OCR error (C:\Conversion\JobRoot\000007P9\tiff\2000SUJI.tif): Unspecified error ------- 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. ------- 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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. ------- 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. ------- 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, ------- 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 ------- 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 ------- 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 ------- 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 ------- 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; 10 ------- - 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. 11 ------- 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 12 ------- 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. 13 ------- 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 14 ------- 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 15 ------- 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 16 ------- 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, 17 ------- 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 18 ------- 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. 19 ------- 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 20 ------- 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. 21 ------- 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 22 ------- 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 23 ------- 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 24 ------- 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 ------- 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 ------- 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. 27 ------- 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, 28 ------- 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 29 ------- 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 30 ------- 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 31 ------- 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 32 ------- 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. 33 ------- 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 34 ------- 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 35 ------- 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. 36 ------- 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, 37 ------- 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 38 ------- 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. 39 ------- Bibliography ALCOA, "Historical Data Analysis of Elliott Ditch/Wea Creek Water- shed", August, 1988. BEAK Consultants, Ltd., "Verification of Unnamed Drain Cleanup", June, 1987. Chemical Waste Management, "Elliott Ditch Documentation Report", Prepared for Aluminum Company of America, Lafayette, Indiana, by Chemical Waste Management, INC., ENRAC Midwest Division, June, 1991. Harris, H.J., P.E. Sager, H.A. Regier and G.R. Francis, "Ecotoxicology and ecosystem integrity: The Great Lakes examined", Environmental Science and Technology, vol. 24, no.5, 1990, p. 598-603. IJC, 1989, "Great Lakes Water Quality Agreement of 1978 as amended...", International Joint Commission, Windsor, Ontario, September, 1989. Marcus, W.A., "Managing Contaminated Sediments in Aquatic Environments: Identification, Regulation, and Remediation", Environmental Law Reporter, 21, 1/91, p.10020-10032. Michigan Department of Natural Resources, "Deer Lake Remedial Action Plan", Lansing, MI, October, 1987. Michigan Department of Natural Resources, "Lake Lansing Dredging Evaluation Study", Division of Land Resource Programs, Inland Lake Management Unit, Lansing, MI, March, 1985. National Research Council, "Contaminated Marine Sediments— Assessment and Remediation", Committee on Contaminated Marine Sediments, National Academy Press, Washington, D.C., 1989. Siami, M., "Arsenic Profiles in Sediments and Sedimentation Processes Along the Slope of a Lake Basin—Lake Lansing, Michigan", Ph.D. Thesis, Michigan State University, Department of Fisheries and Wildlife, East Lansing, MI, 1981. Tetra Tech, Inc., "Final Report on the Conard's Branch Excavation and Removal, Westinghouse Sites, Bloomington, Indiana", prepared for U.S. Environmental Protection Agency, Region V, CERCLA Office, April, 1989. USACOE, 1990, " Bioassessment Methodologies for the Regulatory Testing of Freshwater Dredged Material, Final Report", U.S. Army Corps of Engineers, St. Paul District, March, 1990. USACOE, 1990, "Review of Removal, Containment and Treatment 40 ------- 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 ------- 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 ------- |