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                           DISCLAIMER

This report was  furnished to the U.S. Environmental Protection
Agency by  the student identified  on the cover page,  under a National
Network for Environmental  Management  Studies  fellowship.

The contents are essentially  as  received from  the  author.  The
opinions, findings,  and conclusions  expressed  are  those of the author
and  not necessarily  those of the U.S. Environmental  Protection
Agency.  Mention,  if any, of company, process, or product names  is
not to be considered as an endorsement by the U.S.  Environmental
Protection  Agency.

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A SUMMARY OF CONTAMINATED  SEDIMENT REMEDIAL ACTIONS IN
 REGION V OF THE U.S. ENVIRONMENTAL PROTECTION AGENCY
                          by

                  Mark Elster, Intern
                 National Network for
       Environmental Management  Studies Program
                     Prepared for:

                      Marc Tuchman
         U.S. Environmental  Protection Agency
                       Region V
                    Water  Division
                     August,  1991
                                                 '•~iicn Agency

                                                     •*-u< floor

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                             Abstract

Contaminated sediments, or  in-place pollutants,  can affect water
quality and may contribute to long-term health effects in aquatic
biota  and  human  beings.    This  can  occur  through  toxicity,
bioaccumulation up  the food chain and through  fish consumption.
The pervasive and widespread nature of this problem has resulted
from  historically   inadequate  regulation  of  waste  disposal  and
industrial wastewater discharges.  A directed, dedicated effort to
mitigate the effects of contaminated sediments and to effect their
removal has  yet to  be fully developed due to  several  factors,
including the lack of sediment criteria and a definition as to what
a contaminated sediment is.   Actions are  currently being taken to
address these deficiencies.

In  the  U.S.  Environmental  Protection Agency  Region V,  several
contaminated  sediment  removal  actions have taken place  under a
variety of  enforcement authorities.   At  the Federal enforcement
level,  USEPA has  exercised  authority under  the  Comprehensive
Environmental Response, Compensation,  and  Liability Act, the Clean
Water Act, and to a lesser  extent,  the Resource Conservation and
Recovery Act and the Toxic Substances Control Act.  These acts seek
to  control  the source  of  the contaminant  and to  remediate  the
damage to human health and the environment.  Region V States have
effected removal actions through legal authority given to them to
regulate dischargers  under  the CWA,  through State environmental
protection  laws,  through voluntary  agreements with potentially
responsible parties, and through Federal  grant programs.

This report summarizes a number of contaminated sediment remedial
actions conducted in USEPA Region V.  These cleanups were conducted
at  both  the  Federal  and   State  levels,  using  a  variety  of
enforcement actions, and employed a number  of  different remedial
technologies.    By  examining  the   various  cleanups   and  the
methodologies implemented,  USEPA hopes to  identify the most cost-
effective and technologically sound procedures for application to
future contaminated sediment remedial actions.

By identifying and removing contaminated  sediments, the State and
Federal  agencies  in USEPA  Region  V will  hasten  the  goal  of
improving water quality throughout the region.

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                             Glossary
AOC
ARCS
ASRI
CPAH
CDF
CERCLA

CFS
CSO
CTF
CWA
DOD
DOI
DOJ
FDA
MRS
IAG
IDEM
I EPA
IJC
IPP
ISV
MCD
MDNR
NPDES
NPL
OEPA
PAH
PCB
POTW
PPB
PPM
PRP
RAP
RCRA
RFP
RI/FS
ROD
RRT
SARA
SCP
SRP
STP
TCLP
TSCA
TSD
USAGE
US EPA
USFWS
WDNR
Area of Concern
Assessment and Remediation of Contaminated Sediments
Alternative Specific Remedial Investigation
Carcinogenic Polynuclear Aromatic Hydrocarbons
Confined Disposal Facility
Comprehensive Environmental Response, Compensation,
and Liability Act
Cubic Feet Per Second
Combined Sewer Overflow
Confined Treatment Facility
Clean Water Act
Department of Defense
Department of the Interior
Department of Justice
Food and Drug Administration
Hazardous Ranking System
Interagency Agreement
Indiana Department of Environmental Management
Illinois Environmental Protection Agency
International Joint Commission
In-Place Pollutants
In Situ Vitrification
Modified Consent Decree
Michigan Department of Natural Resources
National Pollution Discharge Elimination System
National Priorities List
Ohio Environmental Protection Agency
Polynuclear Aromatic Hydrocarbons
Polychlorinated Biphenyls
Publicly Owned Treatment Works
Parts Per Billion
Parts Per Million
Potentially Responsible Party(ies)
Remedial Action Plan
Resource Conservation and Recovery Act
Request for Proposal
Remedial Investigation/Feasibility Study
Record of Decision
Regional Response Team
Superfund Amendments and Reauthorization Act
Sediment Characterization Plan
Sediment Remediation Plan
Sewage Treatment Plant
Toxicity Characteristic Leaching Procedure
Toxic Substances Control Act
Treatment, Storage, and Disposal
U.S. Army Corps of Engineers
U.S. Environmental Protection Agency
U.S. Fish and Wildlife Service
Wisconsin Department of Natural Resources

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Introduction

Contaminated  sediments,  or  in-place  pollutants  (IPP),  are  an
important  factor in  the  impairment  of  water  quality and  may
contribute to long-term health effects in aquatic biota and human
beings.  These sediments can act both as a sink for, and a source
of,  contaminants to  the water  column.    Contaminants can  also
bioaccumulate up the food chain and impact human health.  There are
numerous examples  of  fish consumption  advisories  issued  due  to
contaminated  sediments  affecting the  food chain.   Contaminated
sediments have  been  identified  in  41 of  42  International Joint
Commission  (IJC) Areas  of  Concern  (AOC)  and   in other  areas
throughout the Great Lakes region.

The pervasive and widespread nature of the  problem has resulted
from the historic practice  of using water bodies,  intentionally or
unintentionally, for waste disposal and from years of unregulated
or inadequately  regulated discharges of toxic  chemicals from local
industries  and   municipalities.    Urban   and  rural  runoff  and
atmospheric deposition also contribute to the contaminated sediment
problem.

Only recently has it become recognized that a directed, dedicated
effort was needed in  order to mitigate  the effects and to effect
the remediation  or removal of contaminated sediments. Despite this
recognition, several issues must be addressed to achieve this goal.
The authority to remediate contaminated sediments involve several
different Federal and State  Programs.   The contamination problem
itself  is a  cross-media  problem, involving water,  land,  and air
issues.  This  underlying complexity and the relatively new emphasis
on  contaminated  sediment remediation makes  it a  very difficult
problem  to  solve  in  a  short  time  frame.    The  United  States
Environmental Protection Agency  (USEPA)  is  beginning  to  address
these issues through the  development of regional initiatives and a
National Sediment Strategy.  This strategy is  slated for completion
in  1992.   The  USEPA's  Great Lakes  National Program  Office has
instituted the Assessment and Remediation of Contaminated Sediments
(ARCS) Program for the testing and  assessment of remedial action
alternatives  for contaminated  sediments.   A  five  year study and
demonstration project  relating to the  control  and removal of toxic
pollutants in the Great  Lakes  is currently being conducted.   The
program places  emphasis  on developing optimal methods  to assess
sediments  and  examining  new  and  innovative  technologies  for
remediating sediments.

Contaminated sediments can  continue to degrade water quality after
point and non-point sources are eliminated.  Because of this, the
decision must often be made  to remediate  a site.   One of the key
factors involved in contaminated  sediment  sites is  the question of
remediation versus "no action".   If sediments in  a site  are not
prone  to resuspension  and will  eventually  be  covered  over  by
uncontaminated  sediments through  natural  processes,   a  removal

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action may not be necessary.  This "no action" alternative should
be considered in all possible sediment remediation situations.   It
is important to note  that natural phenomena such as storms and the
mixing  of water bodies  due to  seasonal  changes  can lead  to
resuspension of contaminated sediments.  If it is determined that
some sort of removal  or other remediation must take place, careful
planning and precautions  must be  taken.   It  is  very possible to
degrade water quality during removals by resuspension of sediments
during dredging.  Also, due to the large amounts of sediments that
often need to be removed and their varying levels of toxicity, it
is desirable that suitable disposal facilities are secured before
a removal takes place.  This will not always be feasible due to the
pressing need to remove highly contaminated sediments  as quickly as
possible.  Costs incurred in sediment remediations often run into
the millions of dollars.  These high costs  also argue  for a careful
evaluation of the "no action" option.

Contaminated sediment remedial activities in Region V have gained
their legislative authority mainly from the Comprehensive Emergency
Response,  Compensation,  and Liability Act  (CERCLA)  of 1980  as
amended by the  Superfund Amendments and Reauthorization Act (SARA)
of 1986, the Clean Water Act (CWA)  of 1977,  as  amended,  and the
Resource Conservation and Recovery Act  (RCRA), as amended.   While
using the  authority  vested within the acts,  none of  these acts
specifically address sediment remediations.

CERCLA,  as amended  by SARA, and  commonly  known as  Superfund,
addresses  the  cleanup and  remediation of inactive  or abandoned
hazardous waste  sites.   Potential  sites are  ranked  by the USEPA
using  the  Hazardous  Ranking  System (HRS) to determine if  they
should  be  included  on the  National  Priorities  List  (NPL).   The
ranking is based on the hazard a site may pose to human health and
the environment via releases to groundwater,  surface water, land,
and/or  the air.  CERCLA also  includes  removal actions and the
ability  to  file claims  for  natural  resource damages.    SARA
addresses "damage to natural resources which may affect the human
food chain".   This may lead to a greater number of contaminated
sediments sites being remediated under Superfund.

The Clean Water Act gives the USEPA the  responsibility to safeguard
the quality of U.S.  coastal and inland waterways.  In accordance,
the USEPA regulates the disposal of dredged and fill materials in
partnership with the U.S.  Army Corps  of Engineers  (USAGE), and
oversees  the  National  Pollution  Discharge  Elimination  System
(NPDES)  program, regulating  point-source discharges.   All six
states  in  the USEPA  Region V -  Illinois,  Indiana,  Michigan,
Minnesota, Ohio, and Wisconsin - have taken responsibility for the
administration of the NPDES program in their respective state, as
allowed  by  the CWA,  with USEPA oversight.   By  instituting these
source  control  measures,  the  USEPA  hopes  to  stop  sediment
contamination  before  it occurs.   Source  control  is  viewed  as  a
necessary step before  any remediation takes place.

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The Resource Conservation and Recovery  Act  Section 3008(h)  gives
the USEPA authority to commence procedures  for  a RCRA 3004(u)  or
(v) corrective action at any RCRA permitted facility if a release
of hazardous waste has occurred.  This  CERCLA removal will  often
take  the  shape  of  an  emergency  response  to  an  uncontrolled
discharge.  When such discharges  occur  at an abandoned site,  the
site will be put under the authority of CERCLA.

The Toxic Substances Control Act  can  also  influence contaminated
sediment remediations.   Sediments with PCB  concentrations greater
than  50  ppm  must  be  disposed up  at  a TSCA-approved  disposal
facility which can affect the cost of the remediation.

A  number  of  contaminated sediment remediations  have  occurred  in
Region V.   A primary goal  of the  Region  is to determine  which
methods of enforcement/negotiations work best for the remediation
and  removal   of  contaminated  sediments and also work  towards
limiting the  sources of the contamination. The goal of this report
is  to compile a  summary of  remedial actions  taken  to date  at
various sites in USEPA Region V.   It examines how the contaminated
sediment problem was addressed and what solution was decided upon,
i.e., how it  was  remediated.  Maintenance dredging of navigational
channels by the  U.S. Army Corps of Engineers is not  included  in
this report.   The criteria for a site to be included in this report
was either the existence  of  a signed agreement to remediate and/or
a  completed remediation.  This report is by no  means  meant  to  be
exhaustive.  Many more sediment cleanup actions  were in the final
stages of negotiation as this report was nearing completion.

USEPA Region V hopes that by examining  the  processes  and actions
that  have  led  ongoing  and   completed  contaminated  sediment
remediations,   future   remediations   will   be   effected   more
efficiently,   leading  to  improved water quality  throughout  the
Region.

This  report   is  divided  into  sections  containing  contaminated
sediment remediation actions conducted under similar authorities.
The introduction to each section  will explain in more detail the
applicable enforcement powers used  in the remedial actions.   For
many of the cleanups, specific documents are cited.  When specific
documents  are  not cited,  the  information  was   obtained  through
personal  communications  and   USEPA  file   correspondence  and
memoranda.

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Section I

Comprehensive Environmental Response, Compensation, and
Liability Act, as amended by the Superfund Amendments
and Reauthorization Act

The  Comprehensive  Environmental   Response,   Compensation,   and
Liability  Act  (CERCLA,  1980),  as  amended  by  the  Superfund
Amendments and Reauthorization Act  (1986)  has  the  broad goals of
protecting  human  health  and the  environment  by  responding  to
potential or existing  hazardous  substance releases,  remediating or
cleaning  up  contaminated  areas,   and  assessing  liability  for
remediation  actions  and  resource  damages.   In general,  CERCLA
provisions relate either  to  remedial actions  of contamination at
abandoned  sites where  there  is  a  continuing threat  of  more
widespread contamination,  or to  emergency removal actions at spill
sites.   Under Section 104(a),  the  central response  mechanism of
CERCLA, authority is granted to  eliminate current dangers posed by
the  release  of a  hazardous substance  and to  provide  long-term
solutions to prevent  future  threats.  Sites may be scored by the
Hazardous Ranking  System  (HRS)  to  determine  if they  should  be
included on the NPL list of  priority cleanup sites in the country.
A site need  not be on the  NPL  list to be eligible  for a CERCLA
cleanup action.  Examples of both of these types of contamination
are included  in this  report.  Ongoing hazardous waste treatment,
storage,  and disposal  operations are regulated by RCRA.

CERCLA provides broad authority to locate areas with contaminated
sediments.   Section  104  gives  the USEPA  authority  to  undertake
studies or  investigations if it believes a hazardous  substance
release has  occurred  or  may occur.  Studies  on the degree and
extent of contamination and potential routes of human exposure to
a hazardous substance  are  generally  determined through preliminary
assessments and may include sampling and testing sediments during
site   investigations.      Section    104   also   allows   for   the
implementation of a short-term removal or long-term remedial action
where hazardous substances have been released or where contaminants
present an  imminent and substantial danger to  public health and
welfare.   Under Section 105,  the National Contingency Plan for the
response to and the removal of oil and hazardous substance releases
will be  revised and  republished.    Under  the same  section,  the
Hazardous Ranking System  (HRS)  is  revised in  order to accurately
reflect the relative degree of risk hazardous sites pose to human
health and the environment.  Authority under Section 106 allows for
the  abatement of imminent  danger  and  penalties for  failing  to
respond  to  such  a  request.    Section  107   allows  the  Federal
Government to establish liability for the cleanup costs and natural
resource  damages,   allowing  for  cost  recovery.    Section  121
establishes cleanup standards and evaluation criteria for remedial
alternatives  and  establishes a  preference for  remedial actions
where treatment permanently and significantly reduces the volume,
toxicity, or mobility of hazardous substances.

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The   following   section  highlights   several   CERCLA   sediment
remediations in Region V.  Both emergency and remedial actions are
included.

l) Cast Forae - Hovel1. Michigan

The  Cast Forge  Steel  Company  of  Howell,  Michigan,  used  PCB-
containing oils  in  their  die-casting process from  1969  to 1972.
PCB  use  was discontinued  after this  date but  residual amounts
remained in their equipment until 1976, at which time the equipment
was  flushed in  order  to eliminate  the  PCB component of  the
company's oily waste.   These oily wastes  were stored  in unlined
evaporative  lagoons which  would  occasionally   overflow into  a
drainage ditch  which discharged directly  into  the  South Branch
Shiawassee River. Information for this site is taken from the 1991
Draft Remedial Investigation Report.

The  contamination problem  was  defined by  Michigan  Department of
Natural Resources (MDNR) surveys in  1974 and  1977.  Widespread PCB
contamination of the river was found downstream from Howell.  Fish
populations in this stretch  showed elevated PCB  levels  as well.
PCB  levels  in  river sediments exhibited high concentrations for
10.5 miles downstream from Howell, with the greatest concentration
of hotspots located in the first mile downstream of  Cast Forge.
PCB concentrations were found up to 4,800 ppm.

In 1978,  Cast Forge  signed a  Consent Agreement to  spend $75,000 on
the  evaluation   and cleanup of  the  one  mile  stretch  directly
downstream.    In June,   1981,  a   final   Consent  Judgement  was
promulgated between Cast  Forge and the  State of Michigan which
included  removal   of  contaminated   sediment   to  reduce   PCB
contamination  to less than 10  ppm  within the 8  mile  reach
downstream of Cast Forge.  Cast Forge  was required to pay $750,000
on the river cleanup alone.

The cleanup was accomplished by the end of 1982.   River sediments
were  removed by  dragline  or hydrovacuuming.  Vacuumed materials
were dewatered and disposed of in a secure landfill permitted for
PCB-containing wastes.   An  estimated 2,531  pounds of PCBs  were
removed,  contained in approximately 1805  yd3 of river sediment and
500  yd3 of  sand  and gravel  (used  for onsite treatment) .   Solid
wastes were separated by PCB concentrations (greater or less than
50 ppm) and disposed of in the appropriate landfills.

Despite the amount of material removed, the cleanup fell short of
MDNR  expectations.     A greater  extent   of  contamination  than
initially anticipated,  coupled  with low cost estimates  and cost
overruns, resulted  in the cleanup of  only  1.5 river miles rather
than the 8 originally planned.

In 1981,  Cast Forge sold the property to Kelsy-Hayes/Western Wheel,

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a manufacturer of aluminum tires for the automotive industry.  In
September,  1983,  under the  CERCLA,  the South  Branch Shiawassee
River was determined to be an uncontrolled hazardous waste site and
was put  on  the  NPL list of Superfund sites.  MDNR  functioned as
the    lead    agency   in   performing   the    CERCLA   Remedial
Investigation/Feasibility  Study  (RI/FS)  for  the site.   Studies
through  1986  of  PCB accumulation in fish species on  the  10 mile
reach below the facility indicated levels in excess of 2 ppm, the
Food  and Drug Administration's recommended limit.   The Remedial
Investigation began in 1986 principally to characterize the extent
of the PCB  contamination  in the  previously remediated section of
the river as well as 8 miles downstream of this area.  The draft RI
was completed in January 1991 and found high PCB concentrations
downstream  of  the  previously  remediated  area.    Average  PCB
concentrations were at 1.2 ppm and reached a maximum concentration
of 7.2  ppm.  PCB levels  in  the previously remediated  1.5 mile
stretch  were  at  levels  above the 10 ppm cleanup criteria  of the
1982 remediation.  Additional  investigations will be needed for the
final RI.

The completion of the RI will be followed by the performance of a
Feasibility Study  (FS).   Potential  remedial alternatives will be
developed and evaluated and will lead to a selection of a remedy.

2) Crab Orchard National Wildlife Refuge - Carterville, Illinois

Crab  Orchard National  Wildlife Refuge  is  located  in  southern
Illinois  near the city of  Carterville.   The refuge  consists of
approximately 43,000 acres of multiple-use  land.  The land is used
as a  wildlife refuge  and  also for  recreational,  agricultural and
industrial  purposes.   It  is owned by the U.S.  Government  and is
currently  administered by the  U.S.  Fish  and  Wildlife  Service
(USFWS),  a  Bureau of  the Department of the Interior  (DOI).  The
Refuge was  previously administered by the  Department  of Defense
(DOD)  during  which  times portions  were   leased  to  industrial
tenants,  primarily for the  purpose  of munitions  and explosives
manufacturing.  Information for this  site is taken from the Record
of Decision.

After  World War  II  the DOD  transferred the  Refuge to  the DOI.
Other  industries moved in  to occupy the buildings.   Explosives
continued  to be  manufactured as  well as  PCB  transformers and
capacitors, automobile parts, fiberglass boats, corrugated boxes,
plated metal  parts, tape,  flares and jet engine starters.

The law  that  created  the  Refuge mandated a continuing industrial
presence  as  well  as   agriculture,   recreation,   and  wildlife
conservation.  Industrial development was deemed  essential for the
viability of  the Refuge.

Disposal activities at the site included dumping  of waste material
in unused areas,  and  landfilling  of waste materials  in unlined

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landfills which were  covered  with earth.  Liquids  may also have
been disposed to surface water  bodies  and impoundments.   No good
estimates exist for total volume of disposed material.

The site was proposed for the  NPL in  1984  and finalized on the NPL
in July  1987.   The relative roles and  responsibilities  of other
Federal  Agencies and the United  States  Environmental Protection
Agency  (USEPA)  at  Federal  Facilities like Crab  Orchard National
Wildlife  Refuge are  prescribed  in  Section  120  of CERCLA  and
Executive Order Number  12580.   DOI  and DOD are  responsible for
remedial action and compliance with CERCLA, as amended.  The USEPA
is responsible for providing  assistance  and  oversight to DOI and
for final remedy selection.

In February,  1986,  the  USEPA and USFWS  entered into  a Federal
Facility  Initial   Compliance  Agreement,  which   required  the
performance of an RI/FS.   The USFWS,  in conjunction with Sangamo
Weston,  Inc., a PRP at the  site,  began  an RI/FS  in May 1986.   In
August 1989, the FS and proposed plans for the first two operable
units were  made public.    Based on the  FS,  the USEPA  reached a
Record of Decision for final remedy selection at the two operable
units.

An  Interagency  Agreement   (IAG),  pursuant  to  CERCLA  Section
120(e)(2) is currently being  negotiated  between  USEPA,  DOI, DOD,
and the  Illinois Environmental Protection Agency (IEPA).  The IAG
delineates Agency roles and responsibilities  for the site cleanup.

In July 1989,  DOI issued  letters pursuant  to CERCLA Section 104(e)
in an attempt to identify other PRPs and to help characterize the
extent and type of  contaminants at the Refuge.

The conclusions reached in  the ROD follow.

Metals Area Operable Unit

Three distinct sites  contain  soil and  sediment contaminated with
the following metals and their highest concentrations:

     - Cadmium    780 ppm
     - Chromium   889 ppm
     - Cyanide    392 ppm
     - Lead       166 ppm

Cadmium is the most prevalent  contaminant and is the most toxic to
fish.  Approximately 5,200  yd3 of sediment are contaminated.  The
selected remedy will include:

     - Excavation of contaminated soil and sediment;

     - Treatment by stabilization/fixation of all excavated soil

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       and sediment with metals that are considered RCRA hazardous
       because of EP Toxicity to render non-hazardous;

     - Onsite disposal of non-RCRA hazardous stabilized/fixed
       material and untreated residues exceeding the clean up
       targets in a landfill meeting requirements of RCRA
       subtitle D and 35 Illinois Administrative Code Part 807;

     - A cleanup level of less than 10 ppm will be reached for
       cadmium.  Achieving this cleanup level will have the
       associated result of excavating the other contaminants.
       If this requirement  is  not met,  additional sediment
       remediation will be required;

     - Environmental monitoring during and after remedial
       construction to ensure effectiveness of the remedial action.

PCS Area Operable Unit

Four  distinct  sites  contain  soil  and  sediment  contaminated
primarily with PCBs (up to 88,000 ppm in sediments)  and lead (up to
20,500  ppm).    Approximately 1,200  yd3 are  contaminated.    The
selected remedy will include:

     - Excavation of all contaminated soil and sediment;

     - Treatment of excavated materials contaminated with PCBs
       in excess of established remediation goals using mobile
       incineration technology, or in situ vitrification (ISV)
       technology, if a demonstration is made that ISV can meet
       or exceed the performance standards established for
       incinerator technology;

     - Cleanup levels of PCBs at less than 0.5 ppm dry weight and
       for lead at less than 450 ppm dry weight. If this require-
       ment is not met, additional sediment remediation will be
       required;

     - Stabilization/fixation of residues from incineration and
       non-incinerated soil and sediment contaminated with metals
        (if determined to be RCRA hazardous because of their metal
       leachability), to render them non-hazardous;

     - Onsite disposal as per Metal Area Operable Unit;

     - Backfilling, placement of low-permeability caps and
       closure of areas where contamination is below the
       excavation criteria or from where contaminated soil
       and sediment have been evacuated;

     - Environmental monitoring and maintenance during and

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       after remedial construction to ensure the effectiveness
       of the remedial action.

3) Davton Tire and Rubber Company - Dayton, Ohio

The Dayton Tire and Rubber Company  site is  located in Dayton, Ohio
on Wolf Creek,  1.25 miles upstream of its confluence with the Great
Miami River, which discharges to the Ohio River.  Dayton Tire was
a subdivision of Firestone Tire  and Rubber Company,  and operated
the facility from the early 1940s until October of 1980, when plant
operations ceased.   From 1981 to 1987,  the  site was vandalized.
Capacitors and transformers were scavenged for  copper, leading to
oil spills and leaks.

On April 3,  1987,  an oil sheen was reported on Wolf Creek.   The
Ohio Environmental Protection Agency (OEPA) responded to the spill
and determined that approximately 1,600 gallons of PCB-contaminated
oil were released into Wolf Creek,  with  concentrations in the oil
as  high as  22,900  ppm.   OEPA  requested  USEPA  assistance  in
containing and cleaning up the spill.

The USEPA Superfund Emergency Response Branch conducted an initial
site inspection on April 4 and identified electrical transformers
and large capacitors with numerous oil spills and leaks.  Ash and
debris  from  fires were  also noted.  Unknown  liquid wastes  and
asbestos-wrapped pipes and boilers were also present.  Soil, water,
and  sediment samples were  taken.    Wolf  Creek sediment  samples
collected at the site discharge pipe revealed PCB contamination as
high as 6,020 ppm.   PCB contamination was also  found in the water
and soils.   Dioxin and  furan  were  found  in specific areas due to
the incomplete combustion of PCBs.

Fish sample results from specimens  collected  on Wolf  Creek and the
Great Miami River by OEPA showed  PCB levels ranging from 0.3 to 18
ppm, above the FDA's 2 ppm recommended limit for human consumption.
A public  advisory  was issued on May 8  to abstain  from fishing,
swimming, or participating  in water activities in the contaminated
areas of Wolf Creek and the Great Miami  River.

Further stream surveys conducted  between the  site and the mouth of
Wolf Creek revealed that PCBs existed in  Wolf  Creek sediments at
concentrations up to  1,140  ppm.   On June  2, 1987,  the immediate
removal of the contaminated sediments were recommended.

The USEPA initiated actions to stabilize the hazardous conditions
at the  site  and  to prevent additional releases.  Phase  I of the
clean up consisted of a USEPA/OEPA  joint effort to contain the oil
spills and secure the site.  The site's drainage was intercepted in
order to eliminate  further  contamination of Wolf Creek and site
security was provided on a continuous basis to eliminate any future
vandalism.   From July  28  through  August 5,  1987,  contaminated
sediments were  removed from Wolf  Creek,  downstream of  the site

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where concentrations were at or greater than 25 ppm.  If some areas
were deemed high contact areas, the USEPA onsite Coordinator could
authorize removal of sediments at greater than or equal to 10 ppm.
The sediments were containerized  onsite and eventually disposed of
offsite at a licensed hazardous waste landfill.  Approximately 201
yd3 of sediments  were  excavated  and disposed  of in  this manner.
Sediments  were tested  during removal  to  confirm that cleanup
standards were being met.

Further  remedial   activities  were  needed   to  clean  up  soil
contamination at the site.

4) Fields Brook - Ashtabula,  Ohio

The Fields  Brook  Superfund site  is  in  the city and  Township of
Ashtabula  in  northeastern Ohio.    Various  point  and  nonpoint
industrial sources are believed to have contaminated sediments in
the brook with a variety of organic and heavy metal pollutants.
The Ashtabula River has been declared an Area of Concern (AOC) by
the IJC.  It is important to emphasize that the Ashtabula River is
not part of the Fields Brook Superfund Site at this time.

Analysis of fish  tissue  caught in Fields  Brook and the Ashtabula
River prior to 1982 indicated the presence of chlorinated organic
compounds.    A health  advisory   was  issued  on March  1,  1983,
recommending  that people not eat fish  in a  2-mile reach  of the
Ashtabula River.  Because of the possibility of direct contact with
the  sediment, movement  of the  contaminated  sediment  into  the
Ashtabula River,  and  the possibility  of  uncontrolled releases of
hazardous materials from the sediment entering the water  supply of
the City of Ashtabula,  Fields Brook was included by USEPA  in August
1983  on  the  NPL  list  of uncontrolled  hazardous waste  sites.
Placement on  this list makes a  site eligible for  remedial funds
under Superfund (CERCLA).

A CERCLA RI/FS was conducted between 1983 and 1986 by USEPA.  The
FS recommended:

     - Excavation and dewatering of contaminated sediments;

     - Incineration of approximately, 8,000 yd3 of
       contaminated sediments containing organic contaminants
       with higher mobility and the highest ingestion risk, and
       approximately 8,000 yd3 of contaminated sediments containing
       greater than 50 ppm PCBs;

     - Solidification of approximately 25,000 yd3 of
       contaminated sediments containing relatively immobile
       contaminants and potentially the solidification of the
       incinerator  ash if  it is required to be handled as a
       hazardous  waste;


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     - Construction of a new onsite RCRA/TSCA-type landfill;

     - Treatment of water generated during dewatering of
       contaminated sediments,  during the solidification
       process, thermal treatment or during temporary storage.

The ROD followed the above FS recommendations.

In  April  1989,  a  Unilateral  Administrative  Order  was  issued
requiring  the  PRPs,  collectively and individually,  to  undertake
remedial design and pre-design  activities of the Sediment Operable
Unit,  and  a  Source  Control  RI/FS.   USEPA would rescind  this
Administrative Order with respect to any PRP which signed a Consent
Decree for the overall remedial action to be taken at the site, as
detailed in the  1986 ROD.   After eliminating  companies  who were
taken over, merged,  bought out, and gone  bankrupt only 19 companies
were named as PRPs.

In 1991,  the Solvent Extraction Process,  a new technology developed
since the 1986 ROD, was offered by the complying PRPs as a quicker,
cheaper way to treat PCB-contaminated sediments.   Besides these
potential advantages, the Solvent  Extraction Process may be viewed
as  more  publicly  acceptable  than incineration.   The USEPA has
completed  review of  bench  scale  test  results  of this  process
however many concerns still  need to be addressed in regards to the
applicability  of  solvent extraction as an  appropriate  treatment
technology for the contaminated sediments of Fields Brook.

As  of  July 1991,  the PRPS  had  completed  first phase  sediment
sampling.  The results have been submitted but  not interpreted.
The  design   investigation   is   ongoing.     No   agreement  for
implementation of remedial action  has been reached with any of the
PRPs.

The Ashtabula River navigation channel has not been dredged since
1962 and water depths have become  critical to recreational as well
as commercial  navigation.  Contaminated sediments due to pollutants
originating from the Fields Brook Superfund site have impeded the
dredging process and the disposal of the dredge spoils.   Chemical
analysis of  sediment  core  samples  collected  in 1982  indicate
sediment in the Ashtabula River in the vicinity  of Fields Brook may
need to be regulated under TSCA because of the presence of PCBs at
concentrations  greater  than   50  ppm.    Remediation   of  the
contaminated sediments in Fields Brook will help reduce contaminant
loading to the Ashtabula River AOC.

5) Moss-American - Milwaukee county* Wisconsin

The Moss-American site includes the  former  location of  the Moss-
American creosoting  facility,  five miles of  the  Little  Menomonee
River,  and the adjacent  floodplain soils.   It is  located in the
northwestern   section  of  the city  of   Milwaukee,   Wisconsin.

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Information on this  site  is from the 1990 ROD  and from personal
communications.

Beginning  in  1921,  a wood  preserving facility  was established,
using a 50/50 mixture of  creosote and number 6  fuel  oil.   Kerr-
McGee purchased the facility in 1963  and changed  the name to Moss-
American.   The name  changed  again in 1974  to Kerr-McGee Chemical
Corporation—Forest Products Division.

From 1921  to 1971, the facility discharged wastes  to settling ponds
that ultimately discharged into the Little Menomonee River.  These
discharges ceased in 1971  when,  in response to a City of Milwaukee
order, Moss-American diverted  its process water  discharge to the
Milwaukee  sanitary sewerage  system.   Also in 1971, WDNR ordered
Kerr-McGee to clean eight settling ponds and dredge 1700 feet of
the  river after  creosote  contamination   was discovered.    The
settling ponds were filled with clean soil,  the discharge pipe to
the river  was  removed,  and  a  twelve foot deep  underground clay
retaining wall constructed between the ponds and the river.

In 1973, the USEPA financed the  dredging of approximately 5,000
feet  of the river,  storing  most of  the  creosote contaminated
sediments in an onsite landfill.

In 1974, the USEPA  (under the Clean Water Act) and Milwaukee County
filed a complaint seeking an injunction against Kerr-McGee Chemical
Corporation,  and to recover costs incurred for studies and cleanup.
While this suit was pending, the facility closed  in  1976.  In 1978,
the lawsuit was dismissed due to the discovery of inconsistencies
in some data collected.  Milwaukee County reached  a settlement with
Kerr-McGee in which  it  received a major portion of the property
which was  added  to the existing  county  park corridor  along the
river.

Based on soil/sediment contamination and water quality studies done
by USEPA  and  other agencies  from 1970 to 1980  indicating gross
creosote  contamination,   the  site was  placed  on  the  NPL  list
pursuant to CERCLA.  Letters were sent to  three PRPs to take part
in a CERCLA RI/FS,  but all three declined.  The RI/FS was therefore
funded by the Superfund program and was completed in May 1990.

The ROD, based  on  the RI/FS,  addresses remedial actions for the
principal threat to human health and the environment from direct or
indirect exposure contaminants present at the site.  These actions
focus on variety of media:  onsite soil, groundwater, surface water
of the Little Menomonee River, and sediments of the river.

Contaminants detected in the sediments were primarily carcinogenic
polynuclear  aromatic   hydrocarbons   (CPAHs),   similar  to  the
contamination found  in the  soils.  Sediment  contamination was at
approximately  18  ppm  CPAHs,  which  exceeded background levels.
These sediments were  found fairly evenly distributed throughout the

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five mile reach of the river  between  the Site and its confluence
with the Menomonee River.   CPAH  levels were as high as 500 ppm and
total PAH  levels  were as  high  as 5900  ppm.   To  remediate this
situation,  the ROD recommends:

     - Construction of a new channel for the Little Menomonee
       River;

     - Removal and treatment of highly contaminated sediment from
       the old channel.
Sediments in Reaches to be Rerouted

1) Remove all visibly contaminated sediment from the old reach of
   the river and any sediments containing greater than 388 ppm
   total CPAHs.  Dredging technique to be determined.

2) Treat the removed sediment to at least 6.1 ppm CPAHs using the
   slurry bioreactor process or an alternative as selected by
   USEPA.

3) Place treated sediment on the former facility grounds, cover
   with a soil cover, and maintain cover for thirty years.

4) Cover sediment containing less than 388 ppm total CPAHs in place
   with soil removed from the new channel.

Sediments in Reaches Not to be Rerouted

1) Remove sediment containing total PAH concentrations in excess
   of WDNR Sediment Quality Criteria (SQC) of 3 ppm CPAHs or
   background, whichever is greater.  Background levels to be
   determined.

2) Sediments in excess of 6.1 ppm total CPAHs treated by slurry
   bioreactor process and disposed of as above.

3) Deposit removed sediments containing less than 6.1 ppm total
   CPAHs in old stream reaches of the river.

Soil in New Little Menomonee River Channel

1) Remove soil containing total CPAH concentrations greater than
   SQC or sediment background, whichever is greater.

2) Treat soil in excess of 6.1 ppm total CPAHs or background,
   whichever is greater, using slurry bioreactor method to at least
   6.1 ppm total CPAHs.

3) Dispose of onsite as per above.

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4)  Cover removed soil at less than 6.1 ppm total CPAHs in old
   reaches of the river.

The river corridor will  have habitat, wetlands and woodlands areas
restored.  Approximately 5,200 yd3 of contaminated sediments will
be removed.

The above remedial steps minimize the effects of the contaminants
on human  health and the  environment,  and minimize  migration of
contaminants downstream to the Menomonee River and, ultimately, to
the Milwaukee AOC.

The USEPA has reached an agreement with Kerr-McGee to do the work
outlined in  the ROD and  the Statement of Work (SOW), which is used
to implement the ROD.  A Consent Decree was signed by Kerr-McGee in
1991 and awaits  DOJ signature and  lodging.   It  is hoped that the
Consent Decree will be lodged in 1991 and that work will begin as
soon after as  feasible.   According to the 1990 ROD,  the cleanup
should take  3-4 years at a cost estimated to exceed $25M.  The PRPs
have already begun some of the pre-design work.

6)  PR Mallory - Cravfordsville,  Indiana

The  PR Mallory site  in  Crawfordsville,  Indiana,  manufactured
capacitors from  1957 to 1969.   The facility was totally destroyed
by a fire in 1970 after  which the company abandoned the operation.
The company  has since been purchased  by  Duracell International,
Inc.

The site was initially  investigated  by the  Indiana Department of
Environmental Management (IDEM) in 1985 and 1986.  Partially buried
capacitors were observed in a ravine that leads into Little Sugar
Creek, and also  lying on the ground surface adjacent to the site.
Concentrations  of  PCBs  in the oil inside the capacitors were as
high as 100%.

The USEPA conducted a site assessment in April 1986  \nd found PCB
concentrations up to 165,402 ppm in the soil and 9,635 ppm in the
ravine sediments.  Based on the potential threat to public health
resulting from these concentrations,  the USEPA issued  a CERCLA
Administrative  Order in June  1986  to Duracell  International, the
successor to PR Mallory,  and to the current owners  of the site,
that  response  action   be  undertaken  to eliminate  the  threat.
Duracell agreed to undertake the work ordered  in the Administrative
Order.

The cleanup started in December  1986.   Ravine sediments were to be
remediated to 25 ppm PCBs.  Sediment sampling in the ravine found
PCB  levels  upstream of the site  from non-detectable  levels to
23,000 ppm.   The  highest concentrations were  found immediately
upstream of  the site.  A sample downstream exhibited a level of 390


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ppm.  Contaminant migration through the ravine was controlled by a
series of  sediment  traps and oil-absorbent booms.   The sediment
traps were constructed to  encompass  the  full  width of the stream
bed where possible.   Each  sediment trap  was constructed by first
excavating a shallow trench, laying a sheet of filter fabric over
the  excavation,  and  anchoring  hay  bales  in these  excavations.
Excavated sediments were dewatered or stabilized in place prior to
placement in an interim storage  facility  constructed onsite.  Upon
completion of the sediment removal, sediment traps were removed and
placed in the interim storage facility.   The excavated ravine was
backfilled with  clean  fill,  regraded to  promote drainage,  and
revegetated.   Contaminated  soil removals also took place and the
material was placed in the interim storage facility.   Dioxin and
furan, resulting from the incomplete  combustion of PCBs, were also
found in the soil.

The final phases  of the  cleanup began in 1990.   The contaminated
soils and sediments were removed to a hazardous  waste landfill in
Emelle, Alabama.   As of June 1990,  60,000 yd3 of contaminated soil
and  sediment had been  removed at a cost of approximately  $28
million.    Excavation  under a manufacturing facility  next  to the
site was still to be completed.

In June 1991, sediment sampling took place  on Little Sugar Creek,
downstream of the  excavated ravine, to  determine  if any  PCB
contamination was present.  The results  of  this  sampling have not
been completed.

7) Tecumseh Products Company - Lower Sheboyaan River, Wisconsin

The  Lower  Sheboygan  River  and  Harbor Area of Concern involves
approximately 14  miles of the river upstream from its mouth and the
entire  Sheboygan Harbor.    Primary  problems  include  fish  and
sediments contaminated with PCBs and  a fish consumption advisory.

The Federal Channel within the Sheboygan River and Harbor AOC was
dredged annually and the spoils were deposited in offshore waters
of Lake Michigan  by the USAGE from the early 1950s until 1969, when
it was discontinued due to sediment contamination by pollutants and
heavy metals.   The USAGE  proposed a confined disposal facility
(CDF) to accommodate future dredged materials but this idea was put
on hold due to elevated concentrations of contaminants.   The site
was proposed for  the  NPL of  Superfund in September 1985,  and was
finalized in  June 1986.  Prior to beginning  any work, the Office of
Superfund contacted PRPs and asked for their participation in the
RI/FS phase of the cleanup.  As a result, an Administrative Order
was  agreed  to  by USEPA,  the  Wisconsin  Department of  Natural
Resources  (WNDR),  and Tecumseh  Products  Company,  one of  three
identified PRPs,  in April 1986.

By  the  terms  of the  Administrative Order,  Tecumseh  agreed  to


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conduct an RI/FS whose objective was to characterize the nature and
extent  of the  problem,  and  identify  and evaluate  alternative
remedial actions to address the problem.  The RI showed that site
sediments were contaminated  with PCBs, chromium, cadmium,  lead,
mercury, zinc,  and nickel, with PCB concentrations as high as 4,500
ppm.

Tecumseh also agreed to  conduct  an Alternative Specific Remedial
Investigation (ASRI).   This phase of the project will expedite the
clean-up  of  contaminated  sediments  in  the  Sheboygan River  by
providing  information   regarding  various  emerging   innovative
technologies  for  the  treatment  of  PCB-contaminated  sediments.
Tasks to be performed are as follow:

1) The removal of approximately 2,700 yd3  of PCB-contaminated
   sediments from the Sheboygan River and their placement in a
   confined treatment facility (CTF).   During dredging of this
   material,  silt curtains were used to minimize movement of
   sediments into other parts of the river.  The CTF will be used
   to study enhanced natural biodegradation for the  treatment of
   PCB-contaminated sediments with contamination levels from 640-
   4500 ppm.   Dredging was completed in the fall of  1990.

2) An in-situ sediment  armoring pilot  study in which approximately
   13,500 square feet of contaminated river sediments would be
   capped in order to minimize the resuspension of contaminated
   sediments.  The armoring was completed in June 1990.

3) Bench-scale treatability studies of various remedial methods,
   including PCB extraction,  chemical fixation, armoring,
   supplemental biodegradation,  and dewatering.  These
   studies are currently being undertaken.

4) An evaluation of sediment removal technologies and sediment
   control devices.  This evaluation has been completed and
   the results will be issued as part of the Feasibility Study.

5) A comprehensive monitoring program to assess the effectiveness
   of the above mentioned methods.  This will be ongoing until the
   project is completed.

The  work done during  the  ASRI will  enhance the quality  of the
Feasibility Study for the entire river and harbor cleanup, and as
a noteworthy side benefit,  has resulted in the  removal of the most
highly   contaminated   sediments   much  earlier  than   the  final
remediation action would otherwise had.

Tecumseh is undertaking the second phase of the cleanup during the
Summer  of  1991 under a  Removal  Action Consent Agreement entered
into in the Fall of 1990.  The action will involve the removal of
approximately  2,500  yd3 of  PCB-contaminated  sediments  from the


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upper Sheboygan River where it flows through the Village of Kohler.
PCB concentrations range  from 410 to 1,100 ppm.  The sediments will
be removed to a depth at least 6  inches below previously identified
PCB contamination.  A modified  clamshell bucket will be used and
silt curtains will be placed around  the dredge site to contain re-
suspended sediments.  The dredged material  will  be  stored for an
interim period  in a 600,000-gallon tank  recently constructed on
Tecumseh  property,  where  it  will  be  managed  according to  all
applicable State and Federal regulations.  The tank is equipped with
a leak  detection system.   These  sediments will be  removed  for
final treatment  and disposal  as determined in the ROD.   The  ROD
will be based on the ASRI evaluations,  the Feasibility Study,  and
public comment on the recommended remedial action  to be undertaken.
The  final ASRI  report   is expected in  late 1992  with the  ROD
anticipated in 1993.

8) Outboard Marine Corporation - Waukeaan. Illinois

The Waukegan Harbor Superfund  site in Waukegan, Illinois is within
an  International Joint  Commission Area  of  Concern.    Sediment
remediation of this site represents a  long,  protracted  period of
negotiations and  actions taken  to effect  the remediation of PCB-
contaminated  sediments   and   to reduce   PCB  loading  into  Lake
Michigan.

The  Illinois  Environmental  Protection Agency conducted effluent
sampling  of  outfalls on Lake  Michigan   to  attempt to  identify
sources of  PCB  contamination.   In January 1976,  samples  taken
during 1975 at outfalls at the Outboard Motor Corporation (OMC) of
Waukegan,   Illinois were found  to be contaminated  with  PCBs,
discharging at a rate of  9 to  10 pounds of PCBs per day.   Prior to
this discovery,  in  June  1975, an NPDES permit had been  issued to
OMC.  The PCB component  of the  discharge  was not reported in  the
application and consequently no limits were imposed  for  PCBs.

From  approximately 1959 to  1972,  OMC,  a  recreational  marine
products manufacturer,  purchased hydraulic  fluid containing PCBs
that was used in  die-casting machines.   Some of  the PCBs escaped
from  the  oil interceptor, diversion  and pump  system,   and were
released.   The PCBs were  discharged  from two  locations, one at the
western end of Slip 3  at the northern  end of Waukegan Harbor,  and
one at the north end of OMC property to the North Ditch which runs
directly into Lake Michigan.   The discharge pipe to the harbor was
sealed in  1976 but not before large  amounts of PCBs were discharged
into Waukegan Harbor (approx.  300,000 pounds) and on OMC property,
including the  North Ditch/Oval  Lagoon/Crescent  Ditch  area,  the
parking   lot,   and  Slip  3   (approx.   700,000  pounds).     PCB
concentrations in some  areas  are over 25,000  ppm.   It  was also
estimated that  hundreds  of  thousands  of  pounds  of  PCBs migrated
into Lake Michigan.

In  February  1976,  following  the discovery of these  discharges,

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USEPA  and  IEPA  issued  an Administrative  Enforcement Order  for
Compliance with Section  309 of the CWA.  This order required OMC to
eliminate PCB discharges from all of  its outfalls  and to monitor
sediments in order to indicate the nature of the PCB contamination
in the harbor and North Ditch area.   OMC took rapid steps to reduce
PCB contamination  at the outfalls  but negotiations  in regard to
sediments were not as successful.   The USEPA  also  requested that
the US Army Corps of  Engineers (USAGE)  forego maintenance dredging
of Waukegan  Harbor,  pending the  results of  a survey of  harbor
sediments by USEPA.

OMC and USEPA continued  sampling and  negotiations  on eliminating
PCB discharges.   In  1976,  OMC  declined to  act on  any  sediment
removals.  During this year,  the Toxic Substances Control Act was
enacted by Congress,  banning the manufacturing of PCBs except for
use in closed systems and charging USEPA to regulate PCB disposal.

In early 1978, USEPA and OMC negotiations concerning responsibility
for cleanup  of  the Harbor  and  Ditch broke down.   In response,  a
suit was filed on  March  17,  1978 against OMC  on behalf of USEPA.
The suit requested that OMC dispose of the North Ditch soils in a
safe manner  and  dredge  and  dispose  of the  contaminated  Harbor
sediments.   While the suit was being fought by  OMC, USEPA continued
to monitor  and  survey  the  site  to  assess  the  extent of  the
contamination.

In 1979, a Regional Response Team (RRT), an interagency  regional
planning body,  determined  that a  remedial  action  was  necessary
pursuant to  the  emergency  provisions of Section 311  of  the CWA.
The RRT recommended that a bypass be constructed around the North
Ditch  but   during preparation  for  construction,   new  areas  of
substantial PCB contamination were found, postponing construction.
In September 1980, a special Congressional  appropriation of $1.5
million was  put into the  USEPA budget to  begin the  cleanup of
Waukegan Harbor.  In October 1980,  the RRT was again convened and
determined that  a  limited remedial  action was still necessary to
abate the ongoing uncontrolled release of PCBs from the sediments
to Waukegan Harbor and Lake  Michigan.   The  RRT began to evaluate
alternatives for  the remediation and  determined that dredging of
the northern-most  areas  of the  Harbor should  be undertaken where
sediments were contaminated at concentrations  greater than 10 ppm.

Also  during  1980,  the  Comprehensive  Environmental  Response,
Compensation, and Liability Act  (CERCLA/Superfund) was passed.  It
authorized  $1.6  billion for five years to  pay for  the  costs of
cleanup of hazardous substances released into the environment and
allowed for the recovery of cleanup costs from the PRPs.  While the
RRT viewed the act as a  potential source of funds for the proposed
Section 311  emergency cleanup,  CERCLA was to play  a much bigger
role.   Studies and litigation continued under the auspices of the
CWA.   However, with the passage  of CERCLA, the site began to shift
into  Superfund  mode.   CERCLA  gave the USEPA broader  and more

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substantial powers to conduct cleanups.  The site was proposed for
and put  on  the NPL  list of  Superfund.   This move  initiated the
cleanup  mechanisms  of  Superfund  and  led  to  a  new  type  of
enforcement action at the site.  The process included conducting an
RI/FS followed by  a  Record of Decision which selects  a remedial
alternative based on  the RI/FS.  Investigations conducted up until
1984 under the CWA were used as the Remedial Investigation phase of
the CERCLA process.

In 1983,  a preliminary recommendation was made by USEPA use Slip 3,
the location of Larsen Marina,  as  a disposal facility.  This would
have effectively forced Larsen out of business.  This proposal was
thought to  be  a  more effective means to reduce PCB  loading into
Lake Michigan  than by dredging the slip  and using  an  alternate
disposal  site.    The  slip   and   marina  were  used  for  purely
recreational purposes.  The Superfund remedial  process is open to
public comment and this proposed action was received very poorly,
especially by the recreational users of the  slip.   Due  to public
reaction, this proposed remedy was dropped.

A remedy  was  selected  in  1984 by  the USEPA  which  authorized $21
million for the cleanup program.   The objective of the ROD was to
clean areas  within  the site which contained PCB contamination of 50
ppm or greater.  Three  main  areas of  contamination were targeted
for remediation:  The Upper Harbor and Slip  3; the OMC parking lot;
and the North  Ditch/Crescent  Ditch/Oval Lagoon area.   The remedy
selected consisted of the following elements:

     - Dredging of hotspots (greater than 10,000  ppm) from Slip
       3 and the North Ditch area, dewatering,  fixation and
       transport to an offsite chemical waste facility;

     - Remaining sediments  in Slip 3 would be dredged, dewatered in
       lagoons to be built on OMC property,  and disposed of in a
       containment cell to be constructed above the OMC parking
       lot;

     - The North Ditch area was to be enclosed with slurry walls
       and capped with impermeable clay.

The ROD represented the USEPA's decision on the most cost-effective
cleanup approach.

In 1985,  the USEPA's  original  1978  lawsuit was withdrawn, allowing
for a future  suit  under the provisions of Superfund  in order to
recover government costs  for the  cleanup activity.   Engineering
design work based  on the  ROD began in  1984  but was  suspended in
late 1985 due to litigation between OMC and USEPA regarding OMC's
denial of USEPA access to OMC  property.  Such access was essential
to  continue the design process.    OMC  gained  a  stay on USEPA's
administrative warrant  to  their   property  which  was  eventually
appealed to the U.S.  Supreme Court.

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While this  litigation  was pending before the  courts,  CERCLA was
amended by SARA.  This  Act contained broad authority for access to
implement  Superfund remedial  actions  and  required  the use  of
permanent  treatment technologies. Shortly  after the  passage  of
SARA, OMC  agreed  to end ongoing  litigation with  USEPA over site
access  and   to  begin  negotiations  to  clean  up   the  site.
Negotiations  between OMC,  USEPA,  and IEPA began  in late 1986  to
implement the 1984 ROD but as a result of SARA, the remedy needed
to include the use of onsite technology.  Therefore, components of
the remedy were modified and embodied in a 1988  Consent  Decree.  In
March 1989, the ROD was correspondingly modified and  the Consent
Decree was then entered into the  United States District Court in
April 1989.

By terms  of the  Consent  Decree,  OMC was  to  finance  a  Trust  to
implement the cleanup and to ensure performance  of the requirements
of the Consent Decree.   The Consent Decree outlined the  areas to be
remediated,   the   methods  to   be   used,   and  the   financial
responsibility, both immediate and long-term, for the cleanup.  The
modified remedy required the following steps be  taken sequentially:

1) A slip will  be built on the east side of the Upper Harbor to
   replace Slip 3.  Larsen Marine  will be relocated from Slip 3 to
   this new slip.

2) A double sheet pile cut-off wall will be built to isolate Slip
   3 from the Upper Harbor.  A water-tight clay  slurry wall will be
   anchored to  the underlying clay till  and Slip 3 will become a
   permanent containment cell.

3) 8,000 yd3 of sediment in Slip 3 with PCB concentrations
   above 500 ppm will be removed  and isolated  for treatment.
   Approximately  30,000 yd3 of sediment in the  Upper Harbor
   with PCB concentrations between 50 and 500 ppm will then be
   removed and  placed in the new  Slip 3  containment cell.

4) Two other containment cells will be built with a similar design
   as the Slip  3  containment cell.  One  will encompass the
   parking lot  and  the  other the  Crescent Ditch and Oval Lagoon.
   Before construction, all areas containing PCB contamination
   over 10,000  ppm  will be removed for treatment.  PCB
   concentrations below this heavily contaminated sediment layer
   drop significantly.

5) Material removed from designated hotspots will be treated by a
   low temperature extraction procedure which will remove at least
   97% of the PCBs  by mass.  This will separate the PCB oils from
   the sediments.

6) Extracted PCB oil will be removed  off site for  destruction at a
   TSCA-approved  facility.  The treatment facility has not been


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   selected.

7) Residual treated soil will be placed in the containment cells
   which will be closed and capped.  Extraction wells will be used
   to prevent migration of PCBs from the cells.

8) All water generated during remedial activities will be treated
   on site.

In the Fall of 1989, during pre-design field investigation, addi-
tional  contamination   in  the  form  of   polynuclear  aromatic
hydrocarbons were  discovered in the  soil  area  of the new slip.
PAHs  reflect   coking   and  wood  treating  operations.     This
contamination resulted  from a previous  land use prior  to CMC's
ownership  of  the  property.    The  discovery of  PAHs  required  a
limited investigation in the area of the new slip and resulted in
the removal of PAH-contaminated soils above 5 ppm.  Construction of
the new slip began in October 1990 and as of July 1991 the Slip 3
cutoff wall construction had begun.

The proposed  remedy will  greatly reduce  existing  risks  to  PCB
exposure on  OMC property and  will  improve the water  quality of
Waukegan Harbor and reduce PCB  losses  to Lake Michigan.  Treatment
of PCBs onsite is consistent with the goal of SARA to permanently
reduce  toxicity,   mobility  and  volume  of hazardous  materials.
Dredging should begin in November 1991.

9) Westinghouse Electric Corporation - Bloomington,  Indiana

The Westinghouse Electric  Corporation is  located  in Bloomington,
Indiana.  Up until 1982, it discharged wastewater to the Winston-
Thomas  Sewage   Treatment facility.    In  the  early   1970s,  PCB
contamination was discovered in the effluent of this facility.  The
source  was  determined  to  be the Westinghouse  discharge  to  the
facility.   In the mid-1970s, Westinghouse discontinued the use of
PCBs.   The Winston-Thomas facility was closed in 1982 following the
completion  of   a  new  wastewater  treatment  facility south  of
Bloomington.   Subsequent studies found  high PCB  concentrations
persisted in fish and sediments in streams in the area.  The primary
source of this contamination was determined to  be  five landfills
used by Westinghouse to dispose of  PCB-containing wastes such as
capacitors.  Leachate  from these landfills flowed  into  six area
creeks.

In August,  1985,  after lengthy negotiations,  a CERCLA  Consent
Decree was  signed  between USEPA,  IDEM, the  City of Bloomington,
Monroe County,  and Westinghouse.   Westinghouse agreed to remove
650,000 yd3 of contaminated materials from the landfills and creeks
at the site as well as  at the  contaminated Winston-Thomas Sewage
Facility.   Four of the  sites are on the  NPL list and the cleanup
must be completed within 15 years.


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The  landfills were  all capped  by  1987.    Sediment traps  were
installed to  keep  sediments  from  migrating downstream and stream
water treatment plants were placed on Conard's Branch and Richland
Creek radiating out  from the Neal's Landfill.   The stream water
treatment plant will  treat contaminated stream water at the rate of
1  cubic  foot  per  second  (cfs).   Treated  stream water must  be
treated to PCB concentrations of 1 part per billion  (ppb) as per a
state-issued NPDES permit.  The permit has currently been remanded
back  to  the  State for the  consideration  of more  stringent PCB
limits.

Sediment remediation  was completed by October 1988 (see Tetra Tech,
1989) .  Sections of the creeks were diverted and dewatered in order
to successfully remove sediments  from the  bed  and banks  and  to
reduce the  amount  of water that  would need  to be treated  by the
clarification  system.   After dewatering, bank and bed excavation
took  place.   This  was followed by high-pressure water  to loosen
sediments from the cracks  and crevices of  the bedrock creek bed.
Directly following,  sediments were swept from the  creek  using a
hydrovacuum.  The karst formation and limestone  bottom of some of
the sites resulted in pockets of sediments that  were difficult to
remove.  A total  of 4,620 tons of stream sediments were removed.
This material is being stored in an interim  facility located at the
Winston-Salem STP as  required by the Consent  Decree.  Westinghouse
will  monitor  the  interim waste   facility  until  they  build  an
incinerator  onsite  in  order  to  treat the  removed  material  by
thermal destruction.

Sediment removal appears to have been successful and Westinghouse
will continue to monitor the  effects of the removal.  PCB levels in
Conard's Branch creek water  still exceed  I  ppb  at times  due  to
natural  stream  relocation  around  the  sediment  traps  at  the
headwaters of the creeks leading from the landfills and also due to
limited ability of  the stream water treatment plant (1  cfs).  Final
cleanup  and closure  of these landfills  by  Westinghouse  should
eliminate this problem.

The   USEPA  has  also  issued  a  CERCLA  Section  106  order  to
Westinghouse asking Westinghouse to do sampling and  remediation on
soils and on a drainage disk  that  runs off the site.  Westinghouse
has  submitted a sampling and remedial plan  but  work  has  not yet
begun.


Section II

The Clean Water Act

The  Clean  Water  Act  (1977,  as   amended  in  1987 and  1990)  was
designed  to   restore  the   physical,  chemical,  and  biological
integrity  of  the  nation's navigable waters.    There  are broad,
general requirements under the CWA to  locate waters that are not

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meeting water quality standards and, by extension, waters that have
contaminated sediments.  Section 304 of the CWA also authorizes the
development of criteria which may apply  to  dredging  and dredged
material disposal assessment, source control, and remediation.

The CWA exercises source control  as  the  first step in mitigating
sediment contamination.   Through  the  issuance of NPDES  permits
under authority of Section 402, the USEPA  can  regulate point source
dischargers.  A key  issue in  any contaminated sediment remediation
is  the  linkage  of  downstream  contamination  to  an  upstream
discharger.   Violations of  an NPDES  permit have  led to  civil
penalties   in  the   form   of  monetary   fines   and/or  sediment
remediation.  Section 115 provides the authority to  identify the
location of in-place pollutants with emphasis on toxic pollutants
in harbors  and navigable waterways.   Under Section 404,  the U.S.
Army Corps  of  Engineers,  or an authorized State,  issues permits
regulating  the discharge of  dredged and  fill material into U.S.
waters.  The USEPA has the authority to review the permits prior to
their  issuance.    If the  material  is  considered  contaminated,
dredging may be prevented until an adequate disposal site is found.

Section 309 of the CWA grants federal enforcement authority to the
USEPA over Section 402 and 404 permit violations, particularly if
state actions are judged to be insufficient over a specified time.
This authority plays a very important role in USEPA Region V where
the  six member  States  are  in charge of their respective  402
permitting programs. The threat and/or use of federal enforcement
may be needed to assess penalties and to  ensure compliance with a
discharger's NPDES permit.   Section 309 is seen as a key tool for
present and future contaminated sediment  remedial actions.
                             s
Section 504 authorizes the  USEPA Administrator to bring  suit on
behalf of the United States to restrain any person from discharging
pollution that presents an imminent and substantial endangerment to
human health or livelihood.   From prevention  to identification to
enforcement,  the  CWA  provides  tools  that  can  be  used  for
contaminated  sediment  remediation,  although  none are  designed
specifically for addressing sediments.

The following section details two  Region  V cleanups done under the
authority  of  the   CWA.   While   only  a  few cases  of  sediment
remediations conducted under  the CWA are  mentioned in this report,
the amount  of contaminated sediments  that could be remediated or
could  be agreed  upon to remediate under the CWA  is  very large.
Potential cleanups,  particularly in the Grand  Calumet River/Indiana
Harbor Canal AOC, could  be  in the millions  of cubic  yards.   It
should  be   noted that  several  USEPA Clean Water  Actions  are
currently being pursued in Region V.


1) uss Gary Works -  Gary.  Indiana
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The USS  Gary  Works site  in  northwest Indiana is  located in the
Grand Calumet  River/Indiana Harbor Canal (GCR/IHC) Area of Concern.
It is positioned at the headwaters  of  the east branch of the Grand
Calumet River and is the first major discharger on this branch of
the Grand Calumet River.  It  is  responsible  for  60% of the total
flow of the  River into Lake Michigan.  The plant uses Lake Michigan
waters for steel production and discharges process waters  into the
river under an NPDES permit,  pursuant to the CWA.

The USEPA  filed a  complaint  against USS  in October  1988 under
Section 309 of the CWA which grants federal enforcement authority
to the USEPA  over Section 402 NPDES permit  violations.   The suit
claimed  that  USS was violating  the terms  and conditions of its
NPDES permit.   The complaint listed violations in the areas of:

     - Reporting;

     - NPDES Permit limits;

     - Unreported spills;

     - Unauthorized discharges of process waters;

     - Unauthorized discharge points.

Evidence of  these violations included Grand Calumet River sediments
contaminated  with a variety  of pollutants  including  PAHs, heavy
metals, oil, and grease.

In order to resolve the allegations listed in the 1988 complaint,
USS entered into a Consent Decree with the USEPA in October 1990.
The Consent Decree called for USS to;

     - Pay a  $1.6 million fine;

     - Install $24 million worth of in plant pollution control
       and abatement equipment;

     - Spend  $7.5 million on Grand Calumet River studies and
       remediations.

The first portion of GCR activities to be accomplished by  USS will
be  a  $2.5  million  Sediment  Characterization  Plan (SCP),  to be
completed by  12/31/91, in order to identify the extent and nature
of the pollution in  the Grand Calumet River  sediments for the first
12  miles of  the river.   Sampling of river  sediments  will be
reflective  of the  locations  of the outfalls at USS and at fixed
points further downstream.  Attempts  will  be made  to analyze the
history of discharges at each outfall.

The SCP should be the most definitive sediment study of the River
to date.  USEPA, the State,  and other dischargers along the River

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will use the data collected  for their own GCR sediment remediation
work and development of the Remedial Action Plan.  The USS SCP will
quantify and qualify the  contaminants in the sediments and will be
used by USS to develop a Sediment Remediation Plan (SRP).

The SRP will focus on sediment remedial action alternatives in the
first five  miles of the river from the culvert upstream  of USS
Outfall 001 to the Gary Sanitary District POTW discharge outfall.
It is estimated that up to 500,000 yd3 of contaminated sediments in
this stretch of the river may need remedial action.  The SRP will
address the best method for  GCR sediment remediation including the
possibility of recycling the sediment back into  the steel-making
process  at  the USS  Gary  plant.    USS  used to routinely  recycle
sediments  in order  to  recover  its high  metal  content.    This
practice was  stopped by  the passage of  the Clean Air  and Clean
Water  Acts,  which  prohibited  emissions  associated  with  the
recycling process.   If this project is  proposed  and approved, it
will be  the  first  major recycling  effort of  river sediments back
into a steel-making process to be conducted in the U.S.  since the
passage of these acts.  In order for this project to be successful,
the  oily fraction of the sediments need  to be removed prior to
burning, and volatilization must be controlled.  If this sediment
recycling project is successful,  it could be a boon  to the area and
solve a major problem for all of  the steel  industries in northwest
Indiana.    The  completed  Sediment Remediation  Plan is  due  by
9/30/92.

The remediation of the East  Branch  of the Grand Calumet River will
be the first step in what is hoped  to be a thorough remediation of
the  river's  entire  length.    The  cleanup  of  this  heavily
industrialized  area  may  serve  as  a  demonstration  for  future
sediment remedial  actions.  The  use of  the CWA as an enforcement
tool here  and in  other Grand Calumet  River sites points  to its
usefulness in these remedial actions.

2) USS - Lorain, Ohio

The USS Lorain steelmaking facility is located in Lorain,  Ohio on
the banks of the Black River,  an IJC Area of Concern.  Discharges
from this  facility contributed  to  the  degradation of  the Black
River.  In January 1979,  a civil  action was brought against USS by
the USEPA.   The  action  claimed  that USS was  in  violation  of the
terms of its NPDES permit issued pursuant to the CWA.  Negotiations
were entered into and led to a Consent Decree issued in June 1980.

By the terms of this  Consent Decree, USS agreed to pay a  $4 million
penalty.  Of this  amount, $1.5 million was to  be  spent  on  a dust
suppression program at the facility. Because of operation closures
at  the  Lorain  Plant,  USS  did   not  spend  $1.5  million on  dust
suppression.
                                25

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In  order  to  resolve  the   unspent   outstanding  $1.5  million
expenditure,  USS  and the USEPA  entered into  negotiations  which
resulted in an  agreement that required USS to remove and dispose of
50,000 yd3 of sediments from the Black River.   The 50,000 yd3 was
to be removed  from an  area of the  river previously identified as
having the highest concentrations of steelmaking coke plant wastes
commonly referred to as polynuclear aromatic  hydrocarbons.   PAHs
are of concern because they have been shown to produce tumors and
lesions in benthic fish populations. Heavy metal contamination was
also an issue.   Sediment sampling took place on the river and high
concentrations of PAHs were  found at  levels exceeding  50  ppm.
Cadmium was also found at levels exceeding 30 ppm and studies found
tumors in Black River fish.   A civil penalty of $200,000 was also
included in the settlement.

Actual dredging of the river was initiated in the  fall of 1989.
Because  of  delays  due  to   weather  conditions  and  mechanical
failures, the 50,000 yd3 of  sediments  were finally removed by the
Fall  of  1990.   A landfill  was constructed on USS  property for
sediment  disposal  in accordance  with all  state  and  federal
regulations.   Runoff and leachate from the landfill are collected
and treated in accordance  with an NPDES permit.

The dredging and removal of the contaminated sediments should help
alleviate  some of the water quality problems  encountered in the
Black River AOC.
Section III

Resource conservation and Recovery Act/
Toxic substances Control Act

The Resource Conservation and Recovery Act's overall objectives are
to minimize the generation of  hazardous waste and to treat, store,
and  dispose of hazardous  wastes so  as  to minimize  present and
future threats to human health and the environment.  All treatment,
storage, or  disposal  facilities  (TSD)  must meet detailed design,
operation,   maintenance,   and  monitoring  requirements  before
receiving  a RCRA  operating or  closure permit.   RCRA provisions
could require a permittee to remediate sediments contaminated as a
result of releases of hazardous  wastes from a TSD facility.  Under
Section 3004(u), the USEPA can require  corrective action for all
releases of  hazardous waste or  constituents from any solid waste
management  unit at a  TSD facility  seeking a 3005(c)  permit to
operate such a facility,  regardless  of  what time the  waste was
placed  in the  unit.   And under Section  3004(v),  the  USEPA is
directed  to establish standards requiring  corrective action for
releases from a TSD facility that have migrated beyond  the facility
boundary.    Section  3008(h)  provides  for   federal assessment of
penalties  for  violations  of  compliance  with  disposal permits,


                                26

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including violations of applicable regulations and standards.

While none of the cleanups detailed in this report were conducted
under a RCRA corrective action, RCRA still plays a significant role
in  contaminated  sediment remediations.    Contaminated  sediments
and/or treatment residues may be classified as a  RCRA  hazardous
waste and consequently would require treatment and/or disposal at
a RCRA disposal facility.  One scenario requiring sediments to be
handled as  a RCRA  hazardous  waste would  be  if  they failed the
Toxicity  Characteristic  Leaching  Procedure (TCLP)  test.    Note
however that sediments need not be classified as  a RCRA hazardous
waste  in  order  to be  remediated under  RCRA corrective  action
authority.   Disposal of  large  quantities  of materials  in a RCRA-
approved facility can be  very  expensive.  This cost can be further
exacerbated  if  the  sediment  and/or treatment  residue  have PCB
concentrations at  greater  than 50 ppm.   In this  case  they come
under  the authority of  Section  6  of  TSCA.   Sediments at this
concentration or higher  must  be  disposed of at  a TSCA-approved
facility.


Section IV

State Actions

State actions for  the remediation of  contaminated sediments have
followed  both regulatory and  non-regulatory paths.  Many  of the
contaminated sites  are discovered via water quality sampling and/or
violations of NPDES permits.   All  six states in  Region V issue
these  permits  in their  respective  states with USEPA  oversight.
State enforcement can result in monetary penalties and a remedial
action.   If  the party who the  action  is  taken  against  refuses to
comply, the  case  may be referred to  the  USEPA for enforcement.
Often, parties prefer to reach an agreement with the state before
the federal government is called in.

Some states have authority similar to CERCLA.  Both the States of
Ohio  and   Michigan  have their   own  Superfund-type  enforcement
actions.

For some sites,  the threat of some sort of enforcement action may
be enough  to bring  PRPs into negotiations.  Some of the cleanups in
this section have occurred without an enforcement action and have
been considered successful.   An issue of concern in such cleanups
is  the status of  future liability on the part of  the PRP.   A
voluntary cleanup agreed to by all parties involved should not be
construed as absolving any of the PRPs from future actions.

Non-regulatory State measures include federal grants to finance the
cleanup of sites where there  is no  liable party.   One  such grant
source is  the Clean Lakes Program, administered by the USEPA under
authority granted in the CWA.

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Another  grant  source  is  the Coastal  America Program.  It  is a
cooperative effort between the U.S.  Fish and Wildlife Service, the
U.S. Army Corps of  Engineers, the  USEPA  and  the National Oceanic
and Atmospheric Administration.   These  four agencies contribute to
a fund designed to support protection,  prevention, restoration and
remediation in coastal water bodies.
The  last  type of  state  cleanup discussed  in  this section  is a
demonstration project being conducted by the State of Wisconsin's
Sediment Management and Remediation Technologies (SMART) program.
Through voluntary contributions and state funding,  SMART hopes to
create a  model  for other urban waterway  cleanups  throughout the
State.

1) ALCOA - Lafavette, Indiana

The Aluminum Company of America (ALCOA) plant in Lafayette, Indiana
discharges to Elliott Ditch,  a tributary of Wea Creek, which flows
into the  Wabash  River.   In 1982,  ALCOA contracted  to  have a PCB
survey conducted on Elliott Ditch and Wea Creek.  This survey was
requested by  the Indiana State Board of  Health.   Survey results
showed fish and sediment  to be contaminated with PCBs beyond state
allowable limits.  Further studies indicated that an unknown non-
point source on ALCOA property and not discharges associated with
manufacturing  processes,  was the  cause of the  contamination.
Although ALCOA effectively reduced loadings to the ditch and creek,
as indicated by a 1984 study, sediment levels remained constant.

A Consent Decree was  signed  by the  State  of Indiana and ALCOA in
January, 1985, requiring  ALCOA to meet 1 part per billion  (ppb) PCB
limits  at  all  discharge points.    ALCOA  installed  treatment
facilities in order  to meet  these  levels.  No action on sediment
removal was  taken at  this time.    ALCOA felt  that contaminated
sediments would be topped by clean sediments  and  that any attempted
sediment  removal would  remobilize  PCBs  into  the  water column.
While the State of Indiana wanted a removal of sediments, such an
action was delayed pending further studies of the receiving streams
in an attempt to find the exact extent of sediment contamination.

Based on subsequent studies by ALCOA,  and  especially on the report
entitled  Historical  Data Analysis  of  Elliott Ditch/Wea  Creek
Watershed  (August, 1988), PCB sediment hotspots at concentrations
greater than 50 ppm were  identified in a one  mile reach of Elliott
Ditch/Wea Creek, starting at a point  100  feet upstream of ALCOA'S
discharge point.  ALCOA submitted  a work plan to IDEM in June 1990
for the immediate removal of hotspots  in this reach.  IDEM approved
the workplan and a contractor was selected to do the remediation.

The  remediation took  place   from  September  1990  to  April 1991
(following information after  "Elliott Ditch  Documentation Report,


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1991) .    The  remedial method  involved placing  an  upstream  and
downstream dam in order to divert the water from a section of the
of the waterbody and allowing the water to be treated between the
dams.  This water was  treated  to  below .0005 mg/1 and discharged
downstream.  An Interlocutory Agreement between IDEM and ALCOA was
signed on 10/9/90 allowing for discharge of the treated creek water
at this level.  The sediments were then excavated and solidified by
mixing with lime and pugged flue dust.  When an area was completed,
the  system was  shut-down  and moved downstream to  the  next area.
Solidified  materials  exhibiting  TSCA-level  contamination  was
disposed of at the Chemical  Waste Management Facility in Emelle,
Alabama.  The remainder of the solidified material was classified
as  Special Waste  (less  than  50 ppm)  and  disposed of  at  an
appropriate landfill  in Indiana.  A total of 12,346 tons (5600 yd3)
of material were removed (68% Special Waste,  32% TSCA Waste).

ALCOA will conduct post-monitoring of the stream after it returns
to a steady state.   The state of Indiana  is  interested  in water
quality specifications being met during this phase.


2) Dana Corporation - Churubusco,  Indiana

In the Spring of 1986, PCB contamination was found in sludge from
the  Churubusco, Indiana Sewage Treatment  Plant  (STP).  The  STP
discharges to several drainage  ditches which join together to form
a  stream  which provides the headwaters of  the  Eel River.   PCB
concentrations in  the ditches were found at levels up to 7290 ppm.
The  source  of this  contamination was determined  to be the  BRC
Injected Rubber Products plant site which was previously owned by
the Dana Corporation.   IDEM held meetings  in 1986 with the City of
Churubusco, BRC Injected Rubber, and Dana Corporation in order to
formulate a clean-up plan for the site. Manufacturing processes at
BRC Injected Rubber were found  not to be  responsible for the PCB
contamination.  The PCBs were discharged while the plant was under
Dana Corporation ownership.   Dana Corporation agreed to pay for a
voluntary clean up of the STP and the drainage ditches.

The  clean-up  took   place in the summer  of  1987.   The  site  was
cleared  of vegetative matter  and  the  ditches  were  diverted.
Diverted water was  treated to 0.1  ppb  and discharged downstream of
the diversion dams.  The stream and  ditch beds  were excavated by
backhoe to  a  depth of  12-18 inches  although sediment tests  had
indicated the depth of  contamination  was  only 6  inches.   Cleanup
criteria were set for sediments at the surface to 12 inches below
at 1 ppm  and  from  12 inches downwards at  10  ppm.    Confirmation
sampling of  the sediments was  done  during excavation to  ensure
cleanup standards were met.  Excavated sediments  were stabilized
with kiln  dust,  if necessary,   and trucked to a PCB  landfill  in
Ohio.  No post-monitoring of the sediments was required because the
confirmation  sampling  confirmed  that  cleanup levels had  been


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attained.

3) Deer Lake, Michigan

Deer Lake, a 906 acre  impoundment, is located in central Marquette
County in Michigan's  Upper Peninsula.   The lake  is  connected to
Lake Superior by the Carp River.  The Deer Lake AOC includes Carp
Creek, Deer Lake,  and  the Carp River. Mining iron  ore is the major
industry in the area but occurs outside the lake's drainage basin
at this  time.   The following information is taken  from the 1987
Deer Lake Remedial Action Plan  (RAP).  Information from after 1987
was gathered from personal communications.

As determined by the IJC,  degradation of the fisheries in the lake
and its major tributaries is the AOC's use impairment.   Fish were
contaminated with mercury in  excess  of  the  U.S. Food  and Drug
Administration  (FDA)  action  level  of  1.0 ppm wet weight and the
State of Michigan Consumption Advisory  level  of  0.5 ppm.   Fish
consumptions and health advisories were  issued for these waters in
1981 and 1982 and are still in effect.   Levels of mercury in Deer
Creek sediments were very high (10-15 ppm) near the mouth of Carp
Creek.

The major sources of pollution contributing to elevated levels in
fish are believed to have been discharges of mercury from the old
Ishpeming, Michigan Wastewater  Treatment Plant (WWTP) and combined
sewer overflows  (CSOs).  The major  source of  mercury to the WWTP
was the Cleveland Cliffs Iron Company (CCI) laboratories.  Mercuric
chloride was used  in  ore  assays  and research.   Disposal of spent
reagents  was curtailed  in 1981  when   severe  fish  and sediment
contamination was discovered.  Sediments  in the lake may continue
to be a source of mercury, as well as other minor potential sources
such as  leachate from mine tailings and atmospheric deposition.

In  1982, the State  of Michigan filed  suit against CCI seeking
injunctive  and  other  relief to remedy  mercury  pollution of Deer
Lake.  CCI agreed to analyze the nature  of the contamination  and to
develop  a  plan  for  restoration.   In  the  Fall  of   1984,  the
restoration  plan  was implemented.    The lake  outflow dam  was
partially opened and the lake was drawn down to its lowest level in
order to eradicate contaminated fish and further  minimize human and
wildlife exposure.  Fish leaving the impoundments  were killed.  In
Winter 1985, the  Michigan  Department of Natural Resources  netted
and killed  an additional 1,500 pounds  of fish.   In  the fall and
winter of 1986-1987, the remaining fish  were killed with rotenone.
CCI dug a channel to divert the flow of  Carp Creek around the lake
in  order  to prevent  downstream transport  of  rotenone.    MDNR
estimated that  approximately  90% of the  fish  in  the impoundment
were killed.

In the Fall of  1984,  a Consent Judgement was  signed between MDNR
and CCI,  outlining a  plan for  monitoring and  restoration of Deer

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Lake and held  CCI  financially responsible.  CCI  would  also make
access  available  to  other  area  lakes  to compensate  for  the
temporary loss of Deer Lake as a fishing resource.

The monitoring program outlined a 10 year sampling  regime for fish,
sediment, water, and  ice that formed  over tailing piles.   In the
Spring of 1987, the outflow dam was partially closed and Deer Lake
water levels were allowed to be stabilized near  the top of the dam.
The water level will stay at this level for 10  years,  until 1997.
By maintaining a constant water  level,  instead  of draining and
filling  the  lake as  in  the past,  sediment agitation  should be
minimized.   This will help prevent the resuspension of mercury from
the sediments  into the water column.    Over this  10 year period,
clean  sediments entering  the impoundment should  cover up  the
contaminated sediments and render them relatively immobile.

One of the key  goals  of this plan  is  to create an uncontaminated
fishery  in the lake  and  its tributaries.   MDNR introduced  large
numbers of  perch and walleye into the lake in 1987.  Mercury levels
in fish  still  only allow for catch-and-release fishing  but  it is
anticipated that at the end of the 10 year monitoring phase, fish
mercury levels will be comparable to other lakes in the area.

Mercury levels in lake sediments have  greatly improved.  Surficial
sediment values were at 15 ppm for mercury before remediation and
are now down to 8.3 ppm.   Monitoring will continue until 1996.


4) Double Eagle Steel - Dearborn.  Michigan

The Double  Eagle Steel Coating Company is located in  Dearborn,
Michigan on the Rouge  River.  From Spring until  August 1986, due to
a design malfunction in the company's wastewater treatment plant,
levels of zinc far  in excess of the  company's NPDES  permit were
discharged into the  Rouge River,  including quantities of  up to
three tons per day.   Sampling by the MDNR did not find markedly
high levels of zinc in the  river sediments.  It was theorized that
stormy weather caused scouring of the river bed and dispersed the
zinc downstream.  The case was referred to the Michigan Attorney
General's Office for  enforcement action.   A  Consent Decree was
signed in October 1986.

By the terms of  the Consent  Decree,  Double Eagle  Steel  agreed to
undertake a  dredging program in  the Rouge  River to remove the
excess zinc deposits.  The cost of dredging and  disposal was not to
exceed $800,000.   Penalties were  negotiated at  $850,000 less a
$75,000 credit for the cost of a study to  improve the design flaw,
and an additional $100,000 for enforcement and alleged  damage to
aquatic life.

The dredging was completed in September 1987, with the removal of
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39,325 yd3 of sediment, from the company's outfall to approximately
200 yards downriver.   The sediment was disposed of  at the USAGE
confined disposal  facility at  Point  Mouillee,  Michigan.   Post-
monitoring of effluents have showed no indication of renewed zinc
discharge violations.

5) Hitatchi Magnetics Corporation - Edmore, Michigan

The Hitatchi Magnetics Corporation at Edmore, Michigan was and is
the site of a mercury cleanup on an unnamed drain that leads into
Wolf Creek.   Prior to 1973, General Electric owned  the facility
and dumped  large amounts  of mercury into the drain.   In the mid
1970s, the  GE plant was  closed while treatment facilities were
installed under  orders from the  Michigan Department  of Natural
Resources.   The plant was subsequently sold to Hitatchi.

In 1984,  further testing by MDNR found more mercury contamination.
MDNR  classified the  drain  sediments  as  heavily  polluted with
mercury for about  one  mile  downstream  of  the facility's outfall,
and also reported high levels of cadmium, chromium, copper, nickel,
lead,  zinc,  and  oil  and  grease  within  1,700  to   2,400  feet
downstream of the outfall.

After negotiations between MDNR, Hitatchi and General Electric, it
was  agreed that  General  Electric would  pay  for  the  cleanup.
Although the initial intent of MDNR was an Administrative Consent
Agreement,   they  agreed to  General Electric performing  the work
without a Consent Decree.

The  cleanup of the  drain commenced in  August  1986.   Sediments
contaminated with mercury at levels at or greater than 1 ppm were
excavated and disposed of at a Michigan Act 641 licensed landfill
if  they  contained  levels  of  mercury  less than  170 ppm  (non-
hazardous)  as established by MDNR.  Mercury-contaminated sediments
at greater than 170 ppm were classified as hazardous and required
disposal in TSCA-approved disposal facility.  Verification testing
indicated mercury at .15 ppm in the drain after dredging.

PCB contamination was also encountered  in association with mercury
levels above 1 ppm.  These sediments were also dredged and disposed
of at the Act  641  landfill  if  at  less  than 50  ppm  or at the TSCA
facility if at greater  than 50 ppm.  Verification testing indicated
PCBs at .13 ppm.  The drain was filled  with  new soil.   The cleanup
was completed  in April 1987 and was overseen by MDNR (see Beak,
1987) .

While this drain cleanup is considered a success, a new ditch dug
for  an  outfall is now contaminated with mercury.    Hitatchi has
changed its production process to  a closed-loop system  in order to
eliminate  any  future mercury discharges.   Studies  are currently
being  undertaken to determine  the level  of mercury  in  the new


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ditch.  No new enforcement action has been taken as of yet.

6) Dayton Power and Light Company - Davton. Ohio

In March 1983,  the Ohio Environmental Protection Agency was called
in  to investigate  a  source  of  an  oil spill  and to  implement
possible remedial  measures  on an unnamed drain that  flowed into
Opossum  Creek.    Upon  investigation,   OEPA  discovered  numerous
capacitors and transformers.   OEPA determined that the  site had
been  used  to  salvage  oil  for  approximately  12  years.    During
salvaging,  residual oil from transformer casings was drained on the
ground.  The oil contained PCBs in various concentrations.  Samples
of soil, water, sediment and  oil were  collected by OEPA  in March
and June  1983  and  revealed  PCB  contamination exceeding  50 ppm.
Based  on  these findings, OEPA  determined that there may  be  an
imminent and  substantial endangerment  to  the public health and
welfare or the environment and  that action had  to be  taken  to
prevent these endangerments.

On November 22, 1985 an Administrative Order was signed between the
Dayton Power and  Light Company  (DPL)  and OEPA.   DPL  had already
engaged in extensive site characterization and remedial activities
with OEPA oversight. By the terms of the Administrative Order, DPL
agreed to remedial  activities for  the soils and  sediment on the
site  as  well  as  post-monitoring  to  ensure the  success  of the
cleanup.

Contaminated sediments were  to be removed to less than 25 ppm PCBs.
The unnamed drain was rerouted and sediment with PCB concentrations
above  25 ppm were  excavated and  shipped offsite to the  CECOS PCB
Landfill in Ohio.   An additional tool  employed during excavation
was the use of "discovery" trenches to provide a cross section of
an area off of, or  away  from, the  main excavation.  This enabled
personnel to examine a face up to  eight feet deep for any length
desired. After information  was obtained and/or samples taken, the
trench was backfilled.   The excavated drain was  also backfilled
with  clay and  the entire site was seeded  by October 1986.   The
total  amount of  material removed  was  over 1,600  cubic  yd3.   No
differentiation was made  between soils and sediments.

Two years of post-closure monitoring was completed  in December 1990
and cleanup standards were  met.   Monitoring well  closure is the
last step to be completed.
7) Lake Lansing, Michigan

Lake  Lansing,   a  small  lake  (approx.  450  acres)  located  near
Lansing, Michigan,  was treated with sodium arsenite for macrophyte
control in 1957.  Since that time, the Lake had become eutrophic.


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A decision was made by the Ingham County Drain Office to maintain
adequate recreational depth  and  to  retard eutrophication through
dredging.   This  project  was seen as  a  demonstration of  the
effectiveness  of  dredging as  a  technique  for  lake restoration.
Federal  funding was  received through the Clean  Lakes  Program as
administered by the USEPA under Section 314 of the Clean Water Act.
The  grant  required  pre-dredging  and post-dredging studies  to
document  ecological  changes  due   to   dredging  (see  Michigan
Department of Natural Resources,  1985, and Siami, 1981).

Sediment chemistry data prior to dredging was limited and contained
information only on arsenic,  the  principal heavy metal of concern.
The MDNR conducted the post-dredging study  in 1984  and concluded
that arsenic levels had decreased 60% since 1979 and agreed with
studies that arsenic concentrations would reach background levels
by the late 1980s  (17-20 ppm).

During  dredging  procedures,  1.6 million  yd3  of  sediment  were
dredged and disposed of  at an upland facility.  Disposal proved to
be the most controversial part of the project.  Eventually,  three
spoil  sites  were  obtained from  private  easements.    Solids were
settled out of the dredged material and the water was returned to
the lake.   Post-dredge  testing  indicated that  arsenic  and  other
heavy metals were not remobilized by the dredging procedure.  The
lake was deepened  by 9.0  feet  and the trophic status of the lake
went from highly eutrophic to meso-eutrophic.

The project was completed  in 1984 and there was a one year post-
monitoring period for arsenic due to public  health concerns but no
problems were encountered.

8) Little Lake Butte Des Morts, Wisconsin

In  1989,  the  WDNR  began  developing a comprehensive  Sediment
Management  and  Remedial  Technologies  (SMART)  program.    One
component of the program involved selecting a few sites for cleanup
demonstration  projects  and/or Remedial  Investigation/Feasibility
Studies.  Two sites have been selected for these studies.  Little
Lake Butte Des Morts and starkweather Creek.

Little Lake Butte Des Morts is part  of the Lower  Fox River System.
It is the first impoundment downstream from  Lake  Winnebago.  There
is a fish consumption advisory and a  waterfowl consumption advisory
due to high levels of PCBs, presumably coming from PCB-contaminated
sediments,  which  may be  due to  paper industries located on the
river.   Because Little Lake  Butte Des Morts is the most upstream
source of  PCBs to the Lower Fox  River,  removal of hotspots would
provide  a decrease in  PCB  loading  levels  to the  Lower  Fox and
Southern Green Bay. Remedial action at this site is recommended by
the  Green Bay RAP and is  supported by  the Green  Bay  PCB Mass
Balance Study.  The last seven miles of the Lower Fox River and the


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southern part  of  Green Bay contain the  highest concentration of
paper and pulp mills in the world and is an IJC AOC.  Information
on this site is from the 1991 Request for Proposal  (RFP) and from
personal communications.

A  soft sediment  deposit  in  the  southwest  corner  of the  lake
contains approximately 1650 kg of PCBs in a volume of approximately
56,000 m3 of sediment.  This represents about  31% of  the total mass
of PCBs  in  the Lower  Fox  River  but only 2% of the contaminated
sediments by area  and volume.   By removal or  in-place isolation of
this hotspot, this demonstration project will virtually eliminate
this deposit as a PCB source to the Lower Fox River.  An adjacent
abandoned  landfill  will   also  be  evaluated  for   potential  PCB
contributions.

WDNR sent out an RFP  to conduct the RI/FS and  is now  in the process
of rewarding  the  contract.   The RI/FS  will review the  current
literature regarding  contaminated sediment confinement and disposal
techniques, and identify the most environmentally sound and cost-
effective alternative for remediation.  An engineering design based
on the selected remediation will  follow.   It is anticipated that
the remediation will begin in the Fall of 1992.

A variety of  funding mechanisms  are being used on  this project.
The RI/FS will be  supported by $100,000 from the State of Wisconsin
and a $100,000 grant  from the USEPA.  A request  for a $50,000 grant
from the Coastal America Program is expected in  Fall, 1991, to help
pay for the final engineering design.  An additional proposal for
$1,100,000 from the Coastal America Program is hoped  for Fall, 1992
to support the actual remedial action.  The Coastal America Program
is a cooperative effort between the U.S.  Fish  and Wildlife Service,
the  U.S.  Army Corps of Engineers,  the USEPA and the  National
Oceanic  and  Atmospheric   Administration.    These   four  agencies
contribute to  a fund designed  to  support protection,  prevention,
restoration and remediation in  coastal water bodies, including the
remediation of contaminated sediments.  Approximately $21 million
will be divided amongst seven Coastal America  defined regions. WDNR
has  met  with  a  PRP,  seeking  cooperation  for  the  cleanup  on  a
voluntary basis.    It is hoped that the  PRP  will  contribute over
half the cost of any  remediation.  There has been good cooperation
from the PRP but the  issue  of where the PRP's liability ends still
needs to be resolved.

9) Starkweather Creek - Madison,  Wisconsin

Starkweather Creek,  which  flows  into Lake Monona in the  City of
Madison,  has been  chosen as a SMART demonstration project in order
to show how an urban  waterway impacted by polluted sediment can be
restored.  Contaminated urban waterways are  common in Wisconsin and
it is hoped that the restoration of Starkweather Creek will serve
as a  model  for sites  elsewhere  in  the state.   WDNR  is actively


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publicizing the project  in  order to inform the public  as to the
importance of clean urban waterways.

Starkweather  Creek  is  affected  by a  variety  of  pollutants.
Industrial wastes have led to mercury, zinc, lead, oil, and grease
contamination  in  the bottom  sediments.   These  sediments  are
periodically  scoured by  high water  flows,  carrying  pollutants
downstream to Lake Monona.   Nonpoint pollutants also impact on the
water quality of the  creek.  Some of these contaminants have led to
excessive underwater plant and algae growth, reduced populations of
aquatic organisms, smothered fish habitat,  lower dissolved oxygen
levels in  the water, and unsightly or smelly conditions in area
neighborhoods.  Project plans include:

     - bottom sediment removal and disposal;

     - stream bank improvements and landscaping;

     - in-stream aeration to restore dissolved oxygen;

     - potential construction of a northern pike rearing pond;

     - better public access, along with possible improvements
       in walking and biking paths.

Sediment removal  will have  the  effect  of improving  the creek*s
water quality, protecting Lake Monona from further contamination,
improve fish habitat, and increase public use and enjoyment of the
stream.  Creek  dredging  will be  done by  backhoe and the material
will  be  dewatered in  a  dyked sediment  storage facility.   WDNR
testing of the creek sediments has found  that the level of mercury
and  other  contaminants   lie  within current  regulatory  limits
allowing for land disposal.   The  dried sediments may be ultimately
used  to  amend  agricultural  soils or as a  daily cover  in local
landfills.

Funding for the cleanup will come from a cooperative effort between
the WDNR, the City of Madison, and Dane County.  The estimated cost
of  the project  is  $500,000.   The  project  is actively seeking
contributions  from  local  private  industries.    Because  of  the
diverse and convoluted history of pollution of the creek, there is
no action at this  time to attempt to locate PRPs  for cost recovery.
Starkweather Creek is also part of the Yahara-Monona drainage basin
which has been designated a  'Priority Watershed' under Wisconsin's
Nonpoint  Source Pollution Abatement  Program   A  nonpoint source
control plan is now being developed for the watershed.  This effort
will allow the  City  of Madison to receive up to 70 percent of the
funding  needed  to prevent nonpoint  pollutants  from entering the
creek  in the  future.   The project is expected to be completed by
Fall,  1991.
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                  if incorporated - Circleville, Ohio

The PPG Industries, Inc. Coatings  and  Resins  plant is located in
Circleville, Ohio.  The facility used oils containing  PCBs in a
heat transfer system until 1972.  Pipes used to circulate the oil
leaked into  sewer  drains which discharged to  Scippo  Creek.   The
Creek  feeds   into the  Scioto  River.    PPG   discovered  PCB
contamination while removing  sediments from  their sewer system.
Tests  of  these  sediments revealed  high  levels   of  PCBs.    PPG
notified  the  Ohio  Environmental  Protection  Agency  of  their
discovery.  An informal  agreement  was  reached calling for PPG to
remediate the stream.    This was subsequently  changed  to a formal
agency order  from the  OEPA Division  of  Emergency and Remedial
Response,  the state equivalent of the Federal Superfund Program.

The first set of sediment samples from Scippo Creek were taken in
the Spring  of  1988.   These samples showed PCB concentrations as
high  as  300  ppm  adjacent  to  the  PPG  sewer  outfall,   with
concentrations declining downstream.   Areas  of PCB concentration
greater than 10 ppm were identified for removal. During this time,
1260 tons of  dirt and  soil  located  near the  leaking pipes were
removed and  sent to a  chemical waste landfill.   Stormwater was
diverted to a treatment plant onsite and a new sewage outfall was
constructed which  discharges into  Scippo  Creek downstream of the
original.

Sediment remediation of Scippo Creek,  based on the September 1989
Workplan,  took place in  October  of that year.   The  first  50 feet of
the creek downstream of  the sewer outfall were  excavated to the 10
ppm level.  The  creek was  diverted into  a  newly dug bed and silt
curtains were employed  to  minimize sediment  transport downstream
during the  initial diversion activities.   The 50  feet  area was
cordoned  off  by  dams  at  either  end  and   the   sediments  were
stabilized in place before excavation and transport to a chemical
waste landfill.

Unanticipated  high levels of  contamination  were found  during
excavations.   Concentrations  of  up   to  710,000  ppm  PCBs  were
concentrated at a sand/gravel and till  interface and at 37,000 ppm
in iron oxide layers in some sandbars.   The  creek bed was excavated
to this till layer and  a  total of 675  tons  of  the  most highly
contaminated sediments and gravels  were removed.  Two contaminated
sandbars with concentrations up  to 83 ppm still need to be removed.

Post-removal  sampling  of   surface sediments  by  PPG  indicated
concentrations of less than 10 ppm beyond 50 feet downstream of the
outfall.    OEPA  has requested  that PPG  conduct a  more in-depth
sampling of  the  downstream sediments  and  for a  Risk Assessment
study to determine the  effects  of  the  PCB  contamination on human
health and the environment. A fish consumption advisory issued by
the Ohio Department of Health for Scippo Creek is still in place.
Based on additional sediment sampling and a Risk Assessment Study,

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more sediment remediation may be required at this site.
Conclusion

There  have been  a  number  of  successful contaminated  sediment
remediations in USEPA Region V.  While they may not all have taken
the  same  path  and  may  have  not employed  the  same legal  and
technical methods,  they all should succeed in achieving the desired
purpose of improving  water and bottom sediment quality.  Hopefully,
the  sites  currently  undergoing remediation will  also reach this
goal.     Remediating  contaminated   sediments   prevents   their
resuspension and uptake  into the  water column.   This limits the
amount of possible bioaccumulation and the threats posed to human
health and the environment.   Cleaner sediments can also limit the
amount of  contaminants  absorbed  and/or  consumed by  the  benthic
community.  This will lead to healthier organisms  up the food chain
as well.

The  statutory powers  used in  many of these  remedial  actions have
varying degrees of effectiveness,  depending on the site.   CERCLA,
as amended, addresses closed or  abandoned hazardous  waste sites
that pose an imminent hazard to human health and the environment.
CERCLA actions  can  be of  an emergency  nature,  responding  to  a
sudden hazardous   situation,  or  of  a  remedial  sort,  where  no
immediate danger is present.  CERCLA is very effective  in emergency
response situations  such as the  abandoned PR  Mallory site where
emergency  actions can  be  taken  quickly,  with attempted  cost
recoveries from PRPs  follow.  In the remedial response situation,
the  identification of, and an agreement with a PRP may facilitate
remediation.  Most of the CERCLA cleanups examined in this report
involved  the  remediation  of  the  entire  site  and  not  just
contaminated sediments.   Cleanups  at  CERCLA sites are increasingly
including sediment remediation as  a part  of the total site remedy.
Source control may need to be instituted  at the site itself before
any  sediment  action takes   place.    Site-specific factors  will
determine the method  and order of cleanup.

Removal actions conducted under the  CWA  (as  amended), often come
about  due  to  violations of  a discharger's NPDES permit.   These
violations lead to direct degradation  of water quality,  impaired
usages of a water body, and/or contaminated sediments.  Enforcement
actions under the CWA to  date have had a  good rate of  success due,
in part,  to the ability to trace contaminants  to their sources.
Many of  the  sources  are still  actively  discharging wastewaters.
This is in contrast to CERCLA, where the original  polluters or PRPs
may  be out of business.   CWA cleanups have the ability to address
both the  source and  the effects  of illegal discharges,  as does
CERCLA.  By forcing  compliance with NPDES permits, CWA is able to
practice effective source control  on  the  pollutants, both from the
point  source and the sediment source.  This  will help to cleanup

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the waterbody. The Resource Conservation and Recovery Act may also
be used at interim status or permitted TSD facilities to effect a
removal action, although none  of  these removals are addressed in
this report.

State actions often occur due to the discovery of NPDES violations
and  other water  pollution  control programs as  administered  by
states  in the  region.   As  is  the   case  with  the CWA,  State
enforcement  may  include compliance  with  NPDES  permits  and  a
sediment  remediation  of  some  sort.    If a  State  cannot  reach
agreement with  a  discharger,  the  USEPA may become  party  to the
enforcement effort.  Some of the state actions in this report led
to an agreement without the  use of  any  enforcement action.  Often,
the  threat  of using  such  enforcement will  be enough to  bring
parties into negotiation and will lead to an agreed upon remedial
action.   Several  State actions have been and  are currently non-
regulatory  in nature.   Sites  remediated under the  Clean  Lakes
Program and state  in-place  pollutant  initiatives fall under this
category.

From a technical standpoint, removal via dredging is the remedial
action of choice at the moment, with silt curtains being employed
to  limit  remobilization when  appropriate.    Treatment of  these
sediments  is  most  commonly done by  dewatering  on site,  with
disposal  in  the  proper  landfill,  depending  on  the  level  of
contamination.  In situ armoring of sediments is being examined as
an option at  the  Sheboygan  River  Superfund  Site.    Demonstration
projects being conducted by USEPA through the ARCS program may lead
to new removal, treatment,  and disposal methods that will achieve
better levels of cleanup.

While there are a number of enforcement  methods  used to achieve
contaminated  sediment  remediation,  no one method can be  seen as
more effective than another.  Site-specific conditions,  the level
of threat to human health and the environment, and the availability
of a PRP are all factors that need  to be considered when attempting
a remedial action.  To be sure, some steps could be taken to make
the  identification  and remediation   of  contaminated  sediments
quicker and easier.   National Sediment  Quality criteria would help
aid in the determination if sediments are contaminated.   This may
help block many legal challenges  to enforced  cleanups  and could
lead to  easier enforcement measures  and help  industries  better
comply with water quality standards.   Demonstration projects will
help identify the most technologically sound means of remediating
sediments,  aside  from the classical  approach  of  dredging  and
placing the material in a landfill or confined disposal facility.
The taking of  these steps will help the States and Federal agencies
in Region V  effect remedial  actions of  contaminated  sediments in a
more efficient and  thorough  manner  and  improve  water  quality
throughout the region.
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ALCOA, "Historical Data Analysis of  Elliott Ditch/Wea Creek Water-
  shed", August, 1988.

BEAK Consultants, Ltd., "Verification of Unnamed Drain Cleanup",
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Chemical Waste Management, "Elliott Ditch Documentation Report",
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Harris, H.J., P.E. Sager, H.A. Regier and G.R. Francis,
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IJC, 1989, "Great Lakes Water Quality Agreement of 1978 as
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Marcus, W.A., "Managing Contaminated Sediments in Aquatic
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Michigan Department of Natural Resources, "Deer Lake Remedial
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Michigan Department of Natural Resources, "Lake Lansing Dredging
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Siami, M., "Arsenic Profiles in Sediments and Sedimentation
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  Michigan", Ph.D. Thesis, Michigan State University, Department
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USACOE, 1990, " Bioassessment Methodologies for the Regulatory
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USACOE, 1990, "Review of Removal, Containment and Treatment

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  Technologies for Remediation of Contaminated Sediments in the
  Great Lakes, Final Report", U.S. Army Corps of Engineers, North
  Central Division, December, 1990.

USEPA, 1987, "An Overview of Sediment Quality in the United
  States", U.S. Environmental Protection Agency, Office of Water
  Regulations and Standards, Washington, D.C., June, 1987.

USEPA, 1991, "Assessment and Remediation of Contaminated Sediments
  (ARCS)  1991 Work Plan", U.S. Environmental Protection Agency,
  Great Lakes National Program Office, Chicago, IL.

USEPA, 1990, "Contaminated Sediments:  Relevant Statutes and EPA
  Program Activities", U.S. Environmental Protection Agency, Office
  of Water Regulations and Standards,  Sediment Oversight Technical
  Committee, Washington, D.C., December, 1990.

USEPA, 1989, "Five Year Program Strategy for the Great Lakes
  National Program Office",  U.S. Environmental Protection Agency,
  Great Lakes National Program Office, Chicago,  IL,  January, 1989.

USEPA, 1991, "Handbook:   Remediation of Contaminated Sediments",
  U.S. Environmental Protection Agency,  Office of Research and
  Development, Cincinnati, OH, April, 1991.

USEPA, 1990, "Managing Contaminated Sediments: EPA Decision-Making
  Processes", U.S.  Environmental Protection Agency,  Office of Water
  Regulations and Standards, Sediment Oversight Technical
  Committee, Washington, D.C., December, 1990.

USEPA, 1990, "Record Of  Decision,  Crab Orchard National Wildlife
  Refuge Site, Marion, Illinois", U.S. Environmental Protection
  Agency, Office of Superfund, Chicago,  IL, August, 1990.

USEPA, 1986, "Record of Decision, Fields Brook Site, Ashtabula,
  Ohio",  U.S. Environmental Protection Agency, Office of Superfund,
  Chicago, IL, September, 1986.

USEPA, 1990, "Record of Decision, Moss-American Site, Milwaukee
  County, Wisconsin, U.S. Environmental Protection  Agency,
  Office of Superfund, Chicago, IL, September, 1990.

USEPA, 1989, "Record of  Decision,  Outboard Motor Corporation Site,
  Waukegan Illinois, U.S. Environmental Protection  Agency, Office
  of Superfund, March, 1989.

USEPA, 1984, "Record of  Decision,  Outboard Motor Corporation Site,
  Waukegan Illinois, U.S. Environmental Protection  Agency, Office
  of Superfund, May, 1984.

USEPA, 1990, "Report on  Great Lakes Confined Disposal Facilities",
  U.S. Environmental Protection Agency,  Environmental Review

                                41

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  Branch, Planning and Management Division, Chicago, IL, August,
  1990.

USEPA, 1981,  "The PCS Contamination Problem in Waukegan, Illinois",
  U.S. Environmental Protection Agency, Region V, Chicago, IL,
  January 21, 1981.

Warzyn Engineering, Inc., "Draft Remedial Investigation Report,
  South Branch Shiawassee River, Howell, Michigan", vol. 1, Pre-
  pared for Michigan Department of Natural Resources, January,
  1991.

Wisconsin Department of Natural Resources,  "Request for Proposal—
  Little Lake Butte Des Morts Remedial Investigation/Feasibility
  Study", March 15, 1991.
                                42

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