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DISCLAIMER
This report was furnished to the U.S. Environmental Protection
Agency by the student identified on the cover page, under a National
Network for Environmental Management Studies fellowship.
The contents are essentially as received from the author. The
opinions, findings, and conclusions expressed are those of the author
and not necessarily those of the U.S. Environmental Protection
Agency. Mention, if any, of company, process, or product names is
not to be considered as an endorsement by the U.S. Environmental
Protection Agency.
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A SUMMARY OF CONTAMINATED SEDIMENT REMEDIAL ACTIONS IN
REGION V OF THE U.S. ENVIRONMENTAL PROTECTION AGENCY
by
Mark Elster, Intern
National Network for
Environmental Management Studies Program
Prepared for:
Marc Tuchman
U.S. Environmental Protection Agency
Region V
Water Division
August, 1991
'•~iicn Agency
•*-u< floor
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Abstract
Contaminated sediments, or in-place pollutants, can affect water
quality and may contribute to long-term health effects in aquatic
biota and human beings. This can occur through toxicity,
bioaccumulation up the food chain and through fish consumption.
The pervasive and widespread nature of this problem has resulted
from historically inadequate regulation of waste disposal and
industrial wastewater discharges. A directed, dedicated effort to
mitigate the effects of contaminated sediments and to effect their
removal has yet to be fully developed due to several factors,
including the lack of sediment criteria and a definition as to what
a contaminated sediment is. Actions are currently being taken to
address these deficiencies.
In the U.S. Environmental Protection Agency Region V, several
contaminated sediment removal actions have taken place under a
variety of enforcement authorities. At the Federal enforcement
level, USEPA has exercised authority under the Comprehensive
Environmental Response, Compensation, and Liability Act, the Clean
Water Act, and to a lesser extent, the Resource Conservation and
Recovery Act and the Toxic Substances Control Act. These acts seek
to control the source of the contaminant and to remediate the
damage to human health and the environment. Region V States have
effected removal actions through legal authority given to them to
regulate dischargers under the CWA, through State environmental
protection laws, through voluntary agreements with potentially
responsible parties, and through Federal grant programs.
This report summarizes a number of contaminated sediment remedial
actions conducted in USEPA Region V. These cleanups were conducted
at both the Federal and State levels, using a variety of
enforcement actions, and employed a number of different remedial
technologies. By examining the various cleanups and the
methodologies implemented, USEPA hopes to identify the most cost-
effective and technologically sound procedures for application to
future contaminated sediment remedial actions.
By identifying and removing contaminated sediments, the State and
Federal agencies in USEPA Region V will hasten the goal of
improving water quality throughout the region.
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Glossary
AOC
ARCS
ASRI
CPAH
CDF
CERCLA
CFS
CSO
CTF
CWA
DOD
DOI
DOJ
FDA
MRS
IAG
IDEM
I EPA
IJC
IPP
ISV
MCD
MDNR
NPDES
NPL
OEPA
PAH
PCB
POTW
PPB
PPM
PRP
RAP
RCRA
RFP
RI/FS
ROD
RRT
SARA
SCP
SRP
STP
TCLP
TSCA
TSD
USAGE
US EPA
USFWS
WDNR
Area of Concern
Assessment and Remediation of Contaminated Sediments
Alternative Specific Remedial Investigation
Carcinogenic Polynuclear Aromatic Hydrocarbons
Confined Disposal Facility
Comprehensive Environmental Response, Compensation,
and Liability Act
Cubic Feet Per Second
Combined Sewer Overflow
Confined Treatment Facility
Clean Water Act
Department of Defense
Department of the Interior
Department of Justice
Food and Drug Administration
Hazardous Ranking System
Interagency Agreement
Indiana Department of Environmental Management
Illinois Environmental Protection Agency
International Joint Commission
In-Place Pollutants
In Situ Vitrification
Modified Consent Decree
Michigan Department of Natural Resources
National Pollution Discharge Elimination System
National Priorities List
Ohio Environmental Protection Agency
Polynuclear Aromatic Hydrocarbons
Polychlorinated Biphenyls
Publicly Owned Treatment Works
Parts Per Billion
Parts Per Million
Potentially Responsible Party(ies)
Remedial Action Plan
Resource Conservation and Recovery Act
Request for Proposal
Remedial Investigation/Feasibility Study
Record of Decision
Regional Response Team
Superfund Amendments and Reauthorization Act
Sediment Characterization Plan
Sediment Remediation Plan
Sewage Treatment Plant
Toxicity Characteristic Leaching Procedure
Toxic Substances Control Act
Treatment, Storage, and Disposal
U.S. Army Corps of Engineers
U.S. Environmental Protection Agency
U.S. Fish and Wildlife Service
Wisconsin Department of Natural Resources
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Introduction
Contaminated sediments, or in-place pollutants (IPP), are an
important factor in the impairment of water quality and may
contribute to long-term health effects in aquatic biota and human
beings. These sediments can act both as a sink for, and a source
of, contaminants to the water column. Contaminants can also
bioaccumulate up the food chain and impact human health. There are
numerous examples of fish consumption advisories issued due to
contaminated sediments affecting the food chain. Contaminated
sediments have been identified in 41 of 42 International Joint
Commission (IJC) Areas of Concern (AOC) and in other areas
throughout the Great Lakes region.
The pervasive and widespread nature of the problem has resulted
from the historic practice of using water bodies, intentionally or
unintentionally, for waste disposal and from years of unregulated
or inadequately regulated discharges of toxic chemicals from local
industries and municipalities. Urban and rural runoff and
atmospheric deposition also contribute to the contaminated sediment
problem.
Only recently has it become recognized that a directed, dedicated
effort was needed in order to mitigate the effects and to effect
the remediation or removal of contaminated sediments. Despite this
recognition, several issues must be addressed to achieve this goal.
The authority to remediate contaminated sediments involve several
different Federal and State Programs. The contamination problem
itself is a cross-media problem, involving water, land, and air
issues. This underlying complexity and the relatively new emphasis
on contaminated sediment remediation makes it a very difficult
problem to solve in a short time frame. The United States
Environmental Protection Agency (USEPA) is beginning to address
these issues through the development of regional initiatives and a
National Sediment Strategy. This strategy is slated for completion
in 1992. The USEPA's Great Lakes National Program Office has
instituted the Assessment and Remediation of Contaminated Sediments
(ARCS) Program for the testing and assessment of remedial action
alternatives for contaminated sediments. A five year study and
demonstration project relating to the control and removal of toxic
pollutants in the Great Lakes is currently being conducted. The
program places emphasis on developing optimal methods to assess
sediments and examining new and innovative technologies for
remediating sediments.
Contaminated sediments can continue to degrade water quality after
point and non-point sources are eliminated. Because of this, the
decision must often be made to remediate a site. One of the key
factors involved in contaminated sediment sites is the question of
remediation versus "no action". If sediments in a site are not
prone to resuspension and will eventually be covered over by
uncontaminated sediments through natural processes, a removal
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action may not be necessary. This "no action" alternative should
be considered in all possible sediment remediation situations. It
is important to note that natural phenomena such as storms and the
mixing of water bodies due to seasonal changes can lead to
resuspension of contaminated sediments. If it is determined that
some sort of removal or other remediation must take place, careful
planning and precautions must be taken. It is very possible to
degrade water quality during removals by resuspension of sediments
during dredging. Also, due to the large amounts of sediments that
often need to be removed and their varying levels of toxicity, it
is desirable that suitable disposal facilities are secured before
a removal takes place. This will not always be feasible due to the
pressing need to remove highly contaminated sediments as quickly as
possible. Costs incurred in sediment remediations often run into
the millions of dollars. These high costs also argue for a careful
evaluation of the "no action" option.
Contaminated sediment remedial activities in Region V have gained
their legislative authority mainly from the Comprehensive Emergency
Response, Compensation, and Liability Act (CERCLA) of 1980 as
amended by the Superfund Amendments and Reauthorization Act (SARA)
of 1986, the Clean Water Act (CWA) of 1977, as amended, and the
Resource Conservation and Recovery Act (RCRA), as amended. While
using the authority vested within the acts, none of these acts
specifically address sediment remediations.
CERCLA, as amended by SARA, and commonly known as Superfund,
addresses the cleanup and remediation of inactive or abandoned
hazardous waste sites. Potential sites are ranked by the USEPA
using the Hazardous Ranking System (HRS) to determine if they
should be included on the National Priorities List (NPL). The
ranking is based on the hazard a site may pose to human health and
the environment via releases to groundwater, surface water, land,
and/or the air. CERCLA also includes removal actions and the
ability to file claims for natural resource damages. SARA
addresses "damage to natural resources which may affect the human
food chain". This may lead to a greater number of contaminated
sediments sites being remediated under Superfund.
The Clean Water Act gives the USEPA the responsibility to safeguard
the quality of U.S. coastal and inland waterways. In accordance,
the USEPA regulates the disposal of dredged and fill materials in
partnership with the U.S. Army Corps of Engineers (USAGE), and
oversees the National Pollution Discharge Elimination System
(NPDES) program, regulating point-source discharges. All six
states in the USEPA Region V - Illinois, Indiana, Michigan,
Minnesota, Ohio, and Wisconsin - have taken responsibility for the
administration of the NPDES program in their respective state, as
allowed by the CWA, with USEPA oversight. By instituting these
source control measures, the USEPA hopes to stop sediment
contamination before it occurs. Source control is viewed as a
necessary step before any remediation takes place.
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The Resource Conservation and Recovery Act Section 3008(h) gives
the USEPA authority to commence procedures for a RCRA 3004(u) or
(v) corrective action at any RCRA permitted facility if a release
of hazardous waste has occurred. This CERCLA removal will often
take the shape of an emergency response to an uncontrolled
discharge. When such discharges occur at an abandoned site, the
site will be put under the authority of CERCLA.
The Toxic Substances Control Act can also influence contaminated
sediment remediations. Sediments with PCB concentrations greater
than 50 ppm must be disposed up at a TSCA-approved disposal
facility which can affect the cost of the remediation.
A number of contaminated sediment remediations have occurred in
Region V. A primary goal of the Region is to determine which
methods of enforcement/negotiations work best for the remediation
and removal of contaminated sediments and also work towards
limiting the sources of the contamination. The goal of this report
is to compile a summary of remedial actions taken to date at
various sites in USEPA Region V. It examines how the contaminated
sediment problem was addressed and what solution was decided upon,
i.e., how it was remediated. Maintenance dredging of navigational
channels by the U.S. Army Corps of Engineers is not included in
this report. The criteria for a site to be included in this report
was either the existence of a signed agreement to remediate and/or
a completed remediation. This report is by no means meant to be
exhaustive. Many more sediment cleanup actions were in the final
stages of negotiation as this report was nearing completion.
USEPA Region V hopes that by examining the processes and actions
that have led ongoing and completed contaminated sediment
remediations, future remediations will be effected more
efficiently, leading to improved water quality throughout the
Region.
This report is divided into sections containing contaminated
sediment remediation actions conducted under similar authorities.
The introduction to each section will explain in more detail the
applicable enforcement powers used in the remedial actions. For
many of the cleanups, specific documents are cited. When specific
documents are not cited, the information was obtained through
personal communications and USEPA file correspondence and
memoranda.
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Section I
Comprehensive Environmental Response, Compensation, and
Liability Act, as amended by the Superfund Amendments
and Reauthorization Act
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA, 1980), as amended by the Superfund
Amendments and Reauthorization Act (1986) has the broad goals of
protecting human health and the environment by responding to
potential or existing hazardous substance releases, remediating or
cleaning up contaminated areas, and assessing liability for
remediation actions and resource damages. In general, CERCLA
provisions relate either to remedial actions of contamination at
abandoned sites where there is a continuing threat of more
widespread contamination, or to emergency removal actions at spill
sites. Under Section 104(a), the central response mechanism of
CERCLA, authority is granted to eliminate current dangers posed by
the release of a hazardous substance and to provide long-term
solutions to prevent future threats. Sites may be scored by the
Hazardous Ranking System (HRS) to determine if they should be
included on the NPL list of priority cleanup sites in the country.
A site need not be on the NPL list to be eligible for a CERCLA
cleanup action. Examples of both of these types of contamination
are included in this report. Ongoing hazardous waste treatment,
storage, and disposal operations are regulated by RCRA.
CERCLA provides broad authority to locate areas with contaminated
sediments. Section 104 gives the USEPA authority to undertake
studies or investigations if it believes a hazardous substance
release has occurred or may occur. Studies on the degree and
extent of contamination and potential routes of human exposure to
a hazardous substance are generally determined through preliminary
assessments and may include sampling and testing sediments during
site investigations. Section 104 also allows for the
implementation of a short-term removal or long-term remedial action
where hazardous substances have been released or where contaminants
present an imminent and substantial danger to public health and
welfare. Under Section 105, the National Contingency Plan for the
response to and the removal of oil and hazardous substance releases
will be revised and republished. Under the same section, the
Hazardous Ranking System (HRS) is revised in order to accurately
reflect the relative degree of risk hazardous sites pose to human
health and the environment. Authority under Section 106 allows for
the abatement of imminent danger and penalties for failing to
respond to such a request. Section 107 allows the Federal
Government to establish liability for the cleanup costs and natural
resource damages, allowing for cost recovery. Section 121
establishes cleanup standards and evaluation criteria for remedial
alternatives and establishes a preference for remedial actions
where treatment permanently and significantly reduces the volume,
toxicity, or mobility of hazardous substances.
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The following section highlights several CERCLA sediment
remediations in Region V. Both emergency and remedial actions are
included.
l) Cast Forae - Hovel1. Michigan
The Cast Forge Steel Company of Howell, Michigan, used PCB-
containing oils in their die-casting process from 1969 to 1972.
PCB use was discontinued after this date but residual amounts
remained in their equipment until 1976, at which time the equipment
was flushed in order to eliminate the PCB component of the
company's oily waste. These oily wastes were stored in unlined
evaporative lagoons which would occasionally overflow into a
drainage ditch which discharged directly into the South Branch
Shiawassee River. Information for this site is taken from the 1991
Draft Remedial Investigation Report.
The contamination problem was defined by Michigan Department of
Natural Resources (MDNR) surveys in 1974 and 1977. Widespread PCB
contamination of the river was found downstream from Howell. Fish
populations in this stretch showed elevated PCB levels as well.
PCB levels in river sediments exhibited high concentrations for
10.5 miles downstream from Howell, with the greatest concentration
of hotspots located in the first mile downstream of Cast Forge.
PCB concentrations were found up to 4,800 ppm.
In 1978, Cast Forge signed a Consent Agreement to spend $75,000 on
the evaluation and cleanup of the one mile stretch directly
downstream. In June, 1981, a final Consent Judgement was
promulgated between Cast Forge and the State of Michigan which
included removal of contaminated sediment to reduce PCB
contamination to less than 10 ppm within the 8 mile reach
downstream of Cast Forge. Cast Forge was required to pay $750,000
on the river cleanup alone.
The cleanup was accomplished by the end of 1982. River sediments
were removed by dragline or hydrovacuuming. Vacuumed materials
were dewatered and disposed of in a secure landfill permitted for
PCB-containing wastes. An estimated 2,531 pounds of PCBs were
removed, contained in approximately 1805 yd3 of river sediment and
500 yd3 of sand and gravel (used for onsite treatment) . Solid
wastes were separated by PCB concentrations (greater or less than
50 ppm) and disposed of in the appropriate landfills.
Despite the amount of material removed, the cleanup fell short of
MDNR expectations. A greater extent of contamination than
initially anticipated, coupled with low cost estimates and cost
overruns, resulted in the cleanup of only 1.5 river miles rather
than the 8 originally planned.
In 1981, Cast Forge sold the property to Kelsy-Hayes/Western Wheel,
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a manufacturer of aluminum tires for the automotive industry. In
September, 1983, under the CERCLA, the South Branch Shiawassee
River was determined to be an uncontrolled hazardous waste site and
was put on the NPL list of Superfund sites. MDNR functioned as
the lead agency in performing the CERCLA Remedial
Investigation/Feasibility Study (RI/FS) for the site. Studies
through 1986 of PCB accumulation in fish species on the 10 mile
reach below the facility indicated levels in excess of 2 ppm, the
Food and Drug Administration's recommended limit. The Remedial
Investigation began in 1986 principally to characterize the extent
of the PCB contamination in the previously remediated section of
the river as well as 8 miles downstream of this area. The draft RI
was completed in January 1991 and found high PCB concentrations
downstream of the previously remediated area. Average PCB
concentrations were at 1.2 ppm and reached a maximum concentration
of 7.2 ppm. PCB levels in the previously remediated 1.5 mile
stretch were at levels above the 10 ppm cleanup criteria of the
1982 remediation. Additional investigations will be needed for the
final RI.
The completion of the RI will be followed by the performance of a
Feasibility Study (FS). Potential remedial alternatives will be
developed and evaluated and will lead to a selection of a remedy.
2) Crab Orchard National Wildlife Refuge - Carterville, Illinois
Crab Orchard National Wildlife Refuge is located in southern
Illinois near the city of Carterville. The refuge consists of
approximately 43,000 acres of multiple-use land. The land is used
as a wildlife refuge and also for recreational, agricultural and
industrial purposes. It is owned by the U.S. Government and is
currently administered by the U.S. Fish and Wildlife Service
(USFWS), a Bureau of the Department of the Interior (DOI). The
Refuge was previously administered by the Department of Defense
(DOD) during which times portions were leased to industrial
tenants, primarily for the purpose of munitions and explosives
manufacturing. Information for this site is taken from the Record
of Decision.
After World War II the DOD transferred the Refuge to the DOI.
Other industries moved in to occupy the buildings. Explosives
continued to be manufactured as well as PCB transformers and
capacitors, automobile parts, fiberglass boats, corrugated boxes,
plated metal parts, tape, flares and jet engine starters.
The law that created the Refuge mandated a continuing industrial
presence as well as agriculture, recreation, and wildlife
conservation. Industrial development was deemed essential for the
viability of the Refuge.
Disposal activities at the site included dumping of waste material
in unused areas, and landfilling of waste materials in unlined
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landfills which were covered with earth. Liquids may also have
been disposed to surface water bodies and impoundments. No good
estimates exist for total volume of disposed material.
The site was proposed for the NPL in 1984 and finalized on the NPL
in July 1987. The relative roles and responsibilities of other
Federal Agencies and the United States Environmental Protection
Agency (USEPA) at Federal Facilities like Crab Orchard National
Wildlife Refuge are prescribed in Section 120 of CERCLA and
Executive Order Number 12580. DOI and DOD are responsible for
remedial action and compliance with CERCLA, as amended. The USEPA
is responsible for providing assistance and oversight to DOI and
for final remedy selection.
In February, 1986, the USEPA and USFWS entered into a Federal
Facility Initial Compliance Agreement, which required the
performance of an RI/FS. The USFWS, in conjunction with Sangamo
Weston, Inc., a PRP at the site, began an RI/FS in May 1986. In
August 1989, the FS and proposed plans for the first two operable
units were made public. Based on the FS, the USEPA reached a
Record of Decision for final remedy selection at the two operable
units.
An Interagency Agreement (IAG), pursuant to CERCLA Section
120(e)(2) is currently being negotiated between USEPA, DOI, DOD,
and the Illinois Environmental Protection Agency (IEPA). The IAG
delineates Agency roles and responsibilities for the site cleanup.
In July 1989, DOI issued letters pursuant to CERCLA Section 104(e)
in an attempt to identify other PRPs and to help characterize the
extent and type of contaminants at the Refuge.
The conclusions reached in the ROD follow.
Metals Area Operable Unit
Three distinct sites contain soil and sediment contaminated with
the following metals and their highest concentrations:
- Cadmium 780 ppm
- Chromium 889 ppm
- Cyanide 392 ppm
- Lead 166 ppm
Cadmium is the most prevalent contaminant and is the most toxic to
fish. Approximately 5,200 yd3 of sediment are contaminated. The
selected remedy will include:
- Excavation of contaminated soil and sediment;
- Treatment by stabilization/fixation of all excavated soil
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and sediment with metals that are considered RCRA hazardous
because of EP Toxicity to render non-hazardous;
- Onsite disposal of non-RCRA hazardous stabilized/fixed
material and untreated residues exceeding the clean up
targets in a landfill meeting requirements of RCRA
subtitle D and 35 Illinois Administrative Code Part 807;
- A cleanup level of less than 10 ppm will be reached for
cadmium. Achieving this cleanup level will have the
associated result of excavating the other contaminants.
If this requirement is not met, additional sediment
remediation will be required;
- Environmental monitoring during and after remedial
construction to ensure effectiveness of the remedial action.
PCS Area Operable Unit
Four distinct sites contain soil and sediment contaminated
primarily with PCBs (up to 88,000 ppm in sediments) and lead (up to
20,500 ppm). Approximately 1,200 yd3 are contaminated. The
selected remedy will include:
- Excavation of all contaminated soil and sediment;
- Treatment of excavated materials contaminated with PCBs
in excess of established remediation goals using mobile
incineration technology, or in situ vitrification (ISV)
technology, if a demonstration is made that ISV can meet
or exceed the performance standards established for
incinerator technology;
- Cleanup levels of PCBs at less than 0.5 ppm dry weight and
for lead at less than 450 ppm dry weight. If this require-
ment is not met, additional sediment remediation will be
required;
- Stabilization/fixation of residues from incineration and
non-incinerated soil and sediment contaminated with metals
(if determined to be RCRA hazardous because of their metal
leachability), to render them non-hazardous;
- Onsite disposal as per Metal Area Operable Unit;
- Backfilling, placement of low-permeability caps and
closure of areas where contamination is below the
excavation criteria or from where contaminated soil
and sediment have been evacuated;
- Environmental monitoring and maintenance during and
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after remedial construction to ensure the effectiveness
of the remedial action.
3) Davton Tire and Rubber Company - Dayton, Ohio
The Dayton Tire and Rubber Company site is located in Dayton, Ohio
on Wolf Creek, 1.25 miles upstream of its confluence with the Great
Miami River, which discharges to the Ohio River. Dayton Tire was
a subdivision of Firestone Tire and Rubber Company, and operated
the facility from the early 1940s until October of 1980, when plant
operations ceased. From 1981 to 1987, the site was vandalized.
Capacitors and transformers were scavenged for copper, leading to
oil spills and leaks.
On April 3, 1987, an oil sheen was reported on Wolf Creek. The
Ohio Environmental Protection Agency (OEPA) responded to the spill
and determined that approximately 1,600 gallons of PCB-contaminated
oil were released into Wolf Creek, with concentrations in the oil
as high as 22,900 ppm. OEPA requested USEPA assistance in
containing and cleaning up the spill.
The USEPA Superfund Emergency Response Branch conducted an initial
site inspection on April 4 and identified electrical transformers
and large capacitors with numerous oil spills and leaks. Ash and
debris from fires were also noted. Unknown liquid wastes and
asbestos-wrapped pipes and boilers were also present. Soil, water,
and sediment samples were taken. Wolf Creek sediment samples
collected at the site discharge pipe revealed PCB contamination as
high as 6,020 ppm. PCB contamination was also found in the water
and soils. Dioxin and furan were found in specific areas due to
the incomplete combustion of PCBs.
Fish sample results from specimens collected on Wolf Creek and the
Great Miami River by OEPA showed PCB levels ranging from 0.3 to 18
ppm, above the FDA's 2 ppm recommended limit for human consumption.
A public advisory was issued on May 8 to abstain from fishing,
swimming, or participating in water activities in the contaminated
areas of Wolf Creek and the Great Miami River.
Further stream surveys conducted between the site and the mouth of
Wolf Creek revealed that PCBs existed in Wolf Creek sediments at
concentrations up to 1,140 ppm. On June 2, 1987, the immediate
removal of the contaminated sediments were recommended.
The USEPA initiated actions to stabilize the hazardous conditions
at the site and to prevent additional releases. Phase I of the
clean up consisted of a USEPA/OEPA joint effort to contain the oil
spills and secure the site. The site's drainage was intercepted in
order to eliminate further contamination of Wolf Creek and site
security was provided on a continuous basis to eliminate any future
vandalism. From July 28 through August 5, 1987, contaminated
sediments were removed from Wolf Creek, downstream of the site
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where concentrations were at or greater than 25 ppm. If some areas
were deemed high contact areas, the USEPA onsite Coordinator could
authorize removal of sediments at greater than or equal to 10 ppm.
The sediments were containerized onsite and eventually disposed of
offsite at a licensed hazardous waste landfill. Approximately 201
yd3 of sediments were excavated and disposed of in this manner.
Sediments were tested during removal to confirm that cleanup
standards were being met.
Further remedial activities were needed to clean up soil
contamination at the site.
4) Fields Brook - Ashtabula, Ohio
The Fields Brook Superfund site is in the city and Township of
Ashtabula in northeastern Ohio. Various point and nonpoint
industrial sources are believed to have contaminated sediments in
the brook with a variety of organic and heavy metal pollutants.
The Ashtabula River has been declared an Area of Concern (AOC) by
the IJC. It is important to emphasize that the Ashtabula River is
not part of the Fields Brook Superfund Site at this time.
Analysis of fish tissue caught in Fields Brook and the Ashtabula
River prior to 1982 indicated the presence of chlorinated organic
compounds. A health advisory was issued on March 1, 1983,
recommending that people not eat fish in a 2-mile reach of the
Ashtabula River. Because of the possibility of direct contact with
the sediment, movement of the contaminated sediment into the
Ashtabula River, and the possibility of uncontrolled releases of
hazardous materials from the sediment entering the water supply of
the City of Ashtabula, Fields Brook was included by USEPA in August
1983 on the NPL list of uncontrolled hazardous waste sites.
Placement on this list makes a site eligible for remedial funds
under Superfund (CERCLA).
A CERCLA RI/FS was conducted between 1983 and 1986 by USEPA. The
FS recommended:
- Excavation and dewatering of contaminated sediments;
- Incineration of approximately, 8,000 yd3 of
contaminated sediments containing organic contaminants
with higher mobility and the highest ingestion risk, and
approximately 8,000 yd3 of contaminated sediments containing
greater than 50 ppm PCBs;
- Solidification of approximately 25,000 yd3 of
contaminated sediments containing relatively immobile
contaminants and potentially the solidification of the
incinerator ash if it is required to be handled as a
hazardous waste;
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- Construction of a new onsite RCRA/TSCA-type landfill;
- Treatment of water generated during dewatering of
contaminated sediments, during the solidification
process, thermal treatment or during temporary storage.
The ROD followed the above FS recommendations.
In April 1989, a Unilateral Administrative Order was issued
requiring the PRPs, collectively and individually, to undertake
remedial design and pre-design activities of the Sediment Operable
Unit, and a Source Control RI/FS. USEPA would rescind this
Administrative Order with respect to any PRP which signed a Consent
Decree for the overall remedial action to be taken at the site, as
detailed in the 1986 ROD. After eliminating companies who were
taken over, merged, bought out, and gone bankrupt only 19 companies
were named as PRPs.
In 1991, the Solvent Extraction Process, a new technology developed
since the 1986 ROD, was offered by the complying PRPs as a quicker,
cheaper way to treat PCB-contaminated sediments. Besides these
potential advantages, the Solvent Extraction Process may be viewed
as more publicly acceptable than incineration. The USEPA has
completed review of bench scale test results of this process
however many concerns still need to be addressed in regards to the
applicability of solvent extraction as an appropriate treatment
technology for the contaminated sediments of Fields Brook.
As of July 1991, the PRPS had completed first phase sediment
sampling. The results have been submitted but not interpreted.
The design investigation is ongoing. No agreement for
implementation of remedial action has been reached with any of the
PRPs.
The Ashtabula River navigation channel has not been dredged since
1962 and water depths have become critical to recreational as well
as commercial navigation. Contaminated sediments due to pollutants
originating from the Fields Brook Superfund site have impeded the
dredging process and the disposal of the dredge spoils. Chemical
analysis of sediment core samples collected in 1982 indicate
sediment in the Ashtabula River in the vicinity of Fields Brook may
need to be regulated under TSCA because of the presence of PCBs at
concentrations greater than 50 ppm. Remediation of the
contaminated sediments in Fields Brook will help reduce contaminant
loading to the Ashtabula River AOC.
5) Moss-American - Milwaukee county* Wisconsin
The Moss-American site includes the former location of the Moss-
American creosoting facility, five miles of the Little Menomonee
River, and the adjacent floodplain soils. It is located in the
northwestern section of the city of Milwaukee, Wisconsin.
11
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Information on this site is from the 1990 ROD and from personal
communications.
Beginning in 1921, a wood preserving facility was established,
using a 50/50 mixture of creosote and number 6 fuel oil. Kerr-
McGee purchased the facility in 1963 and changed the name to Moss-
American. The name changed again in 1974 to Kerr-McGee Chemical
Corporation—Forest Products Division.
From 1921 to 1971, the facility discharged wastes to settling ponds
that ultimately discharged into the Little Menomonee River. These
discharges ceased in 1971 when, in response to a City of Milwaukee
order, Moss-American diverted its process water discharge to the
Milwaukee sanitary sewerage system. Also in 1971, WDNR ordered
Kerr-McGee to clean eight settling ponds and dredge 1700 feet of
the river after creosote contamination was discovered. The
settling ponds were filled with clean soil, the discharge pipe to
the river was removed, and a twelve foot deep underground clay
retaining wall constructed between the ponds and the river.
In 1973, the USEPA financed the dredging of approximately 5,000
feet of the river, storing most of the creosote contaminated
sediments in an onsite landfill.
In 1974, the USEPA (under the Clean Water Act) and Milwaukee County
filed a complaint seeking an injunction against Kerr-McGee Chemical
Corporation, and to recover costs incurred for studies and cleanup.
While this suit was pending, the facility closed in 1976. In 1978,
the lawsuit was dismissed due to the discovery of inconsistencies
in some data collected. Milwaukee County reached a settlement with
Kerr-McGee in which it received a major portion of the property
which was added to the existing county park corridor along the
river.
Based on soil/sediment contamination and water quality studies done
by USEPA and other agencies from 1970 to 1980 indicating gross
creosote contamination, the site was placed on the NPL list
pursuant to CERCLA. Letters were sent to three PRPs to take part
in a CERCLA RI/FS, but all three declined. The RI/FS was therefore
funded by the Superfund program and was completed in May 1990.
The ROD, based on the RI/FS, addresses remedial actions for the
principal threat to human health and the environment from direct or
indirect exposure contaminants present at the site. These actions
focus on variety of media: onsite soil, groundwater, surface water
of the Little Menomonee River, and sediments of the river.
Contaminants detected in the sediments were primarily carcinogenic
polynuclear aromatic hydrocarbons (CPAHs), similar to the
contamination found in the soils. Sediment contamination was at
approximately 18 ppm CPAHs, which exceeded background levels.
These sediments were found fairly evenly distributed throughout the
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five mile reach of the river between the Site and its confluence
with the Menomonee River. CPAH levels were as high as 500 ppm and
total PAH levels were as high as 5900 ppm. To remediate this
situation, the ROD recommends:
- Construction of a new channel for the Little Menomonee
River;
- Removal and treatment of highly contaminated sediment from
the old channel.
Sediments in Reaches to be Rerouted
1) Remove all visibly contaminated sediment from the old reach of
the river and any sediments containing greater than 388 ppm
total CPAHs. Dredging technique to be determined.
2) Treat the removed sediment to at least 6.1 ppm CPAHs using the
slurry bioreactor process or an alternative as selected by
USEPA.
3) Place treated sediment on the former facility grounds, cover
with a soil cover, and maintain cover for thirty years.
4) Cover sediment containing less than 388 ppm total CPAHs in place
with soil removed from the new channel.
Sediments in Reaches Not to be Rerouted
1) Remove sediment containing total PAH concentrations in excess
of WDNR Sediment Quality Criteria (SQC) of 3 ppm CPAHs or
background, whichever is greater. Background levels to be
determined.
2) Sediments in excess of 6.1 ppm total CPAHs treated by slurry
bioreactor process and disposed of as above.
3) Deposit removed sediments containing less than 6.1 ppm total
CPAHs in old stream reaches of the river.
Soil in New Little Menomonee River Channel
1) Remove soil containing total CPAH concentrations greater than
SQC or sediment background, whichever is greater.
2) Treat soil in excess of 6.1 ppm total CPAHs or background,
whichever is greater, using slurry bioreactor method to at least
6.1 ppm total CPAHs.
3) Dispose of onsite as per above.
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4) Cover removed soil at less than 6.1 ppm total CPAHs in old
reaches of the river.
The river corridor will have habitat, wetlands and woodlands areas
restored. Approximately 5,200 yd3 of contaminated sediments will
be removed.
The above remedial steps minimize the effects of the contaminants
on human health and the environment, and minimize migration of
contaminants downstream to the Menomonee River and, ultimately, to
the Milwaukee AOC.
The USEPA has reached an agreement with Kerr-McGee to do the work
outlined in the ROD and the Statement of Work (SOW), which is used
to implement the ROD. A Consent Decree was signed by Kerr-McGee in
1991 and awaits DOJ signature and lodging. It is hoped that the
Consent Decree will be lodged in 1991 and that work will begin as
soon after as feasible. According to the 1990 ROD, the cleanup
should take 3-4 years at a cost estimated to exceed $25M. The PRPs
have already begun some of the pre-design work.
6) PR Mallory - Cravfordsville, Indiana
The PR Mallory site in Crawfordsville, Indiana, manufactured
capacitors from 1957 to 1969. The facility was totally destroyed
by a fire in 1970 after which the company abandoned the operation.
The company has since been purchased by Duracell International,
Inc.
The site was initially investigated by the Indiana Department of
Environmental Management (IDEM) in 1985 and 1986. Partially buried
capacitors were observed in a ravine that leads into Little Sugar
Creek, and also lying on the ground surface adjacent to the site.
Concentrations of PCBs in the oil inside the capacitors were as
high as 100%.
The USEPA conducted a site assessment in April 1986 \nd found PCB
concentrations up to 165,402 ppm in the soil and 9,635 ppm in the
ravine sediments. Based on the potential threat to public health
resulting from these concentrations, the USEPA issued a CERCLA
Administrative Order in June 1986 to Duracell International, the
successor to PR Mallory, and to the current owners of the site,
that response action be undertaken to eliminate the threat.
Duracell agreed to undertake the work ordered in the Administrative
Order.
The cleanup started in December 1986. Ravine sediments were to be
remediated to 25 ppm PCBs. Sediment sampling in the ravine found
PCB levels upstream of the site from non-detectable levels to
23,000 ppm. The highest concentrations were found immediately
upstream of the site. A sample downstream exhibited a level of 390
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ppm. Contaminant migration through the ravine was controlled by a
series of sediment traps and oil-absorbent booms. The sediment
traps were constructed to encompass the full width of the stream
bed where possible. Each sediment trap was constructed by first
excavating a shallow trench, laying a sheet of filter fabric over
the excavation, and anchoring hay bales in these excavations.
Excavated sediments were dewatered or stabilized in place prior to
placement in an interim storage facility constructed onsite. Upon
completion of the sediment removal, sediment traps were removed and
placed in the interim storage facility. The excavated ravine was
backfilled with clean fill, regraded to promote drainage, and
revegetated. Contaminated soil removals also took place and the
material was placed in the interim storage facility. Dioxin and
furan, resulting from the incomplete combustion of PCBs, were also
found in the soil.
The final phases of the cleanup began in 1990. The contaminated
soils and sediments were removed to a hazardous waste landfill in
Emelle, Alabama. As of June 1990, 60,000 yd3 of contaminated soil
and sediment had been removed at a cost of approximately $28
million. Excavation under a manufacturing facility next to the
site was still to be completed.
In June 1991, sediment sampling took place on Little Sugar Creek,
downstream of the excavated ravine, to determine if any PCB
contamination was present. The results of this sampling have not
been completed.
7) Tecumseh Products Company - Lower Sheboyaan River, Wisconsin
The Lower Sheboygan River and Harbor Area of Concern involves
approximately 14 miles of the river upstream from its mouth and the
entire Sheboygan Harbor. Primary problems include fish and
sediments contaminated with PCBs and a fish consumption advisory.
The Federal Channel within the Sheboygan River and Harbor AOC was
dredged annually and the spoils were deposited in offshore waters
of Lake Michigan by the USAGE from the early 1950s until 1969, when
it was discontinued due to sediment contamination by pollutants and
heavy metals. The USAGE proposed a confined disposal facility
(CDF) to accommodate future dredged materials but this idea was put
on hold due to elevated concentrations of contaminants. The site
was proposed for the NPL of Superfund in September 1985, and was
finalized in June 1986. Prior to beginning any work, the Office of
Superfund contacted PRPs and asked for their participation in the
RI/FS phase of the cleanup. As a result, an Administrative Order
was agreed to by USEPA, the Wisconsin Department of Natural
Resources (WNDR), and Tecumseh Products Company, one of three
identified PRPs, in April 1986.
By the terms of the Administrative Order, Tecumseh agreed to
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conduct an RI/FS whose objective was to characterize the nature and
extent of the problem, and identify and evaluate alternative
remedial actions to address the problem. The RI showed that site
sediments were contaminated with PCBs, chromium, cadmium, lead,
mercury, zinc, and nickel, with PCB concentrations as high as 4,500
ppm.
Tecumseh also agreed to conduct an Alternative Specific Remedial
Investigation (ASRI). This phase of the project will expedite the
clean-up of contaminated sediments in the Sheboygan River by
providing information regarding various emerging innovative
technologies for the treatment of PCB-contaminated sediments.
Tasks to be performed are as follow:
1) The removal of approximately 2,700 yd3 of PCB-contaminated
sediments from the Sheboygan River and their placement in a
confined treatment facility (CTF). During dredging of this
material, silt curtains were used to minimize movement of
sediments into other parts of the river. The CTF will be used
to study enhanced natural biodegradation for the treatment of
PCB-contaminated sediments with contamination levels from 640-
4500 ppm. Dredging was completed in the fall of 1990.
2) An in-situ sediment armoring pilot study in which approximately
13,500 square feet of contaminated river sediments would be
capped in order to minimize the resuspension of contaminated
sediments. The armoring was completed in June 1990.
3) Bench-scale treatability studies of various remedial methods,
including PCB extraction, chemical fixation, armoring,
supplemental biodegradation, and dewatering. These
studies are currently being undertaken.
4) An evaluation of sediment removal technologies and sediment
control devices. This evaluation has been completed and
the results will be issued as part of the Feasibility Study.
5) A comprehensive monitoring program to assess the effectiveness
of the above mentioned methods. This will be ongoing until the
project is completed.
The work done during the ASRI will enhance the quality of the
Feasibility Study for the entire river and harbor cleanup, and as
a noteworthy side benefit, has resulted in the removal of the most
highly contaminated sediments much earlier than the final
remediation action would otherwise had.
Tecumseh is undertaking the second phase of the cleanup during the
Summer of 1991 under a Removal Action Consent Agreement entered
into in the Fall of 1990. The action will involve the removal of
approximately 2,500 yd3 of PCB-contaminated sediments from the
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upper Sheboygan River where it flows through the Village of Kohler.
PCB concentrations range from 410 to 1,100 ppm. The sediments will
be removed to a depth at least 6 inches below previously identified
PCB contamination. A modified clamshell bucket will be used and
silt curtains will be placed around the dredge site to contain re-
suspended sediments. The dredged material will be stored for an
interim period in a 600,000-gallon tank recently constructed on
Tecumseh property, where it will be managed according to all
applicable State and Federal regulations. The tank is equipped with
a leak detection system. These sediments will be removed for
final treatment and disposal as determined in the ROD. The ROD
will be based on the ASRI evaluations, the Feasibility Study, and
public comment on the recommended remedial action to be undertaken.
The final ASRI report is expected in late 1992 with the ROD
anticipated in 1993.
8) Outboard Marine Corporation - Waukeaan. Illinois
The Waukegan Harbor Superfund site in Waukegan, Illinois is within
an International Joint Commission Area of Concern. Sediment
remediation of this site represents a long, protracted period of
negotiations and actions taken to effect the remediation of PCB-
contaminated sediments and to reduce PCB loading into Lake
Michigan.
The Illinois Environmental Protection Agency conducted effluent
sampling of outfalls on Lake Michigan to attempt to identify
sources of PCB contamination. In January 1976, samples taken
during 1975 at outfalls at the Outboard Motor Corporation (OMC) of
Waukegan, Illinois were found to be contaminated with PCBs,
discharging at a rate of 9 to 10 pounds of PCBs per day. Prior to
this discovery, in June 1975, an NPDES permit had been issued to
OMC. The PCB component of the discharge was not reported in the
application and consequently no limits were imposed for PCBs.
From approximately 1959 to 1972, OMC, a recreational marine
products manufacturer, purchased hydraulic fluid containing PCBs
that was used in die-casting machines. Some of the PCBs escaped
from the oil interceptor, diversion and pump system, and were
released. The PCBs were discharged from two locations, one at the
western end of Slip 3 at the northern end of Waukegan Harbor, and
one at the north end of OMC property to the North Ditch which runs
directly into Lake Michigan. The discharge pipe to the harbor was
sealed in 1976 but not before large amounts of PCBs were discharged
into Waukegan Harbor (approx. 300,000 pounds) and on OMC property,
including the North Ditch/Oval Lagoon/Crescent Ditch area, the
parking lot, and Slip 3 (approx. 700,000 pounds). PCB
concentrations in some areas are over 25,000 ppm. It was also
estimated that hundreds of thousands of pounds of PCBs migrated
into Lake Michigan.
In February 1976, following the discovery of these discharges,
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USEPA and IEPA issued an Administrative Enforcement Order for
Compliance with Section 309 of the CWA. This order required OMC to
eliminate PCB discharges from all of its outfalls and to monitor
sediments in order to indicate the nature of the PCB contamination
in the harbor and North Ditch area. OMC took rapid steps to reduce
PCB contamination at the outfalls but negotiations in regard to
sediments were not as successful. The USEPA also requested that
the US Army Corps of Engineers (USAGE) forego maintenance dredging
of Waukegan Harbor, pending the results of a survey of harbor
sediments by USEPA.
OMC and USEPA continued sampling and negotiations on eliminating
PCB discharges. In 1976, OMC declined to act on any sediment
removals. During this year, the Toxic Substances Control Act was
enacted by Congress, banning the manufacturing of PCBs except for
use in closed systems and charging USEPA to regulate PCB disposal.
In early 1978, USEPA and OMC negotiations concerning responsibility
for cleanup of the Harbor and Ditch broke down. In response, a
suit was filed on March 17, 1978 against OMC on behalf of USEPA.
The suit requested that OMC dispose of the North Ditch soils in a
safe manner and dredge and dispose of the contaminated Harbor
sediments. While the suit was being fought by OMC, USEPA continued
to monitor and survey the site to assess the extent of the
contamination.
In 1979, a Regional Response Team (RRT), an interagency regional
planning body, determined that a remedial action was necessary
pursuant to the emergency provisions of Section 311 of the CWA.
The RRT recommended that a bypass be constructed around the North
Ditch but during preparation for construction, new areas of
substantial PCB contamination were found, postponing construction.
In September 1980, a special Congressional appropriation of $1.5
million was put into the USEPA budget to begin the cleanup of
Waukegan Harbor. In October 1980, the RRT was again convened and
determined that a limited remedial action was still necessary to
abate the ongoing uncontrolled release of PCBs from the sediments
to Waukegan Harbor and Lake Michigan. The RRT began to evaluate
alternatives for the remediation and determined that dredging of
the northern-most areas of the Harbor should be undertaken where
sediments were contaminated at concentrations greater than 10 ppm.
Also during 1980, the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA/Superfund) was passed. It
authorized $1.6 billion for five years to pay for the costs of
cleanup of hazardous substances released into the environment and
allowed for the recovery of cleanup costs from the PRPs. While the
RRT viewed the act as a potential source of funds for the proposed
Section 311 emergency cleanup, CERCLA was to play a much bigger
role. Studies and litigation continued under the auspices of the
CWA. However, with the passage of CERCLA, the site began to shift
into Superfund mode. CERCLA gave the USEPA broader and more
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substantial powers to conduct cleanups. The site was proposed for
and put on the NPL list of Superfund. This move initiated the
cleanup mechanisms of Superfund and led to a new type of
enforcement action at the site. The process included conducting an
RI/FS followed by a Record of Decision which selects a remedial
alternative based on the RI/FS. Investigations conducted up until
1984 under the CWA were used as the Remedial Investigation phase of
the CERCLA process.
In 1983, a preliminary recommendation was made by USEPA use Slip 3,
the location of Larsen Marina, as a disposal facility. This would
have effectively forced Larsen out of business. This proposal was
thought to be a more effective means to reduce PCB loading into
Lake Michigan than by dredging the slip and using an alternate
disposal site. The slip and marina were used for purely
recreational purposes. The Superfund remedial process is open to
public comment and this proposed action was received very poorly,
especially by the recreational users of the slip. Due to public
reaction, this proposed remedy was dropped.
A remedy was selected in 1984 by the USEPA which authorized $21
million for the cleanup program. The objective of the ROD was to
clean areas within the site which contained PCB contamination of 50
ppm or greater. Three main areas of contamination were targeted
for remediation: The Upper Harbor and Slip 3; the OMC parking lot;
and the North Ditch/Crescent Ditch/Oval Lagoon area. The remedy
selected consisted of the following elements:
- Dredging of hotspots (greater than 10,000 ppm) from Slip
3 and the North Ditch area, dewatering, fixation and
transport to an offsite chemical waste facility;
- Remaining sediments in Slip 3 would be dredged, dewatered in
lagoons to be built on OMC property, and disposed of in a
containment cell to be constructed above the OMC parking
lot;
- The North Ditch area was to be enclosed with slurry walls
and capped with impermeable clay.
The ROD represented the USEPA's decision on the most cost-effective
cleanup approach.
In 1985, the USEPA's original 1978 lawsuit was withdrawn, allowing
for a future suit under the provisions of Superfund in order to
recover government costs for the cleanup activity. Engineering
design work based on the ROD began in 1984 but was suspended in
late 1985 due to litigation between OMC and USEPA regarding OMC's
denial of USEPA access to OMC property. Such access was essential
to continue the design process. OMC gained a stay on USEPA's
administrative warrant to their property which was eventually
appealed to the U.S. Supreme Court.
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While this litigation was pending before the courts, CERCLA was
amended by SARA. This Act contained broad authority for access to
implement Superfund remedial actions and required the use of
permanent treatment technologies. Shortly after the passage of
SARA, OMC agreed to end ongoing litigation with USEPA over site
access and to begin negotiations to clean up the site.
Negotiations between OMC, USEPA, and IEPA began in late 1986 to
implement the 1984 ROD but as a result of SARA, the remedy needed
to include the use of onsite technology. Therefore, components of
the remedy were modified and embodied in a 1988 Consent Decree. In
March 1989, the ROD was correspondingly modified and the Consent
Decree was then entered into the United States District Court in
April 1989.
By terms of the Consent Decree, OMC was to finance a Trust to
implement the cleanup and to ensure performance of the requirements
of the Consent Decree. The Consent Decree outlined the areas to be
remediated, the methods to be used, and the financial
responsibility, both immediate and long-term, for the cleanup. The
modified remedy required the following steps be taken sequentially:
1) A slip will be built on the east side of the Upper Harbor to
replace Slip 3. Larsen Marine will be relocated from Slip 3 to
this new slip.
2) A double sheet pile cut-off wall will be built to isolate Slip
3 from the Upper Harbor. A water-tight clay slurry wall will be
anchored to the underlying clay till and Slip 3 will become a
permanent containment cell.
3) 8,000 yd3 of sediment in Slip 3 with PCB concentrations
above 500 ppm will be removed and isolated for treatment.
Approximately 30,000 yd3 of sediment in the Upper Harbor
with PCB concentrations between 50 and 500 ppm will then be
removed and placed in the new Slip 3 containment cell.
4) Two other containment cells will be built with a similar design
as the Slip 3 containment cell. One will encompass the
parking lot and the other the Crescent Ditch and Oval Lagoon.
Before construction, all areas containing PCB contamination
over 10,000 ppm will be removed for treatment. PCB
concentrations below this heavily contaminated sediment layer
drop significantly.
5) Material removed from designated hotspots will be treated by a
low temperature extraction procedure which will remove at least
97% of the PCBs by mass. This will separate the PCB oils from
the sediments.
6) Extracted PCB oil will be removed off site for destruction at a
TSCA-approved facility. The treatment facility has not been
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selected.
7) Residual treated soil will be placed in the containment cells
which will be closed and capped. Extraction wells will be used
to prevent migration of PCBs from the cells.
8) All water generated during remedial activities will be treated
on site.
In the Fall of 1989, during pre-design field investigation, addi-
tional contamination in the form of polynuclear aromatic
hydrocarbons were discovered in the soil area of the new slip.
PAHs reflect coking and wood treating operations. This
contamination resulted from a previous land use prior to CMC's
ownership of the property. The discovery of PAHs required a
limited investigation in the area of the new slip and resulted in
the removal of PAH-contaminated soils above 5 ppm. Construction of
the new slip began in October 1990 and as of July 1991 the Slip 3
cutoff wall construction had begun.
The proposed remedy will greatly reduce existing risks to PCB
exposure on OMC property and will improve the water quality of
Waukegan Harbor and reduce PCB losses to Lake Michigan. Treatment
of PCBs onsite is consistent with the goal of SARA to permanently
reduce toxicity, mobility and volume of hazardous materials.
Dredging should begin in November 1991.
9) Westinghouse Electric Corporation - Bloomington, Indiana
The Westinghouse Electric Corporation is located in Bloomington,
Indiana. Up until 1982, it discharged wastewater to the Winston-
Thomas Sewage Treatment facility. In the early 1970s, PCB
contamination was discovered in the effluent of this facility. The
source was determined to be the Westinghouse discharge to the
facility. In the mid-1970s, Westinghouse discontinued the use of
PCBs. The Winston-Thomas facility was closed in 1982 following the
completion of a new wastewater treatment facility south of
Bloomington. Subsequent studies found high PCB concentrations
persisted in fish and sediments in streams in the area. The primary
source of this contamination was determined to be five landfills
used by Westinghouse to dispose of PCB-containing wastes such as
capacitors. Leachate from these landfills flowed into six area
creeks.
In August, 1985, after lengthy negotiations, a CERCLA Consent
Decree was signed between USEPA, IDEM, the City of Bloomington,
Monroe County, and Westinghouse. Westinghouse agreed to remove
650,000 yd3 of contaminated materials from the landfills and creeks
at the site as well as at the contaminated Winston-Thomas Sewage
Facility. Four of the sites are on the NPL list and the cleanup
must be completed within 15 years.
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The landfills were all capped by 1987. Sediment traps were
installed to keep sediments from migrating downstream and stream
water treatment plants were placed on Conard's Branch and Richland
Creek radiating out from the Neal's Landfill. The stream water
treatment plant will treat contaminated stream water at the rate of
1 cubic foot per second (cfs). Treated stream water must be
treated to PCB concentrations of 1 part per billion (ppb) as per a
state-issued NPDES permit. The permit has currently been remanded
back to the State for the consideration of more stringent PCB
limits.
Sediment remediation was completed by October 1988 (see Tetra Tech,
1989) . Sections of the creeks were diverted and dewatered in order
to successfully remove sediments from the bed and banks and to
reduce the amount of water that would need to be treated by the
clarification system. After dewatering, bank and bed excavation
took place. This was followed by high-pressure water to loosen
sediments from the cracks and crevices of the bedrock creek bed.
Directly following, sediments were swept from the creek using a
hydrovacuum. The karst formation and limestone bottom of some of
the sites resulted in pockets of sediments that were difficult to
remove. A total of 4,620 tons of stream sediments were removed.
This material is being stored in an interim facility located at the
Winston-Salem STP as required by the Consent Decree. Westinghouse
will monitor the interim waste facility until they build an
incinerator onsite in order to treat the removed material by
thermal destruction.
Sediment removal appears to have been successful and Westinghouse
will continue to monitor the effects of the removal. PCB levels in
Conard's Branch creek water still exceed I ppb at times due to
natural stream relocation around the sediment traps at the
headwaters of the creeks leading from the landfills and also due to
limited ability of the stream water treatment plant (1 cfs). Final
cleanup and closure of these landfills by Westinghouse should
eliminate this problem.
The USEPA has also issued a CERCLA Section 106 order to
Westinghouse asking Westinghouse to do sampling and remediation on
soils and on a drainage disk that runs off the site. Westinghouse
has submitted a sampling and remedial plan but work has not yet
begun.
Section II
The Clean Water Act
The Clean Water Act (1977, as amended in 1987 and 1990) was
designed to restore the physical, chemical, and biological
integrity of the nation's navigable waters. There are broad,
general requirements under the CWA to locate waters that are not
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meeting water quality standards and, by extension, waters that have
contaminated sediments. Section 304 of the CWA also authorizes the
development of criteria which may apply to dredging and dredged
material disposal assessment, source control, and remediation.
The CWA exercises source control as the first step in mitigating
sediment contamination. Through the issuance of NPDES permits
under authority of Section 402, the USEPA can regulate point source
dischargers. A key issue in any contaminated sediment remediation
is the linkage of downstream contamination to an upstream
discharger. Violations of an NPDES permit have led to civil
penalties in the form of monetary fines and/or sediment
remediation. Section 115 provides the authority to identify the
location of in-place pollutants with emphasis on toxic pollutants
in harbors and navigable waterways. Under Section 404, the U.S.
Army Corps of Engineers, or an authorized State, issues permits
regulating the discharge of dredged and fill material into U.S.
waters. The USEPA has the authority to review the permits prior to
their issuance. If the material is considered contaminated,
dredging may be prevented until an adequate disposal site is found.
Section 309 of the CWA grants federal enforcement authority to the
USEPA over Section 402 and 404 permit violations, particularly if
state actions are judged to be insufficient over a specified time.
This authority plays a very important role in USEPA Region V where
the six member States are in charge of their respective 402
permitting programs. The threat and/or use of federal enforcement
may be needed to assess penalties and to ensure compliance with a
discharger's NPDES permit. Section 309 is seen as a key tool for
present and future contaminated sediment remedial actions.
s
Section 504 authorizes the USEPA Administrator to bring suit on
behalf of the United States to restrain any person from discharging
pollution that presents an imminent and substantial endangerment to
human health or livelihood. From prevention to identification to
enforcement, the CWA provides tools that can be used for
contaminated sediment remediation, although none are designed
specifically for addressing sediments.
The following section details two Region V cleanups done under the
authority of the CWA. While only a few cases of sediment
remediations conducted under the CWA are mentioned in this report,
the amount of contaminated sediments that could be remediated or
could be agreed upon to remediate under the CWA is very large.
Potential cleanups, particularly in the Grand Calumet River/Indiana
Harbor Canal AOC, could be in the millions of cubic yards. It
should be noted that several USEPA Clean Water Actions are
currently being pursued in Region V.
1) uss Gary Works - Gary. Indiana
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The USS Gary Works site in northwest Indiana is located in the
Grand Calumet River/Indiana Harbor Canal (GCR/IHC) Area of Concern.
It is positioned at the headwaters of the east branch of the Grand
Calumet River and is the first major discharger on this branch of
the Grand Calumet River. It is responsible for 60% of the total
flow of the River into Lake Michigan. The plant uses Lake Michigan
waters for steel production and discharges process waters into the
river under an NPDES permit, pursuant to the CWA.
The USEPA filed a complaint against USS in October 1988 under
Section 309 of the CWA which grants federal enforcement authority
to the USEPA over Section 402 NPDES permit violations. The suit
claimed that USS was violating the terms and conditions of its
NPDES permit. The complaint listed violations in the areas of:
- Reporting;
- NPDES Permit limits;
- Unreported spills;
- Unauthorized discharges of process waters;
- Unauthorized discharge points.
Evidence of these violations included Grand Calumet River sediments
contaminated with a variety of pollutants including PAHs, heavy
metals, oil, and grease.
In order to resolve the allegations listed in the 1988 complaint,
USS entered into a Consent Decree with the USEPA in October 1990.
The Consent Decree called for USS to;
- Pay a $1.6 million fine;
- Install $24 million worth of in plant pollution control
and abatement equipment;
- Spend $7.5 million on Grand Calumet River studies and
remediations.
The first portion of GCR activities to be accomplished by USS will
be a $2.5 million Sediment Characterization Plan (SCP), to be
completed by 12/31/91, in order to identify the extent and nature
of the pollution in the Grand Calumet River sediments for the first
12 miles of the river. Sampling of river sediments will be
reflective of the locations of the outfalls at USS and at fixed
points further downstream. Attempts will be made to analyze the
history of discharges at each outfall.
The SCP should be the most definitive sediment study of the River
to date. USEPA, the State, and other dischargers along the River
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will use the data collected for their own GCR sediment remediation
work and development of the Remedial Action Plan. The USS SCP will
quantify and qualify the contaminants in the sediments and will be
used by USS to develop a Sediment Remediation Plan (SRP).
The SRP will focus on sediment remedial action alternatives in the
first five miles of the river from the culvert upstream of USS
Outfall 001 to the Gary Sanitary District POTW discharge outfall.
It is estimated that up to 500,000 yd3 of contaminated sediments in
this stretch of the river may need remedial action. The SRP will
address the best method for GCR sediment remediation including the
possibility of recycling the sediment back into the steel-making
process at the USS Gary plant. USS used to routinely recycle
sediments in order to recover its high metal content. This
practice was stopped by the passage of the Clean Air and Clean
Water Acts, which prohibited emissions associated with the
recycling process. If this project is proposed and approved, it
will be the first major recycling effort of river sediments back
into a steel-making process to be conducted in the U.S. since the
passage of these acts. In order for this project to be successful,
the oily fraction of the sediments need to be removed prior to
burning, and volatilization must be controlled. If this sediment
recycling project is successful, it could be a boon to the area and
solve a major problem for all of the steel industries in northwest
Indiana. The completed Sediment Remediation Plan is due by
9/30/92.
The remediation of the East Branch of the Grand Calumet River will
be the first step in what is hoped to be a thorough remediation of
the river's entire length. The cleanup of this heavily
industrialized area may serve as a demonstration for future
sediment remedial actions. The use of the CWA as an enforcement
tool here and in other Grand Calumet River sites points to its
usefulness in these remedial actions.
2) USS - Lorain, Ohio
The USS Lorain steelmaking facility is located in Lorain, Ohio on
the banks of the Black River, an IJC Area of Concern. Discharges
from this facility contributed to the degradation of the Black
River. In January 1979, a civil action was brought against USS by
the USEPA. The action claimed that USS was in violation of the
terms of its NPDES permit issued pursuant to the CWA. Negotiations
were entered into and led to a Consent Decree issued in June 1980.
By the terms of this Consent Decree, USS agreed to pay a $4 million
penalty. Of this amount, $1.5 million was to be spent on a dust
suppression program at the facility. Because of operation closures
at the Lorain Plant, USS did not spend $1.5 million on dust
suppression.
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In order to resolve the unspent outstanding $1.5 million
expenditure, USS and the USEPA entered into negotiations which
resulted in an agreement that required USS to remove and dispose of
50,000 yd3 of sediments from the Black River. The 50,000 yd3 was
to be removed from an area of the river previously identified as
having the highest concentrations of steelmaking coke plant wastes
commonly referred to as polynuclear aromatic hydrocarbons. PAHs
are of concern because they have been shown to produce tumors and
lesions in benthic fish populations. Heavy metal contamination was
also an issue. Sediment sampling took place on the river and high
concentrations of PAHs were found at levels exceeding 50 ppm.
Cadmium was also found at levels exceeding 30 ppm and studies found
tumors in Black River fish. A civil penalty of $200,000 was also
included in the settlement.
Actual dredging of the river was initiated in the fall of 1989.
Because of delays due to weather conditions and mechanical
failures, the 50,000 yd3 of sediments were finally removed by the
Fall of 1990. A landfill was constructed on USS property for
sediment disposal in accordance with all state and federal
regulations. Runoff and leachate from the landfill are collected
and treated in accordance with an NPDES permit.
The dredging and removal of the contaminated sediments should help
alleviate some of the water quality problems encountered in the
Black River AOC.
Section III
Resource conservation and Recovery Act/
Toxic substances Control Act
The Resource Conservation and Recovery Act's overall objectives are
to minimize the generation of hazardous waste and to treat, store,
and dispose of hazardous wastes so as to minimize present and
future threats to human health and the environment. All treatment,
storage, or disposal facilities (TSD) must meet detailed design,
operation, maintenance, and monitoring requirements before
receiving a RCRA operating or closure permit. RCRA provisions
could require a permittee to remediate sediments contaminated as a
result of releases of hazardous wastes from a TSD facility. Under
Section 3004(u), the USEPA can require corrective action for all
releases of hazardous waste or constituents from any solid waste
management unit at a TSD facility seeking a 3005(c) permit to
operate such a facility, regardless of what time the waste was
placed in the unit. And under Section 3004(v), the USEPA is
directed to establish standards requiring corrective action for
releases from a TSD facility that have migrated beyond the facility
boundary. Section 3008(h) provides for federal assessment of
penalties for violations of compliance with disposal permits,
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including violations of applicable regulations and standards.
While none of the cleanups detailed in this report were conducted
under a RCRA corrective action, RCRA still plays a significant role
in contaminated sediment remediations. Contaminated sediments
and/or treatment residues may be classified as a RCRA hazardous
waste and consequently would require treatment and/or disposal at
a RCRA disposal facility. One scenario requiring sediments to be
handled as a RCRA hazardous waste would be if they failed the
Toxicity Characteristic Leaching Procedure (TCLP) test. Note
however that sediments need not be classified as a RCRA hazardous
waste in order to be remediated under RCRA corrective action
authority. Disposal of large quantities of materials in a RCRA-
approved facility can be very expensive. This cost can be further
exacerbated if the sediment and/or treatment residue have PCB
concentrations at greater than 50 ppm. In this case they come
under the authority of Section 6 of TSCA. Sediments at this
concentration or higher must be disposed of at a TSCA-approved
facility.
Section IV
State Actions
State actions for the remediation of contaminated sediments have
followed both regulatory and non-regulatory paths. Many of the
contaminated sites are discovered via water quality sampling and/or
violations of NPDES permits. All six states in Region V issue
these permits in their respective states with USEPA oversight.
State enforcement can result in monetary penalties and a remedial
action. If the party who the action is taken against refuses to
comply, the case may be referred to the USEPA for enforcement.
Often, parties prefer to reach an agreement with the state before
the federal government is called in.
Some states have authority similar to CERCLA. Both the States of
Ohio and Michigan have their own Superfund-type enforcement
actions.
For some sites, the threat of some sort of enforcement action may
be enough to bring PRPs into negotiations. Some of the cleanups in
this section have occurred without an enforcement action and have
been considered successful. An issue of concern in such cleanups
is the status of future liability on the part of the PRP. A
voluntary cleanup agreed to by all parties involved should not be
construed as absolving any of the PRPs from future actions.
Non-regulatory State measures include federal grants to finance the
cleanup of sites where there is no liable party. One such grant
source is the Clean Lakes Program, administered by the USEPA under
authority granted in the CWA.
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Another grant source is the Coastal America Program. It is a
cooperative effort between the U.S. Fish and Wildlife Service, the
U.S. Army Corps of Engineers, the USEPA and the National Oceanic
and Atmospheric Administration. These four agencies contribute to
a fund designed to support protection, prevention, restoration and
remediation in coastal water bodies.
The last type of state cleanup discussed in this section is a
demonstration project being conducted by the State of Wisconsin's
Sediment Management and Remediation Technologies (SMART) program.
Through voluntary contributions and state funding, SMART hopes to
create a model for other urban waterway cleanups throughout the
State.
1) ALCOA - Lafavette, Indiana
The Aluminum Company of America (ALCOA) plant in Lafayette, Indiana
discharges to Elliott Ditch, a tributary of Wea Creek, which flows
into the Wabash River. In 1982, ALCOA contracted to have a PCB
survey conducted on Elliott Ditch and Wea Creek. This survey was
requested by the Indiana State Board of Health. Survey results
showed fish and sediment to be contaminated with PCBs beyond state
allowable limits. Further studies indicated that an unknown non-
point source on ALCOA property and not discharges associated with
manufacturing processes, was the cause of the contamination.
Although ALCOA effectively reduced loadings to the ditch and creek,
as indicated by a 1984 study, sediment levels remained constant.
A Consent Decree was signed by the State of Indiana and ALCOA in
January, 1985, requiring ALCOA to meet 1 part per billion (ppb) PCB
limits at all discharge points. ALCOA installed treatment
facilities in order to meet these levels. No action on sediment
removal was taken at this time. ALCOA felt that contaminated
sediments would be topped by clean sediments and that any attempted
sediment removal would remobilize PCBs into the water column.
While the State of Indiana wanted a removal of sediments, such an
action was delayed pending further studies of the receiving streams
in an attempt to find the exact extent of sediment contamination.
Based on subsequent studies by ALCOA, and especially on the report
entitled Historical Data Analysis of Elliott Ditch/Wea Creek
Watershed (August, 1988), PCB sediment hotspots at concentrations
greater than 50 ppm were identified in a one mile reach of Elliott
Ditch/Wea Creek, starting at a point 100 feet upstream of ALCOA'S
discharge point. ALCOA submitted a work plan to IDEM in June 1990
for the immediate removal of hotspots in this reach. IDEM approved
the workplan and a contractor was selected to do the remediation.
The remediation took place from September 1990 to April 1991
(following information after "Elliott Ditch Documentation Report,
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1991) . The remedial method involved placing an upstream and
downstream dam in order to divert the water from a section of the
of the waterbody and allowing the water to be treated between the
dams. This water was treated to below .0005 mg/1 and discharged
downstream. An Interlocutory Agreement between IDEM and ALCOA was
signed on 10/9/90 allowing for discharge of the treated creek water
at this level. The sediments were then excavated and solidified by
mixing with lime and pugged flue dust. When an area was completed,
the system was shut-down and moved downstream to the next area.
Solidified materials exhibiting TSCA-level contamination was
disposed of at the Chemical Waste Management Facility in Emelle,
Alabama. The remainder of the solidified material was classified
as Special Waste (less than 50 ppm) and disposed of at an
appropriate landfill in Indiana. A total of 12,346 tons (5600 yd3)
of material were removed (68% Special Waste, 32% TSCA Waste).
ALCOA will conduct post-monitoring of the stream after it returns
to a steady state. The state of Indiana is interested in water
quality specifications being met during this phase.
2) Dana Corporation - Churubusco, Indiana
In the Spring of 1986, PCB contamination was found in sludge from
the Churubusco, Indiana Sewage Treatment Plant (STP). The STP
discharges to several drainage ditches which join together to form
a stream which provides the headwaters of the Eel River. PCB
concentrations in the ditches were found at levels up to 7290 ppm.
The source of this contamination was determined to be the BRC
Injected Rubber Products plant site which was previously owned by
the Dana Corporation. IDEM held meetings in 1986 with the City of
Churubusco, BRC Injected Rubber, and Dana Corporation in order to
formulate a clean-up plan for the site. Manufacturing processes at
BRC Injected Rubber were found not to be responsible for the PCB
contamination. The PCBs were discharged while the plant was under
Dana Corporation ownership. Dana Corporation agreed to pay for a
voluntary clean up of the STP and the drainage ditches.
The clean-up took place in the summer of 1987. The site was
cleared of vegetative matter and the ditches were diverted.
Diverted water was treated to 0.1 ppb and discharged downstream of
the diversion dams. The stream and ditch beds were excavated by
backhoe to a depth of 12-18 inches although sediment tests had
indicated the depth of contamination was only 6 inches. Cleanup
criteria were set for sediments at the surface to 12 inches below
at 1 ppm and from 12 inches downwards at 10 ppm. Confirmation
sampling of the sediments was done during excavation to ensure
cleanup standards were met. Excavated sediments were stabilized
with kiln dust, if necessary, and trucked to a PCB landfill in
Ohio. No post-monitoring of the sediments was required because the
confirmation sampling confirmed that cleanup levels had been
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attained.
3) Deer Lake, Michigan
Deer Lake, a 906 acre impoundment, is located in central Marquette
County in Michigan's Upper Peninsula. The lake is connected to
Lake Superior by the Carp River. The Deer Lake AOC includes Carp
Creek, Deer Lake, and the Carp River. Mining iron ore is the major
industry in the area but occurs outside the lake's drainage basin
at this time. The following information is taken from the 1987
Deer Lake Remedial Action Plan (RAP). Information from after 1987
was gathered from personal communications.
As determined by the IJC, degradation of the fisheries in the lake
and its major tributaries is the AOC's use impairment. Fish were
contaminated with mercury in excess of the U.S. Food and Drug
Administration (FDA) action level of 1.0 ppm wet weight and the
State of Michigan Consumption Advisory level of 0.5 ppm. Fish
consumptions and health advisories were issued for these waters in
1981 and 1982 and are still in effect. Levels of mercury in Deer
Creek sediments were very high (10-15 ppm) near the mouth of Carp
Creek.
The major sources of pollution contributing to elevated levels in
fish are believed to have been discharges of mercury from the old
Ishpeming, Michigan Wastewater Treatment Plant (WWTP) and combined
sewer overflows (CSOs). The major source of mercury to the WWTP
was the Cleveland Cliffs Iron Company (CCI) laboratories. Mercuric
chloride was used in ore assays and research. Disposal of spent
reagents was curtailed in 1981 when severe fish and sediment
contamination was discovered. Sediments in the lake may continue
to be a source of mercury, as well as other minor potential sources
such as leachate from mine tailings and atmospheric deposition.
In 1982, the State of Michigan filed suit against CCI seeking
injunctive and other relief to remedy mercury pollution of Deer
Lake. CCI agreed to analyze the nature of the contamination and to
develop a plan for restoration. In the Fall of 1984, the
restoration plan was implemented. The lake outflow dam was
partially opened and the lake was drawn down to its lowest level in
order to eradicate contaminated fish and further minimize human and
wildlife exposure. Fish leaving the impoundments were killed. In
Winter 1985, the Michigan Department of Natural Resources netted
and killed an additional 1,500 pounds of fish. In the fall and
winter of 1986-1987, the remaining fish were killed with rotenone.
CCI dug a channel to divert the flow of Carp Creek around the lake
in order to prevent downstream transport of rotenone. MDNR
estimated that approximately 90% of the fish in the impoundment
were killed.
In the Fall of 1984, a Consent Judgement was signed between MDNR
and CCI, outlining a plan for monitoring and restoration of Deer
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Lake and held CCI financially responsible. CCI would also make
access available to other area lakes to compensate for the
temporary loss of Deer Lake as a fishing resource.
The monitoring program outlined a 10 year sampling regime for fish,
sediment, water, and ice that formed over tailing piles. In the
Spring of 1987, the outflow dam was partially closed and Deer Lake
water levels were allowed to be stabilized near the top of the dam.
The water level will stay at this level for 10 years, until 1997.
By maintaining a constant water level, instead of draining and
filling the lake as in the past, sediment agitation should be
minimized. This will help prevent the resuspension of mercury from
the sediments into the water column. Over this 10 year period,
clean sediments entering the impoundment should cover up the
contaminated sediments and render them relatively immobile.
One of the key goals of this plan is to create an uncontaminated
fishery in the lake and its tributaries. MDNR introduced large
numbers of perch and walleye into the lake in 1987. Mercury levels
in fish still only allow for catch-and-release fishing but it is
anticipated that at the end of the 10 year monitoring phase, fish
mercury levels will be comparable to other lakes in the area.
Mercury levels in lake sediments have greatly improved. Surficial
sediment values were at 15 ppm for mercury before remediation and
are now down to 8.3 ppm. Monitoring will continue until 1996.
4) Double Eagle Steel - Dearborn. Michigan
The Double Eagle Steel Coating Company is located in Dearborn,
Michigan on the Rouge River. From Spring until August 1986, due to
a design malfunction in the company's wastewater treatment plant,
levels of zinc far in excess of the company's NPDES permit were
discharged into the Rouge River, including quantities of up to
three tons per day. Sampling by the MDNR did not find markedly
high levels of zinc in the river sediments. It was theorized that
stormy weather caused scouring of the river bed and dispersed the
zinc downstream. The case was referred to the Michigan Attorney
General's Office for enforcement action. A Consent Decree was
signed in October 1986.
By the terms of the Consent Decree, Double Eagle Steel agreed to
undertake a dredging program in the Rouge River to remove the
excess zinc deposits. The cost of dredging and disposal was not to
exceed $800,000. Penalties were negotiated at $850,000 less a
$75,000 credit for the cost of a study to improve the design flaw,
and an additional $100,000 for enforcement and alleged damage to
aquatic life.
The dredging was completed in September 1987, with the removal of
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39,325 yd3 of sediment, from the company's outfall to approximately
200 yards downriver. The sediment was disposed of at the USAGE
confined disposal facility at Point Mouillee, Michigan. Post-
monitoring of effluents have showed no indication of renewed zinc
discharge violations.
5) Hitatchi Magnetics Corporation - Edmore, Michigan
The Hitatchi Magnetics Corporation at Edmore, Michigan was and is
the site of a mercury cleanup on an unnamed drain that leads into
Wolf Creek. Prior to 1973, General Electric owned the facility
and dumped large amounts of mercury into the drain. In the mid
1970s, the GE plant was closed while treatment facilities were
installed under orders from the Michigan Department of Natural
Resources. The plant was subsequently sold to Hitatchi.
In 1984, further testing by MDNR found more mercury contamination.
MDNR classified the drain sediments as heavily polluted with
mercury for about one mile downstream of the facility's outfall,
and also reported high levels of cadmium, chromium, copper, nickel,
lead, zinc, and oil and grease within 1,700 to 2,400 feet
downstream of the outfall.
After negotiations between MDNR, Hitatchi and General Electric, it
was agreed that General Electric would pay for the cleanup.
Although the initial intent of MDNR was an Administrative Consent
Agreement, they agreed to General Electric performing the work
without a Consent Decree.
The cleanup of the drain commenced in August 1986. Sediments
contaminated with mercury at levels at or greater than 1 ppm were
excavated and disposed of at a Michigan Act 641 licensed landfill
if they contained levels of mercury less than 170 ppm (non-
hazardous) as established by MDNR. Mercury-contaminated sediments
at greater than 170 ppm were classified as hazardous and required
disposal in TSCA-approved disposal facility. Verification testing
indicated mercury at .15 ppm in the drain after dredging.
PCB contamination was also encountered in association with mercury
levels above 1 ppm. These sediments were also dredged and disposed
of at the Act 641 landfill if at less than 50 ppm or at the TSCA
facility if at greater than 50 ppm. Verification testing indicated
PCBs at .13 ppm. The drain was filled with new soil. The cleanup
was completed in April 1987 and was overseen by MDNR (see Beak,
1987) .
While this drain cleanup is considered a success, a new ditch dug
for an outfall is now contaminated with mercury. Hitatchi has
changed its production process to a closed-loop system in order to
eliminate any future mercury discharges. Studies are currently
being undertaken to determine the level of mercury in the new
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ditch. No new enforcement action has been taken as of yet.
6) Dayton Power and Light Company - Davton. Ohio
In March 1983, the Ohio Environmental Protection Agency was called
in to investigate a source of an oil spill and to implement
possible remedial measures on an unnamed drain that flowed into
Opossum Creek. Upon investigation, OEPA discovered numerous
capacitors and transformers. OEPA determined that the site had
been used to salvage oil for approximately 12 years. During
salvaging, residual oil from transformer casings was drained on the
ground. The oil contained PCBs in various concentrations. Samples
of soil, water, sediment and oil were collected by OEPA in March
and June 1983 and revealed PCB contamination exceeding 50 ppm.
Based on these findings, OEPA determined that there may be an
imminent and substantial endangerment to the public health and
welfare or the environment and that action had to be taken to
prevent these endangerments.
On November 22, 1985 an Administrative Order was signed between the
Dayton Power and Light Company (DPL) and OEPA. DPL had already
engaged in extensive site characterization and remedial activities
with OEPA oversight. By the terms of the Administrative Order, DPL
agreed to remedial activities for the soils and sediment on the
site as well as post-monitoring to ensure the success of the
cleanup.
Contaminated sediments were to be removed to less than 25 ppm PCBs.
The unnamed drain was rerouted and sediment with PCB concentrations
above 25 ppm were excavated and shipped offsite to the CECOS PCB
Landfill in Ohio. An additional tool employed during excavation
was the use of "discovery" trenches to provide a cross section of
an area off of, or away from, the main excavation. This enabled
personnel to examine a face up to eight feet deep for any length
desired. After information was obtained and/or samples taken, the
trench was backfilled. The excavated drain was also backfilled
with clay and the entire site was seeded by October 1986. The
total amount of material removed was over 1,600 cubic yd3. No
differentiation was made between soils and sediments.
Two years of post-closure monitoring was completed in December 1990
and cleanup standards were met. Monitoring well closure is the
last step to be completed.
7) Lake Lansing, Michigan
Lake Lansing, a small lake (approx. 450 acres) located near
Lansing, Michigan, was treated with sodium arsenite for macrophyte
control in 1957. Since that time, the Lake had become eutrophic.
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A decision was made by the Ingham County Drain Office to maintain
adequate recreational depth and to retard eutrophication through
dredging. This project was seen as a demonstration of the
effectiveness of dredging as a technique for lake restoration.
Federal funding was received through the Clean Lakes Program as
administered by the USEPA under Section 314 of the Clean Water Act.
The grant required pre-dredging and post-dredging studies to
document ecological changes due to dredging (see Michigan
Department of Natural Resources, 1985, and Siami, 1981).
Sediment chemistry data prior to dredging was limited and contained
information only on arsenic, the principal heavy metal of concern.
The MDNR conducted the post-dredging study in 1984 and concluded
that arsenic levels had decreased 60% since 1979 and agreed with
studies that arsenic concentrations would reach background levels
by the late 1980s (17-20 ppm).
During dredging procedures, 1.6 million yd3 of sediment were
dredged and disposed of at an upland facility. Disposal proved to
be the most controversial part of the project. Eventually, three
spoil sites were obtained from private easements. Solids were
settled out of the dredged material and the water was returned to
the lake. Post-dredge testing indicated that arsenic and other
heavy metals were not remobilized by the dredging procedure. The
lake was deepened by 9.0 feet and the trophic status of the lake
went from highly eutrophic to meso-eutrophic.
The project was completed in 1984 and there was a one year post-
monitoring period for arsenic due to public health concerns but no
problems were encountered.
8) Little Lake Butte Des Morts, Wisconsin
In 1989, the WDNR began developing a comprehensive Sediment
Management and Remedial Technologies (SMART) program. One
component of the program involved selecting a few sites for cleanup
demonstration projects and/or Remedial Investigation/Feasibility
Studies. Two sites have been selected for these studies. Little
Lake Butte Des Morts and starkweather Creek.
Little Lake Butte Des Morts is part of the Lower Fox River System.
It is the first impoundment downstream from Lake Winnebago. There
is a fish consumption advisory and a waterfowl consumption advisory
due to high levels of PCBs, presumably coming from PCB-contaminated
sediments, which may be due to paper industries located on the
river. Because Little Lake Butte Des Morts is the most upstream
source of PCBs to the Lower Fox River, removal of hotspots would
provide a decrease in PCB loading levels to the Lower Fox and
Southern Green Bay. Remedial action at this site is recommended by
the Green Bay RAP and is supported by the Green Bay PCB Mass
Balance Study. The last seven miles of the Lower Fox River and the
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southern part of Green Bay contain the highest concentration of
paper and pulp mills in the world and is an IJC AOC. Information
on this site is from the 1991 Request for Proposal (RFP) and from
personal communications.
A soft sediment deposit in the southwest corner of the lake
contains approximately 1650 kg of PCBs in a volume of approximately
56,000 m3 of sediment. This represents about 31% of the total mass
of PCBs in the Lower Fox River but only 2% of the contaminated
sediments by area and volume. By removal or in-place isolation of
this hotspot, this demonstration project will virtually eliminate
this deposit as a PCB source to the Lower Fox River. An adjacent
abandoned landfill will also be evaluated for potential PCB
contributions.
WDNR sent out an RFP to conduct the RI/FS and is now in the process
of rewarding the contract. The RI/FS will review the current
literature regarding contaminated sediment confinement and disposal
techniques, and identify the most environmentally sound and cost-
effective alternative for remediation. An engineering design based
on the selected remediation will follow. It is anticipated that
the remediation will begin in the Fall of 1992.
A variety of funding mechanisms are being used on this project.
The RI/FS will be supported by $100,000 from the State of Wisconsin
and a $100,000 grant from the USEPA. A request for a $50,000 grant
from the Coastal America Program is expected in Fall, 1991, to help
pay for the final engineering design. An additional proposal for
$1,100,000 from the Coastal America Program is hoped for Fall, 1992
to support the actual remedial action. The Coastal America Program
is a cooperative effort between the U.S. Fish and Wildlife Service,
the U.S. Army Corps of Engineers, the USEPA and the National
Oceanic and Atmospheric Administration. These four agencies
contribute to a fund designed to support protection, prevention,
restoration and remediation in coastal water bodies, including the
remediation of contaminated sediments. Approximately $21 million
will be divided amongst seven Coastal America defined regions. WDNR
has met with a PRP, seeking cooperation for the cleanup on a
voluntary basis. It is hoped that the PRP will contribute over
half the cost of any remediation. There has been good cooperation
from the PRP but the issue of where the PRP's liability ends still
needs to be resolved.
9) Starkweather Creek - Madison, Wisconsin
Starkweather Creek, which flows into Lake Monona in the City of
Madison, has been chosen as a SMART demonstration project in order
to show how an urban waterway impacted by polluted sediment can be
restored. Contaminated urban waterways are common in Wisconsin and
it is hoped that the restoration of Starkweather Creek will serve
as a model for sites elsewhere in the state. WDNR is actively
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publicizing the project in order to inform the public as to the
importance of clean urban waterways.
Starkweather Creek is affected by a variety of pollutants.
Industrial wastes have led to mercury, zinc, lead, oil, and grease
contamination in the bottom sediments. These sediments are
periodically scoured by high water flows, carrying pollutants
downstream to Lake Monona. Nonpoint pollutants also impact on the
water quality of the creek. Some of these contaminants have led to
excessive underwater plant and algae growth, reduced populations of
aquatic organisms, smothered fish habitat, lower dissolved oxygen
levels in the water, and unsightly or smelly conditions in area
neighborhoods. Project plans include:
- bottom sediment removal and disposal;
- stream bank improvements and landscaping;
- in-stream aeration to restore dissolved oxygen;
- potential construction of a northern pike rearing pond;
- better public access, along with possible improvements
in walking and biking paths.
Sediment removal will have the effect of improving the creek*s
water quality, protecting Lake Monona from further contamination,
improve fish habitat, and increase public use and enjoyment of the
stream. Creek dredging will be done by backhoe and the material
will be dewatered in a dyked sediment storage facility. WDNR
testing of the creek sediments has found that the level of mercury
and other contaminants lie within current regulatory limits
allowing for land disposal. The dried sediments may be ultimately
used to amend agricultural soils or as a daily cover in local
landfills.
Funding for the cleanup will come from a cooperative effort between
the WDNR, the City of Madison, and Dane County. The estimated cost
of the project is $500,000. The project is actively seeking
contributions from local private industries. Because of the
diverse and convoluted history of pollution of the creek, there is
no action at this time to attempt to locate PRPs for cost recovery.
Starkweather Creek is also part of the Yahara-Monona drainage basin
which has been designated a 'Priority Watershed' under Wisconsin's
Nonpoint Source Pollution Abatement Program A nonpoint source
control plan is now being developed for the watershed. This effort
will allow the City of Madison to receive up to 70 percent of the
funding needed to prevent nonpoint pollutants from entering the
creek in the future. The project is expected to be completed by
Fall, 1991.
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if incorporated - Circleville, Ohio
The PPG Industries, Inc. Coatings and Resins plant is located in
Circleville, Ohio. The facility used oils containing PCBs in a
heat transfer system until 1972. Pipes used to circulate the oil
leaked into sewer drains which discharged to Scippo Creek. The
Creek feeds into the Scioto River. PPG discovered PCB
contamination while removing sediments from their sewer system.
Tests of these sediments revealed high levels of PCBs. PPG
notified the Ohio Environmental Protection Agency of their
discovery. An informal agreement was reached calling for PPG to
remediate the stream. This was subsequently changed to a formal
agency order from the OEPA Division of Emergency and Remedial
Response, the state equivalent of the Federal Superfund Program.
The first set of sediment samples from Scippo Creek were taken in
the Spring of 1988. These samples showed PCB concentrations as
high as 300 ppm adjacent to the PPG sewer outfall, with
concentrations declining downstream. Areas of PCB concentration
greater than 10 ppm were identified for removal. During this time,
1260 tons of dirt and soil located near the leaking pipes were
removed and sent to a chemical waste landfill. Stormwater was
diverted to a treatment plant onsite and a new sewage outfall was
constructed which discharges into Scippo Creek downstream of the
original.
Sediment remediation of Scippo Creek, based on the September 1989
Workplan, took place in October of that year. The first 50 feet of
the creek downstream of the sewer outfall were excavated to the 10
ppm level. The creek was diverted into a newly dug bed and silt
curtains were employed to minimize sediment transport downstream
during the initial diversion activities. The 50 feet area was
cordoned off by dams at either end and the sediments were
stabilized in place before excavation and transport to a chemical
waste landfill.
Unanticipated high levels of contamination were found during
excavations. Concentrations of up to 710,000 ppm PCBs were
concentrated at a sand/gravel and till interface and at 37,000 ppm
in iron oxide layers in some sandbars. The creek bed was excavated
to this till layer and a total of 675 tons of the most highly
contaminated sediments and gravels were removed. Two contaminated
sandbars with concentrations up to 83 ppm still need to be removed.
Post-removal sampling of surface sediments by PPG indicated
concentrations of less than 10 ppm beyond 50 feet downstream of the
outfall. OEPA has requested that PPG conduct a more in-depth
sampling of the downstream sediments and for a Risk Assessment
study to determine the effects of the PCB contamination on human
health and the environment. A fish consumption advisory issued by
the Ohio Department of Health for Scippo Creek is still in place.
Based on additional sediment sampling and a Risk Assessment Study,
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more sediment remediation may be required at this site.
Conclusion
There have been a number of successful contaminated sediment
remediations in USEPA Region V. While they may not all have taken
the same path and may have not employed the same legal and
technical methods, they all should succeed in achieving the desired
purpose of improving water and bottom sediment quality. Hopefully,
the sites currently undergoing remediation will also reach this
goal. Remediating contaminated sediments prevents their
resuspension and uptake into the water column. This limits the
amount of possible bioaccumulation and the threats posed to human
health and the environment. Cleaner sediments can also limit the
amount of contaminants absorbed and/or consumed by the benthic
community. This will lead to healthier organisms up the food chain
as well.
The statutory powers used in many of these remedial actions have
varying degrees of effectiveness, depending on the site. CERCLA,
as amended, addresses closed or abandoned hazardous waste sites
that pose an imminent hazard to human health and the environment.
CERCLA actions can be of an emergency nature, responding to a
sudden hazardous situation, or of a remedial sort, where no
immediate danger is present. CERCLA is very effective in emergency
response situations such as the abandoned PR Mallory site where
emergency actions can be taken quickly, with attempted cost
recoveries from PRPs follow. In the remedial response situation,
the identification of, and an agreement with a PRP may facilitate
remediation. Most of the CERCLA cleanups examined in this report
involved the remediation of the entire site and not just
contaminated sediments. Cleanups at CERCLA sites are increasingly
including sediment remediation as a part of the total site remedy.
Source control may need to be instituted at the site itself before
any sediment action takes place. Site-specific factors will
determine the method and order of cleanup.
Removal actions conducted under the CWA (as amended), often come
about due to violations of a discharger's NPDES permit. These
violations lead to direct degradation of water quality, impaired
usages of a water body, and/or contaminated sediments. Enforcement
actions under the CWA to date have had a good rate of success due,
in part, to the ability to trace contaminants to their sources.
Many of the sources are still actively discharging wastewaters.
This is in contrast to CERCLA, where the original polluters or PRPs
may be out of business. CWA cleanups have the ability to address
both the source and the effects of illegal discharges, as does
CERCLA. By forcing compliance with NPDES permits, CWA is able to
practice effective source control on the pollutants, both from the
point source and the sediment source. This will help to cleanup
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the waterbody. The Resource Conservation and Recovery Act may also
be used at interim status or permitted TSD facilities to effect a
removal action, although none of these removals are addressed in
this report.
State actions often occur due to the discovery of NPDES violations
and other water pollution control programs as administered by
states in the region. As is the case with the CWA, State
enforcement may include compliance with NPDES permits and a
sediment remediation of some sort. If a State cannot reach
agreement with a discharger, the USEPA may become party to the
enforcement effort. Some of the state actions in this report led
to an agreement without the use of any enforcement action. Often,
the threat of using such enforcement will be enough to bring
parties into negotiation and will lead to an agreed upon remedial
action. Several State actions have been and are currently non-
regulatory in nature. Sites remediated under the Clean Lakes
Program and state in-place pollutant initiatives fall under this
category.
From a technical standpoint, removal via dredging is the remedial
action of choice at the moment, with silt curtains being employed
to limit remobilization when appropriate. Treatment of these
sediments is most commonly done by dewatering on site, with
disposal in the proper landfill, depending on the level of
contamination. In situ armoring of sediments is being examined as
an option at the Sheboygan River Superfund Site. Demonstration
projects being conducted by USEPA through the ARCS program may lead
to new removal, treatment, and disposal methods that will achieve
better levels of cleanup.
While there are a number of enforcement methods used to achieve
contaminated sediment remediation, no one method can be seen as
more effective than another. Site-specific conditions, the level
of threat to human health and the environment, and the availability
of a PRP are all factors that need to be considered when attempting
a remedial action. To be sure, some steps could be taken to make
the identification and remediation of contaminated sediments
quicker and easier. National Sediment Quality criteria would help
aid in the determination if sediments are contaminated. This may
help block many legal challenges to enforced cleanups and could
lead to easier enforcement measures and help industries better
comply with water quality standards. Demonstration projects will
help identify the most technologically sound means of remediating
sediments, aside from the classical approach of dredging and
placing the material in a landfill or confined disposal facility.
The taking of these steps will help the States and Federal agencies
in Region V effect remedial actions of contaminated sediments in a
more efficient and thorough manner and improve water quality
throughout the region.
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