Based on the balancing of criteria in the remedy
selection process.
Remediation goals: risk assessment vs. ARARs;
- EPA will use chemical-specific/health-based ARARs in
determining remediation goals for SF sites.
- Exceptions:
1) ARARs are not sufficiently protective:
multiple contaminants or pathways where attainment
of chemical-specific ARARs will result in
cumulative risk in excess of 10-4(p. 8718, p.
8848),
2) No ARARs are available.
In these exceptions, risk assessment will be used when
determining the cleanup level.
- 10-6 is the point of departure for establishing
preliminary remediation goals.
15
-------
- Acceptable exposure levels: 10-4 to 10-6 incremental
individual lifetime cancer risk, with a preference for
the more protective end of the range.
- Cleanups to levels more stringent than 10-6 allowed
in exceptional circumstances, (page 8716 and 8717)
- Cleanup level and remedy are selected by balancing
site-specific and remedy-specific factors, including:
- exposure factors
- assumptions and uncertainty factors
- technical factors
- the nine criteria.
Similar approaches are used for non-carcinogens and
ecological and environmental effects.
Non-carcinogens - exposures should present no
appreciable risk of significant adverse effects to
individuals.
Environmental evaluations may be necessary where
sensitive ecosystems and critical habitats of
threatened or endangered species exist.
16
-------
GROUNDWATER AND SURFACE WATER ISSUES
NCP Section 300.430(e)(2)(i) - page 8848 (MCLs vs.
MCLGs)
Preamble - pages 8732 - 8735
MCLs and MCLGs - pages 8750 - 8752
point of compliance - pages 8753 - 8755
Goal: return usable ground waters to their beneficial uses
within a timeframe that is reasonable given the particular
circumstances of the site.
Role of the draft EPA groundwater classification system:
- help set the remediation goal for groundwater restoration,
the timeframe for restoration, and most appropriate method
to achieve these goals.
- THESE GUIDELINES ARE NOT ARARS, BUT ARE ONLY USED TO HELP
DEFINE SITUATIONS FOR WHICH STANDARDS MAY BE APPLICABLE OR
RELEVANT AND APPROPRIATE AND HELP SET GOALS FOR GROUNDWATER
REMEDIATION.
- State or Indian tribe's classification may supersede.
Restoration timeframes:
-reasonable timeframes may range from very rapid (one to
five years) to relatively extended (perhaps several
decades.)
- Rapid restoration is preferred for Class I groundwaters or
current drinking water sources. If there are alternative
drinking water sources, the necessity for rapid restoration
of groundwater may be reduced.
- Rapid restoration may also be appropriate when
institutional controls are not reliable.
Remediation goals: MAJOR POLICY CHANGE FROM THE PROPOSED NCP.
For class I and II groundwaters:
- If MCLG is above zero, MCLG may be relevant and
appropriate. If MCLG is not relevant and appropriate
to the circumstances of the release, the corresponding
MCL may be relevant and appropriate.
- If MCLG is zero, EPA has determined that the MCLG is
not appropriate. The MCL may be relevant and
appropriate, considering the circumstances of the
release.
- MCLs are never applicable except at the tap.
For class III groundwaters:
-drinking water standards are not ARARs and are not
used to set preliminary remediation goals.
For surface water:
- MCLs and non-zero MCLGs will generally be the
relevant and appropriate standards for surface water
designated as a drinking water supply, unless the state
has promulgated water quality standards for the water
body that reflects the specific conditions of the water
17
-------
body.
-The Federal Water Quality Criteria should not be used
to substitute for MCLs and non-zero MCLGs, but may be
used when there are other uses of the water (e.g.
aquatic organism, fishing) or when there are no MCLs.
Alternate concentration limits (ACLs) under CERCLA:
- Use of ACLs is limited under CERCLA.
- In addition to the statutory limitations, the preamble
adds the demonstration that cleanup to MCLs or other
protective levels is not practicable.
- If a site situation qualifies for an ACL, an additional
ARAR waiver of MCLs or MCLGs is not necessary.
Point of Compliance for Groundwater:
- remediation levels should generally be attained
throughout the contaminated plume, or at and beyond the
edge of the waste management area when waste is left in
place.
- alternate points of compliance may be
acceptable/protective when:
- the plume of groundwater contamination is from
several distinct sources that are in close
geographic proximity. Can then address the
problem as a whole, but individual source control
actions still required.
- NEW - A remote site with little likelihood of
exposure. However, contaminated groundwater must
be controlled from further migration.
Natural attenuation:
Natural attenuation is recommended only when:
- active restoration is not practicable, cost-effective
or warranted because of site-specific conditions, or
- where natural attenuation is expected to reduce the
concentration of contaminants in the groundwater to the
remediation goals in a reasonable timeframe, or in a
timeframe comparable to that achieved through active
restoration.
- May also be important once pump and treat systems
have reached their limit. (E.G. as an alternative to
changing the remediation goals.)
- Institutional controls may be necessary.
Remember too the management expectation mentioned above:
when groundwater restoration is not practicable, remedial action
will focus on plume containment to prevent contaminant migration
and further contamination of the groundwater, prevention of
exposures, and evaluation of further risk reduction.
18
-------
At Fund-lead sites, who pays for operating the groundwater and
surface water facilities?
- Complex.
- State pays for O&M of source control measures.
- Fund pays 90% for up to 10 years of certain ground and
surface water restoration measures.
- Exception: Certain interim measures. EPA will consider
interim measures to be "remedial actions" if it is both
necessary and desirable in order to control or prevent the
further spread of contamination while the lead agency is
deciding upon a final remedy for the site. (preamble pages
8736 - 8740)
COMMUNITY RELATIONS
NCP Section 300.415(m) - CR in Removal Actions, page 8842
300.430(c) - CR during the RI/FS, page 8847
300.430(f)(2) and (3) - Proposed plans and
CR to support remedy selection, page 8851
300.430(f)(6) - CR when the ROD is signed, page
8852
300.435(c) - CR during RD, RA, and O&M, page
8852
300.700(c)(6) - CR during private party actions,
page 8858
Preamble pages 8766 - 8774
- No major changes in the way we do business.
Exception:
Comment periods on time-critical and non-time
critical removals are a minimum of 30 days. For
non-time critical removals, the lead agency will
extent the public comment period by a minimum of
15 days upon timely request.
Comment period on the proposed plan, etc, is a
minimum of 30 days, with an extension of the
public comment period by a minimum of 30
additional days upon timely request.
- Community relations starts at the pre-remedial stage and
continues throughout the remedy construction and operation.
Community relations does not stop at the ROD.
- Includes sections on PRP involvement, community
involvement in technical discussions with PRPs, equal
community and PRP access to information on the site.
If private party actions want to be "consistent with the
NCP" for cost-recovery purposes, they must also follow many
of these same community relations/public involvement
activities, (preamble page 8795)
19
-------
REMOVALS
NCP Section 300.415 (pages 8842 - 8844)
Preamble pages 8694 - 8698
Very few changes to the removal program in the NCP.
Main changes are:
- Clarifies community relations and administrative
record requirements
- ARARs apply to the extent practicable!
- Codifies statutory increase of time and dollar limits
to 12 months and $2 million.
OUT-OF-STATE-TRANSFER OF CERCLA WASTE
Preamble page 8740
(Not in the NCP proper)
If SF waste is going to be shipped out-of-state, e.g. to a
permitted waste management facility, the lead agency should
provide written notice to the receiving state prior to shipment
of the SF wastes, Notice should be provided for all remedial
actions and non-time critical removal actions, including Fund-
lead, state lead, federal facility and PRP responses.
20
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FY'89 Record of Decision Analysis
Region V Comparison
Table 1. Definition of Principal and Low-level Threats in Final
Source Control RODs
Principal Threats
RODs clearly defining principal threats
RODs providing volumes of the contaminants
RQDs providing concentrations of the contaminants
Low-level Threats
RQDs clearly defining low, but significant, long-term threat
RODs providing volumes of the contaminants
RODs providing concentrations of the contaminants
Table 2. Documentation of Site Risks in Final Source Control
RODs
CO
II
II
Number of Region V FY'89 Final Source Control RODs = 22
Total number of FY'89 Final Source Control RODs = 85
« c
18
si
RODs identifying populations at risk
RODs identifying current land use
RODs identifying future land use
RODs providing carcinogenic risk or hazard indices for the pathway-specific
risk
RODs providing carcinogenic risk or hazard indices for the population
groups at risk
RODs identifying reasonable exposure pathways
RODs identifvina basic toxicitv information
RODs documenting how the baseline risk relates to the risk range
RODs documenting environmental exposures
RODs providing statement on imminent and substantial endangerment in
summary of site risk section
RODs including description of the initial risks for a pathway or population in
description of alternatives section
RODs providing risk reduction for each alternative
RODs providing risk levels corresponding to cleanup goals in the description
of the selected remedy
73
86
32
59
55
95
55
68
41
82
27
59
59
72
91
38
54
49
89
44
66
44
27
28
46
44
-------
FY'89 Record of Decision Analysis
Region V Comparison
Table 3. Alternatives Description and Comparative Analysis
in Final Source Control RODs
eo
c
RODs fully tracking all identified wastes, including residuals
RODs providing a comparative analysis that uses the nine criteria consistent
with NCR definitions
73
91
66
86
Table 4. ARARs Identification (LDR, RCRA Waste, Closure,
Endangered Species Act, State ARARs) in Final
S«urce C«ntr»l Rtis
li si
n »&
DC S
RODs documentina kev ARARs
RODs documentina whether the waste is RCRA waste
RODs providing a determination of LDR as an ARAR
RODs documenting RCRA closure requirements for actions that involve
capping, excavation, or disposal
RODs identifying the Endangered Species Act as an ARAR at sites where
endangered species may be encountered
RODs addressing State ARARs
RODs highlighting that each alternative meets ARARs in the comparative
analysis of alternatives
RODs documenting that the selected remedy complies with ARARs in the
statutory determinations.
RODs listing and describing the ARARs that will be attained
59
55
50
68
0
86
77
95
77
52
49
51
55
25
86
73
93
68
Number of Region V FY'89 Final Source Control RODs = 22
Total number of FY'89 Final Source Control RODs = 85
-------
FY'89 Record of Decision Analysis
Region V Comparison
Table 5. Description of Selected Remedy in Final Source Control RODs
§0)
o
II
RODs providing remediation goals
RODs providing points of compliance for each medium
RODs documenting the method for managing residuals
RODs providing the rationale for remedy selection in terms of the five
primary balancing criteria
59
55
55
82
62
33
48
71
Table 6. Consistency with Program Expectations in Final
Source Control RODs
E 1
08
II
RODs documenting treatment of principal threats
RODs documenting use of engineering controls for low-level waste
RODs documenting use of engineering controls as the primary component
of the remedy
RODs including institutional controls in the remedy
RODs using institutional controls as the primary component of the remedy
RODs selecting a combination of treatment with engineering controls and
institutional controls
RODs selecting innovative treatment technologies*
100
44
36
64
0
45
53
100
67
24
58
0
41
54
Number of Region V FY'89 Final Source Control RODs = 22
Total number of FY'89 Final Source Control RODs = 85
* Total number of FY'89 Final Source Control Treatment RODs = 69; information obtained from FY'89 Annual Report
-------
FY'89 Record of Decision Analysis
Region V Comparison
Table 1. Documentation of Site Risks in Final
Ground Water RODs
c =
Is
II
!§
II
RODs providing current use of water
RODs providing potential beneficial use of water
RODs identifying populations at risk
RODs identifying the reasonable exposure pathways affecting each
population group identified
RODs identifying the GDI factors
RODs identifying the exposure assumptions
RODs identifying the basic toxicity information
RODs identifyina the pathway-specific cancer risk or HI
RODs identifying the population risk or HI
RODs documenting how the baseline risk relates to the risk range
RODs documentino. consideration of environmental exposures
100
100
92
100
23
46
38
62
38
77
46
100
96
83
91
20
35
44
67
43
72
56
Table 2. Alternatives Description and Comparative Analysis
in Final Ground Water RODs
c =
I 8
c c
5!
0>
Q.
RODs identifying the ground water classification
RODs identifyina remediation goals to be achieved in the around water
RODs identifyina the timeframe for restoration
RODs providina for monitoring the ground water after the system is shut off
RODs identifying the area of attainment
RODs fully describing the waste movement to final destination
RODs usina the nine criteria consistent with NCR definitions
23
77
62
38
54
77
100
46
76
76
47
56
63
91
Number of Region V FY'89 Final Ground Water RODs = 13
Total number of FY'89 Final Ground Water RODs = 54
-------
FY'89 Record of Decision Analysis
Region V Comparison
Table 3. ARARs in Final Ground Water RODs
I?
I 8
EC S
§8
II
RODs identifying State ARARs
RODs identifying whether the waste is a RCRA waste
RODs documenting a determination of LDR as an ARAR
RODs highlighting whether each alternative meets ARARs in the
comparative analysis
RODs documenting that the selected remedy complies with ARARs in the
statutory determinations
RODs listing and describing ARARs that will be attained
85
38
46
85
85
77
83
41
44
78
85
69
Table 4. Selected Remedy in Final Ground Water RODs
co *:
!§
>
1 =
c d)
O O
co 9*
RODs providing the treatment level for the extracted ground water
RODs providing the remediation goal for the selected remedy
100
100
100
87
Number of Region V FY'89 Final Ground Water RODs = 13
Total number of FY'89 Final Ground Water RODs = 54
-------
FY'89 Record of Decision Analysis
Region V Comparison
Table 5. Statutory Determinations in Final
Ground Water RODs
c =
5? fl>
O Q
II
RODs stating the rationale for remedy selection in terms of the nine criteria
85
37
Table 6. Consistency With Program Expectations in
Final Ground Water RODs
c =
Is
II
18
is,
RODs documenting use of institutional controls as part of the remedy
RODs documenting use of institutional controls as the primary component of
the remedy
RODs discussing the expectation to restore ground water to its beneficial
uses within a reasonable period of time
RODs discussing the uncertainty related to ground water restoration
timeframes and cleanup levels
RODs selecting innovative treatment technologies*
77
0
62
46
7
72
2
57
57
8
Number of Region V FY'89 Final Ground Water RODs = 13
Total number of FY'89 Final Ground Water RODs = 54
* Total number of FY'89 Final Ground Water treatment RODs = 62; information obtained from FY'89 ROD Annual Report
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FY'89 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 1. Documentation of Threats at Final Source Control RODs
en
o
f
I
o
100-1
80-
60-
40-
49
20-
Principal and Low-Level Threats
N.as~]
-------
FT89 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 2. Documentation of Risks at Final Source and Final Ground Water RODs
Final Source
Control:
(0
Q
8
g
80 -i
60-
Rlsk Assessment
Final Ground
Water:
CD
Q
§
f
I
I
N.54
100n
80-
60-
40-
20-
Risk Assessment
-------
FY89 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 3. Documentation Findings at Final Source and Final Ground Water RODs
Final Source
Control:
I
•3
I
I
2
100-1
80-
60-
40-
20-
Record of Decision Documentation Sections
Final Ground
Water:
I
"8
V
80-
60-
40-
20-
ftO° *
N- 54
Record of Decision Documentation Sections
-------
Compendium Of Examples
from
FYf89 Records of Decision
1. Declaration
2. Site Description, Site History, Community Relations
3. Scope and Role of Operable Unit
4. Summary of Site Characteristics
5. Summary of Site Risks
6. Description of Alternatives
7, Comparative Analysis
8. Selected Remedy
9. Statutory Determinations
10. Responsiveness Summary
11, State Letter of Concurrence
Office of Emergency and Remedial Response
Office of Waste Programs Enforcement
May 1990
-------
INTRODUCTION
Sections 113 and 121 of CERCLA require that the Agency issue a final remedial action
plan, known as the Record of Decision (ROD). It may include the basis and purpose for the
selected remedy and certain public notification and involvement activities which must occur
to provide opportunity for the public discussion of the information.
The ROD documents the remedial action plan for a site or operable unit. It is prepared
by the lead agency in consultation with the support agency(ies). It has three purposes:
• legally certifies that the remedy selection process was carried out in
accordance with the requirements of CERCLA and, to the extent practicable, the
NCP
• outlines the engineering components and remediation goals of the selected
remedy
• provides the public with a consolidated source of information about the site ,
the cleanup alternatives considered and the rationale for the one selected.
The ROD has three major components: the Declaration, the Decision Summary and the
Responsiveness Summary. Good examples of each section will be presented in this portion of
the handbook. They can serve as illustrative models for remedial Project Managers
responsible for preparing RODs in FY90.
The primary criteria used to compile these examples were:
1) Whether the sections followed the format and contained the appropriate
contents suggested by the "Guidance in Preparing Superfund Decision
Documents (ROD Guidance)" OSWER Directive 9355.0.
2) Whether the sections were clearly written and effectively presented.
3) Whether the sections appropriately reflect current Superfund program policy.
This compendium of examples reflects the fact that there is often more than one way to
present similar information, and the level of detail may appropriately vary from ROD to ROD.
However, some approaches are more effective than others and contain essential information
which should always be included in the ROD.
There were many good examples available for some sections of the ROD which
necessitated selecting a subset that would most effectively convey key concepts. For other
sections of the ROD, ideal examples were not available. It is important to read the comments
that introduce each set of examples to understand what each example is intended to
demonstrate.
-------
1. DECLARATION
The Declaration is a formal statement signed by the Regional Administrator
that identifies the selected remedy and indicates that the selection was carried out in
accordance with the statutory and regulatory requirements of the Superfund program.
EXAMPLE: CROSS BROTHERS FAIL, IL
This sample Declaration follows the guidance exactly by using the standard
language for each section. Under the statement of Basis and Purpose, the Declaration
Includes the appropriate references to CERCLA as amended by SARA, and the NCP
which is to be met "to the extent practicable".
Also, the administrative record is referenced as the basis of the decision but the
index is not attached. (It is no longer a requirement for the administrative record index
to be attached to the ROD.)
The Assessment of the Site section contains the necessary standard language
reflecting that the site may pose an endangerment. This standard language is
Important to include because it provides the necessary basis for Section 106
enforcement actions. Some RODs used alternative language which may or may not
accomplish the same legal purpose. Other RODs did not contain this section at all.
The selected remedy is effectively presented in a bullet fashion, explaining all
major treatment and containment components as well as institutional controls.
The Statutory Determination section contains the appropriate language that
indicates that the remedy will satisfy the statutory preference for treatment of a
principal treatment and that the five year review will be conducted because material
will remain on site above the health-based levels.
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CROSS BROTHERS PAIL, IL
DECIARATION FOR THE RECORD OF DECISION
SITE HAKE AND LOCATION
Cross Brothers Pail Recycling
Pembroke Township, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action
for the Cross Brothers Pail Recycling site developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative
record for the Cross Brothers Pail Recycling site.
The United States Environmental Protection Agency and the
State of Illinois agree on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present a current
or potential threat to public health, welfare, or the
environment.
DESCRIPTION OP REMEDY
This final remedy addresses remediation of groundvater and soil
contamination by eliminating or reducing the rislcs posed by the
site, through treatment and engineering and institutional
controls.
The major components of the selected remedy include:
0 R«-sampling of the localized PCS soil area to identify
th« existence of a PCS source.
0 If identified, remove the localized PCB-contaminated
soil area and incinerate the soils at a TSCA approved
incinerator.
° Install and maintain a groundwater collection system
capable of capturing the groundwater contaminant plume,
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Install and maintain an on-site groundwater treatment
facility to remove contaminants from the collected
groundwater.
Install and maintain a soil flushing system for the
3.5 acres of contaminated soil within the disposal
area.
Instal- and maintain a 6 inch vegetative cover over
that portion of the disposal area not siibject to the
soil flushing operation.
Monitor the groundwater collection/treatment system and
the groundwater contaminant plume during groundwater
remediation activities.
Install and maintain a 6 inch vegetative cover over
the 3.5 acre area subject to soil flushing upon
terminating the soil flushing operation.
Install and maintain a fence around the site during
remedial activities.
Initiate a deed notification identifying U.S. EPA and
IEPA concerns regarding the conductance of intrusive •
activities at the site.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element. As this remedy will initially result in
hazardous substances remaining on-site above health-based levels,
a review will be conducted within five years after commencement
of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Valdas V. AdamXus£7 Date
Regional Administrator
U.S. EPA - Region V
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2. SITE DESCRIPTION, SITE HISTORY AND SUMMARY OF
ENFORCEMENT AND COMMUNITY RELATIONS
These sections of the ROD provide essential background information on the site
so the physical, enforcement and public participation context of the site can be properly
understood.
EXAMPLE: PREFERRED PLATING, NY
The sample illustrates how the necessary information can be provided clearly
and succinctly.
In the Site Location and Description sections note the reference to the fact that
no endangered species or critical habitats have been identified and the proximity of
wetlands to the site. These items should be included in all RODs to reflect that
appropriate assessments have been made.
The Site History and Enforcement Activities section effectively summarizes the
activities that caused the problem, the site investigations conducted to date, and
pertinent enforcement information.
The Community Relations Activities section provides a brief overview of key
public participation activities undertaken to fulfill the requirements of CERCLA
Section 113 and 117.
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PLAITING, NY
r5ITE LOCATION AND DESCRIPTION
The Preferred Plating Corporation Site (the "Site") is located at 32
Allen Boulevard in Farraingdale, Town of Babylon, Suffolk County, New
York. This 0.5-acre Site is situated in a light industrial area
approximately 1 mile west of the Nassau-Suffolk County border. Route
110 passes just west of the Site (see Figure 1).
The land to the east and west of the Site is occupied by commercial
or light industrial properties. Immediately north of the Site is a
large wooded area followed by various industrial facilities further
north of that. To the south are a residential community and a U.S.
Army facility.
The 1980 census records a population of greater than 10,000 within a
3 mile radius of the Site. The population density in the area is
estimated to be 3,000 to 6,000 persons per square mile. All homes
and businesses, in the area surrounding the Site, are supplied by two
public water companies. Ground water is the source of water supplies
for the entire population of both Nassau and Suffolk Counties. All
public water supply wells in the Site area draw water from the deeper
aquifer, the Magothy Aquifer. The nearest public water supply well
fields are located approximately l mile east and 1 mile south of the
ite.
he nearest body of surface water is an unnamed intermittent
tributary of Massapequa Creek which is approximately 6000 feet west
of the Site. There is no designated New York State Significant
Habitat, agricultural land, nor historic, or landmark site directly or
potentially affected. There are no endangered species or critical
habitats within close proximity of the Site. The Site is located
more than 2 miles from a 5-acre coastal wetland and more than 1 mile
from a 5-acre fresh-water wetland.
The Site is situated in the south-central glacial outwash plain of
Long Island, which constitutes the Upper Glacial Aquifer, estimated
to be 90 feet in thickness under the Site. The naturally-occurring
surface soil is a sandy loam which promotes- rapid infiltration to the
ground water. On the Site proper and throughout much of the region,
soils have been classified as urban. This is primarily due to the
development and pavement which promote greater run-off of
precipitation. The Upper Glacial Aquifer overlies the Magothy
Aquifer and the two may act as distinct aquifers, or as one,
depending upon the degree of hydraulic connection between the two.
In the Site area, it is believed that the two are not hydraulically
connected.
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-2-
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Preferred Plating Corporation (PPG) conducted operations
beginning in September 1951 through June 1976. The primary
activities at the Site were to chemically treat metal parts to
increase their corrosion resistance and provide a cohesive base for
painting. The plating processes included degreasing, cleaning, and
surface finishing of the metal parts. These processes involved the
use of various chemicals which resulted in the generation, storage,
and disposal of hazardous waste. Untreated waste water was
discharged to four concrete leaching pits directly behind the
original building.
Ground water contaminated with heavy metals was detected in the Site
area by the Suffolk County Department of Health Services (SCDHS) as
early as June 1953. SCOHS indicated that the leaching pits on the
Site were severely cracked and leaking. Samples taken from the pits
showed the major contaminants to be heavy metals. From 1953 to 1976,
SCDHS instituted numerous legal actions against PPC in an effort to
stop illegal dumping of wastes and to install or upgrade the on-site
treatment facility. PPC prepared an engineering report in May 1974
in order to apply for a State Pollutant Discharge Elimination System
(SPDES) permit which was issued in June 1975. PPC chemically treated
the waste water in the pits and, allegedly, then had the treated
waste water removed. Whether the treated ground water was ever
removed has not been confirmed by EPA. The facility was never in
full compliance with the terms and conditions outlined in the permit.
In 1976, PPC declared bankruptcy. Since then, several firms have
occupied the Site, none conducting similar operations to PPC. In
1982, the original building was extended by 200 feet, thereby burying
tne concrete leaching pits. Nearly the entire Site is covered either
by the one existing building or paved driveways and parking areas.
In September 1984, Woodward-Clyde Consultants, Inc. performed a Phase
I-Preliminary Investigation of the Preferred Plating Site for NYSDEC
for the purpose] of computing a Hazard Ranking System (HRS) score
needed to evaluate-whether to place.the Site on the National
Priorities List (NPL). In the Phase I report, an HRS score of 33.76
was documented, thereby enabling the Site to be included on the NPL.
on October 15, 1984, (49 FR 1984), the Site was proposed toe the NPL
and was added with a ranking of 500 on June 10, 1986, (51 FR 21054).
At EPA1s direction, a remedial investigation (RI) was initiated in
1987. The RI consisted of a field sampling and analysis program
followed by validation and evaluation of the data collected. The
field work was initiated in June 1988 and completed in February 1989.
The work was conducted by EPA's REM III contractor, Ebasco Services,
Inc. The soil sampling program"involved the determination'of lateral
vertical extents of contamination by obtaining samples from six
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-3-
wn-site monitoring wells, two off-site monitoring well locations, six
surface soil locations, and seven angle borings which extended
underneath the on-site building overlying the former leaching pits.
The groundwater sampling program involved the installation of nine
on-site and two off-site monitoring wells. In addition, two storm
water run-off samples and two sediment samples were collected from
on-site storm sewers.
The potentially responsible parties (PRP's) were notified in writing
on February 12, 1988 via a special notice letter and given the
opportunity to conduct the RI/FS under EPA supervision. However,
none elected to undertake these activities.
In July 1989, Ebasco's remedial investigation (RI) and feasibility
study (FS) reports were released to the public along with the
Proposed Remedial Action Plan (PRAP) developed by EPA. A 28-day
public comment period was provided, ending on August 18, 1989.
COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Preferred Plating Site was
finalized in March 1988. This document lists contacts and interested
parties throughout government and the local community. It also
jtablishes communication pathways to ensure timely dissemination of
ftinent information. Subsequently, a fact sheet outlining the RI
ipling program was distributed in June 1988. The RI/FS and the
Proposed Plan were released to the public in July 1989. All of these
documents were made available in both the administrative record and
two information repositories, maintained at the Babylon Town Hall and
the West Babylon Library. A public comment period was held from July
19, 1989 to August 18, 1989... In addition, a public meeting was held
on August 3, 1989 to present the results of the RI/FS and the
preferred alternative as presented in the Proposed Plan for the Site.
All comments which were received by EPA prior to the end of the
public comment period, including those expressed verbally at the
public meeting, are addressed in the Responsiveness Summary which is
attached, as Appendix V, to this Record of Decision.
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3. SCOPE AND ROLE OF OPERABLE UNIT
This section should describe the role of the remedial action within the overall
site cleanup strategy and summarize the scope of the problems to be addressed b y the
remedial action selected. It should identify whether the action will address s any of the
principal threats posed by the site.
EXAMPLE: CHEMICAL INSECTICIDE, NJ
This sample thoroughly describes past response actions, how they provided
protection and the remaining threat and pathways. It also explains how this interim
action ROD will provide additional controls, why EPA chose to address the site in
operable units, and describes the principal threat addressed, (this provides the basis for
the statutory determination made later in the ROD as to whether the remedy satisfies
the preference for treatment of a principal threat.) Future response actions are briefly
described as to their scope, the media they will address, and how they will mesh with
this ROD. It also characterizes when a final remedy may be expected.
EXAMPLE: WAUSAU WATER SUPPLY, WI
This example illustrates how this section might work for a final action ROD and
also does a good job of explaining how the principal threats are being addressed.
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The CIC site, as characterized by the RI field investigations, is
•xtr«m»ly complex, due to the number *nd variety of contaminants
present, the concentrations of contaminant* documented, and the
physical and geological characteristics of the site. The specific
combination of chemical contaminants at the CZC site (herbicides,
pesticides and aetals) will require performance of treatability
tests prior to identification of alternatives to remedy the entire
site. Preparation of an TS report which addresses all aspects of
the CIC site requires performance of the proposed treatability
tests and assessment of the results. Such treatability tests are
in the planning stag*.
EPA has already taken tvo limited response actions related to the
surface water run-off problem at the site. The first action in
February of 1988 vac to install a fane* to prevent access to the
contaminated liquids and sediments in the drainage ditch east of
the CIC property. The second action in March of 1989 was to clean
up the overflow from the drainage ditch to the Metroplex parking
lot and to improve the ditch to reduce the likelihood of future
overflows. The surface watsr run-off during this overflow incident
had a yellow color that is characteristic of standing water at the
southern end of the CZC property. This yellow color is attributed
to dinoseb, an herbicide which has been found in samples of
standing water from the southern and of the sit* and in water
samples from the drainags ditch and parking lot during the overflow
incident. Dinoseb is known to produce a yellow color when
dissolved in watsr.
These limited response actions have only partially addressed tn«
surface water run-off problem in that the surface water run-off
would continue to migrate to downstream waterways (i.e. the unnamed
tributary, Mill BrooJc and the Raritan River), with potential for
harm to the environment and for human exposure.
In this ROD, EPA is selecting an interim remedial action to control
contaminated surface water run-off from the CIC site until the time
that the FS addressing all aspects of the CZC sits is finalized and
the resulting ROD is implemented. This action will be the first
operable unit (i.a., the first clsanup phase) of the remediation
of the entire sits. EPA has elected to address the surface water
run-off problem as the first operable unit because of the threat
posed by the surfaca water run-off (see Section 2, above) and
because sufficient information is available to salect an
appropriate remedy for this problem. This action will focus on one
of the principal threats presented by the sits, that of the
contaminated surface water run-off.
One or more futurs RODS will address the remaining problems
presented by the sits, including the contamination of soil and
groundwater. It should be noted that one* the contaminated soil
at the sits has bean affectively remediated, the surfaca water run-
off from the sits would no longer become contaminated by contact
with the soil. As a result, the rsmady selected in this ROD would
no longer ba needed after the contaminated soil is clsanad up.
Therefore, the remedy selected in this ROD is considered to be an
interim remedy which can be discontinued once a remedy for the soil
contamination has been implemented. EPA expects to be in a
position to select a remedy for the soil contamination after
treatability studies for the contaminated soils are conducted and
after the results of the studies have been analysed and
incorporated in a FS.
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WMEMJ WMDBR 3OPPLX, WI
IV. SCOPE AJ*D R?LP Of RESPONSE ACTION
The scop* of this response action is to address the remaining
concerns (principal threats) at the site. As discussed, a
previous operable unit action at the site addresses the
contaminant plume originating from the former landfill/Marathon
Electric source area which affects CW6.
During development of the final PS, it was determined that the
deep plume which originates from the former City landfill area
and migrates under the River to CW3 would best be addressed by
purging groundwater at the same location as the interim remedy
extraction system. Therefore, it was determined that an increase
in the minimum pumping rates called for in.the extraction system
and modifications to the monitoring plan would provide the most
effective remediation for this contaminant plume. It was also
assumed that the City would continue to use CW3 as a supply well
and thus continue to remove contaminants from the most eastern
portion of the pit
The selected alternative for the final phase of the Wausau
project, in conjunction with the operable unit, will address all
concerns at the site. Remaining concerns include three source
areas and the shallow east side groundwater contaminant plume
originating from the Wausau Chemical source area. The identified
source areas include; former City landfill/Marathon Electric
property, Wausau Chemical property, and Wausau Energy property.
The final remedy for the site is intended to address the entire
site with regards to the principal threats to human health and
the environment posed by the site as indicated in the risk
assessment for the site. The findings of the risk assessment are
included in the RI Report and are summarized in a later section
of this document.
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4. SUMMARY OF SITE CHARACTERISTICS
This section should highlight all known or suspected sources of contamination,
affected media and the characteristics of the contamination such as the mobility,
toxicity, the volumes and concentrations, and location at the site. Also, it should
identify potential routes of migration and potentially exposed populations.
EXAMPLE: BYRON BARREL AND DRUM, NY
The first example demonstrates how site characteristics can be summarized in a
narrative format. Although this summary does not explicitly delineate material
comprising principal versus low-level threats, it does a good job of identifying the
location of different contaminants and their associated concentrations and volumes.
This helps establish a clear basis for the types of remedial alternatives developed.
EXAMPLE: NORTHWEST TRANSFORMERS, WA
The second example provides a good model for explaining the characteristics of
PCBs, the primary contaminant at this site, and the potential migration pathways.
EXAMPLE: WAUSAU WATER SUPPLY, WI
The third example illustrates how a table can provide an efficient vehicle for
conveying great amounts of information. This particular table includes contaminated
media, contaminants found, concentrations (high, low, geometric mean), and the
number of samples.
The first example states the concentrations, volumes, depths of contaminants
in each media, potential migration pathways, and some characteristics of the
contaminants. The contaminants of concern and sampling locations are also laid out
well in two tables.
This section should also clearly state the characteristics (whether they are toxic,
mobile, carcinogens, etc.), potential populations affected, and exposure pathways. Not
all the RODs included had volumes, pathways, and areas affected.
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BYRCN BARREL AND DRUM,
SUMMARY OP SITE CHARACTERISTICS
Approximately 200 55-gallon steel barrels that were filled with
hazardous waste were abandoned at the Byron Barrel and Drum site
from 1978 to 1980, when the site was used as a salvage yard for
heavy construction equipment. Leakage and spillage from these
drums appears to have been the primary source of contamination of
the site. The drums and their contents were removed from the site
by EPA in 1984. In addition, approximately 40 cubic yards of
visibly-contaminated surface soil and debris were removed from the
site during the same period.
Analyses of soil, groundwater, sediment, and surface water from
the site and adjacent areas indicate that the environmental
contamination at the Byron Barrel and Drum site consists primarily
-------
of subsurface soil and groundwater contamination. Based on the
absence of substantial soil contamination, it appears that the EPA
removal action was effective in reducing contaminant releases.
Chlorinated aliphatic hydrocarbons such as 1,1,1-trichloroethane,
1,1-dichloroethane, trichloroethene, and 1,1-dichloroethene are the
primary contaminants. Various monocyclic aromatics such as toluene
and xylenes were also detected, although groundwater contamination
with these substances is minimal when compared to the contamination
with chlorinated species.
SURFACE SOIL
A total of 25 surface soil samples were collected during the field
investigation at the locations shown in Figure 3. The locations
were selected based on the results of the soil-gas investigation
and historical information. Of the 25 samples, 21 were collected
on-site, and 4 were collected off-site to provide background
information. Surface soil samples were collected to provide the
necessary data to assess the risks posed by dermal contact, as well
as to provide information on potential contamination migration via
surface-water erosion of soil.
Surface soils at the Byron Barrel and Drum site contain only low
levels of volatile organics (less than 50 parts per billion (ppb))',
phthalate esters (less than 600 ppb), polynuclear aromatic
hydrocarbons (less than 300 ppb), and benzoic acid (less than
500 ppb). By contrast, much higher concentrations of various
pesticides, such as 4,4'-DDT, 4,4'-DDE, endrin, and dieldrin, were
encountered. The highest concentrations of the pesticides were
detected in surface soil samples which were collected from the
adjacent farmland. On-site samples containing pesticides were
obtained in proximity to the agricultural land and are believed to
be present as a result of atmospheric transport of pesticides
during their application to crops. Figure 3 summarizes the
volatile organics detected in surface soil samples.
Although chromium and lead were detected in site surface soils
above background, contamination with these substances is not
pronounced. Figure 4 presents the analytical results for surface
soil samples containing chromium and lead above background levels.
As is evident from the Figure 4, chromium and lead contamination
is greatest in Source Area 3.
Based on the results of a surface soil sampling program in Source
Area 3, it is estimated that there are 1,100 cubic yards of
contaminated soil in this area.
SUBSURFACE SOIL
As shown in Figure 5, test pits and trenches were dug at 46
locations, from which a total of 130 subsurface samples were
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collected for analysis. No drums were detected in any of these
test pits.
As shown in Figure 6, volatile organics were detected in subsurface
soil samples at concentrations ranging from 5 ppb to 2,669 ppb.
The most pronounced contaminants based on the mobile laboratory
results are toluene, l, i, 1-trichloroethane, and trichloroethane.
Concentrations of these ranged as high as 865 ppb, 551 ppb, and
2,669 ppb, respectively.
Twenty subsurface soil samples were also obtained. As can be seen
by the analytical results summarized in Table 1, volatile organics
are the primary contaminants detected, and toluene and
trichloroethene were detected at relatively high concentrations
(2,700 ppb and 2,800 ppb, respectively). In addition, several
other volatile organics, notably xylenes and tetrachloroethene
(PCE), were detected at high concentrations. Xylene concentra-
tions ranged as high as 1,700 ppb, while PCE concentrations ranged
as high as 4,400 ppb. All of these samples were collected from the
southwestern portion of Source Area 1. In addition, phthalate
esters were detected in several samples at concentrations ranging
as high as 2,000 ppb (di-n-butylphthalate) . Arochlor 1254 was
detected in one test pit sample at a depth of 4 feet. PCBs were!
detected in drum samples collected by the NYSDEC prior to the
removal action. The detection of PCS Arochlor 1254 at a
concentration of 690 milligrams per kilogram (mg/kg) indicates that
some release of PCBs occurred at the site. However, only one
sample from Source Area 1 contained a PCB compound, and the
available data indicate that PCB contamination is not extensive.
PCBs were not identified in any of the other matrices sampled at
the site (i.e., surface soil, sediment, groundwater, or surface
water).
Based upon the sampling results in Source Area 1, it is estimated
that there are 1,100 cubic yards of contaminated soil in this area.
The analytical results for subsurface soil samples obtained in
Source Area 2 are depicted in Figure 7. Subsurface soil samples
contained several chlorinated aliphatic hydrocarbons, including
1,1,1-trichloroethane, 1,1,2-trichloroethane, trichloroethene, 1,1-
dichloroethene, and methylene chloride. TCA concentrations ranged
as high as 410 ppb in these samples.
Based on the results of the subsurface soil sampling and analysis
program in Source Area 2, it is estimated that approximately 3,000
cubic yards of contaminated unsaturated zone soil exists in this
area.
Figure 8 depicts detections of chromium and lead above background
soil concentrations. From this figure, it is apparent that
subsurface contamination with these contaminants is not extensive
in any of the source areas.
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GROUNDWATER
The primary contaminant transport mechanism at the Byron Barrel
and Drum site is associated with groundwater advection of dis-
solved contaminants. Two contaminant plumes originating in the
vicinity of Source Areas 1 and 2 were noted to be migrating in the
downgradient direction to the northwest. No evidence of
contaminant migration toward residential wells to the southwest
was observed during the RI. Based on the analytical results for
monitoring well samples, it is apparent that these contaminant
plumes are confined to the immediate proximity of the source areas.
It is estimated that the contaminant plumes have migrated no
further than 400 and 300 feet from the Source Areas 1 and 2,
respectively. This phenomenon is a manifestation of the shallow
hydraulic gradient and the relatively recent time frame of disposal
activities (as late as 1982).
Four distinct rounds of groundwater sampling were conducted at the
Byron Barrel and Drum site. The first two rounds were conducted
during the course of the monitoring well installation
program. The second complete sampling round included analysis for
volatile organics. The analytical results for groundwater sampling
rounds 3 and 4 are summarized in Tables 2 and 3, respectively.
As shown in Tables 2 and 3, a number of volatile organic chemicals
were detected in site groundwater samples during the third and
fourth sampling rounds. Volatile organics detected frequently
and/or at high concentrations include 1,1,1-trichloroethane, 1,1-
dichloroethane, tetrachloroethene, trichloroethene, 1,1-
dichloroethene, and 1,2-dichloroethene. Concentrations of these
compounds ranged as high as 4,400 ppb, 290 ppb, 82 ppb, 3,300 ppb,
41 ppb, and 110 ppb, respectively. Of these compounds, all but
1,2-dichloroethene are considered major site contaminants. Only
one sample was found to contain 1,2-dichloroethene at a
concentration above 1 ppb, which is the sample mentioned above.
Methylene chloride was detected in one of three samples at a
concentration of 2.8 ppb.
Figures 9 and 10 summarize the results for the predominant site
groundwater contaminants for the third and fourth sampling rounds,
respectively.
In addition to the organic contaminants detected in site
groundwater samples, a number of inorganic constituents were
detected above background levels. Table 4 provides a summary of
the inorganic sample results for the upgradient monitoring well
(MW-4A) versus the site monitoring well samples. Chemicals
detected at concentrations significantly above background include
aluminum, arsenic, barium, calcium, chromium, cobalt, copper, iron,
lead, magnesium, manganese, mercury, nickel, potassium, sodium,
vanadium, and zinc. It should be noted that groundwater samples
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were not filtered prior to acidification. Hence, these results are
indicative of total inorganics in the water samples, including
those present in suspended solids. The average concentrations
presented in Table 4 indicate that there is little difference
between the overall site concentrations and background levels.
With the exception of sodium, mercury, and zinc, the average
background concentrations exceed the site average values. Figure
11 displays the results for chromium and lead detected above
background (upgradient) levels. Based on these results, it appears
that lead contamination exists in all source areas.
The analytical results for groundwater samples collected during
the supplemental activities are summarized in Figure 12.
Groundwater contamination consists of chlorinated aliphatics and
ketones. Organic contamination with 1,1,1-trichloroethane and MEK
is most pronounced. Concentrations of TCA ranged as high as 2,500
ppb while concentrations of MEK ranged as high as 3,000 ppb.
The estimated extent of the contaminant plumes originating from
Source Areas 1 and 2 is depicted in Figure 13. There is not a
contaminant plume originating from Source Area 3.
SURFACE WATER AND SEDIMENT
Surface water and sediment samples obtained from a drainage ditch
adjacent to the site property contained relatively low levels of
organic chemicals. There is no evidence of any downstream impact
on Oak Orchard Creek, the primary receiving surface water body.
Several sediment samples from another drainage ditch that runs east
to west, just north of the site, contained relatively high levels
of toluene, acetone, and MEK. However, based upon surface drainage
patterns and the absence of potential discharge of contaminated
groundwater to this drainage channel, it is not believed that this
contamination is site related.
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NCREEttEST TRANSPCI3MEIS, VJA
V. Site Characteristics
Contaminant Characteristics
The contaminant of concern at the NHT site is PCS, primarily Arochlor
1260. It is unlikely that free-flowing PCB-bearing fluids (I.e.,
transformer dielectrics) are still present at the site. PCB Is read'ly
adsorbed onto soil particles and does not easily leach from soil.
Adsorption of PCB Dy soil is related to tht organic content of a
particular soil type, and PCB recovered fro* soil Is found to concentrate
in the organic fraction of the soil media. The low water solubility and
low volatility of PCB also suggest that It is partitioned most heavily
into the organic fraction of soil. The rate of PCB movemtnt in saturated
soil has been found to be between one-tenth and one-hundredth the rate of
groundwater movement.
Affected Matrices Characteristics
For site management, stabilization, and cleanup purposes, the NHT site
can be divided into specific affected matrices.
The following discussion summarizes the characteristics and volumes of
each wttrlx that are relevant to the identification, screening, and
selection of remedial technologies and strategies.
S-11
The contaminant of concern in the soil Is PCB. The
tri-tetrachlorobenzenes were not included in analyses because these
more volatile compounas were not expected to oe persistent in
surface soils, especially considering the length of time between
EPA IRM and the RI sampling effort. The distribution of PCB
contamination in the surface soil is shown in Figure 2 (p.7). PC3
12
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contamination has seen shown to exist at levels exceeding
April 1985 IRH c'eanuo level of 10 opm (mg/kg) in two areas
area south of the Darn and 2) the former seepage pit a^ea
(Figure 2). "CB concentrations between 1 and 10 DDTI dig/kg) ex's:
in surface soil througnout tne site.
During the July '987 RI, shallow subsurface samoles were taken ^ron
2.5 and 5.0 feet be'ow ground Surface at selected locations. The
principal contaminant of concern in these samples was ?CB. The
tri-tetrachlorobenzenes were not detected in the samples. Resu'ts
indicated that PCS contamination generally decreased with seotn and
that the PCS levels were at or be'ow 1 ppm (mg/kg) btlcw tne deptn
of five feet. The PCS analytical data show concentrations at or
above 10 ppm (mg/kg) m tne area just south of the barn. Analytical
data indicate that below 2.5 feet some PCB concentrations are
between l ppm (mg/kg) and 5 ppm (mg/kg). PCB concentrations in tne
subsurface soil in the seeoage/septlc tank area range between 1 to
10 ppm (mg/kg) at a depth of 19 feet.
The volumes of soil within the ranges of PCB contamination reported
•n the FS are shown in Table 1.
The surface area of the site is approximately 70,000 square feet
(7,778 square yards) or approximately 1.6 acres.
Groundwater
There are two current primary PCB sources relative to groundwater
contamination beneath the NWT site and vicinity. First, historical
dumping of potentially high but undocumented concentrations of PCS
In the seepage pit may have resulted In significant PCS migration
into groundwater In tht past. This high level contamination could
act as a future source of groundwater contamination by PCB. The
current low level PCB soil contamination can be considered a second
source. Tht soil PCB contamination could act as a constant low
level source of groundwater contamination until the site 1$
remediated.
Based on the results of this RI and previous investigations. PCB
contamination In groundwater has not been adequately characterized
to assess tn« lifetime incremental cancer risk through ingestion of
contaminated water, nor have the groundwater flow patterns been
fully determined.
On-Slte Structure (Barn)
During the IRM. a significant amount of washing, rinsing, and
sandblasting of the surface of wooden structural members inside tie
barn was conducted: however, there is uncertainty as to the
effectiveness of tne decontamination of the deeper wood matrix of
the barn. Core samples of the wood must be analyzed for PCB before
all remediation alternatives, including the no action alternative.
can be evaluated for the barn.
13
-------
TABLE i NORTHWEST TRANSFORMER: ESTIMATED VOLUMES
ASSOCIATED WITH SURFACE SOIL CLEANUP LEVELS
RESIDUAL PCB
CONCENTRATION
(PPM)
40
32
24
16
10
8
5
1
EXCAVATION
DEPTH IN
10 PPM AREA
(ft.unm
0.0
0.5
1.0
1.5
1.9
2.0
2.2
2.5
VOLUME OF
SOIL FROM
10 PPM AREA
(eu.vd.Un
0
313
625
938
1,172
1,250
1,367
1,563
VOLUME OF
SOIL FROM
AREA BETWEEN
10 AND 1 PPM
(cu.vd.un
0
0
0
0
0
171
468 -
964
TOTAL
VOLUME OF
SOIL
(cu.vd.)
0
313
625
938
1,172
1,421
1,836
2,526
(1) See Figure 2 for Isoconcentratlon contours.
(2} Assumt that concentration dtcrtasts from surface (avg • 40 ppm) to 2.5
ft. depth (1 ppm) in a linear manner.
14
-------
Migration
Tht transport of the cnlor'nated contaminants in the environment 's
controlled by their onys'cal properties. Three potential pathways
of migration exist: grcundwater,"air, and surface water
The 3Ct9nt'al for airfcome migration of PC3 froC3 in soil -ndlcates that contaminants bind tightly to
the soils. Heavy vegetafon on the site virtually eliminates any
migration of contaminants on particulates generated from wind
erosion. If surface vegetation is removed, the resulting wind
dispersion of existing contaminated surface soils is not expected to
result in off-site PCB contamination greater than one mg/kg based on
results of background soils and on-sUe surface soils obtained In
July 1987.
Likewise, the potential for transport of PCS from the site via
surface water Is minimal. Due to the very high ptrmeablllty of the
soils at the site and relatively flat topography, surface water
runoff from the site 1s minimal.
It 1s for these reasons that the major potential pathway of
contaminant migration identified for this site 1s the regional
groundwater system. PCB is readily absorbed from water by solid
particles and only slowly leaches from soils. PCB has poor mobility
through saturated soil. Downward movement of contaminants would &e
effected very slowly by water infiltration from precipitation
coupled with sorptlon/desorptlon mechanisms based on contaminant
solubility. Rapid downward movement and horizontal migration would
only be suspected if large quantities of oil-soluble solvents were
allowed to percolate through the soil.
The highest potential for the downward migration appears to be in
the seepage pit area, where the excavated and caved area tends to
funnel precipitation. Review of previous investigations indicates
that unknown amounts of liquids were disposed of in this area of the
site by dumping Into the seepage pit. The construction of this pit
was such that liquids would step out to the surrounding formations.
'Sources of the liquids are not known but are suspected to include
some portions of the liquids generated on site. Unless large
quantities of solvents were dumped into the excavated area.
migration of PCB would not be expected to be significant.
-------
WMKMJ WftlER SUPPLY, WI
Cone!'
SURFACE SOILS
SURFACE WATER
Bos Creek
ChenncaJ
Metal/Cs
Iron
Manganese
Volat;1e
Methylene chloride
1,1, l-7ncnioroet,iane
Tetrachloroethene
Xylenes (total)
Senivolati ^
Phenol
4-Methylphenol
Benzoic acid
Naphthalene
Z-Hethylnaphthalene
Acenaphthy lene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Flouranthene
Pyrene
Butylbenzylphthalate
Benzo(a)ahtnracene
Bis(2-ethy1hexyl)pntha1ate
Chrysene
Oi-n-octylphthalate
Benzo b fluoranthene
Benzo k fluoranthene
Benzo a pyrene
IndenoH, 2. 3-cd) pyrene
Oibenz(a,h)anthracene
8enzo(g,h, i)perylene
Pesticide/PCB
Not Analyzed
Hetal/CN
Not Analyzed
» ' r • nun
UC/'.
557
1510
uqAq
«i
..
--
uc/kc
89
..
..
37
,32
2
51
38
100
2CO
32
200
150
59
110
150
390
..
250
..
100
210
230
"a xj mum
ue/L
5300
2920
uq/j(_q
ISO
3
3
4
uc/Va
93
200
ISO
720
770
110
69
180
120
2500
480
6600
2900
390
2400
1600
3200
380
5400
1600
2700
1200
390
1400
Geometric
Mean
uq/L
2110
2110
Ug/ltg
110
--
uq/Vo
90
..
..
192
264
22
59
82
109
651
155
1300
910
150
749
489
S6I
..
1380
604
614
655
ane*:
Volatile
1,2 Oichlonwthene (total)
Tnchloroethene
Tetrachloroethene
jeniivolati le
Not analyzed
Pesticide/PCB
Not Analyzed
Httal/CN
Not Analyzed
uq/L
1
1
1
uq/L
1
110
3
uq/L
1
41
2
Total
3
12
-------
fed
LANDFILL REFUSE
Chemical
Benzo blfluorantriene
Benzo k jfluoranthene
Benzo ajpyrene
Indeno(l,2.3-cd)pyrene
Oibenz(a,h)anthracene
Benzo(g,h, i)perylene
Not Analyzed
netal/CS
Copper
vc .atile
Methylene chloride
Acetone
1,2-Oichloroethene (total)
Trichloroethene
Toluene
Ethyl benzene
Xylenes (total)
Chemi
Minimum
110
100
120
130
'.
120
mq/kq
* •
uq/kq
„ 9
71
21
35
3
2
4
Table 2
(Continued)
cai Conc»"t
Maximum
680
760
750
680
74
800
me/kg
107
uq/kq
1900
160
220
160000
750
4
24
rat-cr
Geomet -• c
Mei-
220
210
250
22C
..
270
mq/kg
--
uq/kq
70
100
67
680
60
3
13
Seim volatile
Phenol
2-Chloroohenol
1,2-Dichlorobenzene
2-Methylphenol
4-Methylphenol
Isophorone
1,2,4-Trichlorobenzene
Naphthalene
4-Chloro-3-fliethy1 phenol
2-Methylnaphthaiene
2-Chloronaphthalene
Acenaphthy lene
Acenaphthene
Dibenzofuran
Fluorene
Pentachlorophenol •
Phenanthrene
Anthracene
Fluoranthene
fyrene
Butylbenzylphthalate
Benzo(a)antnracene
Bis(2-ethylhexyl)phthalate
Chrysene
uq/kq uq/kq
Benzo
Benzo
Benzo
fluoranthene
fluoranthene
pyrene
Indenofl,2.3-cd)pyrene
Oibenz(a,hjanthracene
8en2o(g.h. i)pery1ene
Pesticide/PCB
Arochlor 1260
uq/kg
..
..
..
..
..
..
..
49
..
65
..
..
45
19
82
820
170
19
60
63
130
420
110
54
410
430
480
640
280
560
uq/kq
850
2200
2200
210
75
830
130
1200
1300
2300
890
170
130
730
330
500
32000
15000
2200
45000
49000
2300
24000
54000
25000
25000
25000
25000
31000
1200
14000
ug/kq
2300
.
.
.
.
.
.
150
..
150
..
..
180
63
186
2900
1100
250
1600
1700
500
1400
860
970
1700
1400
1200
940
490
1600
uq/kq
1400
15
-------
5. SUMMARY OF SITE RISKS
The baseline risk assessment should be summarized In this section. It should
include both human health risks and environmental risks. This provides the rationale
for the lead agency's either undertaking a response action or taking no action
EXAMPLE: NORTHSIDE LANDFILL, WA
The example of the human health Site Risk section Includes well defined
sections which discuss contaminants of concern; exposure assessment including
exposure points and calculation of dose; toxicity assessment with separate discussions
of carcinogenic and noncarcinogenic criteria; characterization of carcinogenic and
noncarcinogenic risks; uncertainties and conclusions. The narrative is supported by
several tables on exposures, doses and cancer risk, and hazard index. The introduction
to each section states the parameters to be discussed such as population at risk, and
exposures. Terms such as Reference Dose, Chronic Daily Intake, No Observed Adverse
Effect Levels, and classes of carcinogens are defined. The basic methodology used to
arrive at the basic calculations are briefly explained. There is a great deal of
information provided but it is presented logically, systematically, and is fairly
readable. The result is a basic understanding of the actual and potential exposures,
populations, pathways and risk.
EXAMPLE: FAA TECHNICAL CENTER, NJ
The summary of Site Risk section in this ROD provides good tables that
concisely present appropriate risk information. Table 1 highlights contaminants of
concern, maximum and average concentrations and their frequency of detection in the
environmental media. Table 2 provides a good summary of the toxicity information
for these contaminants. The exposure assumptions are reported in an easy-to-read
manner in Table 3. Tables 4 and 5 should be abbreviated to report only those chemicals
with risks that are above or near the 10"^ level or with hazard indices near or above
one. We also recommend that the noncarcinogenic chemicals of concern not be
included on the table of carcinogenic risks.
EXAMPLE: MARATHON BATTERY, NY
The summary of Site Risks should discuss environmental risks, summarizing
the affects of contaminants on critical habitats and any endangered species.
This ROD also provides a discussion of bioassays conducted to determine
concentrations of contaminants which may affect aquatic organisms. It describes
sampling, levels of contaminants which would be protective of the environment, other
factors which will impact achievement of those levels. The State believes that there
may be an adverse ecological impact. Endangered species are identified and a
conclusion drawn about potential impact of the contamination on that species.
Pojff
c>l*,wic
-------
NCREHEHE IANDFJLLJL, VIA.
SUMMARY OF SITE RISKS
who
-------
FAA TECHNICAL CENTER, HJ
volume of contaminated groundwater is estimated to be 13.3
million gal Ions .
SL'.MMAqY OF SITE RISKS
A baseline risk assessment was conducted for Area D and is
presented in a document entitled, Baseline Risk Assessment, Site
D Jet Fuel Farm (TRC, June 1989). The risk assessment consisted
of hazard identification, a dose-response evaluation, exposure
assessment and risk characterization.
Selection of Contaminants of Concern
The hazard identification involved the selection of
contaminants of concern (COCs), detected contaminants which have
inherent toxic/carcinogenic effects that are likely to pose the
greatest concern with respect to the protection of public health
and the environment. Selected contaminants of concern at Area D
incl uaed :
Volatile Organic Contaminants
* Benzene
* Toluene
* Ethylbenzene
* Xylene
Base/Neutral and Acid Extractable Compounds
* Naphthalene
* Phenol
* 2-Chlorophenol
Metals
* Chromium
* Nickel
* Lead
The media in which these contaminants were detected and
associated concentrations are summarized in Table 1.
-------
Dose-Response Evaluation
The dose-response evaluation presented available human
health and environmental criteria for the contaminants of
concern, and related the chemical exposure (dose) to expected
adverse health effects (response). Included in this assessment
are the pertinent standards, criteria, advisories and guidelines
developed for the protection of human health and the environment.
An explanation of how these values were derived and how they
should be applied is presented below.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg/day)~±,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg/day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper-bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from huma.n
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects of humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The Office of Research and Development (ORD) has developed
Health Effects Assessments (HEAs) for 58 hazardous substances.
The intent of these assessments is to suggest an acceptable
exposure level whenever sufficient data are available. These
values reflect the relative degree of hazard associated with
exposure to the chemical addressed.
When possible, two categories of maximum dose tolerated
(MOT) have been estimated for systemic toxicants. The first, the
"Acceptable Intake Subchronic" (AIS), is an estimate of an
exposure level that would not be expected to cause adverse
effects under subchronic exposure. Limited information is
available on subhcronic exposure because efforts have been
-------
directed primarily to lifetime exposures. Subchronic human data
are rarely available. Reported exposures are usually from
chronic, occupational exposure situations, or from reports of
acute accidental exposure. If data are available to estimate a
chronic exposure, the subcnrcnic exposure is also based on this
data, with an uncertainty factor applied.
The "Acceptable Intake Chronic" (AIC) is similar to the
concept of the Reference Dose (RfD) previously discussed. It is
an estimate of an exposure level which would not be expected to
cause adverse effects when exposure occurs for a significant
portion of the life-span. As with the RfD, the AIC does not
reflect the carcinogenic properties of the contaminant since it
is assumed, correctly or incorrectly, that there is no acceptable
intake level for carcinogens. The AIC is also considered to be
route specific, thus it estimates the acceptable exposure for a
given route with the implicit assumption that exposure via other
routes is insignificant.
AIC and AIS values are generally derived from animal studies
to which uncertainty factors have been applied. AIC and AIS
values are expressed both in terms of human intake (mg/kg/day)
and ambient concentration (e.g., mg/1 for drinking water).
Dose-response parameters used in the assessment of
noncarcinogenic and carcinogenic risks at Area D are presented in
Table 2.
Exposure Assessment
The exposure assessment identified potential pathways and
routes for contaminants of concern to reach the receptors and the
estimated contaminant concentration at the points of exposure.
Contaminant release mechanisms from environmental media, based on
relevant hydrologic and hydrogeologic information (fate and
transport, and other pertinent site-specific information, such as
local land and water use or demographic information), were also
presented. At Area D, the current receptor population was
identified as basically limited to government employees due to
the size and security of the FAA facility. In addition, only a
small percent of the Government employees (<2%) who work at the
Technical Center are authorized access to the Fuel Farm.
Potential exposure pathways evaluated include the ingestion of
groundwater, ingestion of or direct contact with surface soils,
and ingestion of or direct contact with subsurface soils.
Inhalation of airborne contaminants or fugitive dust was not
identified as a significant exposure pathway. For each
potentially significant exposure pathway, exposure assumptions
were made for realistic worst-case and most probable exposure
scenarios.
-------
11
Assumptions used to characterize exposure point
concentrations were all based on a 70-kg adult. Specific
assumptions for each exposure pathway and scanario are summarized
in Table 3 .
Risk Characterization
The risk characterization quantifies present and/or
potential future threats to human health that result from
exposure to the contaminants of concern at Area D. The site-
specific risk values are estimated by incorporating information
from the hazard identification, dose-response evaluation, and
exposure assessment.
When sufficient data are available, a quantitative
evaluation is made of either the incremental risk to the
individual, resulting from exposure to a carcinogen or, for
noncarcinogens, a numerical index or ratio of the exposure dose
level to an acceptable dose level is calculated.
Risks which were assessed in the Area D feasibility study
include noncarcinogenic and carcinogenic risks resulting from
exposure to individual COCs.
For noncarcinogenic compounds, various regulatory agencies
have developed standards, guidelines and criteria which provide
"acceptable" contaminant levels considered to protect human
populations from the possible adverse effects resulting from
chemical exposures. A ratio of the estimated body dose level to
the RfD or AIC/AIS provides a numerical index to show the
transition between acceptable and unacceptable exposure. This
ratio is referred to as the chronic hazard index. For
noncarcinogenic risks, the term "significant" is used when the
chronic hazard index is greater than one. When Federal standards
do not exist, a comparison was made to the most applicable
criteria or guideline.
Calculated body dose levels, as described previously, were
compared to the body dose level associated with the most
applicable standard or guideline. The estimated chronic body
dose level in ug/kg/day is estimated using the exposure
assessment assumptions and actual site data as summarized in
Table 3. The body dose level is then compared to the AIC to
determine if chronic exposure to the contaminated soil presents a
risk. Because certain standards are derived for protection
against acute (e.g., 1-day HA), subchronic (e.g., AIS), and
chronic (e.g., AIC) exposures, body dose levels for
noncarcinogens are developed for both acute and chronic exposures
and the associated risks assessed.
For carcinogens or suspected carcinogens, a quantitative
risk assessment involves calculating risk levels considered to
represent the probability or range of probabilities of developing
-------
12
additional incidences of cancer under the prescribed exposure
conditions. Carcinogenic risk estimates, expressed as additional
incidences of cancer, are determined by multiplying the
carcinogenic potency factor, as described earlier, by the
projected exposure dose level. It is the carcinogenic potency
factor, expressed in (mg/kg/day)~~, which converts the estimated
exposure dose level, expressed in (mg/kg/day), to incremental
risk. These risks are probabilities that are generally expressed
in scientific notation (e.g., 1 x 10~6or 1E-6). An excess
lifetime cancer risk of 1 x 10~6 indicates that, as a plausible
upper bound, an individual has a one in one million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure
conditions at a site. To put the calculated risk estimates into
perspective, they should be evaluated against a baseline risk
level. Risk levels of 10 ~4 to 10~7 can be used to determine the
"environmental significance" of the risk incurred and are used as
a target range for remedial purposes (U.S. EPA, 1986). Using
this range as a baseline, a risk level greater than 10 ~4 is
considered to present a "significant" risk with regard to human
health in an environmental context, and levels less than 10 ~7 are
considered "insignificant". A risk level between 10 and 10~'
is classified as "potentially significant". The use of the terms
"significant", "potentially significant", and "insignificant" are
not meant to imply acceptability; however, they help to put
numerical risk estimates developed in risk assessment into
perspective.
The noncarcinogenic risk characterization for Area D
concluded that under realistic worst-case and most probable
exposure scenarios the acute and chronic noncarcinogenic risks
associated with future exposures (ingestion or dermal contact) to
surface and subsurface soils appear to be "insignificant".
Likewise, acute or chronic ingestion of contaminated groundwater
under realistic worst-case and most probable exposure scenarios
does not appear to result in "significant" noncarcinogenic risk.
A summary of noncarcinogenic chronic hazard indices is presented
in Table 4.
The carcinogenic risk characterization concluded that the
carcinogenic risks associated with future incidental ingestion of
surface or subsurface soils under realistic worst-case and most
probable exposure scenarios are considered "insignificant".
Direct dermal contact with surface or subsurface soils under
future realistic worst-case and most probable exposure scenarios
also appears to be "insignificant". Future scenarios which
evaluate the carcinogenic hazard associated with groundwater
ingestion predict the carcinogenic risk tg.be "significant"
(i.e., exceeds the EPA target range of 10" to 10 ) for the
realistic worst-case and "potentially significant" for the most
probable exposure scenarios. A summary of carcinogenic risks at
Area D is presented in Table 5.
-------
13
Environmental risks associated with the presence of
contamination at Area D are expected to be minimal. Based en the
investigation results, surfisial contamination is limits, to the
presence of petroleum hydrocarbons in relatively small a s a s of
jet fuel spills. The majority of the threats posed by Area D are
associated with the presence of the floating hydrocarbon plume
and subsurface soil contamination. Therefore, risks to flora and
fauna at the surface are limited.
Regardless of the type of risk estimate developed, it should
be emphasized that all estimates of risk are based upon numerous
assumptions and uncertainties. In addition to limitations
associated with site-specific chemical data, other assumptions
and uncertainties that affect the accuracy of the site-specific
risk characterizations result from the extrapolation of potential
adverse human health effects from animal studies, the
extrapolation of effects observed at high dose to lose dose
effects, the modeling of dose response effects, and route-to-
route extrapolation.
The use of acceptable levels (established standards,
criteria and guidelines) and unit cancer risk values which are
derived from animal studies introduces uncertainty into the ris.k
estimates. In addition, the exposure coefficients used in
estimating body dose levels are often surrounded by
uncertainties. As such, these estimates should not stand alone
from the various assumptions and uncertainties upon which they
are based. In developing numerical indices of risk, an attempt
is made to evaluate the effect of the assumptions and limitations
en the numerical estimates. When the assumptions and
uncertainties outweigh the meaningfulness of a risk assessment, a
qualitative assessment of the risk is performed.
The uncertainty factors which are incorporated into the risk
estimates are believed to be conservative. As such, when they
are considered collectively, exposure, and subsequently risk, may
be overestimated.
In conclusion, based on the results of the risk assessment,
actual or threatened releases of hazardous substances from Area
D, if not addressed by implementing the response action selected
in this ROD, may present an endangerment to public health,
welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
Eight remedial alternatives were developed for analysis in
the Area D FS. Each of these alternatives is described in detail
below. Because a number of the alternatives involve common
remedial elements, these are described separately, where
applicable, and then are referenced in the individual alternative
descriptions.
-------
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TABLE 2
ESTIMATED DOSES AND INCREMENTAL CANCER RISKS FROM
AVERAGE EXPOSURE DUE TO USE OF AN OFFSITE WELL
TCE
Concentration (ug/1)
Risk
PERC
Concentration (ug/1)
Risk
Total Excess Risk
Oral
1
3 x !0-7
4 x ID'6
1 x 10-5
Inhalation
3 x 10-7
4 x 10-6
Derma'
1 x 10-9
3
2 x
10-3
(Sum of risks due to three
exposure routes and both
chemicals)
17
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ccnta1*!' ~a"- - cns'te *e ' ' s «ere • zs"~ ~''?~ as nc • • t c - • .i g «e';; '"*-••< a~: 'v,-~
At tie '-'W-M we'l, tne average :jn;en:-a:-:r- c- = rq~_ -^ a^2 -^4 a,3 -^ :
and 5 ug/1. respectively, "he -rgnest concentrafons of ?E3C, TC£, a-: ":-
Deserved at this well are 26. 22, and 15 ug/1, respectively. MW-7 *e!1 «a>
sampled only once in June 1988. The concentrations of PERC, TC£, and TCA
detected in this well are 33, 4, and 18 ug/1, respectively.
Four other organic compounds—chloroform, 1,2-transdichloroetnylene ,
1,1-dicnloroethane, and vinyl chloride—were detected on a few occasions in
less than 301 of the offsite wells. Vinyl chloride, for example, was analyzed
on only one occasion and was detected only in the Pel low, MH-M, and MW-T Wells
at 1 ug/1. Chloroform was sampled for regularly in each well, but was
detected in only 3 wells, on one occasion in each well (maximum concentration
• 6 ug/1 detected in the Costello Well. October 1987). These chemicals were
therefore not evaluated in the risk assessment, because they were detected so
infrequently and at very low concentrations relative to their toxlcity (often
near the detection limit of 1 ug/1). However, because of the weight of
evidence and cancer potency of vinyl chloride and chloroform, the maximum
likely additional cancer risk; due to exposure to these chemicals are
discussed in the uncertainty section.
Iron was the only inorganic compound detected in offsite wells that
exceeded drinking water standards. The ambient water quality criterion for
iron (0.3 mg/1) Is based on taste, odor, and staining properties. This
compound was not considered a contaminant of concern because there are no
known health effects from ingestlon of iron at the concentrations measured.
Exposure Assessment
The population at greatest risk of adverse health effects are those
people who potentially use the groundwater In the area of the NorthsIde
Landfill as their only source of drinking water. The primary routes of
exposure to contaminants in groundwater are Ingestlon, Inhalation of volatile
constituents, and dermal absorption.
A. Exposure Point Concentrations
As mentioned above, groundwater monitoring data from Appendix D of the
Supplemental RI Addendum were used to derive exposure point concentrations.
Appendix D contains organic chemical concentration data for samples taken
during the period of September 1983 through June 1988 for onsite and offsite
wells. Most wells were .sampled periodically during this period and so a time
series of data is- available for these wells. Some wells were sampled only
once or very Infrequently during this period.
A great number of analytical results are reported as below a detection
limit of 1 mlcrogram per liter or as below an unspecified detection limit.
When calculating exposure point concentrations for PERC, TCE and TCA. these
"non-detectable" results were treated in the following manner. If a result
was reported as less than 1 mlcrogram per liter, then it was assumed that the
concentration equals one-half of the detection limit. I.e., 0.5 ug/1. If a
result was reported as less than an unspecified detection limit, it was
assumed that the detection limit is 1 mlcrogram per liter, and that the
concentration equals 0.5 ug/1.
20
-------
I- tnis scenario, it *as as^jnej "at senons ^cu'a be eoosed t;
grcunoater contaminants at a ieve' eaual to trie aritnmetic mean of all t
observations (N » 523) averaged over time for all of tne of*3'te wells
(total » 61). For 'ESC, TCE, and TCA , tnese concentrations are 3. 1, and
, respectively.
2) Exposure Due to Use of the Most Contaminated Off site Wei Us)
For this scenario, for each of the three chemicals of concern, the
off site well which showed the highest average concentration was identified.
The average concentration at a well is defined as the arithmetic mean of the
time series of concentration data.
For PERC, the Pellow Well showed the highest average concentration (28
ug/1 based on 24 observations) . The average concentration of PERC at all
other off site wells is less than 9 ug/1.
For TCE as well, the Pellow Well showed the highest average concentration
(5 ug/1 based on 24 observations). The average concentration of TCE at all
other off site wells is less than 2 ug/1.
For TCA. the Volkman Well showed the highest average concentration (7
ug/1 based on 31 observations). The average concentration of TCA at the
Pellow and Shaw Wells was 4 ug/1. At all other off site wells, the average
concentration of TCA Is less than 2 ug/1.
The Pellow and Volkman Hells were therefore iaentlfied as the most
contaminated wells. Risks associated with the exposure to ground water
contaminants from the both these wells are evaluated assuming two levels of
exposure. The first level Is the average concentration at the wells. These
concentrations are given In the paragraphs above.
The second level considered is the highest concentration observed at the
wells. At the Pellow Well, the highesr observed concentrations of PERC. TCE.
and TCA are 38. 8, and 10 ug/1, respectively. At the Volkman Well, the
highest observed concentrations of TCE and TCA are 7 and 15 ug/1,
respectively. PERC was assumed to be at a concentration of 0.5 ug/1, as it
was not detected in this well.
3) Exposure Due to Use of the Most Contaminated Ons ite Wells
For this scenario, for each of the three chemicals of concern, the onsite
well which snowtd the highest average concentration was identified. The
average concentration at a well is defined as the arithmetic mean of the time
series of concentration data.
For PERC, the MW-T Well showed the highest average concentration (33 ug/1
based on 1 observation In June 1988).
For TCE, the MW-M Well showed the highest average concentration (13 ug/1
based on 16 observations).
For TCA, the MW-T Well showed the highest average concentration (18 ug/1
based on one observation in June 1988).
21
-------
v*e i l s . 3's<; asjcc'are: .v':"1 :~e e<:c3jre :c grc-"c.«i:?-
contarru nants from sotn tnese *e ' 1 s are evaluated assuming :*o leve's cf
sxoosure. The first level is the average concentration at tne ^ens 7-ese
concentrations are given in tne paragracns aoove.
The second level considered is the highest concentration observea at the
wells. At the MW-M Well, the highest observed concentrations of P£3C, TCE,
and TCA are 26, 22, and 15 ug/1, respectively. At the MW-T Well, the only
observed concentrations of PERC, TCE, and TCA are 33, 4, and 18 ug/1,
respectively.
8. Calculation of Dose
For each chemical of concern, an average daily dose was calculated for
two routes of exposure, ingestion and dermal contact. A dose from inhalation
of volatile organic compounds, such as the chemicals of concern, was not
calculated directly, as the various models for estimating risks from
Inhalation exposure have not been critically reviewed by the EPA, Region 10.
Therefore, in this risk assessment it was assumed that the inhalation risks
are equal to (average case) or two times (upper-bound case) the risks from
Ingestion of 2 liters of water per day. according to current EPA, Region 10
guidelines (USEPA, 1989a).
The average daily dose (mg/kg/day) via ingestion was calculated as
follows:
dose - concentration of contaminant (mg/1) x Intake rate (I/day) / 70 kg
body weight
For all exposure scenarios, a person was assumed to Ingest 2 liters of
contaminated water every day for a lifetime. Absorption was assumed to be
1001 for all chemicals.
The average daily dose from dermal absorption of contaminants while
bathing was calculated as follows:
dose • C x CF x Kp x SA x.EF / 70 kg body weight
where,
C
CF
Kp
SA
EF
concentration of contaminant (mg/1)
conversion factor (10~3 l/cm3)
dermal permeability constant (cm/hr)
body surface area contacted (cm2)
frequency (hr/day)
For all the volatile contaminants, a dermal permeability constant of 8.4
x 10~4 cm/hr was used In the above equation (USEPA, 1989O. The body
surface area exposed to water while bathing was assumed to be 18.000 cm' for
the average adult (USEPA, 1989b). For each exposure scenario, a person was
assumed to bathe for a duration and frequency equivalent to one-half hour
every day for a lifetime.
22
-------
Under current EPA guidelines. t~e '•
-------
4s noted c^e /'cus iy, r';<; --cm :nra'a:':r 9<;c$jr? *a-? -
erectly. Out assumed to oe ?Qjal ro (a/e^age case) or :«o fres uc:e--:;.w^c
case) tne risks frcm ingest;cn of 2 liter; of
-------
t: 5C a-: ~Zl J--9- :-e ass.rrec ::-:•:•c^s ""= "m
associated with exccsure :c ea:- :-9-n';a' /'a era'.. • *.na'it1 :^ , a-: ;s'~i
excosures routes are gi.ei. Also, tctai excess MS*, /a'ues are sncwn -"c-
eaci scenario. Total excess n sic values are calculated by adding tne nsus
due to exposure to both ciemicals 3y all three exposure routes.
Table 2 shows tie estimated cancer risks based on an average exposure
to PE3C and TCE due to use of an offsite well. The total excess risk is 9
x 10-6 for this scenario. This numoer represents an increased risk of
contracting cancer of nine chances in one million for a person exposed for
70 years. -
Estimated cancer risks based on exposure to PERC and TCE due to use of
the most contaminated offsite wells (the Pel low and Volkman Wells) is snown
in Table 3. For each of these wells, exposure to the average and maximum
concentrations of each chemical observed at the well was considered
(average and upper-bound cases, respectively). For the Pellow well, total
excess risks are estimated to be 8 x 10~3 and 2 x 10~4 assuming
exposure to average and maximum concentrations, respectively. For the
Volkman Hell, total excess risks are estimated to be 2 x 1Q~6 and 9 x
10*6 assuming exposure to average and maximum concentrations,
respectively.
Table 4 shows the estimated cancer risks based on exposure to PERC and
TCE due to use of the most contaminated onsite wells (the MW-M and MW-T
Wells). For Well MW-M, the same two levels of exposure were considered as
for the offsite wells. Total excess risks are estimated to be 5 x 10-5
and 1 x 10-4 assuming exposure to average and maximum concentrations,
respectively. For the MH-T Well, the total excess risk 1s 1 x TO-4 for
both the average and upper-bound exposure calculations, based on the single
available observation.
B. Non-Carcinogenic Risks
Non-carcinogenic risks are presented as a hazard index which Is the
ratio between the route-specific calculated dose and the RfO. Ratios
exceeding unity (one) Indicate doses that exceed the acceptable level;
ratios less than one are not expected to cause adverse health effects.
Based on the highest observed concentrations of PERC and TCA, the
Pellow and MW-T wells were the offsite and onsite wells, respectively,
found to pose the greatest risk of non-carcinogenic effects. The estimated
doses of each chemical, based on the maximum observed concentration, and
the corresponding hazard index are presented below for the Pellow and MW-T
wells.
Pellow Well PERC TCA
(mg/kg/day) (mg/kg/day)
Oral Dose 1 .1 x 10'3 2.9 x ICr4
Inhalation Dose 2.2 x 10'3 5.7 x ICr4
Dermal Dose 4.1 x 10~6 1.1 x ICr6
Total Dose (A) 3.3 x 10'3 8.6 x 10'4
RfO (B) 1 .0 x 10-2 9.0 x ICr2
Hazard Index (A/B) 0.30 0.01
25
-------
Cra" Dose 9.4 * ;o-4 5.1 x !Q-4
Inhalation Dose 1.9 x 10~3 1 .0 x 10~3
Oer-ia! Dose 3.6 x 1Q-6 1.9 x 10~6
Total Dose (A) 2.8 x 10-3 1.5 x 1Q-3
RfD (3) 1.0 x ID'2 9.0 x ID'2
Hazard Index (A/8) 0.30 0.02
The hazard indices for both chemicals may be totaled as PERC and TCA
have similar toxic endpolnts. The total hazard indices for the Pel low and
MW-T well are 0.34 and 0.30. respectively. As these hazard indices are
below unity, non-carcinogenic health effects are not expected from exposure
to PERC and TCA in these two wells. The risk from exposure to PERC and TCA
in otner wells would be less, as the PeMow and MW-T Wells have the highest
concentrations of these contaminants. Thus no non-carcinogenic effects ar;
expected due to exposure to these chemicals in any well.
C. Uncertainty
The accuracy of the risk characterization depends In large part on the
quality and representativeness of the available sampling, exposure, and
toxicologlcal data.
One major area of uncertainty that may have underestimated health
risks is that cancer risks from exposure to chloroform and vinyl chloride
were not evaluated In this study. These chemicals were detected very
Infrequently and the RI/FS determined there was insufficient data to
evaluate them. However, vinyl chloride is classified as a human
carcinogen, Group A, and chloroform Is classified in Group 82, probable
human carcinogen. Because of their Inherent toxlclty, likely maximum
additional increases In cancer risk from exposure to vinyl chloride and
chloroform were therefore calculated. Using the highest single
concentration detected for vinyl chloride (1 ug/1) and an oral cancer
potency slope of 2.3 (USEPA, 1989d), the upper-bound estimate of additional
cancer risk is 2 x 10~4. For chloroform, the upper-bound estimate of
additional cancer risk Is 3 x 10"6, based on the highest observed
concentration (6 ug/1) and an oral cancer potency slope of 0.0061
(USEPA, 1988). Because these chemicals are degradation products of the
other chlorinated organfrcs, vinyl chloride and chloroform levels could rise
and pose risks greater than the above estimates.
D. Conclusions
In conclusion, the total incremental Increase in cancer risk for the
average exposure scenario Is 9 x 10"6. For exposure to one of the
offsite wells with the highest average concentration of carcinogens, cancer
risks range from 2 x 10~6 to 1 x 10"*. Estimated cancer risks from
exposure to groundwater from the most contaminated onslte wells range from
5 x 10-5 to 1 x 10~4. These scenarios are based on the assumption that
the population at risk Is using groundwater near the Northside Landfill as
the only source of drinking water over an entire lifetime (70 years).
Non-carcinogenic health effects are not expected from exposure to PERC and
TCA at the present level of contamination In onsite and offslte wells.
26
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BftTTEKY, NY
RISKS
Sediment bioassays were conducted on four freshwater estuarine
•p«cies rfariodaphpj,^ dubia. Selanastrun eaericornutun.
Cranoog gjg and pjjfphales promales^ to determine the concentra-
tions of cadmium, nicfcal, and cobalt in sadiment which adversely
affect aquatic organisms. Thirteen sediment samples vara collactad
from Foundry Cove and the Pier Area and ona from Wappingers Falls
(reference location) and used in the bioassay tests. Samples were
recovered from the top 6 inches of sediment. Based on the results
of ~:cs« tests, it vas concluded that a level between 10 ar.d 255
mg/Xg of cadaiua in the sediaent would protect the anvironaer.t.
Research performed for EPA (JRB, 1934) established sediaent
criteria for cadmium based upon limiting concentrations in water
to levels below EPA Ambient Water Quality Criteria. Preliminary
results have shown that sediment cadmium toxicity decreases with
increasing organic content. Therefore, for a total organic carbon
(TOC) concentration of 5%, the chronic sediment cadmium criterion
vas found to be 38.5 mg/fcg, and at a TOC of 10%, the chronic level
vas found to be 77 mg/fcg. Ebasco's field results shoving an
average TOC value of 9.4% for this area vould imply that a cadaiua
concentration somevhare in the range of 73 mg/)cg vould be required
to prevent chronic exposure. The proportion of cadmium found in
the -sediment to that in aqueous solution in the marsh, however,
vill depend not only on TOC, but on other site-specific factors,
including water chemistry, pH, oxidation/reduction potential, and
temperature. Therefore, the model for partitioning based upon
sioplifying assumptions vill only approximate site-specific cadaiua
criteria (ERT, 1986). KYSDEC feels that even at 10 mg/fcg of
cadaium in sediments there may b« adversa ecological impacts.
The shortnosed sturgeon (Aeipenser brevi rostrum^ . an endangered
species since 1967, occurs in the Hudson River from Troy to
Piermont, a range of 125 miles which includes the site. Because
it is a bottom feeder, and benthic organisms accumulate cadaiua,
exposure to site contamination is possible. Hovever, since
critical life stages (e.g., juveniles and larvae) and over-
wintering individuals do not congregate in the Foundry Cove area,
it is expected that the site contamination may not have a
significant effect on these fish.
-------
6. DESCRIPTION OF ALTERNATIVES
The objective of this section is to provide an understanding of the remedial
alternatives developed for the site and their specific components. Each alternative
should be described to provide a clear understanding of how all of the wastes (including
any residuals) will be addressed through treatment, containment, and/or institutional
controls.
An excellent description of alternatives includes discussion of chemical-,
action- and location-specific ARARs, why they are ARARs, assumptions, limitations
and uncertainties, risk reduction, volumes, and the degree of hazard of waste left on site
or disposed off site. Capitol, O&M, and present worth costs should be provided as well as
implementation requirements and time frames.
EXAMPLE: BYRON BARREL AND DRUM, NY
This example contains a helpful introductory section that provides an
overview of the number of alternatives presented and the respective problems they are
intended to address. Although brief, the descriptions provide essential information to
convey how all of the waste is being addressed through treatment, containment, or
institutional controls. In addition, each description addressed volumes of material,
implementation requirements and time frames, monitoring, and the need for a five
year review, as well as present worth costs. Additional information that would be
useful to include are capitol and O&M costs, a bit more detail on the major ARARs each
alternative will trigger (particularly the land ban), and the ground water classification
and area of attainment for the ground water alternatives.
EXAMPLE: NORTHSIDE LANDFILL, WA
Example two is included because it provides a good summary of other major
ARARs associated with each alternative. The ROD also describes the objectives of the
alternative well, although the discussion of advantages and disadvantages is
unnecessary in this section. It would be better placed in the Comparative Analysis
section. Costs, volumes, and other information is missing, although the ROD did
address implementation time frames and the need for treatability studies in a table
that was not included.
-------
BKRCN BARREL AND DKM, NY
DESCRIPTION OF ALTERNATIVES
All of the drums and approximately 40 cubic yards of contaminated
surficial soil and debris have been removed from the site. The
levels of subsurface soil contamination on-site, with the possible
exception of inorganics located in Source Area 3, present risk
-------
17
levels which are within EPA's acceptable range. However,
contaminants remaining at the site have contaminated the underlying
groundwater, exceeding federal and state groundwater quality
standards. Specifically, Source Area 1 and Source Area 2 are
releasing organic contaminants into the groundwater through
infiltration of precipitation. The two plumes exceed ARARs and
pose a risk of off-site migration of contaminants to the nearby
Oak Orchard Creek. There does not appear to be a groundwater
contaminant plume emanating from Source Area 3. The alternatives
described below address the remaining subsurface soil contamina-
tion at the site and the contamination in the groundwater
underlying the site.
A total of eight alternatives were evaluated in detail for
remediating the site. Five remedial alternatives address the
contaminated subsurface soils that contribute to groundwater
contamination at the Byron Barrel and Drum site. In addition, six
alternatives address the contamination in the groundwater beneath
the site. These alternatives are as follows:
ALTERNATIVE 1 - NO ACTION WITH MONITORING
The Superfund program requires that the "no-action" alternative be'
considered at every site. Under this alternative, EPA would take
no further action to control the source of contamination. However,
long-term monitoring of the site would be necessary to monitor
contaminant migration. Monitoring can be implemented by using
previously-installed monitoring wells and residential wells.
Because this alternative would result in contaminants remaining
on-site, CERCLA requires that the site be reviewed every five
years. If justified by the review, remedial actions would be
implemented at that time to remove or treat the wastes.
The present worth cost of this alternative for a 20-year period is
approximately $265,000. The time to implement this alternative is
two months.
ALTERNATIVE 2 - DEED AND GROONDWATER-U8B RESTRICTIONS
This alternative would not require implementation of remedial
actions to address groundwater or subsurface soil contamination.
Deed restrictions would be imposed to prevent excavation in areas
of contamination. Groundwater-use restrictions would be imple-
mented in the affected area to prevent the use of contaminated
groundwater for drinking or irrigation purposes. These institu-
tional controls would also alert future property owners to poten-
tial site-related risks. A long-term monitoring program would also
be implemented. Deed and groundwater restrictions can be
implemented by state and local officials. Groundwater monitoring
can be performed using previously-installed monitoring wells and
residential wells.
-------
18
The present worth cost of this alternative, for a 20-year period,
is approximately $279,000. The time to implement this alterna-
tive would be 2 months.
ALTERNATIVE 3 - DEED RESTRICTIONS AKD GROUNPWATER PUMPING.
TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative would not require implementation of remedial
actions to address subsurface soil contamination. Deed re-
strictions would be imposed to prevent excavation in areas of
subsurface soil contamination. Groundwater would be collected
using a series of extraction wells and pumped to an on-site
treatment system.
To treat the volatile organic contaminants (VOCs) in the extracted
groundwater, an air stripping column and activated carbon adsorber
would be constructed at the site. The air and VOC mixture exiting
the air stripper would be treated by a vapor phase carbon
adsorption unit. The clean air would be emitted to the atmosphere.
It is anticipated that a carbon adsorption unit would be necessary
for the removal of the MEK, since air stripping would not remove
this contaminant from the groundwater. In addition, inorganic.
contaminants in the groundwater would be removed by precipitation-
prior to air stripping. Discharge piping would be installed to
pump the treated water to the drainage ditch located north of the
onion field or to Oak Orchard Creek. All air and surface water
discharges would comply with state and federal standards.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site and its environs would continue for at least five years
after the completion of the remediation to ensure that the goals
of the remedial action have been met. Pre-construction,
construction and post-construction air monitoring would also be
performed.
The present worth cost of this alternative is approximately
$4,874,000. The time to reduce the groundwater contaminant
concentrations to levels based on ARARs is estimated to be 20
years.
ALTERNATIVE 4 - SOIL CAPPING AND GROPNDWATER PUMPING. TREATMENT,
AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternative 3, except that synthetic
membrane caps would be installed over the areas of soil
contamination.
Under this alternative, the maintenance building would be disman-
tled, and decontaminated if necessary, and disposed of off-site.
Prior to capping, the areas would be graded to control surface
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19
water runoff and erosion. A protective soil cover would be placed
over the synthetic membrane, topsoil would be spread, and the
capped areas would be revegetated.
The groundwater pumping, treatment, and discharge scenario would
be the same as that discussed for Alternative 3. Monitoring would
be the same as in Alternative 3.
The present worth cost of this alternative is approximately
$5,143,000. Two months would be required to construct the cap.
The time to reduce the groundwater contaminant concentrations to
levels based on ARARs is estimated to be 20 years.
ALTERNATIVE 5 - SOIL EXCAVATION AND OFF-SITE DISPOSAL AND
GROUNDWATER PUMPING. TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternatives 3 and 4, except that
contaminated soil would be excavated and hauled to an off-site
Resource Conservation and Recovery Act (RCRA) landfill for
disposal.
Under this alternative, the maintenance building would be
dismantled and decontaminated if necessary, and disposed of off-'.
site. Contaminated subsurface soil would be excavated, loaded into
trucks, and hauled to an approved off-site RCRA landfill for
disposal. (So as to comply with RCRA land disposal requirements,
treatment of the contaminated soil might be required prior to
disposal.) The excavations would be backfilled with clean fill
material from an off-site source. These areas would be covered
with a layer of topsoil and revegetated.
The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.
The present worth cost of this alternative is approximately
$7,929,000. Two months will be required to remove the contaminated
soil. The time to reduce groundwater contaminant concentrations
to levels based on ARARs is 20 years.
ALTERNATIVE 6 - SOIL EXCAVATION AND THERMAL DESORPTION AND
GROPNDWATER PUMPING, TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternatives 3, 4, and 5, except
that contaminated subsurface soil would be excavated and treated
on-site using low-temperature thermal desorption to remove volatile
organic contaminants.
Under this alternative, the maintenance building would be disman-
tled, and decontaminated if necessary, and disposed of off-site.
Contaminated soil would be excavated and hauled to a mobile thermal
desorption unit that would be set up at the site. Treated soil
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20
would be used to backfill the excavations. The areas would be
covered with a layer of topsoil and revegetated. Because of the
presence of inorganic constituents in the soil, which thermal
desorption would not remove, treatment of the residual by chemical
fixation might be necessary before backfilling to comply with RCRA
land disposal requirements.
The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
in Alternative 3.
The present worth cost of this alternative is approximately
$6,899,000. Two months would be required to complete soil
treatment. The time to reduce groundwater contaminant
concentrations to levels based on ARARs is estimated to be 20
years.
ALTERNATIVE 7 - IN-SITU SOIL VAPOR EXTRACTION AMD GROUNDWATER
PUMPING. TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternatives 3, 4, 5, and 6, except
that contaminated subsurface soil would be treated by in-situ vapor
extraction using air extraction and injection wells.
Under this alternative, the maintenance building would be disman-
tled and decontaminated if necessary, and disposed of off-site.
Vapor extraction wells would be installed at the centers of Source
Area 1 and 2. Air injection wells would be installed around the
perimeters of the Source Areas 1 and 2. A vacuum would be induced
and the air that would be collected would be treated using vapor-
phase carbon adsorption. A synthetic membrane would be used to
prevent air leakage from the soil surface between the air
extraction and injection wells.
The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.
The present worth cost of this alternative is approximately
$5,200,000. Six months would be required to reduce soil
contaminants to levies that would achieve groundwater ARARs. The
time to reduce groundwater contaminant concentrations to levels
based on ARARs would be 20 years.
ALTERNATIVE 8 - IN-SITU BOIL FLUSHING AND GROUNDWATER PUMPING,
TREATMENT. AND RECHARGE
This alternative is similar to Alternative 3, except that a portion
of the treated groundwater would be recharged to the aquifer in the
areas of subsurface soil contamination. This alternative would
attempt to restore groundwater quality and flush the residual
contaminants from the subsurface soil.
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21
Monitoring would be the same as for Alternative 3.
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JQOHSIEE IANTJFTLL, WA
DESCRIPTIOX OF ALTERNATIVES
The goal of the remedial actions ;s to prevent, reduce, or control 7-5
contaminants leaving the landfill and entering the grcundwater.
Technically appHcaole technologies were identified in the "S for each of
the units. Most of the remedial actions that passed the screening process
for one of the landfill solid waste units (refuse, skimmings, old Qurn. or
sewage sludge) passed for all of the other three. The aquifer unit
includes different technologies that deal with the migration of the
contaminants in groundwater and not the material fn the refuse. The
description of the treatment alternatives is divided Into those for the
landfill units and those for the aquifer unit.
Landfill Units
Remediation of the landfill units must control, as far as possible,
the leaching of contaminants into the groundwater. This may be done by
either:
a) capping the landfill to eliminate leaching;
b) diverting stormwater so that it does not generate leachate; or
c) excavating the landfill and removing the contaminated waste.
If it proves impracticable to control leachate. administrative restrictions
may be enacted to reduce exposure to contaminants. Another alternative
considered 1s to take no action.
a) Capping. The cap system would consist of multiple layers. Including
topsoil, soil cover, drainage layers, and bedding/protection layers.
in conjunction with a low permeability, barrier layer to control
Infiltration. Around the perimeter of the cap. collection ditches
would be Installed to intercept stormwater runoff and convey It to
appropriate points of discharge. Three different types of cap systems
were considered: synthetic membrane, synthetic membrane and day, and
soi1/bentonite.
The cap would utilize proven technologies. Its main advantage is that
it restricts the amount of leachate that can enter the aquifer unit by
reducing the infiltration of precipitation Into the landfill.
Precipitation 1s the principal source of leachate generation for the
landfill because It.is located above the identified groundwater
tables. Therefore, if precipitation, run-on, and any lateral flows
from the hillside can be kept from entering the waste, the health and
environmental hazards associated with leachate generation and
contamination of the aquifer unit would be significantly reduced.
Disadvantages of capping include the waste of concern remaining
onsite. the potential for the cap to leak and generate additional
leachate. and the magnitude of grading and covering 345 acres of
land. Leakage of the cap is a concern because of the potential for
future leachate generation. The design and Installation of the cap
would need to be carefully done, and a maintenance program would be
necessary to reduce the risk of leaks developing In the system over
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f:ie. Erv: r-n7ie"ta I nca::; c*' :"s :ao nsra" ' afcn are :cn$':e'?:
re'ncorary because :~e ex: ;:•<-; Surface tcpograony *oula nor :nan; =
significantly and vegerat'on vcuid be reestao1 isned.
Canping, of course, presupposes the closure of the landfill. Three of
:ne units—old burn, sewage sludge, and ski-nmings—are no longer in jse
and could be capped at any time, but the refuse unit currently is
scheduled to -emain in use until December 31. 1991, when the
waste-to-energy treatment system becomes operational. Any refuse taken
to the Northside site after December 31, 1991, will be required to be
placed into a new disposal unit which meets the state's Minimum
Functional Standards (MFS) requirements.
ARARs
The closure and capping alternative include action-specific applicable or
relevant and appropriate requirements (ARARs). The primary ARAR is the
Washington State Minimum Functional Standards for Performance (MFS) (WAC
173-304-460). The MFS are applicable to landfills that Institute closure
after November 27, 1989. The Northside Landfill will be operating beyond
1989.
The MFS Include requirements for the final cover, groundwater monitoring.
landfill gas monitoring and control, runoff and leachate control, a
closure plan, and a closure cost estimate.
The wastes in the landfill are not currently classified as hazardous
wastes under RCRA because the only sources Identified are small quantity
generators. Since closure and capping do not include the placement of
RCRA hazardous wastes, those RCRA regulations would not apply.
There are no chemical-specific or location-specific ARARs identified for
this alternative.
b) Surface Mater Diversion and Col lection Systems. These systems are
designed to divert and collect stormwater runoff and keep it from
infiltrating the landfilled wastes, thereby reducing the potential for
leachate generation. The diversion and collection systems would consist
of ditches, culverts, and pipelines that collect runoff from flow
concentration areas and convey It to an appropriate point of discharge.
The ditches would be lined to ensure that infiltration would be minimized.
•
This alternative's chief advantages are that it would consistently help
reduce leachate-generating precipitation from entering the landfill, and
it is low in cost. The disadvantage is that it does not address
infiltration by precipitation that falls within the landfill boundaries.
In the final analysis of alternatives, surface water diversion is not
considered a separate alternative, but rather a component of capping, and
is included as part of that alternative.
c) Excavation and Offsite Disposal. One additional remedy passed screening
for the Skimmings Unit only. It was rejected for the refuse unit because
of high cost and EPA preference for onsite. remedies (the old burn and
sewage sludge units have low contaminant levels and disproportionately
28
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. -
s/cmmings (t^cugn tct any ccrtar" "area soil/ .vm:n *GL ! a r~e" 39 :-::;:a:
of offsite at a 3er^'tts2 "azarccus *ast» landfi'l. AS trv s is an
offsite activity, suci disccsal ^ust comoiy *itn all acolicao'e naza-dcus
and solid waste disposal requirements. These include RCRA ana me stars
Dangerous Waste and solid waste regulations.
d) Excavation and Onsite Treatment. Treatment onsite is either througn land
treatment or incineration. Land treatment is described as biological
treatment of the waste done onsite but not tn-situ. This meets EPA's
preference for onsite treatment.
The chief advantages of this alternative are its permanent elimination of
one potential contaminant source, its elimination of the health hazard
for this area of the site, and the fact that it restores the area for
possible future use. No administrative restrictions would be necessary
after excavation and treatment were completed.
Disadvantages of this alternative include health and safety impacts
associated with excavation, environmental concerns (e.g., worker exposure
to contaminants during excavation and treatment), demonstrated
effectiveness, and cost.
ARARs
Several action-specific ARARs are identified for excavation and treatment
alternatives evaluated for the Skimmings Unit area within the landfill.
The skimmings originated from the city's wastewater treatment plant and
are not RCRA hazardous wastes or state dangerous wastes either by
definition or by characteristic.
Any contaminated soils not excavated can be treated as a non-disturbed
solid waste unit (not hazardous) and capped according to applicable
regulations.
Excavation of the skimmings could also be expected to result in the
release of some quantity of volatile organics. There are currently no
standards for PERC emissions, so any requirements would be determined by
risk assessments which are not ARARs. but are "to be considered" in
design of the remedial action.
•
Excavation and onsite treatment of the skimmings Includes two treatment
options. Both options Include the excavation of the grease skimmings
followed by treatment and placement back onsite. Land treatment of the
skimmings has no applicable regulations. However, the disposal of any
hazardous wastes generated as a result of the treatment process would be
required to meet the RCRA disposal requirements, wnich would be
applicable to this new waste's disposal.
The Incineration of the skimmings has relevant and appropriate RCRA
requirements for the operation and disposal of the waste streams.
Although the incoming waste Is not RCRA regulated, the RCRA ash and air
emissions requirements for Incineration would be relevant and appropriate
because of the PERC concentrations in the waste.
29
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"hers *ere no cre^i :a • - $oe:
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standards. THIS *oul2 resjcs tie a^c-'t of -ate' t-a: *o-': ~es: :; ;e
pumped and suosequeitly fs /c:-;me fiat «cu'a se f?a:ed
The difference between the two caoture options, oesides fe amcurt of
water pumped, is the amount of control over the release of contaminants
downgradfent from the system. This would have an impact on the time
needed for recovery of the contaminated plume downgradient. Both options
would control releases downgradient of the extraction system so that they
would meet drinking water ARARs and protectiveness requirements in the
aquifer. The design of the extraction system will determine where the
actual extraction wells will be located.
The extracted contaminated groundwater would then be treated or
discharged into the city's wastewater treatment plant for treatment and
then discharged into the Spokane River. Three levels of treatment have
been identified in the FS, which are: no treatment, treatment to
drinking water levels and Ambient Water Quality Criteria (AWQO levels,
or treatment to background levels.
All of the pump and treat alternatives would also require groundwater
monitoring, administrative restrictions, and an alternative drinking
water supply. There would be minimal environmental impact during well
construction and few anticipated health or safety concerns for the
surrounding community.
ARARs.
The ARARS are essentially the same for tht two extraction alternatives.
The major regulations that contribute to tht list of potential
chemical-specific ARARs are the Clean Water Act (CWA). the Safe Drinking
water Act (SOWA), and the Water Quality Standards for the State of
Washington (WAC-173-201) (90.48 RCH). Tht acts are under the
Jurisdiction of and are enforced by the Washington State Department of
Health Services, tht Washington State Department of Ecology (Ecology),
and EPA.
The SDWA Maximum Contaminant Level (MCL) standards are enforceable
standards that are applicable to surface water or groundwater that can be
classified as a source or potential source of drinking water. The MCLs
are applicable to any action that affects tht concentration of
contaminants in groundwater which is a source of drinking water, such as
the SVRPA.
The discharge of extracted wattr to tht Spokane River is considered to be
offsltt and Is thtrtfore not subjtct to ARARS analysis. Compliance with
the applicable laws, regulations, and permit requirements is necessary.
Somt discussion of tht discharge requirements Is Included si net treatment
may be dont onsite.
The CWA Ambient Wattr Quality Criteria (AHQO art dtsigntd to protect
aquatic life and human health. The statt of Washington adopts the AWQC
by reference Into their wattr quality standards, so tht AWQC art
requirements for surface wattr discharges. Table 5 prtstnts
chemical-specific potential ARARs for wattr. Tht tablt is arrangtd by
chemical compound.
31
------- An error occurred while trying to OCR this image.
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tr9a:~eit ~e t~9 i<:-a:7?a ;-3uncwat9r *'^n j':--ate :'
:ne Spokane 3i/er must come';/ *«'th ^mDiert ^a:9r Qua'':./ 3n:9'
(AwQCXsee Tao'e 5). ~h9 quality of :ne unt-9a:9a gr-ouna*a:9r
ne expected to satisfy tne AWQC *or fresn *at9r cue to VCC
concentrations. An NPDES permit would nave to be obtained from Ecology
prior to initiating the discharge. Discnarges to the 'iver will be
required to comply with the phosphorus discharge limits established for
the Spo
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5) ;' tar-rat've ^ar?" SuscL/- A:; "sw r9Siierc9j -n the area c-
contamination *ould oe connected with me fiuniciDa! water system, a$
existing residences already are. it would oe technically feasicie si"-e
tne^e are nearby water lines, though some new service laterals might nave
to 3e constructed. Public health would be protected and cost would be
low, but the groundwater would remain contaminated. There were no
environmental receptors of the contaminated groundwater identified in the
An alternate source of drinking water for residents located in the local
area of the contaminated o'ume does not satisfy ARARs. Groundwater
contaminant levels would continue to exceed drinking water MCLs until
natural recovery reduces the contaminants below the MCLs. This
alternative would help in the interim to protect public htalth, but
contamination would not be reduced to MCLs; therefore, it would not
satisfy ARARs.
e) No Action. No remedial measures would be Implemented, beyond those
already in place (i.e.. providing alternative water to existing
residences). There would be no cost, no change in the level of
protection of public health, and no reduction of contamination in the
aquifer. Water quality and Safe Drinking Water Act ARARs would not be
me t.
34
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7. COMPARASION OF ALTERNATIVES
This section summarizes the relative performance of the alternatives by
highlighting the key differences among the alternatives in relation to the nine
evaluation criteria. It is recommended that this be presented in a series of paragraphs
headed by each criterion. Under each criterion, the alternative that performs best in
that category may be discussed first, with other options discussed in sequence.
EXAMPLE: HEDBLUM INDUSTRIES, MI
This comparative Analysis includes a helpful introductory sentence under each
criterion that identifies the purpose of that particular comparison. The discussions
under Compliance with ARARs, Short-term Effectiveness, Cost, and State Acceptance
are particularly good. This Comparative Analysis does not address the nine criteria in
the standard sequence established in the ROD guidance. The Overall Protection
discussion inappropriately refers to the different "degrees of protection" provided by the
alternatives. Since Overall Protection of Human Health and the Environment is a
threshold criterion, alternatives should be designated protective or not.
EXAMPLE: CROSS BROTHERS PAIL, IL
This example addresses the nine criteria in the appropriate sequence. The Long-
term Effectiveness and Permanence discussion is very good, appropriately conveying
the relative degrees of long-term effectiveness afforded by the options. This ROD also
identifies up front how remedies are comparable so the subsequent discussion is
focused only on significant differences between options. The alternatives are generally
discussed in order of best to worst under each criterion, which allows for a quick
understanding of results.
EXAMPLE: NORTHSIDE LANDFILL, WA
This example effectively summarizes State and Community Acceptance.
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HEDBLLM INDUSTRIES, MI
A detailed analysis was performed on the six alternatives using v.e
nine evaluation criteria in order to select a site remedy. T^e
following is a sunoary of the oarpariscn of each alternative's
strength and weaJoiess with respect to the rone evaluation criteria.
These nine criteria are: 1) overall protection of hunan neal-w. i.nc
the envirorment, 2) ccnplianoe with applicable or relevant and
appropriate requiraBents (ARARs), 3) short-tera effectiveness, 4,
long-term effectiveness and
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-30
• - • — — , 5) co*t, 6) reduction of tenacity, nat'liry and v^i^re
7) iaplaaentabllity, 8) State acceptance, and 9) contajrur/
of Public ^>«^n *rl tfae
Evaluation of the overall protactiveness of each alternative focuses
on haw the alternative achieves protection over tine and how the
risKs are eliminated, reduced and controlled through treatMnt,
engineering controls or institutional controls. Alternative 5,
which treats contamination in the groundwater and soils would prcv^e
the highest degree of protection to the public health and the
environment. Roping and treating contaminated groundwater should
reduce the levels of \QC contamination in the aquifer to those
required by Michigan Act 399 of 1976. Boavating and treating
contaminated soils en-cite will ranove this possible source of
groundwater contamination though exposure to this source was not
positively identified as a potential health risk in the public health
assessment. Alternative 3 treats the contaminated groundwater as in
Alternative 5, to levels required by Act 399 of 1976 and is
protective of public health and the anvironnent. Alternative 4
treats the contaminated en-site soils but since the residential wells
directly east of the site do not shew elevated levels ?f VOC and
indicate that the soils are not an on-going source of contamination,
this altjernative will have minimal protective effect on human heal
Alternative 2 will eliminate ingestion of and incidental contact '-'
contaminated grounduater for those residents connected to the vate
main but it does not treat contamination in the environment and
therefore is not protective of future well users or the envirorrert
Alternatives 1 and 6 are not protective of public health and trie
environment because they do not treat contamination in the
environment.
ARARs
Each alternative is evaluated for coppliance with ARARs, including
chemical-specific, action-specific and location specific ARARs.
These ARARs are presented in Table 11 with the alternatives to -*-.;:
they apply. All of the alternatives, exaapt the no action
alternative, will meet their respective ARARs with the following
Ion: Alternatives 1, 2, and 4 do not ccoply with the Safe
. Water Act of 1987 and Act 399 of 1976 which set
drinking water standards.
9wfc-'nsM Effect^
This evaluation focuses on the effects on human health and the
environment which «ay onaur while the alternative is being
implemented and until the remedial objectives are met. The fo]
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i«re used to evaluate the short-t^ra effectiveness of
alternative: protection of the community dururg remedial actions,
protection of workers during remedial actions, environmental ir
from implementation of alternatives, and time until remedial
objectives are
With respect to protection of the community, Alternatives 1 through :
will not pose risks to the local community, though there aay be
taBporary inoonveniences. Alternatives 4 and 5 which involve
excavation may result in increased dust generation but this can be
controlled through conventional dust suppression techniques.
Risks to workers during remedial action in Alternatives 1 through 5
can be controlled with safe working practices. Alternatives 4 and 5
may expose worker* to WXs fron excavated soils but the levels should
be within applicable f£Z« and TLVs.
With respect to environmental inpacts, Alternatives l, 2, 3, and 6
will have continued migration of contaminated groundwater at the site
and under the subdivision as they do not address groundwater
contamination. Alternatives 3, 4, and 5 will result in a temporary
change in groundwater flow from extraction and pit dewatering and a
tarporary increase in the flow rate in the bayou fron the discharged
groundwater. Alternatives 4 and 5 could result in the release of low
levels of VDC to the air from the soils excavation.
Evaluation of the **jj"* until protection is achieved reveals the
following estimates: Alternative 2 should taXe a few weeks to a
months, Alternative 4 should take 5-« months, and Alternatives 3 and
5 should take 4-5 years. Alternatives 1 and 6 will not achieve
protection.
This evaluation focuses on the results of a remedial action in terrs
of the risk remaining at the site after response objectives have bee.-.
met. The following factors are addressed for each alternative:
megninjde of remaining risk, adequacy and reliability of controls.
The priamry risk identified at the site by the public
heelth/envii i • seiii il risk m*f trent is from the ingest;or cf
contaminated grounbVeter. Alternatives 3 and 5 offer the greatest
degree of permanence as they minimize the risks from ingestion cf and
incidental contact with contaminated groundwater by removing the
contarinants with treatment. Alternative 5 also treats subsurface
soils on-sitt. However, the soils wtrt not found to pose an
unacceptable rnx. Alternative 2 eliminates the- risks froa ingest; —
and incidental contact with acntanunatad groundwater by supplying
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-38-
lidents connected to the water main with a clean source of potafcle
»cer. However, the contaminated groundwter would still persist
with this alternative. Alternative 4 reduces the risJcx froo cent-act.
with subsurface eoil* but also does not address the contaBLLnaticri of
the grtundwater. Alternatives 1 and 6 will not mitigate any of the
risXs presently associated with the site.
With respect to adequacy and reliability of controls, Alternatives 3
and 5 both use a reliable method to reduce and possibly eliminate
groundwater contamination. Total elimination of VOC ccntammaticr,
will depend on its distribution in the aquifer. If the system
components mechanically fail, they may be replaced or repaired
without much impact on the residences. The excavation and treatrer.t
of on-site soils in Alternatives 4 and 5 should remove this possible
source of grounduatar contamination. If the excavation or treatment
systen mechanically fail, they may be replaced or repaired with no
exposure of the local community to contaminants. Alternative 2 uses
connections to the water main to eliminate risfcs front groundwater
which has a low potential for failure.
This evaluation examines the estijrated costs for iaplementmg the
remedial alternatives. Capital and annual 04M costs are used to
calculate estimated present worth costs for each alternative.
Alternative 3, pumping and treating contaminated groundwater, has a
moderate capital cost and high annual cost which results in an
estimated present worth of $1,379,000. Alternative 4, excavating and
treating on-site soils has a high capital cost but since there is a
short implementation tine, annual costs are low. This results IT. an
estimated present worth cost of $724,800. Alternative 5, which
combines Alternatives 3 and 4, has the highest capital and annual
cost. Estimated present worth costs total $1,914,000 for Alternative
5. The remaining 3 alternatives which provide less overall
protection of public health and the environment cost less than the
already mentioned alternatives. Alternative 6, no action, is
considered to have no associated costs. Alternative 1, continued
monitoring at the site and subdivision, has low capital and annual
costs. Ihe estimated present worth costs is $132,400. Alternative
2, connecting affected residents to the Osocda water train and site
monitoring, also has low capital and annual worth costs total
$170,250.
This evaluation addresses the statutory preference for selecting
remedial actions that enploy treatanent technologies which perrvanertl;
and significantly reduce toxicity, mobility, or volume of the
hazardous substances. This preference is satisfied when treatrer.t -j
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-39-
used to reduce the principal threats at a site through destruction of
contaminants, irreversible reduction in contaminant nobility, or
of total volume of contaminated madia.
For Alternatives 3 and 5, the volume of contaminant* in the grourdwatjer
will be irreversibly reduced by extraction and treatment. The aontaminarrt
plume nobility wall be affected during traacBent but any remaining residual
contamination vill have the same mobility once pumping and treating has
stopped. Alternatives 4 and 5 vill eliminate the toxicity, volume, and
mobility of contaminants in the soil. However, the en-site soil
contamination does not appear to be an on-going cause of groundwater
contamination under the subdivision. Each of these three alternatives will
treat some groundwater, extraction from the aquifer in Alternatives 3 and 5
and dewatering the excavation pit in Alternatives 4 and 5. The resulting
effluent water would meet discharge criteria and vill be monitored to
verify this. The water treatment process will generate spent carbon that
may be considered hazardous waste and must be handled accordingly (by the
carbon supplier and regenerator). The other three alternatives, 1, 2, and
6, provide no treatment, and thus, do nothing to affect tenacity, mobility
or volume.
TTus evaluation ^^rTtirn the technical and administrative feasibility of
implementing the alternatives and the availability of the various services
and materials required during its implementation.
Technically, the placement of the extraction well system in Alterratives 3
and 5 is dependent on the location of objects and structures in the
subdivision and the residents' willingness to have a well placed on their
property, otherwise, the system can be readily constructed or leased ard
operated. The excavation in Alternatives 4 and 5 can be accomplished with
conventional techniques but this may be difficult due to the close
proximity of the plant and the railroad tracks. The treatment unit can be
easily constructed or leased and operated. For both the grourdwater
extraction and the soil treatment, a pre-design study vill be needed to
verify system performance. The connection to a water main in Alternative :
is a common technology proven to be reliable. Alternative 1 only requires
installing a monitoring well and Alternative 6 has no actions.
Adr^nistrttivily, Alternative 2 will require tap-in fees to connect to t.w.e
osccda water main.
Fcr all alternatives which include sera type of action, all equipmr.t,
services and specialists are available locally or from national venders
-------
-40-
Aj.tarrat.ivn 3, tirt- rv •• ^ -*- , ,, ,_;tow »w^ ^ -»-*v*jy sel
in th.
grcundwat*r will b. cl«w«d so as ret
"
ted IT.
Comunity nrpiJTise to the alternatives is presented in tte
responsiveness sunnary which addresses oannents raceived during the
public Garment period.
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PAIL, EL
13
VTII. SUGARY OF CQ »rp a RAT IVg ANALYSIS OF ALTSRKATTVPS
The remedial alternatives developed during the cross
Brothers Pail Recycling site FS were evaluated by
and IEPA using the following 9 criteria. The advantages
and disadvantages of each alternative were then compared to
identify the alternative providing the best balance among
these'9 criteria.
1. Overall Protection of Human Health and the Environment
addresses whether or not an alternative provides adequate
protection and describes how risks are eliminated, reduced
or controlled through treatment and engineering or
institutional controls.
2. Compliance with Applicable or Relevent and Appropriate
Requirements (ARARs) addresses whether or not an alternative
will meet all of the applicable or relevant and appropriate
requirements or provide grounds for invoicing a waiver.
3. Long-term Effectiveness and Permanence refers to the
ability of an alternative to maintain reliable protection cf
human health and the environment, over time, once cleanup
objectives have been met.
4. Reduction of Toxicity, Mobility or Volume is the
anticipated performance of the treatment technologies an
alternative may employ.
5. Short-tern Effectiveness involves the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed during
the construction and implementation period until cleanup
objectives arc achieved.
6. Implementability is the technical and administrative
feasibility of an alternative, including the availability of
goods and services needed to implement the solution.
7. Co«% includes capital costs, as well as operation and
maintenance costs.
8. Agency Acceptance indicates whether, based on its
review of the HS/FS and Proposed Plan, U.S. EPA and IEPA
agree on the preferred alternative.
9. Community Acceptance indicates the public support of a
given alternative. This criteria is discussed in the
Responsiveness Summary.
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19
A natrix summarizing the comparative analysis of
alternatives on a criteria by criteria basis is presented i-
Table 10.
The following discussion expounds on the information
provided in Table 10.
A. Overall Protect ?H nf frif*j\ Health and the Environment
All of the remedial alternatives considered for the Cross
Brothers Pail Recycling site, except for the no action
alternative, are protective of human health and the
environment by eliminating, reducing or controlling risks
through various combinations of treatment and engineering
controls and/or institutional controls. As the no action
alternative does not provide protection of human health and
the environment, it is not eligible for selection and shall
not be discussed further in this document.
All of the alternatives reduce the risks associated with
groundwater contamination by pumping and treating
contaminated groundwater. A groundwater monitoring program
will also be implemented to evaluate the effectiveness of
the groundwater remediation activities. In addition, all of
the alternatives utilize access restrictions (i.e. fence an:
deed notification).
Alternative 3A does, however, include the removal of soil
contaminants through soil flushing. The treated groundwater
will be utilized as the flushing agent. In addition, a
6 inch vegetative cover will be placed over the non-flushed
areas to stablize the soils on-site. Alternative 2 includes
the same basic remedial components as Alternative 3A, less
the vegetative soil cover.
Alternative 3B does not include the soil flushing system.
Treated groundwater would be returned to the aquifer through
a series of re-injection wells. Alternative 3B also includes
a 6 inch vegetative cover over the entire site area. The use
of this cover type will result in passive flushing of the
soils through natural infiltration.
Alternative 4A is very similar to Alternative 3B. The
treated groundwater will be re-injected into the aquifer.
Rather than a 6 inch vegetative cover, Alternative 4*
utilizes a small multi-layer cap over the most heavily
contaminated soil area to prevent the infiltration of
precipitation. Alternative 4B is identical to Alternative 4A
except the multi-layer cap will cover the entire site area.
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20
PCS Soil Removal - Option 1 requires removal of the
localized PCB-contaminated soil area and incineration at. a
TSCA approved incinerator. PCS Soil Removal - Option 2
requires removal of the localized PCB-contaminated soil araa
and landfilling of the soils at a TSCA approved landfill.
B. ARAR3 Compliance
SARA requires that remedial actions meet legally applicable
or relevant and appropriate requirements (ARARs) of other
environmental laws. These laws may include: the Toxic
Substances Control Act, the Safe Drinking Water Act, the
Clean Air Act, the Clean Water Act, the Resource
Conservation and Recovery Act, and any state law which has
stricter requirements than the corresponding federal law.
A "legally applicable" requirement is one which would
legally apply to the response action if that action were not
taken pursuant to Sections 104, 106 or 122 of CERCLA. A
"relevant and appropriate" requirement is one that, while
not "applicable", is designed to apply to problems
sufficiently similar that their application is appropriate.
All of the alternatives proposed for the Cross Brothers Pail
Recycling site meet or exceed ARARs.
C. Long-tern Effectiveness and Permanence
The alternatives considered for the Cross Brothers Pail
Recycling site vary in their ability to provide long-term
effectiveness and permanence.
Each of the alternatives considered includes a groundwater
pump and treat component. By eliminating the contaminants
present in groundvater each of the alternatives achieves a
certain degree of long-term effectiveness and permanence.
The difference betveen the alternatives with regard to
long-term effectiveness and permanence is directly related
to how each alternative addresses soil contamination at the
site.
Alternative 3A provides the greatest degree of permanence.
The> heavily contaminated soil area is flushed, removing any
leachable materials from the soil. A € inch vegetative
cover is placed over the site's non-flushed area stabilizing
the soils on-site. Alternative 2 follows Alternative 3A in
degree of permanence. Alternative 2 does not include the
6 inch vegetative cover. As such, soils in the non-flushed
areas will be subject to wind and water erosion.
Alternative 3B, which includes pump and treat with re-
injection of the treated groundwater, provides the least
amount of long-term effectiveness and permanence.
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Alternative 3B does not actively address the contaair.at i zr.
in the soil. The presence of only a 5 inch vegetative cover
will allow passive flushing of the soil contaminants. Thus
recontamination of the groundwater due to leaching of the
contaminated soils is likely. Alternatives 4A and 43, while
not removing the contaminants present in the soil, do offer
greater long-term effectiveness than Alternative 33 by
containing the contaminants. Both of these alternatives
include a multi-layer cap that will limit the infiltration
of precipitation through the soils and preclude the leaching
of contaminants into the groundwater.
The long-term effectiveness and permanence differ greatly
with respect to the PCS Soil Removal Options. Option l,
removal and incineration, provides far greater permanence
than Option 2 - removal and landfilling. Under Option l, the
PCBs present in the soils will be permanently destroyed.
Option 2, however, only displaces the contamination to a new
location.
D. Reduction of Toxicity. Mobility or Volume through Treatment
All of the alternatives include a component which reduces
the toxicity, mobility and volume of the contaminants
present in the groundwater at the site through treatment.
The difference between alternatives is most noted with
regard to the contaminants present in the soils at the sits.
Alternatives 2 and 3A provide for the greatest reduction in
the toxicity, mobility and volume of the contaminated soils.
Both of these alternatives require the soils to be
continually flushed during the groundwater remediation
activities. Upon completion of the groundwater remediation
activities (estimated 15 years), any leachable contaminants
will be removed from the soils. Alternatives 4A and 4B
reduce only the mobility of the soil contaminants through
the use of a multi-layer cap. The multi-layer cap will
limit the infiltration of precipitation, and preclude the
leaching of soil contaminants into the groundwater.
Alternative 3B does not actively address the contaminated
soils at the site. Therefore, Alternative 3B does not
provid* a significant reduction in the toxicity, mobility or
volum* of the soil contaminants.
PCS Soil Removal - Option 1 significantly reduces the
toxicity, mobility and volume of the PCB contaminated soils
by thermally destroying the PCBs. Option 2, however, only
reduces the mobility of the PCBs by landfilling the soil in
a TSCA landfill.
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22
Short-tern Effectiveness
All of the alternatives considered have siailar iapacts on
short-term effectiveness resulting from a groundwater"
treatment system being utilized. The alternatives differ,
however, with respect to the other remedial ccmponents~used
as well as the length of time required to remediate the
site. These factors present varying potential short-tern
risks across all the alternatives. It is not obvious
however, that any one alternative presents lower overall
short-term risks than the others.
The use of the soil flushing under Alternatives 2 and 3A
presents a potential short-term risk to the environment by
temporarily increasing the mobility of the contaminants
within the soils. This increased risk, however, will be
controlled through the proper placement of the groundwater
pumping system. In addition, the groundwater monitoring
program will assess any changes in aquifer conditions. The
use of soil flushing in these alternatives lengthens the
estimated period required to meet the site's cleanup
objectives. The remedial action time estimated for
Alternatives 2 and 3 A is 15 years, compared with the 11
years estimated for Alternative 3B and the 10 years
estimated for Alternatives 4A and 48.
Alternatives 3A, 3B, 4A and 4B which utilize a vegetative
cover or a multi-layer cap will involve the grading of
surface soils which may create a temporary dust problem.
Conventional dust control measures will be employed
however, to limit any fugitive dust emissions that may occur
during grading activities.
The PCS Soil Removal Options are siailar in the area of
short-term effectiveness. Both options require the
excavation and off-site transport of the contaminated sub-
soils. Short-term exposure risks to workers and the
community may result. One potential difference between the
options is tHe length of time necessary to complete the
remedial action if a larger quantity of soil needs to be
removed*^ Option 1 will take longer than Option 2 due to
capacity restraints of the licensed TSCA incinerators. The
projected volume of soil to be excavated under either
option, however, is expected to be small enough that no
problems would a^ise with either incineration or
landfilling.
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?. Tapleaentabil Ify
'while all of the alternatives considered are implement able ,
seme alternatives are technically easier to implement tnan'
based on their design and complexity.
Alternative 33 is the easiest alternative to implement as
the remaining alternatives involve modifying this design.
Next in implementability would be Alternative 2, which
involves installing flushing equipment at the site.
Alternative 3A is next and is similar to Alternative 2 vith
the addition of the 6 inch vegetative cover.
Alternatives 4A and 4B would be next, respectively, due to
the complexities in designing and installing a multi-layered
cap. Alternative 4A would be easier to implement than
Alternaitve 4B as it involves a smaller multi-layer cap
than Alternative 4B.
Excavation of the localized PCB-contaminated soil area is
easily implemented under either PCS Soil Removal Option.
Option 1 has some implementability problems due to the
finite availability of incinerators that are licensed to
handle PC3 contaminated soil. This could potentially lead
to delays in transporting the materials to be incinerated if
a large volume of soils is removed.
G. Cost
The estimated present worth value of each alternative and
option is as follows:
Groundwater and Soil Remediation Alternatives
Alternative 2 $ 1,729,400
Alternative 3A $ 1,956,700
Alternative 3B $ 1,872,300
Alternative 4A $ 2,285,000
Alternative 4B $ 2,997,000
Localized PCB Soil Removal Options
Option 1 $ 17,700
Option 2 $ 8,600
H. Aoencv Acceptance
U.S. EPA and IEPA agree on the preferred alternative. Both
Agencies have been involved in the technical review of this
state-lead fund financed HS/FS, and the development of the
Proposed Plan and ROD.
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I. Community Acceptance
Community acceptance is assessed in the attached
Responsiveness Suaaary. The Responsiveness Suaaary provides
a thorough review of the public ccmaents received on twe
HS/FS and Proposed Plan, and U.S. EPA's and IZPA's resccr.ses
to the comments received.
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IANEFTLL, WA
Modifying Criteria
The modifying criteria are used In the final evaluation of .
alternatives. The two modifying criteria are state and community ac;so:a"c»
For both of these elements, the factors considered in the evaluation are t"e
elements of the alternative which are supported, the elements of tne
alternative which are not supported, and the elements of the alternative »*a
have strong opposition.
3. State Acceptance
Washington State Department of Ecology (Ecology) has been closely
involved with the development and review of the Remedial Investigation ana
feasibility Study srocessss. -co'cgy ccmme^red en tie 3T'"S anc .«crO2 «-v
£3A on tne proposed plan. The comments from me stars «era 3n 'ncc-tant
factor in EPA's decision to -eccmme'a an alternative that a'**ered *rzm tna
recommendation in the Feasipihty Study. The state strongly favors oumo
featment of the contaminated groundwater plume as an interim measure jn
contamination coming from tne landfill is reduced to acceptable 'eve's
Although EPA has been wording closely with Ecology to ensure fiat
includes the state's comments, EPA, has not yet received the stare ;
concurrence letter.
9. Community Acceptance
The results of the public comment period and the discussion during the
RI/FS public meeting Indicate that the residents who live near or have been
affected by contamination from the NorthsIde Landfill support the proposed
plan with its Interim pump and treatment system. The community desires a
remedy which would begin treating the contamination as soon as possible, "he
City of Spokane (the PRP> recommended that pump and treat only be implemented
if contaminant levels in the plume were not lowered by tne other closure
actions, specifically the cap. The community recognizes that none of the
alternatives, except for the pump and treatment system, will be Implementable
until tft* landfill closes. The pump and treatment system provides a
prottctton mtchanism which Is not contingent on landfill closure.
The differences between tie city's and EPA's recommended remedial action
were highlighted in the proposed plan fact sheet and at tne public meeting.
The resident community supported the EPA Interim pump and treatment system
because it actually reduces the contamination In tne aquifer, rather than
relying solely on natural attenuation. It was estimated that it would ta
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8. SELECTED REMEDY
This section of the ROD should identify the selected remedy and remediation
goals , state the carcinogenic risk level to be attained and the rationale for it, and the
specific points of compliance for each media addressed.
EXAMPLE: VOGEL PAINT AND WAX, IA
This example provides a good, detailed technical description of the selected
remedy. The strong points are the inclusion of a figure that depicts the selected
treatment process in general terms, and cost tables for both the source control and
ground water components. One flaw in this discussion is that a specific vendor is
named for the low temperature thermal treatment system that may be used. Vendors
should never be named in a ROD. Also, although technical parameters are well
established, remediation goals and points of compliance are not distinctly addressed.
A summary of the important features of this ROD'S contingency remedy and the
criteria for its implementation are described in an appropriate level of detail.
EXAMPLE: MARATHON BATTERY, NY
This second example provides a good, succinct description of the selected remedy
and explicitly addressed remediation goals and their basis. Points of compliance are,
however, not outlined specifically.
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VDGEL FAINT & WAX, IA
2.8 Seiectea Remeav
The selected remedy is Alternative S-3 involving on-site
bioremediation of soils coupled with Alternative GW-1 involving
pumping and air stripping of groundwater.
The selected remedy will include the following ancillary
activities:
o Continued listing and restrictions associated with the State
Abandoned or Uncontrolled Sites Registry until no further
threat remains.
o Continued floating hydrocarbon removal until no appreciable
amounts can be recovered.
o Removal of the uncontaminated cover soil and temporary storage
of the material in a protected area.
o Removal of solid waste material, other than contaminated soil
(e.g., drums, paint cans, wooden pallets, paint solids,
general trash), from the disposal trenches and temporary
storage in a protected area.
o Ultimate disposal of the solid waste material in a municipal
landfall if the material is non-hazardous or can be made non-
hazardous through decontamination. Ultimate disposal in a
hazardous waste landfill or off-site incineration of this
material may be warranted if the material is hazardous and
cannot be made non-hazardous.
o Removal of free solvent liquids from the excavation and
temporary storage in tanks, and off-site recycling of the
solvent, if possible, or off-site incineration.
18
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o Fcr "clean closure" soils must pass the E? Toxizity test fs-
leachable metals (40 CFR 261.24), the TCLP test for leachable
organics (40 CFR 253.41) and shall not contain aore than ico
mg/Xg of Total Organic Hydrocarbons prior to final placement.
o An air monitoring program approved by the DKR will be
implemented during all site work.
o Dust control will be provided during excavation.
Bioremediation of soils will involve a fully contained surface
impoundment system complying with minimum technology standards
using conventional soil management practices (e.g., nutrient
addition and soil aeration) to enhance microbial degradation and
volatilization of organic contaminants. The system will be
designed to contain and treat soil leachate and volatilized
contaminants.
A system consists of a double lined treatment bed, a sand/gravel
layer to serve as a leachate collection system with perforated
drainage pipe and a sump, and groundwater monitoring, if volatile
contaminants must be contained, the entire treatment bed will be
covered by a modified plastic film greenhouse. An overhead spray
irrigation system will be installed to control moisture and used
as a means of distributing nutrients (see Figure 9).
The leachate will be recycled back to the treatment area via the
spray irrigation system. Leachate in excess of acceptable limits
will be treated on-site or collected for off-sif.e treatment.
Vapors will be treated (i.e. carbon adsorption) and released. The
spent carbon would be regenerated if possible, or sent to an
approved landfill facility. Approximately one-acre of land will
be needed for treatment of 3000 cubic yards of soil.
High concentrations of heavy metals may prohibit use of this
process. Additional soil sampling and testing and a treatability
study are necessary prior to implementation. If small quantities
of soils are identified as containing high levels of heavy metals
which are incompatible with bioremediation, these noils will be
isolated and treated on-site using a stabilization process (e.g.
lime, Portland cement or bentonite). Treated noil will be
redeposited in the excavation and covered with clean coil.
If high concentrations of heavy metals pose excessive restrictions
on the use of bioremediation, thermal treatment of soils would be
implemented in its place; in which case, ancillary activities would
remain the same and the soil would then be treated using low
temperature thermal treatment to drive off the volatile organic
compounds. The organic compounds in the off-gas would be destroyed
using an afterburner if ARARs for air emissions cannot be met. The
mobile low temperature thermal treatment system developed by WESTON
is designed to handle 15,000 Ib/hr of contaminated soil based on
19
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Contaminated Soil
Excavation
Soil
Screening
Oversized Material
to Special Handling
Solid Phase
Treatment
Soil Layer
Perforated
Drain Pipe
Sprinkler
System
Source: Evoca Corp.
(revised)
SOLID PHASE BIODECEADATIOK
FIGURE 9
19*
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20* soil aoisture and 1% (10,000 ppm) VOCs. The systea is
comprised of three trailers that are a total of 120 feet long and
8 feet wide. The total height of the trailers, with t.he equipment
assembled, is under 13.5 feet. As with bioremediation, thermal
treatment will not remove metals and residual soil will be
stabilized, if necessary, prior to redeposition.
Contaminated groundwater would be removed by pumping from one or
more recovery wells. A pumping test will be conductud during the
remedial design to determine aquifer characteristics. This
information will be used to design the pumping system; i.e., number
and location of wells, pumping rates, and gradient controls. The
well (or wells) would be located and sized to draw water from the
entire contaminant plume thereby preventing any off-site migration
of groundwater contaminants. The pumped water would be treated by
air stripping to remove greater than 95 percent of the volatile
organic contaminants. Carbon adsorption would be ucted to remove
contaminants in the air discharged from an air stripper, if
necessary. Treated water from the air stripper would be discharged
to the adjacent stream. Activated carbon used for Jiir stripping
off-gas and water polishing prior to discharge would be regenerated
or disposed of in an approved landfill facility. Pumping and
treatment will be continued until groundwater ARARs are met. A
groundwater monitoring program, approved by the DNR, will be
implemented and criteria for ceasing remedial action based on
monitoring results will be developed.
Air modeling will be done to ensure that air emissions pose no
acute or chronic health risks with risks from carcinogens less than
10"6 and 1/100 threshold limit value (TLV) for non-carcinogens. Air
emissions will be evaluated during pilot studies and an air
monitoring program acceptable to the DNR will be developed for
normal operation.
Some changes may be made to the selected remedy as a result of the
remedial design and construction processes.
Estimated costs for the selected remedy are shown in Tables 4 and
5.
20
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BSTIXATED COST OT SOIL RZM2DIXTION
irer- Cosr Iteas Basis Cosr*
1. Reacval of clean soil & staging $4/cy x 9,000 cy $ 36,000
2. Excavation of solid waste, staging
and disposal $150/cy x 3,200 cy 480,000
3. Free product removal, trans-
portation and incineration $0.50/gal x 5,000 gal 2,500
4. Air monitoring 2,000
5. Excavation & staging of
contaminated soil $5/cy x 3,000 cy 15,000
6. Sampling & analysis of staged
soil 20,000
7. Land & site development 10,000
8. Construction of staging areas &
physical facilities for bioremediation 99,000
(Thermal Treatment) (40,000)
9. Biological Treatment including
leachate disposal) $33/cy x 3,000 cy 100,000
(Thermal Treatment) ($265/cy x 3,000 cy) (795,000)
10. On-site stabilization $60/cy x 3,000 cy 180,000
11. Backfill $4.5/cy x 3,200 cy 14,400
12. Clay Cap $15/cy x 6,450 cy 96,750
13. Revegetation $l,250/ac x 2 ac 2.500
TOTAL DIRECT $1,058,150
($1,694,150)
'direct Cost Items
i. Engineering, design and treatability study $150,000(100,000)
2. Contingency $160.000(250.0001
TOTAL INDIRECT $310,000(350,000)
TOTAL CAPITAL COST $1,368,150(2,045,000
CSM Cost Items $l,000/year for 30 years
TOTAL PRZSENT WORTH COST $1, 385,000(2 , 060, OOC
Discount Rat* • 5.00%
*NOTE: Cost for Thermal treatment same as bioremediation except as shown in
parentheses^
21
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TXBL2 5
ESTIMATED COST OF GROCNDWXTER REXSDIATION
Direc- Ccst Iteas
1. construction of recovery wells $ 40,000
2. Installation of pumps 10,000
3. Construction of air stripper 110,000
4. Activated carbon disposal (air treatment) 3,000
5. Air monitoring 2,000
6. Monitoring well installation 5 ,20.000
TOTAL DIRECT $ 3.85,000
Indirect Cost Items
1. Engineering and Design (incl.
treatability study) $ 80,000
2. Aquifer pump test 25,000
3. Contingency 30.QQQ
TOTAL INDIRECT $ 135,000
TOTAL CAPITAL COST $ II20,000
O&M Cost Items
1. Power, operation and maintenance $50fOOO/year for 3 years
2. Groundwater monitoring $ 1,200/year for 3 years
3. Lab analyses $ 2,400/year for 3 years
TOTAL PRESENT WORTH COST $ 466,000
Discount Rat* « 5.00%
22
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The combination of Alternative 5-2 for soils and GW-i fcr
groundwater, would provide a substantial risk reduction through
treatment of contaminated soils and removal and air stripping cf
contaminated groundwater. The selected remedy ranks high with
respect to the nine evaluation criteria except for impleaentability
cf the soil remediation. If iaplementability of on-site
bioreaediation of soils proves impractical, then Alternative s-2
(on-site thermal treatment) will be utilised as the method for
soils remediation. Alternatives S-2 and 5-3 are similar with
regard to the evaluation criteria except for costs and
implementability.
Since no immediate risk has been identified, the risks (i.e., time
and development costs) of attempting to implement Alternative S-
3 are justified. If Alternative S-3 proves impractical,
Alternative S-2 will provide a well-proven technology as a
substitute.
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BATTERY, NY
TCT SELECTED MXZDY
The results of the RI/FS have shown that elevated levels of cadmium
above bacfcround are present in Area III sediments.
Based upon consideration of the requirements of CZRCLA, the
detailed analysis of the alternatives, and public comments, both
EPA and KYSOEC have selected Alternative EFC-3, dredging of the
contaminated sediments from East Foundry Cove to a depth of one
foot, chemical fixation and off-site disposal of those sediments,
and restoration of the original contours, as necessary; Alternative
W7C-1, continued monitoring, for West Foundry Cove; and
Alternative CSP-3, sampling and analysis adjacent to and under Cold
Spring pier with dredging of any contaminated sediments determined
to be a threat to the environment, followed by chemical fixation,
off-site disposal, and restoration of the original contours, as
necessary.
The data compiled for East Foundry Cove indicate that over 95% of
the cadmium contamination is located in the upper layer (1 foot)
of the sediments. Due to the nature of the dredging process,
dredging to a specific action level (e.g., 10, 100, or 250 mg/kg
of cadmium) would be technically difficult, since these
concentrations vary in the sediments by only a few inches of depth.
Therefore, expectations are that by dredging the upper layer of
contaminated sediments, 95% of the cadmium contamination will be
removed. Following remediation, it is anticipated that cadmium
concentrations would not exceed 10 ag/kg in most of the dredged
areas.
A no-action alternative was chosen for West Foundry Cove. It was
assumed that West Foundry Cove receives cadmium-contaminated
sediments from East Foundry Cove and East Foundry Cove Marsh and
the Cold Spring Pisr Area. Ones these sources are remediated,
cadmium-free sediments would then b« deposited in West Foundry
Cove. Tidal action would cause the existing sediments to mix with
the newly deposited sediments thereby causing the average cadmium
29
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concentration in the sediments to decrease gradually belcw its
current average concentration of 43.9 ag/Xg. A hydrolo
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The risJc assessment has concluded that, with th« cada--^
contamination presently remaining in East Foundry Cove and the P~er
Area, a threat to human health and the environment exists
Existing condition, at the site have b«en determined to nose *
threat predominantly from ingestion of contaminated sediments bv
human and animal populations. *-«uus 3y
The purpose of this response action is to r«aov« the contaminated
sediments to levels consistent with state and Federal AKARs and to
ensure protection of the environment from the continued exposure
of contaminants froa the sediments. Since no federal or state
ARARs exist for sediments, the action level was determined through
a site-specific risk analysis.
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9. STATUTORY DETERMINATIONS
The remedy selected must satisfy the requirements of Section 121 of CERCLA. to:
• protect human health and the environment
• comply with ARARs or justify a waiver
• be cost effective
• utilize permanent solutions and alternative technologies
or resource recovery technologies to the maximum extent practical
• satisfy the preference for treatment as a principal element to Justify
not meeting the preference
Documentation of each finding is Important but perhaps most crucial is the
rationale for the selection decision (in terms of the nine criteria), which should be made
under the Utilization of Permanent Solutions (to the maximum extent practicable)
determination.
EXAMPLE: WAUSAU WATER SUPPLY, WI
Highlights worth noting in this example are that the discussion under
Protection of Human Health and the Environment describes how the selected remedy
addresses the specific risks identified in the baseline risk assessment. This discussion
also explicitly states that the remedy will not pose any unacceptable short-term risks,
cross-media impacts, or environmental risks. These items should be addressed in
every ROD.
The rationale for ARARs determination are provided as necessary and the land
disposal restrictions are discussed ,as they should be in every ROD, in order to
document clearly whether or not they are ARAR. The discussion under Utilization of
Permanent Solutions and Alternative Treatment Technologies to the maximum extent
practicablel provides a logical rationale for the selection that highlights choices made
on the basis of differences between the options related the the five balancing criteria.
EXAMPLE: SOLID STATE CIRCUITS, MO
The second example is well written overall and shares many of the same
strengths as the previous example. In addition, the ARARs have been organized into
chemical, action, and location-specific and pertinent 'To Be Considered" is also
included.
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WMJSAU WMH* SOPFLtf, WI
1. Protection of Human Health and the Environment;
Based on the risk assessment developed for the site, long-term
•xposur* to low levels of VOCs in drinking water, potential
exposure through the use of private wells, and exposure to air
eaissions froa existing VOC treataent systems are the identified
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33
risks associated with the site.
the source areas and treatment of off-gases, as called fcr ur.der
Alternative 5, provides protection to human health and the
environment through volatilization of VGCs from contaminated
soils, and expedited removal of contaminants from groundwater cy
increased pumpage of municipal wells.
Volatilization of VOC-contaminated soils will eliminate the
source of continued loading of VOCs to the aquifer; thus reducing
the time during which residents are exposed to trace levels of
VOCs. Implementation of Alternative 5 will not pose any
unacceptable short-term risks or cross-media impacts to the site,
the workers, or the community. No environmental impacts have
been identified for the site. This is largely due to the fact
that impacts from the site have been to groundwater, and soils in
industrial areas.
2. Attainment of Applicable or Relevant and Appropriate
Requirements of Environmental Laws
Alternative 5 will be designed to meet all applicable or relevant
and appropriate requirements (ARARs) of Federal and more
stringent State environmental laws. Tables 7-11 list the ARARs
that apply to each of the action alternatives and the following
discussion provides the details of the ARARs that will be met by
Alternative 5. The Land Ban requirements of RCRA do not apply to
this remedial action.
a. Federal: Safe Drinking Water Act (SDWA) / state:
Chater NR 109 Wisconsin Administrative Code
The SDWA and corresponding State standards specifies maximum
contaminant levels (MCLs) for drinking water at public water
supplies. Since TCS is regulated under the SOWA MCLs,
requirements for achieving MCLs are relevant and appropriate for
this remedial action. PCS is under consideration for a proposed
MCL of 5 ug/1 in th« near future. Therefore, the likely proposed
MCL for PC2 is a TBC (to be considered) for this remedial action.
b. State: Chanter NTR 140 WAC
Wisconsin groundwater protection Administrative Rule, Chapter N-R
140 WAC, regulates public health groundwater quality standards
for the Stats of Wisconsin. Tha enforceable groundwater quality
standard for TCE is 1.3 ug/L. Groundwater quality standards as
found in NR 140 WAC arc ARARs for this remedial action.
c. Federal; Clean air act (CAAl
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34
The CAA identifies and regulates the release of pollutants to
air. Section 109 of the CAA identifies those pollutants far
which Aaibient Air Quality Standards (AAQS) have been established.
Section 112 outlines criteria for pollutants for which there are
no applicable AAQS . Emissions from existing and proposed
treatment systems are not expected to exceed the AAQSs for any cf
the compounds present in groundwater.
d. State; Chapter ra 445 WAC
Wisconsin Chapter NR 445 establishes hourly or annual emission
rata limits for specific contaminants. Emissions rates on the
order of 1 Ib/day for individual systems are estimated and would
be expected to meet the limits.
3. Cost-effectiveness
Alternative 5 affords a high degree of effectiveness by providing
protection from chronic low level exposure of TC2 for production
vails CW3 and CW6, providing protection from potential exposure
to future private well users, and preventing further discharge of
VOC emissions. Alternative 5 is the least costly alternative
that is protective of human health and the environment.
Therefore, Alternative 5 is considered to be the most cost-
effective alternative that is protective.
4 . utilization of Permanent Solutions and Alternative
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
U.S. EPA and the State of Wisconsin believe the selected remedy
represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective
manner for the final remedy at the Wausau site. Of the
alternatives that are protective of human health and the
environment and comply with ARARs, U.S. EPA and the State have
determined that the selected remedy provides the best balance of
tradeoffs in terms) of long-term effectiveness and permanence,
reduction in toxicity, mobility or volume achieved through
treatment, short-term effectiveness, implementability, cost, also
considering the statutory preference for treatment as a principal
element and considering State and community acceptance.
Although all of the alternatives that are protective and comply
with ARARs will achieve reduction of risks, there are significant
differences in the time required to achieve this goal.
Alternatives 2, 3, and 4 are groundwater remediation alternatives
that do not address source areas. This results in contamination
froa source area soils loading to the aquifer for several
additional years. In addition, none of these alternatives
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35
provide any reduction in tiae to remediate the deep TCi pl^es
originating from the foraer landfill source area. This also
results in a significant tiae period to achieve reduction of
risks. Alternative 5 requires the shortest tia«» period for
remediation of the site because it eliainates the continued
loading of contaainants to the groundwater, and it provides far
reduction in tiae to purge the deep TCZ plumes by removing the
source and increasing reaoval rates of contaminants at the
Municipal supply wells.
The selection of a treatment technology for remediation of
contaminated soils is consistent with the Super fund program
policy that the highly toxic and mobile wastes are a priority fcr
treatment and to ensure permanence and long-tena effectiveness of
the remedy. Under the selected remedy, treatment of groundwater
will not provide a reduction of toxicity, mobility, or volume
(TMV) . However, it will reduce contaminant levels in groundwater
and thus reduce the risks associated with ingesiiion of
groundwater, which has been determined to be a greater risk
than inhalation of air emissions. While other alternatives
evaluated provided treatment to achieve TMV reductions in
groundwater, these alternatives had other difficulties.
Alternative 2 required almost twice as long to purge
contaminants. Alternatives 3 and 4 propose a technology that has
not been shown to work on contaminants present in groundwater at
the site and thus would require extensive testing that would
delay full scale operation of the system for an estimated two
years. Based on these factors, it was determined that
Alternative 5 would provide the shortest time period during
which receptors would be exposed to contaminants in drinking
water. In addition, based on air modeling, release of emissions
from the municipal air strippers do not contribute a greater than
1 x 10"6 risJc level to receptors.
Since treatment of groundvater will not achieve a reduction in
toxicity, mobility or volume, the major trade-offs that provide
the basis for this selection decision are long-tern
effectiveness, short-term effectiveness, implementability, and
cost. The selected remedy can be implemented a.nd completed more
quickly with less difficulty and at less cost than groundwater
treatment alternatives, thus reducing the exposure time for
pathway* of concern. Alternative 5 is therefore considered to be
the most appropriate solution to contamination at the site
because it provides the best trade-offs with respect to the nine
criteria and represents the maximum extent to which permanent
solutions and treatment are practicable.
5. Preference for Treatment as a Principal Element
By treating ths VOC-contaainated soils using SVE with carbon
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36
absorption of off-gases with regeneration of the carbon, the
selected remedy satisfies the statutory preference for remedies
that employ treatment of the principal threat which permanently
and significantly reduces toxicity, mobility, or volume of
hazardous substances as a principal element. Treatment of
groundwater to reduce toxicity, mobility, or volume would also
seem to b« desirable to satisfy th« statutory preference.
However, treatment of groundwater to permanently and
significantly reduce toxicity, mobility, or volume of
contaminants was not found to be practicable or cost-effective
for remediation of the site.
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SOLID STATE CXRCUITS, MD
SECTIC.V 10.0 STATVTCPY -r-^^wf^MATICNS
Vnder its legal authorities, EPA's primary respo-sici1it. it
S-parfund sites is to undertake remedial actions that acn _ = •.-="
ader--3te protection of human r.ealtn and the environment I"
additic-. section 121 of CEP.CLA estaolisr.es several ot.- = r
statutory requirements and preferences. These specify tnat -••=-
complete, t.-.e selected remedial action for tnis site rust cc-r..
with applicable :r relevant and appropriate environmenta.
standards established under federal and State environments. . i-s
unless a statutory waiver is justified. The selected re.-ec/. 2.5:
rust be cost effective and utilize permanent solutions and a.ter-
native treatment technologies or resource recovery technologies
to the maximum extent practicable. Finally, the statute incl.ies
a preference for remedies that employ treatment that perr.ane-t...
and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
10.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environ-
ment through extraction and treatment of the VOC contaminates
ground water. The contaminants will be permanently removed :rc-
tr.e ground water by air stripping. The volatile dissolved gas^s
will be transferred to the air stream for release tc the
atmosphere.
Extraction of the VOC contaminated ground water also will
eliminate the threat of exposure to the most mobile contaminants
from direct contact or from ingestion of contaminated ground
water. The future carcinogenic risks associated with these
exposure pathways are as high as 1.1 x 10 , or one person in
ten, for TCE. By extracting the contaminated ground water and
treating it bv air stripping, the cancer risks will be reduced to
acout l x 10"6 and an Hazard Indices (HI) ratio of less than l.
A numerical computer model was utilized to predict the highest
airborne concentrations emitted from the air strippers. The
location with the highest concentrations was used to evaluate
potential h«alth risks. The highest cancer risk is 6.5 x i:-5
and the nigh«st HI ratio is 0.3997. These levels are within- the
range of acceptable exposure levels of between 10*4 and 10" and
an HI ratio of less than 1 There are no short-term threats
associated with the selected remedy that cannot be readily
controlled. In addition, no adverse cross-media impacts are
expected from the remedy.
61
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— — - a
The selected remedy of extraction , or.sita =- /sic al, c.-eriral
treatment, and discharge of tr.e treated effluent io tr.e' PCT'* » . . 1
ocmply with all applicable or relevant and approcriate cr.emical.
artier., and location specific retirements 'XkA^sj. The A?.A3s
are presented below.
Action -specific .AJIAJ? s :
N'ational Primary ana Secondary A,T_oient Air ^ualif/
Standards (40 CF3 Part 50)
State air quality Ce M'.nimis Emission levels
; 10 CSR 6.060(7) (A) ] ;
State water quality standards for aquatic life
protection (10 CSR 20-7.031) incorporated into tne
MPDES pemit for the POTW discharge to Dry Branch;
National Pretreatment Standards, 40 CFR Part 403;
and,
Pretreatment standards of 200 ug/ 1 and 200 gpn
established by the City of Republic for the
discharge of treated S5C effluent to the POTW.
Chemical-specific ARARs:
Federal Maximum Contaminant Levels for inorganic and
volatile organics in drinking water supplies
(40 CFR Part 141) ;
state Maximum Inorganic Chemical Contaminant Levels
(10 CSR 60-4.030) for public water systems;
State Maximum Volatile Organic Chemical Contaminant
Levels for public water systems (1C CSR 60-4.100);
and,
State water quality standards for inorganic and
volatile organics in ground water (10 CSR 20-7.031).
Lccation-sp«cif ic ARARs:
Other Criteria, Advisories or Guidance To Be Considered for This
Remedial Action (TBCs) :
62
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£?A and t.-.e State cf Missouri nave agreed to
incorporate a local ordinance to pronicit zonstr'-o-
tion of new water supply -ells in cr -ear tr.e ~~~-
taminant plumes until" tr.e remediation is comclata.
This will erevent direct contact and ~r ingest ion -
contaminated ground water.
ess
7-2 sa.ectad remedy 13 cost-effactive cecause it -.as ce =
T-i.-.ed to provide overall effectiveness propcrtional to
zests, t.u.a net present worth value being $4 , 529 , 4 CO . The s.
ed remedy is the least costly of the Alternatives II, III an- :v.
wr.irn are equally protective a: human health and tr.e environre.-.t.
13.4 Utilization of Permanent Solutions and Alternative Treats--.
Techno locries (or Resource Recovery Technologies i to tr.e
'X3xi~un Extent Practicable
The State of Missouri and EPA have determined that the
selected remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-
effective manner for the Solid State Circuits Site. Of those
alternatives that are protective of human health and the
environment and comply, with A_RARs, the State of Missouri and IPA
have determined that this selected remedy provides the cest
calance of tradeoffs in terms of long-term effectiveness and
permanence, reduction in toxicity, mobility, or volume achieved
t.-.rough treatment, short-term effectiveness, implementaoility.
cost, also considering the statutory preference for treatment 35
a pr.ncipal element and considering State and ccm.munity input.
Alternative II reduces the toxicity, mobility, and volume o:
tr.e contaminants in the ground water; complies with ARARs; pro-
vides short-term effectiveness; and protects human health and tr.e
environment ecojally as well a Alternatives III and IV. In terms
cf long-term effectiveness, Alternative II is more reliable
cackup to the stripper units and because it does not generate any
residuals. Alternative II will be easier to implement techni-
cally because it requires less construction and administratively
cecause it will require less coordination with relevant agencies.
Finally, and importantly, Alternative II costs the least of t.-.e
equally protective alternatives. The major tradeoffs that pro-
vide the basis for this selection decision are long-term effec-
tiveness, inplementability, and cost. The selected remedy is
-.ore reliable and can be implemented more quickly, with less
difficulty and at less cost than the other treatment alternatives
and is therefore determined to be the most appropriate solution
for the contaminated ground waters at the SSC site.
63
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^
addressed in
ugn cuoiic corrjr.er.ts were r-ce-vad ---- *—--Z -"3
tne —^unity's ?C7W, tr.csa ccrj-.er.-sT--"-'- : • "• """
the Responsiveness Sugary. ---- '
The Proposed Plan for tr.e S3C site was re'.», = ««
recent on August 14, 1339. The Pressed Plan "^. -1^
n:-f::r--r! -;".-"• ^e^red alterative. ^A"" r^i;;;1:. all
a..- .e__a^ comments sucmitted iurirg --<= ,i<- a_-
:?:;:!• ;:cl.raviaw of these -=-e--s, it ---as'det^.In-r-a-'
..,n ant ...anges to the remedy, as it was original'y
--en.i.ied in _ne Proposed Plan, was necessary. "
i:.5 Preference fo_r Treatment as a Princ—ai Him^nt
3y treating the VOC-contaminated ground waters in fo
existing onsite air strippers and discharging the treated
effluent to the POTW for secondary treatment, the se><-»ed —
addresses the principal threat of future direct contact/ i-q«s- ''•
of contaminated ground -waters posed by the site through the -si'
of treatment technologies. Therefore, the statutory pre*e-or^
f«iS;?*H1M that empl°y treac:nent as a Principal element Is
AaUXSr L@Li «
64
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10. RESPONSIVENESS SUMMARY
The final component of the ROD is the Responsiveness Summary which serves
two purposes. First, it provides lead agency decision makers with information about
community preferences regarding both the remedial alternatives and general concerns
about the site. Second, it demonstrates to members of the public how their comments
were taken into account as an integral part of the decision making process.
EXAMPLE: CHEMICAL INSECTICIDE, NJ
The sample Responsiveness Summary is very thorough and easy to follow. It
provides an overview of the activities required by Section 121 for public notification
and comment and outlines the various sections of the remainder of the Summary.
There is a brief history of the community relations activities for the community, and a
summary of major questions and responses received during the comment period. The
questions found here are excellent examples and typical of concerns often posed by the
public. The responses are logical and informative. A citizens' petition and the specific
response to it are also reproduced. For general information and a reference source the
proposed plan, attendance sheets from the public meeting, list of information
repositories and labs used (in response to a specific question) are attached as
appendices.
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. /%, ',
j fsmmV^ } UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
''*•***'„ ~ <\ •' ••» TQQQ JACO6 K JAVITS FED€^A1 BUUDfNG
i ^ U ' -^ " ^ »^ ..^ w^K^ii, kj£\A^ V/^Bv irt^TSl
S«c Address List
R«: Your August 28, 1989 L«tt«r Concerning th«
Chsaical Ins«cticid« Corporation Sit« in Edison, N«v Jersey
Dear :
Thank you for the August 28, 1989 letter which you and other
concerned citizens wrote to express your questions and cements
concerning the Environmental Protection Agency's Proposed Plan
for an interim remedial action at the Chemical Insecticide
Corporation Site. The concerns expressed in your letter have
been reviewed by appropriate Environmental Protection Agency
staff, by Ebasco Services personnel who worked on the Remedial •
Investigation and Feasibility Study for the site, and also by an
Agency for Toxic Substances and Disease Registry representative
assigned to the EPA Region II office. A response to the
questions and comments expressed in your letter has been
prepared, incorporating information obtained from the reviewers
mentioned above. A copy of this response is enclosed and is
being be sent to each of the signers of the August 21 letter.
Copies of both the August 28 letter and EPA's response will also
be placed in the information repositories for the Site.
EPA will keep you informed of our progress regarding the Chemical
Insecticide Corporation Site, including the decision regarding
the selection of an interim remedial action. I appreciate your
interest and participation in the Superfund program.
Sincerely yours
Jonathan Jolephs
chemical Engineer
New Jersey Compliance Branch
Emergency and Remedial Response Division
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RZSPONSIVZXZSS SUMMARY
CHEMICAL EHSECTICIDE CORPORATION SITS
EDISON, NKH JERSEY
I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public
comment period from August 3, 1989 through September 8, 1989 for
interested parties to comment on the Focused Remedial
Investigation/Feasibility Study (RI/FS) report for Surface Water
Run-off Control and the Proposed Remedial Action Plan (PRAP) for
the chemical Insecticide Corporation (CIC) Site in Edison, New
Jersey.
The PRAP, which has been provided as Appendix A of this document,
provides a summary of the background information leading up to
the public comment period. Specifically, the PRAP includes
information pertaining to the history of the CIC Site, the scope
of the proposed cleenup action and its role in the overall Site
cleanup, the risks presented by the Site, the descriptions of the
remedial alternatives evaluated by EPA, the identification of •
EPA's preferred alternative, the rationale for EPA's preferred
alternative, and the community's role in the remedy selection
process.
EPA held a public meeting at 7:00 p.m. on August 10, 1989 at the
Edison Municipal Complex in Edison, New Jersey to outline the
interim remedial alternatives described in the focused RI/FS and
to present EPA's proposed remedial alternative for controlling
the surface water run-off from the CIC Site.
The responsiveness summary, required by the Superfund Lav,
provides a summary of citizens' comments and concerns identified
and received during the public comment period, and EPA's
responses to those comments and concerns. All comments received
by EPA during the public comment period will be considered in
EPA's final decision for selecting the remedial alternative for
addressing surface water run-off from the CIC Site.
•
This responsiveness summary is organized into sections and
appendices as described below:
I. RESPOMSIVBflSS SUMMARY OVXK7XIV. This section outlines
the purposes of the Public Comment period and the
Responsiveness Summary. It also references the
appended background information leading up to the
Public Comment period.
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II. BACKGROUND ON COMMUNITY INVOLVEMENT AMD COWCZKNS. This
section provides a brief history of community concerns
and interests regarding the Chemical Insecticide
Corporation Site.
III. SUMMARY OP MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
TSE PUBLIC COMMENT PERIOD AKD EPA RESPONSES TO THESE
COMMENTS. This section summarizes the oral comments
received by EPA at the August 10, 1989 public meeting,
and provides EPA's responses to these comments.
IV. HRIlTKIf COKKENTS RECEIVED DORZKG TEE PUBLIC COMMENT
PERIOD AMD EPA RESPONSES TO THESE COMMENTS. This
section contains the one letter received by EPA
containing written comments, es well as EPA's written
response to that letter.
Appendix A: The Proposed Remedial Action Plan (PRAP)
which was distributed to the public during the public
meeting on August 10, 1989.
Appendix B: Sign-in sheets from the Public
Meeting held on August 10, 1989 in The Edison Municipal
Complex, Edison, New Jersey.
Appendix C: Names, addresses and phone numbers of the
information repositories designated for the CIC Site.
Appendix D: A list of the laboratories used to
analyze samples from the CZC Site.
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II. BACKGROUND ON COMMUNITY ZHVOLVBCZXT AMD COMCBOfS
Township records show that community concern regarding the CIC
Site, existed as early as 1966, when residents living near the
Site complained of odors emanating from the CIC Sit*. The Edison
Township Department of Health and Human Resources and the New
Jersey Department of Health (NJDOH) continued to receive
complaints from residents and business operators about odors and
air pollution from 1966 through 1970.
Community interest increased in June 1983 when the New Jersey
Department of Environmental Protection (NJDEP) and ZPA began
collecting soil samples for a State-wide dioxin-screening
program. Residents were concerned about the potential for off-
site migration of dioxin into surrounding residential areas. EPA
held a public meeting on June 20, 19S3 to address community
concerns. Several hundred residents attended the meeting and
extensive media coverage continued for week*.
Residents, local officials and business owners were interviewed
in 1987 during the development of the Community Relations Plan
for the Site. Their concerns are summarized below:
• Residents would like to be better informed of all EPA
activities at the CIC site.
• Residents were concerned about the potential exposure to
dioxin during EPA activities.
• Local officials and residents were concerned that local
property values could be adversely affected by the EPA
activities at the CIC Site.
• Residents and business owners were concerned regarding
the extent and potential of contamination at the Site and
of the surrounding business and residential properties.
As part of EPA's responsibility and commitment to the Superfund
Program, the community has been kept informed of ongoing
activities conducted at the CZC Site. EPA has established
information repositories where relevant site documents may be
reviewed* Documents stored at the repositories include:
• The focused RZ/FS Report for surface run-off
control.
• The Proposed Remedial Action Plan (PRAP).
• Fact sheets, summarizing the technical studies
conducted at the sits.
• Public Meeting Transcript.
3
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"PA1* aalaction of L ramedy to control «urfac«t watar run-off at'
the Sit* will be praaentad in a document known as a Record of
Decision (ROD). The ROD and the document* containing information
that EPA used in aaJcing it* decision («xc«pt for docuaant* that
arc published and generally available) will al«o be placad in the
information r«po*itori«a, as will this r««pon*ivene*a summary.
ITT. SUXHARY 07 KAJOR QUESTIONS AKD COWGWTS RBCETTSD DURING TKZ
PuttLIC COMMENT sERIOO AKD ZPA RZSPONS&S TO TBZS* COMMENTS
Oral comments raised during the public comment period for the cic
Sit* interim raaadiation have b««n aunuiriz«d b«lov together with
EPA'a ra«pon«« to thece coaaientc.
COKKQIT: One resident wanted to know why it vai neceaaary to
aelect an interim remediation alternative if a final reaedy would
be the aoat protective of huaan health and the environment.
RZSPONSf: A final reaedy which would, among other thing*, clean
up the contaminated soil at the Site, cannot be aelected at the
present time. £PA has determined that treatability studies are
needed to find the most effective technology or combination of -
technologies for treating the Site soils. The particular mixture
of pollutants in the Site soils (arsenic and pesticides, in
particular) is potentially difficult to treat. This is because
the most proven technology for organic pesticides, thermal
treatment (e.g. incineration), may not be effective in treating
arsenic. In fact, the arsenic emissions from an incinerator
treating Site soils might present an air pollution hazard, unless
treatability studies caji show that air pollution controls are
capable of reducing arsenic emissions to safe levels. Therefore,
EPA is currently planning to test thermal treatment and other
technologies such as soil extraction and soil fixation on soil
samples from the Site.
Depending on the final remedy eventually selected, it could taJce
up to eight years to perform treatability studies, select the
remedy, design the; remedy and implement the remedy. Unless an
interim remedy Is Implemented first, the surface water run-off
from the Site would present continued risks until the remedy for
Site soil* ham been implemented.
EPA believe* that the surface water run-off problem should be
addressed first, since EPA is now in a position to addrsss the
hazards presented by the surface water run-off from the site.
While the interim remedy is proceeding, EPA would not slacken its
efforts to achieve a final remedy. Once the final remedy for
sita soil has been implemanted, surface run-off fro* the Sits
would no longer b« contaminated by contact with Site soils.
Therefore, the surface watar raaedy la considered to b* an
interim measure which would no longer be naadad onea the Site
soils have been cleaned up.
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COMXZNT: On* resident asked what typ« of capping cyfc.ea would be
used and how effective would it be.
RESPONSE: If an impermeable •urficial capping system was
implemented, it would probably consist of a multi-layer cap with
a synthetic membrane or a sprayed-on lining, together with
protective layers, such as textile "abrics. Standard landfill
caps are intended to b« effective f_>r thirty years or sore.
However, the capping systea recommended by EPA for the CIC site
would only be needed for the duration of the interim remedy
(probably less than eight years). This capping system would have
fewer layers than the standard landfill caps. Therefore, the
capping system would allow easier access to collect any soil
samples required for a treatability study, and would be easier to
remove once the final remediation plan was implemented.
COMMENT: A resident inquired whether capping system* have been
used on other sites and, if so, how effective they were.
RESPONSE: Surficial caps have been employed at a number of sites
such as hazardous waste landfills and municipal landfills. This
technology has proven quite effective over time periods similar
to that contemplated for this interim action in preventing the *
migration of contamination in the past.
COMMENT: One resident noted that there would be a large quantity
of run-off if a surficial cap were installed on CIC's six acre
lot. The resident wanted to know what type of storage capacity
EPA has planned to accommodate the large volume of accumulated
run-off.
RESPONSE: A detention structure would be constructed in the
northeast corner of the Site to regulate the flow of discharge so
that the remedy would not cause any adverse flooding impact. As
part of the remedial design for Alternative 2, a drainage
analysis would be performed. The size of the detention structure
and the details of any other measures needed to avoid flooding
impact (e.g., improvements in area storm drains), would be based
on that drainage anelyeis. The detention structure for
Alternative 2 would not necessarily be designed to detain the
precipitation fro* a once in twenty-five year storm event.
COMMENT* A resident asked if Alternative 2 was selected, when
would Zffe expect the surficial cap to be installed.
RESPONSE: Work could begin on capping the Site approximately six
months following finalization of the ROD for this interim action.
The remedial design would be) performed during those six months.
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EPA RESPONSE TO THE AUGUST 28, 1989 WRITTEN COMMENTS REGARDING
THE CHEMICAL INSECTICIDE CORPORATION SITE IN EDISON, NEW JERSEY
The August 28, 1989 written comments regarding the Chemical
Insecticide Corporation Site have been summarized below, together
with and EPA's responses to these comments.
COMMENT: How much and what types of contaminants were on-site
and have spread off-site?
RESPONSE: The types of contaminants linXed to the Site were
discussed at the August 10, 1989 public meeting and summaries of
the analytical data were presented. Unfortunately, the slides
that were projected were not very clear. The chief contaminants
are arsenic, pesticides (DOT, lindane, chlordane, dieldrin,
etc.), herbicides (e.g., 2,4,5-T, 2,4-D and dinoseb) and dioxin.
Summaries of this data, which provide concentration values for
the measured contaminants in the different media sampled, can be
found in Exhibits 1-12 through 1-24 of the Focused RI/FS Report.
The results for on-site and off-site samples have been summarized
separately in these exhibits. The complete set. of sampling data,
together with maps showing the sampling locations, can be found
in the two-volume document containing the "Remedial Investigation
Field Data: Validated Laboratory Results" (Ebasco, July 1989).
These documents are available in the information repositories
the Site. Because of the volume of this information, it is not
practicable to present it here.
COMMENT: What effects did these contaminants have on the workers
of the factory, the community and the surrounding land and
animals?
RESPONSE: There is little information currently available to EPA
indicating any effects of the contaminants on *:he CIC employees,
the area residents and animals. In the 1960's several cattle
were alleged to have died as a result of drinJcing arsenic
contaminated water downstream of the factory. However, the
levels of arsenic found at the downstream sampling locations
during th« Remedial Investigation are much less than those
associated with such acute effects. In all likelihood, the
arsenic concentrations were much higher during the period when
the Chemical Insecticide corporation was operating and the cattle
deaths occurred.
As noted at the public meeting, sampling results from the
Remedial Investigation and other studies indicates that
contamination of the land around the CIC property by arsenic,
pesticides and herbicides is chiefly limited to the easement area
immediately east of the CIC property. In addition, soil
concentrations of dioxin off of the CIC property have all been
-------
11. LETTER FROM SUPPORT AGENCY
It is recommended that a letter stating the position of the support agency be
attached as an appendix to the ROD to demonstrate their concurrence. State
concurrence may also be demonstrated by the State Director's signature, however, that
seems to be more rare than a copy of the State letter. If the State has withheld an
opinion or given concurrence verbally, the ROD should state this in the Declaration and
in the Summary of Comparative Analysis of Alternatives section of the Decision
Summary.
EXAMPLE: MW MANUFACTURING, PA
A copy of two State letters are attached. These letters are brief and recount what
documents were reviewed, the major components of the remedial action with which the
State concurs, and lists any conditions to that concurrence such as continued
consultation during RD/RA, reserving the right to take independent enforcement action
and to be party to any negotiations with the PRPs.
EXAMPLE: WAUSAU WATER SUPPLY, WI
The second letter reviews costs and recognizes that the State may be required to
contribute 10% of the cost of the remedy should the PRPs refuse or be unable to fund the
action. It also outlines the role the State expects to play during the RD/RA.
-------
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office 3ox 2063
Harnsburg, Pannsylvania 17120
Deputy Secretary for
Environmental Protection
March 30, 1989
(717) 737.5023
Mr. Stephen R. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
341 Chestnut Building
Philadelphia, PA 19107
Re: Letter of Concurrence
M. W. Manufacturing Superfund Site, Record of Decision (ROD)
Dear Mr. Wassersug:
The Record of Decision for the initial operable unit which addresses
the main source of the contamination by remediation of the carbon waste pile at
the M. w. Manufacturing site has been reviewed by the Department,
The major components of the selected source control remedy include:
* Excavation of approximately 875 cubic yards of contaminated waste
and contaminated underlying soils and incineration in an off-site
RCRA approved Incinerator.
* Disposal of incinerator ash in a RCRA permitted hazardous waste
landfill.
conditions:
I hereby concur with the EPA's proposed remedy with the following
Tht Otpirtment will be given the opportunity to concur with
decisions related to the overall Remedial Investigation and
Feasibility Study to identify the extent of, a/id future potential
for, groundwater contamination and remaining sources of that
•contamination, and evaluate appropriate remedial alternatives to
assure compliance with DER cleanup ARARs and design specific
ARARs.
EPA will assure that the Department is provided an opportunity to
fully participate in any negotiations with responsible parties.
The Department will reserve our right and responsibility to take
independent enforcement actions pursuant to state law.
-------
Mr. Stsonen
This concurrence with :he selected remedial acti:n ^
^tended to provide .-y assurances pursuant to SARA
Section 104(c)(3).
ot
Thank you for the oooortunity to concur with thi; E°4 Record :f Tec'
If you have questions regarding this matter, please do not hesitate to contact
Sincerely,
Mark M. McClellin
Deputy Secretary
Environmental Protection
-------
EHP 29.
State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
Ctrrett 0. SiMtfry, S«c.-«:«'y
Sor 792T
kbdltan, WT«conifn J37C7
TZLefAX HO. «OI-2«7.3S;)
7DO MO. «0«-2«7.«837
September 28, 1989 IH RI?LY R2?£R TO: 4440
Mr. Valdus Adaakus, Regional Administrator
U.S. Environmental Protection Agency, Region V
230 South Dearborn Street
Chicago, IL 60604
SUBJECT: Selected Super fund Remedy
Vaujau Groundvater Cont«ain«tion Sice
W«u**u, Uiseonxin
Dear Mr. Adtakua:
Your ataff ha* requested thii letter to doeuaent our pocition on the final
reaedy for the tfauaau Groundvater Contaaination Site. The propoaed final
reaedy, identified ai Alternative No. 5, ia diaeussed fully in the Record of
Decision and includes:
• Installation of Soil Vapor Extraction (SVE) sycteas to remove volatile
organic compound* (VOCa) in soils at each of the three identified source
area*
• Tree went of of f> gases froa the SVE operation using vapor phase carbon
units which will be regenerated at a off-sice RCSA-approved facility; and
• Croundwater reaediation utilizing specified puapage rates of the
aunicipal supply veils in order to expedite removal of the groundvater
contaainant pluaes affecting these wells.
The costs of the selected reaedy are estimated to be
*
Capital costs - $252,000
• Operatioa costs • $222,000
An eighteen aottCh operating period was assuaed and the costs vere not
discounted.
Based upon our review of th« public comaent Feasibility Study received on
August 14, 1989, and the draft Record of Decision received on
September 8, 1989, our agency concurs with the selection of this reaedy.
We understand that your staff snd contrsctors, or the potentially responsible
psxtiss vill develop the asjor design eleaents of the soil vapor extraction
systeas, the off* gas trestaent systea snd tbs groundwatsr remediation system
-------
3535333 5£? 29.
-.-so-: 3
i ,j •
Mr. Veldus Adaskua • S«ptaab«r 23. 1939
In eloae consultation with BY staff dur
-------
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive: 9335.3-02FS-1
November 1989
&EPA
A Guide to Developing
Superfund Records of Decision
Office of Emergency and Remedial Response
Hazardous Site Control Division
Quick Reference Fact Sheet
EPA issues the Record of Decision (ROD) as the final remedial action plan for a site or operable unit. The ROD summarizes the problems
posed by the conditions at a site, the alternative remedies considered for addressing those problems, and the comparative analysis of those
alternatives against nine evaluation criteria. The ROD then presents the selected remedy and provides the rationale for that selection,
specifically explaining how the remedy satisfies the requirements of section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986.
This guide provides ROD preparers with a quick reference to the essential ROD components. The information to be included in each of the
three major sections of a ROD is summarized below. Close attention should be given to the sections in which alternatives are described, risk
information is presented, the comparative analysis against the nine evaluation criteria is summarized, and the declaration of statutory
determinations is made. Additional information on ROD preparation is provided in Chapters 6,7, and 9 of the "Interim Final Guidance on
Preparing Superfund Decision Documents" (the "ROD Guidance") (OSWER Directive 9335.3-02, November, 1989, EPA/540/G-89/007).
THE DECLARATION
The Declaration is a formal statement signed by the EPA Regional Administrator (RA)or Assistant Administrator (AA)of the Office of Solid
Waste and Emergency Response (OSWER) that identifies the selected remedy and indicates that the selection was carried out in accordance
with the statutory and regulatory requirements of the Superfund program. The State Director may also sign the Declaration, if appropriate.
The Declaration should be approximately two pages long and should include the information provided in Highlight 1.
Highlight 1: Outline and Sample Language for the Declaration of the Record of Decision
Site Name and Location
Statement of Basis and Purpose
"This decision document presents the selected remedial ac-
tion for the [site], in [location], which was chosen in accor-
dance with CERCLA, as amended by SARA, and, to the ex-
tent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based
on the administrative record for this site."
"The State/Commonwealth of concurs with the se-
lected remedy."
Assessment of the Site
"Actual or threatened releases of hazardous substances
from this site, if not addressed by implementing the response
action selected in this Record of Decision (ROD), may pre-
sent an imminent and substantial endangerment to public
health, welfare, or the environment."
Description of the Selected Remedy
n Describe the role of this operable unit within the overall site
strategy. (Does this operable unit address the principal
threats posed by the site?)
n Describe the major components of the selected remedy in
bullet fashion.
Statutory Determinations
a When the selected remedy satisfies the statutory preference
for treatment as a principal element by addressing the prin-
cipal threat(s) at the site with treatment, the Declaration
should state:
"The selected remedy is protective of human health and
the environment, complies with Federal and State re-
quirements that are legally applicable or relevant and ap-
propriate to the remedial action [or "a waiver can be justi-
fied for whatever Federal and State applicable or relevant
and appropriate requirement that will not be met"], and is
cost-effective. This remedy utilizes permanent solutions
and alternative treatment (or resource recovery) technol-
ogy, to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal
element."
(or)
When a remedy involving little or no treatment is selected (i.e.,
treatment is not utilized to address the principal threat(s)),
CERCLA, as amended by SARA, requires a statement and ra-
tionale explaining why a remedial action involving such reduc-
tions was not selected. The Declaration should state:
"The selected remedy is protective of human health and the
environment, complies with Federal and State requirements
that are legally applicable or relevant and appropriate to the
remedial action [or "a waiver can be justified for whatever
Federal and State applicable or relevant and appropriate re-
quirement that will not be met"], and is cost-effective. This
remedy utilizes permanent solutions and alternative treat-
ment (or resource recovery) technologies, to the maximum
extent practicable for this site. However, because treatment
of the principal threats of the site was not found to be practi-
cable [or "within the limited scope of this action"], this rem-
edy does not satisfy the statutory preference for treatment as
a principal element."
If the remedy will leave hazardous substances on-site above
health-based levels, the Declaration should include the follow-
ing:
"Because this remedy will result in hazardous substances re-
maining on-site above health-based levels, a review will be
conducted within five years after commencement of reme-
dial action to ensure that the remedy continues to provide
adequate protection of human health and the environ-
ment."
(or)
If the remedy will not leave hazardous substances on-site
above health-based levels, the Declaration should include the
following:
"Because this remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year
review will not apply to this action."
(Signature of Assistant/Regional Administrator)
(Signature of State Director (if appropriate))
Date
(Note: Attach the State's letter of concurrence to the Record of
Decision package)
Printed on Recycled Paper
-------
THE DECISION SUMMARY
The Decision Summary provides an overview of the problems
posed by the conditions at a site, the remedial alternatives, and the
analysis of those options. The Decision Summary explains the
rationale for the selection and how the selected remedy satisfies
statutory requirements. The information to be presented in each
of the sections of the Decision Summary is outlined below. In
most cases, much of the information presented can be
summarized from the Remedial Investigation/Feasibility Study
(RI/FS).
Site Name, Location, and Description. Briefly describe the
site in terms of:
n Name, location, address (include maps, a site plan, or
other graphic descriptions, as appropriate);
n Area and topography of the site, especially if it is located
within a floodplain or wetlands;
D Adjacent land uses;
D Natural resource uses;
n Location and distance to nearby human populations;
D General surface-water and ground-water resources; and
D Surface and subsurface features (e.g., number and volume
of tanks, lagoons, drums, or other structures).
Site History and Enforcement Activities. Summarize the
following:
n History of site activities that led to current problems;
n History of Federal and State site investigations and
removal and remedial actions conducted under CERCLA
or other authorities; and
n History of CERCLA enforcement activities at the site,
including:
- The results of searches for potentially responsible
parties (PRPs); and
- Whether special notices have been issued to PRPs.
Highlights of Community Participation. Summarize the
major public participation activities, as follows:
o Describe how the public participation requirements of
CERCLA sections 113(kX2)(BXi-v) and 117 were met in
the remedy selection process.
Note: Community response to the selected remedy should be
addressed under the "community acceptance" criterion in the
Comparative Analysis section of the ROD. Responses to
community concerns should be addressed in the "Responsiveness
Summary' of the ROD.
Scope and Role of Operable Unit [or Response Action]
Within Site Strategy.
n Describe the role of the remedial action within the overall
site clean-up strategy.
a Summarize the scope of the problems addressed by the
remedial action selected. Will the action address any of
the principal threats posed by conditions at the site?
Note: The Statutory Determinations section of the ROD should
explain whether or not the selected remedy satisfies the statutory
preference for remedies employing treatment that reduces
toxicity, mobility, or volume as a principal element. By indicating
whether the principal threat(s) will be addressed by the action, the
Scope and Role section of the Decision Summary should provide
the basis for that statutory determination.
Summary of Site Characteristics. Highlight the following
factors:
n All known or suspected sources of contamination;
n Contamination and affected media, including:
- Types and characteristics (e.g., toxic, mobile,
carcinogenic, non-carcinogenic) of contaminants;
- Volume of contaminated material; and
- Concentrations of contaminants;
n Location of contamination and known or potential routes of
migration, including:
- Population and environmental areas that could be
affected, if exposed;
- Lateral and vertical extent of contamination; and
- Potential surface and subsurface pathways of
migration.
Include maps, charts, tables, and other graphic descriptions, as
appropriate.
Summary of Site Risks. Summarize the results of the baseline
risk assessment conducted for the site.
Human Health Risks:
n Identify the concentrations of the contaminants (indicator
chemicals) of concern in each medium of exposure;
a Summarize results of the exposure assessment;
n Summarize the toxicity assessment of contaminants of
concern;
Q Summarize risk characterization for each pathway and the
total risk for the site, including:
- Potential or actual carcinogenic risks;
- Noncarcinogenic risks; and
- Brief explanation of the meaning of key risk terms.
Environmental Risks:
n Summarize the affects of the contamination on critical
habitats; and
Q Summarize the affects of the contamination on any
endangered species.
Note: This summary of the baseline risk assessment provides the
rationale for the lead agency's either undertaking a response
action or taking no action.
Description of Alternatives. The objective of this section is to
provide an understanding of the remedial alternatives developed
for the site and their specific components. Each alternative
should be described in terms of the components listed below.
Figure 1 is an example of elements to be addressed in this section.
n Treatment components. Describe the following, as
appropriate:
- Treatment technologies (e.g., thermal destruction)
that will be used;
- Type and volume of waste to be treated;
- Process sizing; and
- Primary treatment levels (e.g., best demonstrated
available technology [BOAT], percentage or order of
magnitude of concentration reductions expected).
D Containment or storage components. Describe the
following, as appropriate:
- Type of storage (e.g., landfill, tank, surface
impoundment, containers);
- Type of closure that will be implemented
Subtitle C clean closure, landfill closure, Subtitle
solid waste closure);
- Type and quantity of waste to be stored; and
- Quantity of untreated waste and treatment residuals
to be disposed off-site or managed on-site in a
- 2 -
-------
containment system (cap., minimum technology unit,
etc.) and the degree of hazard remaining in such waste.
n Ground-water component. Describe the following, as
appropriate:
- Ground-water classification (e.g., Class I, II, or III);
- Remediation levels (e.g., Maximum Contaminant
Levels [MCLs]);
- Estimated restoration timeframe; and
- Area of attainment
a General components. Describe the following, as
appropriate, for each of the three previous components:
- Contaminated media addressed (and physical location
at the site);
- Initial risk;
- Risk reduction;
- Whether treatability testing has been or will be
conducted;
- Implementation requirements;
- Institutional controls;
- Residual levels (e.g., delisting, BOAT);
- Assumptions, limitations, uncertainties;
- Estimated implementation timeframe; and
- Estimated capital, O&M, and present-worth costs.
n The major applicable or relevant and appropriate
requirements (ARARs), risk-based levels, and other "to
be considered" (TBCs) being met/utilized for the specific
components of the waste management process.
- The description should summarize how the specific
components of the alternative will comply with the
major ARARs, as well as briefly describe why the
standard is applicable or relevant and appropriate
(e.g., placing a RCRA characteristic waste, thus
RCRA closure is applicable).
Summary of Comparative Analysis of Alternatives. In this
section, summarize the relative performance of the alternatives by
highlighting the key differences among the alternatives in relation
to the nine evaluation criteria. An effective way of organizing this
section is to present a series of paragraphs headed by each
criterion. Under each criterion, the alternative that performs best
in that category should be discussed first, with other options
discussed in sequence. Refer to the RI/FS and ROD guidance
documents for additional information on the factors included in
each Of the nine criteria. The nine evaluation criteria are
summarized below.
Threshold Criteria
n Overall protection of human health and the environment
- addresses whether a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
n Compliance with applicable or relevant and approptiate
requirements (ARARs) addresses whether a remedy will meet
all of the ARARs of other Federal and State environmental
laws and/or justifies a waiver.
Primary Balancing Criteria
D Long-term effectiveness and permanence refers to expected
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time,
once clean-up goals have been met.
D Reduction of toxicity, mobility, or volume through treatment
is the anticipated performance of the treatment technologies a
remedy may employ.
D Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until clean-up goals
are achieved.
n Implementability is the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement a particular option.
a Cost includes estimated capital and O&M costs, as well as
present-worth costs.
Figure 1
Components of Alternatives 1
28,000 YD3
(JON 1 AMINA 1 tU * EXCAVA
SOIL
[DRY
SCRUBBER
t
ON-SITE
noN INCINERATION
o be Described AIR
• 99 99% Destruction Removal Efflck
Residual Ash ON-SI^
Heavy Metals SUBTITI
• Heavy metals • clean closure • Meets LDfi BOAT 28'C
Cd+28ppm. , Backflll/regrade standards TRE
5?' I2KJIM , Revegetate
Pb 41 ppm
• VOCs
TCE 127 ppm
Benzene 52 ppm
• 1 0 ~ 2 carcinogenic risk level AIR
• Waste restricted under LDRs EMISSIONS
t
CONTAMINATED GROUND-V
GROUND WATER EXTRACT
• TCE 202 ppm • 1 75 Mil
Benzene 103 ppm Gallons
• 10~2 Carcinogenic Day pun
risk level rate
Time Until Cleanup Goals Met
WTER . AIRSTRIP
ION GAG
TREAT IN
Spent GAC ACCORDANCE
* WITH
LDR BOAT
OFF-SITE RCRA
» SI IBTITLE C
mcy DISPOSAL
• I nnq form OA,M
rE DISPOSAL - Ground-water
N RCRA monitoring
EC LANDFILL ' ?fP»er
OP Integrity
)UALS FROM • Deed restrictions
00 YD3 OF • Exposure level at
ATEDSOIL 10 -fi
concentration
levels
• $14,666,000
Capital
$43, 700 Annual
O&M
• $14,400,000
Present worth
OFF-SITE RCRA
DISPOSAL
Ion 982%
per tmuent ^ Removal Efficiency
DISCHARGE
TO
XYZ RIVER
Soil
'
• NPDES permit
• 10~6 carcinogenic
risk level
• $12.527,000 Capital
$525,000 Annual O&M
• $15,300,000
Present worth
~ 28 Months
i
Ground water ^^
~ 8Yrs
-------
Modifying Criteria
a State/Support Agency Acceptance should be used to indicate
the support agency's comments. Where the State or Federal
agency is the lead for the ROD, EPA's acceptance of the
selected remedy should be addressed under this criterion.
n Community Acceptance summarizes the public's general
response to the alternatives described in the Proposed Plan
and RI/FS Report. The specific responses to public
comments should be addressed in the Responsiveness
Summary section of the ROD.
Notes: In addressing the long-term effectiveness and
permanence of an alternative, the term "permanence" should be
used carefully. Permanence is viewed along a continuum; an
alternative can be described as offering a greater or lesser degree
of long-term effectiveness and permanence. Alternatives
generally should not be described as "permanent" or
"impermanent."
Only reductions achieved through treatment should be addressed
under the "reduction of toxicity, mobility, or volume through
treatment" criterion. Reductions of mobility accomplished
through containment should be addressed under "overall
protection of human health and the environment."
The Selected Remedy. In this section of the ROD, identify the
selected remedy and remediation goals and state:
a The carcinogenic risk level to be attained and the
rationale for it; and
n The specific points of compliance, as appropriate, for the
media being addressed (e.g., "MCLs will be met at the
edge of the waste management area").
The Statutory Determinations. The remedy selected must
satisfy the requirements of section 121 of CERCLA to:
a Protect human health and the environment;
D Comply with ARARs (or justify a waiver);
n Be cost-effective;
n Utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and
n Satisfy the preference for treatment as a principal element
or justify not meeting the preference.
A description of how the selected remedy satisfies each of the
statutory requirements should be provided. Points to address for
each of these requirements are presented in Highlight 2.
Documentation of Significant Changes. CERCLA section
1 17(b) requires an explanation of any significant changes from the
preferred alternative originally presented in the Proposed Plan. If
the selected remedy reflects significant changes from the
preferred alternative, the ROD should:
a Identify the preferred alternative originally presented in
the Proposed Plan;
Q Describe the significant changes; and
n Explain the reason(s) for such changes.
THE RESPONSIVENESS SUMMARY
The final component of the ROD is the Responsiveness
Summary, which serves two purposes. First, it provides lead
agency decisionmakers with information about community
preferences regarding both the remedial alternatives and general
concerns about the site. Second, it demonstrates to members of
the public how their comments were taken into account as an
integral part of the decision making p rocess.
Guidance on preparing Responsiveness Summaries is available in
Community Relations in Superfund: A Handbook (OSWER
Directive 9230.0-3B, June 1988). That document details the
process of preparing the Responsiveness Summary and includes a
sample Responsiveness Summary.
Highlight 2: The Statutory Determinations
Protection Of Human Health And The Environment
a Describe how the selected remedy will eliminate, reduce,
or control risks posed through each pathway through
treatment, engineering controls, or institutional controls,
to ensure adequate protection of human health and the
environment (including that the site risk will be reduced
to within the 10-4 to 10-6 range for carcinogens, and that
the Hazard Indices for non-carcinogens will be less than
one).
D Indicate that no unacceptable short-term risks or cross-
media impacts will be caused by implementation of the
remedy.
Compliance with ARARs
a State whether the selected remedy will comply with
ARARs. When appropriate, state the waiver that is being
invoked and justify the waiver. Organize the ARARs ac-
cording to chemical-specific, location-specific, and ac-
tion-specific.
a List and describe the Federal and State ARARs that the
selected remedy will attain, distinguishing applicable
from relevant and appropriate requirements, as neces-
sary. Note: Cite the specific section of the statute or regu-
lation that contains the requirement and provide a brief
synopsis of the requirement.
Q List and provide the rationale for using any "to be consid-
ered" (TBCs). Note: TBCs are not ARARs, but they may
be used to design a remedy or set clean-up levels if no
ARARs address the site, or if existing ARARs do not en-
sure protectiveness.
Cost-Effectiveness
D Describe how the selected remedy provides overall effec-
tiveness proportionate to its costs, such that it represents a
reasonable value for the money to be spent.
Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Technolo-
gies to the Maximum Extent Practicable ("MEP")
n Describe the rationale for the remedy selection, explaining
that the remedy selected provides the best balance of trade-
offs among the alternatives with respect to the evaluation
criteria, especially the five balancing criteria.
a Discuss those criteria that were most critical in the selec-
tion decision (i.e., those that distinguish the alternatives
most).
n Highlight the tradeo ffs among the alternatives with respect
to the five balancing, criteria.
D Describe the role of the State and community acceptance
considerations in the decision-making process (modifying
criteria).
n Provide a general statement that the selected remedy
meets the statutory requirement to utilize permanent solu-
tions and treatment technologies, to the maximum extent
practicable.
Note: For a remedy that does not employ any treatment or re-
source recovery technologies, the explanation of the rationale
should discuss the reasons why treatment was found to be impracti-
cable or acknowledge that treatment was not within the limited
scope of the action (e.g., an interim action).
Preference for Treatment as a Principal Element
n Describe how the preference for treatment is satisfied if the
remedy uses treatment to address the principal threat(s)
posed by conditions at the site; or
n Explain why the preference is not satisfied if treatment is
not used to address the principal threats. This explanation
will refer back to the explanation under the "MEP" finding
that explains why treatment of the principal threats was
found to be either impracticable or not within the limited
scope of the action.
- 4 -
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United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive: 9335.3-02FS-2
May 1990
A EPA
A Guide to Developing
Superfund Proposed Plans
Office of Emergency and Remedial Response
Hazardous Site Control Division
Quick Reference Fact Sheet
Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization Act (SARA) of 1986, requires preparation of Proposed Plans as part of the site remediation
process. The Proposed Plan is prepared after the Remedial Investigation/Feasibility Study (RI/FS) is completed and is made available with the
RI/FS to the public for comment. The Proposed Plan highlights key aspects of the RI/FS, provides a brief analysis of remedial alternatives
under consideration, identifies the preferred alternative, and provides members of the public with information on how they can participate in
the remedy selection process. A notice and brief analysis of the Proposed Plan is published in a major local newspaper of general circulation. In
addition, the Proposed Plan, the RI/FS, and the other contents of the Administrative Record are available at an information repository near
the site.
This guide outlines the major components of the Proposed Plan and suggests effective ways in which the various sections can be presented.
EPA recommends issuing the Proposed Plan in a fact sheet format. For some highly complex sites or remedies, more detailed Plans may be
appropriate. All Proposed Plans should be written in a style that makes the material easy for the public to understand and should emphasize
that the preferred alternative identified in the Proposed Plan is a preliminary determination, and that the Agency is requesting comments on all
of the alternatives.
Detailed guidance on the preparation of the Proposed Plan is provided in Chapters 2,3, and 9 of the "Interim Final Guidance on Preparing
Superfund Decision Documents" (the "ROD Guidance") (OSWER Directive 9335.3-02, November 1989, EPA/540/G-89/007).
Introduction
Begin with a statement of the document's purpose. This
introduction should state the site name and location, identify the
lead and support agencies, and state that the Proposed Plan:
n Fulfills the requirements of CERCLA section 117(a);
n Describes the remedial alternatives analyzed for the site or
operable unit;
a Identifies the preferred alternative and explains the rationale
for the preference;
D Highlights key information in the RI/FS and administrative
record, to which the reader is referred for further details;
n Solicits community involvement in the selection of a remedy;
and
a Invites public comment on all alternatives.
Site Background
Provide a brief description of the site, including:
n History of site activities that led to current problems at the site;
and
a The site area or media to be addressed by the selected remedy.
Figure 1 is an example of a site map that could be included.
Scope and Role of Operable Unit or Response
Action
a Identify the principal threats posed by conditions at the site;
and
a Describe the scope of the problems addressed by the preferred
alternative and its role within the overall site clean-up
strategy.
Summary of Site Risks
a Provide a brief overview of the baseline risk assessment,
including the contaminated media, contaminants of concern,
exposure pathways and populations, and potential or actual
risks;
a Describe how current risks compare with remediation goals;
and
n Discuss environmental risks, as appropriate.
Summary of Alternatives
Describe briefly each of the alternatives evaluated in the detailed
analysis of the FS. Highlight the following:
a Treatment components;
a Engineering controls (noting the type of containment
controls); and
a Institutional controls.
Quantities of waste and implementation requirements related to
each component should be noted, as well as major applicable or
relevant and appropriate requirements (ARARs), the estimated
construction, and operation and maintenance (O&M) costs (also
expressed in present worth), and the implementation time of each
alternative. Emphasize that these latter two evaluations are
estimates. An example is presented in Highlight 1.
-------
Figure 1
EIO Industrial Site and Surroundings
D c C
E7/3 Soil Contamination
C Private Wells
- - Site Boundary
F Municipal Well ~ N '
• NOT TO SCALE
Highlight 1: Summarizing an Alternative
Treatment Components:
Excavation, on-site incineration of contaminated soils, and
solidification and off-site disposal of residual metals and ash.
Estimated Construction Cost: $42,463,300
Estimated Annual O&M Costs: $26,200
Estimated Present-Worth Costs: $42,708,780
Estimated Implementation Timeframe: 30 Months
Under this alternative, a mobile incinerator would be brought
to the site, and 28,000 cubic yards of soils contaminated with
RCRA listed wastes would be excavated and incinerated on-
site to BOAT levels established under the RCRA Land Dis-
posal Restrictions (LDR). Waste gases and water from this
process would be collected and treated off-site in a RCRA
Subtitle C treatment facility; residual metals and ash would be
solidified to achieve LDR treatment standards and disposed
off-site in a RCRA Subtitle C disposal facility.
Evaluation of Alternatives and the Preferred
Alternative.
a Identify the preferred alternative, emphasizing that the
selection of this alternative is preliminary and could change
in response to public comments or other new information.
Sample text is presented in Highlight 2.
Highlight 2: Stating the Preferred Alternative
The preferred alternative is alternative number 3. Alterna-
tive 3 includes excavation and on-site incineration of con-
taminated soils, with solidification and off-site disposal of
residual metals and ash. Based on new information or pub-
lic comments, EPA, in consultation with the State of Ten-
nessee, may later modify the preferred alternative or select
another remedial action presented in this Proposed Plan
and the RI/FS. The public, therefore, is encouraged to re-
view and comment on all of the alternatives identified in
this Proposed Plan. The RI/FS should be consulted for
more information on these alternatives.
Introduce the nine evaluation criteria used to evaluate the
alternatives.
Summarize the expected performance of the preferred
alternative in terms of the nine evaluation criteria
explaining how the preferred alternative compares to the
other alternatives with respect to those criteria This
description is for the preliminary preference. Sample text
for one criterion is presented in Highlight 3.
Highlight 3: Presenting the Evaluation of
Alternatives
Short-term effectiveness.
Alternative number 4 uses a treatment process for soils and
disposal of residuals in an on-site landfill that contains the
contaminated soils and reduces the possibility of direct hu-
man contact with contaminants more quickly than all of the
other alternatives except Alternative 1 (no action). Under
the preferred alternative, once the volatile organics have
been collected in canisters, there is some minor short-term
risk of exposure to the community during transportation of
the canisters to a disposal site.
Because the capacity of on-site and off-site incinerators is
limited, under Alternatives 3 and 5 contaminated soils
would be stockpiled for up to six years. Under these two
alternatives, the risks of direct contact with stockpiled con-
taminated soils would be increased until incineration has
been completed. In addition, there are some risks of expo-
sure to air emissions from the incinerators.
The nine evaluation criteria are summarized below.
Threshold Criteria:
- Overall protection of human health and the environment
addresses whether a remedy provides adequate protection
of human health and the environment and describes how
risks posed through each exposure pathway are elimi-
nated, reduced, or controlled through treatment, engi-
neering controls, or institutional controls.
- Compliance with applicable or relevant and appropriate
requirements (ARARs) addresses whether a remedy will
meet all of the ARARs of other Federal and State envi-
ronmental laws and/or justifies a waiver.
Primary Balancing Criteria:
- Long-term effectiveness and permanence refers to ex-
pected residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment
over time, once clean-up goals have been met.
- Reduction of toxicity, mobility, or volume through treat-
ment is the anticipated performance of the treatment
technologies a remedy may employ.
- Short-term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed ,
during the construction and implementation period, until I
clean-up goals are achieved.
- 2 -
-------
- Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
- Cost includes estimated capital and O&M costs, also
expressed as net present worth-costs.
Modifying Criteria:
- State/Support Agency Acceptance reflects aspects of the
preferred alternative and other alternatives that the
support agency favors or objects to, and any specific
comments regarding State ARARs or the proposed use of
waivers. The Proposed Plan should address views known at
the time the plan is issued but should not speculate. The
assessment of State concerns may not be complete until
after the public comment period on the RI/FS and
Proposed Plan is held.
- Community Acceptance summarizes the public's general
response to the alternatives described in the Proposed Plan
and in the RI/FS, based on public comments received. Like
State Acceptance, evaluations under this criterion usually
will not be completed until after the public comment period
is held.
Present the lead agency's preliminary determination that the
preferred alternative provides the best balance of tradeoffs with
respect to the nine criteria. Sample text is presented in Highlight
4. The preferred alternative is anticipated to meet the following
statutory requirements to:
a Protect human health and the environment;
a Comply with ARARs (or justify a waiver);
D Be cost-effective;
a Utilize permanent solutions and alternative treatment or
resource recovery technologies, to the maximum extent
practicable; and
Satisfy the statutory preference for treatment as a principal
element, or justify not meeting the preference.
Highlight 4: Summarizing the Statutory
Findings
In summary, the preferred alternative is believed to pro-
vide the best balance of trade-offs among alternatives
with respect to the criteria used to evaluate remedies.
Based on the information available at this time, therefore,
EPA and the State of Tennessee believe the preferred al-
ternative would protect human health and the environ-
ment, would comply with ARARs, would be cost-
effective, and would utilize permanent solutions and alter-
native treatment technologies or resource recovery tech-
nologies to the maximum extent practicable. The pre-
ferred alternative should/will not satisfy the preference for
treatment as a principal element.
Community Participation
The Proposed Plan is a public participation decision document. It
should include information that helps the public understand how
they can be involved. To this end, the Plan should:
a Provide notice of the dates of the public comment period;
a Note the date, time, and location of public meeting(s)
planned to be held;
a Identify names, phone numbers, and addresses of lead and
support agency contact people to whom comments should
be sent;
a State whether a special notice has been issued to the
potentially responsible parties (PRPs), if applicable; and
D List the location of the Administrative Record and other
information repositories.
- 3 -
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive: 9335.3-02FS-2
November 1989
fxEPA
A Guide to Developing
Superfund Proposed Plans
Office of Emergency and Remedial Response
Hazardous Site Control Division
Quick Reference Fact Sheet
Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization Act (SARA) of 1986, requires preparation of Proposed Plans as part of the site remediation
process. The Proposed Plan is prepared after the Remedial Investigation/Feasibility Study (RI/FS) is completed and is made available with the
RI/FS to the public for comment. The Proposed Plan highlights key aspects of the RI/FS, provides a brief analysis of remedial alternatives
under consideration, identifies the preferred alternative, and provides members of the public with information on how they can participate in
the remedy selection process. A notice and brief analysis of the Proposed Plan is published in a m ajor local newspaper of general circulation. In
addition, the Proposed Plan, the RI/FS, and the other contents of the Administrative Record are available at an information repository near
the site.
This guide outlines the major components of the Proposed Plan and suggests effective ways in which the various sections can be presented.
EPA recommends issuing the Proposed Plan in a fact sheet format. For some highly complex sites or remedies, more detailed Plans may be
appropriate. All Proposed Plans should be written in a style that makes the material easy for the public to understand and should emphasize
that the preferred alternative identified in the Proposed Plan is a preliminary determination, and that the Agency is requesting comments on all
of the alternatives.
Detailed guidance on the preparation of the Proposed Plan is provided in Chapters 2, 3, and 9 of the "Interim Final Guidance on Preparing
Superfund Decision Documents" (the "ROD Guidance") (OSWER Directive 9335.3-02, November 1989, EPA/540/G-89/007).
Introduction
Begin with a statement of the document's purpose. This
introduction should state the site name and location, identify the
lead and support agencies, and state that the Proposed Plan:
n Fulfills the requirements of CERCLA section 117(a);
n Describes the remedial alternatives analyzed for the site or
operable unit;
o Identifies the preferred alternative and explains the rationale
for the preference;
n Highlights key information in the RI/FS and administrative
record, to which the reader is referred for further details;
o Solicits community involvement in the selection of a remedy;
and
n Invites public comment on all alternatives.
Site Background
Provide a brief description of the site, including:
a History of site activities that led to current problems at the site;
and
n The site area or media to be addressed by the selected remedy.
Figure 1 is an example of a site map that could be included.
Scope and Role of Operable Unit or Response
Action
n Identify the principal threats posed by conditions at the site;
and
n Describe the scope of the problems addressed by the preferred
alternative and its role within the overall site clean-up
strategy.
Summary of Site Risks
n Provide a brief overview of the baseline risk assessment,
including the contaminated media, contaminants of concern,
exposure pathways and populations, and potential or actual
risks;
a Describe how current risks compare with remediation goals;
and
Q Discuss environmental ris>: s, as appropriate.
Summary of Alternatives
Describe briefly each of the alternatives evaluated in the detailed
analysis of the FS. Highlight the following:
a Treatment components;
n Engineering controls (noting the type of containment
controls); and
n Institutional controls.
Quantities of waste and implementation requirements related to
each component should be noted, as well as major applicable or
relevant and appropriate requirements (ARARs), the estimated
construction, and operation and maintenance (O&M) costs (also
expressed in present worth), and the implementation time of each
alternative. Emphasize that these latter two evaluations are
estimates. An example is presented m Highlight 1.
Printed on Recycled Paper
-------
Figure 1
EIO Industrial Site and Surroundings'
I TCE-Contaminattd Son SIU Boundary
POJ M<<>1> Cool mi tniixj 3oM ^F MunlcloAl Well \ N7 r
D Privit»W»IU . NQT T0 SCAL£
Highlight 1: Summarizing an Alternative
Treatment Components:
Excavation, on-site incineration of contaminated soils, and
solidification and off-site disposal of residual metals and ash.
Estimated Construction Cost: $42,463,300
Estimated Annual O&M Costs: $26,200
Estimated Present-Worth Costs: $42,708,780
Estimated Implementation Timeframe: 30 Months
Under this alternative, a mobile incinerator would be brought
to the site, and 28,000 cubic yards of soils contaminated with
RCRA listed wastes would be excavated and incinerated on-
site to BOAT levels established under the RCRA Land Dis-
posal Restrictions (LDR). Waste gases and water from this
process would be collected and treated off-site in a RCRA
Subtitle C treatment facility; residual metals and ash would be
solidified to achieve LDR treatment standards and disposed
off-site in a RCRA Subtitle C disposal facility.
Evaluation of Alternatives and the Preferred
Alternative.
a Identify the preferred alternative, emphasizing that the
selection of this alternative is preliminary and could change
in response to public comments or other new information.
Sample text is presented in Highlight 2.
Highlight 2: Stating the Preferred Alternative
The preferred alternative is alternative number 3. Alterna-
tive 3 includes excavation and on-site incineration of con-
taminated soils, with solidification and off-site disposal of
residual metals and ash. Based on new information or pub-
lic comments, EPA, in consultation with the State of Ten-
nessee, may later modify the preferred alternative or select
another remedial action presented in this Proposed Plan
and the RI/FS. The public, therefore, is encouraged to re-
view and comment on all of the alternatives identified in
this Proposed Plan. The RI/FS should be consulted for
more information on these alternatives.
Introduce the nine evaluation criteria used to evaluate the
alternatives.
Summarize the expected performance of the preferred
alternative in terms of the nine evaluation criteria
explaining how the preferred alternative compares to the
other alternatives with respect to those criteria. This
description is for the preliminary preference. Sample text
for one criterion is presented in Highlight 3.
Highlight 3: Presenting the Evaluation of
Alternatives
Short-term effectiveness.
Alternative number 4 uses a treatment process for soils and
disposal of residuals in an on-site landfill that contains the
contaminated soils and reduces the possibility of direct hu-
man contact with contaminants more quickly than all of the
other alternatives except Alternative 1 (no action). Under
the preferred alternative, once the volatile organics have
been collected in canisters, there is some minor short-term
risk of exposure to the community during transportation of
the canisters to a disposal site.
Because the capacity of on-site and off-site incinerators is
limited, under Alternatives 3 and 5 contaminated soils
would be stockpiled for up to six years. Under these two
alternatives, the risks of direct contact with stockpiled con-
taminated soils would be increased until incineration has
been completed. In addition, there are some risks of expo-
sure to air emissions from the incinerators.
The nine evaluation criteria are summarized below.
Threshold Criteria:
- Overall protection of human health and the environment
addresses whether a remedy provides adequate protection
of human health and the environment and describes how
risks posed through each exposure pathway are elimi-
nated, reduced, or controlled through treatment, engi-
neering controls, or institutional controls.
- Compliance with applicable or relevant and appropriate
requirements (ARARs) addresses whether a remedy will
meet all of the ARARs of other Federal and State envi-
ronmental laws and/or justifies a waiver.
Primary Balancing Criteria:
- Long-term effectiveness and permanence refers to ex-
pected residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment
over time, once clean-up goals have been met.
- Reduction of toxicity, mobility, or volume through treat-
ment is the anticipated performance of the treatment
technologies a remedy may employ.
- Short-term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be poseoj
during the construction and implementation period, unt|
clean-up goals are achieved
- 2 -
-------
- Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
- Cost includes estimated capital and O&M costs, also
expressed as net present worth-costs.
Modifying Criteria:
- State/Support Agency Acceptance reflects aspects of the
preferred alternative and other alternatives that the
support agency favors or objects to, and any specific
comments regarding State ARARs or the proposed use of
waivers. The Proposed Plan should address views known at
the time the plan is issued but should not speculate. The
assessment of State concerns may not be complete until
after the public comment period on the RI/FS and
Proposed Plan is held.
- Community Acceptance summarizes the public's general
response to the alternatives described in the Proposed Plan
and in the RI/FS, based on public comments received. Like
State Acceptance, evaluations under this criterion usually
will not be completed until after the public comment period
is held.
Present the lead agency's preliminary determination that the
preferred alternative provides the best balance of tradeoffs with
respect to the nine criteria. Sample text is presented in Highlight
4. The preferred alternative is anticipated to meet the following
statutory requirements to:
3 Protect human health and the environment;
n Comply with ARARs (or justify a waiver);
n Be cost-effective;
n Utilize permanent solutions and alternative treatment or
resource recovery technologies, to the maximum extent
practicable: and
Satisfy the statutory preference for treatment as a principal
element, or justify not meeting the preference.
Highlight 4: Summarizing the Statutory
Findings
In summary, the preferred alternative is believed to pro-
vide the best balance of trade-offs among alternatives
with respect to the criteria used to evaluate remedies.
Based on the information available at this time, therefore,
EPA and the State of Tennessee believe the preferred al-
ternative would protect human health and the environ-
ment, would comply with ARARs, would be cost-
effective, and would utilize permanent solutions and alter-
native treatment technologies or resource recovery tech-
nologies to the maximum extent practicable. The pre-
ferred alternative should/will not satisfy the preference for
treatment as a principal element.
Community Participation
The Proposed Plan is a public participation decision document. It
should include information that helps the public understand how
they can be involved. To this end, the Plan should:
n Provide notice of the dates of the public comment period;
n Note the date, time, and location of public meeting(s)
planned to be held;
n Identify names, phone numbers, and addresses of lead and
support agency contact people to whom comments should
be sent;
o State whether a special notice has been issued to the
potentially responsible parties (PRPs), if applicable; and
n List the location of the Administrative Record and other
information repositories.
- 3 -
-------
United States
Environmental
Agency
ppwaWwtwml
Office of
*lid Waste and
Emergency Response
Superfund Publication:
9335.3-02FS-3
May 1990
iSEPA
Guide to Developing Superfund
No Action, Interim Action, and
Contingency Remedy RODs
Office of Emergency and Remedial Response
Hazardous Site Control Division
Quick Reference Fact Sheet
This guide provides Remedial Project Managers (RPMs) with a quick reference to the essential
components of Records of Decision (RODs) prepared to document the following three special types of
remedial action decisions: (1) no action; (2) interim actions; and (3) contingency remedies. The first type
of special ROD, the no action ROD, documents that no response action is necessary to ensure adequate
protection of human health and the environment or is not possible either technologically or under CERCLA
authority. The second type of special ROD, the interim action ROD, documents that the response action
selected will be of limited scope and will be followed by a later, final response action for that operable unit.
For interim action RODs, the documentation provided should be tailored to the limited scope and purpose
of the interim action (as opposed to a limited final action, where the ROD may be streamlined within the
standard ROD format). Finally, the contingency remedy ROD provides a fall-back remedy in the event that
the primary, selected remedy does not achieve its expected performance. In preparing all three types of
special RODs, RPMs should modify, as outlined in this guide, the format of the standard ROD for final
response actions (see Highlight 1). Sections that have been crossed out should not appear in a special ROD.
Sections that appear in bold should be supplemented according to the directions provided in this fact sheet.
Finally, sections of the standard ROD that are not modified in the outlines below should be included in the
special ROD at the same level of detail as if they were standard ROD discussions. More detail on preparing
the three types of special RODs is provided in Chapter 9 of the Interim Final Guidance on Preparing
Superfund Decision Documents (the "ROD Guidance")(December 1989, EPA/624/1-87/001).
I. DOCUMENTING NO ACTION DECISIONS
EPA may determine that no action is warranted
for a site or operable unit within a site under the
following three general sets of circumstances:
• When the site or operable unit poses no current
or potential threat to human health or the
environment (i.e., the site or operable unit is
already in a protective state);
• When the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization
Act (SARA) of 1986, does not provide the
authority to take remedial action; or
• When no effective action can be taken, given
currently available technology and the site or
contaminant characteristics.
Highlight 2 provides specific examples of
potential sites requiring no action decisions for
each of the reasons cited above. The remainder
of this section presents an outline of the ROD
format to use in each of these situations.
Highlight i
OUTLINE FCR THE STAHDARD ROD
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Selected Remedy
Statutory Determinations
Signature and Support Agency Acceptance
of the Remedy
2. Decision Summary
Site Name, Location, and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit
Site Characteristics
Summary of Site Risks
Description of Alternatives
Summary of Comparative Analysis of
Alternatives
Selected Remedy
Statutory Determinations
Documentation of Significant Differences
3. Responsiveness Summary
• Community Preferences
• Integration of Comments
-------
DRAFT
Highlight 2
POTENTIAL SITES REQUIRING
NO ACTION DECISIONS
• Where a previous removal action
mitigated the threat;
• Where a natural environmental
process, such as the attenuation of a
ground-water contaminant plume,
eliminated the threat;
• Where the baseline risk assessment
concluded that the conditions posed
no threat;
• Where a remedy includes no
treatment, engineering, or institutional
controls; and
• Where a release involved only
petroleum wastes, making the
contaminants exempt from remedial
action under CERCLA section 101.
NO ACTION SITUATION #1:
ACTION NOT NECESSARY FOR PROTECTION
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
• Assessment of the Site
• Description of the Selected Remedy: The lead
agency should state that it has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
"*" oi2itiitory LJctcr tninfltiom
• Declaration Statement: None of the Section
121 statutory determinations are necessary in
this section. Instead, the lead agency should
state briefly that no remedial action is
necessary to ensure protection of human health
and the environment This section should also
note whether five-year review is required. (A
five-year review is necessary under a no action
ROD when previous removal or remedial
actions at the site resulted in the
implementation of engineering controls to
prevent unacceptable exposures and when these
controls will remain in place over the long
term.)
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
• Summary of Site Risks: The information in
this section provides the primary basis for the
no action decision. The discussion should
support the determination that no remedial
action is necessary to ensure protection of
human health and the environment The lead
agency should explain how the baseline risk
assessment conducted during the remedial
investigation (RI) indicates that unacceptable
exposures will not occur. Any engineering
controls implemented as part of previous
actions that contribute to protection of human
health and the environment should be
discussed.
-of—6ei
3xOjr3I^^^^^™wT
™ oRiTtitOTjr iJLjiC-fnTinqUOD3
• Description of the No Action Alternative: The
lead agency should identify the no action
alternative in this section of the ROD. If
alternatives were developed in the feasibility
study (FS), the lead agency should reference
the RI/FS Report.
• Explanation of Significant Changes
3. Responsiveness Summary.
-------
DRAFT
NO ACTION SITUATION #2:
NO CERCLA AUTHORITY TO TAKE ACTION
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
* /\SSCSS IT! will OI IDC OHC
• Description of the Selected Remedy: The lead
agency should state that it has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
••—Statutory Determinations
• Declaration Statement No Section 121
statutory determinations are necessary in this
section. This section should explain that EPA
does not have authority under CERCLA Section
104 to address the site or operable unit The
statement that the no action decision does not
constitute a finding by EPA that adequate
protection has been achieved at the site.
Rather, the statement should identify the
statutory or regulatory authority that does have,
or potentially could have, jurisdiction over the
problem. If the problem has been referred to
other authorities, this should be explained.
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
• Summary of Site Risks
• Description of Alternatives
• Summary—of—Comparative—Analysis of
• Selected Remedy
• Statutory Authority Finding: The concluding
statement of the absence of CERCLA authority
to address the problem should be the same as
in the Declaration.
• Explanation of Significant Changes
3. Responsiveness Summary.
NO ACTION SITUATION #3:
NO EFFECTIVE ACTION POSSIBLE
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
* /kooCSST^Tu'l-ll. OI L.UW vjl* w
Description of the Selected Remedy: The lead
agency should state that is has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
• Declaration Statement: This Declaration should
state that it has been determined that no
effective remedial action is possible at the site.
The Declaration should also explain that the no
action decision does not constitute a finding
that the remedy ensures adequate protection of
human health and the environment. A
statement that a five-year review will be
conducted should be included.
• Signature and Support Agency Acceptance of the
Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
-------
DRAFT
Summary of Site Risks
i_xt sen p*iGir"uA?«3tt m
-------
DRAFT
final response action]. Subsequent actions are
planned to address fulfy the principal threats
posed by the conditions at this [site/operable
unit].
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit: This section
provides the rationale for taking the limited
action. To the extent that information is
available, the section should detail how the
response action fits into the overall site
strategy. This section should state that the
interim action will be consistent with any
planned future actions, to the extent possible.
• Site Characteristics: This section should focus
on the description of those site characteristics
to be addressed by the interim remedy.
• Summary of Site Risks: This section should
focus on risks addressed by the interim action
and should provide the rationale for the limited
action. This could be supported by facts that
indicate that action is necessary to stabilize the
site, prevent further degradation, or achieve
significant risk reduction quickly. Qualitative
risk information may be presented if
quantitative risk information is not yet
available, which will often be the case.
• Description of Alternatives: This section should
describe only the limited alternatives that were
considered for the interim action. Applicable
or relevant and appropriate requirements
(ARARs) associated with the limited action
should be incorporated into the description of
alternatives.
• Summary of Comparative Analysis of
Alternatives: The comparative analysis should
be presented in light of the limited scope of the
action. Criteria not relevant to the evaluation
of interim actions need not be addressed in
detail. Rather, their irrelevance to the decision
should be noted briefly.
• Selected Remedy
• Statutory Determinations: The interim action
should protect human health and the
environment from the exposure pathway or
threat it is addressing, any releases generated,
or the waste material that is managed. The
ARARs discussion should focus only on those
ARARs specific to the interim action -- those
related to any final disposition of waste, off-site
treatment or disposal, or released caused during
implementation. An interim remedy waiver may
be necessary in some situations. However, if an
interim waiver is needed, the final remedy must
comply with this requirement The discussion
under "utilization of permanent solutions and
treatment to the maximum extent practicable"
should indicate that the selected remedy
represents the best balance of tradeoffs among
alternatives with respect to pertinent criteria,
given the limited scope of the action. The
discussion under the preference for treatment
section should note that the preference will be
addressed in the final decision document for the
site or operable unit
• Explanation of Significant Changes
3. Responsiveness Summary.
III. DOCUMENTING CONTINGENCY
REMEDIES
In some limited cases, the lead agency may
determine that to ensure implementation of the
most appropriate remedy, a ROD will be prepared
with a selected remedy that is accompanied by a
contingency remedy. The contingency remedy may
be appropriate to use in the following cases:
(1) when an innovative treatment technology
appears to be the most appropriate remedy for the
site, although further testing is needed during
remedial design to verify its potential effectiveness;
and (2) when two different technologies appear to
offer comparable performance on the basis of the
five primary balancing criteria, and neither one
offers the better balance of tradeoffs. Highlight 4
provides specific examples of contingency remedies,
which typically involve treatment categories, rather
than specific technology process options.
In general, the lead agency identifies a preferred
alternative in the Proposed Plan and selects a
single remedy in the ROD. When selecting a
treatment technology to address the source of
contamination, this typically involves selection of a
treatment class or family, (i.e.,thermal destruction),
rather than a specific technology process option
(i.e., rotary kiln). Selection of a treatment class
affords the lead agency flexibility during the remedy
-------
DRAFT
Highlight 4
CIRCUMSTANCES WHERE CONTINGENCY
REMEDIES MAY BE APPROPRIATE
• An innovative treatment technology may
appear to be the most appropriate
remedy for a site or operable unit
during the RI/FS, but more testing is
needed during remedial design to verify
the technology's expected performance
potential. If there are uncertainties
about an innovative treatment
technology, then the lead agency, in
consultation with the support agency,
may elect to include a proven technology
as a contingency remedy in the ROD.
• Where two different technologies under
consideration appear to offer comparable
performance on the basis of the five
primary balancing criteria, such that both
could be argued to provide the "best
balance of tradeoffs." Under such
circumstances, the ROD may identify
one as the selected remedy and the
other as a contingency remedy and
specify the criteria whereby the
contingency remedy would be
implemented.
remedy design to procure the most cost-effective
process through competitive bidding. There are
limited situations, however, where additional
flexibility may be required to implement the most
appropriate treatment remedy for a site. In such
situations, the lead agency may determine a ROD
with a selected remedy and a contingency remedy
is appropriate.
CONTINGENCY REMEDY ROD FORMAT
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
• Assessment of the Site
• Description of the Selected Remedy: Both the
selected remedy and the contingency remedies
should be described in bullet form.
• Statutory Determinations: The Declaration
should be modified to indicate that both the
selected remedy and the contingency remedy will
meet the statutory findings.
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
• Summary of Site Risks
• Description of Alternatives: This section should
identify any uncertainties about the use of the
technologies being considered, and the extent
additional testing is needed. The selected
remedy and the contingency remedy must be
fully described.
• Summary of Comparative Analysis: The
selected remedy and any contingency alternative
should be evaluated fully against the nine
criteria. The uncertainties should be noted, as
well as performance expectations. In the
discussion of community (and support agency)
acceptance of an innovative technology, the
support of the interested parties should be
discussed in light of the CERCLA provisions in
Section 121 (b) (2). Where alternatives are
chosen because they are comparable, the
analysis should provide support for the finding.
• Selected Remedy: The selected and contingency
remedy should be identified. If an innovative
technology is identified as the preferred
alternative, this section should describe what
will happen if further testing determines that
the preferred alternative is not effective or
implementable. If comparable alternatives are
selected, each should be described in detail.
• Statutory Determinations: The statutory
determination discussion should show that both
remedies fulfill CERCLA Section 121
requirements.
• Explanation of Significant Changes
3. Responsiveness Summary.
-------
United States
Environmental
Agency
DRAFT
ice of
lid Waste and
Emergency Response
Superfund Publication:
9335.3-02FS-3
May 1990
i
«EPA
Guide to Developing Superfund
No Action, Interim Action, and
Contingency Remedy RODs
Office of Emergency and Remedial Response
Hazardous Site Control Division
Quick Reference Fact Sheet
This guide provides Remedial Project Managers (RPMs) with a quick reference to the essential
components of Records of Decision (RODs) prepared to document the following three special types of
remedial action decisions: (1) no action; (2) interim actions; and (3) contingency remedies. The first type
of special ROD, the no action ROD, documents that no response action is necessary to ensure adequate
protection of human health and the environment or is not possible either technologically or under CERCLA
authority. The second type of special ROD, the interim action ROD, documents that the response action
selected will be of limited scope and will be followed by a later, final response action for that operable unit.
For interim action RODs, the documentation provided should be tailored to the limited scope and purpose
of the interim action (as opposed to a limited final action, where the ROD may be streamlined within the
standard ROD format). Finally, the contingency remedy ROD provides a fall-back remedy in the event that
the primary, selected remedy does not achieve its expected performance. In preparing all three types of
special RODs, RPMs should modify, as outlined in this guide, the format of the standard ROD for final
response actions (see Highlight 1). Sections that have been crossed out should not appear in a special ROD.
Sections that appear in bold should be supplemented according to the directions provided in this fact sheet.
Finally, sections of the standard ROD that are not modified in the outlines below should be included in the
special ROD at the same level of detail as if they were standard ROD discussions. More detail on preparing
the three types of special RODs is provided in Chapter 9 of the Interim Final Guidance on Preparing
Superfund Decision Documents (the "ROD Guidance")(December 1989, EPA/624/1-87/001).
I. DOCUMENTING NO ACTION DECISIONS
EPA may determine that no action is warranted
for a site or operable unit within a site under the
following three general sets of circumstances:
• When the site or operable unit poses no current
or potential threat to human health or the
environment (i.e., the site or operable unit is
already in a protective state);
• When the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization
Act (SARA) of 1986, does not provide the
authority to take remedial action; or
• When no effective action can be taken, given
currently available technology and the site or
contaminant characteristics.
Highlight 2 provides specific examples of
potential sites requiring no action decisions for
each of the reasons cited above. The remainder
of this section presents an outline of the ROD
format to use in each of these situations.
Highlight 1
OUTLIHZ FOB THE STANDARD ROD
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Selected Remedy
Statutory Determinations
Signature and Support Agency Acceptance
of the Remedy
2. Decision Sunmary
Site Name, Location, and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit
Site Characteristics
Summary of Site Risks
Description of Alternatives
Sunmary of Comparative Analysis of
Alternatives
Selected Remedy
Statutory Determinations
Documentation of Significant Differences
3. Responsiveness Summary
• Community Preferences
• Integration of Comments
-------
Highlight 2
POTENTIAL SITES REQUIRING
NO ACTION DECISIONS
Where a previous removal action
mitigated the threat;
Where a natural environmental
process, such as the attenuation of a
ground-water contaminant plume,
eliminated the threat;
Where the baseline risk assessment
concluded that the conditions posed
no threat;
Where a remedy includes no
treatment, engineering, or institutional
controls; and
Where a release involved only
petroleum wastes, making the
contaminants exempt from remedial
action under CERCLA section 101.
NO ACTION SITUATION #1:
ACTION NOT NECESSARY FOR PROTECTION
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
• Assessment of the Site
• Description of the Selected Remedy: The lead
agency should state that it has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
Declaration Statement: None of the Section
121 statutory determinations are necessary in
this section. Instead, the lead agency should
state briefly that no remedial action is
necessary to ensure protection of human health
and the environment. This section should also
note whether five-year review is required. (A
five-year review is necessary under a no action
ROD when previous removal or remedial
actions at the site resulted in the
implementation of engineering controls to
prevent unacceptable exposures and when these
controls will remain in place over the long
term.)
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
• Summary of Site Risks: The information in
this section provides the primary basis for the
no action decision. The discussion should
support the determination that no remedial
action is necessary to ensure protection of
human health and the environment. The lead
agency should explain how the baseline risk
assessment conducted during the remedial
investigation (RI) indicates that unacceptable
exposures will not occur. Any engineering
controls implemented as part of previous
actions that contribute to protection of human
health and the environment should be
discussed.
• Description of Alternatives
—of Comparative An
Alternatives
• Description of the No Action Alternative: The
lead agency should identify the no action
alternative in this section of the ROD. If
alternatives were developed in the feasibility
study (FS), the lead agency should reference
the RI/FS Report.
• Explanation of Significant Changes
3. Responsiveness Summary.
-------
DRAFT
NO ACTION SITUATION #2:
NO CERCLA AUTHORITY TO TAKE ACTION
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
* / iSSc-ooiiicni. 01 tow out
• Description of the Selected Remedy: The lead
agency should state that it has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
• Declaration Statement: No Section 121
statutory determinations are necessary in this
section. This section should explain that EPA
does not have authority under CERCLA Section
104 to address the site or operable unit The
statement that the no action decision does not
constitute a finding by EPA that adequate
protection has been achieved at the site.
Rather, the statement should identify the
statutory or regulatory authority that does have,
or potentially could have, jurisdiction over the
problem. If the problem has been referred to
other authorities, this should be explained.
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
• Summary of Site Risks
• Description of Alternatives
Ol
Ol
• Statutory Authority Finding: The concluding
statement of the absence of CERCLA authority
to address the problem should be the same as
in the Declaration.
• Explanation of Significant Changes
3. Responsiveness Summary.
NO ACTION SITUATION #3:
NO EFFECTIVE ACTION POSSIBLE
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
• Assessment of the Site
• Description of the Selected Remedy: The lead
agency should state that is has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
• Statutory Determinations
• Declaration Statement: This Declaration should
state that it has been determined that no
effective remedial action is possible at the site.
The Declaration should also explain that the no
action decision does not constitute a finding
that the remedy ensures adequate protection of
human health and the environment. A
statement that a five-year review will be
conducted should be included.
• Signature and Support Agency Acceptance of the
Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
-------
DRAFT
Summary of Site Risks
l_xCoCiIp'lOu Ol 7»3T^jimCT
"^5i
Alternatives
• Selected Remedy
Analysis of
• Summary of Basis for No Action Decision: The
rationale for the no action decision should be
provided. The remedial alternatives that were
considered, and the impact associated with them
or their feasibility, should be summarized in
this discussion. A detailed comparative analysis
using the nine evaluation criteria need not be
included. A statement should also be included
to the effect that this no action decision does
not constitute a finding that adequate protection
of human health and the environment has been
achieved at the site.
• Explanation of Significant Changes
3. Responsiveness Summary
II. DOCUMENTING INTERIM ACTION
DECISIONS
During scoping, or at other points in the RI/FS,
the lead agency may determine that an interim
action should be taken either to respond to an
immediate site threat or to take advantage quickly
of an opportunity to reduce risk at a site. Interim
actions are limited in scope and are followed by
other operable units that complete the steps to
provide definitive protection of human health and
the environment for the long term. Highlight 3
Highlight 3
EXAMPLES OF INTERIM
ACTION DECISIONS
• Constructing a fence to restrict access to
the site;
• Pumping a ground-water aquifer to
restrict migration of a contaminant
plume;
• Providing an alternative source of
drinking water; and
• Constructing a temporary cap.
provides specific examples of types CL interim
action decisions.
Interim actions should not be confused with
final actions that are limited in scope. A limited
final action is the last action to be taken at or on
a limited portion of the site to ensure that
protection of human health and the environment
has been achieved. The ROD used for these
actions should be a streamlined version of the
standard ROD format shown in Highlight 1. An
interim action is an action that must be followed
by a subsequent action (and ROD) to achieve
definite protection of human health and the
environment at a portion of a site. In an Interim
Action ROD, an outline of which follows this
discussion, the "Summary of Site Risks" discussion
may be very brief, providing information to support
the need to take action but usually not specifying
final acceptable exposure levels for the site. The
findings of the baseline risk assessment should be
included in the decision documents for future, final
operable units. The number of alternatives
considered for interim actions should generally be
limited to three or fewer, and the nine-criteria
evaluation should be limited to addressing factors
pertinent to the scope and purpose of the interim
action.
INTERIM ACTION ROD FORMAT
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
• Assessment of the Site
• Description of Selected Remedy
• Statutory Determinations: The declaration
statement should read as follows:
This interim action is protective of human health
and the environment, complies with Federal and
State applicable or relevant and appropriate
requirements directly associated with this action,
and is cost-effective. This action utilizes
permanent solutions and alternative treatment (or
resource recovery) technologies, to the maximum
extent practicable, given the limited scope of the
action. Because this action does not constitute
the final remedy for the [site/operable unit], the
statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume
as a principal element [will not be satisfied by
this interim action (or) will be addressed by the
-------
DRAFT
final response action]. Subsequent actions are
planned to address fully the principal threats
posed by the conditions at this [site/operable
unit].
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit: This section
provides the rationale for taking the limited
action. To the extent that information is
available, the section should detail how the
response action fits into the overall site
strategy. This section should state that the
interim action will be consistent with any
planned future actions, to the extent possible.
• Site Characteristics: This section should focus
on the description of those site characteristics
to be addressed by the interim remedy.
• Summary of Site Risks: This section should
focus on risks addressed by the interim action
and should provide the rationale for the limited
action. This could be supported by facts that
indicate that action is necessary to stabilize the
site, prevent further degradation, or achieve
significant risk reduction quickly. Qualitative
risk information may be presented if
quantitative risk information is not yet
available, which will often be the case.
• Description of Alternatives: This section should
describe only the limited alternatives that were
considered for the interim action. Applicable
or relevant and appropriate requirements
(ARARs) associated with the limited action
should be incorporated into the description of
alternatives.
• Summary of Comparative Analysis of
Alternatives: The comparative analysis should
be presented in light of the limited scope of the
action. Criteria not relevant to the evaluation
of interim actions need not be addressed in
detail. Rather, their irrelevance to the decision
should be noted briefly.
Selected Remedy
• Statutory Determinations: The interim action
should protect human health and the
environment from the exposure pathway or
threat it is addressing, any releases generated,
or the waste material that is managed. The
ARARs discussion should focus only on those
ARARs specific to the interim action - those
related to any final disposition of waste, off-site
treatment or disposal, or released caused during
implementation. An interim remedy waiver may
be necessary in some situations. However, if an
interim waiver is needed, the final remedy must
comply with this requirement. The discussion
under "utilization of permanent solutions and
treatment to the maximum extent practicable"
should indicate that the selected remedy
represents the best balance of tradeoffs among
alternatives with respect to pertinent criteria,
given the limited scope of the action. The
discussion under the preference for treatment
section should note that the preference will be
addressed in the final decision document for the
site or operable unit
• Explanation of Significant Changes
3. Responsiveness Summary.
III. DOCUMENTING CONTINGENCY
REMEDIES
In some limited cases, the lead agency may
determine that to ensure implementation of the
most appropriate remedy, a ROD will be prepared
with a selected remedy that is accompanied by a
contingency remedy. The contingency remedy may
be appropriate to use in the following cases:
(1) when an innovative treatment technology
appears to be the most appropriate remedy for the
site, although further testing is needed during
remedial design to verify its potential effectiveness;
and (2) when two different technologies appear to
offer comparable performance on the basis of the
five primary balancing criteria, and neither one
offers the better balance of tradeoffs. Highlight 4
provides specific examples of contingency remedies,
which typically involve treatment categories, rather
than specific technology process options.
In general, the lead agency identifies a preferred
alternative in the Proposed Plan and selects a
single remedy in the ROD. When selecting a
treatment technology to address the source of
contamination, this typically involves selection of a
treatment class or family, (i.e.,thermal destruction),
rather than a specific technology process option
(i.e., rotary kiln). Selection of a treatment class
affords the lead agency flexibility during the remedy
-------
DRAFT
Highlight 4
CIRCUMSTANCES WHERE CONTINGENCY
REMEDIES MAY BE APPROPRIATE
• An innovative treatment technology may
appear to be the most appropriate
remedy for a site or operable unit
during the RI/FS, but more testing is
needed during remedial design to verify
the technology's expected performance
potential. If there are uncertainties
about an innovative treatment
technology, then the lead agency, in
consultation with the support agency,
may elect to include a proven technology
as a contingency remedy in the ROD.
• Where two different technologies under
consideration appear to offer comparable
performance on the basis of the five
primary balancing criteria, such that both
could be argued to provide the "best
balance of tradeoffs." Under such
circumstances, the ROD may identify
one as the selected remedy and the
other as a contingency remedy and
specify the criteria whereby the
contingency remedy would be
implemented.
remedy design to procure the most cost-effective
process through competitive bidding. There are
limited situations, however, where additional
flexibility may be required to implement the most
appropriate treatment remedy for a site. In such
situations, the lead agency may determine a ROD
with a selected remedy and a contingency remedy
is appropriate.
CONTINGENCY REMEDY ROD FORMAT
1. Declaration
• Site Name and Location
• Statement of Basis and Purpose
• Assessment of the Site
• Description of the Selected Remedy: Both the
selected remedy and the contingency remedies
should be described in bullet form.
• Statutory Determinations: The Declaration
should be modified to indicate that both the
selected remedy and the contingency remedy will
meet the statutory findings.
• Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
• Site Name, Location, and Description
• Site History and Enforcement Activities
• Highlights of Community Participation
• Scope and Role of Operable Unit or Response
Action
• Site Characteristics
• Summary of Site Risks
• Description of Alternatives: This section should
identify any uncertainties about the use of the
technologies being considered, and the extent
additional testing is needed. The selected
remedy and the contingency remedy must be
fully described.
• Summary of Comparative Analysis: The
selected remedy and any contingency alternative
should be evaluated fully against the nine
criteria. The uncertainties should be noted, as
well as performance expectations. In the
discussion of community (and support agency)
acceptance of an innovative technology, the
support of the interested parties should be
discussed in light of the CERCLA provisions in
Section 121(b)(2). Where alternatives are
chosen because they are comparable, the
analysis should provide support for the finding.
• Selected Remedy: The selected and contingency
remedy should be identified. If an innovative
technology is identified as the preferred
alternative, this section should describe what
will happen if further testing determines that
the preferred alternative is not effective or
implementable. If comparable alternatives are
selected, each should be described in detail.
• Statutory Determinations: The statutory
determination discussion should show that both
remedies fulfill CERCLA Section 121
requirements.
• Explanation of Significant Changes
3. Responsiveness Summary.
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive: 9355.0-27FS
April 1990
&EPA
A Guide to Selecting
Superfund Remedial Actions
Office of Emergency and Remedial Response
Hazardous Site Control Division OS-220
Quick Reference Fact Sheet
INTRODUCTION
The Superfund program's rem-
edy selection process is the decision-
making bridge between the analy-
sis of remedial alternatives for clean-
ing up a site conducted in a remedial
investigation/feasibility study (RI/
FS) and the explanation of the se-
lected remedy that is documented
in a Record of Decision (ROD). This
fact sheet describes statutory re-
quirements for CERCLA remedies
and the process EPAhas established
in the 1990 revised National Con-
tingency Plan (55 FR £fifi£ (3/8/90))
for meeting these requirements.
This process is a general framework
for reaching a judgment as to the
most appropriate method of achiev-
ing protection of human health and
the environment at a particular site.
This framework can be streamlined
as appropriate to the site.
STATUTORYREQUIREMENTS
Section 121 of CERCLA man-
dates that the remedial action must:
1. Protect human health and the
environment;
2. Comply with applicable or rele-
vant and appropriate require-
ments (ARARs) unless a waiver
is justified;
3. Be cost-effective;
4. Utilize permanent solutions and
alternative treatment technolo-
gies or resource recovery tech-
nologies to the maximum ex-
tent practicable;
5. Satisfy the preference for treat-
ment as a principal element, or
provide an explanation in the
ROD why the preference was
not met.
EPAhas established a national
goal and expectations reflecting
these requirements in the 1990 NCP
(Sec. 300.430(a)(l)(i) and (iii). The
NCP also defines nine criteria that
are to be used to compare remedial
alternatives, to establish the basis
for the selection decision, and to
EXHIBIT 1: PROGRAM EXPECTATIONS
Protection of human health and the environment can be achieved
through a variety of methods: treatment to destroy or reduce the
inherent hazards posed by hazardous substances, engineering con-
trols (such as containment), and institutional controls to prevent ex-
posure to hazardous substances. The NCP sets out the types of
remedies that are expected to result from the remedy selection
process (Sec. 300.430(aXlXiii)).
>• Treat principal threats, wherever practicable. Principal threats
for which treatment is most likely to be appropriate are
characterized as:
- Areas contaminated with high concentrations of toxic com-
pounds;
- Liquids and other highly mobile materials;
- Contaminated media (e.g., contaminated ground water,
sediment, soil) that pose significant risk of exposure; or
- Media containing contaminants several orders of magni-
tude above health-based levels.
> Appropriate remedies often will combine treatment and con-
tainment. For a specific site, treatment of the principal
threat(s) may be combined with containment of treatment
residuals and low-level contaminated material.
>• Containment will be considered for wastes that pose a relatively
low long-term threat or where treatment is impracticable. These
include wastes that are near health-based levels, are substan-
tially immobile, or otherwise can be reliably contained over long
periods of time; wastes that are technically difficult to treat or
for which treatment is infeasible or unavailable; situations
where treatment-based remedies would result in greater over-
all risk to the human health or the environment duringimplem-
entation due to potential explosiveness, volatilization, or other
materials handling problems; or sites that are extraordinarily
large where the scope of the problem may make treatment of all
wastes impracticable, such as municipal landfills or mining
sites.
>• Institutional controls are most useful as a supplement to engi-
neering controls for short- and long-term management. Institu -
tional controls (e.g. deed restrictions, prohibitions of well con-
struction) are important in controlling exposures during reme-
dial action implementation and as a supplement to long-term
engineering controls. Institutional controls alone should not
substitute for more active measures (treatment or containment)
unless such active measures are found to be impracticable.
> Innovative technologies should be considered if they offer the
potential for comparable or superior treatment performance,
fewer/lesser adverse impacts, or lower costs for similar levels of
performance than demonstrated technologies.
>• Ground waters will be returned to their beneficial uses within
reasonable periods of time wherever practicable.
April 1990 - 1
-------
Exhibit 2
Key Steps in the Development of Remedial Alternative*
Develop Preliminary Remediation Goals
Health-based remediation goals (e g , 10 ^excess cancer nsk as
point of departure, ARARs resulting in X ppm
Based on unlimited exposure for relevant land use
Determine areas of contamination
that require remedial action
Identify Pnncpal Threats that are Candidates for Treatment
• Treat contaminants significantly above Preliminary Remediation Goat* (e g., 2 orders of magnitude)
I
Exceptions include large munepal
landfills, areas where contaminants
are inaccessfcle, or other situations
where treatment is not implementable
Identify Low-level Threats that are Candidates for Containment
I
Contain Treatment
Residuals and
Remaining Material
Exceptions
• Small volumes
• Sensitive exposure
• Containment unreliable
Identify Remedial
Alternatives for
Detailed Analyses
and Remedy
Select on
Partially Treat
• Treat to levels that can
be reliably contained
T
Fully Treat
• Treat to levels for
which access
restrictions are not
necessary
demonstrate that statutory require-
ments have been satisfied (Sec.
300.430(f)(D). Each of these as-
pects of EPA's remedy selection
approach are described below.
GOAL AND EXPECTATIONS
OF THE REMEDY SELECTION
PROCESS
The national goal of the remedy
selection process is "to select reme-
dies that are protective of human
health and the environment, that
(maintain protection over time, and
that minimize untreated waste"
(NCP Sec. 300.430(a)(l)(i)).
While protection of human
health and the environment can be
achieved through a variety of meth-
ods, this goal reflects CERCLA's em-
phasis on achieving protection
through the aggressive, but realis-
tic use of treatment. The 1990 NCP
presents EPA's expectations regard-
ing circumstances under which
treatment, as well as engineering
and institutional controls, are most
likely to be appropriate (Sec.
300.430(aXD(iii), see Exhibit 1).
These expectations are intended pri-
marily to assist in focusing the de-
velopment of alternatives in the FS
(see The Feasibility Study: Devel-
opment and Screening of Alterna-
tives, OSWER Directive 9355.3-
01FS). These expectations do not
substitute for site-specific balanc-
ing of the nine criteria to determine
the maximum extent to which treat-
ment can be practicably used in a
cost-effective manner for a operable
unit.
Exhibit 2 illustrates the alter-
natives development process, as
shaped by the expectations. The
process begins with the identifica-
tion of preliminary remediation
goals, which provide initial esti-
mates of the contaminant concen-
trations/risk levels of concern. Based
on ARARs, readily available toxic-
ity information, and current and fu-
ture land use, preliminary remedia-
tion goals are initial health-based
levels and are used to define site ar-
eas that may require remedial ac-
tion (i.e., action areas). Areas on-
site with contaminant concentra-
tions several orders of magnitude
above these preliminary remedia-
tion goals are candidate areas for
treatment. Areas onsite with con-
taminant concentrations within
several orders of magnitude of these
preliminary remediation goal levels
are candidate areas for containment.
The remediation goals, action ar-
eas, and target treatment/contain-
ment areas are refined throughout
the RI/FS process as additional in-
formation becomes available. The
final determination of remediation
goals, action areas, and the appro-
priate degree of treatment and con-
tainment are made as part of the
remedy selection.
THE REMEDY SELECTION
PROCESS
Overview
The remedy selection process
begins with the identification of a
preferred alternative from among
those evaluated in detail in the FS
by the lead agency, in consultation
with the support agency. The pre-
ferred alternative is presented to
the public in a Proposed Plan that is
2 - OSWER Directive 9355.0-27FS
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EXHIBITS: NINE EVALUATION
CRITERIA
EPA has developed nine criteria to
be used to evaluate remedial alterna-
tives to ensure all important considera-
tions are factored into remedy selection
decisions. These criteria are derived
from the statutory requirements of
Section 121, particularly the long-term
effectiveness and related considerations
specified in Section 121(bXD, as well as
other additional technical and policy
considerations that have proven to be
important for selecting among remedial
alternatives.
Threshold Criteria
The two most important criteria
are statutory requirements that must
be satisfied by any alternative in order
for it to be eligible for selection.
1. Overall protection of human health
and the environment addresses
whether or not a remedy provides
adequate protection and describes
how risks posed through each
exposure pathway (assuming a rea-
sonable maximum exposure) are
eliminated, reduced, or controlled
through treatment, engineering
controls, or institutional controls.
2. Compliance with applicable or rele-
vant and appropriate requirements
(ARARs) addresses whether a rem-
edy will meet all of the applicable
or relevant and appropriate require-
ments of other Federal and State
environmental laws or whether a
waiver can be justified.
Primary Balancing Criteria
Five primary balancing criteria are
used to identify major trade-offs between
remedial alternatives. These trade-offs
are ultimately balanced to identify the
preferred alternative and to select the final
remedy.
1. Long-term effectiveness and
permanence refers to the ability of a
remedy to maintain reliable protec-
tion of human health and the envi-
ronment over time, once cleanup goals
have been met.
2. Reduction of toxicity, mobility, or
volume through treatment is the an-
ticipated performance of the treat-
ment technologies a remedy may
employ.
3. Short-term effectiveness addresses the
period of time needed to achieve pro-
tection and any adverse impacts on
human health and the environment
that may be posed during the con-
struction and implementation period,
until cleanup goals are achieved.
4. Implementability is the technical and
administrative feasibility of a rem-
edy, including the availability of ma-
terials and services needed to imple-
ment a particular option.
5. Cost includes estimated capital and
operation and maintenance costs, and
net present worth costs.
Modifying Criteria
These criteria may not be considered
fully until after the formal publiccomment
period on the Proposed Plan and RI/FS
report is complete, although EPA works
with the State and community throughout
the project.
1. State acceptance addresses the sup-
port agency's comments. Where the
State or other Federal agency is the
lead agency, EPA's acceptance of the
selected remedy should be addressed
under this criterion. State views on
compliance with State ARARs are
especially important.
2. Community acceptance refers to the
public's general response to the alter-
natives describedin the Pro posed PI an
and the RI/FS report.
The 1990 NCP at 55 FR 8719-23
describes how the detailed analysis of al-
ternatives is to be performed using these
criteria. The detailed analysis is the infor-
mation base upon which the remedy selec-
tion decision is made. Chapter 7 of the
"Interim Final Guidance for Conducting
Remedial Investigations and Feasibility
Studies Under CERCLA" (October 1988)
provides further detail on the process.
issued for comment along with the
RI/FS. Upon receipt of public com-
ments on the Proposed Plan, the
lead agency consults with the sup-
port agency to determine if the pre-
ferred alternative remains the most
appropriate remedial action for the
site or operable unit. The final
remedy is selected and documented
in a Record of Decision.
Considering the Nine Criteria
The identification of a preferred
alternative and final selection of a
remedy is derived from considera-
tion of nine evaluation criteria in
three major steps, as described in
the 1990 NCP (Sec.
300.430(f)(l)(ii)(E)). The nine crite-
ria are presented in Exhibit 3. The
steps in which the criteria are con-
Jsidered are depicted in Exhibit 4
and discussed below.
Threshold Criteria
The first step of remedy selec-
tion is to identify those alternatives
that satisfy the threshold criteria.
Only those alternatives that pro-
vide adequate protection of human
health and the environment and
comply with ARARs (or justify a
waiver) are eligible for selection.
Alternatives that do not satisfy the
threshold criteria should not be
evaluated further.
Primary Balancing Criteria
The second step involves the
balancing of tradeoffs among pro-
tective and ARAR-compliant alter-
natives with respect to the five pri-
mary balancing criteria (and modi-
fying criteria, if known). In this
step, alternatives are compared with
each other based on their long-term
effectiveness and permanence, re-
duction in toxicity, mobility, or vol-
ume achieved through treatment,
implementability, short-term effec-
tiveness, and cost. The sequence in
which the criteria are generally con-
sidered, and pertinent considera-
tions related to each, are noted be-
low.
1. Long-term effectiveness and
permanence is a major theme of
CERCLA Section 121, and,
therefore, is one of the two most
important criteria used during
remedy selection to determine
the maximum extent to which
permanence and treatment are
practicable. This factor will
often be decisive where alterna-
tives vary significantly in the
types of residuals that will
remain onsite and/or their re-
spective long-term management
controls.
Aprill 990 -3
-------
Exhibit 4
THRESHOLD
CRITERIA
BALANCING
CRITERIA
Alternatives
from Screening,
Based on Program
Expectations
ARAR\No /Waiver\No
Evaluate:
• Long-term Effectiveness
• Reduction of T.M.V.
• Short-term Effectiveness
• Implementability
• Cost
Choose Preferred Alternative:
• Balancing across Criteria
• Emphasize Long-Term
Effectiveness and Reduction of
T.M.V.
MODIFYING
CRITERIA
Proposed Plan Issued for Comment
State and
Community
Acceptance
i
Selected Remedy
2. Reduction in the toxicity, mobil-
ity, or volume of contaminants
achieved through the applica-
tion of treatment technologies
is the other criterion that will
be emphasized during remedy
selection in determining the
maximum extent to which per-
manent solutions and treatment
are practicable. Remedies that
use treatment to address mate-
rials comprising the principal
threats posed by a site are pre-
ferred over those that do not.
Treatment as part of CERCLA
remedies should generally
achieve reductions of 90 to 99
percent in the concentrations or
mobility of individual contami-
nants of concern. There will,
however, be situations where
reductions outside the 90 to 99
percent range will be appropri-
ate to achieve site-specific re-
mediation goals.
3. The short-term effectiveness of
an alternative includes consid-
eration of the time required for
each alternative to achieve pro-
tection, as well as adverse short-
term impacts that maybe posed
by their implementation. Many
potential adverse impacts can
be avoided by incorporating
mitigative steps into the alter-
native. Poor short-term effec-
tiveness can weigh significantly
against an option and can, in
fact, result in an alternative
being rejected as unprotective if
adverse impacts cannot be ade-
quately mitigated.
4. Implementability is particularly
important for evaluating reme-
dies at sites with highly hetero-
geneous wastes or media that
make the performance of cer-
tain technologies highly uncer-
tain. Implementability is also
significant when evaluating
technologies that are less proven
and remedies that are depend-
ent on a limited supply of facili-
ties (e.g., TSCA - permitted land
disposal facility), equipment
(e..g.,in-situ vitrification units),
or experts.
5. Cost may play a significant role
in selectingbetweenoptionsthat
appear comparable with respect
to the other criteria, particu-
larly long-term effectiveness and
permanence, or when choosing
among treatment options that
provide similar performance.
Cost generally will not be used
to determine whether or not
principal threats will be treated,
except under special circum-
stances that make treatment
impracticable (see expecta-
tions). Cost can never be used to
pick a remedy that is not protec-
tive.
Modifying Criteria
If known at the completion of
the RI/FS, state (support agency)
and community acceptance of the
alternatives should be considered
with the results of the balancing
criteria evaluation to identify the
preferred alternative. After the
public comment period, state and
community acceptance are again
considered, along with any new in-
formation, and may prompt modifi-
cation of the preferred alternative.
4 - OSWER Directive 9355.0-27FS
-------
Exhibit 5
Relationship of the Nine Criteria to the Statutory Findings
J
STATUTORY FINDINGS
J
PROTECTION OF HUMAN HEALTH
AND THE ENVIRONMENT
COMPLIANCE WITH ARARs
LONG-TERM EFFECTIVENESS
AND PERMANENCE
TOXICITY, MOBILITY, OR
VOLUME REDUCTION
THROUGH TREATMENT
SHORT-TERM EFFECTIVENESS
IMPLEMENTABILITY
COST
STATE AGENCY ACCEPTANCE
COMMUNITY ACCEPTANCE
PROTECTION OF HUMAN HEALTH
AND THE ENVIRONMENT
COMPLIANCE WITH ARARs OR
JUSTIFICATION OF A WAIVER
COST-EFFECTIVENESS
UTILIZATION OF PERMANENT
SOLUTIONS AND TREATMENT OR
RECOVERY TO THE MAXIMUM
EXTENT PRACTICABLE ("MEP")
PREFERENCE FOR TREATMENT
AS A PRINCIPAL ELEMENT OR
EXPLANATION AS TO WHY
PREFERENCE NOT SATISFIED
Identification of a Preferred
Alternative
Once the relative performance
of the protective and ARAR-compli-
ant alternatives under each crite-
rion has been established, prelimi-
nary determinations of which op-
tions are cost-effective and which
alternatives utilize permanent so-
lutions and treatment technologies
to the maximum extent practicable
are made to identify the preferred
alternative. Exhibit 5 illustrates
the relationship between the nine
criteria and the statutory require-
ments for remedy selection.
Cost-effectiveness is determined
by comparing the costs of all alter-
natives being considered with their
overall effectiveness to determine
whether the costs are proportional
to the effectiveness achieved. Over-
all effectiveness for the purpose of
this determination includes long-
term effectiveness and permanence;
reduction of toxicity, mobility, and
volume through treatment; and
short-term effectiveness. More than
one alternative can be cost-effec-
tive.
The determination of which cost-
effective alternative utilizes perma-
nent solutions and treatment to the
maximum extent practicable is a
risk management judgment made
by the decisionmaker who balances
the tradeoffs among the alterna-
tives with respect to the balancing
criteria (and modifying criteria to
the extent they are known). As a
general rule, those criteria that dis-
tinguish the alternatives the most
will be the most decisive factors in
the balancing. See Exhibit 6 for a
summary of criteria likely to be im-
portant in certain site situations.
The alternative determined to pro-
vide the best balance of trade-offs,
as considered in light of the statu-
tory mandates and preferences, as
well as the NCP goal and expecta-
tions, is identified as the preferred
alternative and presented to the
public for comment in a Proposed
Plan.
Final Selection of Remedy
Upon receipt of public com-
ments, the preferred alternative is
reevaluated in light of any new in-
formation that has become avail-
able, including State and commu-
nity acceptance, if previously un-
known. This new information should
be considered to determine whether
an option other than the preferred
alternative better fulfills the statu-
tory requirements. The decision-
maker's final judgment is docu-
mented in a Record of Decision.
April 1990 - 5
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Exhibit 6
EXAMPLES OF PROMINENT CRITERIA AND EXPECTATIONS
FOR SELECTED SITE SITUATIONS
SITUATION
Small area of high levels of toxic contaminants
(e.g., lagoon, hot spots)
Highly mobile contaminants (e.g., liquids, vola-
tiles, metals)
Very large volume of material contaminated
marginally above health-based levels (e.g., mine
tailings one order of magnitude above health-
based levels in soil)
Complex mixture of heterogeneous waste
without discrete hot spots (e.g., heterogeneous
municipal landfill waste)
Soils contaminated with high concentrations
ofVOCs
Contaminated ground water
PROMINENT CRITERIA
Long-term effectiveness,
Reduction of toxicity, mobility, or vol-
ume through treatment
Long-term effectiveness,
Reduction of mobility through treat-
ment
Implementability,
Cost
Implementability,
Short-term effectiveness,
Cost
Long-term effectiveness,
Short-term effectiveness
Long-term effectiveness,
Short-term effectiveness
EXPECTED RESULT OF REMEDY
SELECTION*
Treatment is preferred when highly toxic mate-
rial is a principal threat at a site
Treatment is preferred when highly mobile
material is a principal threat at a site
Containment may afford high level of long-term
effectiveness; treatment may be difficult to im-
plement because of insufficient treatment ca-
pacity for large volume of material, and cost of
treatment may be prohibitive due to large scope
of site
Treatment of heterogeneous waste often diffi-
cult or infeasible, reducing implementability;
containment avoids short-term impacts and un-
certainties associated with excavation; cost of
treatment may be prohibitive
In-situ treatment may be preferred over excava-
tion because of negative short-term impacts and
high cost of excavation
Ground waters should be returned to beneficial
use as soon as is practicable
* These are only examples and have been highly simplified for illustration purposes. They are not intended to prescribe certain remedies
for certain situations.
NOTICE: The policies set out in this memorandum are intended solely for the guidance of Government personnel. They are not intended, nor can they be relied
upon, to create any rights enforceable by any party in litigation with the United States. EPA officials may decide to follow the guidance provided in this
memorandum, or to act at variance with the guidance, based on an analysis of specific site circumstances. Remedy selection decisions are made and justified on
a case-specific basis. The Agency also reserves the right to change this guidance at any time without public notice.
n: — „•»,;..„
n OVK'O
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CHECKLIST FOR RECORDS OF DECISIONS
I. The Declaration
o Site Name and Location
Does the ROD contain the name of the site as it
appears on the National Priorities List (NPL)?
Does the ROD contain the name of the town or county
and the State in which the site is located?
o Statement of Basis and Purpose
Does the ROD contain the following standard language?
"This decision document presents the selected remedial
action for the (site name). in (location). which was
chosen in accordance with CERCLA, as amended by SARA,
and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based on the administrative record for
this site."
"The State/Commonwealth of concurs with the
selected remedy."
o Assessment of the Site
Does the ROD contain the following standard language?
"Actual or threatened releases of hazardous substances
from this site, if not addressed by implementing the
response action selected in this Record of Decision
(ROD), may present an imminent and substantial
endangerment to public health, welfare, or the
environment."
o Description of the Selected Remedy
Does the ROD include a description of the role of this
operable unit within the overall site strategy?
Does the description indicate whether the operable unit
addresses the principal threats posed by the
conditions at the site?
Does the ROD include a description of the major
components of the selected remedy in bullet fashion?
-------
o Statutory Determinations
If the selected remedy satisfies the statutory
preference for treatment as a principal element (by
addressing the principal threats at the site with
treatment), does it contain the following standard
language?
"The selected remedy is protective of human health and
the environment, complies with Federal and State
requirements that are legally applicable or relevant
and appropriate to the remedial action [or "a waiver
can be justified for whatever Federal and State
applicable or relevant and appropriate requirement that
will not be met"], and is cost-effective. This remedy
utilizes permanent solutions and alternative treatment
(or resource recovery) technologies, to the maximum
extent practicable, and satisfies the statutory
preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal
element."
If the remedy does not satisfy the preference for
treatment as a principal element, does it contain the
following standard language?
(Repeat standard psrt) "However, because treatment of
the principal threats of the site was not found to be
practicable, this remedy does not satisfy the
statutory preference for treatment that as a principal
element."
If hazardous substances will remain on-site above
health-based levels, does the ROD contain the
following standard language?
"Because this remedy will result in hazardous
substances remaining on-site above health-based
levels, a review will be conducted within five years
after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of
human health and the environment."
If hazardous substances will not remain on-site above
health-based levels, does the ROD contain the
following standard language?
"Because this remedy will not result in hazardous
substances on-site above health-based levels, the
five-year review will not apply to this action."
-------
II. The Decision Summary
o Site Name, Location, and Description
Does the ROD include a description of the site in
terms of the following factors?
name, location, and address of the site;
area and topography of the site (especially if the
site is located within a floodplain or wetlands);
adjacent land uses;
natural resource uses;
general surface-water and ground-water resources;
location of and distance to nearby populations; and
surface and subsurface features (e.g., number and
volume of tanks, lagoons, drums, or other
structures).
Does the ROD include maps, a site plan, or other
graphic descriptions?
o Site History and Enforcement Activities
Does the ROD include a history of the site activities
that led to current problems?
Does the ROD include a history of Federal and State
site investigations, removal actions, and remedial
actions conducted under the CERCLA or other statutory
authorities?
Does the ROD include a history of CERCLA enforcement
activities at the site, including:
the results of searches for PRPs?
whether special notices have been issued?
o Highlights of Community Participation
Does the ROD summarize how the public participation
requirements of CERCLA sections 113(k)(2)(B)(i-v) and
117 were met in the remedy selection process?
o Scope and Role of Operable Unit [(or Response Action)]
Within Site Strategy
Does the ROD include a description of the role of this
remedial action within the overall site clean-up
strategy?
Does the ROD summarize the scope of the problems
addressed by the remedial action selected?
-------
Does the ROD describe whether or not the action will
address any of the principal threats posed by
conditions at the site?
o Summary of Site Characteristics
Does the ROD indicate all known or suspected sources
of contamination at the site?
Does the ROD include a description of the following
information related to the contamination and affected
media?
types and characteristics (e.g., toxicity,
mobility, carcinogenicity) of contaminants?
volume of contaminated material?
concentrations of contaminants?
Does the ROD include a description of the location of
contamination and known or potential routes of
migration, including the following factors?
population and environmental areas that could be
affected, if exposed?
lateral and vertical extent of contamination?
potential surface and subsurface pathways of
migration?
Does the ROD include maps, charts, tables, or other
graphic descriptions of contaminants and affected
media?
o Summary of Site Risks
Does the ROD summarize the results of the baseline risk
assessment conducted for the site?
Does the ROD include a description of the following
factors related to human health risks?
concentrations of the contaminants chemicals) of
concern in each medium of exposure?
results of the exposure assessment?
results of the toxicity assessment of contaminants
of concern?
results of the risk characterization for each
population by each pathway and the total risk for
the site?
potential or actual carcinogenic risks
non carcinogenic risks
explanation of key risks times
-------
Does the ROD include, where appropriate, a description
of the following factors related to environmental
risks?
effects of the contamination on critical
habitats?
effects of the contamination on any endangered
species?
o Description of Alternatives
Does the ROD include a description of the treatment
components of each remedial alternative, including the
following?
treatment technologies that will be used?
type and volume of waste to be treated?
process sizing?
primary treatment levels (e.g., best demonstrated
available technology [BOAT], percentage or order
of magnitude of concentration reductions
expected?
Does the ROD include a description of the containment
or storage components of each remedial alternative,
including the following:
type of storage (e.g., landfill, tank, surface
impoundment)?
type of closure that will be implemented (e.g.,
RCRA Subtitle C clean closure, landfill closure,
Subtitle D solid waste closure)?
type and quantity of waste to be stored?
quantity of untreated waste and treatment residuals
to be disposed of off-site or managed on-site in a
containment system (e.g., cap, minimum-technology
unit) and the degree of hazard remaining in such
waste)?
Does the ROD include a description of the ground-water
components of each remedial alternative (if
appropriate), including the following?
ground-water classification (e.g., Class I, II, or
III)?
remediation goals (e.g., maximum contaminant
levels [MCLs] to be achieved)?
estimated restoration timeframe?
area of attainment?
-------
Does the ROD include a description of the general
components of each remedial alternative, including the
following?
quantities of contaminated media addressed (and
physical location at the site)?
expected risk reduction to be achieved?
whether treatability testing has been or will be
conducted?
implementation requirements
use of institutional controls?
residual levels (e.g., delisting, BOAT)?
implementation requirements?
whether treatability testing has been or will be
conducted?
estimated implementation timeframe?
estimated capital, operation and maintenance
(O&M), and present-worth costs?
assumptions and uncertainties?
Does the ROD include a description of the major
applicable or relevant and appropriate requirements
(ARARs) and other standards "to be considered" (TBCs)
being met/utilized for the specific components of the
waste management process of each remedial alternative,
including the following?
how the specific components of each will or will
not comply with the major ARARs?
why the standard is applicable or relevant and
appropriate for each alternative?
whether RCRA Land Disposal Restrictions are
ARARs?
o Summary of Comparative Analysis of Alternatives
Does the ROD highlight the key differences among the
alternatives in relation to the nine criteria?
Overall protection of human health and the
environment; addresses whether a remedy provides
adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or
controlled through treatment, engineering
controls, or institutional controls;
Compliance with ARARs; addresses whether a
remedy will meet all of the ARARs of other
Federal and State environmental laws and/or
justifies use of a waiver.
Long-term effectiveness and permanence:
addresses the expected residual risk and the
ability of a remedy to maintain reliable
-------
protection of human health and the environment
over time, once clean-up goals have been met;
Reduction of toxicity. mobility, or volume
through treatment; addresses the anticipated
performance of the treatment technologies the
remedy may employ;
Short-term effectiveness: addresses the period of
time needed to achieve protection and any adverse
impacts on human health and the environment that
may be posed during the construction and
implementation period (i.e., until clean-up goals
are achieved);
Implementability; addresses the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option; and
Cost; addresses the estimated capital and O&M
costs, as well as a present-worth.
State/support agency acceptance; addresses the
support agency's comments and concerns. (Where the
State or Federal agency is the lead agency for the
ROD, EPA's acceptance of the selected remedy
should be addressed under this criterion);
Community acceptance; addresses the public's
comments on and concerns about the Proposed Plan
and RI/FS report. (The specific responses to
public comments should be addressed in the
Responsiveness Summary section of the ROD).
o The Selected Remedy
Does the ROD identify the selected remedy
Does the ROD identify remediation goals for the
selected remedy?
Does the ROD describe the carcinogenic risk level that
the selected remedy will attain and the rationale for
selecting that level?
Does the ROD identify the specific points of
compliance, as appropriate, for the media addressed by
the selected remedy (e.g., "MCLs will be met at the
edge of the waste-management area")?
-------
o Statutory Determinations
Does the ROD document how the selected remedy
satisfies the requirement of CERCLA section 121 to
protect human health and the environment, as follows?
A description of how the selected remedy will
eliminate, reduce, or control risks posed through
each pathway to each population through treatment,
engineering controls, or institutional controls,
to ensure adequate protection of human health and
the environment (including that the site risk will
be reduced to within the 10~4 to 10~6 risk range
for carcinogens, and that the Hazard Indices for
non-carcinogens will be less than one?
An indication that no unacceptable short-term
risks or cross-media impacts will be caused by
implementation of the remedy?
Does the ROD document how the selected remedy
satisfies the requirement of CERCLA section 121 to
comply with ARARs, as follows?
A statement of whether the selected remedy will
comply with ARARs. When appropriate, the ROD
should state that a waiver that is being invoked
and justify the waiver. The ARARs should be
organized as chemical-specific, location-specific,
and action-specific?
A list and description of the Federal and State
ARARs that the selected remedy will attain,
distinguishing applicable from relevant and
appropriate requirements, as necessary?
A listing and the rationale for using any TBCs?
Does the ROD describe how the selected remedy provides
overall effectiveness proportionate to its costs, such
that it represents a reasonable value for the money to
be spent (i.e., is cost-effective).
Does the ROD document how the selected remedy
satisfies the requirement of CERCLA section 121 to
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable, as follows?
A description of the rationale for the remedy
selection, including a statement that the remedy
selected provides the best balance of tradeoffs
among the alternatives with respect to the
evaluation criteria, especially the five balancing
criteria?
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A discussion of those criteria that were most
critical in the selection decision (i.e., those
criteria that distinguish the alternatives most)?
Emphasis on the tradeoffs among the alternatives
with respect to the five balancing criteria?
A description of the role of the State and
community acceptance considerations (i.e.,
modifying criteria)in the decision-making
process?
A general statement that the selected remedy meets
the statutory requirement to utilize permanent
solutions and treatment technologies to the
maximum extent practicable?
Does the ROD document how the selected remedy
satisfies the preference of CERCLA section 121 for
treatment as a principal element, as follows?
If the remedy uses treatment to address the
principal threat(s) posed by conditions at the
site, a description of how the preference for
treatment is satisfied; or
If treatment is not used to address the principal
threats, an explanation of why the preference is
not satisfied. This explanation will refer back
to the explanation under the "maximum extent
practicable" finding of why treatment of the
principal threats was found to be either
impracticable or not within the limited scope of
the response action.
o Documentation of Significant Changes
Does the ROD identify the preferred alternative
originally presented in the Proposed Plan?
Does the ROD describe any significant changes and
explain the reasons for them, as required by CERCLA
section 117(b)?
III. The Responsiveness Summary
Does the ROD contain information about (1) community
preferences regarding the remedial alternatives; and
(2) general public concerns about the site?
Does the ROD contain the comments of the public,
including PRPs, on key Agency documents related to the
site cleanup, as well as the Agency response to those
comments?
-------
CHECKLIST FOR PROPOSED PLANS
I. INTRODUCTION
Does the introduction state the site name and location,
identify the lead and support agencies, and state that
the Proposed Plan:
fulfills requirements of CERCLA section 117(a)?
describes remedial alternatives analyzed?
identifies preferred alternative and explains
rationale for preference?
highlights key information in the RI/FS and
administrative record?
solicits community involvement in the selection of
remedy?
invites public comment on all alternatives?
II. SITE BACKGROUND
Does the Proposed Plan provide a brief description of the
site, including:
history of site activities leading to current
problems?
site area or media to be addressed by the selected
remedy?
III. SCOPE/ROLE OF OPERABLE UNIT OR RESPONSE ACTION
Are the principal threats posed by conditions at the
site identified?
Is the scope of the problems addressed by the preferred
alternative and its role within the overall site clean-up
strategy discussed?
IV. SUMMARY OF SITE RISKS
Is a brief overview of results of the baseline risk
assessment presented?
Are current risks compared against remediation goals?
Are environmental risks addressed?
-------
V. SUMMARY OF ALTERNATIVES
Is each alternative adequately described by highlighting
the following:
treatment/engineering components and quantities of
waste related to each component
institutional controls
implementation time/requirements
estimated construction and O&M costs (including
present worth)
major ARARs
VI. EVALUATION OF ALTERNATIVES & THE PREFERRED ALTERNATIVE
Is the preferred alternative identified and is it
emphasized that selection of this alternative is
preliminary and could change as a result of public
comments or new information?
Are the nine criteria used to evaluate alternatives
described?
Is the expected performance of the preferred alternative
(in terms of the nine criteria) discussed, explaining how
the preferred alternative compares to the other
alternatives?
Does discussion present the lead agency's preliminary
determination that the preferred alternative provides the
best balance of tradeoffs with respect to the nine
criteria, and that it is anticipated to meet the
following statutory requirements:
protect human health and the environment
comply with ARARs (or justify a waiver)
be cost-effective
utilize permanent solutions and alternative treatment
or resource recovery technologies, to the maximum
extent practicable
satisfy the statutory preference for treatment as a
principal element, or justify not meeting the
preference
VII. COMMUNITY PARTICIPATION
Does the plan provide information that helps public
understand how they can be involved, including:
notice of the dates of the public comment period
date, time, and location of public meeting(s) planned
names, numbers, and addresses of lead and support
agency contacts to whom comments should be sent
whether a special notice has been issued to PRPs
location of the administrative record and other
information repositories
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C 20460
OCT I 8 1989
Directive No. 9355.4-03
OFFICE OF
SOLID WASTE AND EMERGENICV RESPONSE
MEMORANDUM
SUBJECT:
FROM:
TO:
Considerations in Ground Water Remediation at Superfund
Sites /
'
JonathahZ
,4'»"
nnon
Acting Assistant Administrator
Waste Management Division Directors
Regions I, IV, V, VI, VII, VIII
Emergency and Remedial Response Division Director
Region II
Hazardous Waste Management Division Directors
Region III, IX
Hazardous Waste Division Director
Region X
Purpose
The purpose of this memorandum is to transmit our findings
from a recently completed study of several sites where ground
water extraction is being conducted to contain or reduce levels of
contaminants in the ground water. In addition, this memorandum
presents several recommendations for modifying the Superfund
approach to ground water remediation.
Background
The most common method for restoring contaminated ground
water is extraction and treatment of contaminated ground water.
Recent research has suggested that in many cases, it may be more
difficult than is often estimated to achieve cleanup concentration
goals in ground water. In response to these findings, the Office of
Emergency and Remedial Response (OERR) initiated a project to
assess the effectiveness of ground water extraction systems in
achieving specified goals. Nineteen case studies were developed
from among Superfund and State-lead sites, RCRA and Federal
facilities. These sites were selected primarily on the basis that
the ground water extraction systems had been operating for a period
of time sufficiently long to allow for an evaluation of the system.
-------
Ob-iective
The objective of this memorandum is to describe the findings
of this study and to recommend the consideration of certain
factors and approaches in developing and implementing ground water
response actions at Superfund sites.
Findings of Study
Several trends were identified from the case studies:
o The extraction systems are generally effective in
containing contaminant plumes, thus preventing further
migration of contaminants.
o Significant mass removal of contaminants (up to 130,000
pounds over three years) is being achieved.
o Concentrations of contaminants have generally decreased
significantly after initiation of extraction but have t
tended to level off after a period of time. At the sites
examined, this leveling off usually began to occur at
concentrations above the cleanup goal concentrations
expected to have been attained at that particular point
in time.
i
o Data collection was usually not sufficient to fully
assess contaminant movement and system response to
extraction.
Several factors appear to be limiting the effectiveness of
the extraction systems examined, including:
o Hydrogeological factors, such as the heterogeneity of the
subsurface, the presence of low permeability layers, and
the presence of fractures;
o Contaminant-related factors, such as sorption to the
soil, and presence of non-aqueous phase liquids
(dissolution from a separate non-aqueous phase or
partitioning of contaminants from the residual non-
aqueous phase);
o Continued leaching from source areas;
o System design parameters, such as pumping rate, screened
interval, and location of extraction wells.
The report summarizing the study and findings, entitled
Evaluation of Ground Water Extraction Remedies is attached.
Additional copies of the report are available through the Public
Information Center ((202) 382-2080) or the Center for
-------
Environmental Research Information (FTS 684-7391 or (513) 569-
7391).
Recommendations
The findings of the study substantiate previous research and
confirm that ground water remediation is a very new, complex
field. Based on this study, I am recommending consideration of
certain factors and approaches in developing and implementing
ground water response actions. The major recommendation is to
orient our thinking so that we initiate early action on a small
scale, while gathering more detailed data prior to committing to
full-scale restoration. These recommendations are consistent
with the Guidance on Remedial Actions for Contaminated Ground
Water at Superfund Sites and do not alter Superfund's primary
goal of returning ground water to its beneficial uses in a time
frame that is reasonable given the particular site circumstances.
The recommendations do, however, encourage the collection of data
to allow for the design of an efficient cleanup approach that
more accurately estimates the time frames required for
remediation and the practicability of achieving cleanup goals. .
While standard procedures for the more refined data
collection techniques suggested below are being developed, it
will be beneficial at most sites to implement the ground water
remedy in stages. This might consist of operating an extraction
system on a small scale that can be supplemented incrementally as
information on aquifer response is obtained.
These recommendations are described further below. The
attached flow chart illustrates how the recommendations fit into
the Superfund ground water response process.
Recommendation 1: Initiate Response Action Early.
The bias for action should be considered early in the site
management process. Response measures may be implemented to
prevent further migration of contaminants if they will prevent
the situation from getting worse, initiate risk reduction, and/or
the operation of such a system would provide information useful
to the design of the final remedy. Because the data needed to
design a ground water containment system are often more limited
than that needed to implement full remediation, it will in a
number of cases be possible and valuable to prevent the
contaminant plume from spreading while the investigation to
select the remediation system progresses. The determination of
whether to implement a containment system should be based on
existing information, data defining the approximate plume
boundaries, hydrologic data, contaminants present, and
approximate concentrations, and best professional judgment.
Examples of situations where this type of action will probably be
warranted include sites where ground water plumes are migrating
-------
rapidly (e.g., highly permeable aquifers, mobile contaminants,
potential migration thorough fractures) and sites near drinking
water wells that are potentially affected by the plume.
A Record of Decision (ROD) for an interim remedy may be
prepared with a limited evaluation of alternatives that compares
the advantages of taking an early action to the possible
ramifications of waiting until the investigation has been
completed. The evaluation of this action should be included as
part of the scoping phase for the site and if determined to be
appropriate, implemented while the overall RI/FS is underway.
The RI/FS for the final action at the site should continue and
incorporate information gained from this early action. If a
containment action is implemented, the ground water flow should
be monitored frequently, immediately before, during, and
immediately after initiation of the action to obtain information
on system response.
It is alfjo advisable to implement ground water remediation
systems in a staged process at sites where data collected during
the remedial investigation did not clearly define the parameters
necessary to optimize system design. This might consist of
installing an extraction system in a highly contaminated area and
observing the response of the aquifer and contaminant plume
during implementation of the remedy. Based on the data gathered
during this initial operation, the system could be modified and
expanded as part of the remedial action phase to address the
entire plume in the most efficient manner.
Recommendation 2: Provide Flexibility in the Selected Remedy to
Modify the System Based on Information Gained During Its
Operation.
In many cases it may not be possible to determine the
ultimate concentration reductions achievable in the ground water
until the ground water extraction system has been implemented and
monitored for some period of time. Records of Decision should
indicate the uncertainty associated with achieving cleanup goals
in the ground water.
In general, RODs should indicate that the goal of the action
is to return the ground water to its beneficial uses; i.e.,
health-based levels should be achieved for ground water that is
potentially drinkable. In some cases, the uncertainty in the
ability of the remedy to achieve this goal will be low enough
that the final remedy can be specified without a contingency.
However, in many cases, it may not be practicable to attain that
goal, and thus it may be appropriate to provide in the ROD for a
contingent remedy, or for the possibility that this may only be
an interim ROD. Specifically, the ROD should discuss the
possibility that information gained during the implementation of
-------
the remedy may reveal that it is technically impracticable to
achieve health-based concentrations throughout the area of
attainment, and that another remedy or a contingent remedy may be
needed.
Where sufficient information is available to specify an
alternative or contingent remedy at the time of remedy selection,
the ROD should discuss the contingency in equal detail to the
primary remedial option, and should provide substantive criteria
by which the Agency will decide whether or not to implement the
contingency. See Interim Final Guidance on Preparing Superfund
Decision Documents, OSWER Directive 9355.3-02 (May 1989), at page
9-17.1 Tne ROD may aiso discuss the possibility that an ARARs
waiver will be invoked when MCLs or other Federal or State
standards cannot practicably be attained in the ground water; a
written waiver finding should be issued at the time the
contingency is invoked, or in limited circumstances, in the ROD
itself.2
The public should be informed of the decision to invoke the
contingency (and, perhaps, the waiver) through issuance of an •
Explanation of Significant Differences (ESD) which involves a
public notice. A formal public comment period is not required
when a decision is made to invoke a contingency specified in the
ROD; however, the Region may decide to hold additional public
comment periods pursuant to NCP section 300.825(b) (proposed)
(Dec. 21, 1988, 53FR at 51516). In any event, the public may
submit comments after ROD signature on any significant new
information which "substantially support[s] the need to
significantly alter the response action" NCP Section 300.825(c)
(proposed).
There may also be situations where the Region finds that it
is impracticable to achieve the levels set out in the ROD, but no
contingency had been previously specified in the ROD. In such
cases, a ROD amendment would be necessary to document fundamental
changes that are made in the remedy based on the information
gained during implementation; an ESD would be necessary to
1 For instance, the ROD may provide that a contingent
remedy will be implemented if there is a levelling-off of
contaminant concentrations despite continued ground water
extraction over a stated period of time.
2 It may be possible to invoke a waiver at the time of ROD
signature (a "contingent waiver") where, for example, the ROD is
detailed and establishes an objective level or situation at which
the waiver would be triggered. However, the use of contingent
waivers should only be considered on a case-by-case basis after
discussion with OERR\OWPE.
-------
document significant but non-fundamental changes in the remedy
based on the additional information.
For sites where there is substantial uncertainty regarding
the ability of the remedy to return the ground water to its
beneficial uses (e.g., dense non-aqueous phase liquids in
fractured bedrock) it is appropriate to indicate that the initial
action is interim with an ultimate remedy to be determined at
some specified future date. The action should be designed to
achieve the basic goal and carefully monitored over time to
determine the feasibility of achieving this goal. In many of
these cases, this can only be determined after several years of
operation. The five year review may be the most appropriate time
to make this evaluation. When sufficient data have been
collected to specify the ultimate goal achievable at the site
(e.g., first or second five year review), a final ROD for ground
water would be prepared specifying the ultimate goal, including
anticipated time frame, of the remedial action.
Although overall system parameters must be specified in the
ROD, it is usually appropriate to design and implement the ground
water response action as a phased process. An iterative process
of system operation, evaluation, and modification during the
construction phase can result in the optimum system design.
Extraction wells might be installed incrementally and observed
for one to three mpnths to determine their effectiveness. This
will help to identify appropriate locations for additional wells
and can assure proper sizing of the treatment systems as the
range of contaminant concentrations in extracted ground water is
confirmed.
If it is determined that some portion of the ground water
within the area of attainment cannot be returned to its
beneficial uses, an evaluation of an alternate goal for the
ground water should be made. Experience to date on this phase of
ground water remediation is extremely limited and more definitive
guidance on when to terminate ground water extraction will be
provided later. When the point at which contaminant
concentrations in ground water level off, however, this should be
viewed as a signal that some re-evaluation of the remedy is
warranted. In many cases, operation of the extraction system on
an intermittent basis will provide the most efficient mass
removal. This allows contaminants to desorb from the soil in the
saturated zone before ground water is extracted providing for
maximum removal of contaminant mass per volume of ground water
removed.
Ground water monitoring should continue for two to three
years after active remediation measures have been completed to
ensure that contaminant levels do not recover. For cases where
contaminants remain above health-based levels, reviews to ensure
-------
that protection is being maintained at the site will take place
at least every five years.
Recommendation 3: Collect Data to Better Assess Contaminant
Movement and Likely Response of Ground Water to Extraction.
In addition to the traditional plume characterization data
normally collected, the following data is of particular
importance to the design and evaluation of ground water remedies
and should be considered in scoping ground water RI/FSs.
Assessments of contaminant movement and extraction effectiveness
can be greatly enhanced by collecting more detailed information
on vertical variations in stratigraphy and correlating this to
contaminant concentrations in the soil during the remedial
investigation. More frequent coring during construction of
monitoring wells and the use of field techniques to assess
relative contaminant concentrations in the cores are methods that
may be used to gain this information. More detailed analysis of
contaminant sorption to soil in the saturated zone can also
provide the basis for estimating the time frame for reducing
contaminant concentrations to established levels and identifying
the presence of non-aqueous phase liquids. Cores taken from
depths where relatively high concentrations of contaminants were
identified might be analyzed to assess contaminant partitioning
between the solid and aqueous phases. This might involve
measuring the organic carbon content and/or the concentration of
the contaminants themselves.
The long-term goal is to collect this information during the
RI so that more definitive decisions can be made at the ROD
stage. Standardized sampling and analytical methods to support
these analyses are currently being evaluated.
For further information, please consult the appropriate
Regional Ground Water Forum member, Jennifer Haley at
FTS 475-6705 or Caroline Roe at FTS 475-9754 in OERR's Hazardous
Site Control Division, or Dick Scalf at the Robert S. Kerr
Environmental Research Laboratory (FTS 743-2308)
Attachment: Flow Chart
Summary Report
cc: Superfund Branch Chiefs, Regions I - X
Superfund Section Chiefs, Regions I - X wo/summary report
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Page 6-35
EXHIBIT 6-11
RESIDENTIAL EXPOSURE: INGESTION OF
CHEMICALS IN DRINKING WATER0
(AND BEVERAGES MADE USING DRINKING WATER)
Equation:
Intake (mg/kg-day) = CW x IR x EF x ED
BWxAT
Where:
C\V =
IR =
EF =
ED =
BW =
AT =
Chemical Concentration in Water (nig/liter)
Ingestion Rate (liters/day)
Exposure Frequency (days/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
Variable Values:
CW:
IR:
EF:
ED:
BW:
AT:
Site-specific measured or modeled value
2 liters/day (adult, 90th percentile; EPA 1989d)
1.4 liters/day (adult, average; EPA 1989d)
Age-specific values (EPA 1989d)
Pathway-specific value (for residents, usually daily — 365 days/year)
70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile)
at one residence; EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic
effects (i.e., 70 years x 365 days/year).
See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 9Slh or 90lh percentile values for contact rate
and exposure frequency and duration variables.
-------
Pace 6-36
EXHIBIT 6-12
RESIDENTIAL EXPOSURE:
INGESTION OF CHEMICALS IN SURFACE WATER
WHILE SWIMMING"
Equation:
Intake (mg/kg-day) = CW x CR x ET x EF x ED
BWxAT
Where:
CW =
CR =
ET =
EF =
ED =
BW =
AT =
Chemical Concentration in Water (mg/liter)
Contact Rate (liters/hour)
Exposure Time (hours/event)
Exposure Frequency (events/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
Variable Values:
CW:
CR:
ET:
EF:
ED:
BW:
AT:
Site-specific measured or modeled value
50 ml/hour (EPA 1989d)
Pathway-specific value
Pathway-specific value (should consider local climatic conditions
[e. g., number of days above a given temperature] and age of
potentially exposed population)
7 days/year (national average for swimming; USDOI in
EPA 1988b, EPA 1989d)
70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one
residence; EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic
effects (i.e., 70 years x 365 days/year).
' See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate
and exposure frequer and duration variables.
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Page 6-37
EXHIBIT 6-13
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN WATER'
Equation
Where:
CW =
SA =
PC =
ET =
EF =
ED =
CF =
BW =
AT =
:
Absorbed Dose (mg/kg-dav) - CW x SA x PC x ET x EF x ED x CF
BW x AT
Chemical Concentration in Water (mg/iiter)
Skin Surface Area Available for Contact (cm2)
Chemical-specific Dermal Permeability Constant (cm/hr)
Exposure Time (hours/day)
Exposure Frequency (days/year)
Exposure Duration (years)
Volumetric Conversion Factor for Water (1 liter/1000 cm3)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
j
Variable Values:
CW: Site-specific measured or modeled value
SA:
50th Percentile Total Bodv Surface Area (m2) (EPA 1989d. 1985a)
AGE (YRS) MALE FEMALE
3 < 6 0.728 0.711
6 < 9 0.931 0.919
9 < 12 1.16 1.16
12 < 15 1.49 1.48
15 < 18 1.75 1.60
Adult 1.94 1.69
50th Percentile Bodv Part-specific Surface Areas for Males (m2) (EPA 1989d. 1985a>
AGE (YRS) ARMS HANDS LEGS
3 < 4 0.096 0.040 0.18
6 < 7 0.11 0.041 0.24
9 < 10 0.13 0.057 0.31
Adult 0.23 0.082 0.55
See Section 6,4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate and
exposure frequency and duration variables. Use 50th percentile values for SA; see text for rationale.
(continued)
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Page 6-38
EXHIBIT 6-13 (continued)
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN WATER0
NOTE: Values for children were calculated using age-specific body surface areas and the average
percentage of total body surface area represented by particular body parts in children,
presented in EPA 1985a. Values for adults presented in EPA 1989d or calculated from
information presented in EPA 1985a. Information on surface area of other body parts (e.g.,
head, feet) and for female children and adults also is presented in EPA 1985a, I989d
Differences in body part surface areas between sexes is negligible.
PC: Consult open literature for values [Note that use of PC values results in
an estimate of absorbed dose.]
ET: Pathway-specific value (consider local activity patterns if information
is available)
2.6 hrs/day (national average for swimming; USDOI in
EPA 1988b, EPA 1989d)
EF: Pathway-specific value (should consider local climatic conditions
[e. g., number of days above a given temperature] and age of potentially
exposed population)
7 days/year (national average for swimming; USDOI in EPA 1988b,
EPA 1989d)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
CF: 1 liter/1000 cm3
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
"See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate
the reasonable maximum exposure. In general, combine 95lh or 90th percentile values for
contact rate and exposure frequency and duration variables.
-------
Pafe 6-40
EXHIBIT 6-14
RESIDENTIAL EXPOSURE:
INGESTION OF CHEMICALS IN SOIL*
Equation:
Intake (mg/kg-day) = CS x IR x CF x FI x EF x ED
BWxAT
Where:
CS = Chemical Concentration in Soil (mg/kg)
IR = Ingestion Rate (mg soil/day)
CF = Conversion Factor (10-• kg/mg)
FI = Fraction Ingested from Contaminated Source (unitless)
EF = Exposure Frequency (days/years)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged — days)
Variable Values:
CS: Site-specific measured value
IR: 200 mg/day (children, 1 through 6 years old; EPA 1989g)
100 mg/day (age groups greater than 6 years old; EPA 1989g)
NOTE: IR values are default values and could change based
on site-specific or other information. Research is currently ongoing
to better define ingestion rates. IR values do not apply to individuals
with abnormally high soil ingestion rates (i.e., pica).
CF: 10 -* kg/mg
FI: Pathway-specific value (should consider contaminant location and
population activity patterns)
EF: 365 days/year
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one
residence; EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
16 kg (children 1 through 6 years old, 50th percentile; EPA 1985a)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate
the reasonable maximum exposure. In general, use 9Slh or 90th percentile values for contact rate
and exposure frequency and duration variables.
-------
Page 6-41
EXHIBIT 6-15
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN SOIL*
Equation:
Absorbed Dose (me/ke-dav) = CS x CF x SA x AF x ABS x EF x ED
BWxAT
Where:
CS = Chemical Concentration in Soil (mg/kg)
CF - Conversion Factor (10 *• kg/mg)
SA = Skin Surface Area Available for Contact (cnvYevent)
AF = Soil to Skin Adherence Factor (mg/cm2)
ABS = Absorption Factor (unitless)
EF = Exposure Frequency (events/year)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged — days)
Variable Values:
CS: Based on site-specific measured value
CF: 10"' kg/mg
SA:
50th Percentile Total Bodv Surface Area (m2) (EPA 1989d. 1985a)
NOTE:
ACE (\US^ MALE FEMALE
3 < 6 0.728 0.711
6 < 9 0.931 0.919
9 < 12 1.16 1.16
12 < 15 1.49 1.48
15 < 18 1.75 1.60
Adult 1.94 1.69
50th Percentile Bodv Part-specific Surface Areas for Males (m') (EPA 1989d. 1985a)
AGE (YRS) ARMS HANDS LEGS
3 < 4 0.096 0.040 0.18
6 < 7 0.11 0.041 0.24
9 < 10 0.13 0.057 0.31
Adult 0.23 0.082 0.55
Values for children were calculated using age-specific body surface areas and the average percentage
of total body surface area represented by particular body parts in children, presented in EPA I985a.
Values for adults presented in EPA I989d or calculated from information presented in EPA I985a.
" See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate the reason-
able maximum exposure. In general, combine 95th or 90th percentile values for contact rate and exposure
frequency variab' Use 50th percentile values for SA; see text for rationale.
(continued)
-------
Page 6-42
EXHIBIT 6-15 (continued)
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN SOIL"
NOTE (continued): Information on surface area of other body parts (e.g., head, feet) and for female
children and adults also is presented in EPA I985a, 1989d. Differences in body part surface
areas between sexes is negligible.
AF: 1.45 rag/cm* — commercial potting soil (for hands; EPA 1989d, EPA
1988b)
2.77jng/cm2 — kaolin clay (for hands; EPA 1989d, EPA 1988b)
ABS: Chemical-specific value (this value accounts for desorption of
chemical from the soil matrix and absorption of chemical across
the skin; generally, information to support a determination of ABS is
limited — see text)
EF: Pathway-specific value (should consider local weather conditions
[e.g.,number of rain, snow and frost-free days] and age of potentially
exposed population)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 95lh or 90th percentile values for contact rate
and exposure frequency and duration variables.
-------
Page 6-44
EXHIBIT 6-16
RESIDENTIAL EXPOSURE:
INHALATION OF AIRBORNE (VAPOR PHASE) CHEMICALS
ab
Equation:
Intake (mg/kg-day) = CA x IR x ET x EF \ ED
BWxAT
Where:
CA =
IR =
ET =
EF =
ED =
BW =
AT =
Contaminant Concentration in Air (mg/m3)
Inhalation Kate (nWhour)
Exposure Time (hours/day)
Exposure Frequency (days/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
Variable Values:
CA:
IR:
Site-specific measured or modeled value
30 m3/day (adult, suggested upper bound value; EPA 1989d)
20 m3/day (adult, average; EPA 1989d)
Hourly rates (EPA 1989d)
Age-specific values (EPA 1985a)
Age, sex, and activity based values (EPA 1985a)
0.6 m3/hr — showering (all age groups; EPA 1989d)
ET: Pathway-specific values (dependent on duration of exposure-related
activities)
12 minutes — showering (90th percentile; EPA 1989d)
7 minutes — showering (50th percentile; EPA 1989d)
EF: Pathway-specific value (dependent on frequency of showering or other
exposure-related activities)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
See Section 6.4.1 and 6.6.3 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, use 9Slh or 90th percentile values for contact rate and
exposure frequency and duration variables.
The equation and variable values for vapor phase exposure can be used with modification to calculate
particulate exposure. See text.
-------
r
tage 6-45
EXHIBIT 6-17
RESIDENTIAL EXPOSURE: FOOD PATHWAY —
INGESTION OF CONTAMINATED FISH AND SHELLFISH'
Equation:
Intake (mg/kg-day) = CF x IR x FI x EF x ED
BWxAT
Where:
CF
IR
FI
EF
ED
BW
AT
Contaminant Concentration in Fish (mg/kg)
Ingestion Rate (kg/meal)
Fraction Ingested from Contaminated Source (unitless)
Exposure Frequency (meals/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
Variable Values:
CF: Site-specific measured or modeled value
IR: 0.284 kg/meal (95th percentile for fin fish; Pao et ol. 1982)
0.113 kg/meal (50th percentile for fin fish; Pao etol. 1982)
132 g/day (95th percentile daily intakes averaged over three days
for consumers of fin fish; Pao et ol. 1982)
38 g/day (50th percentile daily intake, averaged over three days
for consumers of fin fish; Pao et ol. 1982)
6.5 g/day (daily intake averaged over a year, EPA 1989d.
NOTE: Daily intake values should be used in conjunction with
an exposure frequency of 365 days/year.)
Specific values for age, sex, race, region and fish species are
available (EPA 1989d, 1989h)
FI: Pathway-specific value (should consider local usage patterns)
EF: Pathway-specific value (should consider local population patterns
if information is available)
48 days/year (average per capita for fish and shellfish; EPA Tolerance
Assessment System in EPA 1989H)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
"See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, use 95th or 90th percentile values for intake rate and
exposure frequency and duration variables.
-------
Page 6-46
EXHIBIT 6-18
RESIDENTIAL EXPOSURE: FOOD PATHWAY —
INGESTION OF CONTAMINATED FRUITS AND VEGETABLES"
Equation:
Intake (mg/kg-day) = CF x IR x FI x EF x ED
BWxAT
Where:
CF
IR
FI
EF
ED
BW
AT
Contaminant Concentration in Food (mg/kg)
Ingestion Rate (kg/meal)
Fraction Ingested from Contaminated Source (unitless)
Exposure Frequency (meals/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
Variable Values:
CF:
IR:
FI:
EF:
ED:
BW:
AT:
Site-specific measured value or modeled value based on soil
concentration and plant:soil accumulation factor or deposition factors
Specific values for a wide variety of fruits and vegetables are available
(Pao el al. 1982)
Pathway-specific value (should consider location and size of
contaminated area relative to that of residential areas, as well as
anticipated usage patterns)
Pathway-specific value (should consider anticipated usage patterns)
70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
"See Section 6.4. J and 6.6.4 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure, in general, use 95th or 90lh percentile values for contact rate and
exposure frequency and duration variables.
-------
Page 6-48
EXHIBIT 6-19
f
RESIDENTIAL EXPOSURE: FOOD PATHWAY —
INGESTION OF CONTAMINATED MEAT, EGGS,
AND DAIRY PRODUCTS"
Equation:
Intake (mg/kg-day) = CFx IR x FI x EF x ED
BWxAT
Where:
CF
IR
FI
EF
ED
BW
AT
Contaminant Concentration in Food (mg/kg)
Ingestion Rate (kg/meal)
Fraction Ingested from Contaminated Source (unitless)
Exposure Frequency (meals/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
Variable Values:
CF:
IR:
FI:
EF:
ED:
BW:
AT:
Site-specific measured or modeled value. Based on soil
concentrations, plant (feed) accumulation factors, and feed-to-meat
or feed-to-dairy product transfer coefficients
0.28 kg/meal — beef (95th percentile; Pao el al. 1982)
0.112 kg/meal — beef (50th percentile; Pao etal. 1982)
Specific values for other meats are available (Pao et al. 1982)
0.150 kg/meal — eggs (95th percentile; Pao el al. 1982)
0.064 kg/meal — eggs (50th percentile; Pao et al. 1982)
Specific values for milk, cheese and other dairy products are available
(Pao et al. 1982)
Pathway-specific value (should consider location and size of contaminated
area relative to that of residential areas, as well as anticipated usage
patterns)
Pathway-specific value (should consider anticipated usage patterns)
70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA1989d)
70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
" See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate
the reasonable maximum exposure. In general, use 95lh or 90th percentile values for contact rate
and exposure frequency and duration.
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INFORMATION TO BE INCLUDED IN AN RI/FS TO DOCUMENT THE INTENT
TO COMPLY WITH THE LDRs THROUGH A TREATABHJTY VARIANCE FOR
ON-SITE AND OFF-SITE CERCLA RESPONSE ACTIONS INVOLVING THE
PLACEMENT OF SOIL AND DEBRIS CONTAMINATED WITH RESTRICTED RCRA WASTES
ON-SITE
• Description of the soil or debris waste and the source of the contamination;
• Description of the Proposed Action (e.g., "excavation, treatment, and off-site disposal");
• Intent to comply with the LDRs through a Treatability Variance;
• For each alternative using a Treatability Variance to comply, the specific treatment level range
to be achieved.
OFF-SITE
For off-site Treatability Variances, the information above should be extracted from the RI/FS report and
combined with the following information in a separate document:*
,J?£titiofler!s.iname ^pH-ajitificari/Mi of .an authorized contact person {if ..different);
Statement of petitioner's interest in obtaining a Treatability Variance; and
* This document may be prepared after the ROD is signed (and Treatability Variance granted) but will
need to be compiled prior to the first shipment of wastes (or treatment residuals) to the receiving
treatment or disposal facility.
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Page?
SUBCATEGORJES FOR CHARACTERISTIC WASTES
The following are RCRA characteristic wastes for which EPA established more than the two standard
treatability groups (i.e., wastewaters and nonwastewaters):
• D001 Ignitables
Ignitable liquids
- organic liquids
-- aqueous liquids
~ wastewaters
Ignitable reactives
Oridizers
Ignitable compressed gases
D002 Corrosives
Acids
Alkalines
Other corrosives
D003 Reaaives
Reactive cyanides
Explosives
Water reactives
Reactive snifMfg
Other reactives
D006 Cadmium
Wastewaters
Nonwastewaters
Cadmium Batteries
D007 Chromium
Wastewaters
Nonwastewaters
Chromium Bricks
Chromium Batteries
DOOSLead
Wastewaters
Nonwastewaters
Lead-Acid Batteries
Note: Those characteristic wastes not included were divided only into wastewater and nonwastewater
forms.
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Page 9
SURFACE-DISPOSED WASTES RECEIVING NATIONAL CAPACITY VARIANCES IN THE THIRD TfflRD RULE
Technology Waste Code*
Vitrification D004
K031
K084
K101
K102
P010
P011
P012
P036
P038
U136
Chromium Recovery D007*
Combustion of Sludge/Solids FDS^
Mercury Retorting D009
K106
P065
P092
U151
Secondary Smelting DOGS'*
Thermal Recovery P015
P073
P087
Combustion, vitrification, wet-air Soil and
oxidation, mercury retorting, and Debris
chromium reduction
a Variances are granted only to the nonwastewater forms.
6 D007 refractory bricks.
c Multi-source leachate.
d D008 lead-acid batteries.
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Page 12
CONSTITUENTS AND REGULATORY LEVELS
ESTABLISHED UNDER THE TOX3CITY CHARACTERISTIC RULE
Old EP Toridty Characteristics
(also regulated under TC)
Waste Regulated Reg. Level
Code Constituent (mg/1)
New TC Constituents
D004 Arsenic
D005 Barium
D006 Cadmium
D007 Chromium
D008 Lead
D009 Mercury
D010 Selenium
D011 Silver
D012 Endrin
D013 Lindane
D014 Methoxyclor
D015 Toxaphene
D016 2,4-D
D017 2,4,5-TP (silvex)
5.0
100.0
1.0
5.0
5.0
0.2
1.0
5.0
0.0
0.4
10.0
0.5
10.0
1.0
Waste Regulated Reg. Level
Code Constituent (me/I)
D018 Benzene
D019 Carbon Tetrachloride
D020 Chlordane
D021 Chlorobenzene
D022 Chloroform
D023 o-Cresol
D024 m-Cresol
D025 p-Cresol
D026 1,4-Diehlorobenzene
D027 1,2-Dichloroethane
D028 1,1-Dichloroethylene
D029 2,4-Dinitrotoluene
D030 Heptachlor
D031 Hexachlorobenzene
D032 Hexachloro-13-butadiene
D033 Hexachloroethane
DQ34 Methyl ethyl ketone
D035 Nitrobenzene
D036 Pentachlorophenol
D037 Pyridine
D038 Tetrachloroethylene
D039 Trichloroethylene
D040 2,3,5-Trichlorophenol
D041 2,4,6-Trichlorophenol
D042 Vinyl chloride
0.5
0.5
0.0
100.0
6.0
200.0*
200.0*
200.0*
7.5
0.5
0.7
0.1
0.0
0.1
0.5
3.0
200.0
2.0
100.0
5.0
0.7
0.5
400.0
2.0
0.2
* If o-, m-, and p-Cresol cannot be differentiated, total cresol concentration of 200.0 mg/1 is used as a
regulatory level
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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