- I 7 - 2_
OOOR83001
SUPPORT DOCUMENT F6R THE
NATIONAL PRIORITIES LIST
PREPARED BY
HAZARDOUS SITE CONTROL DIVISION
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEPTEMBER 1983
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ABSTRACT
Pursuant to Section 105 of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), the U.S.
Environmental Protection Agency published a proposed National
Priorities List of 418 hazardous waste sites on December 30, 1982.
On March 4, 1983, the Agency added to the proposed NPL the Times
Beach, Missouri site. In response to the proposed NPL, ฃhe Agency
received 348 public comments. The purpose of this document is to
provide the detailed rationale that the Agency used to respond to
these comments. In summary, 231 sites were commented on, 92 hazard-
ranking system scores were changed as a result of an analysis of the
technical information submitted arid new data developed, 7 sites were
removed from the proposed list and 7 proposed sites are still under
consideration.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
1.0 INTRODUCTION 1-1
1.1 Background for the National Priorities List 1-1
1.2 Development of the National Priorities List 1-2
1.3 The EPA Hazard Ranking System 1-6
1.4 Organization of This Document 1-9
1.5 Glossary 1-9
2.0 REGION I COMMENTS 2-1
2.1 Beacon Heights, Beacon Falls, Connecticut 2-1
2.2 Laurel Park, Inc., Naugatuck Borough, Connecticut 2-2
2.3 Solvents Recovery Systems, Southington, Connecticut 2-4
2.4 Yaworski, Canterbury, Connecticut 2-10
2.5 Baird & McGuire, Holbrook, Massachusetts 2-11
2.6 Cannon Engineering, Bridgewater, Massachusetts 2-13
2.7 Charles-George, Tyngsborough, Massachusetts 2-15
2.8 Groveland Wells, Groveland, Masschusetts 2-16
2.9 Hocomonco Pond, Westborough, Massachusetts 2-19
2.10 Industri-Plex, Woburn, Massachusetts 2-20
2.11 New Bedford Harbor, New Bedford, Massachusetts 2-22
2.12 Nyanza Chemical, Ashland, Massachusetts 2-23
2.13 Cannon Engineering Site, Plymouth, Massachusetts 2-24
2.14 PSC Resources, Palmer, Massachusetts 2-26
2.15 Re-Solve, Dartmouth, Massachusetts 2-27
2.16 Silresim, Lowell, Massachusetts 2-28
2.17 Wells G&H, Woburn, Massachusetts 2-30
2.18 McKin Company, Gray, Maine 2-32
2.19 O'Connor Site, Augusta, Maine 2-33
2.20 Pinette's Salvage Yard, Washbum, Maine 2-34
2.21 Saco Tanning, Saco, Maine 2-36
2.22 Winthrop Landfill, Winthrop, Maine 2-38
2.23 Auburn Road Landfill, Londonderry, New Hampshire 2-43
2.24 KES-Epping, Epping, New Hampshire 2-45
2.25 Sylvester, Nashua, New Hampshire 2-46
2.26 Tinkham Site, Londonderry, New Hampshire 2-47
2.27 Forrestdale, North Smithfield, Rhode Island 2-51
2.28 Landfill and Resource Recovery, Inc., North Smithfield
Rhode Island 2-52
2.29 Peterson-Puritan, Lincoln/Cumberland, Rhode Island 2-57
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TABLE OF CONTENTS (Continued)
2.30. Picillo Coventry, Coventry, Rhode Island 2-58
2,31-..Western Sand and Gravel, Burrillville, Rhode Island 2-60
2ซ32- .Old Springfield Landfill, Springfield, Vermont 2-62
2.,33-r Pine Street Canal, Burlington, Vermont 2-63
3..0- REGION II COMMENTS 3-1
3.1 A. 0. Polymer, Sparta Township, New Jersey 3-2
3.2 American Cyanamid Co., Bound Brook, New Jersey 3-4
3.3 Bridgeport Rental and Oil Services, Bridgeport,
New" Jersey 3-7
3.4 Combe Fill North Landfill, Mt. Olive Township,
New Jersey 3-8
3.5 CPS-Madison Industries, Old Bridge Township,
New Jersey 3-10
3.6 Fair Lawn Well Field, Fair Lawn, New Jersey 3-12
. 3.7 Gems Landfill, Gloucester Township, New Jersey 3-13
3.8 Helen Kramer Landfill, Mantua Township, New Jersey 3-14
3.9 Imperial Oil, Marlboro Township, New Jersey 3-15
.4-3L.10 King of Prussia, Winslow Township, New Jersey 3-18
..i-3j.11 Lipari Landfill, Pitman, New Jersey 3-24
v.3,12. Maywood Chemical Co., Maywood/Rochelle, New Jersey 3-25
3.13 NL Industries, Pedricktown, New Jersey 3-29
3.14 Renora Inc., Edison Township, New Jersey 3-35
; ,,3,. 15 Rockaway Township Well, Rockaway Township, New Jersey 3-37
-.3.16 Sharkey Landfill, Parsippany/Troy Hills, New Jersey 3-39
. ;3.17 South Brunswick Landfill, South Brunswick, New Jersey 3-41
-,.3.18 Syncon Resins Site, South Kearney, New Jersey 3-42
'3.19 Toms River Chemical, Toms River, New Jersey 3-45
,"3.20 Universal Oil Products, East Rutherford, New Jersey 3-50
".-3'.21 U.S. Radium Corp., Orange, New Jersey 3-54
,3.22 Batavia Landfill, Batavia, New York 3-56
3.23 Fulton Terminals, Fulton, New York 3-59
-3.24 G. E. Moreau, South Glens Falls, New York 3-60
:, 3.25 Hooker (Hyde Park), Niagara Falls, New York 3-61
, 3.26 HookeV (S Area), Niagara Fans, New York 3-63
c-.3.27 Hooker (102nd Street), Niagara Falls, New York 3-64
J 3.28 Love Canal, Niagara Falls, New York 3-65
-3.29 .Ludlow Sand and Gravel, Clayville, New York 3-67
3.30 Marathon Battery, Cold Springs, New York 3-68
3.31 Mercury Refining, Albany, New York 3-69
3.32 Clean Well Field, Olean, New York 3-70
3.33 Pollution Abatement Services, Oswego, New York 3-71
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TABLE OF CONTENTS (Continued)
3.34 Port Washington Landfill, Port Washington, New York 3-73
3.35 Sinclair Refinery, Wellsville, New York 3-75
3.36 Solvent Savers, Lincklaen, New York 3-79
3.37 Syosset Landfill, Oyster Bay, New .York . 3-82
3.38 Wide Beach Development, Brant, New York '""'!. 3^-83
3.39 G. E. Wiring Devices, Juana Diaz, Puerto Rico - 3-84 ^
3.40 RCA, del Caribe, Barceloneta, Puerto Rico",,
4.0 REGION III COMMENTS ' 4-1
4.1 Delaware Army Creek, New Castle 4-2
Delaware City PVC Plant, Delaware City -' -
Delaware Sand and Garvel, New Castle ";-' - :
Harvey Knott Drum Site, Kirkwood
New Castle Steel Site, New Castle
New Castle Spill Site, New Castle
Tybouts Corner, New Castle County
Wildcat Landfill, Dover
4.2 Tris Spill Site, New Castle, Delaware 4-3
4.3 Limestone Road Site, Cumberland, Maryland , - 4-4
4.4 Middletown Road Site, Annapolis, Maryland / 4-5
4.5 Monument Street Landfill, Baltimore, Maryland 4-6
4.6 Sand, Gravel & Stone, Elkton, Maryland ^ " "- '"'; 4-8 _
4 . 7 Bruin Lagoon , Bruin Boro , Pennsylvania _ .4-JLO ,
4.8 Heleva Landfill, West Ormrod, Pennsylvania \ 4-12
4.9 Hranica Landfill, Buffalo, Pennsylvania , " "" -' 4~16
4.10 Lord-Shope Landfill, Girard Township, Pennsylvania 4-17
4.11 McAdoo, McAdoo, Pennsylvania . - 4-18
4.12 Metal Banks, Philadelphia, Pennsylvania " 4-20
4.13 Moyer's Landfill, Eagleville, Pennsylvania 4-24
4.14 Old City of York Landfill, York County, Pennsylvania 4-26-
4.15 Osborne, Grove City, Pennsylvania 4-27
4.16 Palmerton Zinc Pile, Palmerton, Pennsylvania 4-30
4.17 Presque Isle, Erie, Pennsylvania , . , 4-32
4.18 Westline, Westline, Pennsylvania . , 4-47
4.19 Chisman Creek, York County, Virginia .. " " ..4-50 -
4.20 Matthews, Roanoke County, Virginia . 4-55
4.21 Saltville Waste Disposal, Saltville, Virginia ' 4-56
4.22 U.S. Titanium Corporation, Piney River, Virginia 4-61
4.23 Fike Chemicals, Nitro, West Virginia "" - 4-63
4.24 Follansbee Sludge Fill, Follansbee, West Virginia ', 4-<69
4.25 Leetown Pesticide Pile, Leetown, West Virginia 4-71
4.26 West Virginia Ordnance, Point Pleasure, West
Virginia . ' - 4-72
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TABLE-OF CONTENTS (Continued) A
5.0 REGION IV- COMMENTS .
t , ** ,f
5.1 ,,,Mowbray Engineering, Greenville, Alabama
5.2 , .Perdido Ground Water Contamination Site, Perdido,
.L1 Alabama 5-4
5.3 " Tfiana-Tennessee River, Limestone and Morgan
-.Counties, Alabama 5-5
5.4 , .Alpha Chemical, Galloway, Florida 5-6
5.5 4..1:American Creosote, Pensacola, Florida 5-11
5.6 Brown Wood Preserving, Live Oak, Florida 5-13
5.7 wHollingsworth Solderless Terminal Co., Fort
.Lauderdale, Florida 5-14
5.8 . Kassauf-Kimerling, Tampa, Florida 5-15
5.9 Munisport, North Miami, Florida 5-16
5.10 Northwest 58th Street Landfill, Hialeah, Florida 5-17
5.11 Parramore Surplus, Mount Pleasant, Florida 5-18
5.12 Pickettville Road Landfill, Jacksonville, Florida 5-19
5.13 Pioneer Sand, Warrington, Florida 5-21
5.14 Sapp Battery, Cottondale, Florida 5-22
5.15 Schuylkill Metals, Plant City, Florida 5-23
5.16. Tower Chemical, Clermont, Florida 5-27
5.17 62nd Street Dump, Tampa, Florida 5-28
5.18- B. F. Goodrich, Calvert City, Kentucky 5-29
5.19 "Distler Brickyard, West Point, Kentucky 5-34
5.20-^Martin Marietta, Sodyeco Division, Charlotte,
:, "North Carolina 5-36
5.21-'Murray Ohio Dump, Lawrenceburg, Tennessee 5-41
5.22- North Hollywood Dump, Memphis, Tennessee 5-43
5.23 "Velsicol Chemical Company, Toone, Tennessee 5-49
6.0 REGION V COMMENTS 6-1
6.1.-'- Wisconsin Sites 6-1
6.2 Johns-Manville, Waukegan, Illinois 6-3
6.3 Outboard Marine Corporation, Waukegan Harbor,
, Illinois 6-6
6.4.. , Velsicol Illinois, Marshall, Illinois 6-9
6.5 Envirochem, Boone County, Illinois 6-11
6.6. Fisher-Calo, Kingsbury, Indiana 6-12
6.7' --.Neal's Landfill, Bloomington, Indiana 6-14
6.8; Parrot Road, Allen County, Indiana 6-15
6.9 Cliff/Dow Dump, Marquette, Michigan 6-17
6.10 Gratiot County Golf Course, St. Louis, Michigan 6-21
6.11 McGraw Edison, Albien, Michigan 6-22
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TABLE OF CONTENTS (Continued)
6.12 Packaging Corporation of America, Filer City, Michigan 6-24
6.13 Rasmussen's Dump, Brighton, Michigan 6-31
6.14 SCA Independent Landfill, Muskegon, Michigan .6-32
6.15 Spiegelburg Landfill, Brighten, Michigan 6-^33
6.16 Velsicol Michigan, Marshall, Michigan 6-34
6.17 Burlington Northern, Brainerd/Baxter, Minnesota 6-35
6.18 FMC, Fridley, Minnesota 6^37
6.19 National Lead Taracorp, St. Louis Park, Minnesota .&"41
6.20 Big D Campgrounds, Kingsville, Ohio 6-44
6.21 E. H. Schilling Landfill, Ironton, Ohio 6-45
6.22 Fields Brook, Ashtabula, Ohio 6-47
6.23 Summit National Services, Deerfield, Ohio 6~53
6.24 Van Dale Junkyard, Marietta, Ohio 6-55
7.0 REGION VI COMMENTS 7-1
7.1 Cecil Lindsey, Newport, Arkansas 7-1
7.2 Crittenden County Landfill, Marion, Arkansas '' 7-3
7.3 Fritt Industries, Walnut Ridge, Arkansas 7-6
7.4 Gurley Pit, Edmondsen, Arkansas ' 7-8
7.5 Industrial Waste Control, Ft. Smith, Arkansas 7-11
7.6 Mid-South Wood Products, Mena, Arkansas 7-15-
7.7 Vertac, Inc., Jacksonville, Arkansas 7-16
7.8 Bayou Bonfouca, Slidell, Louisiana - - 7-19
7.9 Cleve Reber, Sorrento, Louisiana ' 7-21
7.10 Old Inger, Darrow, Louisiana n 7-22
7.11 Homestake, Milan, New Mexico - '7-23
7.12 South Valley, Albuquerque, New Mexico 7-27
7.13 United Nuclear Corporation, Churchrock, New Mexico ij -7-30
7.14 Tar Creek, Ottawa County, Oklahoma 7-33
7.15 Harris (Farley Street), Houston, Texas ^-7-41
8.0 REGION VII COMMENTS '" 8-1
r ~ . *
8.1 Aidex Corporation, Council Bluffs, Iowa - 8-1
8.2 Dico, Des Moines, Iowa ''-- 8-2
8.3 Arkansas City Dump, Arkansas City, Kansas - s 8-5
8.4 Doepke Disposal, Johnson County, Kansas '""' 8-6
8.5 Tar Creek, Cherokee County, Kansas - - : 8-7
8.6 Times Beach, Times Beach, Missouri 7 1 - ' 8-10
8.7 Phillips Chemical, Beatrice, Nebraska ? " '8-11
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TABLE OF CONTENTS (Continued)
9.0 REGION VIII COMMENTS 9-1
9.1 California Gulch, Leadville, Colorado 9-1
9.2 Denver Radium, Denver, Colorado 9-2
9.3 Sand Creek, Commerce City, Colorado 9-3
9.4 Wpodbury Chemical, Commerce City, Colorado 9-5
9.5 Anaconda Minerals Company, Anaconda, Montana 9-6
9.6 Milltown, Milltown, Montana 9-9
9.7 Silver Bow Creek, Silver Bow/Deer Lodge Counties,
Montana 9-12
9.8 Whitewood Creek, Whitewood, South Dakota 9-13
9.9 Baxter/Union Pacific, Laramie, Wyoming 9-18
10.0 REGION IX COMMENTS 10-1
10.1 Indian Bend Wash Area, Scottsdale-Tempe-Phoenix,
Arizona 10-1
10.2 Mountain View Mobile Home, Globe, Arizona 10-2
10.3 Tucson International Airport, Tucson, Arizona 10-4
10.4 19th Avenue Landfill, Phoenix, Arizona 10-5
10.5 Aerojet, Rancho Cordova, California 10-6
10.6 Celtor Chemical, Hoopa, California 10-7
10.7 Coast Wood Preserving, Ukiah, California 10-9
10.8 Iron Mountain Mine, Redding, California 10-14
10.9 MGM Brakes, Cloverdale, California 10-20
11.0 REGION X COMMENTS 11-1
11.1 Arrcom (Drexler Enterprises), Rathdrum, Idaho 11-1
11.2 Bunker Hill, Smelterville, Idaho 11-3
11.3 - Flynn Lumber Company, Caldwell, Idaho 11-7
11.4 Gould, Inc., Portland, Oregon 11-9
11.5 Teledyne Wah Chang (Albany), Albany, Oregon 11-12
11.6 Commencement Bay, South Tacoma Channel, Tacoma,
Washington 11-17
11.7 FMC Corp., Yakima, Washington 11-18
11.8 Harbor Island (Lead), Seattle, Washington 11-21
11.9 Kaiser Mead, Mead, Washington 11-24
11.10 Pesticide Pit, Yakima, Washington 11-27
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EXECUTIVE SUMMARY
Pursuant to Section 105 of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), the U.S.
Environmental Protection Agency published a proposed National
Priorities List (NPL) on December 30, 1982 (47 FR 58476). The
proposed NPL listed 418 hazardous waste facilities as defined by
CERCLA and as selected through the use of the EPA Hazard Ranking
System (HRS), taking into consideration the State's priorities. On
March 4, 1983, EPA proposed the addition of Times Beach, MO, to the
proposed NPL (48 FR 9311), bringing the total to 419 sites. Public
comment was solicited on these 419 sites.
The Agency received a total of 348 comments on 231 of the
listed sites. As a result of analysis of the information provided
by these commenters and additional data developed by the States and
EPA, 7 sites were removed from the proposed list and the rank brder
of many others was changed.
The purpose of this document is to provide the public with the
rationale for changes to the NPL made as a result of the analysis of
technical information submitted and new data developed. A summary
of the 92 HRS scoring changes made as a result of this review is
shown below. Comments of a general nature have been addressed in
the preamble to the NPL (48 FR 40658). .
NATIONAL PRIORITIES LIST HRS SCORE CHANGES
HRS Score
State City/County Site Name Original Revised
EPA Region I ;'
.- '"-*
CT Southington Solvents Recovery Service 37.28"' 44.9^3
MA Bridgewater Cannon Engineering .44.20':'. 39.89
MA Groveland Groveland Wells 40.06 40ป-74"
MA East Woburn Wells G&H - 59.20 : . 42.>1
ME Washburn Pinette's Salvage Yard 39.61:: 33;98,
ME Saco Saco Tannery Waste Pits 33;40 43.19
ME Winthrop Winthrop Landfill 40.47 35.62
NH Nashua Sylvester 63.26 63.28
NH Londonderry Tinkham Garage 42.70 43.24.
RI Coventry Picillo Coventry 67.70 53:.63
VT Burlington Pine Street Canal 40.40 40.42
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State City/County
EPA Region II
Site Name
HRS Score
Original Revised
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
PR
PR
EPA
DE
MD
PA
PA
PA
PA
PA
PA
VA
WV
EPA
FL
FL
FL
FL
FL
FL
KY
KY
TN
TN
Mount Olive Twp.
Gloucester Township
Mantua
Marlboro Township
Pittman
Pedricktown
Rockaway Township
Dover Township
Batavia
South Glens Falls
Niagara Falls
Wellsville
Juana Diaz
Barceloneta
Region III
New Castle County
Annapolis
North Whitehall Twp.
McAdoo
Grove City
Palmerton
Erie
Westline
Saltville
Follansbee
Region IV
Galloway
Pensacola
Hialeah
Mount Pleasant
Jacksonville
Clermont
Calvert City
West Point
Lawrenceburg
Memphis
Combe Fill North Landfill 42.44 47.79
Gems Landfill 68.88 68.53
Helen Kramer Landfill 70.06 72.66
Imperial Oil/Champion Chem. 42.69 33.87
Lipari Landfill 72.12 75.60
NL Industries 49.74 52.96
Rockaway Township Wells 44.46 28.90
Toms River Chemical 45.87 50.33
Batavia Landfill 44.16 50.18
G.E. Moreau Site 49.83 58.21
Hooker-S Area 52.58 51.62
Sinclair Refinery 72.01 53.90
G.E. Wiring Devices 42.40 31.24
RCA, del Caribe 31.28 31.14
New Castle Spill
Middletown Road Dump
Heleva Landfill
McAdoo
Osborne
Palmerton Zinc Pile
Presque Isle
Westline
Saltville Waste Disposal
Ponds
Follansbee Sludge Fill
Alpha Chemical Corporation 55.66 43.24
American Creosote 40.44 58.41
Northwest 58th Street LF 49.27 49.43
Parramore Surplus 34.85 37.61
Pickettville Road Landfill 58.75 42.94
Tower Chemical 38.53 44.03
B. F. Goodrich 31.14 33.01
Distler Brickyard 37.62 44.77
Murray Ohio Dump 46.43 46.44
North Hollywood Dump 16.58 19.46
38.43
38.51
41.79
65.32
58.41
46.44
37.20
31.85
53.23
31.89
38.33
29.36
50.23
63.03
54.60
42.93
40.59
31.71
29.52
33.77
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State City/County
EPA Region V
, IL Waukegan
IN Allen County
MI Marquette
M Albien
MI Filer City
MI Muskegon
MI St. Louis
MN Brainerd/Baxton
MN Fridley
,MN St. Louis Park
OH Kingsville
OH Ironton
OH Ashtabula
..OH Marietta
EPA Region VI
'AR Newport
, ,AR Marion
.AR Edmondson
AR Ft. Smith
.,AR Mena
AR Jacksonville
LA Slidell
NM Milan
NM Albuquerque
OK Ottawa County
EPA Region VII
IA Des Moines
KS Arkansas City
KS Cherokee County
NE Beatrice
EPA Region VIII
CO Leadville
CO Denver
CO Commerce City
Site Name
HRS Score
Original Revised
Johns-Manville Corp. 38.82 38.20
Parrot Road 28.58 14.16
Cliff/Dow Dump 34.66 34.50
McGraw Edison Corp. 44.63 33.42
Packaging Corp. of America 51.95 51.91
SCA Independent Landfill 36.36 34.75
Velsicol Michigan 48.78 52.29
Burlington Northern 58.41 46.77
FMC Corp. 74.16 65.50
National Lead Taracorp 50.95 39.97
Big D Campgrounds 34.78 30.77
E.H. Schilling Landfill 40.37 34.56
Fields Brook 51.62 44.95
Van Dale Junkyard 28.73 22.59
Cecil Lindsey
Crittenden County Landfill
Gurley Pit
Industrial Waste Control
Mid-South Wood Products
Vertac, Inc.
Bayou Bonfouca
Homestake Mining Co.
South Valley
Tar Creek
Des Moines TCE 28.91 42.28
Arkansas City Dump 4.23 5.49
Tar Creek 66.74 58.15
Phillips Chemical 29.97 16.32
California Gulch 51.94 55.84
Denver Radium Site 44.00 44.11
Sand Creek 37.00 59.65
35.40
33.10
38.10
36.90
45.43
64.96
36.75
42.29
35.57
58.20
35.60
23.54
40.13
30.31
45.87
65.46
29.78
34.21
42.24
58.15
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State City/County
EPA Region VIII (Concluded)
CO Commerce City
MT Silver Bow/
Deer Lodge
SD Whitewood
WY Laramie
EPA Region IX
AZ
AZ
CA
CA
Scottsdale
Globe
Ukiah
Cloverdale
EPA Region X
ID
OR
OR
HA
WA
WA
WA
Caldwell
Portland
Albany
Yakima
Seattle
Mead
Yakima
Site Name
Woodbury Chemical Co.
Silver Bow Creek
Whitewood Creek
Baxter/Union Pacific Tie
Treating
Indian Bend Wash Area
Mountain View Mobile Homes
Estates
Coast Wood Preserving
MGM Brakes
Flynn Lumber Co.
Gould, Inc.
Teledyne Wah Chang
FMC Corp. (Yakima)
Harbor Island Lead
Kaiser Mead
Pesticide Lab
HRS Score
Original Revised
45.00
63.80
59.50
37.00
40.02
26.46
42.02
34.52
44.87
63.76
63.76
37.24
42.24
30.24
44.73
34.70
41.87
32.84
48.15
32.18
41.79
41.26
33.50
22.96
C32.12
54.27
38.80
34.60
38.07
^29.33
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1.0 INTRODUCTION
The purpose of this document is to describe in detail the
technical responses to public comments received on the proposed
National Priorities List of hazardous waste sites published by the
Environmental Protection Agency on December 30, 1982. EPA's
responses to comments not specific to any particular site, as well
as the Agency's position regarding certain general types of site-
specific comments, have been presented in the preamble to the NPL
(48 FR 40658). The Agency received a total of 348 comments on 231
of the individually listed sites. As a result of analyzing the
information submitted by commenters and additional technical data
developed since the list was published, 7 sites were removed from
the proposed list, 7 sites are still under consideration, and the
rank order of many others was changed.
1.1 Background for the National Priorities List
Section 105 of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) required that the
National Contingency Plan (NCP) be amended to establish procedures
and standards for responding to releases and threatened releases of
hazardous substances, pollutants, and contaminants, including
criteria for determining priorities among releases or threatened
releases for the purpose of taking remedial action. CERCLA Section
105(8)(B) requires that these criteria be used to prepare a list of
national priorities among known releases or threatened releases and
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that, to the extent practicable, at least 400 individual sites be
designated. The amendment to the NCP was promulgated on July 16,
1982 (47 FR 31180). Criteria for determining priorities are
included in the Hazard Ranking System (MRS) which comprises Appendix
A of the NCP (40 CFR 300).
1.2 Development of the National Priorities List
Section 105(8) of CERCLA contemplates that the bulk of the
initial identification of sites for the NPL will be done by the
States according to EPA criteria, although EPA also has independent
authority to consider sites for listing. In most cases, therefore,
States have used the HRS to evaluate sites and have submitted their
priorities to EPA, although in some cases EPA Regional Offices also
scored additional sites using the HRS. EPA reviewed this work and
conducted quality assurance audits on a sample of the sites
submitted for the NPL. The purpose of these audits was to ensure
accuracy and consistency among the various EPA and State offices
participating in the scoring.
On" December 30, 1982, the proposed NPL of 418 sites was
published in the Federal Register (47 FR 58480). The 418 sites
proposed were those receiving an HRS score of 28.50 or higher, a
number selected because it would yield an NPL of at least 400 sites
as suggested by CERCLA. On March 4, 1983, the Agency added to the
proposed NPL the Times Beach, Missouri site, and has considered
comments on that site along with those for the other 418 sites.
1-2
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Based on the comments the Agency has received on each site, as well
as further investigation by EPA and the States, the HRS scores were
recalculated where appropriate to reflect any new data.
As noted above, CERCLA requires that the NPL include, if
practicable, at least 400 sites. The December proposal listed sites.,
having HRS scores of 28.50 or higher, and EPA is continuing to use
the same minimum score for including sites on the NPL. Each entry
on the NPL contains the name of the facility, the State in which it
is located, and the corresponding EPA Region. For informational
purposes, each entry on the NPL is accompanied by a notation on the
current status of response and enforcement activities at the site.
The entries on the NPL are listed in order of their HRS scores,^.
except where EPA modified the order to reflect top priorities
designated by States. The list is presented in groups of 50 sites
each. EPA has grouped the sites in order to emphasize the fact.that
minor differences in HRS scores are not indicators of significantly
different levels of risk and that within groups EPA will consider
the sites as having approximately the same priority for response
actions.
Section 105(8)(B) of CERCLA requires that, to the extent
practicable, the NPL include within the one hundred highest
priorities at least one facility designated by each State as
representing the greatest danger to public health, welfare, or the ,
environment among known facilities in the State. Any site
1-3
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designated by a State as its top priority is, therefore, included
within the one hundred highest priority sites. The States are not
required to rely exclusively on the HRS in designating their top
priority sites, and certain of the sites designated by the States as
their top priority were not among the one hundred highest sites
according to HRS score. These lower scoring State priority sites
are listed at the bottom of the group of one hundred highest
priority sites. All top priority sites designated by States are
indicated by asterisks.
Response actions already taken were not considered in scoring
sites for inclusion on the NPL, for reasons discussed in the
preamble to the final NPL (48 FR 40664).
CERCLA Section 101(22) excludes several types of releases of
radioactive materials from the statutory definition of "release."
These releases are, therefore, not eligible for CERCLA response
actions or inclusion on the NPL (48 FR 40661).
CERCLA Section lll(e)(3) prohibits use of the Fund for remedial
actions at Federally owned facilities. In development of this
priority list EPA has not listed any sites where the release comes
solely from a Federal facility, regardless of whether contamination
remains on-site or has migrated off-site. EPA did, however,
consider eligible for inclusion on the NPL sites where the sources
of contamination near a Federal facility is unclear or not verified,
or -where it is not exclusively the responsibility of the Federal
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Government, on the grounds that, depending on how the uncertainty is
resolved, EPA might be authorized to respond. In these situations,-
the off-site contaminated area associated with this type of release ;
was considered eligible for inclusion. Sites that are not currently-
owned by the Federal Government were also considered eligible for ^
the NPL, even if they were previously owned by the Federal
Government. Finally, non-Federally owned sites where the Federal
Government may have contributed to a release were also eligible for
inclusion (48 FR 40662).
Mining waste releases were considered for the NPL. Comments
questioning this approach are discussed in the preamble to the final-
NPL (48 FR 40663).
Both CERCLA and the Resource Conservation and Recovery Act
(RCRA) contain authorities applicable to hazardous waste
facilities. These authorities overlap for certain sites.
Accordingly, where a site consists of regulated units of a RCRA -
facility operating pursuant to a permit or interim status, it will
not be included on the NPL but will instead be addressed under the .
authorities of RCRA. As further explained in the preamble to the
final NPL (48 FR 40662), only if the facility is abandoned and the
RCRA corrective action requirements cannot be enforced will EPA -?"-
consider listing the site on the NPL for possible response under
CERCLA. EPA does, however, consider eligible for listing on the NPL
those RCRA facilities at which a significant portion of the release
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appears to come from "non-regulated units" of the facility, that is,
portions of the facility that ceased operation prior to January 26,
1983.
1.3 The EPA Hazard Ranking System
This section summarizes the Hazard Ranking System (HRS) used in
evaluating the relative potential of uncontrolled hazardous
substance facilities to cause human health or safety problems, or
ecological or environmental damage. Detailed instructions for using
the HRS are given in Appendix A of the NCP. Uniform application of
the ranking system by each State permits EPA to identify those
releases of hazardous substances that pose the greatest hazard to
humans or the environment. However, the HRS by itself cannot
establish priorities for the allocation of funds for remedial
action. The HRS is a means for applying uniform technical judgement
regarding the potential hazards presented by a facility relative to
other facilities. It does not address the feasibility, desirability,
or degree of cleanup required. Neither does it deal with the
readiness or ability of a State to carry out such remedial action as
may be indicated, or to meet other conditions prescribed in CERCLA.
The HRS assigns three scores to a hazardous facility:
Sjj reflects the potential for harm to humans or the
environment from migration of a hazardous substance away
from the facility by routes involving ground water, surface
water, or air. It is a composite of separate scores for
each of the three routes.
SPE reflects the potential for harm from substances that
can explode or cause fires.
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reflects the potential for harm from direct contact r , ,,
with hazardous substances at the facility (i.e., no
migration need be involved).
Of these scores, only SM is considered for purposes of
including sites on the NPL. The other two scores, 8-,, and S^-,,
may be used to identify facilities requiring emergency attention.
The score for each of the fire and explosion and direct contact
hazard modes and each route of the migration mode is obtained by
considering a set of factors that characterize the potential of the
facility to cause harm. Each factor is assigned a numerical value
(on a scale of 0 to 3, 5 or 8) according to prescribed guidelines.
This value is then multiplied by a weighting factor yielding the
factor score. The factor scores are then combined: scores within a
factor category are added; then the total scores for each factor .
category are multiplied together to develop a score for ground
water, surface water, air, fire and explosion, and direct contact.
In computing S^g or 3,^,, or an individual migration route
score, the product of its factor category scores is divided by the
maximum possible score, and the resulting ratio is multiplied by
100. The last step puts all scores on a scale of 0 to 100.
SM is a composite of the scores for the three possible
migration routes:
SM = __
M 1.73
where: Sgw = ground water route score
Sgw = surface water route scor
Sa = air route score
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The effect of this means of combining the route scores is to
emphasize the primary (highest scoring) route in aggregating route
scores while giving some additional consideration to the secondary
or tertiary routes if they score high. The factor 1/1.73 is used
simply for the purpose of reducing SM scores to a 100-point scale.
The HRS does not quantify the probability of harm from a
facility or the magnitude of the harm that could result, although
the factors have been selected in order to approximate both those
elements of risk. It is a procedure for ranking facilities in terms
of the potential threat they pose by describing:
the manner in which the hazardous substances are contained,
the route by which they would be released,
the characteristics and amount of the harmful substances, and
the likely targets.
The multiplicative combination of factor category scores is an
approximation of the more rigorous approach in which one would
express the hazard posed by a facility as the product of the proba-
bility of a harmful occurrence and the magnitude of the potential
damage.
Throughout this document, references are made to rating factor
"values" and pathway or HRS "scores" which were commented on. Values
refer to the number assigned a rating factor and scores refer to
either the result of a pathway calculation or total calculation
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1.4 Organization of This Document
In order to enhance the usefulness of this document, public
comments are addressed by site, and sites are categorized by EPA
Regions.
General comments not specific to a particular site are
addressed in the NPL preamble (48 FR 40658). These comments
expressed concern about EPA policy decisions regarding several
NPL-related topics.
Commencing with Section 2.0, each section addresses the site-
specific public comments for all sites located in one of the ten EPA
Regions. Not all sites received comments. The sites receiving
comments are arranged alphabetically by State and by site name
within States. For each site, a listing of the commenters is
presented, followed by a summary of the pertinent comments and
details of the Agency responses. A concluding statement indicates
the effect of the comment on the HRS score for the site.
1.5 Glossary
The following acronyms and abbreviations are used throughout
the text. They are presented here in summary as well as the first
time in text to provide easy reference and avoid confusion.
Agency - U.S. Environmental Protection Agency
CERCLA - Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (PL96-510) also known as
Superfund
EPA - U.S. Environmental Protection Agency
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FIT - Field investigation team
HRS - Hazard ranking system, Appendix A of the National
Contingency Plan (47 FR 31219)
HRS Score - Total migration route score (S^) calculated from
use of the hazard ranking system
NCP - National Contingency Plan (47 FR 31180)
NPL - National Priorities List, Appendix B of the National
Contingency Plan (47 FR 58476, 48 FR 9311 and 48 FR
40669)
NPL-### - Public comment index numbers as recorded in Federal
docket
RAMP - Remedial action master plan, see Proceedings from
National Conference on Management of Uncontrolled
Hazardous Waste Sites, November 1982, Washington,
D.C., (pg. 124)
Rating Value - Rating factor numeral assigned in using the hazard
ranking system
RCRA - Resource Conservation and Recovery Act of 1976
(PL94-580)
Sjj - Total migration route score calculated from use of
the hazard ranking system
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2.0 COMMENTS ON REGION I SITES
2.1 Beacon Heights, Beacon Falls, Connecticut
2.1.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.1.2 Summary of Comments and Response
The U.S. Department of the Interior commented that the
Naugatuck River is near this site, and therefore of interest to the
Department because of existing or potential anadromous fish runs.
Consideration of surface waters that may support aquatic life
in the area of the site have been taken into account in the original
scoring. The rating factor for surface water use was assigned a
value of 2 due to the recreational use of surface water in the area
of the site.
The original migration score for this facility was 46.77. No
new technical information was submitted and no change in score was
required. The HRS scores for Beacon Heights are:
Ground Water 79.59
Surface Water 14.55
Air 0
Total 46.77
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2.2 Laurel Park, Inc., Naugatuck Borough, Connecticut
2.2.1 List of Commenters
NPL-205 Updike, Kelley and Spellacy, P.C., Counsellors at Law
representing Laurel Park, Inc. 2/28/83
NPL-L4 Updike, Kelley and Spellacy, P.C., Counsellors at Law
representing Laurel Park, Inc. 2/28/83 (resubmittal
of NPL-205 with revisions)
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83
2.2.2 Summary of Comments and Response
Updike, Kelley and Spellacy presented hydrogeology information
prepared by a technical consultant that indicates low permeability
of bedrock and very low potential for vertical drainage (i.e.,
little potential for migration of contaminants). The commenter
further noted that no contaminants were found in residential wells
at levels above drinking water standards and stated that there is no
conclusive evidence of ground water contamination from the landfill.
In response, sampling in 1981 and 1983 of the on-site wells
show a measurable release of contaminants above background levels.
Residential well data also showed lower, but measurable, levels of
contaminants. The HRS assigns a value for an observed release
because there is strong evidence that substances can migrate from
the site and that more may do so in the future, not because the
release observed is itself a health threat. Therefore, as explained
in Section 3.1 of the HRS, 47 FR 31224, an observed release is
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scored whenever the substances are detected in concentrations higher
than background levels.
The U.S. Department of the Interior commented that the
Naugatuck River is near the site and therefore of interest to the
Department because of existing or potential anadromous fish runs.
In response, consideration of surface waters that may support
aquatic life in the area of the site have been taken into account in
the original scoring. The rating factor for surface water use was
assigned a value of 2 due to the recreational use of surface waters
in the area of the site.
The original migration score for this facility was 46.76.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Laurel Park Inc. are:
Ground Water 79.59
Surface Water 14.54
Air 0
Total 46.76
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2.3 Solvents Recovery Systems, Southington, Connecticut
Renamed: Solvents Recovery Service of New England,
Southington, Connecticut
2.3.1 List of Commenters
NPL-240 Lowenstein, Sandier, Brochin, Kohl, Fisher, Boylan &
Meaner, Counsellors at Law on behalf of Solvents
Recovery Service of New England. 2/24/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
NPL-L27 Lowenstein, Sandier, Brochin, Kohl, Fisher, Boylan &
Meaner, Counsellors at Law. 5/16/83.
2.3.2 Summary of Comments and Response
This site has been inaccurately referred to in the listing of
sites as "Solvents Recovery Systems" and should be referred to as
"Solvents Recovery Service of New England."
The Solvents Recovery Service of New England commented that it
does not agree with the inclusion on the NPL of active waste
management facilities operating pursuant to interim status under
RCRA and facilities which have entered into Consent Agreements with
the Federal government for cleanup of the site. This commenter also
indicates that the listing of the site could affect the company* s
solvency, and therefore jeopardize its ability to satisfy its
efforts to comply with ongoing cleanup activities. Solvents
Recovery Service of New England recommended that facilities such as
theirs (the sites operating under consent decrees or other legally
binding commitments) be identified in a separate appendix to the NPL
if the inclusion of these sites is required by the EPA.
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In response, the existence of a Consent Agreement cannot affect
the HRS score, because the score is based on certain objective "
characteristics of the site before response actions are taken and,
therefore, does not reflect current or prospective response
actions. EPA recognizes, however, the good faith cleanup efforts of
those who have entered into court-sanctioned agreements, and, where
EPA is a party to such an agreement, has identified these sites by
notation in the "Voluntary or Negotiated Response" category of the
NPL. In addition, EPA has determined that if the HRS score places a
site on the NPL, the site must remain on the NPL until EPA
determines that no further response actions are appropriate, or any
other criteria for deletion are met, as discussed in Part VIII of
the preamble to the final NPL.
Even though the facility as a whole may have interim status
under RCRA, the listing of the site on the NPL is based on portions
of the facility that are not "regulated units" under RCRA. EPA's
policy regarding the listing of facilities that may also be subject
to RCRA is discussed in Part VI of the preamble to the final NPL.
The commenter has made a point by point review of the HRS as it
applies to this site in its comments submitted 16 May 1983.
Responses to comments made are addressed in the order they appeared
in the commenter's submittal.
The commenter stated that the major discrepancy it found with
the application of the HRS to the Solvents Recovery Service of New
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England's (SRSNE) facility appeared to result from the application
of the HRS to a "controlled" hazardous waste facility. The
commenter added that the HRS model was developed for the evaluation
of "uncontrolled" hazardous waste facilities.
In response, the Agency's application of the HRS to this
facility and subsequent listing of the site on the NPL is the result
of the Agency's belief that past disposal practices have negatively
affected the environment, and represent an existing potential threat
to the public. References made in the documentation record to
existing structures or operations is done to estimate the magnitude
of the potential impact of the past waste disposal operations. As
the commenter noted in its review of the HRS and its application,
the Agency considers the area of the plant occupied 15 years ago by
an unlined lagoon used to temporarily store still bottoms as the
location or origination point of the hazardous waste contaminants.
In conclusion, the Agency believes its scoring approach to this
facility is correct.
The commenter noted that the abandoned lagoon, which was
excavated, graded and paved over in 1967 does not represent a fire
and explosion hazard. Therefore, the commenter concludes, the HRS
score for evaluation of the fire and explosion threat of the site
should be 0.
In response, the Agency concurs with the commenter's comment
and has changed its scoring to reflect the existing conditions at
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the site. Scoring of the site for potential fire and explosion has
been changed from 35.40 to 0. The fire and explosion score,
however, is not considered for purposes of including sites on the
NPL.
The commenter did agree that the scoring of an observed release
is appropriate if the abandoned lagoon is considered the hazardous
waste site, and that the value of 12 assigned to the rating factor
toxicity/persistence is also correct. However, the commenter states
that the value assigned for hazardous waste quantity should be 1
rather than 8 as originally scored. The commenter states that the
value of 1 should be used for this rating factor because it is
estimated that less than 10 tons of hazardous waste remain as
contaminated soil in the abandoned lagoon.
In response to comments regarding estimates of hazardous wastes
quantities, the HRS requires scoring of sites on the basis of
conditions existing prior to any response actions, as explained in
Part VII of the preamble to the final NPL. One of the rationales
for this approach is that public agencies might be discouraged from
response actions if such actions could reduce the HRS score and,
hence, reduce the chances a site would be included on the NPL. The
commenter is correct that this rationale does not apply to this
site, since the response actions were taken well before HRS scoring
efforts began. Other rationales behind this policy, however,
support its application to this site. As explained further in
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Part VII of the preamble of the final NPL, wastes may have begun
migrating before removal, and contaminants may remain in the
ground. The extent of this possible migration is appropriately
represented by scoring on the basis of the original quantity of
waste. The Agency in scoring this rating factor has used a quantity
of 10,000 drums of waste that had been disposed at the site based
upon historical records identified in the site documentation.
The commenter stated that it disagreed with the target score
of 35 assigned to the rating factor distance to nearest well/
population served. The commenter stated that the value of 24 should
be used for this rating factor, based upon its review of the data
that showed one municipal well located 1-1/2 miles south of the site
serving an estimated 8300 residents.
In the process of re-evaluation of the site in response to
comments, changes were made to the original scoring. EPA determined
that the Quinnipiac River is not a discontinuity in the aquifer, and
found that wells on the other side of that river are used for
drinking water with no alternative supply readily available. This
resulted in the rating factor score for ground water use being
raised from 2 to 3; and the estimated total population served by the
aquifer being revised from 8,300 to 31,000. The change in the
number of people being served by the aquifer caused the distance of
nearest well/population served factor score to be raised from 35
to 40.
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The commenter noted in its review of the surface water route
score that it still disagreed with the estimates used for quantity
of waste at the site. However, it pointed out the fact that the
surface water route score is low whether or not the hazardous waste
quantity rating factor was changed.
The Agency's review of the surface water route scores has
resulted in changes in the original scoring for two rating factors:
surface water use and distance to a. sensitive environment. The
rating factor surface water use value was changed from 1 to 2. This
change was made to reflect the recreational use of surface water in
the site area. The rating factor value for distance to a sensitive
environment was changed from 0 to 1 because a fresh water wetland
1500 feet from the site was identified.
The U.S. Department of the Interior commented that the site is
near the Quinnipiac and of interest to the Department because of
existing or potential anadromous fish runs. In response to this
comment (change noted previously), the value assigned to the surface
water use was raised from 1 to 2 reflecting the potential
recreational use of the surface water.
The original migration score for this facility was 37.28.
Based on the changes noted previously, the HRS scores for Solvents
Recovery Service of New England (Solvents Recovery Systems) are:
Ground Water 76.92
Surface Water 11.19
Air 0
Total 44.93
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2.4 Yaworski, Canterbury, Connecticut
2.4.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.4.2 Summary of Comments and Response
The U.S. Department of the Interior commented that the site is
near the Quinnipiac River and therefore of interest to the
Department because of existing or potential anadromous fish runs.
Consideration of surface waters that may support aquatic life
in the area of the site have been taken into account in the original
scoring. The recreational use of surface waters in the area of the
site was considered in the scoring of the site.
Review of this facility revealed a rounding error in the
calculation of the ground water score. This error has been
corrected although it does not change the migration score.
The original migration score for this facility was 36.70.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Yaworski are:
Ground Water 39.20
Surface Water 8.39
Air 49.23
Total 36.70
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2.5 Baird & MoGuire, Holbrook, Massachusetts
2.5.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation.
An Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
2.5.2 S'urmary of Comments and Response
The commenter noted a discrepancy between the HRS score sheets
and the documentation records for this facility. The commenter
stated that based on the documentation records it reviewed, the
ground water population matrix should have been scored 24 rather
than 40.
The discrepancy noted by the commenter was the result of the
commenter reviewing documentation records that had not been updated
to reflect additional information gathered during a quality
assurance audit conducted 31 August 1982. The audit showed that a
public water supply well within 1000 feet of the site had been
contaminated by the ground water plume migrating from the site. The
contamination of the public water resulted in a population estimate
of 18,200 rather than 5000 as noted in the unrevised documentation
record. This additional information resulted in a value for
population served and value for distance to nearest well of 4 and 5,
respectively. Therefore, the combined ground water population
matrix score is 40.
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The original migration score for this facility was 66.35.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Baird & McGuire are:
Ground Water 100.00
Surface Water 56.36
Air 0
Total 66.35
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2.6 Cannon Engineering, Bridgewater, Massachusetts
2.6.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.6.2 Summary of Comments and Response
A. D. Little, Inc. commented that the scoring of the Cannon
Engineering Site in Bridgewater, Massachusetts, and the Cannon
Engineering Site located in Plymouth, Massachusetts (Cordage Park)
used the same documentation record in scoring the individual sites;
however, different MRS scores resulted.
The commenter has documented a clerical error that did occur in
the copying and attachment of HRS scoring sheets to supporting
documentation records, but has drawn an inacurrate conclusion.
Documentation records for the Plymouth site were inappropriately
attached to the scoring sheets for the Bridgewater site. This
clerical problem has been rectified. Site-specific documentation
records were used and available for the Bridgewater and Plymouth,
Massachusetts sites. The HRS scoring for both sites was
accomplished independently as two facilities, based on site-specific
data for each facility.
The U.S. Department of the Interior expressed concern regarding
the contamination of an unnamed pond in the vicinity of the site.
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In regard to the contamination of surface waters and wetlands,
the site received a 6 (the maximum) factor score for distance to
sensitive environment.
New data developed for the Remedial Action Master Plan for this
facility (RAMP, 1/18/83) has resulted in several changes. EPA found
that the toxicity/persistence value for trichloroethylene under the
ground water waste characteristics had been incorrectly assigned a
value of 18. This rating factor was revised from a value of 18 to
12 for the contaminant trichloroethylene. The surface water value
for toxicity/persistence for methylene chloride was also incorrectly
assigned a value of 18. It was revised to the correct value of 12.
The reactivity and incompatibility factor under the air route was
changed from 1 to 2 to reflect the presence of materials such as
methanol, xylene, cyanide salts (i.e., flammable and oxidizing
materials) which may pose a future hazard.
The original migration score for this facility was 44.20.
Based on the changes noted previously, the HRS scores for Cannon
Engineering, Bridgewater are:
Ground Water 42.39
Surface Water 15.10
Air 52.31
Total 39.89
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2.7 Charles-George, Tyngsborough, Massachusetts
Renamed: Charles-George Reclamation Trust Landfill,
Tyngsborough, Massachusetts
2.7.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.7.2 Summary of Comments and Response
The U.S. Department of the Interior commented that the
Merrimack River is an Atlantic salmon stream. The river is directly
connected to Flint Pond, which is receiving contaminated surface
water runoff.
The location of Flint Pond relative to the site has been
considered in the scoring of the site. A value of 2 for distance to
a sensitive environment was assigned.
The original migration score for this facility was 47.20. No
new technical information was submitted and no change in score was
required. The HRS scores for Charles George Reclamation Trust
Landfill (Charles-George) are:
Ground Water 79.60
Surface Water 18.20
Air 0
Total 47.20
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2.8 Groveland Wells, Groveland, Massachusetts
2.8.1 List of Commetiters
NPL-184, Posternak, Blankstein & Lund, Attorneys at Law,
235, 263 representing the Town of Groveland (NPL-235 and
NPL-263 are resubmissions of the material submitted
as NPL-184)
2.8.2 Summary of Comments and Response
The commenter commented that additional water samples taken
since the site was originally scored and ranked have shown increased
levels of ground water contamination, and requested that the HRS
scores be raised to reflect this higher level.
In response, the HRS assigns a value for observed release for
any valid measurement above background levels, regardless of the
frequency or concentration of the contaminant (i.e., above
background levels). The HRS scoring process does not permit
increasing the score relative to increasing concentrations of
contaminant detected. In any regard, the site was assigned the
maximum value of 18 for toxicity/persistence based upon the type of
contaminant detected and its potential for impact to the environment,
The commenter noted that the ground water route worksheet
should reflect a greater quantity of hazardous waste based upon the
high levels of ground water contamination evidenced by current well
sampling.
The Agency has reviewed the data on this site and has
determined that there are insufficient data to document a greater
waste quantity present at the site. The HRS scoring process does
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not permit increasing the waste quantity value based upon increases
in the concentrations of contaminants found in the ground water
samples. Therefore, the value was left unchanged at 2 for both the
ground water and surface water routes.
The commenter noted that the surface water route should be
assigned a higher toxicity/persistence value based upon the presence
of trichloroethylene and trans-l,2-dichloroethylene found in brooks
near the wells.
In response, a review of data shows three surface water samples
taken at the site contained chloroform. Scoring of the site based
upon the presence of chloroform resulted in the assigning of a value
of 18 for the rating factor of toxicity/persistence. Scoring of the
site based upon the contaminants noted by the commenter would result
in a lower value.
The commenter noted that the site is close to a sensitive
environment and the value for distance to a sensitive environment
ranking should be increased along with an increase in the score for
population served/distance to water intake downstream.
The value given for distance to a sensitive environment was
raised from 0 to 2 to reflect the 18 acre freshwater wetland located
200 feet from the site.
In regard to increasing the score from 0 for population served/
distance to water intake downstream, further investigation by the
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Agency of the site area indicates no water intakes are within
3 miles of the site. Therefore the value was left unchanged as 0.
The original migration score for this facility was 40.06.
Based on the changes noted previously, the HRS scores for Groveland
Wells are:
Ground Water 69.07
Surface Water 13.99
Air 0
Total 40.74
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2.9 Hocomonco Pond, Westborough, Massachusetts
2.9.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.9.2 Summary of Comments and Response
The U.S. Department of the Interior commented that the Hocomonco
pond is used for recreation.
In scoring of the site the rating factor ground water use was
assigned a value of 2 reflecting the recreational use of the pond.
The original migration score for this facility was 44.80. No
new technical information was submitted and no change in score was
required. The HRS scores for Hocomonco Pond are:
Ground Water 75.98
Surface Water 15.38
Air 0
Total 44.80
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2.10 Industri-Plex, Woburn, Massachusetts
2.10.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.10.2 Summary of Comments and Response
The U.S. Department of the Interior commented on the proximity
of the ground water contamination from the site to the Aberjona
River.
The proximity of this river to the facility and its use for
recreation was considered in the original scoring of rating factors
surface water use and distance to a sensitive environment.
An alternative set of scores was submitted for this facility
by A. D. Little, Inc., to illustrate whether two independent
evaluators applying the Hazard Ranking System and using comparable
available data for the same site would develop similar or the same
score.
The A. D. Little, Inc., alternative HRS score of 75 was very
similar to the original HRS score of 72.42. Information provided by
A. D. Little, Inc., noted differences in HRS scores for ground
water, surface water and air migration routes, but provided no
information with its submittal to indicate why differences in
migration scores occurred in its calculations. Because no specific
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information was submitted to indicate why differences occurred, no
response is possible.
The original migration score for this facility was 72.42.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Industri-Plex are:
Ground Water 89.80
Surface Water 21.80
Air 84.60
Total 72.42
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2.11 New Bedford Harbor, New Bedford, Massachusetts
2.11.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.11.2 Summary of Comments and Response
The U.S. Department of the Interior commented that fishing in
the New Bedford Harbor, Buzzard's Bay area is not permitted for
finfish, shellfish, and lobster due to PCB contamination of the
water. The Department noted that the Bay area is used by waterfowl
such as the scaup, brant, eiders, black ducks, and mallards.
The sensitivity of the Bay area was reflected in the scoring
of distance to a sensitive environment with the maximum score of 6.
This concern was already reflected in the scoring of the site.
The original migration score for this facility was 50.73. No
new technical information was submitted and no change in score was
required. The HRS scores for New Bedford Harbor are:
Ground Water 0
Surface Water 21.82
Air 85.00
Total 50.73
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2.12 Nyanza Chemical, Ashland, Massachusetts
2.12.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.12.2 S""""ary of Comments and Response
The U.S. Department of the Interior commented that mercury
contamination of the Sudbury River is possible, however, no
anadromous fish are affected. In addition the Department noted that
the Great Meadows National Wildlife Refuge is 10 miles downstream
along the Sudbury River.
The presence of the Great Meadows National Wildlife Refuge did
not directly affect the scoring for the site. The Refuge is located
beyond the two mile distance limit used in the HRS procedure for
inclusion of sensitive environments in the scoring process.
Although this particular environmental concern was not considered in
developing a score for the site under the HRS, it is noted that
surface water use and distance to a sensitive environment rating
factors received maximum HRS values because of other surface waters
affected that are closer to the site.
The original migration score for this facility was 69.22, No
new technical information was submitted and no change in score was
required. The HRS scores for Nyanza Chemical are:
Ground Water 77.55
Surface Water 63.64
Air 65.38
Total 69.22
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2.13 Cannon Engineering Site, Plymouth, Massachusetts
Renamed: Cannon Engineering Site formerly identified as
Plymouth Harbor/Cordage
2.13.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-253 Massachusetts Department of Environmental Quality
Engineering. 2/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.13.2 Summary of Comments and Response
The Massachusetts Department of Environmental Quality
Engineering recommended renaming the facility the "Cannon
Engineering" site. The Agency is complying with the recommendation
and is renaming the site.
A. D. Little, Inc., commented that the scoring of the Cannon
Engineering site in Bridgewater, Massachusetts, and the site in
Plymouth, Massachusetts (Cordage Park), also owned by Cannon
Engineering, used the same documentation record in scoring the
individual sites; however, different HRS scores resulted.
The commenter has documented a clerical error that did occur
in the copying and attachment of HRS scoring sheets to supporting
documentation records. Documentation records for the Plymouth site
were inappropriately attached to the scoring sheets for the
Bridgewater site. This clerical problem has been rectified.
Site-specific documentation records were used and are available for
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the Bridgewater and Plymouth, Massachusetts sites. The HRS scoring
for both sites was accomplished independently as two facilities,
based on site-specific data for each facility.
The U.S. Department of the Interior commented that Plymouth
Harbor is the principal surface water body of concern.
The close proximity of the site to the harbor is reflected in
the documentation package and the resultant score. Distance to a
sensitive environment was assigned the maximum value for this site.
The original migration score for this facility was 54.82. No
new technical information was submitted and no change in score was
required. The HRS scores for Cannon's Engineering, Plymouth are:
Ground Water 71.43
Surface Water 10.26
Air 61.54
Total 54.82
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2.14 PSC Resources, Palmer, Massachusetts
2.14.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.14.2 S'i"""ary of Comments and Response
The U.S. Department of the Interior commented on contamination
of an adjacent stream and wetlands, and stated that no known
anadromous fish are found in this area. (The Department did not
cite any specific data indicating that surface waters have actually
been contaminated.)
In response to the Department's comment, the Agency has no
data that would indicate that a release into surface waters has
occurred. Scoring for the surface water migration route used a zero
for the observed release rating factor.
The original migration score for this facility was 38.66. No
new technical information was submitted and no change in score was
required. The HRS scores for PSC Resources are:
Ground Water 53.06
Surface Water 40.72
Air 0
Total 38.66
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2.15 Re-Solve, Dartmouth, Massachusetts
2.15.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.15.2 Summary of Comments and Response
The U.S. Department of the Interior commented that the
Copicult River is contaminated but contains no known anadromous fish.
This concern was already reflected in the scoring of the
site. Observed releases were scored for the ground water and
surface water migration routes.
The original migration score for this facility was 47.71. No
new technical information was submitted and no change in score was
required. The HRS scores for Re-Solve are:
Ground Water 79.59
Surface Water 21.82
Air 0
Total 47.71
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2.16 Silresim, Lowell, Massachusetts
2.16.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.16.2 Summary of Comments and Response
A. D. Little recommended a score of 45 be used for this site.
They calculated a HRS score of 45 for this site using data they have
regarding the air emission pathway which includes an observed
release for the air migration route.
EPA has reviewed the available air monitoring data and
concluded that these data are not documented sufficiently for the
purposes of the HRS to warrant the scoring of an air release. The
possibility of migration of contaminants via the air remains of
concern to EPA, however, and the Agency will continue to investigate
this possibility in further examination of the site.
The U.S. Department of the Interior commented that the site is
on the bank of the Merrimack River, an Atlantic salmon restoration
river.
In response to the Department's comment, no data are available
showing that a surface water release to the river has occurred.
Scoring of the site for the surface water route is based upon the
potential for such a release.
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The original migration score for this facility was 42.72. No
new technical information was submitted and no change in score was
required. The HRS scores for Silresim are:
Ground Water 73.47
Surface Water 8.00
Air 0
Total 42.72
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2.17 Wells G&H, Wobu.ru, Massachusetts
2.17.1 List of Commenters
NPL-253 Massachusetts Department of Environmental Quality
Engineering. 2/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.17.2 Summary of Comments and Response
The Department of Environmental Quality Engineering
recommended that the summary description for the Wells G&H site be
amended in accordance with the language it submitted. The
Department recommended that the summary description include
historical information such as: between 1954 and 1979 the wells
provided 25% of the drinking water for the City; 600 homes and 300
businesses were served by these wells; in 1979 chlorinated solvents
were detected in the wells of approximately 500 ppm which resulted
in closure of the wells; and during the period of 1980 through 1982
EPA studies were conducted to determine industries that may have
contaminated the wells and to evaluate the geology and ground water
quality of North and East Woburn.
The recommended language provided by the Department has been
incorporated as requested by the Agency.
The U.S. Department of the Interior noted concern for surface
water contamination of the Aberjona River even though ground water
contamination is of principal interest with well sites.
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This concern was taken into account in the original scoring of
the site by assigning the maximum rating factor of 3 for distance to
a sensitive environment.
EPA reviewed the documentation for this facility and concluded
that the hazardous waste quantities originally estimated for the
ground water and surface water routes were based upon calculations
and estimates of plume size. The Agency believes that the data
available for this site are not sufficient to make estimates of the
quantity of contaminants using plume size. It concluded the
quantity is more appropriately scored as a value of 1, indicating
the fact the quantity of contaminants is unknown at this time.
Thus, hazardous waste quantities were assigned a value of 1 rather
than 8.
The original migration score for this facility was 59.20.
Based on the changes noted above, the HRS scores for Wells G&H are:
Ground Water 73.08
Surface Water 10.91
Air 0
Total 42.71
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2.18 McKin Company, Gray, Maine
2.18.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.18.2 Summary of Comments and Response
The U.S. Department of the Interior commented that ground
water contamination is of primary concern, with the potential for
contamination of the Androscoggin River, used by Atlantic salmon for
spawning.
In response to the Department's comment, investigation of site
data indicate that the potential surface water targets for
contamination are Collier Brook and Royal River which flow to the
Atlantic Ocean. The Agency believes there is little potential for
measurable surface water contamination of Androscoggin River because
of ground water contamination at the site. This conclusion is based
upon the fact that the Androscoggin River is in a different drainage
basin, and the significant distance separating the site from the
river.
The original migration score for this facility was 60.97.
Based on the above response to comments, the score remains
unchanged. The HRS scores for McKin Company areJ
Ground Water 79.59
Surface Water 52.73
Air 44.87
Total 60.97
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2.19 O'Connor Site, Augusta, Maine
2.19.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.19.2 S"""nary of Comments and Response
The U.S. Department of the Interior commented that this site
is located adjacent to a tributary of the Kennebec River. The
Kennebec River is used by Atlantic salmon and two endangered
species; shortnose sturgeons and bald eagles.
In response, it is noted that the Kennebec River is located at
a greater distance downstream from the site than that allowed in the
HRS for scoring of the rating factor distance to a sensitive
environment. There are, however, fresh water wetlands adjacent to
the site which have resulted in the assignment of a maximum score
for the rating factor distance to a sensitive environment.
The original migration score for this facility was 31.86.
Based on the above response to comments, the score remains
unchanged. The HRS scores for O'Connor Site are:
Ground Water 51.63
Surface Water 19.30
Air 0
Total 31.86
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2.20 Pinette's Salvage Yard, Washburn, Maine
2.20.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.20.2 Summary of Comments and Response
The U.S. Department of the Interior commented about the high
potential for contamination by the site of the Aroostock River,
which is inhabited by anadromous fish. The Department's comment
noted that the site is in a wetland adjacent to the river.
In response to the Department's comments, scoring of the site
did consider the recreational use of the Aroostock River, and a
review of the data shows that the wetland is adjacent to the site
located approximately 0.6 mile from the site. This resulted in a
revision to the rating factor distance to a sensitive environment
from a score of 0 to 1.
A further review of the documentation for this facility showed
that the surface water route was inappropriately scored for an
observed release based on the presence of contaminants in a drainage
ditch. Water in the drainage ditch does not directly flow into
surface water and therefore can not be considered an observed
release to surface water in accordance with the MRS instructions.
Because there is no observed release for the surface water route,
scoring of the site was done using route characteristics: facility
slope and intervening terrain are less than 3% and 4%, value
assigned 1; 1-year, 24 hour rainfall is 2.2 inches, value assigned 2;
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distance to nearest surface water is 500 feet, value assigned 3;
physical state of waste is liquid, value assigned 3; and containment
received a value of 3 indicating no active containment measures
being used.
In addition, it was noted that the original score erroneously
assigned a value of 2 for hazardous waste quantity when the
documentation indicated that 789 gallons of waste (value of 1) are
present. This error has been corrected resulting in a value of 1
for this rating factor.
Additional site data review showed that surface water intakes
downstream of the site use the surface water for industrial use
only, not for drinking water as originally scored. This new
information resulted in a change of population served/distance to
water intake downstream from a score of 16 to 0.
The original migration score for this facility was 39.61.
Based on the changes noted above, the HRS scores for Pinette's
Salvage Yard are:
Ground Water 58.16
Surface Water 8.50
Air 0
Total 33.98
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2.21 Saco Tanning, Saco, Maine
Renamed: Saco Tannery Waste Pits, Saco, Maine
2.21.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.21.2 Summary of Comments and Response
The U.S. Department of the Interior commented that the site is
on the Saco River, and that they expect concentrations of Atlantic
salmon below the first dam near the site.
The comment by the Department indicates that it is referring
to a site not on the NPL, but which has a similar name. The Saco
Tanning site listed on the NPL drains to Stewart Brook and Cascade
Brook which join the Scarborough River which ultimately drains to
the Atlantic Ocean. The Saco River is not affected by this site.
The scoring of the site did consider the recreational use of the
brooks by assigning a value of 2 for surface water use under the
surface water migration route category.
Additional sampling information indicated the presence of
hexavalent chrome at this facility. The toxicity/persistence values
under the ground and surface water pathways, which were originally
evaluated on the basis of tetrachloroethylene, have been raised from
12 to 18.
The surface water route worksheet has been rescored on the
basis of route characteristics rather than an observed release. The
samples that document the scoring of an observed release were taken
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from standing water in an on-site disposal pit, which is not defined
as surface water, per instructions given for the HRS model.
The appropriate route characteristic values are: facility
slope and intervening terrain are less than 3%, value assigned Oj
1-year, 24-hour rainfall is 2.5 inches, value assigned 2; distance
to nearest surface water is less than 1000 feet in that the site is
located adjacent to a wetland and tributary of Stuart Brook, value
assigned 3; physical state of the waste is liquid, value assigned 3;
and containment is assigned a value of 3 indicating no active
containment measures being used.
The original migration score for this facility was 33.40.
Based on the changes noted above, the HRS scores for Saco Tannery
Waste Pits (Saco Tanning) are:
Ground Water 74.29
Surface Water 8.00
Air 0
Total 43.19
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2.22 Winthrop Landfill, Winthrop, Maine
2.22.1 List of Commenters
NPL-168 Department of Environmental Protection, State of
Maine. 2/22/83.
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-222 Wald, Harkrader and Ross, Attorneys at Law
representing the Inmont Corporation. 2/28/83.
NPL-L13 Wald, Harkrader and Ross (telecom). 3/14/83.
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.22.2 Summary of Comments and Response
An alternative set of scores was submitted for this facility by
A. D. Little, Inc., indicating that their scoring of the site
resulted in a migration total score of 34 rather than 40.47 as
originally proposed. However, A. D. Little, Inc., did not provide
information that could be used to evaluate its suggested alternative
score changes. Because no information was offered in its submittal
no changes to the scoring could be evaluated.
The Inmont Corporation commented that its review of the HRS
scoring of the site indicated that the 40.47 score assigned to the
site by the NPL cannot be supported with the information gathered for
the scoring process. Inmont Corporation noted that application of
the HRS to the data in the record yields a HRS score between zero and
a maximum of 25.96 (depending on interpretation of HRS manual
guidance), insufficient for listing the site in the NPL. The lower
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scores calculated by the Inmont Corporation resulted due to
disagreement with scoring by the Agency for at least five pathway
factors: waste characteristics for both ground water and surface
water; distance to nearest wells/population served; facility slope
and intervening terrain; and distance to a sensitive environment.
The commenter stated that the record contains no demonstrative
evidence that hazardous substances are present at the landfill
itself, and no evidence whatsoever of specific substances or
quantities at the landfill.
In response, the scores assigned for type of waste and quantity
of waste disposed of at the landfill are based upon confidential
information given to EPA. These reliable information sources
(familiar with industry operations and disposal practices) were used
in determining that the landfill is the source of contaminants found
in a drinking water well. These sources have indicated the type of
wastes disposed of at the landfill and have stated that at least 5000
drums of hazardous wastes were delivered to the landfill. The Agency
has no reason to believe that these sources of information are
anything less than an account of activities that did occur. The
Agency believes the information is accurate and no change is
warranted to these rating factors.
Based upon a review of the data used to score the rating factor
toxicity/persistence, the chemical used as the basis for scoring has
been changed from heptachlor to tetrahydrofuran. The Agency
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concluded that there is no indication from current data available
that heptachlor was disposed of at the site. Therefore, the value
assigned for toxicity/persistence was changed from 18 to 15.
The commenter stated that there was no justification for
considering at risk those people served by wells that are upgradient
of the landfill and could not be contaminated by substances from it.
In regard to the comment concerning the rating factor distance
to nearest well/population served, the population used is based upon
150 people as reported by officials in the Town of Winthrop. As
explained in Part VII of the preamble to the Final NPL, the distance
to the well Is based upon distance (radius) and does not require
consideration of ground water flow direction for scoring of this
factor.
The commenter stated that the Agency misconstrued the
instructions in the HRS for measuring the facility slope and slope of
intervening terrain. The commenter stated that the resultant value
for the rating factor facility slope and intervening terrain should
be 2.
In response to comments regarding values assigned for facility
slope and intervening terrain, an average facility slope of between
5% and 8% can be calculated using reliably made site maps. The
intervening terrain slope, between the site and the nearest
downgradient surface water was calculated as 15%. The resulting
value for this rating factor is 3 and no change is warranted.
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The commenter stated that the record does not support the
assigning of a maximum score for the rating factor distance to a
sensitive environment. The commenter stated that the score for this
rating factor should be 4 rather than the 6.
In response, the site scored the maximum for distance to a
sensitive environment because of 23 acres of wetland adjacent to the
site and the contaminants (tetrahydrofuran) sampled in a monitoring
well located within the wetland. The documentation data have been
revised to indicate the presence of these wetlands in the scoring
process. No change is warranted based upon the commenter's
statements.
The Inmont Corporation further commented that it did not believe
that the designation by the State of Maine of the site as its top
priority site should merit EPA recognition. Comment identified as
NPL-L13 was made to specify that comments made by Inmont Corporation
in its submittal identified as NPL-222 related specifically to the
Winthrop Landfill in Maine.
In regard to listing this site as Maine's top priority site, the
comment received from the Department of Environmental Protection
(DEP), State of Maine (NPL-168), states that it does not wish to
designate this site or any other site as having a higher priority
than any other that may exist. The DEP commented that it has not
specified its most hazardous site nor its highest priority site.
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In response to comments by the DEP, it is sufficient to note
that the site is listed on the NFL based upon its total migration
score and not based upon any designation made by the State of Maine.
The U.S. Department of the Interior commented on the possible
contamination of Lake Annabessacook, which is known for bass,
pickerel, and perch fishing.
In response, scoring of the rating factor surface water use has
been assigned a value reflecting its use for drinking water, which
has a higher HRS rating value than would be given for only
recreational use of surface water.
The original migration score for this facility was 40.47. Based
on the changes noted above, the HRS scores for Winthrop Landfill are:
Ground Water 50.08
Surface Water 35.90
Air 0
Total 35.62
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2.23 Auburn Road Landfill, Londonderry, New Hampshire
2.23.1 List of Commenters
NPL-81 Richard and Monique Cote on behalf of homeowners,
Londonderry, New Hampshire. 1/30/83
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.23.2 Snmiqary of Comments and Response
Richard and Monique Cote expressed their desire to have CERCLA
funds allocated expeditiously so local authorities can provide an
uncontaminated water supply to homeowners that have contaminated
water supplies.
Listing on the NPL makes a site eligible for remedial action
funding, and EPA will examine the site to determine an appropriate
response. Actual funding may not necessarily be undertaken in the
precise order of HRS scores, however, and in some cases may not be
necessary at all. EPA will determine the need for using CERCLA Fund
monies for remedial activities on a site-by-site basis, taking into
account the HRS score, State priorities, further site data, other
response alternatives, and other factors as appropriate. EPA will
keep the public informed of funding decisions and plans for types of
response actions.
The U.S. Department of the Interior commented that Cohas Brook
is a tributary of the Merrimak River, which is an Atlantic salmon
spawning stream.
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In response to the Department's comment, the rating factor for
distance to a sensitive environment surface water use was scored as
recreational, receiving a value of 2. The rating factor received a
value of 2 because the closest surface water is Cohas Brook, 0.25
miles from the site.
The original migration score for this facility was 36.30. No
new technical information was submitted and no change in score was
required. The HRS scores for Auburn Road Landfill are:
Ground Water 61.22
Surface Water 13.98
Air 0
Total 36.30
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2.24 KES-Epping, Epping, New Hampshire
Renamed: Keefe Environmental Services (KES), Epping, New
Hampshire
2.24.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
2.24.2 Snmniary of Comments and Response
The U.S. Department of the Interior commented that the Lamprey
River has runs of coho salmon and summering striped bass near its
mouth at Great Bay.
Recreational use of surface waters and impact to wetlands
adjacent to the site have been accounted for in the scoring.
The original migration score for this facility was 65.19. No
new technical information was submitted and no change in score was
required. The HRS scores for Keefe Environmental Services
(KES-Epping) are:
Ground Water 89.80
Surface Water 14.54
Air 66.67
Total 65.19
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2.25 Sylvester, Nashua, New Hampshire
2.25.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.25.2 S""""^ry of Comments and Response
The U.S. Department of the Interior commented that this site
ultimately drains into the Merrimack River, which is an Atlantic
salmon spawning stream.
Recreational use of surface waters and impact to wetlands in
the site area have been accounted for in scoring.
Review of this facility revealed rounding errors in the
calculation of the ground water and air pathway scores. These
errors have been corrected.
The original migration score for this facility was 63.26.
Based on the changes noted above, the HRS scores for Sylvester,
Nashua are:
Ground Water 90.27
Surface Water 10.49
Air 61.03
Total 63.28
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2.26 Tinkham Site, Londonderry, New Hampshire
Renamed: Tinkham Garage, Londonderry, New Hampshire
2.26.1 List of Commenters
NPL-81 Richard and Monique Cote on behalf of homeowners,
Londonderry, New Hampshire. 1/30/83.
NPL-189 Day, Berry and Howard, Counsellors at Law
representing the Tinkhams. 2/25/83.
NPL-200 Day, Berry and Howard, Attorneys for the Tinkhams.
2/25/83 (with attachments not submitted with
NPL-189).
2.26.2 Simmary of Comments and Response
Richard and Monique Cote expressed their desire to have super
fund monies allocated expeditiously so local authorities can provide
an uncontaminated water supply for homeowners that have contaminated
water supplies.
In response, listing on the NPL makes a site eligible for
remedial action funding, and EPA will examine the site to determine
an appropriate response. Actual funding may not necessarily be
undertaken in the precise order of HRS scores, however, and in some
cases may not be necessary at all. EPA will determine the need for
using Fund monies for remedial activities on a site-by-site basis,
taking into account the HRS score, State priorities, further site
data, other response alternatives, and other factors as
appropriate. EPA will keep the public informed of funding decisions
and plans for types of response actions.
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The Tinkhams commented that the site should either be removed
from the priority list or the site redefined to exclude the steel
garage site (owned by the Tinkhams) from the listing. The Tinkhams
noted in its comment that the Tinkhams' property was placed onto the
NPL solely because of the presence of contaminants in the vicinity
of the Londonderry Green Apartments, and that no evidence exists
that connects the contamination of wells at the apartments with
properties owned by the Tinkhams. Further, the commenter stated
that the Hazard Ranking System score was predicated on assumptions
made about the site that had no basis in fact. Examples offered
were that waste quantity should be scored zero because there is no
data to support a value; scoring of the site was derived without
knowledge of bedrock contours, ground water hydrology, and the
pathways any chemical migration may take. The commenter concluded
that its analysis of the listing process (of the site) and
preparation of its comments was hampered by poor records management
on the part of the regulatory agencies.
In response to the Tinkhams' comments, aerial photographs
indicate areas of no vegetation and stressed vegetation on the
Tinkhams' property, and soil samples taken at the Tinkhams' property
revealed the same contaminants also found in ground and surface
waters at the apartments. Although there is no extensive study of
the area hydrogeology, the following points indicate to the Agency
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that the ground water contamination recorded in nearby wells is
associated with the garage site:
1) Soils in the general area are permeable sands and gravel
(down to a depth of 12 feet).
2) Local road cuts extending to bedrock show bedrock
fracturing is observable and trends northeast to southwest
in the direction of the wells.
3) The Londonderry Green Apartment wells are southwest of the
Tinkhams' garage site.
Given the short distances between the garage disposal area, the
contaminated well located on site, and the above geological factors,
EPA has concluded that there is a high likelihood that the garage
disposal area is the source of the contaminants found in the
apartment well. The commenter has not suggested the possibility or
likelihood that there are other private industries in the area that
could be associated with the contamination. The Agency believes the
documentation available sufficiently supports its designation of the
source of contamination.
The rating factor hazardous waste quantity is not scored zero
because there is an observed release. In the absence of specific
data on quantities of contaminants at the site, the value of 1 was
assigned to the rating factor hazardous waste quantity. Data
indicate that contaminants are at the site; the quantity is unknown
at this time.
The commenter also indicates that data used for ranking were
not sufficient to apply the HRS with confidence. The HRS (which was
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promulgated as Appendix A of the NCP after notice and public
comment) specifies explicit criteria for both the types and quality
of information required for HRS use. This is explained in the HRS
itself, and the accompanying Preamble, published in the Federal
Register July 16, 1982 (40 CFR 300). The Agency believes that the
types and quantity of data used to score the Tinkham Garage site
meet these criteria in the HRS.
Review of this facility revealed that the toxicity/persistence
rating factor in the ground water pathway was assigned an incorrect
value of 18 for trichloroethylene (TCE). However, the presence of
chloroform at the site supports the original value assigned and the
documentation records have been modified to reflect the presence of
this compound. The value for this rating factor in the surface
water pathway has been raised from 12 to 18 and the surface water
documentation has also been modified to indicate the presence of
chloroform.
A review of documentation records for this site revealed
rounding errors in the pathway score calculations.
The original migration score for this facility was 42.70.
Based on the changes noted above, the HRS scores for Tinkham Garage
(Tinkham) site are:
Ground Water 73.08
Surface Water 15.94
Air 0
Total 43.24
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2.27 Forrestdale, North Smithfield, Rhode Island
Renamed: Stamina Mills, Inc., North Smithfield, Rhode Island
2.27.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
2.27.2 Summary of Comments and Response
A. D. Little, Inc., commented that the toxicity/persistence
matrix should receive a value of 15 rather than 12 based on Sax's
high rating ("high" in Sax is equal to a value of 3) for the
toxicity of trichloroethylene (TCE).
In response to the comment, according to Sax the toxicity of
TCE is high only for the intravenous route of exposure. Toxicity
values for releases of hazardous substances are more appropriately
based on Sax's rating of moderate toxicity via oral exposure because
intravenous injection of the contaminant is unlikely. Because the
Agency believes that exposure to the contaminant is most likely due
to oral ingestion, the scoring for the rating factor was not changed.
The original migration score for this facility was 34.07.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Stamina Mills, Inc. (Forrestdale) are:
Ground Water 58.71
Surface Water 5.23
Air 0
Total 34.07
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2.28 Landfill and Resource Recovery, Inc., North Smithfield,
Rhode Island
2.28.1 List of Commenters
NPL-167 Coffey, McGovern, Noel, Novogroski and Neal, Ltd.
Attorneys at Law representing Landfill and Resource
Recovery, Inc. 2/23/83.
2.28.2 Summary of Comments and Response
The commenter presented a hydrogeologic analysis which
indicate: that the aquifer of concern is unusable because of
extremely low yield; that there are no wells between the site and
Trout Brook, a ground water discontinuity; that the nearest well is
not in the aquifer of concern; and that the site is not a recharge
area for any planned or existing public drinking water supplies.
In response to comments regarding hydrology, the existence of
public, private and industrial wells pumping from the aquifer of
concern are recorded in the documentation record. The commenter's
statement that the aquifer is unusable is therefore unfounded.
As explained in Part VII at the preamble to the final NPL, the
MRS does not require determination of ground water flow gradients
but utilizes a radius (distance of 3 miles or less) around the site
when determining the distance to the nearest well in the contam-
inated aquifer and the population at risk due to (potential)
contamination, provided that a discontinuity in the aquifer does not
exist between the site and the well being scored for purposes of the
HRS. The Agency does acknowledge that no wells are located between
the site and Trout Brook. However, the Agency disagrees with the
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commenter's claim that the brook constitutes a discontinuity in the
aquifer. The commenter asserts that wells beyond the brook, which
are within the 3 mile radius used in scoring of the site, should not
be considered in the scoring due to the presence of the brook (i.e.,
a discontinuity). The Agency has concluded that the Brook is too
small to constitute a discontinuity in the aquifer thereby
preventing migration of contaminants beyond the brook itself. Data
indicate that portions of the brook in the area are narrow enough to
step across. Water flow in the brook is not sufficient to produce a
saturated zone large enough to prevent migration of contaminants
beyond it. The Slatersville Reservoir north of the site does
represent a discontinuity and because of this, populations served by
wells beyond the reservoir were not counted in the scoring of the
site. The Agency believes that it is correct in including the wells
located beyond the brook in the scoring of the site and has done
so. No changes are warranted to the distance to nearest well/
population served rating factors.
The population using the aquifer of concern was calculated by
the Agency as 3210, and the distance to nearest well is estimated to
be 3,000 feet, which results in a value of 32 for the population/
distance matrix.
The commenter noted that the containment value for the ground
water migration pathway should be zero because the site is now
covered with a PVC liner.
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In response, the existence of a PVC "liner" could not be
considered as an effective measure for containment of contaminants
because it is on top of the site, not beneath the site and the
hazardous material. While the PVC material may prevent rain water
from infiltrating the site, there is nothing preventing ground water
from entering the site or hazardous materials from leaching directly
into the ground water. In addition, the PVC covering was not
installed until 1979. The commenter ignores the fact that the
uncapped facility may have caused contamination of the aquifer prior
to 1979.
The commenter stated that the hazardous waste quantity is less
than 100 tons rather than the 18,240 drum equivalents.
In response, quantity calculations of hazardous materials are
based upon "as received" quantities of materials disposed.
Consideration is not given for what percentage of the material
disposed of is the hazardous contaminant. The HRS assigns values
for waste quantity based on the entire quantity of all waste
deposited that contains hazardous material, not on the quantity of
the constituents that are actually hazardous. As explained in the
preamble to the final National Contingency Plan, 47 FR 31190, this
position was taken because of the difficulty in determining for all
sites that portion of the total waste deposited that actually
constitutes hazardous material. The values assigned to waste
quantities in the HRS take into account the fact that actual
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hazardous material is likely to be only a portion of the total waste
deposited. Further, a review of the data regarding disposal of
materials at the site indicates that hazardous wastes from one
generator alone totals more than the amount required to assign a
maximum value for waste quantity, using the HRS scoring system.
The commenter noted that measures have been taken to direct
runoff away from the site. EPA personnel who visited the site
evaluated the measures for diversion of runoff as unsound and noted
that there is no collection system for surface runoff. The
containment value for surface water, therefore, remains unchanged.
The commenter stated that the surface water score should be
zero because containment measures taken at the site have prevented a
surface water release to date (i.e., containment value should have
been assigned a 0 rather than 3).
In response, while data previously noted show that the site is
covered with a PVC material, adequate containment or diversion
structures are not in place that would prevent contaminants from
entering surface water via ground water. The documentation on the
site shows that ground water below the site (which has been shown to
be contaminated) recharges Trout Brook. This indicates that the
potential for contamination of surface water did exist prior to 1979
and may exist now. The scoring of the surface water migration route
was therefore correctly scored on its potential for contamination of
surface waters, not on an observed release of contaminants.
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The original migration score for this facility was 49.58.
Based on the preceding responses to comments, the score remains
unchanged. The HRS scores for Landfill and Resource Recovery, Inc.,
are:
Ground Water 83.67
Surface Water 18.91
Air 0
Total 49.58
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2.29 Peterson-Puritan, Lincoln/Cumberland, Rhode Island
2.29.1 List of Commenters
NPL-106 Zuckert, Scoutt, Rasenberger & Delaney, Attorneys at
Law representing Peterson-Puritan Corporation.
2/7/83.
2.29.2 S"""qary of Comments and Response
The commenter stated that EPA is lacking data on other sources
of ground water contamination that are hydrologically connected to
the Lincoln well field and noted that Peterson-Puritan is currently
preparing a detailed study of the site.
In response, the study or portions of it referenced by the
commenter were not submitted to EPA and the commenter presented no
information to consider that would influence the HRS scoring of the
site. EPA believes the existing documentation record is sufficient
to link the contaminants found to the Peterson-Puritan facility.
The original migration score for this facility was 40.10.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Peterson-Puritan are:
Ground Water 69.23
Surface Water 4.53
Air 0
Total 40.10
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2.30 Picillo Farm, Coventry, Rhode Island
2.30.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation.
An Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.30.2 Summary of Comments and Response
A. D. Little, Inc., commented that more than 5000 yards of
contaminated soil was included in the waste quantity calculation
used in the scoring of the site*
In response to this comment, the value for hazardous waste
quantity has been changed from an 8 to 7. HRS instructions do not
permit consideration of contaminated soil in waste quantity
calculations.
In addition, A. D. Little, Inc., submitted alternative
migration scores for the site, but provided no information
indicating why there was a difference from the HRS scores. The
total migration score submitted by A. D. Little, Inc., for the site
was 54. This score compares favorably to the revised migration
score of 53.63. EPA believes the existing documentation record is
sufficient to support the HRS scoring at the site.
The Department of the Interior noted the evident contamination
of Whitford Pond and an unnamed wetland in the vicinity of the site.
In response, the location of these surface water bodies was
considered in scoring the site. The Agency originally assigned a
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value of 3 to distance to sensitive environment. This score has
been changed to 2. Data indicate that the wetland is 600 feet from
the site, which requires assigning a value of 2.
Review of the available data on this facility revealed that air
measurements were taken during hazardous waste removal operations.
Therefore, in accordance with the HRS instructions the air pathway
route can not be used for scoring of the site. Consequently, the
air pathway score has been changed to 0. No data currently exist
indicating an observed release for the air pathway.
The original migration score for this facility was 67.70.
Based on the changes noted above, the HRS scores for Picillo Farm
are:
Ground Water 76.53
Surface Water 52.45
Air 0
Total 53.63
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2.31 Western Sand and Gravel, Burrillville, Rhode Island
2.31.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation.
An Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.31.2 Summary of Comments and Response
Alternative scores for the ground water pathway and total
migration score were submitted by A. D. Little, Inc., but It
provided no information indicating why there was a difference from
the HRS scores. In the absence of supporting data, no changes can
be considered. The total migration score of 48 submitted by A. D.
Little, compares favorably with HRS recommended score. EPA believes
the existing documentation record is sufficient to support the HRS
scoring of the site.
The U.S. Department of the Interior commented that
contamination has affected the Slaterville Reservoir which is used
for fishing.
In response, the location of this surface water body and its
recreational use was considered in developing the original HRS
score. Surface water use was assigned a value of 2 and distance to
a sensitive environment was assigned a value of 3.
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The original migration score for this facility was 51.35. No
new technical information was submitted and no change in score was
required. The HRS scores for Western Sand and Gravel are:
Ground Water 86.34
Surface Water 20.98
Air 0
Total 51.35
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2.32 Old Springfield Landfill, Springfield, Vermont
2.32.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.32.2 Summary of Comments and Response
The U.S. Department of the Interior commented that heavy
metals are leaching into the Black River.
In scoring of the site toxicity/persistence rating for
chloroform was used as the contaminant for scoring of this rating
factor. It was assigned a value of 18 which is equivalent to the
value that would have been assigned if a metal were used for scoring
of the rating factor.
The original migration score for this facility was 34.79. No
new technical information was submitted and no change in score was
required. The HRS scores for Old Springfield Landfill are:
Ground Water 59.18
Surface Water 10.91
Air 0
Total 34.79
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2.33 Pine Street Canal, Burlington, Vermont
2.33.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project
Review, U.S. Department of the Interior. 3/17/83.
2.33.2 Summary of Comments and Response
The U.S. Department of the Interior commented that contami-
nation of the Pine Street Canal and adjacent wetlands, and Lake
Champlain have occurred. Contamination of Lake Champlain is minimal
due to dilution.
In response to the Department's comments, the importance of
these surface waters has been considered in assigning maximum scores
for surface water use and distance to sensitive environment.
During review of the documentation for this facility, the
Agency noted that there are no wells in the aquifer of concern
within 3 miles of the site. Thus, the ground water route target
value was incorrectly assigned a score of 1. The value has been
corrected to 0. This reduces the ground water pathway score from
1.6 to 0.
A rounding error occurred in the calculation of the surface
water pathway score and has been corrected resulting in a change
from 69.9 to 69.93.
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The original migration score for this facility was 40.40.
Based on the changes noted above, the HRS scores for Pine Street
Canal are:
Ground Water 0
Surface Water 69.93
Air 0
Total 40.42
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3.0 COMMENTS ON REGION II SITES
The U.S. Department of the Interior had comments on two sites
consisting of brief site descriptions or statements that there were
no anticipated impacts on protected species of flora and fauna. The
following facilities were mentioned. These comments do not affect
the scores for the sites.
New York Old Bethpage Landfill, Oyster Bay
Vestal Water Supply, Vestal
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3.1 A. 0. Polymer, Sparta Township, New Jersey
3.1.1 List of Commenters
NPL-18 Dolan and Dolan, Attorneys for A. 0. Polymer Corp.
1/17/83.
3.1.2 Summary of Comments and Response
The A. 0. Polymer Corporation stated that it has consistently
denied any contamination of its property, or surrounding properties,
by virtue of its operations. Further, it notes that relations with
customers and suppliers have been harmed by its status on the
proposed list. In response, the preamble to the National Priorities
List specifically states that inclusion does not "constitute a
judgment concerning the responsibilities of owners or operators"(47
PR 58479).
The respondent also noted that the Corporation has cooperated
with the New Jersey Department of Environmental Protection surface
clean-up which is now complete and states that no further allega-
tions of contamination have been addressed to the Corporation. The
respondent requested that the site be removed from the NPL. EPA,
however, computes HRS scores and lists sites on the basis of
conditions existing before any response actions are taken in order
to represent the full scope of the original problem presented by a
site. The basis for this position is discussed further in Part VII
of the preamble to this rule. If EPA determines that a site is
cleaned up so that no further response is necessary, EPA will delete
the site from the list, as discussed in Part VIII of the preamble to
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the final NPL. EPA has not yet made such a determination with
respect to the A. 0. Polymer site, but will continue to examine
conditions at the site to determine whether deletion is
appropriate. For sites that remain on the list, any cleanup
activities conducted pursuant to formal agreements with EPA are
acknowledged on the final NPL by notation in the "Voluntary or
Negotiated Response" category.
The original migration score for this facility was 28.91. No
new technical information was submitted and no change in score was
required. The HRS scores for A.O. Polymer are:
Ground Water 47.80
Surface Water 14.69
Air 0
Total 28.91
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3ซ2 American Cyanamid Co., Bound Brook, New Jersey
3.2.1 List of Commenters
NPL-275 M. Odian, Plant Manager, American Cyanamid Company.
2/28/83.
3.2.2 Summary of Comments and Response
The commenter stated that it is inappropriate to list this site
because portions of the site are active RCRA facilities under
interim status and because the company has joined in an
Administrative Consent Order with the State of New Jersey to assure
adequate remediation and protection of the public health and the
environment. In response, as detailed below, EPA has evaluated only
those portions of the facility not under RCRA status. Further, the
existence of a consent order cannot affect the HRS score, because
the score is based on certain objective characteristics of the site
before response actions are taken and, therefore, does not reflect
current or prospective response actions. In addition, EPA has
determined that if the HRS score places a site on the NPL, the site
must remain on the list until EPA determines that no further
response actions are appropriate, or any other criteria for deletion
are met, as discussed in Part VIII of the preamble to the final
NPL. EPA recognizes, however, the good faith cleanup efforts of
those who have entered into court-sanctioned agreements, and has
identified these sites by notation in the "Voluntary or Negotiated
Response" category of the NPL.
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The commenter supplied a 2 page, apparently incomplete,
critique of the HRS scoring of the site. The commenter evaluated
observed release to ground water as zero and scored route
characteristics. In response, the well sampling reports supplied by
the commenter document observed release to both production and
monitoring wells and conclude, "As in earlier quarters, water from
production wells 16 and 17 is heavily contaminated, primarily with
benzene, chlorobenzene, and aniline."
The commenter submitted data indicating the waste
impoundments are designed for two feet of freeboard above the level
required by the 100 year, 24-hour storm. Diking and diversion
structures are said to be in good condition. The Agency has
photographs of the impoundments showing the liquid within 12" to 18"
of overflowing. Consequently, no score change has been made.
The commenter noted that EPA files refer to 27 impounds, a
number of which have never been used, or contain non-hazardous
materials or are RCRA facilities covered by interim status. The
commenter expressed concern that the aggregate of these impounds may
have been used in HRS scoring. In the critique of the HRS scoring,
however, the commenter awarded a score of 8 to hazardous waste
quantity, the same score awarded by EPA on the basis of the
documentation in the State Administrative Order.
The commenter rated surface water use as either one or three
and noted that some portions of the plant are upstream of the
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Elizabethtown Water Company Intake and some are downstream.
Likewise, the commenter indicated that population served/distance to
water intake matrix should be scored either zero or 40. In
response, the scores of 3 and 40 were selected because locations of
potential discharge to surface water lie upstream of the
Elizabethtown Water Company Intake.
The original migration score for this facility was 50.28.
Based on the above response to comments, the score remains
unchanged. The HRS scores for American Cyanamid Co. are:
Ground Water 83.67
Surface Water 23.76
Air 0
Total 50.28
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3.3 Bridgeport Rental and Oil Services, Bridgeport, New Jersey
3.3.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
3.3.2 Summary of Comments and Response
The commenter asserted that the ground water score should be
reduced from 89 to 59. However, the commenter did not provide the
analysis and the data on which the statement was based. The ground
water scoring has been evaluated and is correct with respect to the
documentation record.
The commenter stated that a. direct release to the air was
measured in November 1982. The commenter did not submit any data to
support the assertion.
The original migration score for this facility was 60.73. No
new technical information was submitted and no change in score was
required. The HRS scores for Bridgeport Rental and Oil Services are:
Ground Water 89.80
Surface Water 54.55
Air 0
Total 60.73
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3.4 Combe Fill North Landfill, Mt. Olive Township, New Jersey
3.4.1 List of Commenters
NPL-L21 Frank P. Ruggiero, Mayor, Township of Mount Olive, New
Jersey. 3/07/83.
3.4.2 Summary of Comments and Response
The commenter stated that Federal help is needed to properly
close this landfill and provided comments on the present status of the
site. The comments were reviewed and found to be represented in the
documentation and scoring of the site. With respect to the need for
Federal help, listing on the NPL makes a site eligible for remedial
action funding, and EPA will examine the Combe Fill North Landfill
site to determine an appropriate response.
Agency review of this facility revealed two errors in scoring.
Hazardous waste quantity was scored 0 in all three pathways rather
than 1. Although the quantity of hazardous material at this facility
is unknown, the factor should be scored 1 in each pathway due to the
observed releases. An observed release indicates that the quantity of
hazardous material must be greater than zero. In addition, the
toxicity factor in the air pathway has been raised from a value of 2
to 3. For purposes of the NPL, the toxicity of chloroform is
indicated in the HRS (Table 4 (47 FR 31229)).
The original migration score for this facility was 42.44. Based
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on the changes noted above, the HRS scores for Combe Fill North
Landfill are:
Ground Water 73.08
Surface Water 10.63
Air 37.18
Total 47.79
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3.5 GPS/Madison Industries, Old Bridge Township, New Jersey
3.5.1 List of Commenters
NPL-242 Lowenstein, Sandier, Brochin, Kohl, Fischer and
Baylan, on behalf of CPS Chemical Co., Inc. 2/28/83
3.5.2 Summary of Comments and Response
The commenter stated that extensive pollution-preventative
actions approved by the court and New Jersey Department of
Environmental Protection (DEP) have been taken since 1979, and these
actions have completely abated the threat of any contamination from
ongoing operations. In response, it is noted that, according to the
HRS, facilities are scored to reflect site conditions prior to any
remedial action. This approach is explained in Part VII of the
preamble to the final NPL.
The commenter stated that extensive analytical data are
available on the ground water problems affecting the wellfield.
However, for comment purposes, only two salient points need to be
stressed:
(1) The contaminated wells are located west of the plant site
on property owned by the City of Perth Amboy and this adjacent area
should be listed as the site. (2) The ranking of the site did not
take into consideration the remedial measures already taken.
In response, the Agency has determined that sufficient
documentation exists to associate the contamination problems with the
CPS-Madison facility.
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In addition, EPA computes HRS scores and lists sites on the
basis of conditions existing before any response actions are taken,
in order to represent the full scope of the original problem
presented by a site. If EPA determines that a site is cleaned up so
that no further response is necessary, EPA will delete the site from
the list, as discussed in Part VIII of the preamble to the final
NPL. EPA has not yet made such a determination with respect to the
CPS-Madison Industries site, but will continue to examine conditions
at the site to determine whether deletion is appropriate. For sites
that remain on the list, any cleanup activities conducted pursuant to
formal agreements with EPA are acknowledged on the final NPL by
notation in the "Voluntary or Negotiated Response" category.
The commenter referred to illegal dumping that has taken place
in the City of Perth Amboy wellfield property. The Agency will
investigate this allegation.
The original migration score for this facility was 69.73. No
new technical information was submitted and no change in score was
required. The HRS scores for GPS Madison Industries are:
Ground Water 88.46
Surface Water 82.03
Air 0
Total 69.73
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3.6 Fair Lawn Well Field, Fair Lawn, New Jersey
3.6.1 List of Commenters
NPL-291 John L. Schneider, Borough Engineer, Borough of Fair
Lawn, New Jersey. 1/13/83.
3.6.2 Summary of Comments and Response
The commenter expressed concern for the quality of drinking
water in the Borough of Fair Lawn and supported the listing of this
facility on the National Priorities List.
In response, listing on the NPL makes a site eligible for
remedial action funding, and EPA will examine the Fair Lawn Well
Field site to determine an appropriate response.
The original migration score for this facility was 42.49. No
new technical information was submitted and no change in score was
required. The HRS scores for Fair Lawn Wellfield are:
Ground Water 73.08
Surface Water 7.97
Air 0
Total 42.49
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3.7 Gems Landfill, Gloucester Township, New Jersey
3.7.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation, An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
3.7.2 Summary of Comments and Response
The commenter noted an incorrect score assigned to the
"distance to sensitive environment" rating factor. This value has
been changed from 3 to 2 reflecting the 1/4 mile to the freshwater
wetland.
The original migration score for this facility was 68.88.
Based on the change noted above, the HRS scores for Gems Landfill
are:
Ground Water 100.00
Surface Water 18.18
Air 61.03
Total 68.53
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3.8 Helen Kramer Landfill, Mantua Township, New Jersey
3.8.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation.
An Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
3.8.2 Summary of Comments and Response
The commenter noted an addition error in the targets category
of the air pathway. The targets score should have totaled 27
instead of 24 as shown. This error has been corrected.
In addition, Agency review of this facility indicated that the
land use rating factor in the air pathway should have been scored 3
rather than 2 because of the proximity of the site to prime and
non-prime agricultural land. This raised the total targets score
for the air pathway to 28.
The original migration score for this facility was 70.06.
Based on the changes noted above, the HRS scores for Helen Kramer
Landfill are:
Ground Water 79.59
Surface Water 72.73
Air 64.62
Total 72.66
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3.9 Imperial Oil, Marlboro Township, New Jersey
Renamed; Imperial Oil/Champion Chemicals, Morganville,
New Jersey
3.9.1 List of Commenters
NPL-212 Pitney, Kardin, Kipp, and Szuch, Attorneys for
Imperial Oil Company. 2/28/83.
3.9.2 Summary of Comments and Response
The commenter submitted data from testing by Princeton Aqua
Science to support the statement that more recent testing by
approved methods has failed to confirm the presence of PCBs. The
commenter concluded that the value assigned to ground water
toxicity/persistence should be reduced from 18 to 12 as a result of
discarding the PCB data and the surface water toxicity/persistence
value should be reduced from 12 (sic) to 6 because "the surface
discharge is fairly clean." In response, the document submitted by
the commenter shows PCBs at 89 ppm in the oil phase of the 8/12/82
sample from well 3. Further, a number of toxic metals such as
arsenic and barium are shown in the monitoring wells. The value
assigned to the ground water toxicity/persistence is maintained at
18.
With respect to surface water, the original data supported the
assignment of a value of 18 to toxicity/persistence. As noted in
the original documentation, arsenic and lead were detected in the
surface water, both in the vicinity of the waste oil dumps and also
at the discharge from the oil-water separator towers. The value of
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18 for toxicity/persistence has been maintained, based on the
evaluation of arsenic.
The commenter stated that the target population of 20,076 via
the ground water migration route is false. The municipal wells of
Matawan and Aberdeen draw from the Raritan Magothy aquifer whereas
the alleged contamination is associated with the Englishtown
aquifer. Since the aquifers are separated by some 100 feet of clay
and no hydrological connection has been demonstrated, the population
using the Raritan Magothy aquifer cannot be counted. The commenter
concluded that the value assigned to ground water use should be
lowered from 3 to 1 and the value assigned to distance/population
should be reduced from 40 to 6 because of the small number of
persons using shallow private wells.
The commenter is correct in noting evidence of an aquaclude and
the lack of evidence of any hydrological connection between the two
aquifers. The number of persons using the shallow Englishtown
aquifer has been redocumented and is estimated to be 760. The
commenter noted that a number of the private wells within a three
mile radius may be upgradient from the site. However, because of
the need to develop a nationally uniform scoring system that could
be used to score a large number of sites with the data commonly
available, the MRS does not specifically take into account such
level of detail as flow gradients when determining the target
population. This position is explained more fully in the preamble
3-16
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to the final National Contingency Plan at 47 FR 31190. The value
assigned for distance/population has been reduced from 40 to 20.
The value of 3 for ground water use has been maintained because
alternate water supply to these users of the Englishtown aquifer is
not directly available.
The commenter requested that, if the site is not dropped from
the NPL because of score changes, the name should be changed to
Champion Chemical Company to reflect the fact that Champion owns the
site and that any alleged unpermitted releases took place before the
Imperial lease. The State of New Jersey has stated that the name of
this site should be Imperial Oil/Champion Chemicals and notes that
no clear determination of responsibility has yet been reached, nor
is one implied by the name which identifies the site. EPA has
adopted the site name suggested by the State.
In the process of reevaluating this site, the hazardous waste
quantity, previously referred to as "unknown", was estimated as
1,572 square yards based on the dimensions of the waste storage
areas. This raises the value assigned to hazardous waste quantity
for both the ground water and the surface water routes from 1 to 7.
The original migration score for this facility was 42.69.
Based on the changes noted above, the HRS scores for Imperial
Oil/Champion Chemicals (Imperial Oil) are:
Ground Water 56.91
Surface Water 13.99
Air 0
Total 33.87
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3.10 King of Prussia, Winslow Township, New Jersey
3.10.1 List of Commenters
NPL-194 D. K. Rothermel, Vice President, General Counsel and
Secretary of Carpenter Technology Corp. 2/25/83.
NPL-264 B. Curtis, Corporate Environmental Specialist for
Johnson Matthey, Inc. 2/24/83.
3.10.2 Siiitimary of Comments and Response
Carpenter Technology stated that the data used in scoring the
site is internally inconsistent and based on inaccurate assumptions
and concluded that the documentation and scoring record is
inadequate for the purpose of rulemaking. Johnson Matthey stated
that the HRS score for the site is far too high and presented
alternative worksheets and explanations to indicate a site score of
10.7.
Both commenters disagree with the assignment of a value of 8
for hazardous waste quantity. That quantity was estimated in the
original documentation record to be 19,167 cubic yards. It was
based on the dimensions of the six lagoons to a once-filled depth of
15 feet. Carpenter Technology noted that this estimate runs counter
to the HRS cover sheet that refers to six sand-filled lagoons, one
half-filled with waste. In response, the HRS scoring instructions
(47 PR 31229) direct that the waste quantity is to be evaluated as_
received. The use of the once-filled capacity of the lagoons to
represent the total waste deposited in the lagoons during their
period of use is probably conservative.
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Johnson Matthey estimated the hazardous waste quantity to be
2,926 cubic yards, or possibly as,much as 4,210 cubic yards based on
the USEPA Region II scope of work draft that was given to poten-
tially liable parties in 1982. Johnson Matthey awarded a value of 6
to this hazardous waste quantity. The HRS scoring instructions
indicate that the proper value for a quantity of 2500 cubic yards or
more is 8 (47 FR 31229).
The hazardous waste quantity has since been redocumented, based
on the letters received from 3 of the 4 generators pursuant to
Section 103 of CERCLA. This quantity is over 40,000
drum-equivalents and has been assigned a value of 8 for hazardous
waste quantity for both the surface and the ground water routes.
With respect to the ground water targets factors, both com-
menters note that the ground water release is observed in relatively
shallow wells, that the Cohansey aquifer is documented at 150 to 200
feet deep in the vicinity of the site, that no hydrogeological
connection is demonstrated between aquifers and that no wells are
documented that are at least 150 feet deep. They conclude that
there is no observed release to the Cohansey aquifer and, if there
were, no documented population using the Cohansey for drinking water.
In response, the drilling log of the Johnson Matthey well has
been examined. This well, 1600 feet from the site, was drilled to
185 feet and shows no distinct clay layers that are judged by EPA to
constitute an aquaclude to the plume of contamination that has been
3-19
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observed in shallower wells. This is in disagreement with Johnson
Matthey who states that several clay layers effectively prevent
downward migration.
Johnson Matthey stated that the Great Egg Harbor River
constitutes an aquaclude and that there are no wells between the
site and the stream. They concluded that the population/distance
factor should therefore be rated as zero rather than 30. In
response, the Great Egg Harbor River is a relatively small stream
less than 1 1/2 feet deep and is not judged to constitute an
effective aquaclude.
Johnson Matthey also stated that the nearest well is more than
2000 feet away, is not in the path of ground water flow and that
several clay layers would effectively prevent downward migration to
the well's 142 foot depth. The nearest downgradient well, they
stated, is the New Jersey Fish and Game Office which is more than
2000 feet away from the site and is not used for drinking water.
All other downgradient wells are more than 1 mile away. These
statements imply that the distance to the nearest well of concern is
more than one mile and that the evaluation factor should have been
rated as 2. In response, the Johnson Matthey well, which has already
been discussed as showing no clay layers that might serve as an
aquaclude, was measured as 1600 feet from the site on the USGS 7 1/2
minute map. Because of the need to develop a nationally uniform
scoring system that could be used to score a large number of sites
3-20
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with the data commonly available, the HRS does not specifically take
into account such level of detail as flow gradients when determining
the target population. This position is explained more fully in the
preamble to the final National Contingency Plan at 47 FR 31190. For
these various reasons, the distance to the nearest well drawing from
an aquifer of concern is judged to be 1600 feet and the evaluation
factor has been rated as 4.
The target population for the ground water route is documented
as 2973 persons, based on the interpretations that documented
migration of contaminants is relatively unrestricted and that the
Great Egg Harbor River does not constitute an effective barrier to
migration of contaminants. This population was awarded a rating of
3. This rating, combined with the rating of 4 for distance to the
nearest well, yielded a distance/population matrix rating of 30.
This is the same rating as was originally assigned.
Carpenter Technology noted inconsistent documentation with
respect to the use of the shallow well at the New Jersey Fish and
Game Office and concluded that the Agency cannot lawfully rely on
such poor and inconsistent information to support the overall ground
water score. This well is referred to as a drinking water well
under ground water use and was referred to as "not used for
consumption" under population served. In response, this well was
built for drinking water purposes and is the sole source of water in
the office. It is not documented, however, how many persons might
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actually drink the water from the well. Hence, no population was
counted for this well.
Carpenter Technology noted in both the press release and in
back-up documents the reference to an area of dead vegetation as
evidence of ground water contamination and stated that the dead
vegetation could be the result of a one-time surface water run-off.
In response, this information and conclusion was not used in the
scoring of either the ground water or surface water route. The
Agency has reworded the press release.
With respect to the observed release to surface water,
Johnson Matthey stated that no surface water samples were ever
collected and analyzed, but rather, only run-off in a drainage
ditch. Johnson Matthey concluded that this factor should be rated
as zero, and proposed an evaluation of the surface water route based
on route characteristics and containment. This approach resulted in
a surface water route migration score of 7.46 rather than 18.18.
In response, the observed release has been redocumented based
on samples and analytical data from April, 1980. The 1979 data in
the original documentation shows contaminants in the drainage ditch
that eventually connects to the Great Egg Harbor River about 1100
feet downgradient. The 1980 data was taken from the downgradient
point in the river itself and showed contamination by copper, zinc
and hazardous organics, in contrast with clean water upstream.
Copper and zinc are among the contaminants reported to be deposited
3-22
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at the site by generators. The EPA has concluded than an observed
release was properly scored.
Johnson Matthey noted that no recreational use of the river is
documented but did not propose to change the score. Documentation
has been added to the effect that the Great Egg Harbor River is used
for game fishing.
Carpenter Technology noted that conditions at this site have
been materially affected by actions of the present owner, Winslow
Township and cited the filling of lagoons with sand as an example.
The EPA, however, computes HRS scores and lists sites on the basis
of conditions existing before any attempts to mitigate exposure are
taken in order to represent the fall scope of the original problem
presented by the site. The basis for this position is discussed
further in the preamble to the final NPL. Whether an attempt at
mitigation has helped or hindered will become a subject of concern
when field studies to define the problems of clean-up are begun.
Sites are listed or the NPL without regard to the liability of the
various parties for conditions at the site.
The original migration score for this facility was 47.19.
Based on the above response to comments, the score remains
unchanged. The HRS scores for King of Prussia are:
Ground Water 79.59
Surface Water 18.18
Air 0
Total 47.19
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3.11 Lipari Landfill, Pitman, New Jersey
3.11.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
3.11.2 Summary of Comments and Response
The commenter noted that the distance to a 5-acre freshwater
wetland in the air route documentation is listed as 10 feet which
should warrant a value of 3, rather than 0, under "distance to
sensitive environment". The commenter is correct and the air route
worksheet has been changed.
The original migration score for this facility was 72.12.
Based on the change noted above, the HRS scores for Lipari Landfill
are:
Ground Water 83.67
Surface Water 76.36
Air 65.38
Total 75.60
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3.12 Maywood Chemical Co., Maywood/Rochelle Park, New Jersey
3.12.1 List of Commenters
NPL-6 Maywood resident Gertrude Peter. 1/6/83.
NPL-8 F. B. Dahlinger, Secretary, Township of Rochelle Park
Planning Board. 1/3/83.
NPL-10 Maywood residents Caroline and Vincent W. Trovato.
1/1/83.
NPL-26 Maywood resident Karin R. Mitchell. 1/19/83.
NPL-27 Maywood resident Prudence Turnamian. 1/17/83.
NPL-29 Maywood resident Mrs. M. Carpenter. 1/21/83.
NPL-30 Maywood resident Marion Camillo. undated.
NPL-31 Maywood resident Jim Walker. 1/21/83.
NPL-33 Maywood resident Joyce and Cornelius Enright.
1/22/83.
NPL-36 Maywood resident R. Eskenazi. 1/21/83.
NPL-38 Maywood residents Peter and Jeanette Berman. 1/23/83.
NPL-40 Maywood residents Phyllis and Warner Strohmeyer.
1/20/83.
NPL-41 Maywood resident Renee Trey. 1/28/83.
NPL-43 Maywood resident Ann Duffy. 1/28/83.
NPL-44 Maywood resident Ms. Barbara Green. 1/27/83.
NPL-45 Maywood resident Mrs. Joan Maiorise. 1/25/83.
NPL-46 Maywood resident Mrs. Sickowski. 2/28/83.
NPL-47 Maywood resident Frieda Rosenberg. 1/25/83.
NPL-48 Maywood resident Carol Pfieffer. Undated.
NPL-49 Maywood resident Mary Duffy. 1/28/83.
NPL-50 Maywood resident Mrs. Rose Spiech. 1/28/83.
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NPL-51 Maywood resident William J. Turner. 1/27/83.
NPL-52 Maywood resident John J. Jacob. Undated.
NPL-53 Maywood residents David and Linda Babcock. 1/24/83.
NPL-60 Maywood resident Darlene A. La Vella. Undated.
NPL-61 Maywood resident Reta Warren. Undated.
NPL-62 Maywood residents Frank and Jean Heinz. 2/1/83.
NPL-63 Maywood residents Mr. and Mrs. Albert J. Bole.
2/1/83.
NPL-64 Maywood resident Celia F. Milling. 1/29/83.
NPL-68 Maywood residents Mr. and Mrs. Stephen Orban.
1/28/83.
NPL-69 Maywood residents Mr. and Mrs. Robert Lewis. 1/30/83,
NPL-71 Maywood resident Steven Markowski. Undated.
NPL-72 Maywood residents Antoinette and Theodore Sturm.
2/1/83.
NPL-73 Maywood resident Mildred Kocher. 1/27/83.
NPL-74 Maywood resident George Aumuller. 1/29/83.
NPL-79 Maywood resident John H. Schafer. 1/27/83.
NPL-83 Maywood resident B. Freukian. 2/3/83.
NPL-90 Maywood residents Fred and Ruth Abels. 1/29/83.
NPL-91 Maywood resident Marilyn Tinghino. 1/29/83.
NPL-92 Maywood resident Gertrude Yafcak. 2/4/83.
NPL-96 Maywood residents Mr. and Mrs. Robert Cork. 2/5/83.
NPL-98 Maywood resident Lucille Bastangs. 1/28/83.
NPL-99 Maywood resident Ruth Luspichi. 1/28/83.
NPL-102 Maywood resident Mrs. N. Ciriello. 2/6/83.
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NPL-104 Maywood resident Mrs. Nedra Niscia. Undated.
NPL-108 Maywood resident William E. Cazin. 2/7/83.
NPL-114 Maywood residents Robert H. and Ruth Ann Meehan.
2/8/83.
NPL-131 Maywood resident Joseph Beanich, Jr. 2/7/83.
NPL-132 Maywood residents Mr. and Mrs. Peter Luciano. 1/7/83.
NPL-137 Maywood resident Ms. Nash. 2/16/83.
NPL-138 John A. Steuert, Jr., Mayor, Borough of Maywood, Bergen
County. 1/21/83.
NPL-142 William P. Schuber, Assemblyman, District 38, General
Assembly of New Jersey, Trenton. 1/28/83.
NPL-147 Maywood resident Mrs. Hedwig W. Niebauck. 2/1/83.
NPL-155 William P. Schuber, Assemblyman, District 38, General
Assembly of Trenton New Jersey. 2/16/83.
NPL-158 Maywood residents Mr. and Mrs. Robert Gross. Undated.
NPL-183 Maywood residents Ruth and John Morgan. 2/22/83.
NPL-241 Maywood residents Mr. and Mrs. George Remes. 2/24/83.
NPL-288 Robert G. Torricelli, Member of Congress, House of
Representatives. 2/28/83.
3.12.2 Summary of Comments and Response
A number of citizens supported the inclusion of this site on
the National Priorities List and expressed their concerns for the
hazards posed by this site. These concerns were reflected in the
site score.
Listing on the NPL makes a site eligible for remedial action
funding, and EPA will examine the Maywood site to determine an
appropriate response.
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The original migration score for this facility was 51.19. No
new technical information was submitted and no change in score was
required. The HRS scores for Maywood Chemical Co. are:
Ground Water 62.59
Surface Water 6.55
Air 62.31
Total 51.19
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3.13 NL Industries, Pedricktown, New Jersey
3.13.1 List of Commenters
NPL-271 F. R. Baser, Director, Environmental Control
Department, NL Industries. 2/28/83.
3.13.2 Summary of Comments and Response
The commenter stated that the analytical procedures used by
the State of New Jersey are inappropriate, that samples should be
filtered to remove suspended solids prior to testing, and that
observed release to ground water should be scored zero.
The testing of unfiltered samples is the accepted procedure in
New Jersey. While concentration data for hazardous substances in
ground water samples taken in this manner may not be accurate, the
presence of these materials constitutes direct evidence that the
materials have migrated into ground water.
The commenter stated that samples from the Raritan-Magothy
aquifers "have conclusively shown that no releases to these ground
water systems have occurred." In response, a report prepared for NL
Industries by its consultant, B&M, dated May 4, 1983, reported lead
concentrations of .40- .46 mg/1 in samples taken in January 1983 from
an on-site monitoring well screened at 59 feet in the
Raritan-Magothy Formation. This observation, in addition to other
observations recorded in the overlying Cape May aquifer, support the
original scoring for an observed release to ground water, and
indicates that both aquifers are aquifers of concern for purposes of
calculating the target population as discussed below.
3-29
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The commenter offered data to support alternative HRS
evaluation of this facility using the Route Characteristics and
Containment rating categories. In response, this information is not
pertinent to the site evaluation given the above noted observed
release to the Raritan-Magothy system and the previously documented
release to the shallow Cape May formation.
The commenter stated that the computation for hazardous waste
quantity in the documentation records of 720,000 cubic yards was
based on incorrect landfill dimensions and omitted the conversion
factor from cubic feet to cubic yards. Review of the documentation
indicates that the commenter is correct, and documentation records
have been revised to show the correct landfill volume of 200,000
cubic yards based on information provided by the commenter. Since
any waste quantity over 2,500 cubic yards receives the maximum
value, the waste quantity factor value of 8 remains unchanged.
The commenter indicated that there are no private wells in the
aquifer of concern and that the Pennsgrove Water Supply Company
(serving 17,000 people) draws only 19 percent of its water from
within the specified three mile radius. The commenter suggested a
reduction in the ground water use score to 2 based on the
availability of the Pennsgrove Water Supply system as an
alternative supply, as well as a substantial reduction in the
population score.
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The ground water use rating factor was originally assigned a
value of 3 based on the presence of private potable wells within the
specified 3 mile radius. The nearest of these wells is a private
residence on Route 130 approximately 1/2 mile from the facility.
All private wells tap the aquifer of concern because both the
shallow Cape May formation and the Raritan-Magothy aquifer system
are contaminated. The Pennsgrove Water Supply system cannot be
considered an alternative supply since part of that system draws
from the contaminated Raritan-Magothy aquifer.
The existence of wells (the Clemente wellfield) supplying the
Pennsgrove Water Supply Company was not known by EPA at the time of
scoring for the proposed NPL. Once the existence of these wells and
the supply system was recognized, EPA realized that the precise
number of homes on private wells within a 3 mile radius of the
facility cannot be determined at this time. It is likely that the
figure of 2500 people, based on a house count, includes some overlap
with the Pennsgrove water supply system. When the Pennsgrove Water
Supply system is counted for purposes of the population served
factor, however, it becomes clear that the factor value must be
raised, and that the increase is unaffected by the possibility of
such overlap.
Water from the potentially affected Clemente wellfield is sent
to a central distribution system. Therefore, the entire population
of 17,000 serviced by the Pennsgrove Water Supply Company is
3-31
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potentially affected. Since this is well over the 10,000 person
threshold for receiving the maximum value of 5, the possible overlap
with the original figure of 2500 people served by private wells is
of no consequence. The increase in the population served factor
results in a change in the distance to nearest well/population
served matrix value from 30 to 35.
The commenter stated that, "As the distance to the
No-Strip/Tomah well is less than 2000 feet, the assigned matrix
value is 4." It was further stated that the population served value
should also be 4 based on 3200 people (19% of the population served
by the Pennsgrove Water Supply Company). It was concluded by the
commenter that the matrix value should be 30.
In response, the commenter incorrectly applied the distance
and population values to the matrix. The suggested values for these
factors would result in a matrix value of 35. While this is the
correct matrix value, the values for the rating factors used to
arrive at this matrix value are incorrect. The No-Strip/Tomah well
is not used for drinking water. As indicated above, the nearest
potable well is approximately one half mile from the facility.
Distance to nearest well is assigned a value of 3. Population
served is greater than 10,000 and is assigned a value of 5. These
values result in a matrix value of 35.
The commenter stated that there is no known irrigation using
ground water. In response, the Agency is unable to confirm the use
3-32
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of ground water for irrigation at this time. The 180 people
originally counted as being potentially exposed through irrigation
have been deleted from the calculation of population served.
The commenter questioned the observed release to surface water
on the grounds that the water body was an on-site borrow pit rather
than a marsh. The commenter suggested that this was acknowledged by
the New Jersey DEP when the department signed a 1982 Consent Order
mandating the elimination of this water body.
In response, the observed release to surface water is based on
samples taken from a stream running from this water body to a
wetland 1/8 of a mile from the facility. These samples, taken in
October 1981, showed lead concentrations of 7.52 mg/1 in the stream.
The commenter correctly noted that the on-site water body was
not a marsh. They also stated their belief that there are no "...
wetlands incorporating 5 contiguous acres within a quarter-mile of
the site, nor any critical habitats within 1 mile."
In response, there is a wetland approximately 1/8 of a mile
from the facility. This wetland is more than 5 acres in extent and
is included in the National Wetlands Inventory. The assigned value
for the distance to a sensitive environment rating factor has been
lowered from 3 (incorrectly based on the on-site water body) to 2 to
reflect the distance to this wetland.
The commenter stated that, "As the site is not on, or near,
Oldmans Creek, there is no irrigation as stated in the Documentation
3-33
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Records." During the original evaluation of this facility, the
above mentioned stream between the on-site water body and the nearby
wetland was incorrectly identified as Oldmans Creek. This creek is
approximately 4000 feet from the facility and is in a separate
drainage area. The value assigned to the rating factor, Population
Served/Distance to Water Intake Downstream, has been reduced from 6
(based on irrigation diversion permits from Oldmans Creek) to 0.
Reference to irrigation has also been removed from the documentation
records under Surface Water Use.
The original migration score for this facility was 49.74.
Based on the changes noted above, the HRS scores for NL Industries
are:
Ground Water 89.80
Surface Water 18.18
Air 0
Total 52.96
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3.14 Renora, Inc., Edison Township, New Jersey
3.14.1 List of Commenters
NPL-246 Riker, Danzig, Scherer and Hyland. 2/28/83.
3.14.2 Summary of Comments and Response
The commenter, representing S&W Waste, Tenneco Chemicals, W.R.
Grace & Co., and Reigel Products Corp., stated that there is a
pending State enforcement action regarding this facility, State of
New Jersey, Department of Environmental Protection vs. Renora, Inc.,
etc., et al, and that successful completion of this action will
result in securing "all necessary remedial action of the site". The
commenter contended that this facility should be removed from the
NPL because further Federal action or the threat of future Federal
enforcement actions will inhibit alleged waste generators from
coming forth and agreeing to participate in voluntary remedial
activities.
The existence of a pending state enforcement action does not
affect the HRS score because the score is based on certain objective
characteristics of the site before response actions are taken, as
noted in Part VII of the preamble to the final NPL. EPA rejects the
hypothetical argument that EPA should refrain from listing a site as
a priority as a means of encouraging voluntary cleanup.
3-35
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The original migration score for this facility was 40.44. No
new technical information was submitted and no change in score was
required. The HRS scores for Renora are:
Ground Water 69.32
Surface Water 9.40
Air 0
Total 40.44
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3.15 Rockaway Township Well, Rockaway, New Jersey
3.15.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation, An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
3.15.2 Summary of Comments and Response
The commenter stated that the HRS model is structured for the
scoring of discrete or well-defined areas of land and that
inconsistencies in scoring can result when the site is
non-discrete. Such is the case with this site, an aquifer and
associated wells contaminated by an unidentified source. In the
absence of an observed release from the contaminated ground waters
to surface water, the model requires that route characteristics for
surface water be evaluated. Dimensions such as "containment" or
"one year 24 hour rainfall" cannot be evaluated in a consistent
manner when the site is an underground aquifer.
In response, the surface water route was not evaluated and
cannot be evaluated until the original source of contamination is
identified. The placement of this site on the NPL will permit the
required studies to be conducted.
Agency review of this facility revealed scoring errors. The
toxicity/persistence matrix was erroneously scored 18, based on the
observed presence of trichloroethylene in the aquifer of concern.
The proper toxicity/persistence value for trichloroethylene is 12.
3-37
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i
Secondly, the documentation in support of evaluating the
hazardous waste quantity as 2 was found to be inadequate. When
there is an observed release, the quantity is considered to be
greater than zero and is properly evaluated as 1.
The original migration score for this facility was 44.46.
Based on the changes noted above, the HRS scores for Rockaway
Township Wells are:
Ground Water 50.00
Surface Water 0
Air 0
Total 28.90
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3.16 Sharkey Landfill, Parsippany/Troy Hills, New Jersey
3.16.1 List of Commenters
NPL-154 E. F. Fillipone, Executive Administrator, Passaic
River Coalition. 2/16/83
NPL-157 H. Cannon, Passaic Valley Groundwater Protection
Committee. 2/16/83.
NPL-174 E. F. Fillipone, Executive Administrator, Passaic
River Coalition. 2/16/83.
3.16.2 S""""ซry of Comments and Response
The commenters expressed concerns about potential
contamination of ground water from the site and requested that
monitoring of ground water should be started immediately. In
response, the feasibility study for this site is listed in the State
four year cleanup plan for the second quarter of 1984. This plan
has been approved for funding by the USEPA.
The Passaic River Coalition noted that waste and fill was
transported from this site to Mt. Olive Township and to Combe Fill
South. This information has been noted by the Environmental
Protection Agency for investigation.
The commenters also expressed concern that the potential for
ground water contamination from the Horstmann Dump also be
evaluated. An investigation has been initiated to identify what was
dumped at this site.
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i
The original migration score for this facility was 48.85. No
new technical information was submitted and no change in score was
required. The MRS scores for Sharkey Landfill are:
Ground Water 82.56
Surface Water 18.01
Air 0
Total 48.85
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3.17 South Brunswick Landfill, South Brunswick, New Jersey
Renamed: South Brunswick Landfill (BFI), South Brunswick, New
Jersey
3.17.1 List of Commenters
NPL-292 Jerry A. Bittner, Municipal Administrator, Township
of South Brunswick. 12/23/83.
3.17.2 Summary of Comments and Response
The commenter noted that the landfill of concern is the BFI
landfill rather than the municipal landfill. While EPA recognizes
that this is true, the Agency believes that it is often best to name
the facility according to the city or town in which it is located to
provide sufficient locational information for purposes of the
National Priorities List. To clarify that the site is the BFI
landfill and not the municipal landfill, however, the name for this
facility has been changed to South Brunswick Landfill (BFI).
The original migration score for this facility was 53.42. No
new technical information was submitted and no change in score was
required. The HRS scores for South Brunswick Landfill (BFI) are:
Ground Water 89.80
Surface Water 21.82
Air 0
Total 53.42
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3.18 Syncon Resins, South Kearny, New Jersey
3.18.1 List of Commenters
NPL-280 Shapiro, Mortman, and Schwartz, Attorneys for
Benjamin Farber. 2/25/83.
3.18.2 S'wniary of Comments and Response
The commenter stated that the site does not present an
immediate and substantial endangerment to the public health and the
environment and should, therefore, be deleted from the NPL. The
commenter further stated that the site was listed because of fire
hazard and that will be remedied when the trustees comply with an
order from the Bankrupcy Court to remove all drums from inside the
premises. In response, the site is on the National Priorities List
because of the combined assessment of the ground water, surface
water, and air exposure routes. The fire and explosion route was
not considered in selecting sites for the NPL.
The commenter noted that major contamination can be consumed
by several months of chemical operations. In response to this and
to the possible removal of drums from the site, the nature of any
prospective actions is not a factor in the selection of sites for
the NPL. EPA computes HRS scores and lists sites on the basis of
conditions existing before any response actions are taken in order
to represent the full scope of the original problem presented by a
site. If EPA determines that a site is cleaned up so that no
further response is necessary, EPA will delete the site from the
list, as discussed In Part VIII of the preamble to the final NPL.
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The commenter noted that the drums contain resins and that no
chlorinated or brominated substances were found which produce toxic
substances. The commenter further noted that the substances found
in the soil and tanks onsite are solvents and other byproducts of
the resin manufacturing process. In response, the materials found
onsite include various aromatic hydrocarbons, chlorinated
hydrocarbons, and heavy metals that are hazardous substances as
defined in CERCLA.
The commenter stated that the site must be viewed in the
context of various other properties in the immediate area and
concluded that the site presents no more significant endangerment
than adjoining and neighboring properties. In response, the site
has been evaluated for migration of contaminants from the site
itself and is on the NPL on the basis of its overall migration score.
The commenter stated that there is little potential harm to
humans from the migration of hazardous substances by the ground
water route. In response, a total ground water targets value of 3
out of 49 reflects this situation.
The commenter noted that the Passaic river has been previously
contaminated by numerous other sites in the area and is far from
pristine. In response, the surface water route score of 16.36 is
based on an observed release from this site, on the waste
characteristics of the materials on site, and of the contribution of
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the site to impacts on industrial water use and on an identified
sensitive environment. If data used to compute HRS values indicate
threat to the resource and use of the resource, the potential harm
is not diminished by the fact that the resource may also be
contaminated by other sources.
The original migration score for this facility was 43.43. No
new technical information was submitted and no change in score was
required. The HRS scores for Syncon Resins are:
Ground Water 6.12
Surface Water 16.36
Air 73.08
Total 43.43
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3.19 Toms River Chemical, Toms River, New Jersey
3.19.1 List of Commenters
NPL-226 W. B. Bobsein, Manager, Environmental Technology,
Toms River Plant. 2/24/83.
3.19.2 Summary of Comments and Response
The commenter provided a reevaluation of this site, based on
additional analytical and geohydrological information, that indi-
cated a total migration score of 12.18. The commenter said that, on
the basis of score, the site should be dropped from the NPL.
The commenter noted that the four drinking water wells are
clearly upgradient from the monitoring well where contamination was
observed and stated that this gradient constituted a geohydrological
barrier. On this basis, the commenter said the distance to nearest
well/population served matrix should have been evaluated as zero.
In response, because of the need to develop a nationally uniform
scoring system that could be used to score a large number of sites
with the data commonly available, the HRS does not specifically take
into account such level of detail as flow gradients when determining
the target population. This position is explained more fully in the
preamble to the final National Contingency Plan at 47 FR 31190.
The commenter noted that the distance from the point of
observed release to the closest drinking water well is 5100 feet.
This distance, if correct, should be assigned a value of 3. In
response, the distance from contaminated well 0110 to drinking water
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well 404 was estimated from a site map and the USGS quad map to be
2400 feet. This distance received an HRS evaluation of 3 rather
than the 4 originally awarded. The original value resulted from an
improper application of the HRS. It was incorrectly assumed that,
because drinking water wells were on site (within the property
boundaries), the distance to nearest well should be zero feet.
The commenter also presented analytical data indicating that
the water quality of the four on-site drinking water wells was
excellent. The site was properly scored, however, for an observed
release to ground water and then was evaluted, as noted in the
previous paragraph, for the possibility that the contamination could
spread to some or all of the wells drawing drinking water in that
aquifer within a 3 mile radius from the area of contamination.
The commenter noted that if the drinking water wells were
found to be unsafe, it could and would switch over to water supplied
by the Toms River Water Company. The wellfield for the Toms River
Water Company, however is within the 3 mile radius of the site (2 to
2.5 miles) on the other side of the Toms River. Five of the wells
are in the Cohansey Aquifer and two are in the deeper Kirkwood
Aquifer. The Kirkwood Aquifer appears to be protected from
migration by a clay layer. There is, however, no evidence that the
Toms River constitutes a geohydrological barrier to the Cohansey
aquifer wells which range in depth from 51 to 86 feet. The drawdown
effect of the wellfield may, in fact, increase the rate of migration
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or contaminants. If the Cohansey Aquifer were contaminated, a
substantial portion of the capacity of the Toms River Water Company
would be threatened. There is no readily available alternative to
this lost capacity. Given this threat to the Toms River Water
Company supply, the employees of the Toms River Chemical Company
have no unthreatened backup to the on-site wells. For these
reasons, ground water use was assigned a value of 3.
The commenter noted that a number of remedial actions have
been taken that have resulted in greatly improved analytical
readings at the contaminated monitoring well and expressed
confidence that continued cooperation between the company and the
State of New Jersey will result in sound environmental management
and prompt and effective response to any environmental questions
that arise. As explained in Part VII of the preamble to the final
NPL, however, EPA computes HRS scores and lists sites on the basis
of conditions existing before any response actions are taken in
order to represent the full scope of the original problem presented
by a site. If EPA determines that a site is cleaned up so that no
further response is necessary, EPA will delete the site from the
list, as discussed in Part VIII of the preamble to the final NPL.
EPA has not yet made such a determination with respect to the Toms
River site, but will continue to examine conditions at the site to
determine whether deletion is appropriate. For sites that remain on
the list, any cleanup activities conducted pursuant to formal
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agreements with EPA are acknowledged on the final NFL by notation in
the "Voluntary or Negotiated Response" category.
The commenter provided data from United States Geological
Survey sampling operations at Gauging Station 4085, immediately
downstream from the facility, that show contaminant concentrations
lower than those obtained from samples taken one-quarter mile
upstream. This negates the observed release on which the surface
water score was based.
In the absence of an observed release to surface water, EPA
has reevaluated the site on the basis of route characteristics. The
values assigned are reflected in the revised HRS worksheets for the
site and are as follows: slope 1, rainfall 2, distance to nearest
surface water 3, physical state of waste (sludge and liquids) 3, and
containment 2.
The commenter supplied information that indicated that the
surface water containment value should be zero: a landfill with a
30 mil PVC liner, 24 inch seeded topsoil and intact run-off
diversion. Not all landfill areas on the site, however, are so
covered. The 1980 EPA site inspection report of the closed sludge
disposal area describes the cover as "inadequate at some spots, with
sludge being exposed at points of erosion" and did not identify any
diversion structure. On this basis, the site has been awarded a
containment value of 2.
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The commenter noted that the distance to a sensitive environ-
ment was improperly awarded the value of 3 rather than 2 (100 feet
to 1/4 mile). This error has been corrected.
In the process of reevaluation of the site for ground water
use, the customers of the Toms River Water Company were identified
as potential targets of ground water contamination. This increases
the ground water population value from 3 to 5. This change,
combined with the change in distance to nearest well from 4 to 3
that has already been noted, changed the value of the ground water
population/distance matrix from 30 to 35.
The original migration score for this facility was 45.87.
Based on the changes noted above, the HRS scores for Toms River
Chemical are:
Ground Water 86.34
Surface Water 11.19
Air 0
Total 50.33
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4
3.20 Universal Oil Products, East Rutherford, New Jersey
3.20.1 List of Commenters
NPL-191 R. M. Baratta, President and Chief Executive Officer
of UOP Inc. 2/28/83.
3.20.2 Summary of Comments and Response
The commenter stated that the HRS values assigned this site
are inaccurate and severely overstate the degree of hazard actually
posed by the site. The commenter recalculated an overall site score
of 5.65 and concluded that the site should be removed from the NPL.
The commenter denied that 4.5 million gallons of hazardous
waste was deposited at the site and described the waste as sludge
and oily surface layer from the clarifier of combined process
water. Insofar as this sludge contained less than 0.01 percent
priority pollutants, the commenter concluded that the quantity of
hazardous waste was 1,001 to 2500 drums. This quantity should
receive a rating of 6.
In response, the HRS assigns values for waste quantity based
on the entire quantity of all waste deposited that contains
hazardous material, not on the quantity of the constituents that are
actually hazardous. As explained in the preamble to the final
National Contingency Plan, 47 FR 31190, this position was taken
because of the difficulty in determining, for all sites, that
portion of the total waste deposited that actually constitutes
hazardous material. Without this information, the Agency knows of
no internally consistent approach for comparing pure hazardous
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substance quantity at facilities where definitive information is
available with hazardous substace quantity at facilities where such
information is not available. In the case of this site, and based
on the information supplied by the commenter, the hazardous waste
quantity as deposited was greater than 10 million drums (1,001 drums
divided by 0.0001). The proper rating for this quantity is 8.
The commenter stated that no reportable quantities of
acrolein, chloroform or mercury were kept or used on site and that
the toxicity/persistence should have been evaluated on benzene,
toluene or benzyl chloride. The commenter suggested a
toxicity/persistence rating of 15 as appropriate instead of 18. In
response, chloroform has been measured in both soil and water
samples from the site and was, therefore, appropriately used. The
consideration of reportable quantities is applicable only at those
facilities where the total inventory of substances present is known
(47 FR 31229). The proper toxicity/persistence value for chloroform
is 18.
The commenter noted that an observed release to ground water
was scored, based on the results of soil boring and shallow water
sampling from the upper saturated zone. The conclusions about
population were, however, based on the deep tabular aquifer which
lies under this site. This deep aquifer, the Brunswick formation,
is separated from the surficial aquifer by over 100 feet of
impermeable clay in the region of the site. Since there is no use
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of the surficial aquifer for drinking and no connection has been
demonstrated to the Brunswick formation, the target factor should
have been evaluated as zero rather than 40.
In response, the site has been reevaluated using the deep
aquifer for both observed release and for population exposure.
Sampling by NJDEP on July 2, 1981 of on-site production wells in the
glacial till at depths of 100 to 120 feet showed contamination by
chloroform and trichloroethylene. This portion of the glacial till
is believed to be in hydrological connection with the bedrock
Brunswick formation (commenter's consultant report).
The commenter stated that there is no population using the
Brunswick formation in the vicinity of the site for drinking water
because of its high mineral content and that its only use is
industrial. In response, the Agency notes that both the cities of
Garfield and Lodi are reported to draw drinking water from the
Brunswick formation. The hydrogeological reports that the commenter
referred to indicate a tabularized aquifer with existing but poor
hydraulic connection between the various segments of the aquifer.
The mineral content of some portions of the aquifer is believed to
be much higher than that of other portions. The value awarded to
the distance/population matrix is 40.
The commenter stated that the observed release to surface
water is based on old information obtained while the facility was
still in operation and ia no longer applicable. In response, the
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HRS documentation package cites the evidence of an observed release
in 1979 to Ackerman's Creek with measured contamination far above
background. The HRS scoring is intended to address potential
dangers to environment and health from historical as well as from
ongoing releases. If EPA determines that a site is cleaned up so
that no further response is necessary to the historical release or
to potential future releases, EPA will delete the site from the list
as discussed in Part VIII of the preamble to the final NPL.
The original migration score for this facility was 54.63.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Universal Oil Products are:
Ground Water 93.88
Surface Water 10.91
Air 0
Total 54.63
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3.21 U.S. Radium Corp., Orange, New Jersey
3.21.1 List of Commenters
NPL-164, Dughl and Hewit, counsel for Safety Light
206, 231 Corporation, Bloomsburg, PA. 2/24/83.
3.21.2 Summary of Comments and Response
The commenter stated that the available information does not
justify the HRS score or inclusion of the site on the NPL on the
basis that;
(1) The value of 7 assigned to hazardous waste quantity under
the Air route of the HRS allegedly is unsupported. The commenter
states that the 1600 ton quantity, estimated by the New Jersey
Department of Environmental Protection (NJDEP), was made without
performing the necessary sampling by either NJDEP or EPA.
(2) The value of 27 assigned to the population within a four
mile radius of the site should instead be zero. Only three of the
twelve radon progeny measurements taken by the NJDEP off-site showed
any measurable amount of radon progeny and the measurements are
below acceptable standards. The evidence presumably shows that
there is no health threat to the population off-site and therefore,
no target population.
In response, the waste quantity value was modified upward to
reflect the historical record as acknowledged by individuals
responsible for the site during its period as a radium product
manufacturing facility. Based on the evidence, the best estimate of
accumulated materal is between 3,000 and 6,000 tons. The overall
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waste characteristics category value of 17 was not changed because
the reactivity factor value was reduced to "0" and the changes
effectively cancelled each other. The original value of 1 for
reactivity was based on the incorrect assumption that the natural
chemical changes of radioactive materials over time constitute
reactivity.
In addition, hazardous materials do not have to be demon-
strated to have migrated off site to have the population within the
four mile radius included as the target population. The population
can be considered if there are "... data that show levels of a
contaminant at or in the vicinity of the facility that significantly
exceed background levels ..." as stated in HRS Section 5.1, 47 FR
31236 (July 16, 1982). This position is justified by the fact that
once air releases are shown to be occurring, the possibility is
established that future releases may migrate off-site.
The original migration score for this facility was 37.79.
Based on the changes noted above, the final HRS scores for U.S.
Radium Corp. remain the same:
Ground Water 0.00
Surface Water 0.00
Air 65.38
Total 37.79
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3.22 Batavia Landfill, Batavia, New York
3.22.1 List of Commenters
NPL-255 F. R. Baser, Director, Environmental Control
Department, NL Industries, Inc. for Burroughs Corp.,
Eaton Corp., GTE Service Corp., and NL Industries,
Inc. 2/25/83.
3.22.2 Summary of Comments and Response
The commenter stated that there is no observed release of
contaminants to ground water above background presumably based on
the data attached to the comment and suggested that rescoring of the
ground water route is required based on route characteristics.
The Agency reviewed the file and found recent data showing
barium concentration as high as 1400 ppb in the ground water, which
is significantly above the background level. Therefore, it is not
necessary to rescore the ground water route based on route
characteristics.
The commenter stated the labelling of the upgradient and the
downgradient well is reversed presumably based on a reference in the
file. That the offending contaminants were actually found in the
upgradient well suggested the doubtful significance of the
analytical data in indicating an observed ground water release.
The Agency wishes to point out that the well referred to as
upgradient is labeled as such because it is in a different ground
water regime than the downgradient well. Three existing shallow
wells were selected to sample the shallow aquifer just beneath the
land surface, and the well labeled as upgradient is located on the
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opposite side of the site and separated by a surface stream, which
serves as a ground water divide in regard to the shallow aquifer.
Since the farmland surrounding the landfill is unlikely to be
contaminated by other sources of pollution, this upgradient well,
though not hydrologically connected with the other two wells, can
therefore serve as background against which the observed ground
water release is measured.
The commenter stated that the magnesium sludges containing
barium deposited at the site were high in sulfate ion content, which
would tend to immobilize the barium as insoluble and non-toxic
barium sulfate. Therefore, the persistence value of barium
presumably should be zero.
The Agency noted that no data were presented in supporting the
claim that solutions deposited at the site were high in sulfate ion
content. The persistence factor is, however, properly assigned a
value of 3. Persistence refers to biodegradability rather than
availability and metals are not biodegradable.
Furthermore, the toxicity of barium was assigned a value of 3
based on available information in SAX. This has resulted in an
increase in the value assigned to the toxicity/persistence matrix
from 15 to 18. The magnesium sludge has also been identified as EP
toxic based on the data submitted to EPA in June 1983 by concerned
parties.
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The commenter noted that the maximum amount of barium disposed
of at the site is 31 tons (6% of 800 tons of magnesium sludge) and
the hazardous waste quantity should have been assigned a value of 2.
The Agency reviewed the file and found that a value of 7 should
be assigned. Quantity is evaluated on the basis of the total amount
of toxic waste deposited (1320 tons) rather than on the percent of
that waste which is the hazardous material itself.
The original migration score for this facility was 44.16.
Based on the above response to comments, the HRS scores for Batavia
Landfill are:
Ground Water 86.34
Surface Water 9.09
Air 0
Total 50.18
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3.23 Fulton Terminals, Fulton, New York
3.23.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.23.2 Summary of Comments and Response
The U.S. Department of the Interior noted that there are no
known Federally designated endangered species in this area. This
comment was reflected in the rating of the surface water pathway by
assigning a value of zero to the distance to a sensitive environment
factor.
The original migration score for this facility was 36.50. No
new technical information was submitted and no change in score was
required. The HRS scores for Fulton Terminals are:
Ground Water 62.86
Surface Water 6.15
Air 0
Total 36.50
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3.24 G. E. Moreau, South Glens Falls, New York
3.24.1 List of Commenters
NPL-236 Kathleen Listen Morrison, Assistant Attorney General,
Environmental Protection Bureau, State of New York.
2/25/83.
3.24.2 Summary of Comments and Response
The commenter supported the inclusion of the G. E. Moreau Site
on the NPL. Ongoing and potential impacts of contamination from the
facility were described in some detail. It was stated that,
"Indications are that at least 450 tons of various chemicals were
deposited at this site." This is in contrast to the original
estimate of 5000 pounds and the Agency has adjusted the HRS score
accordingly.
The original migration score for this facility was 49.83.
Based on the changes noted above, the HRS scores for G. E. Moreau
are:
Ground Water 88.46
Surface Water 24.77
Air 41.28
Total 58.21
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3.25 Hooker (Hyde Park), Niagara Falls, New York
3.25.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.25.2 S""flry of Comments and Response
A. D. Little, Inc. noted that they could not document the
particulate matter listed in the HRS Air route during a visit to the
site in the week of Jan 14, 1983.
In response, particulate matter was detected as settled
materials on rafters and other undisturbed locations in neighboring
facilities.
A. D. Little proposed revised scores for the Hyde Park site.
However, with the exception of the difference in an observed release
via the air route, mentioned above, no rationale for the changes was
given and no response can be made.
The U.S. Department of the Interior noted that the Niagara
River above the falls is a major waterfowl habitat. The river also
supports game fishing and Hyde Park Lake supports fishing and is
stocked by the New York Department of Environmental Conservation
(NYDEC).
The Agency found that no Federally designated endangered
species are noted in the area. This information was taken into
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i
account in the ranking of the site since the surface water use is
already rated for recreation.
The original migration score for this facility was 34.77.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Hooker (Hyde Park) are:
Ground Water 6.12
Surface Water 10.90
Air 58.85
Total 34.77
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3.26 Hooker (S Area), Niagara Falls, New York
3.26.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.26.2 Summary of Comments and Response
A. D. Little, Inc. noted a computational error in the targets
section of the ground water route worksheet. This error has been
corrected.
The U.S. Department of the Interior noted that the Niagara
River above the falls is a major waterfowl habitat. The river also
supports game fishing.
In response, the surface water use factor has already received
a maximum value of 3 because the water is also used for drinking
water.
The original migration score for this facility was 52.58.
Based on the change noted above, the HRS scores for Hooker (S Area)
are:
Ground Water 6.12
Surface Water 89.09
Air 0
Total 51.62
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3.27 Hooker (102nd Street), Niagara Falls, New York
3.27.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.27.2 Summary of Comments and Response
The U.S. Department of the Interior noted that the Niagara
River above the falls is a major waterfowl habitat. The river also
supports game fishing.
In response, the surface water use factor has already received
a maximum value of 3 because the water is also used for drinking.
The original migration score for this facility was 30.48.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Hooker (102nd Street) are:
Ground Water 0
Surface Water 52.73
Air 0
Total 30.48
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3.28 Love Canal, Niagara Falls, New York
3.28.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.28.2 Summary of Comments and Response
A. D. Little noted that the score for the surface water route
should be 67 rather than 60. No information explaining the
derivation of this score was submitted. EPA has reviewed the
documentation and computation of the surface water route score and
concurs with the original score of 60.
The U.S. Department of the Interior noted that the Niagara
River above the falls is a major waterfowl habitat. The river also
supports game fishing. In response, the surface water use factor
received the maximum value of 3 because the water is used for
drinking. The Agency acknowledges the recreational uses of the
Niagara River; however, this fact has no bearing on the surface
water use factor value because it is already at the maximum.
Further, EPA has considered the proximity of the site to the
waterfowl habitat. The value of 2 assigned to the factor, distance
to sensitive environment, reflects the Agency's recognition that
this habitat is less than one quarter mile from the site.
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The original migration score for this facility was 52.23.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Love Canal are:
Ground Water 0
Surface Water 60.00
Air 67.56
Total 52.23
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3.29 Ludlow Sand and Gravel, Clayville, New York
3.29.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.29.2 Summary of Comments and Response
The U.S. Department of the Interior noted that the blueback
herring runs in the Mohawk River 14 miles downstream from the site.
In response, this distance is greater than the 3 mile limit for
which surface water use is scored. Since no other surface water use
has been documented within the prescribed 3 mile limit, the value
remains 0.
The original migration score for this facility was 36.88.
Based on the above response to comments, the score remains
unchanged. The MRS scores for Ludlow Sand and Gravel are:
Ground Water 62.86
Surface Water 10.91
Air 0
Total 36.88
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3'30 Marathon Battery, Cold Springs, New York
3.30.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.30.2 Summary of Comments and Response
The U.S. Department of the Interior expressed concern that the
short-nosed sturgeon, a Federally designated endangered species, is
apt to be affected by this site. In response, critical habitat for
this species is at the foot of the Troy Dam, which is outside the 1
mile limit for the scoring of distance to a critical habitat.
However, this rating factor received the maximum value of 3 because
the site is less than a quarter of a mile away from other critical
habitats.
The original migration score for this facility was 30.27.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Marathon Battery are:
Ground Water 12.24
Surface Water 50.91
Air 0
Total 30.27
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3.31 Mercury Refining, Albany, New York
3.31.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.31.2 Summary of Comments and Response
The U.S. Department of the Interior expressed concern that
contamination reaching the Hudson River would affect a number of
species including the, short-nose sturgeon, a Federally designated
endangered species, that spawns at the foot of Troy Dam. The dis-
tance to a critical habitat of an endangered species was assigned a
value of 0 because the distance to the Troy Dam is greater than the
1 mile limit specified in the HRS 47 FR 31236.
The original migration score for this facility was 44.58.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Mercury Refining are:
Ground Water 5.50
Surface Water 76.92
Air 0
Total 44.58
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3.32 Olean Well Field, Olean. New York
3.32.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.32.2 S""""ary of Comments and Response
The U.S. Department of the Interior commented that there are
no known Federally designated endangered species in this area but
that there is good sport fishing in the Allegheny River.
There is no evidence to indicate an actual or potential
release to surface water from this facility. Accordingly, the
surface water pathway was scored zero.
The original migration score for this facility was 44.46. No
new technical information was submitted and no change in score was
required. The MRS scores for Olean Well Field are:
Ground Water 76.92
Surface Water 0
Air 0
Total 44.46
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3.33 Pollution Abatement Services, Oswego, New York
3.33.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.33.2 Summary of Comments and Response
A. D. Little noted a ground water population of more than 100
people based on a house count and the existence of restaurants and
small businesses in the area. In response, 20 houses (76 people)
draw drinking water from the aquifer of concern within the 3 mile
radius based on a house count by EPA. The Agency has not observed
any restaurants or businesses in the immediate vicinity of the site,
and therefore considers the estimate of 76 people to be the most
reliable based on existing information. The population served by
ground water factor value therefore remains 1.
A. D. Little stated that there is disagreement between EPA and
New York State Department of Environmental Control about the
distance to the nearest well. In response, the Agency and NYSDEC
report the same distance to nearest well in the HRS documentation
records: 0.25 miles which corresponds to a factor value of 4.
There has been no disagreement.
A.D. Little stated that an observed release to surface water
was scored based on concentrations of contaminants in a waste
lagoon. In response, NY State Department of Environmental Control
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has observed releases of contaminants from leaking drums to creeks
which feed into Lake Ontario. It was on that basis that the Agency
scored an observed release to surface water.
The U.S. Department of the Interior noted that no Federally
designated endangered species inhabit the area but that the New York
State listed bog turtle has been found in similar terrains. Any
runoff to Lake Ontario could affect numerous species of fish and
wildfowl. In response, the Agency has assigned a value of 2 to the
distance to a sensitive environment factor because Wine Creek is
2000 feet to the northeast of the site and a maximum value of 3 to
the surface water use factor for drinking water use. These two
factor values represent the highest supportable consideration EPA
can give the Lake Ontario fauna.
The original migration score for this facility was 70.80.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Pollution Abatement Services are:
Ground Water 32.65
Surface Water 96.36
Air 68.21
Total 70.80
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3.34 Port Washington Landfill, Port Washington, New York
3.34.1 List of Commenters
NPL-262 John B. Kiernan, Supervisor, Town of North Hempstead,
New York. 2/28/83.
NPL-294 Richard J. Halpern, President, Harbor Hills Residents
Association.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.34.2 S"""ngry of Comments and Response
Comments generally supported listing of this facility on the
National Priorities List. The Town of North Hempstead requested a
change in the status code from "Federal and State Enforcement" (E)
to "Voluntary or Negotiated Response" (V) to reflect the voluntary
nature of response actions taken by the Town of North Hempstead.
EPA assigns this status only to sites where the response actions
undertaken by responsible parties were sanctioned by EPA, since this
is the only way that EPA can consistently know that proper response
actions are being taken. The actions taken at this site have not
been sanctioned by the Federal Government.
The U.S. Department of the Interior expressed concern for the
prickly pear cactus which is protected by the State of New York and
a number of bird, fish, clam and turtle species residing in or
migrating through Long Island Sound, Hempstead Harbor and Manhasset
Bay. In response, EPA notes that the site borders on Hempstead
Harbor which is a sensitive environment. A factor value of 3 is
assigned because the distance to the harbor is zero.
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The original migration score for this facility was 45.46. No
new technical information was submitted and no change in score was
required. The HRS scores for Port Washington Landfill are:
Ground Water 68.60
Surface Water 0
Air 38.46
Total 45.46
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3.35 Sinclair Refinery. Wellsville, New York
3.35.1 List of Commenters
NPL-225 Atlantic Richfield Company. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.35.2 Summary of Comments and Response
Atlantic Richfield stated that the ground water pathway should
not be scored because data are lacking for two factors, the depth to
aquifer of concern and permeability of the unsaturated zone.
In accordance with instructions in the HRS, the value for
depth to aquifer of concern has been changed to 0 due to a lack of
data. The original estimate could not be substantiated. The value
for permeability is substantiated by the site report and by data in
the remedial action master plan (RAMP) for this site (3/4/83).
These data indicate that the sediments are sand and gravel
components of glacial outwash deposits which have a permeability
_3
greater than 10 cm/sec. The corresponding factor value is 3.
Atlantic Richfield stated that contaminants found in 1981
sampling could not be confirmed by 1982 sampling. The commenter
further stated that the waste characteristics factor values should
be based on naphthalene which would substantially reduce the score.
In response, mercury was found in both sampling efforts and
was listed in the documentation records as one of the substances
evaluated. In addition, lead was found in high concentrations
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(RECRA Research, Inc., 10/30/81), justifying the assigned value for
toxicity and persistence of 18.
The commenter also suggested that some double counting had
occurred in the ground water pathway scoring of population.
Population figures were provided by the Allegheny Health
Department. Population directly affected and that affected by
irrigation are not necessarily the same population because the food
produced on the irrigated lands may feed people who do not drink the
affected well water but use another, unthreatened, source. The
Agency concurs with the population calculated, 4358 persons, which
corresponds to a factor value of 4.
ARCO stated that mercury, at 3.8 ppm, was the only contaminant
found at the site and that the low concentration should not make the
site hazardous. In addition, the commenter stated that all analyses
of drinking water show no constituents of concern to be above
prescribed limits. In response, the HRS assigns a value for an
observed release because it is an indication that substances can
migrate from the site and that more may do so in the future, not
because the release observed is itself a health threat. Therefore,
as stated in Section 3.1 of the HRS, 47 FR 31224, an observed
release is scored whenever the substances are detected in
concentrations higher than background levels.
ARCO stated that mercury is not a contaminant associated with
the refining industry. In response, the detection of mercury in
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1981 and 1982 on site justifies its use as one of the reported
contaminants according to 47 FR 31229.
For the surface water pathway, the commenter states that the
score presumes contamination of a public water supply. In response,
HRS scores represent actual or potential impacts on drinking water
supplies. An observed release does not imply that drinking supplies
are already affected, only that a release from the site that may
potentially affect these supplies has occurred. Population figures
are those associated with water intakes within 3 miles of the
facility.
The value assigned to waste quantity was questioned because
not all of the material was hazardous.
In response, the HRS assigns values for waste quantity based
on the entire quantity of all waste deposited that contains
hazardous material, not on the quantity of the constituents that are
actually hazardous. As explained in the preamble to the final
National Contingency Plan, 47 FR 31190, this position was taken
because of the difficulty in determining, for all sites, that
portion of the total waste deposited that actually constitutes
hazardous material. Without this information, the Agency knows of
no internally consistent approach for comparing pure hazardous
substance quantity at facilities where definitive information is
available with hazardous substance quantity at facilities where such
information is not available.
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The commenter contended that there is no documented evidence
of release by the air route. EPA agrees with this comment because
the data were inconclusive and the air route score has been reduced
from 45.77 to 0.
The U.S. Department of the Interior noted that, although there
are no endangered species in the area, the Genesee River has
smallmouth bass and managed trout fishing. In addition, there is
some usage by wood ducks, teal, and mallards, and some beaver
activity.
The absence of endangered species disqualifies that portion of
the Genesee River within one mile of the site as a critical habitat
according to 47 FR 31236. Neither are there coastal or fresh water
wetlands within the prescribed distances of two and one mile,
respectively. The factor value for distance to sensitive
environment is, therefore, zero.
The original migration score for this facility was 72.01.
Based on the changes noted above, the HRS scores for Sinclair
Refinery are:
Ground Water 47.89
Surface Water 80.00
Air 0
Total 53.90
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3.36 Solvent Savers, Lincklaen, New York
3.36.1 List of Commenters
NPL-222 Wald, Harkrader & Ross for Bristol-Myers Company.
2/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.36.2 S"fflfflary of Comments and Response
Bristol-Myers Co. stated that the site does not pose a threat
to the public health or environment because recent ground water
sampling has detected nothing to warrant major concern and that a
FIT report (12/82) shows that fish in the nearby creek have not
experienced chronic exposure to any priority pollutants. In
response, the Agency considers the FIT data (8/82) to be conclusive
of ground water contamination and the FIT and New York State
sampling data of 1982 to be conclusive of surface water observed
release. HRS assigns a value for observed release for any valid
measurement above background levels, regardless of the frequency of
the observation as explained in the preamble to the National
Contingency Plan (47 FR 31188). For purposes of the HRS, an
observed release is an indication of the ability of substances to
migrate from the site, not a determination that the release is
widespread or currently is extensive enough to harm public health.
Consequently, as long as no errors in sampling have occurred,
assigning a value for an observed release based on a single
observation is justified.
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Bristol-Myers Co. stated that the facility should be deleted
from the NPL based on information provided by an engineering
consultant regarding population served by ground water. The value
of 1 proposed by the commenter for a population of 19 served is
based on ground water flow gradient and the fact that ground water
is discharged to a surface water body which is assumed to act as a
discontinuity to the aquifer.
In response, Bristol-Myers consultant's report has been
reviewed and does not provide sufficient justification for lowering
the facility score. The HRS states clearly in 47 FR 31230 that flow
gradient is not to be considered in developing population values.
Because of the need to develop a nationally uniform scoring system
that could be used to score a large number of sites with the data
commonly available, the HRS does not specifically take into account
such level of detail as flow gradients when determining the target
population. This position is explained more fully in the preamble
to the final National Contingency Plan at 47 FR 31190. Further,
although ground water is known to discharge to a shallow creek, no
information is provided to suggest that flow does not continue
beneath the creek. The Agency concurs with the original calculation
of 517 people served by ground water which corresponds to a value
of 2.
Bristol-Myers stated that the documentation for the waste
quantity used to assign that factor value is insufficient, and that
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a letter confirming the quantity used by EPA has not been available
for public review.
In response, the waste quantity cited in the documentation
records is based upon an analysis of generator records which the
Agency considers to be accurate. Further, the letter of
confirmation is available for public review at EPA Region II
Headquarters.
The U.S. Department of the Interior noted no known endangered
species in the area, but expressed concern for fish and wildfowl
downstream from the site and remarked that the Otselic River is
stocked by the NYDEC.
The lack of any critical habitat within the one mile distance
specified in the HRS 47 FR 31236 and the use of surface water for
recreation and fishing were reflected in the scoring of this
facility.
The original migration score for this facility was 34.78.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Solvent Savers are:
Ground Water 59.18
Surface Water 10.91
Air 0
Total 34.78
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3.37 Syosset Landfill, Oyster Bay, New York
3.37.1 List of Commenters
NPL-9 Susan A. Watins, Syosset, New York. 1/03/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.37.2 Summary of Comments and Response
Ms. Watins supported the listing of this facility.
The Department of the Interior expressed concern for transient
species of shore and wading birds, raptors and waterfowl.
Review of this facility indicates that contamination of
surface water is not likely because the contaminants are not exposed
to runoff and there are no nearby surface water bodies.
The original migration score for this facility was 54.27. No
new technical information was submitted and no change in score was
required. The HRS scores for Syosset Landfill are:
Ground Water 93.88
Surface Water 0
Air 0
Total 54.27
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3.38 Wide Beach Development, Brant, New York
3.38.1 List of Commenters
NPL-293 Thomas M. Reynolds, Erie County Legislator. 12/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
3.38.2 Summary of Comments and Response
Mr. Reynolds supported the listing of this facility on the
National Priorities List. He requested immediate establishment of a
community relations program and a timetable for cleanup.
Listing on the NPL makes a site eligible for remedial action
funding, and EPA will examine the Wide Beach Development site to
determine an appropriate response.
The Department of the Interior made reference to two
endangered species, now probably extinct, and expressed concern over
potential impacts of the contamination on spring and fall runs of
trout and salmon in the Delaware Creek. In response, EPA assigned
the maximum value of 3 to the distance to sensitive environment
factor because the site is immediately adjacent to an 8 acre wetland
to the south.
The original migration score for this facility was 56.58. No
new technical information was submitted and no change in score was
required. The HRS scores for Wide Beach Development are:
Ground Water 79.43
Surface Water 19.30
Air 53.85
Total 56.58
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3.39 G. E. Wiring Devices, Juana Diaz, Puerto Rico
3.39.1 List of Commeiiters
NFL-227 R. I. Schauseil, Plant Manager, The General Electric
& 269 Company. 2/25/83.
3.39.2 Su"""qry of Comments and Response
The commenter suggested that this facility was scored
incorrectly and should, therefore, be removed from the NPL. The
commenter stated that the observed release to ground water is scored
incorrectly because it is measured in an area of isolated perched
water rather than in the zone of saturation or true ground water.
The commenter stated that this perched water lies at least 40 feet
above the uppermost aquifer and that the intervening unsaturated
material includes a continuous clay layer.
In response, Agency review of the data reveals that the
populations originally cited cannot be linked with the contaminated
perched water because they draw from the uppermost aquifer.
Therefore, the facility has been rescored based on route
characteristics as follows: depth to aquifer of concern of 23.5
feet (value of 2) based on well logs attached to the original
documentation file; net precipitation of -26 inches annually (value
of 0); permeability of the unsaturated zone for silty clay (value of
1) based on information in well logs; and physical state for liquid
(value of 3) based on the presence of mercury. The containment
factor was assigned a value of 3 based on an unlined open dump with
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an observed release to shallow ground water. These values
effectively reduce the value indicating likelihood of migration from
45 for an observed release to 24 for route characteristics.
In addition to the above changes, the hazardous waste quantity
factor value was increased from 1 to 8. This is based on 5,000 to
10,000 cubic yards of waste containing phenolic compounds and
mercury.
The original migration score for this facility was 42.40.
Based on the changes noted above, the HRS scores for G. E. Wiring
Devices are:
Ground Water 53.33
Surface Water 8.73
Air 0
Total 31.24
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3.40 RCA, del Caribe, Barcelonata, Puerto Rico
3.40.1 List of Commenters
NPL-176 D. B. Bauer, Counsel, RCA Corporation.
NPL-289 J. Paul Sasso, Plant Manager, RCA del Caribe, Inc.
1/14/83.
NPL-290 S. M. Porfido, Staff Vice President, RCA
Corporation. 1/21/83.
3.40.2 Summary of Comments and Response
The commenter stated that the site is a RCRA regulated
facility and that a closure plan has been submitted for final EPA
approval.
In response, the portions of the facility that constitute this
site, containing hazardous materials which drained from basins 3 and
4 due to sinkhole development, are not "regulated units" under RCRA
because these portions ceased receiving waste before Janaury 26,
1983. Therefore, according to EPA policy discussed in Part VI of
the preamble to the final NPL, that volume of hazardous waste which
escaped from basins 3 and 4 falls under CERCLA jurisdiction. EPA
recognizes that the material in the remaining two lagoons and onsite
is RCRA regulated. Further, the Agency recognizes that there can be
no surface water score because the CERCLA regulated waste is all in
the ground water. The surface water route score has been changed
from 5.09 to 0.
The commenter stated that new management practices for ferric
chloride are in effect which eliminate to the extent possible the
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chance for further release. The commenter further stated that the
site should therefore be removed from the NFL.
In response, this action did not affect the hazardous
materials which drained from basins 3 and 4; therefore, the
potential hazard remains unchanged. These new management practices
affect the RCRA regulated facility, not the CERCLA regulated escaped
contaminants.
The commenter noted that local hydrogeological factors
immobilize and neutralize ferric chloride. In response, wastes are
scored for toxicity and persistence without taking into account
attenuation according to 47 FR 31229.
The commenter noted that an error had been made in the
calculation of lagoon volumes in determining waste quantity. In
response, EPA has calculated the waste quantity contained in basins
3 and 4 from dimensions furnished by the commenter in its RCRA
closure plan. The volume is 15,782.8 drums which is assigned a
value of 8.
The commenter questioned the analytical methods that
established the presence of selenium and chromium ions in the
presence of a high concentration of ferric chloride. In response,
the commenter supplied no information on the representativeness of
the RCA/BCM sample nor the comparability of the BCM method to EPA
methods. The single analytical result that was supplied cannot
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negate the greater weight and credibility of the previous positive
finding.
The commenter noted the nearest active drinking water well is
greater than one mile from the site, and that this aspect of the
population matrix should be rated as 2. In response, the value of 3
is correct because the Magueyas Public Water Supply Well is located
4,200 ft. from the site.
The commenter stated that less than 10,000 people are
connected to the Tiburones Well. In response, it is noted that the
Magueyas Well is the nearest well. The Villas Well, which is within
the 3 mile radius around the site and which draws from the aquifer
of concern, is connected to the Barceloneta water supply system and
supplies 12,000 people. This interpretation is in accordance with
47 FR 31233.
The original migration score for this facility was 31.28.
Based on the changes noted above, the HRS scores for RCA del Caribe
are:
Ground Water 53.88
Surface Water 0
Air 0
Total 31.14
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4.0 COMMENTS ON REGION III SITES
4.1 Delaware Sites;
Army Creek, New Castle County
Delaware City PVC Plant, Delaware City
Delaware Sand and Gravel, New Castle County
Harvey & Knott Drum Inc., Kirkwood
New Castle Steel, New Castle County
New Castle Spill, New Castle County
Tybouts Corner, New Castle County
Wildcat Landfill, Dover
4.1.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.1.2 Summary of Comments and Response
The commenter noted the possibility of leachate from these
facilities reaching the Delaware River and the C&D Canal. These
water bodies serve as spawning areas or food resources for a number
of anadromous fish, the endangered shortnose sturgeon, and
endangered turtle species. The presence in New Castle County of a
plant species under review for threatened status is also indicated.
The proximity of these facilities to critical habitat and
sensitive environments was considered in developing HRS scores. No
new technical information was submitted and no change in score was
required. The HRS scores for these facilities are:
GW SW Air Total
Army Creek 93.88 22.22 73.08 69.96
Delaware Sand & Gravel 80.46 5.13 0 46.60
Delaware City PVC Plant 34.30 40.21 0 30.55
Harvey Knott Drum Site 52.35 9.65 0 30.77
4-1
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New Castle Steel Site 49.56 17.62 0 30.40
New Castle Spill Site 65.62 9.57 0 38.33
Tybouts Corner 100.00 56.36 55.38 73.67
Wildcat Landfill 48.98 20.14 0 30.61
4-2
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4.2 Tris Spill Site, New Castle, Delaware
Renamed: New Castle Spill Site, New Castle County, Delaware
4.2.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.2.2 Summary of Comments and Response
The Department of the Interior comment is summarized in
Section 5.1.
Further, investigation of this site has shown that there are
chemical substances present other than Tris. As a result the name
could be misleading and has been changed to New Castle Spill Site.
The original migration score for this facility was incorrectly
reported as 38.43. Review of EPA Region III files revealed that all
available information pertaining to this facility supports a score
of 38.33. The HRS scores for New Castle Spill Site (Tris Spill
Site) are:
Ground Water 65.62
Surface Water 9.57
Air 0
Total 38.33
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4.3 Limestone Road, Cumberland, Maryland
4.3.1 List of Commenters
NPL-77 Harry Hughes, Governor, State of Maryland. 1/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.3.2 Summary of Comments and Response
The Governor of Maryland supported the listing of this facility
on the NPL.
The Department of the Interior noted that pollutants from this
facility may eventually migrate to the Potomac River with subsequent
impacts on migratory waterfowl.
In response, no sensitive environment, as defined in the HRS,
has been identified within the distance criteria specified.
The original migration score for this facility was 30.54. No
new technical information was submitted and no change in score was
required. The HRS scores for Limestone Road are:
Ground Water 32.81
Surface Water 9.23
Air 40.38
Total 30.54
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4.4 Middletown Road Dump, Annapolis, Maryland (03MD004)
4.4.1 List of Commenters
NPL-77 Harry Hughes, Governor. 1/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.4.2 Summary of Comments and Response
The Governor of Maryland supported the listing of this facility
on the NPL.
The Department of the Interior noted potential food chain
impacts on bald eagle, waterfowl and anadromous fish.
The proximity of this facility to critical habitat and
sensitive environments was considered in the original application of
the HRS. No sensitive environments or critical habitats were
identified within the distance criteria specified by the HRS.
The original migration score for this facility was incorrectly
reported as 38.51. Review of EPA Region III files revealed that all
available information pertaining to this facility supports a score
of 29.36. The HRS scores for the Middletown Road Site are:
Ground Water 48.98
Surface Water 13.43
Air 0
Total 29.36
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4.5 Monument Street Landfill, Baltimore, Maryland (03MD005)
4.5.1 List of Commenters
NPL-213 Graham G. Wisner of the Law Offices of Wisner and
Schwarz, on behalf of the Monument Street Civic
Association. 2/28/83.
The commenter stated that a recalculation of the Monument
Street Landfill HRS score based on new data results in an increase
from 7.2 to 38.49.
The commenter's recalculation is founded upon an observed
release to air, an observed release to surface water, and a maximum
value for hazardous waste quantity.
In response, the data do not support an observed release to air
because the measurements were taken in the vents and an observed
release to air retires ambient air measurements (47 FR 31236). The
Agency believes the original score of zero for the air route was
appropriate. The data likewise do not support an observed release
to surface water, via an onsite storm drain. Contaminant
concentrations in the storm drain, which passes through the site,
are greater upstream of the site than downstream because the storm
sewer passes through additional contaminant sources above the
landfill. The Agency believes the original scoring of surface water
by route characteristics was appropriate. Finally, the commenter
assigned a maximum value for hazardous waste quantity but has not
specified a quantity or offered a rationale for assigning a maximum
value. EPA uncovered five drums of hazardous materials in a limited
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excavation effort which corresponds to a rating factor value of
one. In the absence of data to the contrary, the Agency believes
the original documentation and scoring of waste quantity was
appropriate.
The Agency will consider sites for addition to the NPL during
periodic updates and will review new data relevant to the HRS as
discussed in Part VIII of the preamble to the final NPL.
4-7
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4.6 Sand. Gravel & Stone Site, Elktcm, Maryland (03MD007)
4.6.1 List of Commenters
NPL-77 Harry Hughes, Governor, State of Maryland. 1/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.6.2 Summary of Comments and Response
The Governor of Maryland supported the listing of this facility
on the NPL.
The Department of the Interior stated that contamination from
this facility has been documented in Little Elk Creek. Concern was
expressed for several species of fish occurring seasonally in the Elk
River watershed as well as for the bald eagle which may feed on these
fish. It is also noted that a plant, (Helonias bullata) , currently
under Federal review for listing as threatened, may be affected.
Review of this facility indicates that contamination has only
been documented in Little Mill Creek for a short distance downstream
from the site. Even though Little Elk Creek and Little Mill Creek
combine to become part of the same watershed, the Agency has no
documentation evidencing that contamination has entered Little Elk
Creek. Thus, no sensitive environment, as defined in the HRS , has
been identified within the distance criteria specified.
The original migration score for this facility was 41.08. No
new technical information was submitted and no change in score was
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required. The HRS scores for Sand, Gravel and Stone are:
Ground Water 70.41
Surface Water 9.65
Air 0
Total 41.08
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4.7 Bruin Lagoon, Bruin Borough, Pennsylvania
4.7.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-225 P. M. Kaplow, Atlantic Richfield Company. 2/25/83.
4.7.2 Summary of Comments and Response
A.D. Little questioned EPA consideration of a 1968 spill in
evaluating the surface water pathway for this facility.
In response, the 1968 spill involved an overflow of materials
from a lagoon on-site. The material involved wastes from refinery
processes and synthetic soap manufacturing. Immediate concerns were
the low pH (2) of the waste and degradation of surface waters due
primarily to surfactants. The material, which was extremely
soluble, moved down the South Branch of Bear Creek as a slug for a
distance in excess of 190 miles forcing the closing of several water
intakes. An estimated 4 million fish were also killed.
The HRS rates the potential threat of uncontrolled hazardous
substance facilities to human health, or ecological and
environmental resources. Evidence of these threats could be the
measurement of levels of contaminants from a facility in surface
water that represent a "...significant (in terms of demonstrating
that a release has occurred, not in terms of potential effects)
increase over background levels." Direct evidence of release
(regardless of frequency) can be used for scoring purposes. The
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distance is measured from the hazardous substance which can be
beyond the facility boundaries.
Atlantic Richfield stated that references to wastes associated
with oil and gas exploration, development and production activities
should be deleted from the site description. This commenter is
correct and all references to oil and gas exploration have been
deleted from the site description.
The original migration score for this facility was 73.11. No
new technical information was submitted and no change in score was
required. The HRS scores for Bruin Lagoon are:
Ground Water 79.59
Surface Water 89.09
Air 41.54
Total 73.11
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4.8 Heleva Landfill, North Whitehall Township, Pennsylvania
4.8.1 List of Commenters
NPL-178 D. G. Baer, Secretary, North Whitehall Township.
2/25/83.
NPL-261 H. E. and E. A. Taylor, residents. 2/25/83.
NPL-274 Dilworth, Paxson, Kalish & Kauffman representing
Heleva Landfill, Inc. 2/28/83.
4.8.2 Summary of Comments and Response
Two comments were received supporting the listing of this
facility on the NPL. It was noted that wastes were dumped on top of
an old mine hole and that underground shafts could carry the wastes
several miles.
The following discussion is in response to comments made by
attorneys for Heleva Landfill, Inc. The commenter stated that EPA
obviously failed to conduct a factual investigation of this site
before branding Heleva a Superfund priority. In addition, the
commenter stated that the EPA used grossly out-dated data and the
rankest form of hearsay (newspaper articles) and never tried to
update or verify this information. In response, though the
referenced newspaper articles are contained in the EPA Region III
files on this facility, these articles were not used in the HRS
evaluation process as justification for HRS rating factor values.
Numerous sampling expeditions have been conducted at the Heleva
facility, the most recent of which was conducted by the State of
Pennsylvania on May 26, 1983. Samples taken on that date continue
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to support the presence of trichloroethylene, dichloroethylene and
chloroform in the ground water at this facility.
The commenter noted inaccuracies in the press release
describing this facility. The press release has been changed to
correct these inaccuracies.
The commenter stated that the HRS worksheets do not provide any
interpretive information to explain how scores were calculated, nor
do they identify the source of the information relied upon by EPA in
computing each score.
Specific information used to develop HRS scores, and the
sources of that information are generally contained in the
documentation records supporting HRS score sheets. These records
are contained in the public docket on the NPL. "Interpretive"
information explaining how data are used to develop scores is
contained in the Hazard Ranking System which is Appendix A of the
National Contingency Plan (40 CFR 300) as published in the Federal
Register (47 FR 31219) and was available for comment during the
rulemaking.
The commenter stated that Heleva never accepted PCBs or waste
from any PCB generator as indicated in the HRS documentation
records. In response, review of the site file for this facility
indicates insufficient evidence to support the scoring of this
facility based on the presence of PCB. No change to values for
waste characteristics is required due to the presence of chloroform
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at the facility. The original observed release to surface water,
however, was based on low ppb levels of PCS. This pathway has been
reevaluated for route characteristics and containment, and values
were assigned as indicated below.
Facility slope and intervening terrain was assigned a value of
3 to reflect slopes greater than 8 percent. One year 24-hour
rainfall was evaluated using HRS maps and assigned a value of 2.
Distance to nearest surface water was assigned a value of 3 because
Todd Lake is partially on the Heleva site. Physical state also
received a value of 3 to reflect the presence of liquids. Contain-
ment was rated a 3 because of the lack of adequate cover and
diversion systems. These changes resulted in a reduction of the
surface water pathway score from 10.49 to 9.79. The site descrip-
tion and documentation records have been changed accordingly.
The commenter requested information to substantiate the value
assigned to hazardous waste quantity. In response, the hazardous
waste quantity factor value has been raised from 6 to 7. This score
is substantiated by a memo, prepared by the staff of the
Pennsylvania Department of Environmental Resources, containing
information obtained during a field investigation of May 27, 1971.
This memo cites 3000 gallons of waste (25-50 percent TCE) per week
for two years (1968-1969) from Western Electric. This converts to
6240 drum equivalents or 1545 cubic yards. The change in score was
necessary because quantity was originally reported as 772 cubic
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yards based on the concentration of TCE. The HRS, however, assigns
values for waste quantity based on the entire quantity of all waste
deposited that contains hazardous material, not on the quantity of
the constituents that are actually hazardous. As explained in the
preamble to the final National Contingency Plan, 47 FR 31190, this
position was taken because of the difficulty in determining for all
sites that portion of the total waste deposited that actually
constitutes hazardous material.
Review of this facility revealed an error in the calculation of
the ground water targets score. The multiplier of 3 was omitted for
ground water use. Correction of this error results in a value of 9
rather than 3 for this rating factor and raises the targets category
score from 38 to 44.
The original migration score for this facility was 41.79.
Based on the changes noted above, the HRS scores for Heleva Landfill
are:
Ground Water 86.34
Surface Water 9.79
Air 0
Total 50.23
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4.9 Hranlca Landfill, Buffalo Township, Pennsylvania
4.9.1 List of Commenters
NPL-256 PPG Industries. 2/28/83.
4.9.2 Summary of Comments and Response
The commenter indicated ongoing efforts to clean up this
facility and requested a change in response status from "E" (Federal
and State Enforcement) to "V" (Voluntary or Negotiated Response).
While the Agency encourages voluntary actions by responsible
parties, the actions described have not been sanctioned by a formal
agreement with EPA and, therefore, do not meet current criteria for
the "Voluntary" classification set forth in Part VI of the Preamble
to the final NPL.
Review of EPA Region III files for this facility, however,
indicate that the "E" classification is also inappropriate. The
response status has been changed to "D" (to be determined).
The original migration score for this facility was 51.94. No
new technical information was submitted and no change in score was
required. The HRS scores for Hranica Landfill are:
Ground Water 67.35
Surface Water 10.91
Air 58.46
Total 51.94
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4.10 Lord-Shope Landfill, Girard Township, Pennsylvania (03PA020)
4.10.1 List of Commenters
NPL-180 Lord Corporation. 2/24/83.
4.10.2 Summary of Comments and Response
The commenter indicated that extensive remedial efforts have
been undertaken and continue under a Consent Order and Agreement
signed by Lord Corporation, the Pennsylvania Department of
Environmental Resources, and the property owners, Mr. and Mrs.
Melvin Shope. A change in response status from "E" (Federal and
State Enforcement) to "V" (Voluntary or Negotiated Response) was
requested.
While the Agency encourages voluntary actions by responsible
parties, the actions described have not been sanctioned by a formal
agreement with EPA and, therefore, do not meet current criteria for
the "Voluntary" classification as set forth in Part VI of the
preamble to the final NPL.
The original migration score for this facility was 38.89. No
new technical information was submitted and no change in score was
required. The HRS scores for Lord-Shope Landfill are:
Ground Water 65.62
Surface Water 14.88
Air 0
Total 38.89
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4.11 McAdoo, McAdoo Borough/Kline Township, Pennsylvania
4.11.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation, An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
4.11.2 Summary of Comment and Response
The commenter noted that this facility is actually two sites
separated by 1.25 miles, and claimed that CERCLA requires such
facilities to be scored separately, for purposes of the NPL.
Section 104 of CERCLA, however, specifically, authorizes EPA
to treat two noncontiguous facilities as one for purposes of taking
response action if the sites are reasonably related, and CERCLA does
not speak to the issue with respect to the listing of sites on the
NPL. Since the NPL lists sites "for the purpose of taking remedial
action, CERCLA Section 105 (8) listing is sufficiently related to
the response function that EPA can treat two sites, as one for
purposes of listing as well. Although EPA's policy is to score
individual sites separately whenever possible, the sites that
comprise the McAdoo facility are being scored and listed as one
facility because both sites were operated as one facility involving
the same ownership and wastes.
The original migration score for this facility was incorrectly
reported as 65.32. Review of EPA Region III files revealed that all
available information pertaining to this facility supports a score
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of 63.03. The HRS scores for McAdoo are:
Ground Water 86.34
Surface Water 10.49
Air 65.77
Total 63.03
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4.12 Metal Banks, Philadelphia, Pennsylvania
4.12.1 List of Commenters
NPL-L20 Mattioni, Mattioni and Mattioni, Attorneys for Metal
Bank of America. 3/7/83.
4.12.2 Summary of Comment and Response
The commenter noted that Metal Banks currently is cleaning up
the site and stated that, given this fact, inclusion on the NPL is
improper for a variety of reasons.
The commenter stated that because of cleanup actions and other
reasons the site is not inactive and, therefore, should not be
listed. Whether or nor the site is inactive however, EPA's
authority to examine and respond to sites is not limited to inactive
sites, but extends to any site of a release or threatened release.
EPA calculates the HRS score for purposes of listing on the NPL
based only on the characteristics of that release or threatened
release. The site's status as active or inactive, and the
determination whether it is currently being cleaned up, will be
taken into account after inclusion on the list to determine what
response by EPA, if any, is appropriate.
The commenter also claimed that because the site is being
cleaned up there is no current or imminent release, and that EPA's
own contractor has stated that the cleanup is being performed
properly. EPA's response is that releases have been observed both
into the Delaware River and into ground water underlying the site.
Those releases are more than sufficient to establish the authority
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to respond under CERCLA and to list the site on the NPL if EPA finds
it appropriate to do so. In addition, HRS scores are calculated
according to conditions existing at the site before any response
actions are taken, for reasons discussed in the preamble to the NPL,
and, therefore, even if cleanup has largely eliminated the release,
the scoring would remain correct. The fact that cleanup is underway
will be taken into account in determining what additional EPA
response, if any, is necessary, and may eventually justify deleting
the site from the list when cleanup is complete. Until cleanup is
fully achieved, however, EPA cannot rely on current activities or
promises as a determination that the problem is solved, and that the
site therefore should not be on the NPL, because there is always the
possibility that current activities might be suspended for some
reason or that additional contamination requiring additional
response actions might be found in the course of cleanup. The
Agency has not yet developed guidance for determining when cleanup
will be considered complete for purposes of deleting sites, and has
not taken the position that a site cannot be deleted until "the last
drop of waste material" has been removed, which was the commenter's
apparent misconception.
The commenter claims also that inclusion of the site on the
NPL is inconsistent with requirements in CERCLA that response
actions be cost-effective, since cleanup is underway at the site and
any additional EPA response would be unnecessary. This comment,
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however, does not recognize the fact that inclusion of a site on the
NPL does not determine that reponse funds will be spent. Listing
serves to guide EPA as to what sites appear to present the most risk
to the public for purposes of determining what response might be
appropriate to abate the risk. It is fully within EPA's discretion
to determine that cleanup actions at a site on the NPL will be
adequately completed by a private party and that, therefore, no
fund-financed cleanup is necessary.
The commenter also noted that the Metal Banks site was
assigned a status notation of "E" in the proposed NPL, interpreted
this to designate a need for federal and state enforcement action,
and protested that no such need exists because cleanup is currently
underway. In response, the "E" notation does not represent a
judgment as to what may be necessary at the site in the future, but
simply reports that an enforcement action has been filed with
respect to the site. This is an accurate report of the status at
the Metal Banks site, where EPA filed an action in 1980 to enforce
cleanup of the site, and the responsible party's cleanup actions
have been taken in response to that lawsuit. It is noted that the
commenter reported that approximately 4000 gallons of oil have been
recovered. EPA review of the documentation for this facility noted
that the waste quantity should be 400-420 drums rather than 381. No
change in HRS score results.
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The original migration score for this facility was 33.23. No
new technical information was submitted and no change in score was
required. The HRS scores for Metal Banks are:
Ground Water 4.95
Surface Water 57.27
Air 0
Total 33.23
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4.13 Moyers Landfill, Eagleville, Pennsylvania
4.13.1 List of Commenters
NPL-107 Richard Sheehan, Attorney representing residents.
2/4/83
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L14 N.T. McFarland, Chairperson Board of Supervisors,
Lower Providence Township. 3/11/83.
NPL-L15 R. T. Brown, Board of Supervisors, Lower Providence
Township. 3/13/83.
NPL-L18 M. S. Ralston, Board of Supervisors, Lower Providence
Township. 3/12/83.
NPL-L26 C. E. Kane, Resident. 5/9/83.
4.12.2 Summary of Comments and Response
Commenters Sheehan, McFarland, Brown, Ralston and Kane
requested that the site be included on the final NPL.
Arthur D. Little noted that the toxicity value for
trichloroethylene should have been 3 rather than 2. This is,
however, the Sax score for intravenous intake. In the case of the
ground water and surface water routes, the mode of exposure would be
oral or inhalation, for which trichloroethylene is scored as
moderately toxic. Consequently, an HRS value of 2 is appropriate.
The original migration score for this facility was 37.62.
Based on the above response to comments, the score remains
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unchanged. The HRS scores for Moyers Landfill are:
Ground Water 53.88
Surface Water 36.50
Air 0
Total 37.62
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4.14 Old City of York Landfill, Seven Valleys, Pennsylvania
4.14.1 List of Commenters
NPL-70 Henrietta Williamson. 1/31/83.
NPL-75 Kenneth E. Chilcoat. No date.
NPL-171 M. L. Rohrbaugh. 2/22/83.
NPL-239 J. A. and M. L. Rohrbaugh. 2/22/83.
4.14.2 Summary of Comments and Response
The conmenters voiced concerns about contaminated wells and
leachate seeps. These concerns were taken into consideration during
the original site scoring.
The original migration score for this facility was 33.93. No
new technical information was submitted and no change in score was
required. The HRS scores for The Old City of York Landfill are:
Ground Water 58,16
Surface Water 7.97
Air 0
Total 33.93
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4.15 Osborne, Grove City, Pennsylvania (03PA031)
A.15.1 List of Commenters
NPL-214 Skadden, Arps, Slate, Meagher and Flora, Attorneys for
Cooper Industries. 2/28/83.
4.15.2 Summary of Comments and Response
The commenter indicated that the rainfall and evapotrans-
piration maps used to score the site were misread and that net
precipitation in the area of the landfill is 12-15 inches. This net
precipitation range merits a score of 2 rather than 3. Review of
the site file shows that State maps, more detailed than those in the
HRS, were used to evaluate this factor. Based on these maps
(Isolluvial Map of Annual Rainfall and Evapotranspiration in Western
Pennsylvania, from Pennsylvania Department of Environmental
Resources (PADER) Water Bulletin #13), the factor, originally scored
as a 3, was correct.
It was noted that the documentation records, and documents
cited therein, support different scores from 0 to 2 for permeability
of the unsaturated zone rather than the assigned value of 3. The
original score of 3 was based upon permeabilities reported in the
"Mercer County Soil Survey." The value for this factor has been
reduced to 2 because the Clarion and Homewood formations underlying
the site are primarily sandstones with permeabilities ranging from 7
-3 -4
x 10 cm/sec to 9x10 cm/sec (value of 2). These values were
taken from a report by C. W. Poth (State of Pennsylvania, 1963)
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which better describes the site specific characteristics of the
intervening strata than the country-wide survey originally used to
evaluate this rating factor.
The value of 8 for hazardous waste quantity was questioned by
the commenter because it was not supported by the information
presented in the documentation records. In response, the volume of
waste was originally estimated conservatively as one percent of
landfill volume or 2,420 cubic yards, which should have received a
value of 7. The hazardous waste quantity was originally scored an 8
on the basis that the estimate was conservative. Additional reports
submitted to EPA by generators of wastes which were disposed of at
the site indicate an estimated waste quantity of 3,111 cubic yards
which supports the original value of 8.
The population figure of 10,602 was also questioned by the
commenter. The commenter acknowledged the Grove City population but
stated that it is unlikely that sufficient other people could be
included to bring this figure to 10,000, the number required to
justify the assigned matrix value. In response, the original
population estimate was based upon the Federal Reporting Data
System - Public Water Supply (FRDS-23) 5/7/82 which is maintained by
EPA Regional Offices. These records were reviewed and the
population figure has been recalculated. The records identify the
following population served by ground water within the 3-mile
radius: Grove City Municipal Authority (8,300), two mobile home
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parks (82), a small township (100), a large business enterprise
(1,400) and six other wells serving a total population of (440).
The total population served is conservatively estimated to be 10,312
(assigned value of 5) and no change was required.
The original migration score for this facility was 58.41.
Based on the change noted above, the HRS scores for Osborne are:
Ground Water 93.33
Surface Water 14.55
Air 0
Total 54.60
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4.16 Palmerton Zinc Pile, Palmerton, Pennsylvania
4.16.1 List of Commenters
NPL-270 W. R. Bechdolt, Director of Administration and
Engineering, The New Jersey Zinc Company, Inc.
2/24/83.
4.16.2 Summary of Comment and Response
The commenter noted typographical errors in the site
description and indicated that zinc and cadmium have not been found
in the deep aquifer.
Corrections to the site description suggested by the commenter
were accepted and the allusion to the finding of zinc and cadmium in
the deep aquifer was deleted.
It was also stated by the commenter that the facility is not
an "Uncontrolled Hazardous Waste Site."
In response, the term "uncontrolled hazardous waste site" has
a very broad definition associated with it and is generally applied
to all Superfund sites. This term is not meant to imply any
judgment as to whether or not the conditions or wastes at any site
are actually "controlled".
The commenter indicated that the only use of shallow ground
water in the area is industrial use and that no population is
affected by the contamination.
In response, the estimate of 2,000 people served by ground
water is a valid assessment of the population at risk due to usage
of the contaminated shallow wells through 1981. The ground water
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use value is changed from 3 to 2 because of the availability of
alternative water from the uncontaminated deep aquifer.
The original migration score for this facility was 46.44.
Based on the change noted above, the HRS scores for Palmerton Zinc
Pile are:
Ground Water 73.47
Surface Water 10.91
Air 0
Total 42.93
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4.17 Presgue Isle. Erie, Pennsylvania (03PA034)
4.17.1 List of Commenters
NPL-59 T. 0. Andrews, Hammermill Paper Company visit to
EPA. 2/1/83.
NPL-80 T. 0. Andrews, Manager, Environmental Affairs,
Hammermill Paper Company. 2/1/83.
NPL-112 T. 0. Andrews to Denise Sines (Telecon). 2/8/83.
NPL-172 Skadden, Arps, Slate, Meagher and Flora, for
Hammermill Paper Company. 2/25/83.
NPL-248 Hammermill Paper Company meeting with EPA
Region III. 2/8/83.
NPL-278 T. 0. Andrews, Manager, Environmental Affairs,
Hammermill Paper Company. 2/28/83.
NPL-L1 Skadden, Arps, Slate, Meagher and Flora, for
Hammermill Paper Company. 2/28/83.
NPL-L22 Skadden, Arps, Slate, Meagher and Flora, for
Hammermill Paper Company. 4/4/83.
4.17.2 Summary of Comments and Response
The Hammermill Paper Company has submitted several reports
regarding the contamination found at the site. A number of the
comments received by the Agency related to meetings and discussions
held by representatives of the Company and the Agency over several
years. However, two principal reports were submitted which serve as
the basis for making response. One report was prepared in July 1979
and submitted as a comment to the EPA on 28 February 1983
(NPL-278). The second report was prepared in March 1983 and
submitted as comment on 4 April 1983 (NPL-L22). The response to
comments focuses on the material contained in the March 1983 report,
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and the specific changes to the HRS scores recommended by the
commenter in its submittal in April 1983.
The comments made by the Hammermill Paper Company center
around three general areas regarding the listing of the site on the
NPL: (1) insufficient time has been provided to obtain and evaluate
pertinent material in EPA's files, and to complete the technical
analysis needed to respond to EPA's allegations; (2) EPA's proposed
procedure to list sites on the NPL and make subsequent revisions
does not provide opportunity for interested parties to submit
comments and to use the HRS to delete sites; and (3) the Hazard
Ranking System was inappropriately applied to the Presque Isle site.
In regard to the commenter's statement that insufficient time
was provided for response, the NPL was announced to the public on 20
December 1982 and published in The Federal Register on 30 December
1982. The docket package for the site, consisting of the HRS
worksheets and Documentation Record, was available to the public for
those sites appearing on the NPL at that time. Essentially all
background data and other information relied upon by EPA in
developing the proposed listing of Presque Isle were released to
Hammermill in response to its first request. Although some
information related to the site was withheld as confidential
internal Agency information, none of the information constituted a
basis for proposing the listing. In addition, even though EPA did
not formally extend the comment period, within its discretion to
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consider late comments EPA has accepted and considered comments at
least through July 1983. Considering all these factors, EPA
believes sufficient time has been provided (through August of 1983)
for preparation and submittal of comments.
The commenter expressed a concern that EPA intended to revise
the NPL without notice and opportunity for comment. In response,
although the statute and legislative history are somewhat unclear as
to whether such procedures are required, EPA intends to propose any
revisions to the NPL, and provide an opportunity for comment before
promulgating them as final additions to or deletions from the NPL.
The commenter also stated that the criteria for deleting sites
from the NPL, set forth in the preamble to the proposed NPL (47 FR
58479, December 30, 1982), are too restrictive and that EPA should
delete sites on the basis of recalculation of HRS scores. In
response, EPA's publication of these criteria in the preamble to the
proposed list did not constitute the final adoption of these as
exclusive criteria for listing. These criteria are considered as
guidance by EPA. In accordance with this guidance the Agency does
not expect to delete sites based on changes in HRS score, for a
variety of reasons set forth in the preamble to the final NPL. The
actual decisions as to what factors will be relied on for deleting
sites, however, will be made on a case by case basis as individual
sites are considered for deletion, taking into account the guidance
criteria and any other appropriate factors.
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The commenter's general statement that the HRS was inappro-
priately applied to the site is based upon two specific comments
made in a technical report on the HRS prepared by the commenter's
consultant. First, the commenter states that there is no conclusive
evidence of a connection between Hammermill's injection activities
and the fluid which once seeped from the now-plugged Presque Isle
gas well on Beach No. 7 and that, therefore, there is no known
established technical basis for linking Hammermill with this site.
Second, the commenter maintained that completion of the HRS model
for the Presque Isle site, according to EPA instructions, results in
a score different from and significantly lower than that originally
calculated by the EPA. Further, the site does not meet the criteria
for placement on the National Priorities List (NPL).
In response to the first point, the documentation of seepage
occurring at the well is not disputed by the commenter. Conditions
did exist at Well No. 7 that caused fluids from deep geological
strata (i.e., the Bass Island formation) surrounding the well to, in
the early 1970s, rise vertically to elevations (below the ground)
that may affect shallower aquifers which are used for drinking
water. Examination of Well No. 7 (an abandoned gas well, one of
many that are believed to be in the area) indicates that the
construction of it permits fluids to move upward via the annulus
opening around the well pipe. The method used to construct Well No.
7 is typical of the manner in which gas wells were constructed in
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the area. The Agency's interest with Well No. 7 is broader than
simply mitigating the potential for contamination at this single
well. The Agency believes there is sufficient cause to be concerned
that other abandoned wells in the area also pose a potential threat
to the shallower aquifer which is used for drinking water.
In order to estimate the quantity of the fluid threatening
drinking water for purposes of MRS scoring, EPA attempted to
determine the source of the fluid. After examining all apparent
alternative sources, and analytical evidence indicating the
composition of the fluid, EPA determined that the most likely source
of the fluid is pulping process waste injected during the 1970's by
Hammermill. These wastes were injected into geological strata below
the site of Well No. 7, approximately four miles horizontal distance
from Well No. 7. No monitoring well has ever been installed to
monitor the migration of 1.1 billion gallons of injected waste.
However, fluid samples taken at Well No. 7 over a number of years
indicate the presence of resin acids, phthalates, hydrogen sulfide
and several other compounds which may be reasonably linked to the
pulping process. (See report number EPA 440/l-80/025b,
December 1980, referenced by the commenter.)
EPA has therefore used as the waste quantity the roughly one
billion gallons of waste injected by Hammermill. It should be borne
in mind, however, that, the assumption that Hammermill's injection
activity caused the discharge from the Beach No. 7 well is relied
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upon only to determine this waste quantity factor in calculating an
HRS score for the site. Listing the Presque Isle site on the NPL
does not constitute any determination of responsibility or
reliability.
The commenter presents the view that the conditions that have
occurred at Well No. 7 may be attributed to factors such as:
interaction of fluids with natural formational materials; materials
indigenous to oil and gas bearing strata; expected concentrations of
naturally occurring materials in the Bass Island aquifer; and
natural formation pressures. Technical reports submitted by the
commenter presented computations showing that the concentration of
any injection fluids reaching Well No. 7 would be one percent or
less of point source concentration.
In response, current analytical results (lUS concentrations,
variability of specific concentrations of contaminants over time,
and the identification of compounds associated with pulping
processes) versus background conditions of the Bass Island aquifer
indicate that a reasonable basis exists for the conclusion that the
injection of pulping wastes bears a causal relationship to the
fluids in the Bass Island formation. Supporting this is the fact
that exploratory borings in the Erie, Pennsylvania, area indicate
that the Bass Island formation naturally contains a clear high
chloride brine with no indication of oil or gas present. The
commenter's citation in technical reports submitted of the
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characteristics of oil and gas bearing strata located in Texas and
California is inappropriate to known conditions of the Bass Island
formation. The commenter's analysis of the Bass Island brine, prior
to the start of injection, also exhibits characteristics quite
different from current analysis of the aquifer at Well No. 7,
Additionally, the foul-smelling discharge from Well No. 7 was
not reported to have started until the early 1970's. Since this
well was abandoned at the turn of the century and no foul-smelling
discharge was noted until the early 1970's, coincident with the time
when Hammermill was injecting waste, and because the commenter
agrees that the source of the discharge is the Bass Island
formation, it is reasonable to link the discharge to the injection
program. This is further supported by pressure data collected prior
to the injection program and data from the Renkis Well, neither of
which showed sufficient pressures to cause surface flows. The
commenter did not provide any creditable data demonstrating that the
Bass Island formation is under sufficient natural pressure to cause
surface flows in the Erie area.
The commenter1s comments regarding the application of the HRS
model in the scoring of the site is done on a point by point basis
beginning with the ground water migration route.
It was the contention of the commenter that, based on the HRS
stated criteria, there is no basis for an observed release to ground
water if the aquifer of concern is the surface (shallow) aquifer.
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The commenter is correct. Contamination in the surface
aquifer has not been measured. The fact that the open annulus of
the bore hole intercepts the surface aquifer is not evidence of a
measured release to the aquifer. The original score was based upon
an observed release, value 45. Without evidence of an observed
release the value is changed to 0, and the site has been rescored
using route characteristics and containment factors.
The commenter indicated that if the route characteristics are
scored they should receive the maximum score for all rating factors
tested.
In response, all the factors under route characteristics have
received the maximum values except net precipitation which received
a value of 2. The apparent discrepancy is probably due to
interpretation between printed lines on figures printed in the HRS
manual.
The commenter stated that the well should be considered a
container and since it has been capped since 1979, should be
considered sealed. This would result in the assigning of a rating
factor score of 1.
In response, the construction of Well No. 7, and potentially
other abandoned gas wells in the area, provides an open conduit for
fluid migration to the surface aquifer. The fact that the well has
been capped at the surface (ground elevation) since 1979 does not
negate the potential impact of past waste migration at this well, or
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other abandoned wells not yet identified in the area. The well is
considered to have had no containment historically and has been
assigned a containment value of 3.
The commenter claimed that documentation has not been provided
to show that potentially hazardous substances are present at the
Presque Isle site in amounts greater than reportable quantities and,
therefore, the rating factor's toxicity/persistence and hazardous
waste quantity should receive a score of zero.
In response, various substances have been identified in the
fluids seeping from Well No. 7 including organic chemicals. Test
results from a well considered by the Agency to be representative of
background ground water quality show levels of contaminants below
those found in the fluid samples taken from Well No. 7 and
formational waters sampled at the site. This ground water analysis,
information available on the geology of the area, and knowledge of
past disposal practices in the area, indicate that the substances
detected at Well No. 7 (that are above background levels) resulted
from past deep well injection. A review of the past injection
disposal program, and knowledge of the geology in the area indicate
that the Bass Island formation contains the potentially hazardous
materials. Since Well No. 7 intercepts this formation and acts as
the conduit for migration, it is considered part of the site.
Since the substances cannot be separated from the total volume
of injected fluid, (approximately 1.1 billion gallons of pulping
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wastes), the entire volume must be considered hazardous. A value of
8 has been assigned to the hazardous waste quantity rating factor.
Additionally, the original score for toxicity/persistence was
based upon the presence of lead (value 18). The Agency has reviewed
the available data on the site and has reduced the toxicity/
persistence value to 12 based on the presence of benzene and
phenol. Analysis of water samples taken from Well No. 7, when
compared to background ground water samples, does not indicate a
sufficiently high concentration of lead in Well No. 7 to warrant
scoring based upon this metal. However, benzene and phenol do
exceed background levels sufficiently for inclusion in scoring.
According to the promulgated HRS (47 FR 31229, July 16, 1982),
reportable quantities of a substance are required to score it for
toxicity/persistence only where "the total inventory of the
substances in a facility is known," which is not the case at the
Presque Isle site.
It was suggested by the commenter that, if the Bass Island
formation is the aquifer of concern, there are no targets at risk
since the water is saline. However, if the surface aquifer (the
aquifer used as the source of drinking water) is the aquifer of
concern, then the commenter would agree with the scoring of the
rating factors under the targets category.
In response, the aquifer of concern is the surface aquifer.
As discussed previously, the Bass Island formation was the
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receptacle for the injected material. The Agency believes there is
sufficient evidence to indicate that the surface aquifer may
potentially be affected because fluids from the Bass Island
formation are rising vertically in Well No. 7, and possible other
abandoned wells in the area. Contamination of the surface aquifer
in the area of Well No. 7 is estimated to affect a target population
of 1 to 100 persons.
The result of changes previously discussed reduced the ground
water route score from 28.57 to 20.51.
In the scoring of the observed release rating factor under the
surface water pathway, the commenter agreed with the Agency that no
evidence is available to indicate an observed release has occurred
to surface waters.
In the scoring of route characteristics the commenter
suggested that rainfall, as assessed under surface water route
characteristics, will act as a diluter of the contaminants and not
as a driving or leachate generating mechanism.
In response to this point, the evaluation of the surface water
pathway effects of rainfall are assessed to determine the potential
risk from runoff, not the potential for leachate generation. The
HRS model does not provide for any beneficial effect purported due
to dilution of contaminants. No change in scoring is warranted due
to acclaimed potential for dilution.
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The commenter noted that the MRS Instructions for scoring the
containment rating factor for the surface water pathway are not very
applicable to the Presque Isle Well No. 7. The commenter suggested
that a scoring value of 1 be assigned to the assessment of the
containment. The commenter pointed to the instructions of the HRS
which require assignment of a value of 1 for the rating factor if
the containers (i.e., the well) are sealed and in sound condition,
but not surrounded by a sound diversion or containment system.
In response, the scoring of the containment rating factor with
a value of 3 is the result of the Agency's evaluation that the
potential for release to surface water did exist prior to the
capping of the well in 1979. The HRS allows for the assessment of
potential effects to the environment based upon past disposal
practices or conditions that existed prior to any remedial action
taken at a hazardous waste site. The Agency believes the assignment
of the value of 3 is correct, and this value more accurately
represents the site-specific conditions of Well No. 7.
The commenter disagreed with the values assigned for the
rating factors under the waste characteristic category. The
commenter stated that the value should be zero for both the toxicity/
persistence and hazardous waste quantity rating factors, based upon
similar reasoning as previously described under the ground water
pathway discussion of comments.
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In response, the Agency believes scoring for these two rating
factors is justified as discussed previously in the response to
comments under the ground water route pathway. However, similar
changes to the scoring are required under this pathway to reflect
scoring of the toxicity/persistence rating factor on the basis of
benzene and phenol. This resulted in a change of the toxicity/
persistence value from 18 to 12. The surface water pathway score
has been changed from 10.67 to 8.20 due to the value change of
toxicity/persistence.
In the evaluation of the air route pathway, the commenter
stated that the observed air release is invalid because the
investigative team created transitory conditions when they opened
the capped well to conduct sampling. The commenter noted that
measured levels may not be appropriate if readings were taken in the
well casing; were not made under conditions of equilibrium; and/or
were not above background levels. Additionally, the commenter noted
that the presence of hydrogen sulfide in the Bass Island formation
was not reported. The commenter acknowledged that controlled
releases (by opening the vent cap) have taken place in the past
(twice a week) to relieve seepage and gas pressures. The commenter
also implied that the well might require opening for maintenance.
In response, receptors would clearly be at risk during any
venting or opening of the well for whatever purposes. Opening the
well for maintenance (i.e., venting) occurs periodically and
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presents a risk to receptors. In addition, draeger tube sampling
gave a positive indication of hydrogen sulfide when the problem at
Well No. 7 first became evident. The HRS defines an observed air
release as data that show levels of a contaminant at, or in the
vicinity of, the facility that significantly exceed background
levels regardless of the frequency of occurrence. Subsequent air
sampling measured levels of hydrogen sulfide significantly higher
than background levels in the area. Sampling procedures and
protocol were strictly adhered to, with sampling indicating releases
to the ambient air surrounding Well No. 7 after equilibrium
conditions were achieved at the site. Sampling was not done in the
well itself.
The Agency's review of the data and method of documentation of
the air release is sufficient to record an observed release for the
air pathway; therefore, a value of 45 for scoring of the observed
release was assigned.
The commenter stated that it accepted the original scoring of
total waste characteristics at the score of 17, largely due to the
fact that sufficient information was not provided in the documenta-
tion package to permit it to technically score the rating factors.
The commenter added that the fact that hydrogen sulfide was found in
the well was not surprising, since this well was a deep gas well.
In review of the rating factors by the Agency, for waste
characteristics, a change was made to increase the original
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reactivity and incompatibility score of 0 to 3. The other rating
factors were not changed. The change to the reactivity and
incompatibility rating factor was made in recognition of the fact
that dissolved hydrogen sulfide in the Bass Island brine can be
released as gas once the brine reacts with lower pH water. This
change has resulted in a change of the total waste characteristics
score from a 17 to 20.
No substantive comments were made by the commenter regarding
the scoring of the targets category under the air pathway. No
changes were made by the Agency. However, due to the scoring change
in waste characteristics, the total scoring of the air route pathway
increased from 56.67 to 66.67.
The original migration score for this facility was 37.20.
Based on the changes noted above, the HRS scores for Presque Isle
are:
Ground Water 20.51
Surface Water 8.21
Air 66.67
Total 40.59
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4.18 Westline, Westline, Pennsylvania
4.18.1 List of Commenterst
NPL-L29 Robert P. Ging, Jr., Attorney at Law on behalf of
Westline Inn. 5/11/83.
4.18.2 Snmmary of Comment and Responses
The commenter stated that ground water contamination is
occurring from a source unrelated to the site, probably oil and gas
drilling. Numerous wells in the Westline area contain similar or
greater amounts of five aromatic contaminants and several of the
wells sampled are geologically and topographically updip. One well
is across the stream.
In response, EPA has identified several species of organic
contaminants in ground water samples taken from the Westline Inn
well which either do not appear or occur in significantly lower
concentrations in offsite well samples. This is conclusive evidence
that a release to ground water from Westline has occurred;
therefore, no change to the ground water route score (36.73) is
warranted.
The commenter stated that concentrations of phenols in Kinzua
Creek upstream of the site are higher than the 0.52 ppb concentra-
tion detected in a downstream sample. Consequently, other sources,
probably oil and gas drilling and natural contamination, are
contributing or solely responsible for the observed surface water
contamination.
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In response, the Agency has not, to date, detected a
significant increase in contamination in Kinzua Creek downstream of
the site. EPA agrees with the comment that an observed release to
surface water cannot be substantiated at this time. The Agency,
therefore, has reevaluated the surface water route using route
characteristics. The score for surface water is changed from 7.55
to 5.54 based on the following rating factor values. Facility slope
and intervening terrain were evaluated using a U.S.G.S.
topographical map (Westline, PA quadrangle) and assigned a value of
0. One year 24-hour rainfall was assigned a value of 2 using the
rainfall map provided in the HRS. Distance to nearest downslope
surface water was determined to be less than 1000 feet and assigned
a value of 3. Physical state of the material, as deposited, was
sludge warranting a value of 3. Containment was assigned a value of
3 due to unsound diking of the waste lagoons.
The commenter stated that none of the air samplings to date
has shown air contamination in excess of OSHA industrial
contamination levels for workers in a similar environment.
In response, the Agency attributes an air release to sites
where ambient contaminant concentrations exceed background levels as
explained in the HRS (47 FR 31236). OSHA regulations are not
considered; therefore, no score change is warranted.
The commenter stated that contact exposure does not exceed
OSHA regulations.
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In response, the direct contact score was based on
accessibility to the hazardous substance, its containment and
toxicity, and the potential targets as described in Section 8.0 of
the MRS (47 FR 31241). OSHA regulations are not considered;
therefore, no score change is warranted. The direct contact score
is not, however, considered in the total MRS migration score upon
which listing on the NPL is based.
The original migration score for this facility was 31.85.
Based on the changes noted above, the HRS scores for Westline are:
Ground Water 36.73
Surface Water 5.54
Air 40.38
Total 31.71
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4.19 Chisman Creek, York County, Virginia (03VA001)
4.19.1 List of Commenters
NPL-113 Hunton and Williams, representing Virginia Electric
and Power Company (telecom). 2/14/83.
NPL-134 Hunton and Williams. 2/17/83.
NPL-265 Hunton and Williams. 2/28/83.
NPL-L24 Hunton and Williams. 4/7/83.
4.19.2 Summary of Comments and Response
The commenter noted that fly ash is not currently considered a
"hazardous waste" or otherwise a hazardous substance. Futhermore,
because the quantity of selenium in the fly ash cannot be
determined, the waste quantity factor should be scored 0.
In response, the fly ash at the site contains selenium which
is a hazardous substance under CERCIA. The HRS assigns values for
waste quantity based on the entire quantity of all waste deposited
that contains hazardous material, not on the quantity of the
constituents that are actually hazardous. In this case, this means
that quantity is based on the volume of fly ash rather than the
amount of selenium. As explained in the preamble to the final
National Contingency Plan, 47 FR 31190, this position was taken
because of the difficulty in determining, for all sites, that
portion of the total waste deposited that actually constitutes
hazardous material. Without this information, the Agency knows of
no internally consistent approach for comparing pure hazardous
substance quantity at facilities where definitive information is
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available with hazardous substance quantity at facilities where such
information is not available.
The commenter contended that an observed release to ground
water is questionable due to the fact that five of the seven
monitoring wells were drilled directly through the fly ash. With
the installation of these monitoring wells, a pathway of migration
could have been established for contaminants found in the ground
water. In addition, an upgradient well, representative of
background quality, was not designated.
The installation of monitoring wells directly through waste
material might present a pathway of migration if proper installation
techniques were not incorporated. However, there is no evidence to
suggest improper installation of wells at Chisman Creek. In
addition, analytical evidence indicates that nearby domestic wells
and native materials below the fly ash are contaminated, showing
that migration to ground water has occurred. Further, 33 private
wells in the area were sampled during other investigations. Several
of the shallow private wells were determined to be upgradient and
the Agency utilized analytical results from those wells in
determining background levels.
The commenter stated that low levels of selenium can be
nutritionally beneficial. It has been established that selenium is
an essential micro-nutrient. In response, documented levels of
selenium in private wells and the fact that selenium is among the
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more toxic metals at higher levels, indicates a potential for risk.
The HRS does not consider the prescribed dosage of selenium or any
other chemical that may be beneficial because there is no method of
regulating the level of release of any chemical from a waste site.
The commenter suggested that ground water use should be scored
drinking water with municipal water from alternate unthreatened
sources presently available (i.e., minimal hookup requirements).
Also, since the majority of the homes in the area are now served by
municipal sources or deep wells, the population using the aquifer of
concern is minimal.
The intent of the "minimal hookup" is that water lines are
already in place with only connection to residences still required.
A water line was extended 1500 feet to serve residents along Wolf
Road after contamination was identifed. The majority of residences
in the area are now served by municipal water sources although many
were connected recently. In response, the fact that residents are
now served by a different water source does not negate the risk
incurred by past usage of potentially contaminated water supplies.
EPA computes HRS scores and lists sites on the basis of conditions
existing before any response actions are taken, in order to
represent the full scope of the original problem presented by a
site. Because of the effort required to provide these alternate
supplies, and because sites are scored according to conditions prior
to response actions, alternative supplies cannot be considered
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available with "minimal hookup requirements" for purposes of
scoring, and a value of 3 must be assigned. The same reasoning
applies to the determination of population served. The fact that
residents may now be using uncontaminated supplies will, however, be
taken into account in determining the nature and priority of
response actions.
The commenter noted that assigning a value for surface water
use predicated on shellfishing and recreational use is inappropriate
due to the fact that shellfish harvesting has been prohibited since
1972 because of domestic pollution.
Surface water uses are those associated with the use of water
downstream from the facility (i.e., fishing, recreation) and the
potential risk to receptors from that use. Citing shellfish
harvesting is inappropriate if it was banned for reasons of
pollution not associated with the site. However, because of
recreational use, the original value of 2 is appropriate.
Finally, the commenter stated that all appropriate
cost-effective cleanup actions at the Chrisman Creek Site have been
completed. EPA computes HRS scores and lists sites on the basis of
conditions existing before any response actions are taken in order
to represent the full scope of the original problem presented by a
site. If EPA determines that a site is cleaned up so that no
further response is necessary, EPA will delete the site from the
list, as discussed in Part VIII of the preamble to the final NPL.
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EPA has not yet made such a determination with respect to the
Chrisman Creek site, but will continue to examine conditions at the
site to determine whether deletion is appropriate. For sites that
remain on the list, any cleanup activities conducted pursuant to
formal agreements with EPA are acknowledged on the final NPL by
notation in the "Voluntary or Negotiated Response" category.
The original migration score for this facility was 47.19.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Chisman Creek are:
Ground Water 79.59
Surface Water 18.18
Air 0
Total 47.19
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4.20 Matthews, Roanoke County, Virginia (03VA002)
4.20.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.20.2 Summary of Comments and Response
The commenter identified two species of fish in the Roanoke
River currently under Federal review for listing as "threatened
species."
For purposes of scoring by the HRS, the critical habitat of
Federally listed species must be within one mile of a facility.
Critical habitat does not include the entire range of a species,
but only the areas in which such species are normally found nesting
or breeding. The original score for "distance to sensitive
environments" was 0, based upon the distance criteria specified by
the HRS. Insufficient information has been submitted as to the
location of the species to warrant a change in score for this
facility.
The original migration score for this facility was 31.86. No
new technical information was submitted and no change in score was
required. The HRS scores for Matthews are:
Ground Water 54.63
Surface Water 7.38
Air 0
Total 31.86
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4.21 Saltville Waste Disposal. Saltvllle, Virginia (03VA003)
4.21.1 List of Commenters
NPL-170 J. C. Brown, Manager, Environmental Technology, Olin
Chemical Group. 2/21/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.21.2 Summary of Comments and Response
Olin Chemical Group stated that the river serves as an
"aquifer interruption;" all ground water flow from the site
discharges to the river. Thus, the contaminant has no potential for
reaching the aquifer of concern.
In response, even though it has been established that the
direction of shallow ground water flow is towards the river, it has
not been documented that ground water is totally discharging to the
river. Various consultants have identified a substantial thickness
of weathered bedrock, numerous vertical fractures and zones of high
permeability, and beads of mercury in joints in the weathered
bedrock. Due to the bedrock structural conditions, steeply dipping
beds, and potential artesian conditions, it is conceivable that
migration to bedrock aquifers might occur. However, the risk to the
area's municipal water source (surface springs) appears to be
negligible due to the position in the geological sequence (discharge
to the springs is from a formation that is above the Maccrady
formation found at the site, and apparently isolated from it by
intervening formations). Other wells in the area may be isolated
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due to the complex geological structure. The ground water
population matrix value has been reduced from 24 to 0 and the ground
water use factor value from 3 to 1 to indicate that shallow ground
water, though usable, is not currently used (47 FR 31230).
The original scores of 24 and 3 for the ground water population
matrix and use factors, respectively, were based upon correspondence
with the Supervisor for the City of Saltville. It was noted that
drinking water was supplied by municipal wells within one mile of
the site and that the population served by ground water within 3
miles was approximately 4,000 persons. The reduction in score is
based upon the availability of data which better describe the
conditions at this site.
The commenter also maintained that observed releases are over
estimated, stating that the total quantity of mercury being released
is less than 0.2 pounds per day. As explained in Section 3.1 of the
HRS, 47 FR 31220 (July 16, 1982), the quantity of a substance
detected is not relevant to scoring for observed release, as long as
the concentrations are greater than background levels. This portion
of the HRS is designed to estimate the likelihood that the waste
will migrate from the site, which is certain once any substances are
observed off-site, not necessarily whether the concentrations in the
observed release itself are high enough to cause damage to public
health.
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The commenter indicated that the HRS guidelines for surface
water use based a factor of 2 on the loss of fishing as recreation.
The commenter stated that fishing on the North Fork was minimal
prior to the current restriction and that recreational fishing
continues despite the restriction. Therefore, no loss of the
resource has occurred. In response, surface water uses are those
associated with water downstream from the facility and is scored on
the use of the water (i.e., recreational) and the potential risk to
receptors from the use. The HRS guidelines are not based upon the
loss of a surface water use as stated by the commenter.
Olin Chemical Group stated that air monitoring data from recent
measurements indicates the magnitude of the problem is less than
originally cited. The commenter stated that recent data found
mercury levels typically an order of magnitude less than those
previously measured. Considering these later data, the score is
inordinately high simply because mercury is toxic and people live
within 4 miles of the site.
In response, a measured release is valid regardless of the
frequency of occurrence. It is a measure of potential risk to
receptors. In addition, the lower concentrations that were cited by
the commenter were obtained during winter months which may not be
representative of the release occurring during other seasons due to
the reduced volatilization.
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The commenter suggested that the reactivity rating is
unrealistic based on site specific conditions. While mercury does
emit toxic fumes when subjected to heating, the temperatures
required are higher than those that might conceivably be encountered
at the site. EPA concurs with the commenter and the reactivity
rating factor value has been reduced from 1 to 0.
The commenter stated that the accessibility rating in the
direct contact pathway is inappropriate. In response, the facility
does not have barriers which completely surround it and has,
therefore, been appropriately assigned a value of 3. In any case,
this pathway does not affect the HRS score for purposes of the NPL.
The commenter stated that remedial work is on-going and
objected to the fact that the HRS does not include any mechanism for
considering these activities. In response, EPA computes HRS scores
and lists sites on the basis of conditions existing before any
response actions are taken in order to represent the full scope of
the original problem presented by a site. This position is
discussed further in Part VII of the preamble to the final NPL. If
EPA determines that a site is cleaned up so that no further response
is necessary, EPA will delete the site from the list, as discussed
in Part VIII of the preamble to the final NPL. EPA has not yet made
such a determina- tion with respect to the Saltville Waste Disposal
site, but will continue to examine conditions at the site to
determine whether deletion is appropriate. For sites that remain on
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the list, any cleanup activities conducted pursuant to formal
agreements with EPA are acknowledged on the final NPL by notation in
the "Voluntary or Negotiated Response" category.
Finally, the commenter states that the public and media
perceive the NPL to be a ranking of the worst sites in the nation.
In response, the commenter is referred to Part II of the preamble
for the NPL which describes the purpose of the NPL.
The U.S. Department of the Interior stated that this facility
has contributed to contamination of 80 miles of river and resulted
in elimination of several endangered species. Two other endangered
species are currently in jeopardy. This information has been
considered and the distance to a sensitive environment value has
been raised from 0 to 3.
The original migration score for this facility was 53.23.
Based on the changes noted above, the HRS scores for Saltville Waste
Disposal are:
Ground Water 6.12
Surface Water 21.82
Air 45.77
Total 29.52
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4.22 U.S. Titanium Corporation, Piney River, Virginia (03VA004)
4.22.1 List of Commenters
NPL-L8 M. R. Tribble, Legal Department, American Cyanamid
Company. 3/7/83.
4.22.2 Summary of Comment and Response
The commenter stated that there is no upgradient analysis of
ground water to show that the contamination is due to a release and
not naturally occurring. In response, wells located to the
northwest (UST-R2) and west (UST-W5) are considered upgradient and
indicate parameters lower than those in an east-southeast well
(UST-W8) considered downgradient from the disposal area.
The commenter stated that since only substances exceeding
reportable quantities are evaluated, the toxicity/persistence factor
should be based on ferrous sulfate, not lead and chromium. In
response, use of the reportable quantity is only applicable when the
total inventory of substances in a facility is known. In the
absence of this information, the HRS considers those contaminants
which are greater in concentration than the background levels about
the site. The site was appropriately scored on chromium and lead as
measured in the observed releases.
The commenter stated that the nearest well is greater than
2000 feet and the population within 3 miles is less than 100
persons. In response, there are several residences and a doctor's
office using ground water east of Route 151, less than 2000 feet
from the site. There are approximately 75 homes within a 3 mile
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radius that use ground water. These homes are estimated to
represent 285 persons. The matrix value of 20 was appropriate.
The commenter noted that data used by the EPA were so variable
as to be statistically meaningless and should not be used to score
this site. In response, variations in the levels of concentration
of detected contaminants are not relevant to calculation of an HRS
score because levels of concentration are not taken into account.
In scoring for an observed release, sampling data are taken into
account only to the extent that they show whether any release has
occurred, for the purpose of showing the likelihood that substances
can migrate from the site. Since the available data show that a
release has occurred, the data are meaningful for purposes of HRS
scoring.
The commenter stated that surface water levels of chromium are
higher upstream than downstream. In response, sampling data
indicate that this is not the case and show increased levels of
sulfates, manganese, iron and chromium downstream of the site.
The original migration score for this facility was 34.78.
Based on the above response to comments, the score remains
unchanged. The HRS scores for U.S. Titanium are:
Ground Water 59.18
Surface Water 10.91
Air 0
Total 34.78
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4.23 Fike Chemical. Nitro. West Virginia
4.23.1 List of Commenters
NPL-127 E. A. Fike, President, Fike Chemicals, Inc. 1/27/83.
NPL-143 R. Hoyer, Attorney for Fike Chemicals. 2/17/83.
NPL-L12 S. Powers representing Fike Chemicals. 3/7/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.23.2 Summary of Comments and Response
Fike Chemicals objected to the fact that the HRS does not take
into account remedial action which has already been conducted at the
site. In response, as explained in the preamble to the final NPL,
EPA computes HRS scores and lists sites on the basis of conditions
existing before any response actions are taken in order to represent
the full scope of the original problem presented by a site. If EPA
determines that a site is cleaned up so that no further response is
necessary, EPA will delete the site from the list, as discussed in
Part VIII of the preamble to the final NPL. EPA has not yet made
such a determination with respect to the Fike Chemicals site, but
will continue to examine conditions at the site to determine whether
deletion is appropriate. For sites that remain on the list, any
cleanup activities conducted pursuant to formal agreements with EPA
are acknowledged on the final NPL by notation in the "Voluntary or
Negotiated Response" category. The cleanup activities at the Fike
Chemicals site have been so noted.
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Fike Chemicals indicated that the hazardous waste quantity
score is high for several reasons. First, the contents of lagoon 1
were found to be non-hazardous based on EP toxicity testing.
Second, the contents of lagoons 1 and 2 have been reclaimed. Third,
lagoon 3 has a three foot impermeable liner and is regulated under
RCRA Interim Status.
In response, EP toxicity testing has no bearing on the
calculation of hazardous waste quantity. The MRS assigns values for
waste quantity based on the entire quantity of all waste deposited
that contains hazardous material, not on the quantity of the
constituents that are actually hazardous. As explained in the
preamble the final National Contingency Plan, 47 FR 31190, this
position was taken because of the difficulty in determining for all
sites that portion of the total waste deposited that actually
constitutes hazardous material. The contents of lagoon 1 continue
to be counted because of measured priority pollutants in the sludge
and in a nearby downgradient monitoring well. Neither does the
reclamation of the contents of lagoons 1 and 2 affect the
determination of waste quantity because the HRS scores sites on the
basis of conditions existing before any response actions are taken,
as discussed above. Finally, removal of the contents of lagoon 3
from the waste quantity calculation does not lower the value
assigned to this rating factor.
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Fike Chemicals questioned the consideration of heptachlor and
methylene chloride in developing HRS scores. It was stated that
heptachlor was not used or produced at Fike Chemicals and that,
because methylene chloride was used to clean sampling equipment, any
measurement of this substance is unusable. In response, chloroform
is identified for both the ground water and surface water routes,
and its presence was not disputed by the commenter. Therefore, the
toxicity/persistence value of the chemicals onsite remains 18 for
both the ground and the surface water routes.
The commenter stated that air samples were taken from
production areas and represented high background levels due, in
part, to several other chemical manufacturing plants located within
2000 feet of the sampling stations.
In response, air route sampling methods and data were reviewed
to verify that onsite readings were higher than background for
methylene chloride and toluene and were representative of storage
areas rather than simply plant production areas. Three sample
locations were in areas well removed from active production areas
and still measured contaminants. Eight of the nine priority
pollutants found in the air samples were also detected in the liquid
and soil samples collected at the site.
The commenter objected to the consideration of metallic sodium
as a waste, indicating that it was used as a raw material at the
facility.
4-65
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Although metallic sodium is used as a raw material at the
facility, historic poor handling and storage has led to releases in
the past. These poor handling practices, and the fact that metallic
sodium is a solid waste as defined by RCRA, justify the HRS
consideration.
The commenter contends that the waste quantity is ridiculously
high for scoring the air pathway but provided no additional details
beyond those already discussed pertaining to the ground water and
surface water pathways.
Several comments were directed at the direct contact score for
this facility. Based on the comments and an Agency review of the
documentation, the direct contact score remains 50.00. This takes
into consideration a substantially reduced population at; risk.
It should also be noted that the direct contact does not affect
the HRS score for the purposes of the NPL.
The commenter, who heads the company that owns the site, noted
that the company has entered into a Consent Decree with EPA, which
provides for the company to take specific cleanup actions at the
site and release the company from any claims by EPA for civil
liability concerning the site once such cleanup is completed. The
commenter claims that listing the Fike Chemicals site on the NPL is
a violation of this consent decree.
4-66
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EPA disagrees based on the fact that, as explained in the
preamble to the proposed NPL, listing on the NPL in no way
establishes liability for cleanup at a site. In addition, the
consent decree in no way addresses the issue of listing the site on
the NPL. Indeed, since any additional cleanup that might be
necessary beyond that specified in the consent decree cannot be
required of the company but must be performed by EPA, as noted by
the commenter, listing the site is particularly appropriate to help
guide the Agency as to the need for such additional response and to
authorize remedial investigation and cleanup if necessary. This
position is consistent with EPA's general policy that sites must
remain on the NPL, even if agreements have been reached and actions
are underway to clean up the site, until EPA determines that cleanup
is complete. EPA does recognize sites where private parties are
taking response actions, however, by noting in the listing that the
site falls into the "Voluntary or Negotiated Response" status
category. The Fike Chemicals site has been assigned this notation.
The U.S. Department of the Interior expressed concern regarding
potential impacts to lake sturgeon and migratory waterfowl. Agency
review of this facility reveals no designated sensitive environments
or critical habitat within the distance limitations specified in the
HRS.
4-67
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The original migration score for this facility was 36.30.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Fike Chemical are:
Ground Water 6.12
Surface Water 10.91
Air 61.54
Total 36.30
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4.24 Follansbee Sludge Fill. Follansbee, West Virginia (03WV004)
4.24.1 List of Commenters
NPL-56 J. M. Dern, Manager, Environmental Regulatory
Program, Koppers. 1/20/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.24.2 Summary of Comment and Response
Koppers correctly noted that there is no verification that
coal tars have been disposed in the fill. Phenol has been measured
in the ground water under the fill, however, and data supplied by
the commenter's consultant yield an estimate that greater than 2500
drum equivalents of phenol were in the ground water at the time of
sampling. Based on these calculations, the hazardous waste quantity
is scored as 6 rather than 5. The previous HRS score had been based
on the calculation of phenol estimated to be leaving the ground
water by surface seeps. The site description which is a part of the
docket has been updated to reflect the inaccuracies noted by Koppers.
The U.S. Department of the Interior (DOI) expressed concern
regarding potential impacts to lake sturgeon and migratory
waterfowl. Review of this facility reveals no designated sensitive
environments within the distance limitations specified in the HRS.
4-69
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The original migration score for this facility was 31.89.
Based on the change noted above, the HRS scores for Follansbee
Sludge Fill are:
Ground Water 57.93
Surface Water 7.55
Air 0
Total 33.77
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4.25 Leetown Pesticide, Leetown, West Virginia
4.25.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.25.2 Summary of Comments and Response
The commenter stated that the site has had a direct impact on
source water for the Leetown National Fisheries Center.
The source of water for the Fisheries Center is a surface
spring. Contaminants have not been found in the ground water and
cannot be linked to the spring.
The original migration score for this facility was 36.72. No
new technical information was submitted and no change in score was
required. The HRS scores for Leetown Pesticide are:
Ground Water 62.85
Surface Water 9.23
Air 0
Total 36.72
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4.26 West Virginia Ordnance. Point Pleasant, West Virginia (03WV012)
4.26.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
4.26.2 Summary of Comments and Response
The primary concern expressed about this facility by the U.S.
Department of the Interior is contamination of migratory waterfowl
and Federally protected fish species using the McClintic Wildlife
Management Area and the Ohio River.
The proximity of these areas to the site was considered in the
original scoring of the facility. The distance to critical habitat
was scored a 3 based upon the facility now being known as the
McClintic Wildlife Station.
The original migration score for this facility was 35.72. No
new technical information was submitted and no change in score was
required. The MRS scores for West Virginia Ordnance are:
Ground Water 59.23
Surface Water 17.62
Air 0
Total 35.72
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5.0 COMMENTS ON REGION IV SITES
The U.S. Department of the Interior had comments on a number of
sites consisting of brief site descriptions or statements that there
were no anticipated impacts on protected species of flora and
fauna. The following facilities were mentioned.
Alabama
Florida
Mississippi
North Carolina
South Carolina
Kentucky
Tennessee
Perdido Ground Water Contamination, Perdido
Davie Landfill, Davie
Florida Steel, Indiantown
Gold Coast Oil, Miami
Miami Drum, Miami
NW 58th Street Dump, Hialeah
Parramore Surplus, Mount Pleasant
Reeves SE Galvanizing, Tampa
Schuylkill Metals, Plant City
Sherwood Medical, Deland
Varsol Spill, Miami
Plastifax, Gulfport
Chemtronics Inc., Swannanoa
Martin Marietta, Sodyeco, Charlotte
PCS Spills, 210 Miles of Roads
Carolawn, Inc., Fort Lawn
SCRDI Bluff Road, Columbia
SCRDI Dixiana, Cayce
Lee's Lane Landfill, Louisville
Newport Dump, Newport
Galloway Pits, Galloway
5-1
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The U.S. Department of the Interior noted the potential impact
of contamination on Federally listed endangered species, including
the Indiana bat, gray bat, Cumberland monkey face pearly mussel,
slackwater darter and pink mucket pearly mussel. These comments
apply to:
Kentucky A. L. Taylor, Brooks
Distler Brickyard, West Point
Dlstler Farms, Jefferson County
Tennessee Amnicola Dump, Chattanooga
Lewisburg Dump, Lewisburg
Murray Ohio Dump, Lawrenceburg
Insufficient information was provided to determine whether a
critical habitat for these species is located within the distance
limitations specified in the HRS. Efforts by EPA Region IV
personnel to confirm the proximity of critical habitats to the
listed facilities have proved unsuccessful. No score change can be
made at this time based on these comments.
5-2
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5.1 Mowbray Engineering, Greenville, Alabama
5.1.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.1.2 Sunnnary of Comments and Response
The commenter noted that sediments downstream from the primary
discharge site may need to be removed to clean up lanyard Branch and
Persimmon Creek. The effects of this facility on Tanyard Branch and
Persimmon Creek are reflected in the HRS score. The HRS, however,
cannot be used to evaluate the suitability of specific remedial
activities.
The original migration score for this facility was 53.67. No
new technical information was submitted and no change in score was
required. The HRS scores for Mowbray Engineering are:
Ground Water 92.31
Surface Water 10.06
Air 0
Total 53.67
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5.2 Perdido Ground Water Contamination Site, Perdido, Alabama
5.1.1 List of Commenters
NPL-225 Paul Kaplow, Manager, Environmental and Regulatory
Affairs, Health, Safety and Environmental Protection,
Atlantic Richfield Company. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.1.2 Summary of Comments and Response
The Department of the Interior comment is acknowledged in
Section 6.0.
ARCO suggested that the inference, in the site description of
Perdido, that seismic crew blasting in the Perdido area may have
caused contamination of water in private wells is inappropriate and
should be deleted.
The Agency agrees with this comment because there is
insufficient information available to establish any connection
between blasting activities and the ground water contamination in
the Perdido area. Accordingly, references to these activities have
been deleted from the site description.
The original migration score for this facility was 30.29.
Based on the above response to comments, the score remains
unchanged. The HRS scores for the Perdido ground water
contamination site are:
Ground Water 52.04
Surface Water 6.18
Air 0
Total 30.29
5-4
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5.3 Triana-Tennessee River, Limestone and Morgan Counties, Alabama
5.3.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.3.2 Summary of Comments and Response
The commenter noted that DDT is found in the Tennessee River
from mile 300 to mile 200 and in fish at high concentrations. Bird
species at Wheeler National Wildlife Refuge and other areas are
contaminated, as well as mammals and other vertebrates. A number of
endangered species also inhabit this area. In response, this
facility was evaluated for distance to sensitive environment, as an
integral part of the original HRS process, and assigned the maximum
value for this rating factor based on the proximity of a wetland and
streams that run through and border the Wheeler National Wildlife
Refuge.
The original migration score for this facility was 61.42.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Triana, Tennessee River are:
Ground Water 35.92
Surface Water 100.00
Air 0
Total 61.42
5-5
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5.4 Alpha Chemical, Galloway, Florida
5.4.1 List of Commenters
NPL-230 Zuckert, Scoutt, Rasenberger & Delaney for Alpha
Corporation. 2/28/83.
NPL-L7 Zuckert, Scoutt, Rasenberger & Delaney for Alpha
Corporation. 3/4/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.4.2 Summary of Comment and Response
Alpha Corporation acknowledged the observed release to ground
water but suggested alternative ratings for other parameters. Alpha
Corporation stated that the use of arsenic as a representative waste
is indefensible given the most reliable information available and
suggested the use of ethyl benzene to score toxicity/persistence.
EPA believes that despite the recorded levels of heavy metals at the
Alpha facility, there is presently insufficient evidence to
conclusively attribute these contaminants to Alpha. The samples
taken by the Florida DER in late 1982 from the Robinson well, now
owned by Alpha, continue to support a measured release to ground
water of ethyl benzene, benzene, xylene and naphthalene.
Therefore, the HRS documentation records have been revised to
reflect a measured release of the above mentioned substances to the
ground water. According to the HRS, benzene presents a greater
hazard potential than ethyl benzene. Therefore, it is appropriate
to evaluate benzene for the toxicity/persistence matrix factor
5-6
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score, reducing the previous value for toxicity/persistence from 18
to 12.
The commenter stated that the Floridan aquifer is not the
"affected" aquifer or the aquifer of concern and that the population
served by the aquifer of concern should be revised downward to
reflect only the two or three wells found not to be cased through
the Hawthorne formation. The commenter referred to a
hydrogeologist's report that claims the Floridan aquifer is confined
or protected by the Hawthorne Formation.
The Agency disagrees with this comment based on information
reported by the USGS, the Florida Geological Survey and by the
commenter's own hydrogeology report. Three reports, Report of
Investigation 42, 44, and 64 by the agencies referenced above, state
that recharge of the Floridan aquifer is through the overlying
aquifers and intervening units. In addition, the commenter's
hydrogeologist stated that the facility is "located on the western
edge of the Green Swamp and Lakeland Highland areas" and that
"recharge to the Floridan aquifer is primarily from the west on the
Green Swamp and Lakeland Highland areas." This is in agreement with
the referenced reports and contradicts the argument that the
Hawthorne formation functions as a confining layer between the
surficial aquifer and the Floridan.
The opportunity for a more direct connection of all aquifers is
further enhanced by the presence of sink holes (geologically recent
5-7
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and ancient) within a 3 mile radius of the facility.
The Agency recognizes that there is no evidence, at this time,
of a release to the Floridan aquifer. There is a documented
measured release, however, to the surficial water table which
recharges the Floridan. As evidenced above, the aquifers are
hydraulically connected. Therefore, the population figures used in
the target score are appropriate.
The commenter stated that pond No. 3 should not be used as part
of the waste quantity because pond No. 3 showed no waste or sediment
levels of any contaminant above background concentrations. The
value given should, therefore, be reduced.
Agency review of the files pertaining to this facility
indicates that holding pond No. 3 was not used to calculate the
waste quantity. Although the HRS documentation records were not
clear on designating the ponds, the file verified the quoted
dimensions as those of ponds 1 and 2. The State of Florida issued a
permit to Alpha Corporation allowing a maximum discharge of 1000
gallons per day of still bottoms and floor drains. Even a small
percentage of this discharge rate would result in a volume in excess
of that required for a maximum HRS value for hazardous waste
quantity. Because the exact discharge rate cannot be determined,
the assigned value of 7 is conservatively based on the once-filled
volume of the ponds 1 and 2.
5-8
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Finally, Alpha expressed the conviction that their facility
meets Agency criteria for deletion from the NPL because "...
considering the nature and severity of the problems ... no
remedial actions should be undertaken at the site." 47 FR 58479.
In response, this determination cannot be made without conducting a
more in depth remedial investigation to establish the nature and
extent of contamination.
The Department of the Interior expressed concern for the
proximity of this facility to habitats of the endangered American
alligator and the wood stork, a species currently under Federal
review for listing as an endangered species.
The Florida Department of Environmental Regulation reports that
neither of these species are nesting within the distance limitations
specified in the MRS. The relevant rating factor, however (distance
to a sensitive environment), received the maximum value of 3 based
on the proximity of the facility to a freshwater wetland.
Agency review of the surface water work sheet and documentation
records reveals that the surface water route score should be
increased from 5.24 to 15.94 based on the following information.
The surface water use rating factor should be assigned a value
of 2 for recreational use rather than 0. The original reviewer
cited recreation and fishing use in the documentation records but
this was not reflected in the original score. Application of the
multiplier results in a value of 6.
5-9
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A computational error was noted for the distance to sensitive
environment rating factor. The value of 3 was incorrectly
multiplied by 1 instead of 2. These items increase the total
surface water target score from 3 to 12.
The original migration score for this facility was 55.66.
Based on the changes noted above, the HRS scores for Alpha Chemical
are:
Ground Water 73.08
Surface Water 15.94
Air 0
Total 43.24
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5.5 American Creosote, Pensacola, Florida
5.5.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation, An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.5.2 Summary of Comments and Response
A. D. Little questioned the waste quantity value because it is
based upon the design capacity or volume of the percolation ponds
which were in operation for nearly 80 years rather than the waste
throughput.
EPA agrees that this is a conservative approach in determining
waste quantity. Unfortunately, where there is no basis to estimate
waste throughput, because of the lack of operational records, the
Agency has no alternative but to use the only available factual
information. This approach was used during the original MRS
review. New information on the measurements of the ponds at this
facility indicates that the combined volume is approximately 12,444
cubic yards. These data support a maximum waste quantity value of 8
rather than 6 as originally recorded.
The U.S. Department of the Interior expressed concern regarding
the proximity of the endangered brown pelican to the facility. The
information provided was not corroborated by the Florida Department
of Environmental Regulation. Their information indicates that there
are no pelican nests in Escambia County. The facility was
5-11
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originally scored, however, for its distance to Escambia Bay. This
distance to a sensitive environment, the coastal wetland, received a
maximum value of 3.
The Department of the Interior also noted commercial and
recreational fishing for estuarine, marine and shellfish species.
The surface water use rating factor, assigned a value of 2 in the
original scoring, reflects both economically important resources
(e.g., shellfish) and recreational usage.
Review of this facility indicates that, while the
toxicity/persistence matrix was originally assigned a value of 12
for phenols, the substance of major concern is pentachlorophenol,
used in a wood treating operation. Based on this substance, the
toxicity/persistence matrix value has been raised to 18.
The original migration score for this facility was 40.44.
Based on the changes noted above, the HRS scores for American
Creosote are:
Ground Water 100.00
Surface Water 14.55
Air 0
Total 58.41
5-12
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5.6 Brown Wood Preserving, Live Oak, Florida
5.6.1 List of Commenters
NPL-42 Frank C. Davis, Suwannee County Coordinator. 1/25/83.
5.6.2 Summary of Comments and Response
The commenter noted that this facility is not located within
the incorporated area of Live Oak, Florida, but just west of the
corporate limits of Live Oak. In response, the facility was listed
in Live Oak because of its postal address and because this is a more
specific locator than unincorporated Suwannee County.
The original migration score for this facility was 45.51. No
new technical information was submitted and no change in score was
required. The HRS scores for Brown Wood Preserving are:
Ground Water 76.92
Surface Water 16.78
Air 0
Total 45.51
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5.7 Hollingsworth Solderless Terminal Co., Fort Lauderdale, Florida
5.7.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation, An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
5.7.2 Summary of Comments and Response
The commenter stated that the toxicity of trichloroethylene
should have a value of 3 according to N. Irving Sax in his book
Dangerous Properties of Industrial Materials. The HRS, however,
relates toxicity of a substance to the type or mode of exposure.
Sax clearly notes that the toxicity of trichloroethylene is moderate
via the oral and inhalation routes. Sax's reference to a "HIGH"
toxicity is for an intravenous exposure. Since exposure to
trichloroethylene in a waste site will be by ingestion or inhalation
rather than injection, the toxicity is moderate, and a toxicity
value of 2 and a toxicity/persistence matrix factor value of 12 are
correct.
The original migration score for this facility was 44.53.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Hollingsworth are:
Ground Water 76.92
Surface Water 4.20
Air 0
Total 44.53
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5.8 Kassauf-Kimerling, Tampa, Florida
5.8.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.8.2 S""nnary of Comments and Response
The commenter noted the presence of alligator and several bird
species that may be affected by this facility. Of particular
concern are the brown pelican, a federally listed endangered
species, and the wood stork, under review for Federal listing.
The Florida Department of Environmental Regulation reports that
the closest brown pelican nesting area is 3 to 4 miles from the
facility. No endangered species are presently known to inhabit the
area within 1 mile of the facility as required by the HRS under
distance to critical habitat (47 FR 31236). It is noted that the
pertinent HRS rating factor, distance to sensitive environment,
received the maximum value of 3 based on proximity to a freshwater
wetland.
The original migration score for this facility was 53.42. No
new technical information was submitted and no change in score was
required. The HRS scores for Kassauf-Kimerling are:
Ground Water 89.80
Surface Water 21.82
Air 0
Total 53.42
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5.9 Munisport, North Miami, Florida
5.9.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.9.2 Summary of Comments and Response
The commenter mentioned a number of species as being
potentially affected by this facility. Of particular concern are
two species, the brown pelican and manatee, listed by the Federal
government as endangered This information had been considered in
assigning the maximum value of 3 to the distance to sensitive
environment rating factor.
The original migration score for this facility was 32.37. No
new technical information was submitted and no change in score was
required. The HRS scores for Munisport are:
Ground Water 53.69
Surface Water 15.94
Air 0
Total 32.37
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5.10 Northwest 58th Street Landfill, Hialeah, Florida
5.10.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation.
An Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.10.2 Summary of Comments and Response
The Department of the Interior comment is noted in Section 6.0.
A. D. Little inquired why no value was assigned to the
population rating factor for the surface water route when surface
water use is scored 2 for irrigation.
Water must be used to irrigate agricultural lands growing food
or forage crops to link a population score to surface water. The
documentation records for this facility indicate that the irrigation
is for "lawn sprinkling."
Review of this facility revealed an error in the scoring of
the distance to sensitive environment rating factor for the surface
water pathway. The documentation records indicate the facility is
adjacent to a wetland. The value for this factor has been raised
from 2 to 3.
The original migration score for this facility was 49.27.
Based on the above response to comments, the HRS scores for
Northwest 58th Street Landfill are:
Ground Water 84.62
Surface Water 12.31
Air 0
Total 49.43
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5.11 Parramore Surplus, Mount Pleasant, Florida
5.11.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.11.2 Summary of Comments and Response
The Department of the Interior comment is noted in Section 6.0.
Agency review of information on this facility revealed an
error in the ground water targets scoring. The documentation
records indicate that ground water use is as a sole-source drinking
supply and, thus, the value assigned to this rating factor should be
a 3 rather than 2.
The original migration score for this facility was 34.85.
Based on the changes noted above, the HRS scores for Parramore
Surplus are:
Ground Water 63.67
Surface Water 13.43
Air 0
Total 37.61
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5.12 Pickettville Road Landfill, Jacksonville, Florida
5.12.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83
5.12.2 Summary of Comments and Response
The U.S. Department of the Interior expressed concern for a
number of fish and bird species in the area. High priority species
which may be affected are the brown pelican and manatee.
The Florida Department of Environmental Regulation reports
that there are no nesting brown pelicans in Duval County and that
there are no designated habitats for manatee within the county.
Distance to a wetland area was originally considered in developing
the HRS scores for the facility and assigned a value of 2.
Review of this facility revealed a lack of documentation to
support the value of 8 originally assigned to hazardous waste
quantity. Quantity was assumed to be 2 percent of landfill capacity
based on limited records from 1976-1977. EPA has decided that these
data are not sufficiently specific to warrant rating this factor on
that basis. The value assigned has been reduced to 1 which reflects
a quantity which, although unknown, is known to be more than zero
due to the occurrence of an observed release.
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The original migration score for this facility was 58.75.
Based on the change noted above, the HRS scores for Pickettville
Road Landfill are:
Ground Water 73.08
Surface Water 13.29
Air 0
Total 42.94
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5.13 Pioneer Sand, Warrington, Florida
5.13.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.13.2 Summary of Comments and Response
The commenter noted the potential for ground and surface water
contamination, with possible adverse effects on associated fish and
wildlife through food chain contamination Potentially affected
species include eagles and brown pelicans. The Florida Department
of Environmental Regulation reports that there are no known eagle or
pelican nests within a mile of the facility. The distance to a
sensitive environment rating factor, however, was assigned a value
of 2 based on the distance to a coastal wetland.
The original migration score for this facility was 51.97. No
new technical information was submitted and no change in score was
required. The HRS scores for Pioneer Sand are:
Ground Water 88.45
Surface Water 16.08
Air 0
Total 51.97
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5.14 Sapp Battery, Cottondale, Florida
5.14.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.14.2 Summary of Comments and Response
The commenter noted the loss of more than 54 acres of forested
wetland habitat and potential impacts on eagles and anadromous
fish. In response, the facility was originally evaluated for
distance to sensitive environment and assigned a maximum value of 3
for this rating factor.
The original migration score for this facility was 47.70. No
new technical information was submitted and no change in score was
required. The HRS scores for Sapp Battery are:
Ground Water 79.59
Surface Water 21.82
Air 0
Total 47.70
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5.15 Schuylkill Metals, Plant City, Florida
5.15.1 List of Commenters
NPL-233 Lee Norman, Safety Coordinator, Schuylkill Metals
Corporation. 2/22/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.15.2 S""""ary of Comments and Response
The U.S. Department of the Interior noted the proximity of
this facility to high quality fish and wildlife resource areas.
This information was considered in developing the original HRS
scores for this facility.
Schuylkill Metals Corporation stated that an EPA field
investigation team (FIT) report did not report priority pollutants
or other contaminants in or near any private drinking water supply
wells.
The EPA report cited by the commenter stated that the private
wells, "showed no unusually high concentrations of metals." The
report noted that two priority pollutants, copper and zinc, were
detected in certain private wells. The report does not indicate the
source or the significance of these contaminants. However, the HRS
score and background information were not based on private well
contamination. The finding of an observed release to ground water
is based upon heavy metal contamination detected in monitoring wells
at the facility.
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Schuylkill Metals also maintained that priority pollutants
have not "migrated" off the site.
In response, sediment samples collected in a drainage ditch
outside the facility's property boundary, which receives the
facility's surface water runoff, have detectable concentrations of
chromiuir, copper, lead and antimony which are all priority
pollutants. Water samples from this location contained elevated
levels of lead. This drainage ditch connects to Pemberton Creek, a
tributary of Lake Thonotasassa.
Schuylkill Metals also stated that it has initiated a cleanup
project at its expense and that its operation has been modified to
help eliminate some of their problems and that this is cause for
deletion from the NPL.
EPA, however, computes HRS scores and lists sites on the basis
of conditions existing before any response actions are taken, in
order to represent the full scope of the original problem presented
by a site. The basis for this position is discussed further in Part
VII of the preamble to the final NPL. If EPA determines that a site
is cleaned up so that no further response is necessary, EPA will
delete the site from the list, as discussed in Part VIII of the
preamble to the final NPL.
In addition, Schuylkill Metals has noted that their response
actions only address "some" of their operation. Furthermore, there
are no data to evaluate the success of these actions.
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Schuylkill Metals stated that the company "... is willing to
enter into a closure plan with DER to close the unlined pond and
eliminate any additional problems. The company will establish
closure funds for this. Therefore, no demands will be needed for
Superfunds."
In response, EPA has determined that if the HRS score places a
site on the NPL, the site must remain on the list until EPA
determines that no further response actions are appropriate, or any
other criteria for deletion are met, as discussed in Part VIII of
the preamble to the final NPL.
Schuylkill Metals stated that its facility "... did not score
as high as the three similar sites in Florida engaged in the same
activities on the Hazard Ranking System and yet Schuylkill was the
only firm placed on the Superfund Priorities List."
In response, review of EPA Region IV files did not reveal a
record of any such sites as described by the commenter. While
primary responsibility for nominating facilities for inclusion on
the NPL rests with individual states, the Agency may nominate
additional facilities if such action is warranted. If brought to
the attention of the Agency, these facilities may be considered for
the NPL during a future update.
The original migration score for this facility was 59.16.
Based on the above response to comments, the score remains
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unchanged. The HRS scores for Schuylkill Metals are:
Ground Water 100.00
Surface Water 21.82
Air 0
Total 59.16
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5.16 Tower Chemical, Clermont, Florida
5.16.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.16.2 Summary of Comments and Response
The commenter noted potential for food chain magnification of
DDT to concentrations that could affect migratory birds and
waterfowl. In response, the facility was originally evaluated for
distance to a sensitive environment and assigned a maximum value of
3 for this factor.
Review of this facility revealed that the toxicity/persistence
matrix was evaluated for the pesticide Kelthane and received a value
of 15. References in the documentation records indicate that DDT is
present at the facility, resulting in a matrix value of 18. The HRS
scores have been increased accordingly.
The original migration score for this facility was 38.53.
Based on the changes noted above, the HRS scores for Tower Chemical
are:
Ground Water 73.47
Surface Water 20.14
Air 0
Total 44.03
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5.17 62nd Street Dump, Tampa, Florida
5.17.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.17.2 Summary of Comments and Response
The U.S. Department of the Interior expressed concern about
toxic materials reaching an 80-acre coastal marsh and a nearby
lake. Migratory birds and waterfowl could be involved as well as
the alligator, Federally listed as an endangered species.
According to the Florida Department of Environmental
Regulation, no endangered or threatened species inhabit the area
around the site. The distance to a sensitive environment rating
factor, however, was assigned a value of 1 based on the distance to
a coastal wetland.
The original migration score for this facility was 49.09. No
new technical information was submitted and no change in score was
required. The HRS scores for 62nd Street Dump are:
Ground Water 83.67
Surface Water 14.54
Air 0
Total 49.09
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5.18 B. F. Goodrich, Calvert City, Kentucky
5.18.1 List of Commenters
NPL-207 W. C. Holbrook, Director, Environmental Affairs,
B. F. Goodrich Company. 2/23/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.1.8.2 Summary of Comments and Response
B. F. Goodrich stated that the depth to the aquifer of concern
should receive a value of 2 rather than 3 because the shallowest
aquifer is at 25-30 feet and excavation has been 3 feet or less.
In response, the test boring records submitted by
B. F. Goodrich document a seasonal water level in test borings 1-4,
located west of the landfill at approximately comparable elevations,
in the range of 10-15 feet below the land surface. The depth of
excavation, more appropriately termed depth of deposition, appears
to be far greater than 3 feet below land surface based on
engineering diagrams submitted to the State of Kentucky. In
summary, the data presented by B. F. Goodrich documents ground water
levels on a range of 10-16 feet below land surface (value of 3).
B. F. Goodrich has also stated that the permeability of the
unsaturated zone should be scored 0 rather than 1 based on shallow
8
test borings reporting permeabilities in the 10 cm/sec, range
due to the presence of a clay layer beneath the site.
In response, other boring logs presented by the commenter
continue to support the original score. A review of geologic
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information in the site files indicates inconsistent units of sand,
silty clays, clay with gravel and clay. The variability of these
units illustrates their alluvial origin and that they are of limited
lateral extent. There is no evidence of an effective confining
layer since water rises into the units seasonally.
The commeuter stated that the physical state of the wastes
should be scored 0 rather than 3, maintaining that the sludge was
dewatered to a dry residue prior to disposal.
In response, a 1973 EPA report entitled "Report of Mercury
Source Investigation - Lower Tennessee River Valley and the B.F.
Goodrich Chemical Company, Calvert City, Kentucky," notes that
mercury-contaminated sludges were dumped on the ground near lagoon
#4. It further notes that process sludges from.three other lagoons
were also disposed of in landfills. The authors expressed a concern
that these materials would leach into the Tennessee River. This
process of dumping sludges directly on the ground for "dewatering"
purposes warrants a physical state value of 3.
Additional justification to support a physical state value of 3
involves the disposal of an estimated 2,600,000 gallons of
chlorinated hydrocarbon liquids into burnpits. These materials were
ignited in the pits. The potential existed for migration into the
soils prior to complete incineration. These materials, as disposed,
warrant a value of 3.
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The commenter stated that ground water containment should be
scored 1 rather than 3 because of low soil permeability and a clay
layer of 21-30 feet in thickness under the site.
As noted earlier, data presented by the commenter do not
support the presence of a continuous clay layer or the reported
permeability. Historical information indicates that the materials
were not properly contained. The containment value of 3 is
appropriate in light of the inadequate liner, seasonally high water
table, a leaching problem in 1980 and the period of time the
landfill was not properly covered.
B. F. Goodrich stated that their facility does not threaten the
Calvert City water supply because the water supply is 8000 feet
upgradient of the facility. According to B. F. Goodrich, their data
"indicates that the landfill has not contaminated the aquifer" and
that the flow of ground water is consistently toward the Tennessee
River and away from the Calvert City well field.
Because of the need to develop a nationally uniform scoring
system that could be used to score a large number of sites with the
data commonly available, the HRS does not specifically take into
account such level of detail as flow gradients when determining the
target population. This position is explained more fully in the
preamble to the final National Contingency Plan at 47 FR 31190.
In addition, the commenter's attachment B indicates the
reversal of ground water flow during periods of high water in the
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Tennessee River. During these seasonal periods the river recharges
the aquifer. While the complete impact of this reversal is unknown,
it does demonstrate a possible threat to the Calvert City well field.
The population served by ground water was originally estimated
to be 6,582 people. B. F. Goodrich has correctly noted the 1980
U.S. Census figure of 2388 for Calvert City and estimated a maximum
total population in the range of 4,000. According to the Marshall
County Chamber of Commerce, the city's six major industries employ
2405 people. These industries are connected to the Calvert City
water supply. Only those employees not living in Calvert City
should be added to the population at risk to avoid duplication. The
Chamber of Commerce estimates that 80% of these individuals do not
reside within Calvert City. This gives an estimated total
population of 4312 people which is within the same population range
used by the original reviewer and thus causes no change to the
matrix score.
B. F. Goodrich further suggested that, given the distance to
the Calvert City wells and the size of the population potentially
exposed, an interpolative value of 19 would be more appropriate than
the 24 currently assigned to the distance/population matrix.
The Agency believes that to allow interpolation of rating
factor values would negate the comparability of scores achieved by
application of a uniform scoring system. In the case of the
B. F. Goodrich facility, the actual distance to the well field and
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the population are well within the ranges represented by the
assigned matrix value.
The Department of the interior expressed concern for aquatic
resources in the vicinity of this facility. The proximity of the
facility to a sensitive environment, as defined in the HRS, was
considered during the original scoring of the site. The distance to
a sensitive environment rating factor is assigned a maximum value
of 3.
Agency review of this facility revealed historical information
that indicates that the landfill and other waste management
practices did not offer adequate containment to preclude a surface
water release. Specifically, the waste piles of "brine sludge"
dumped on the ground and the lack of any cover and diversion
structures for 7 years at the landfill justifies a containment value
of 3 rather than the 0 previously assigned.
The original migration score for this facility was 31.14.
Based on the changes noted above, the HRS scores for B. F. Goodrich
are:
Ground Water 53.88
Surface Water 18.91
Air 0
Total 33.01
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5.19 Distler Brickyard, West Point. Kentucky
5.19.1 List of Commenters
NPL-218 Arthur D. Little, Inc. Report to FMC Corporation.
An Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
5.19.2 Summary of Comments and Response
The commenter questioned the use of a lower waste quantity in
the ground water pathway than in the surface water pathway based
upon the number of drums that were leaking.
The commenter has correctly noted an inconsistency with the
waste quantity figures used to evaluate the Distler Brickyard. In
applying the reduced waste quantity value in the ground water
pathway, the original reviewer incorrectly assumed that a portion of
the waste was adequately contained, in which case those wastes would
not be considered in determining waste quantity according to the
HRS. Open drum storage, however, is not considered adequate
containment for hazardous substances, particularly where spill
containment is absent. Accordingly, the ground water waste quantity
value has been changed from 2 to 5 to reflect more accurately the
nuantity of hazardous material at the facility.
A review of the ground water pathway revealed a computational
error in the ground water use factor. The correct value for the
total targets score is 44 rather than 38 as previously calculated.
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The original migration score for this facility was 37.62,
Based on the changes noted above, the HRS scores for Distler
Brickyard are:
Ground Water 63.55
Surface Water 7.72
Air 43.59
Total 44.77
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5.20 Martin Marietta, Sodyeco Division, Charlotte, North Carolina
5.20.1 List of Commenters
NPL-208 E. J. Eccles, Environmental Manager for Martin
Marietta Corporation, Sodyeco Division. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.20.2 Summary of Comments and Response
The Department of the Interior comment is acknowledged in
Section 5.0.
Sodyeco stated that the HRS score was based on 1980
information, "that does not accurately reflect the present situation
at the facility," and suggested that the ground water pathway be
scored on route characteristics instead of an observed release.
EPA, however, computes HRS scores and lists sites on the basis
of conditions existing before any response actions are taken, in
order to represent the full scope of the original problem presented
by a site. The basis for this position is discussed further in Part
VII of the preamble to the final NPL. If EPA determines that a site
is cleaned up so that no further response is necessary, EPA will
delete the site from the list, as discussed in Part VIII of the
preamble to the final NPL. EPA has not yet made such a determina-
tion with respect to the Sodyeco site, but will continue to examine
conditions at the site to determine whether deletion is appropriate.
For sites that remain on the list, any cleanup activities conducted
5-36
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pursuant to formal agreements with EPA are acknowledged on the final
NPL by notation in the "Voluntary or Negotiated Response" category.
As noted in Sodyeco's comments, the landfill areas, in
combination with spills, have resulted in measurable releases to
ground water. Therefore, the ground water release was appropriately
assigned a value of 45.
Sodyeco has noted that ground water contamination from a RCRA
interim status facility should not be addressed by CERCLA. However,
evaluation of Sodyeco's releases to ground water has been based on
portions of the facility that do not constitute "regulated units"
under RCRA pursuant to the policy explained in Part VI of the
preamble to the final NPL. The measured contamination used for the
HRS scoring was from monitoring well WQ-6, and as Sodyeco has
stated, is from their former unpermitted disposal areas.
In a revised ground water score sheet provided by Sodyeco, the
commenter indicated that the toxicity/persistence value should be
raised from 12 to 15. However, no documentation was provided to
justify this change and the original value of 12 for chlorobenzene
is considered appropriate.
Sodyeco also maintained that population values in the ground
water pathway should be lower due to alleged ground water
discontinuities as a result of the intervening Catawba River and
Long Creek. They estimate the population as 1763 people living
between these two water bodies. Reference is made to unattached
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monitoring well data to support this contention. In response, a
hydrogeologic report dated March 18, 1981, prepared by a contractor
for Sodyeco, does not agree that these surface water bodies are
discontinuities in the ground water. It does appear that portions
of the surface aquifer in the overlying soil unit discharge to the
Catawba River and Long Creek. The surficial aquifer also recharges
the underlying bedrock aquifer. The report states that "the site
rock units function as the main aquifer and are in direct hydrologic
connection with the overlying soil units," The bedrock is described
as fractured with bedding planes, joints and shear zones. Given the
hydrogeologic connection, there is a possibility for contaminants to
migrate beyond Long Creek. The population figures used to score the
ground water route did not include residents on the west side of the
Catawba River and, thus, represent a conservative value for the HRS.
The commenter stated that the surface water route score should
be zero since the landfill cap at Sites I, II, and III precludes a
surface water release. In response, this site was scored based on
conditions and operations prior to remedial measures taken. As
indicated above, this is consistent with the HRS instructions in the
National Contingency Plan.
Sodyeco has correctly noted that leachate containment, as
noted in the HRS documentation, is not an issue for surface
containment. HRS documentation records have been changed
accordingly.
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Sodyeco has stated that surface water entering their
impoundments passes through their NPDES treatment facility prior to
discharge to the Catawba River.
This statement appears to be true for the water that reaches
the NPDES impoundments. However, these impoundments do not receive
all surface water from the facility.
EPA believes that a more important issue is the lack of
containment for spills that Sodyeco asserts to be a contributing
source of ground water contamination. These spills at manufacturing
and loading areas present a potential for surface water release as
substantiated by samples collected by EPA in June 1982, A soil
sample from the "flood plain" area adjacent to Long Creek contained
levels of the coal tar derivatives acenaphthene and carbazole. The
"flood plain" sample is downhill from the main plant complex and
receives surface water runoff from the central portion of the
plant. Surface runoff from another sector of the facility, referred
to as the northwest quadrant, was reported by Sodyeco's contractor
in 1981 (Law Engineering). In summary, there is no evidence of
containment of these surface spills, which are likely to have
occurred over the history of the facility, and the assigned value of
3 for this rating factor is appropriate.
Sodyeco has correctly stated that there is no tidal influence
on this portion of the Catawba River at the site location. River
flow is regulated by the hydroelectric dams as the commenter has
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noted. During periods of "draw and fill" at the dams, the river has
been noted to reverse flow. According to Mecklenburg County health
officials, this flow reversal has threatened the upstream Mount
Holly water intake with industrial contaminants. This phenomenon
was documented in 1961 by the North Carolina State Department of
Water Resources. Sodyeco has correctly pointed out that the City of
Belmont water intake is more than 3 miles from their declared CERCLA
disposal areas. The population associated with this intake is no
longer included in the tabulation of population potentially exposed
through surface water. This change does not result in any change in
score.
The commenter reexpressed concerns for the quality of an EPA
site inspection report. In response, the site inspection report was
not used to score the Sodyeco facility for the NPL.
The original migration score for this facility was 51.93.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Martin Marietta, Sodyeco are:
Ground Water 69.07
Surface Water 57.44
Air 0
Total 51.93
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5.21 Murray Ohio Dump, Lawrenceburg, Tennessee
5.21.1 List of Commenters
NPL-223 Collier, Shannon, Rill & Scott, Attorneys, on behalf
of Murray Ohio Manufacturing Company. 2/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.21.2 Smeary of Comments and Response
Murray Ohio Manufacturing Company stated that the classification
given to the current status of their facility should be changed from
"D" to "V" because of remedial actions completed in cooperation with
the State of Tennessee.
While it is true that some corrective measures have been
completed, there has been no participation by EPA. As stated in the
preamble to the proposed NPL (47 FR 58478), and in Part V of the
preamble to the final NPL, a site is included in the Voluntary or
Negotiated Response Category only when response is taken pursuant to a
formal agreement to which EPA is a party.
The U.S. Department of the Interior stated that Shoal Creek is
directly adjacent to the Cypress Creek which is a critical habitat for
the slackwater darter, an endangered species. Furthermore, the
endangered Indiana bat and gray bat have been reported from this
area. In response, the Agency has determined that the critical
habitat of the slackwater darter is beyond the one mile distance
limitation specified in the HRS (47 FR 31236). As stated in
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Section 5.0 of this document, the Agency does not have sufficient data
to determine the location of the Indiana and gray bats.
Review of this facility revealed a rounding error in the
calculation of the total score.
The original migration score for this facility was 46.43. Based
on the change noted above, the HRS scores for Murray Ohio Dump are:
Ground Water 79,59
Surface Water 10.91
Air 0
Total 46.44
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5.22 North Hollywood Dump, Memphis, Tennessee
5.22.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.22.2 Summary of Comments and Response^
The commenter stated that aquatic resources in the vicinity of
this facility have been severely affected. No protected species are
specifically noted and no sensitive environments or critical
habitats, as defined in the HRS, are near to the facility.
The original migration score for this facility was incorrectly
reported as 16.58. Review of EPA Region IV files revealed that all
available information pertaining to this facility supports a score
of 19.46. The HRS scores for North Hollywood Dump are:
Ground Water 31.84
Surface Water 10.91
Air 0
Total 19.46
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5.23 Velsicol (Hardeman County), Toone, Tennessee
5.23.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
5.23.2 Summary of Comments and Response
The commenter noted that, based on wildlife toxicology
studies, the potential for adverse impacts to fish and wildlife
resources is extremely high for this facility.
The proximity of this facility to sensitive environments as
defined in the HRS was reflected in the original scores.
The original migration score for this facility was 47.71.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Velsicol (Hardeman County) are:
Ground Water 79.59
Surface Water 21.82
Air 0
Total 47.71
ADDENDUM
(As a result of a clerical error, the comment from J.M. Rademacher
on the Velsicol (Hardeman County) site inadvertently was not
reviewed or considered by the Agency before promulgation of the
final NPL. Subsequent review of this comment indicates, however,
that consideration of the comment does not result in any score
change for this site. The comment and EPA's response, are discussed
below.)
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5.23.3 Commenter
NPL-252 J.M. Rademacher, Environmental Health and Regulatory
Affairs, Velsicol Chemical Corp. 2/28/83.
5.23.4 Summary of Comments and Response
Velsicol Chemical Corporation disagreed with EPA's decision
not to factor in the numerous remedial actions undertaken by
Velsicol which "...in Toone's case have made the site environ-
mentally secure and have resulted in the elimination of any
possibility of future exposure." In response, the commenter is
correct in his statement of EPA policy regarding past remedial
actions. This policy was explained in the preamble to the final
revisions to the NCP (47 FR 31187, July 16, 1982). It is further
explained in Part VII of the preamble to the Final NPL (48 FR 40664,
September 8, 1983).
Velsicol further stated that "...if even minimal credit had
been given for the extensive remedial actions already taken there,
the site would be placed substantially lower on the proposed NPL
than it presently stands." In response, as noted above, these
actions are not considered in the HRS evaluation process and cannot
affect the relative placement of a facility on the NPL. EPA does,
however, recognize sites where private parties are taking response
actions by noting in the listing that the site falls into the
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"Voluntary or Negotiated Response" status category. The Velsicol
(Hardeman County) site has been assigned this notation. In
addition, any remedial actions taken at the site will be taken into
account by EPA in determining what further action, if any, is
appropriate.
Velsicol stated that the aquifer of concern never served more
than 50 people rather than the 1000-3000 persons cited in the HRS
documentation record. Correction of this alleged error would lower
the HRS score sufficiently to remove the site from the NPL.
Velsicol's population figure is based on expert witness testimony
(Sterling v. Velsicol, Civ. No. 78-1100, W.D. Tenn., Dec. 8, 1978)
to the effect that "... the local groundwater aquifer has its head
waters and outcrops at known locations which define the aquifers'
boundaries."
In response, Velsicol is apparently referring to the
approximately fifty people living along the Toone - league Road
whose private wells were contaminated by the dump site but who are
now served by the Town of Toone via a water line financed by
Velsicol. These people, as well as the population of Teague, are
located in areas where the surface drainage flows north to Clover
Creek. Likewise, the slope of the surficial aquifer here is
generally northward to its primary discharge area along Clover
Creek. Toone, however, is located in the Pugh Creek South drainage
basin which flows generally south to Mill Creek and then to the
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Hatchie River. The slope of the surficial aquifer in this area has
been shown to be also generally toward the south, thus suggesting a
ground water flow divide somewhere between Toone and the dump site
and probably situated roughly along Tennessee Highway 100.
Notwithstanding, the entire area of concern (within a three mile
radius of any contamination known to have been caused by the dump
site) is underlain by the surficial aquifer and there are no major
topographic features between Toone and the dump site which would
suggest any irreversible patterns of subsurface flow.
In any case, because of the need to develop a nationally
uniform scoring system that could be used to score a large number of
sites with the data commonly available, the HRS does not
specifically take into account such level of detail as flow
gradient when determining the target population. This position is
explained more fully in the preamble to the final National
Contingency Plan at 47 FR 31190.
The score considers the population at risk to be those who use
the contaminated aquifer and who are located within, a three mile
radius of any contamination from the dump site. Using this
criterion, the State reports at least 154 households within city
limits based on sewerage records and 157 others outside city limits
but within the radius. The homes with sewer connections were
counted during a 1981 inspection and the others were obtained from
the General Highway Map of Hardeman County (1970) produced by the
Tennessee Department of Highways. Thus, a total of 311 homes are
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included. Using a figure of 3.8 persons per household, a. total
population at risk of 1,182 is counted. This is, moreover, a
conservative figure due to local growth since 1970.
Finally, Velsicol expressed the belief that the site meets EPA
criteria for deletion from the NPL because responsible party cleanup
is complete so that no fund-financed response is required, or
because "EPA in considering the nature and severity of the problems,
the potential costs of cleanups, and available funds, has determined
that no remedial actions should be taken at the site."
In response, while EPA has acknowledged the voluntary remedial
actions undertaken by the commenter, no technical data have been
submitted to the Agency to indicate that cleanup of this facility is
complete or that no additional cost-effective measures can be
taken. At such time as either of these determinations can be made
by the Agency, this facility will be proposed for deletion from the
NPL.
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6.0 COMMENTS ON REGION V SITES
6.1 Wisconsin Sites
6.1.1 List of Commenters
NPL-238 Thomas J. Dawson, Wisconsin Public Intervenor and
Matthew D. Cohn, ClinicapL Intern to Public Intervenor,
State of Wisconsin, Department of Justice. 2/24/83.
6.1.2 Summary of Comments and Response
The commenter stated that there are no Wisconsin sites on the
proposed NPL because no candidates wete submitted by the Wisconsin
Department of Natural Resources. It is further stated that, "we
believe that EPA should, pursuant to its duty to protect the 'public
health or welfare or environment* (CERCLA Sec. 104 (a)(2)),
designate at least one hazardous waste site in Wisconsin for cleanup
action." A specific site was suggested.
The National Contingency Plan assigns a major responsibility to
the states to identify candidates for inclusion on the NPL.
However, the Agency does have the authority to include sites on the
NPL which were not identified by the states if there is sufficient
data to calculate the HRS scores and if those scores warrant
including the site on the NPL. In the case of Wisconsin, the state
did not identify any sites as being priority sites for cleanup, and
EPA has no independant information indicating any sites in Wisconsin
which should be included on the NPL.
6-1
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The commenter did not supply enough information to enable EPA
to develop a proposed score for its suggested site. If EPA obtains
additional information indicating the extent of potential threats
posed at the site, the site could be proposed for inclusion during a
future NPL update.
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6.2 Johns-Manville, Waukegan, Illinois
6.2.1 List of Commenters
NPL-63 Schiff, Hardln and Waite, Attorneys for
Johns-Manville. 2/28/83.
6.2.2 Summary of Comment and Response
The commenter stated that the ground water pathway was
misscored. Documents were cited that indicate that asbestos
particles generally migrate only minimally through soil. Scoring
the containment factor zero (rather than 3) would remove this
*
pathway from consideration. Following this logic, and citing
language in the HRS instructions indicating that waste
characteristics scores must be based on the hazardous substance that
could migrate to ground water, the commenter contended that asbestos
cannot be used to score the toxicity/persistence or hazardous waste
quantity factors under the ground water pathway.
In response, review of the available data regarding this
facility reveals that the asbestos is underlain by dense beach sand
rather than soil. The high permeability of this material renders
the references cited by the commenter inapplicable to this
facility. The toxicity value for asbestos via the two ingestion
pathways has been changed from 3 to 2 because chronic effects from
ingestion have not been demonstrated.
The commenter stated that because the asbestos is covered in
accordance with Clean Air Act NESHAP regulations, the surface water
containment factor should be scored zero rather than 2.
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Agency review of the available information indicates that the
cover material at this facility is not "non-asbestos-containing" as
required by NESHAP regulations at 40 CFR 61.25(e)(l). In addition,
portions of the asbestos are not completely covered. The cover,
therefore, does not adequately prevent surface water contamination.
Other than the toxicity score adjustment cited above, no change was
appropriate for the surface water pathway.
The commenter raised several questions regarding the sampling
and analysis procedures used to document the air release. For the
purpose of determining an asbestos release, dichotomous sampling was
considered sufficient. Dust filters were not switched (as suggested
by the comment) because the samples were taken one at a time. The
upwind (background) coarse filter was slightly cracked as it was
removed; however, it is unlikely that any fibers were dislodged due
to the strong electrostatic attraction generated by the filter and
the very minor damage involved. Because of the many fiber types
present in the site area, TEM (transmission electron microscope) was
selected over optical methods because its superior resolution
permits unambiguous fiber identification. This alleviated the
possibility of fiberglass and other fibrous materials being
erroneously counted as asbestos.
Finally, the commenter took exception to the toxicity rating of
3 as opposed to the moderate value of 2 assigned in Sax's 5th
Edition. The use of the toxicity value of 2 for the ingestion
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pathways has already been noted and is based only on the lack of
definitive justification for a maximum value. For the air pathway
(inhalation), while the Sax 5th Edition does assign moderate
toxicity to asbestos, the 4th Edition assigned a high toxicity.
Since the HRS references both editions (47 FR 31230, July 16, 1982),
either value could be chosen. EPA chose to assign a high toxicity
value, according to the 4th Edition, based in part on the additional
consensus that asbestos is a known carcinogen via inhalation.
The original migration score for this facility was 38.82.
Based on the changes noted above, the HRS scores for Johns-Manville
are:
Ground Water 4.33
Surface Water 8.58
Air 65.38
Total 38.20
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6.3 Outboard Marine Corporation, Waukegan Harbor, Illinois
6.3.1 List of Commenters
NPL-195 Martin, Craig, Chester and Sonnenschein, for Outboard
Marine Corporation. 2/25/83.
6.3.2 Summary of Comments and Response
The commenter stated that EPA should have considered only the
OMC premises. In response, EPA has properly defined the OMC site
to be the entire area within boundaries that include the North Ditch
and that portion of Waukegen Harbor that was contaminated by
discharges from the OMC premises in order to determine the potential
targets in accordance with the HRS instructions.
The commenter stated that no present release to ground water
has been shown. In response, a U.S. EPA Region V report (1/21/81)
entitled "The PCB Contamination Problem in Waukegan, Illinois"
states that the ground water beneath the OMC property is
contaminated with high levels of PCBs.
The commenter stated that EPA is unable to demonstrate present
release of PCB in reportable quantities to the surface water. In
response, the HRS does not require a release to be ongoing;
historical releases may be considered (Section 4.1 of the HRS (47 FR
31233)). Contamination of the ground water with PCB was reported in
sampling by the commenter1s consultant in 1977. Further, in 1975,
EPA found OMC to be a major source of contamination to Lake Michigan
and a continuing source of discharge to the surface waters (EPA,
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January 21, 1981). The HRS form is appropriately scored for
observed release (47 FR 31233).
The commenter stated that an NPDES permit provides for best
management practices in the event of any present discharge which may
threaten surface water. In response, EPA computes HRS scores based
upon conditions existing before any response actions, such as best
management practices, are taken in order to represent the full scope
of the original problem presented by a site.
The commenter stated that route characteristics and containment
should be considered. In response, the HRS does not consider the
factors for determining the potential for a release when an observed
release has been documented since the release shows a 100 percent
probability of the potential for release.
The commenter stated that EPA's toxicity determination is not
supported by scientific evidence. In response, the HRS uses the
toxicity ratings assigned in N. I. Sax. PCB's are rated as having
high toxicity and have, therefore, been assigned a value of 3.
Although the commenter stated that the quantity of hazardous
material is purely speculative, that quantity was based on
documented purchases of hydraulic fluid and on the percentage that
the commenter estimated was discharged to the North Ditch and
Waukegan Harbor.
The commenter stated that under the surface water route, EPA
has identified a population exposed which does not regularly use the
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water. For the purposes of the HRS, EPA considers the population
potentially exposed to contaminated drinking water to be at risk
regardless of the frequency of the exposure (47 FR 31236). The
population of Waukegan (67,653) is considered to be potentially at
risk due to exposure from contamination of the auxiliary water
intake.
The commenter stated that exposure by direct contact will not
occur. In response, EPA has observed individuals washing
contaminated sediments off of boats in a slip adjacent to the OMC
property. This situation clearly represents exposure by direct
contact.
The original migration score for this facility was 42.82.
Based on the above response to comments, the score remains un-
changed. The HRS scores for Outboard Marine Corporation are:
Ground Water 5.65
Surface Water 73.85
Air 0
Total 42.82
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6.4 Velsicol Illinois, Marshall, Illinois
6.4.1 List of Commenters
NPL-L25 Daniel B. Crane, U.S. House of Representatives.
4/12/83.
6.4.2 Summary of Comments and Response
The commenter stated that, due to completed, ongoing, and
planned remedial actions, this facility does not pose a threat to
the public or to the environment. Further, it was indicated that
these actions have been undertaken by Velsicol and that the status
of cleanup actions of the facility should be recorded as voluntary.
In response, EPA does not consider past remedial actions in the
evaluation of a site for listing on the NPL. This policy was
explained in the preamble to the final revisions to the NCP (47 FR
31187, July 16, 1982). It is further explained in Part VII of the
preamble to the Final NPL (48 FR 40664, September 8, 1983). The
comment noted that not all the cleanup actions have been completed.
Thus, the site does not meet the criteria for deleting sites from
the NPL discussed in Part VIII of that preamble. It should be noted
that actions taken or planned to date address surface cleanup and
improved disposal practices. None are directed at restoration of
ground and surface waters damaged by past disposal practices.
The EPA recognizes sites where private parties are taking
response actions by noting in the listing that the site falls into
the "Voluntary or Negotiated Response" status category. The
Velsicol Illinois site has been assigned this notation.
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The commenter asked who interprets the data, and whether there
has been enough recent, site-specific input to permit an adequate
assessment. The commenter further asked how an assessment can be
made without contact with the company.
In response, EPA's designated Quality Assurance Team, Regional
Office and Headquarters review the data for consistency and
objectivity. Furthermore, EPA last visited Velsicol Illinois on
June 17, 1983 and met with Memphis and Chicago Velsicol officials.
The original migration score for this facility was 48.78. No
new technical information was submitted and no change in score was
required. The HRS scores for Velsicol Illinois are:
Ground Water 83.67
Surface Water 10.91
Air 0
Total 48.78
ADDENDUM
(As a result of a clerical error, the comment from J.M. Rademacher
on the Velsicol Illinois site inadvertently was not reviewed or
considered by the Agency before promulgation of the final NPL.
Subsequent review of this comment indicates, however, that
consideration of the comment does not result in any score change for
this site. The comment, and EPA's response, are discussed below.)
6.4.3 Commenter
NPL-252 J.M. Rademacher, Environmental Health and Regulatory
Affairs, Velsicol Chemical Corp. 2/28/83.
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6.4.4 Summary of Comments and Response
The commenter disagreed with the EPA position on not taking
voluntary cleanup efforts into account in evaluating sites for
listing on the NPL. He listed the extensive clean-up actions taken
by Velsicol in recent years and concluded that the site presents no
risk to people or to the environment. In response, the commenter is
correct in his statement of EPA policy regarding past remedial
actions. This policy was explained in the preamble to the final
revisions of the NCP (47 FR 31187, July 16, 1982). It is further
explained in Part VII of the preamble to the Final NPL (48 FR 40664,
September 8, 1983). While EPA has acknowledged the voluntary
remedial actions undertaken by the commenter, no technical data have
been submitted to the Agency to indicate that cleanup of this
facility is complete or that no additional cost-effective measures
can be taken. At such time as either of these determinations can be
made by the Agency, this facility wil be proposed for deletion from
the NPL.
The commenter suggested that a distinction should be made
between orphan and uncontrolled sites and those like Marshall with
work either completed or in progress.
In response, EPA recognizes sites where private parties are
taking response actions by noting in the listing that the site falls
into the "Voluntary or Negotiated Response" status category. The
Velsicol Illinois site has been assigned this notation. More
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detailed distinctions, such as on the basis of work planned, work
under way, work completed and so on, would be to difficult to
verify, and a list reflecting such distinctions would demand an
undue level of resources that would be better spent investigating
and cleaning up sites. The reasons for presenting the NPL in the
manner chosen by EPA are discussed further in Part V of the preamble
to the final NPL.
The commenter stated that there is no observed release either
to surface or to ground water. All process waste waters and storm
waters are contained on site and disposal of in an approved deep
well disposal system.
In response, the observed releases to ground water and surface
water that are included in the documentation record for this site
predate the remedial actions taken by Velsicol. As noted above,
recent remedial actions are not taken into account in the evaluation
of a site. Velsicol's remedial actions will be taken into account
by EPA in determining what further action, if any, is appropriate.
The commenter stated that there is absolutely no evidence of
potential impacts upon the public water supply aquifer used by the
City of Marshall, and cited hydrological studies which indicate that
groundwater flows westward from the site away from the city wells
and with no demonstrated interconnection to that portion of the
aquifer from which city water is drawn. In response, because of the
need to develop a nationally uniform scoring system that could be
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used to score a large number of sites with the data commonly
available, the MRS does not specifically take into account such
level of detail as flow gradients when determining the target
population. This position is explained more fully in the preamble
to the final National Contingency Plan at 47 FR 31190. Wells within
a three mile radius of any contamination from the site are used in
determining target population.
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6.5 Envirochem, Zionsville, Indiana
6.5.1 List of Commenters
NPL-204 Baker and Daniels on behalf of landowners. 2/24/83.
NPL-L10 Baker and Daniels on behalf of landowners. 3/7/83.
6.5.2 Summary of Comments and Response
The commenter noted that the site is upstream of the water
supply of the City of Indianapolis. In response, the reservoir
intake is at least 10 miles downstream from the site. The HRS
values of 2 for recreational surface water use within 3 miles and
zero for population served are appropriate (47 FR 31236).
The commenter made several comments in reference to an adjacent
facility, indicating that the two sites should be treated as one.
The practice of listing multiple facilities is limited by several
criteria as discussed in the preamble to the National Priorities
List. Wherever possible, facilities are evaluated and listed
separately to enable the HRS evaluation and score to more accurately
reflect site-specific conditions. Despite the legal and financial
relationship between these two facilities described by the
commenter, they are separately functioning facilities.
The original migration score for this facility was 46.44.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Envirochem are:
Ground Water 79.59
Surface Water 10.91
Air 0
Total 46.44
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6.6 Fisher Calo, La Porte, Indiana
6.6.1 List of Commenters
NPL-193 Winston and Strawn, Attorneys for Fisher-Calo
Chemicals and Solvents Corporation. 2/25/83.
6.6.2 Summary of Comments and Response
The commenter contended that the HRS scores are based on
outdated information and do not consider remedial actions already
taken in response to a consent order. Further, the facility is
under RCRA interim status and should not be included on the proposed
NPL.
As discussed in Part VII of the preamble to the final NPL, EPA
computes HRS scores and lists sites on the basis of conditions
existing before any response actions are taken, in order to
represent the full scope of the original problem presented by a
site. If EPA determines that a site is cleaned up so that no
further response is necessary, EPA will delete the site from the
list, as discussed in Part VIII of the preamble to the final NPL.
EPA has not yet made such a determination with respect to the
Fischer-Calo site, but will continue to examine conditions at the
site to determine whether deletion is appropriate. For sites that
remain on the list, any cleanup activities conducted pursuant to
formal agreements with EPA are acknowledged on the final NPL by
notation in the "Voluntary or Negotiated Response" category. The
cleanup activities at the Fisher-Calo site have been so noted.
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In scoring this facility, EPA did not consider those portions
of the property that are "regulated units" operating pursuant to
interim status under RCRA. Scores are based on releases from
leaking drums on the surface and those buried in 1975 until their
removal in 1978.
The data used to score this facility have been reviewed and
found to support the assigned score. A March 29, 1983 analysis of
local monitoring well samples corroborates earlier findings,
detecting trichloroethylene, tetrachloroethylene, and
1,1-dichloroethylene at higher concentrations than previously found
in ground water in the site area. In the absence of technical data
to the contrary, no change in score is warranted at this time.
The original migration score for this facility was 52.05.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Fisher-Calo are:
Ground Water 89.80
Surface Water 6.55
Air 0
Total 52.05
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6.7 Neal's Landfill, Bloomington, Indiana
6.7.1 List of Commenters
NPL-7 James Ridenous, Director, Department of Natural
Resources, State of Indiana. 1/14/83.
6.7.2 Summary of Comments and Response
The commenter noted several caves in the area used by the
Indiana bat, a threatened species. None of the four caves, however,
is within a mile of the site, nor are the caves designated as
critical habitats by the U.S. Fish and Wildlife Service.
The original migration score for this facility was 42.93.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Neal's Landfill are:
Ground Water 73.47
Surface Water 10.91
Air 0
Total 42.93
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6.8 Parrot Road, New Haven, Indiana
6.8.1 List of Commenters
NPL-201 Bennett C. Jaffee, SCA Services, Inc. 2/24/83
6.8.2 Summary of Comments and Response
The commenter stated that follow-up sampling by an SCA
Services, Inc. contractor failed to detect specific, identifiable
contaminants in the well relied upon by EPA to ascribe observed
release to ground water. In response, after review of available
data on this facility, the Agency does not believe that
contamination in this well, if it is contaminated, can be positively
linked to the Parrot Road site at this time. The ground water
pathway has been rescored based on route characteristics and
containment.
EPA assigned a value of 2 to the depth to aquifer of concern
factor based on information provided by the commenter and the EPA
Site Inspection Report that the depth is 30 to 45 feet. Net annual
precipitation is +3.97 inches (value 1). Permeability receives a
value of 1 based on information provided by the commenter that the
unsaturated zone is predominantly hardpan and clay. Physical state
receives a value of 3 because contaminants known to be present (from
surface sampling) would only be in liquid or sludge form. No method
of containment is used at the facility resulting in a value of 3 for
this factor.
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Regarding the surface water route, the commenter stated that
the site acts as a filter for contaminants in the drainage ditch
rather than a contributor. In response, the presence of seeps from
the landfill and information provided by the State of Indiana
regarding substances disposed of at the site convince the Agency
that the facility is contributing to surface water contamination.
Review of file material for this facility revealed that
toxicity/persistence was incorrectly assigned a value of 15 rather
than 12 for tetrachloroethylene in the ground water and surface
water pathways. This error has been corrected.
The original migration score for this facility was 28.58.
Based on the changes noted above, the MRS scores for Parrot Road are:
Ground Water 23.88
Surface Water 5.45
Air 0
Total 14.16
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6.9 Cliff/Dow Dump, Marquette, Michigan
6.9.1 List of Commenters
NPL-217 Donald W., Genson, Manager, Environmental Regulatory
Activities, Dow Chemical Co. 2/28/83.
NPL-243 William R. Lehmann, Administrator of Environmental
Affairs, Cleveland-Cliffs Iron Co. 2/25/83.
NPL-282 David A. Svanda, Manager, City of Marquette.
(Telegram). 2/28/83.
6.9.2 Sปtnmary of Comments and Response
The City of Marquette Management believes that the site is
properly listed on the NPL.
Cleveland-Cliffs Iron Company stated that the
toxicity/persistence value should be 12 rather than 18 and should be
based on the presence of phenol rather than benzo(a)pyrene. The
commenter said that the value should be limited to consideration of
those materials which are CERCLA hazardous substances.
In response, Dow Chemical's analysis "tentatively identified"
benzo(a)pyrene in a sediment sample and a tar sample. If this
compound were present, it was below the detection limit in
Environmental Control Technology Corp. (Ann Arbor, Michigan)
(ENCOTEC) analyses of split samples. Thus, it is not clear whether
benzo(a)pyrene is present. However, ENCOTEC identified other
compounds (such as chloroform and lead) as being present in the
waste. These compounds have a value of 3 for both toxicity and
persistence, resulting in a combined value of 18 and no change in
the site score.
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Cleveland-Cliffs stated that fewer than 100 people can be
affected by using the aquifer of concern, rather than 372 as was
used by EPA in the scoring. Ground water flow from the site is to
the east. Wells to the north and west of the site may obtain water
from a separate aquifer, given the direction of ground water flow
and the presence of granite outcroppings.
As stated in the HRS and further explained in Part VII of the
preamble to the final NPL, the direction of ground water flow is not
considered in developing HRS scores. The area used to determine
population is bounded by the Dead River to the south, Lake Superior
to the east and the north, and the 3-mile radius to the west. The
effect of the granite outcroppings on the continuity of the aquifer
is uncertain and is now under study, according to the City of
Marquette city engineer. The number of homes in this area shown on
the USGS 7.5-minute topographic map for Marquette, Michigan,
photorevised in 1975, is 54. The corresponding population is 205,
resulting in a population served by ground water value of 2 (no
change).
Dow Chemical Company stated that the site does not have the
potential for gas generation. Because the physical state of the
waste material is a solid that is not easily transportable, the
value for physical state should be 1 rather than 3.
In response, the waste material, a tar-like substance, is like
a liquid or sludge because it does "flow", especially when it is
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warmed by exposure to sunlight and ambient temperatures (according
to EPA Field Investigation Team members who have visited the site)
and probably was poured originally. A liquid or sludge is assigned
a value of 3 for physical state.
Cleveland-Cliffs Iron stated that the nearest surface water is
1000 feet from the site and not 800 feet as stated in the original
documentation. Distance to nearest surface water should, therefore,
have a value of 2, reflecting a distance between 1000 feet and
1 mile rather than a 3 which represents a distance of less than 1000
feet.
In response, the distance to the pond located to the northeast
of the site, which is the nearest surface water, is approximately
1300 feet. Distance to nearest surface water has, therefore, been
changed to a value of 2 reflecting a distance between 1000 feet and
1 mile.
Cleveland-Cliffs Iron also stated that the value for surface
water containment should be 1 rather than 3 because the landfill is
adequately covered.
Because the waste is exposed, the landfill is considered to be
not covered. The commenter does not mention a run-on diversion
system and photographs of the site indicate that none exists.
Therefore, the value of 3 for containment was appropriate.
The commenter stated that distance to sensitive environment
should be scored 0 instead of 1 because intervening high ground
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prevents runoff from the site from reaching the wetland. In
response, runoff from the site can reach the wetland along railroad
tracks which cut through the high ground between the site and
wetland. The distance to sensitive environment factor value remains
1.
Cleveland-Cliffs Iron and Dow Chemical stated that the direct
contact population was overestimated.
The Agency considers the Marquette City Manager's estimate
appropriate. An estimate of 1000 to 2000 persons results in the
same direct contact score. The direct contact score, however, does
not affect the HRS migration score.
The original migration score for this facility was 34.66.
Based on the changes noted above, the HRS scores for Cliff/Dow are:
Ground Water 59.18
Surface Water 7.76
Air 0
Total 34.50
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6.10 Gratiot County Golf Course, St. Louis, Michigan
6.10.1 List of Commenters
NPL-252 J. M. Rademacher, Vice President, Environmental,
Health and Regulatory Affairs, Velsicol Chemical
Corporation. 2/28/83.
6.10.2 Summary of Comments and Response
The commenter indicated that this facility has been cleaned up
pursuant to a signed agreement between Velsicol, the Michigan
Department of Natural Resources, the U.S. EPA and the U.S.
Department of Justice. Full releases were agreed to and given by
all parties. These were reconfirmed in the consent decree signed by
all parties and entered into Federal court on December 27, 1982.
The existence of a Consent Agreement does not, in itself,
affect the MRS score because the score is based on certain objective
characteristics of the site before response actions are taken and,
therefore, does not reflect current or prospective response
actions. However, the Agency agrees that the site has been cleaned
up so that no further fund-financed response will be necessary, and
Gratiot County Golf Course has thus been deleted from the NPL.
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6.11 McGraw Edison, Albion, Michigan
6.11.1 List of Commenters
NPL-160 McDermott, Will and Emery. 2/22/83.
6.11.2 Summary of Comments and Response
The commenter noted that the toxicity of trichloroethylene is
only moderate through the oral routes of exposure. The Agency
agrees and the toxicity/persistence matrix values have been changed
from 15 to 12 accordingly.
The commenter also indicated that the hazardous waste quantity
value of 5 should be a 1. Most of the trichloroethylene at the site
was used in a closed system and recovered and, therefore, should
have a containment value of 0. According to the commenter, the only
waste not completely contained consists of thirty drums of still
bottoms disposed each year for 10 years, resulting in a waste
quantity figure of 300 drums. Of that quantity, between 2.7 percent
and 10 percent of the volume was pure trichloroethylene. EPA agrees
that the waste in the closed system should not be counted, and
accepts the commenter thus believes the waste quantity factor should
be based on 8 to 30 drums of pure trichloroethylene, resulting in a
value of 1.
The HRS requires consideration of all hazardous substances at
a facility (as received) except that with a containment value of 0.
The commenter's estimate of 300 drums of still bottoms disposed on
site is acceptable as the basis for scoring hazardous waste quantity
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(47 FR 31229). The HRS does not allow reduction of the "as-received"
waste quantity to eliminate portions with concentrations of hazardous
constituents that are less than 100 percent (pure compound). The
value for 300 drums is 3 and the waste quantity value has been
adjusted from 5 to 3 accordingly.
Finally, it was suggested that the value for distance to a
sensitive environment should be 0 rather than 1 because the
sensitive environment in question does not meet the definition of a
wetland.
In response, the area in question is not a wetland larger than
5 acres. The value for distance to a sensitive environment should
be 0 and the HRS has been changed from 1 to 0 accordingly.
The original migration score for this facility was 44.63.
Based on the changes noted above, the HRS scores for McGraw Edison
are:
Ground Water 57.69
Surface Water 3.78
Air 0
Total 33.42
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6.12 Packaging Corporation of America, Filer City, Michigan
6.12.1 List of Commenters
NPL-210 F.B. Schelhorn, Senior Vice President, Packaging
Corporation of America. 2/25/83.
NPL-L11 Squire, Sanders and Dempsey, Counsellors at Law,
Columbus, Ohio. 3/9/83.
6.12.2 Summary of Comments and Response
The comment was made that although Michigan DNR did not pro-
pose PGA for inclusion on the NPL, the U.S. EPA did. The commenter
assumed that this proposal was based on a report by Ecology &
Environment, the (misstated) information that the Village of
Eastlake had to abandon a municipal well in 1976, and an erroneously
high HRS score.
In response, the Agency may include sites on the NPL,
independently of State recommendations, using any relevant data to
support its conclusions. Further, EPA has noted that the well which
was abandoned in 1976 was a test well and not a municipal well in
use. This fact has no bearing on the HRS score because the well was
not used to score ground water targets. The details of the HRS
score criticism are discussed below.
The commenter stated that PCA has conducted a detailed
hydrogeologic study which estimates the risk posed by the site
better than the HRS. EPA has already chosen the HRS, however, after
giving notice and an opportunity for comment, as the tool for
approximating risk. While EPA does not contest that a more detailed
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method might be able to produce a more accurate risk estimate in
individual cases, requiring such an approach to all sites for
listing on the NPL would be inordinately expensive and not a wise
use of limited fund resources. To maintain the consistency in
comparisons between sites that is necessary for NPL listing, EPA
must rank all sites according to a single method, the HRS. Where
more detailed information or estimates are available, EPA will take
this into account after listing in order to determine what response,
if any, is appropriate.
The commenter stated that the site is not abandoned, and that
there is no indication at present that Federal remedial action is
required. The criteria for NPL listing, however, reflect whether
the site is a potential threat to human health, not whether the site
is abandoned. While many of these sites are abandoned, a site need
not be abandoned before EPA can list or respond to it. In addition,
NPL listing does not establish that Federal remedial action is
necessary. Such need will be closely examined for all NPL sites.
The commenter further stated that prior action and past
cooperation with Michigan Department of Natural Resources should be
taken into account in compiling the NPL, and that the HRS is
inadequate because it does not take these factors into account. The
commenter also stated that the response status should reflect
voluntary response.
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As discussed in Part VII of the preamble to the final NPL, EPA
computes HRS scores and lists sites on the basis of conditions
existing before any response actions are taken in order to represent
the full scope of the original problem presented by a site. If EPA
determines that a site is cleaned up so that no further response is
necessary, EPA will delete the site from the list, as discussed in
Part VIII of the preamble to the final NPL. EPA has not yet made
such a determination with respect to the site, but will continue to
examine conditions at the PCA site to determine whether deletion is
appropriate. For sites that remain on the list, any cleanup
activities conducted pursuant to formal agreements with EPA are
acknowledged on the final NPL by notation in the "Voluntary or
Negotiated Response" category.
The commenter stated that EPA should consider the effects of
adverse publicity on NPL sites.
In response, the NPL, required by law, serves primarily
informational purposes. The commenter is referred to the Preamble
to the final NPL for further explanation.
Packaging Corporation of America (PCA) stated that EPA used
the flow of wastewater to the lagoons as the basis for scoring. PCA
further stated that they have no information, nor has EPA, that any
of the wastewater contained heavy metals in concentrations greater
than trace amounts. PCA stated that the hazardous waste quantity
factor is clearly intended to reflect the material in a facility
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which presents a threat of release, and is not designed to consider
the "release" itself.
The level of contaminant concentration is not a criterion of
hazardous waste identification or quantification, as long as the
contaminant is detected above background levels (47 FR 31229). EPA
has detected arsenic and cadmium in the lignin darkened paper mill
waste water in ground water samples.
To consider the quantity of waste at a site, the HRS assigns a
value for waste quantity based on the entire quantity of all waste
deposited that contains hazardous material, not on the quantity of
the constituents that are actually hazardous. As explained in the
preamble to the final National Contingency Plan, 47 FR 31190, this
position was taken because of the difficulty in determining, for all
sites, that portion of the total waste deposited that actually
constitutes hazardous material. Without this information, the
Agency knows of no internally consistent approach for comparing pure
hazardous substance quantity at facilities where definitive
information is available with hazardous substace quantity at
facilities where such information is not available. Further, waste
quantity, as defined in 47 FR 31229, is the total amount of waste as
received by the facility whether released or not.
PGA stated that EPA based the hazardous waste quantity score
on the monthly wastewater flow of 15 to 60 million gallons while the
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HRS says that all hazardous substances at a facility should be
considered, not the monthly use.
Because the wastewater is the source of the contamination, the
wastewater is the hazardous substance and the actual quantity of
hazardous substances "as received" at the facility would be the
volume of wastewater (47 FR 31229). One method of estimating this
volume would be to multiply the monthly wastewater flow by the
number of months of operation. The Michigan DNR has made this
calculation and concluded that PCA "... has dumped approximately 3.5
billion gallons of paper mill waste into the local ground water
aquifer." The flow of one month is sufficient to support the
maximum value of 8 for hazardous waste quantity according to 47 FR
31229.
Two procedures for calculating the quantity of pure arsenic
and cadmium were offered by PCA.
Neither procedure considers the total quantity of waste at the
facility (47 FR 31229).
PCA stated that Manistee Lake represents an effective barrier
to migration of the contaminated ground water to the west of the
lake, preventing wells on the west bank from being in the aquifer of
concern. Accordingly, they say the population on the west side of
the lake should not be considered in scoring population served by
ground water.
6-31
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In response, the Agency has determined that Manistee Lake is
not a discontinuity in the aquifer as described in the HRS. The
presence of the lake does influence the ground water gradient, but
the shallow aquifer is continuous beneath and west of the lake as
determined by well sampling done by the Michigan DNR. The three
reports submitted by Squire, Sanders and Dempsey, do not refute the
continuity of the aquifer. Wells drawing from the aquifer of
concern on the west side of the lake and within three miles of the
facility were appropriately included in the scoring.
PCA stated that the ground water is darker and off-color and
contains some heavy metals in concentrations over the primary
drinking water standards but below EP toxicity hazardous waste
standards and that the dark color of this ground water will prevent
its use.
The HRS criteria dictate that measured levels be "... at a
significantly (in terms of demonstrating that a release has
occurred, not in terms of potential effects) higher level than the
background level..." EP toxicity is not relevant to this
determination (47 FR 31224).
PCA stated that tests by an EPA contractor gave the same
results as earlier tests, showing that priority organic pollutants
associated with papermaking are not present in the ground water.
Although the priority organic pollutants were not detected in
the ground water samples, the Michigan DNR report, which is
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corroborated by the comments, states that the wastewater is the
source of the ground water contamination.
Finally, PGA stated that the value for surface water
containment should be 0 since the remaining lagoon is a depression
in the terrain and is not lined. The lagoon cannot leak to surface
water.
In response, while there is no diking around the lagoon, EPA
agrees that liquids in the lagoon are unlikely to leak or spill to
the surrounding ground surface. Due to the permeability of the
lagoon bottom, it is not anticipated that the lagoon could fill with
rainwater and overflow to the ground surface. According to the HRS,
surface water containment should score 0 if "all the water at the
site is surrounded by diversion structures that are in sound
condition and adequate to contain all runoff, spills, or leaks from
the waste...". The remaining lagoon meets this requirement and
should score 0 for surface water containment. The HRS score for the
surface water pathway has been reduced from 8.73 to 0.
The original migration score for this facility was 51.95.
Based on the changes noted above, the HRS scores for Packaging
Corporation of America are:
Ground Water 89.80
Surface Water 0
Air 0
Total 51.91
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6.13 Rasmussen's Dump, Green Oak Township, Michigan
6.13.1 List of Commenters
NPL-37 Edward C. Madere, City Manager, City of Brighton,
Michigan. 1/05/83.
6.13.2 Summary of Comments and Response
The commenter stated that this facility is not located in
Brighton but in Green Oak Township. This error is acknowledged and
has been corrected in the final listing.
The original migration score for this facility was 31.80. No
new technical information was submitted and no change in score was
required. The HRS scores for Rasmussen's Dump are:
Ground Water 53.59
Surface Water 12.40
Air 0
Total 31.80
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6.14 SCA Independent Landfill, Muskegon Heights. Michigan (05MI060)
6.14.1 List of Commenters
NPL-201 Bennet C. Jaffee, SCA Services, Inc. 2/24/83.
6.14.2 Summary of Comments and Response
The commenter indicated that SCA and the Michigan Department
of Natural Resources (DNR) have agreed to enter into a Closure
Agreement which will provide for "...closure of the existing
landfill, implementation of a wetlands restoration plan, maintenance
of the closed disposal area, monitoring of the disposal area, and
performance bonding." SCA stated that they have been informed
orally by DNR that DNR will request deletion of this facility from
the NPL once the Closure Agreement is executed.
Neither the consent agreement nor the State's request meet EPA
criteria for removing facilities from the NPL. These criteria are
discussed in the preamble to the NPL.
Review of this facility revealed errors in the values assigned
for the toxicity/persistence data from this site. These errors have
been corrected.
The original migration score for this facility was 36.36.
Based on the changes noted above, the HRS scores for SCA Independent
Landfill are:
Ground Water 44.90
Surface Water 10.91
Air 38ป46
Total 34.75
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6.15 Spiegelberg Landfill, Green Oak Township, Michigan
6.15.1 List of Commenters
NPL-37 Edward C. Madere, City Manager, City of Brighton,
Michigan. 1/05/83.
6.15.2 Summary of Comments and Response
The commenter states that this facility is not located in
Brighton but in Green Oak Township. This error is acknowledged and
has been corrected in the final listing.
The original migration score for this facility was 53.61. No
new technical information was submitted and no change in score was
required. The HRS scores for Speigelberg Landfill are:
Ground Water 92.31
Surface Water 8.95
Air 0
Total 53.61
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6.16 Velsicol Michigan, St. Louis, Michigan
6.16.1 List of Commenters
NPL-133 David B. Davis, Assistant City Manager, City of
Marshall, Michigan. 2/83.
6.16.2 Summary of Comments and Response
The City of Marshall indicated that neither the City of
Marshall nor the Michigan Department of Natural Resources is aware
of any problem in Marshall, Michigan.
It is acknowledged that the Velsicol Michigan facility is not
located in Marshall, Michigan. It is located in St. Louis,
Michigan. This error has been corrected.
The original migration score for this facility was incorrectly
reported as 48.78. Review of EPA Region V files revealed that all
available information pertaining to this facility supports a score
of 52.29. The HRS scores for Velsicol Michigan are:
Ground Water 89.80
Surface Water 10.91
Air 0
Total 52.29
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6.17 Burlington Northern, Brainerd/Baxter, Minnesota
6.17.1 List of Commenters
NPL-224 Barry McGrath, Attorney for Burlington Northern
Railroad Company. 2/28/83.
6.17.2 Summary of Comments and Response
The commenter contended that there is no evidence of offsite
migration of contaminants to ground or surface water. In response,
observed release for ground water is scored when there is analytical
evidence that there has been a release of a substance of concern to
ground water. Once the release is verified, extent of migration is
not relevant for HRS application (47 FR 31224). Ground water
monitoring at the site has clearly demonstrated that contaminants
have been released. Moreover, results of sampling done in 1982
disclose direct, quantitative evidence of the release of
contaminants from the site to the Mississippi River.
The commenter further said that the vast majority of the
population counted under ground water targets are not in danger of
exposure because one part of the population is protected by a
discontinuity and the other is upgradient of the contamination. The
Agency is in partial agreement with this comment. The population of
Brainerd, which was included in the calculations for the proposed
rulemaking, has been discounted because Brainerd receives water from
wells east of the Mississippi River, and the river acts as a
discontinuity to the aquifer of concern as defined in Section 3.5 of
the HRS. The Baxter city wells, which Burlinton Northern says are
6-38
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upgradient of the site, are located within 1900 feet of the
hazardous substance and serve 2,625 people. This population is
counted.
Because of the need to develop a nationally uniform scoring
system that could be used to score a large number of sites with the
data commonly available, the HRS does not specifically take into
account such level of detail as flow gradients when determining the
target population. This position is explained more fully in the
preamble to the final National Contingency Plan at 47 FR 31190.
A population of 2,625 receives a value of 3 and a distance of
1900 feet receives a value of 4. The distance to nearest
well/population served value, therefore, is 30 according to
Section 3.5 of the HRS. The original rating factor value was 40.
The original migration score for this facility was 58.41.
Based on the changes noted above, the HRS scores for Burlington
Northern are:
Ground Water 79.59
Surface Water 14.55
Air 0
Total 46.77
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6.18 FMC, Fridley, Minnesota
6.18.1 List of Commenters
NPL-218 William W. Warren, Counsel, FMC Corporation. 2/28/83.
6.18.2 Summary of Comment and Response
The commenter stated that because FMC Corporation entered into
a Consent Order with EPA Region V and the State of Minnesota on
June 8, 1983, which ended June 30, 1983, the site should be deleted
from the NPL.
In response, the existence of a Consent Agreement does not
affect the HRS score because the score is based on certain objective
characteristics of the site before response actions are taken and,
therefore, does not reflect current or prospective response
actions. EPA recognizes, however, the good faith cleanup efforts of
those who have entered into court-sanctioned agreements, and has
identified these sites by notation in the "Voluntary or Negotiated
Response" category of the NPL.
The commenter questioned the waste quantity (4820 drums) used
to calculate ground and surface water scores and said that only 119
tons could be attributed to the facility.
The commenter's analysis of 119 tons based on residual soil
concentrations of hazardous waste on site failed to include the
volume of contaminants which have migrated from the facility. The
waste quantity submitted does not represent the total quantity of
hazardous waste as received by the facility. Calculation of the
6-40
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amount of contaminant that reached the ground water added to the
residual waste quantity on site, gives a more accurate estimate of
the total waste quantity disposed. The calculated quantity of
trichloroethylene estimated to have reached the ground water is 28.6
tons based on Minnesota Pollution Control Agency data on TCE loading
of the Mississippi River. The total waste quantity is estimated to
be 147.6 tons. Based on the revised estimate, the total waste
quantity factor value is reduced from 8 to 4.
The commenter stated that there is no substantial threat to
the water supply for Minneapolis because the concentration of TCE is
not high enough to pose a significant public health risk. In
response, an observed release to the surface water is scored because
Minnesota Pollution Control Agency downstream samples show a
significant increase in trichloroethylene. An observed release is
an indication of the likelihood of release, not the harm from the
particular release observed.
The commenter stated that double-counting was involved in
estimating the target population for surface water, i.e., that the
same potential target population was used to score both surface and
ground water routes. EPA disagrees with this argument. The ground
water route was scored for Fridley and Brooklyn Center which use the
Prairie du Chien aquifer, and the surface water route is scored for
the Minneapolis intake from the Mississippi River which is, in turn,
contaminated by discharge from the more shallow drift aquifer.
6-41
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The commenter presented a risk assessment to show that there
is insufficient discharge from the site to cause any public health
concerns. The HRS, while it approximates risk, is not itself a risk
assessment. In light of the purpose of the NPL as an initial
indication of possible threats to public health for the purposes of
determining the need for further investigation and possible
response, it would have been an inappropriate use of fund resources
to compute actual risk assessments on all sites taking into account
all factors considered in the HRS. Risk assessment done by private
parties with respect to any one site cannot, therefore, affect
scoring or listing. More precise estimates of actual risk than
provided by the HRS may be taken into account, however, in
determining an appropriate response.
In addition to the risk assessment, the commenter also
submitted a detailed study of the Hazard Ranking System and the
Proposed National Priorities List. EPA is addressing comments
pertaining to specific facilities on the proposed NPL with other
comments on those facilities throughout this document. General
comments on the application of the HRS are discussed in the preamble
to the final NPL. Comments criticizing the HRS itself may in some
cases be briefly discussed, but the commenter should realize that
the HRS has already been subject to public comment and has been
promulgated. Comments received and Agency responses were published
in the preamble to the National Contingency Plan (40 CFR 300) in the
6-42
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Federal Register of July 16, 1982 (47 FR 31180).
The commenter stated that the HRS was not executed in a manner
that assures uniformity and reliability.
In response, HRS scores are audited by a quality assurance
team whose conclusions, in turn, are reviewed by EPA Regional
Offices and Headquarters. This procedure, which is discussed in the
preamble to the final NPL, is designed to assure uniform and
reliable application of the HRS.
The original migration score for this facility was 74.16.
Based on the changes noted above, the HRS scores for FMC are:
Ground Water 84.61
Surface Water 75.38
Air 0
Total 65.50
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6.19 National Lead Taracorp, St. Louis Park, Minnesota
Renamed: NL Industries/Taracorp/Golden Auto Parts
6.19.1 List of Commenters
NPL-94 J. W. Wentz, (Taracorp Industries) and
W. K. Weddendorf (NL Industries). 8/23/82.
NPL-272 J. W. Wentz, (Taracorp Industries) and F. R. Baser (NL
Industries). 2/28/83.
6.19.2 S""""ary of Comments and Response
National Lead Industries stated that the correct name of the
site is National Lead Taracorp Golden site because of Golden Auto
Parts involvement. In response, the site name has been modified to
reflect the involvement of Golden Auto Parts.
National Lead Industries stated that any reference to past air
emissions is not applicable to the HRS scoring of the site.
In response, the Agency concurs because air emissions were due
to past secondary smelter operations.
National Lead Industries stated that it did not dispose of
lead dust from fugitive or stack emissions on the property, and that
the sale to Taracorp was in 1979 and not 1978.
In response, EPA has observed lead dust at the facility and,
therefore, has used dust to assign a value for physical state. The
Agency acknowledges that the sale to Taracorp occurred in 1979.
The commenter stated that "excessively conservative scoring
judgements" results in an inflated score for this facility. Princi-
pal points of contention involve depth to aquifer of concern,
6-44
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physical state of the waste, ground water use and population served
by ground water.
According to the commenter, the depth to aquifer of concern
should be scored 2 or 1 depending on which aquifer is considered.
The Platteville limestone aquifer is 61 feet from the buried waste
and the St. Peter aquifer is 88 feet from the waste.
The USGS has indicated that the St. Peter aquifer (the aquifer
of concern) is hydraulically connected to the shallow Middle Drift
aquifer by vertical leakage caused by well construction, head
differences, and through contact caused by a discontinuity in the
Glenwood Shale confining layer approximately one-half mile from the
site. Because of this hydraulic connection, value for the depth to
aquifer factor was based on the depth to the shallow aquifer. The
originally assigned value of 3 is correct.
The commenter objected to the score for physical state because
most of the waste material is slag. The commenter stated that a
value of 1 is proper. The Agency believes that the value of 2 is
proper due to the large amount of dust present at the site.
The commenter stated that ground water use should be scored 2
rather than 3 because unthreatened sources are available. Agency
review of this facility indicates that this claim is justified. The
deeper Prairie du Chien-Jordan and Mount Simon-Hinckley aquifers
appear to be unthreatened and capable of meeting ground water
6-45
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requirements. The ground water use factor value has been reduced
from 3 to 2.
Finally, the commenter indicated that because only ten percent
of ground water needs are met by the St. Peter aquifer, only ten
percent of the population should be counted. In response, water
from all supply wells is fed to a central system; therefore, the
entire population is potentially affected.
The original migration score for this facility was 50.95.
Based on the changes noted above, the HRS scores for NL Industries/
Taracorp/Golden Auto Parts are:
Ground Water 68.84
Surface Water 6.46
Air 0
Total 39.97
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6.20 Big D Campground, Kingsville, Ohio
I
6.20.1 List of Commenters i
NPL-L17 Richard S. Hendey, Manager, Regional Environmental
Affairs, Olin Corporatira. 3/16/83.
6.20.2 S"fflflry of Comments and
The commenter indicated that 01Ln has completed an extensive
erosion control project at the facility, that the site is not a
significant threat to human health or
further corrective action is required
The Agency applied the HRS to facilities as they existed prior
to any remedial actions. Once sites
responsibility of EPA to determine wh
Response
the environment, and that no
or warranted.
ire identified, it is the
sther additional actions are
warranted. In addition, this facility was partially scored based on
i
an observed release to ground water, i No data have been submitted to
indicate that this problem has been rectified.
Review of this facility revealep that the toxicity/persistence
i
i
matrix was incorrectly assigned a valiie of 18 in the ground water
and surface water pathways. The proper value for vinyl chloride is
15. !
The original migration score for this facility was 34.78.
Based on the changes noted above, the HRS scores for Big D Camp-
ground are:
Ground Water 52.35
Surface Water 9.65
Air 0
Total 30.77
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6.21 E. H. Schilling Landfill, Hamilton Township, Ohio
6.21.1 List of Commenters
NPL-251 S. K. Todd, Attorney, U.S. Steel Corporation. 2/29/83.
6.21.2 Summary of Comments and Response
U.S. Steel stated that although Ohio EPA has identified the
Corporation as a major contributor to the E. H. Schilling landfill,
they had no opportunity to dispose of any PCS material and had no
knowledge of PCS at the facility. In response, the presence of a
particular substance at a facility does not necessarily imply the
assignment of liability. A soil sample taken at the site by EPA on
October 30, 1980 revealed the presence of PCB. Toxicity/persistence
was appropriately scored on the basis of PCB.
The commenter stated that the nearest aquifer is deeper than
the 10 to 20 feet assumed by EPA and that the material in the
unsaturated zone contains significant quantities of sandy shale and
should be scored 1 rather than 2, to reflect its low permeability.
The Ohio EPA has surveyed local well logs and determined that
the depth from the lowest point of the hazardous substance to the
highest seasonal level of the saturated zone of the aquifer of
concern is less than 20 feet. The depth to aquifer of concern was
scored appropriately. The unsaturated zone is a mixture of medium-
grained sandstone and sandy shale, according to EPA files. This
mixture should be scored 1 instead of 2 for permeability of the
unsaturated zone and the HRS score has been adjusted accordingly (47
FR 31224).
6-48
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The conunenter also noted that alternative unthreatened water
supplies are available to area residents. In response, municipal
drinking water was recently made available to residents in the
area. This is an unthreatened alternative supply and the ground
water use factor value has been reduced from 3 to 2 (47 FR 31230).
The commenter stated that ground water containment is
misscored because there is a liner of native clay and sand and no
ponding occurs on the surface. In response, the Ohio EPA reports
that the soil beneath the site has not been compacted or reworked in
any way and does not constitute a liner. Ohio EPA further states
that they have observed surface ponding.
Finally, the commenter stated that the landfill cover is four
feet rather than "less than 2 feet" as indicated by the HRS
scoring. In response, the Agency assumes this comment is directed
at the direct contact scoring since the depth of landfill cover
would not affect the migration pathways. There is evidence that the
cover is less than 2 feet in some areas. Therefore, the direct
contact score was appropriate.
The original migration score for this facility was 40.37.
Based on the changes noted above, the HRS scores for E. H. Schilling
Landfill are:
Ground Water 58.78
Surface Water 10.91
Air 0
Total 34.56
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6.22 Fields Brook, Ashtabula, Ohio
6.22.1 List of Commenters
NPL-198 William J. Henrick, Associate General Counsel, The
General Tire and Rubber Company. 2/25/83.
NPL-216 Reed, Smith, Shaw and McClay on behalf of Detrex
Chemical Industries, Inc. 2/28/83.
NPL-254 Richard S. Hendey, Jr., Manager, Regional
Environmental Affairs, Olin Chemicals Group. 2/25/83.
NPL-268 Robert W. Hill, Senior Counsel, Diamond Shamrock.
2/28/83.
6.22.2 Summary of Comments and Response
Detrex Chemical Industries stated that the site is not
well-defined. Both contaminated water and Ashtabula River Harbor
sediments appear to have been used in the scoring, but are not
linked (by monitoring data) to Fields Brook.
The Agency has defined the site as Fields Brook and adjacent
industrial areas, the Ashtabula River, and the Harbor because they
are contiguous and the same hazardous substances are involved.
Olin Chemicals Group stated that there are no monitoring data
to support an observed release from the sediments to surface water.
In response, contaminated sediments are in contact with
surface water and are contained within the stream bed. This is
direct evidence that contaminated substances have been released to
the surface water.
Olin Chemicals Group stated that the Ashtabula surface water
intake is upstream of the normal course of surface water flow,
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considering the currents in the harbor. Detrex Chemical Industries
and Olin Chemicals Group stated that the distance to the surface
water intake is incorrect.
In response, although the predominant current flow in Lake Erie
at Ashtabula Harbor may be west to east, the currents vary
seasonally and with river flow. The lake is most appropriately
considered to be a static water body for the purpose of scoring the
facility. The distance to water intake downstream was appropriately
considered in that contamination was found in Ashtabula Harbor which
correlates with contaminants in Fields Brook. Because the
breakwater is not a barrier to water flow, it does not affect the
measurement (1350 feet from contamination to water intake).
Olin Chemicals Group and General Tire and Rubber Co. stated
that surface water use should have a value of 2 for recreational use
rather than 3 for drinking water.
EPA feels that the surface water use was scored appropriately
because the Ashtabula drinking water intake is within three miles of
the facility.
Olin Chemicals Group stated that hazardous waste quantity
should have a value of 0 because there are no data to support a
higher value. General Tire and Rubber estimated a worst case waste
quantity for the ground water route of 94 cubic yards based on
concentrations in the sediments.
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In response, the HRS Documentation Records for the scoring do
not quantify the hazardous substances. It is evident, based on
water sampling and analysis, that hazardous compounds are present in
the ground water. The waste quantity for ground water is greater
than zero and a value of 1 is appropriate. The Agency has
determined the waste quantity for the surface water route to be the
amount of contaminated stream sediments, 101.93 tons. This quantity
is given a factor value of 3 which represents a quantity between 63
and 125 tons.
Diamond Shamrock and General Tire and Rubber stated that the
ground water route work sheet should be deleted because it
characterizes a separate facility. The commenters stated that the
facility is the Fields Brook sediments and, therefore, the ground
water route score should characterize the potential for a hazardous
substance release from these sediments into ground water. The
ground water route work sheet, however, describes releases from a
separate facility, the sludge lagoon at IMC. The nearest IMC
tailings pond is at least 1/4 mile away from Fields Brook.
The CERCLA definitions of "release" and "facility" are quite
broad (CERCLA Section 101(9) and (22)), and give EPA a great deal of
flexibility in how to define the boundaries of a site for listing on
the NPL. For purposes of the HRS, EPA has chosen to determine the
boundaries of a site to include all areas where substances have been
deposited, extending to all areas to which the substances have
6-52
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migrated. EPA has, therefore, defined the site to include the
industrial areas adjacent to Fields Brook, including the IMC lagoons.
Reed, Smith, Shaw, and McClay stated, on behalf of Detrex
Chemical Industries, Inc., that EPA has not identified the hazardous
substances that are the basis for scoring Fields Brook.
In response, EPA has identified mercury, PCBs, various organics
and heavy metals in the ground and surface waters of Field Brook.
General Tire and Rubber Co., stated that route characteristics
should not be scored since there is no evidence of ground water
contamination.
In response, Fields Brook has had an observed release;
therefore, route characteristics are not scored according to HRS
guidelines. 47 FR 31224.
General Tire and Rubber Co. calculated the waste quantity for
the surface water route from water concentrations, obtaining an HRS
value of 1. In response, the waste quantity for the surface water
route is not accurately estimated by water concentrations because
the contaminants in the stream sediments are not included. Agency
experience with surface water releases involving these types of
contaminants is that the majority of the substances reside in the
sediments. EPA has calculated waste quantity for the surface water
route to be the amount of contaminated stream sediments, 101.93 tons.
Diamond Shamrock stated that more data need to be developed
before responsible parties can be properly identified and that EPA
has not considered all sources of contamination.
6-53
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In response, the NPL does not purport to identify responsible
parties but to serve as a source of information for the States and
public. The commenter is referred to the preamble to the NPL.
Changes in the original score were made based on the
acquisition of new data by EPA. Waste quantity factor value for the
ground water route was reduced from 8 to 1 to reflect that the
quantity is unknown. The original value of 8 was assigned using
undependable data on the volume of the IMC lagoons. EPA has
determined that the quantity of contaminated sediments in Fields
Brook, 101.93 tons, is an appropriate estimate of this factor, which
is assigned a value of 3.
Groundwater use was originally assigned a value of 1 to reflect
that the water is not used but usable. The Agency has more current
information which shows that there are three private wells within a
three mile radius of the site which draw from the aquifer of
concern, the closest of which is 2000 feet to the west. Since
municipal water is also available for drinking water, ground water
use is assigned a factor value of 2 to indicate that the water is
used but that alternative unthreatened supplies are available.
Distance to nearest well/population served was originally assigned a
value of 0 because ground water was not known to be used within the
three mile radius of the site. The Agency is now aware of three
residential wells the closest of which is 2000 feet west of the site
which serve an estimate of 11.4 people (3.8 x 3). These facts
6-54
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correspond to a distance to nearest well/population served factor
value of 8.
The Agency identified wetlands 1700 feet from the site which
receives a factor value of 1 for distance to sensitive environment.
The original documentation did not identify a sensitive environment
within a mile of the site and assigned a factor value of 0.
The original migration score for this facility was 51.62.
Based on the changes noted above, the HRS scores for Fields Brook
are:
Ground Water 20.88
Surface Water 74.90
Air 0
Total 44.95
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6.23 Summit National Services, Deerfield Township, Ohio
6.23.1 List of Commenters
NPL-198 W. J. Henrick, Associate General Counsel, General Tire
and Rubber Company. 2/25/83.
6.23.2 Sปnimary of Comments and Response
The commenter stated that the source of the observed ground
water release must be carefully evaluated. Two other waste disposal
sites are in the immediate area, and there have been coal strip
mining and oil and gas drilling in the area.
The Ohio EPA has assured U.S. EPA Region V that its ground
water sampling data provide direct evidence that the compounds
detected in the ground water can be attributed to the Summit
National facility.
The commenter further suggested that the facility should be
removed from the NPL because surface cleanup has already taken
place. In response, the HRS is applied to sites as they existed
prior to any remedial action, as explained in Part VII of the
preamble to the final NPL. In addition, before deleting a site from
the list on the basis that cleanup has been accomplished, EPA must
make final decisions as to whether additional cost effective actions
can be taken. In addition, despite the completion of some cleanup
actions at this facility, no technical data are provided to indicate
that ground and surface water contamination have been corrected.
6-56
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The original migration score for this facility was 52.28.
Based on the above response to comments, the score remains un-
changed. The HRS scores for Summit National are:
Ground Water 89.80
Surface Water 10.91
Air 0
Total 52.28
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6.24 Van Dale Junkyard, Marietta, Ohio
6.24.1 List of Commenters
NPL-128 David P. Eckart
NPL-181 R. R. Clark, Manager, Environmental Engineering,
B.F. Goodrich Company. 2/23/83.
6.24.2 Summary of Comments and Response
Mr. Eckart supported the inclusion of this facility on the
National Priorities List.
B.F. Goodrich stated that the Van Dale Junkyard presented its
most hazardous condition prior to December 1980, and the risk
associated with it has been diminishing even since. Cleanup at this
time, therefore, would provide little benefit to society.
In response, EPA computes MRS scores and lists sites from data ^
representing the full scope of the original problem presented by a
site, as discussed in Part VII of the preamble to the final NPL. If
EPA determines that a site is cleaned up so that no further response
is necessary, EPA will delete the site from the list, as discussed
in Part VIII of the preamble to the final NPL.
B.F. Goodrich stated that there are no data to indicate that
tetrachloroethylene was disposed of at the site. This compound
should not be used to score toxicity/persistence. Only compounds
found in both sets of tests and onsite in some reportable quantity
should be used for scoring.
Tetrachloroethylene was detected in the marsh area adjacent to
and down-slope from the facility. The only probable source of
tetrachloroethylene is the facility, given the sampling location and V
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the lack of other probable sources in the area. It is reasonable to
conclude that tetrachloroethylene is present on the facility. The
toxicity/persistence matrix has been reduced from 15 to 12 to
correct an error in assigning a matrix value to tetrachloroethylene.
B.F. Goodrich stated that tests conducted on all three
B.F. Goodrich waste streams show none of them to be EP toxic. In
response, EP toxicity is not the criterion used to evaluate hazard-
ous substances in the HRS. N. I. Sax, Hazardous Properties of
Industrial Materials is used. The commenter is referred to the HRS
(47 FR 31229).
The commenter stated that the 500,000 pounds of American
Cyanamid waste disposed at the site are not hazardous and should be
excluded in scoring waste quantity. The commenter also stated
B.F. Goodrich disposed of the equivalent of 455 drums (113 tons) at
the site.
EPA now has data submitted by American Cyanamid Company
listing 600,000 pounds of material disposed at the site. The
description of the composition of this waste material and the fact
that American Cyanamid filed a RCRA Part A application as a
hazardous waste generator leads the Agency to believe that of that
quantity, the 300,000 pounds (150 tons) of "tar cake" waste is
hazardous. In 1981, B.F. Goodrich reported to the Ohio EPA that
approximately 632 drums (158 tons) of hazardous waste were delivered
to the Van Dale site and the waste quantity value of 5 was
appropriate.
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The commenter stated that B.F. Goodrich wastes were poured on
the ground and apparently evaporated or were open burned.
The HRS requires consideration of all hazardous substances at
a facility (as received) except that with a containment value of 0,
and does not allow reduction of the hazardous waste quantity due to
percolation, evaporation, or burning of the substances. This
approach was taken because of the possibility that deposited wastes
could begin migration before burning was completed.
The commenter was advised by the Reno Water District Authority
that the house within 1,300 feet used to score distance to nearest
well is served by municipal water. The Reno Water District
Authority also advised the commenter that the entire area is served
by municipal water and that wells still in use are used primarily
for livestock watering. They indicated that the 270 wells cited in
scoring population served by ground water are not used for drinking
water.
When EPA requested verification, Mr. Henry Lauderman of the
Reno Water District Authority (RWDA) indicated that water service to
the house in question, and to several other nearby houses, has been
discontinued indefinitely. The distance to nearest well was,
therefore, scored (value of 4) appropriately. The RWDA stated that
water service is available to most homes and businesses in the
vicinity of the site; however, many homeowners continue to use their
private well supplies. Based on this information, ground water use
should have a value of 2 instead of 3. The RWDA also advised that
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more than half of the homes in the area use municipal water. Using
data supplied by the Ohio EPA, the potentially affected population
is 2524 persons. The value for population served by ground water
should be 3. The matrix value for distance to nearest
well/population served remains 30.
Finally, the commenter suggested that a realistic indication
of the risk to population via ground water associated with the site
would be to evaluate the population served at the various
incremental distances cited in the HRS.
The HRS requires that the population served by wells within 3
miles of the hazardous substances be counted in scoring population
served by ground water. The distance to nearest well is scored
independently of population, and the two values are used in the
matrix to determine the score for distance to nearest
well/population served.
The commenter stated that route characteristics need not be
evaluated because sampling does not indicate the presence of ground
water contamination.
In response, analytical evidence of ground water contamination
constitutes an observed release, for which case the HRS provides
that route characteristics should not be scored. If there were no
observed release, however, route characteristics would be scored in
order to estimate the likelihood of future contamination (see the
HRS at 47 FR 31224).
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The original migration score for this facility was 28.73.
Based on the changes noted above, the HRS scores for Van Dale
Junkyard are:
Ground Water 38.43
Surface Water 7.13
Air 0
Total 22.59
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7.0 COMMENTS ON REGION VI SITES
7.1 Cecil Lindsey, Newport, Arkansas
7.1.1 List of Commenters
NPL-185 Arkansas Department of Pollution Control and
Ecology. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.1.2 Summary of Comments and Response
The Arkansas Department of Pollution Control and Ecology noted
that the City of Newport Municipal Water Works wells are outside of
the three mile radius of the site; that there are 8 private wells
and 1 industrial well within the three mile radius which serve
approximately 200 people; that the on-site well is not in use; that
the nearest well drawing from the aquifer of concern is 400 feet
northwest of the site; and that 5,156 acres are irrigated by wells
within a 3 mile radius of the site. Information concerning the
location of the City of Newport wells was provided by Mr. David
Sherman, Superintendent of Water Works. Information on irrigated
acreage was provided by the U.S. Soil Conservation Service.
The factor score (matrix) for distance to nearest
well/population served was originally 35 resulting from a distance
to the nearest well of 0 and a population of 8,339. The matrix
score based on the new information presented above (a distance to
nearest well of 400 feet and a population of 7,940) is also 35.
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The U.S. Department of the Interior noted that heavy metals,
pesticides, and hydrocarbons constitute the main contaminants
present at the site; and that the area ultimately drains into the
White River and waterfowl and the fishery may be affected.
In response, the factor score for toxicity/persistence was
based on Chromium, which scored the maximum of 18. Including
pesticides and/or hydrocarbons would not change the factor score.
The existence of the fishery and waterfowl on the White River do not
affect the scoring of this site. The commenter did not provide
specific information concerning the fishery and waterfowl which
would affect the score of the site.
Review of the scores for this facility revealed that scores
were improperly rounded in the original listing. The ground water
route score was originally calculated to be 61.0, but rounded to two
decimal places, the proper score is 61.25. The surface water route
score was originally calculated to be 6.0 but, rounded to two
decimal places, the proper score is 6.38. The migration route score
based on the new calculation equals 35.60 not 35.4 as originally
calculated.
The original migration route score for this facility was 35.4.
Based on the changes noted above, the route scores for Cecil Lindsey
are:
Ground Water 61.25
Surface Water 6.38
Air 0
Total 35.60
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7.2 Crittenden County Landfill, Marion, Arkansas
7.2.1 List of Commenters
NPL-185 Arkansas Department of Pollution Control and
Ecology. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.2.2 Summary of Comments and Response
The Arkansas Department of Pollution Control and Ecology noted
that high levels of chromium and lead found in one sample point
(point 3) do not adequately represent the entire site; that the
wells which supply the residents of Marion and Sunset are 3 and 1/4
miles from the site and drawing from the Wilcox formation at a depth
of 1500 feet; that the wells serving the communities of Vincent and
Ebony are approximately 3 and 1/2 miles from the site and are about
1600 feet in depth; and that the wells within a 3 mile radius are
private and serve 15 homes and the Mount Zion Church. Information
on the Marion and Sunset wells was provided by Mr. Horace Brackin,
City Superintendent for Marion and Mr. Matt Broom of U.S.G.S.
Information on the Vincent, Ebony and local private wells was
received from Mr. Kevin McCormick of the Arkansas Health Department.
The high levels of chromium and lead found in one site sample
may, in fact, not represent the levels found elsewhere on the site.
However, the HRS scoring is based only on the observance of any
levels higher than background, not on the precise levels, so
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different contaminant levels at different sample points does not
affect the score.
The factor score (matrix) for distance to nearest well/
population served was originally 35, resulting from a distance to
nearest well of 1/2 mile and a population served of 3665, which
included those people served by the Marion City Water Works. No
documentation for the estimate by the Arkansas Department of
Pollution Control and Ecology of 15 houses served by ground water
was provided. The population served by private wells in the area
was estimated by EPA using a topographic map to count homes that
most likely have private wells. Using this method it was estimated
that 31 homes or 118 people plus the 20 members of the Mt. Zion
Church are the population served. The nearest well is 150 feet from
the site. The matrix score based on a population of 138 and a
distance to nearest well of 150 feet is 20.
The U.S. Department of the Interior noted that this site was
used mainly for garbage disposal, although heavy metals have been
detected; that the principal threat is to subsurface waters and that
a subterranean hydrological connection to the Mississippi River may
exist.
Heavy metals (lead and chromium) were used in scoring the
site. The ground water route was scored for potential release. The
Department of the Interior did not provide any detailed information
or documentation on a subterranean hydrological connection to the
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Mississippi River, so its impact on the site score was not analyzed.
The original migration score for this facility was 33.1. Based
on the changes noted above, the route scores for Crittenden County
Landfill are:
Ground Water 40.37
Surface Water 5.31
Air 0
Total 23.54
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7.3 Frit Industries, Walnut Ridge, Arkansas
7.3.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.3.2 Summary of Comments and Response
The commenter noted that the site discharges heavy metals and
fertilizer; and that the site is a potential threat to fish and
wildlife resources.
The site was scored 18 for cadmium, a heavy metal. No score
change results from evaluating fertilizers.
The potential threat to fish and wildlife are accounted for in
the HRS method of scoring ground water, surface water, and air
routes which reflect the potential for harm to humans or the
environment from migration of a hazardous substance from the site.
Review of the scores for this facility revealed that scores
were improperly rounded in the original listing. The surface water
route score was originally calculated to be 10.9, but rounded to two
decimal places, the proper score equals 10.91. The air route score
was originally calculated to be 51.10, but rounded to two decimal
places, the proper score equals 51.15. The migration route score
was originally calculated to be 39.4, but rounded to two decimal
places, the proper score equals 39.47.
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Based on the change noted above, the route scores for Fritt
Industries are:
Ground Water 43.90
Surface Water 10.91
Air 51.15
Total 39.47
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7.4 Gurley Pit, Edmondsen, Arkansas
7.4.1 List of Commenters
NPL-185 Arkansas Department of Pollution Control and
Ecology. 1/26/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.4.2 Summary of Comments and Response
The Arkansas Department of Pollution Control and Ecology noted
that the population served by the aquifer of concern (an alluvial
aquifer at a depth of 15 feet) should not include those served by
the Midway Water Association which draws from wells in the Wilcox
Sands Aquifer (at a depth of approximately 1000 feet); that the
aquifer of concern serves only 19 people; that the Midway Water
Association system is an alternate, unthreatened source for the
population; and that, based on the preceding information, the ground
water score drops to 30.48 and the overall site score becomes 18.71.
Review of the information provided by the Arkansas Department
of Pollution Control and Ecology indicates that the population
served by the Midway Water Association is served by the deeper
aquifer and should not be included in the scoring. However, in
addition to the 19 people served by the alluvial aquifer, 1920 acres
are irrigated from this aquifer within a 3 mile radius of the site.
The irrigated land equates to a target population of 2880. The 19
people drawing from the aquifer of concern should be added to this
to result in a total target poulation of 2899. The combined factor
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score for a population served of 2899 and a distance to nearest well
of 1/4 mile is 30.
The Midway Water Association is an alternative source, reducing
the numerical value for the ground water use factor from 3 to 2
resulting in a change of factor score from 9 to 6.
An addition error in the total route characteristics category
score was found. It should be 14, not 11 as used in the initial
scoring. Based on the above changes, the ground water route score
changed from 65.00 to 68.57 and the migration route score changed
from 38.1 to 40.13.
The U.S. Department of the Interior noted that this site
discharges chromium, lead, PCB's and hydrocarbons to Fifteen-Mile
Bayou, a tributary of the Saint Francis River during flood events;
and that a light oil slick, which poses a threat to migratory
waterfowl, exists on the surface.
In response, PCB's were used to determine the combined factor
score for toxicity/persistence and both lead and chromium were also
evaluated. Since all three score the maximum of 18, the inclusion
of hydrocarbons would not alter the score.
The surface water route score was determined on the basis of an
observed release as indicated by the U.S. Department of the
Interior. The potential threat to fish and wildlife are accounted
for in the HRS method of scoring ground water, surface water, and
air routes which reflect the potential harm to humans or the
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environment from migration of a hazardous substance from a site.
The original migration score for this facility was 38.10.
Based on the changes noted above, the HRS scores for Gurley Pit are:
Ground Water 68.57
Surface Water 10.91
Air 0
Total 40.13
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7.5 Industrial Waste Control, Ft. Smith, Arkansas
7.5.1 List of Commenters
NPL-185 M. Bates, Hazardous Waste Inspector, Arkansas
Department of Pollution Control and Ecology. 2/24/83.
NPL-281 J. L. Fortner, Manager, Plant and Process
Engineering, Whirlpool Corporation. 2/25/83.
7.5.2 Summary of Comments and Response
The Arkansas Department of Pollution Control and Ecology stated
that only 23 people are served by ground water from the aquifer of
concern. Revised documentation records submitted by this commenter
indicate the presence of six private wells within 3 miles of the
facility. The report cited in the revised documentation records
contained insufficient information to determine the basis for these
numbers.
At the same time, insufficient information is available to
support the original HRS value for population based on 1100 people.
EPA investigation of this facility shows 200 homes using ground
water within the 3 mile radius. This information is based on
discussions with representatives of nearby water supply agencies
(Greenwood and South Sebastian) and counting homes on a topographic
map. Areas served by municipal water were indicated on the same map
and were not considered. Based on the HRS assumption of an average
of 3.8 persons per home, two hundred homes convert to 760 people.
The HRS values for distance to nearest well/population served has
been lowered from 30 to 20.
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The revised documentation records submitted by this commenter
also indicated the presence of alternative unthreatened water
supplies within one mile of homes on private wells, which would
result in a ground water use value of 2 rather than 3 as originally
assigned. In response, the one mile distance to these supplies does
not meet HRS criteria of "minimal hookup requirements" to warrant
the lower value. The value assigned to this rating factor remains a
3.
This commenter also noted soil sample cadmium levels above
background reported in a December 1982 sampling survey. In
response, it is noted that although this site was not evaluated on
the presence of cadmium, the maximum toxicity/persistence value of
18 was assigned for arsenic, and would be the same for cadmium.
The Whirlpool Corporation indicated that since the observed
surface water release in 1977, the ponds have been filled and the
surface graded to prevent the offsite flow of rainwater. In
response, while the Agency encourages private party response, the
Agency evaluates facilities based on site conditions prior to any
remedial action, as explained in Part VII of the preamble to the
final NPL. No score change is required.
The Whirlpool Corporation stated that recent visual examination
of the facility revealed no indication that any contaminant is
leaving the site. The commenter further stated a "casual observer
would not notice that the site was ever used for waste disposal."
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In response, despite appearances, this facility had a measurable
release to surface water in 1977 and, based on available information
pertaining to site and waste characteristics, represents a con-
tinuing threat to ground water and, consequently, to drinking water.
Whirlpool also expresses the opinion that many of the disposed
materials were not hazardous and that many of those that are
hazardous are so considered only because of their flammability.
They further state that these materials were not incorporated into
the soil at the site.
In response, the quantity of hazardous material deposited at
this facility is discussed in the Field Investigation Team report
cited in the documentation records. While the fate of these
materials is not known at this time, the presence of elevated levels
of cadmium in site soil samples indicates that some of these
materials have migrated into the soil.
Whirlpool also indicated that sampling and analysis conducted
by the Arkansas Department of Pollution Control and Ecology showed
that no materials have moved from the site. In response, EPA's
calculation of the site's HRS score is consistent with the fact,
since the ground water pathway has been evaluated on the basis of
potential for migration rather than for observed release.
Review of this facility revealed that the permeability rating
factor in the ground water pathway, was incorrectly assigned a value
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of 2. Soil maps for Sebastian County indicate soils of gravelly
loam, warranting a value of 3.
In addition, in "Hydrogeologic Study of landfill site near
Jenny Lind" by Buren and Durham, they state that the site is
situated on the Harthorne Sandstone and McAlester Formation. Both
of these formations are characterized as containing strata that have
high hydraulic conductivities. These strata are more than likely
interconnected because they are alluvially derived and because the
site is within a faulting zone.
The original migration score for this facility was 36.90.
Based on the changes noted above, the HRS scores for Industrial
Waste Control are:
Ground Water 51.29
Surface Water 10.91
Air 0
Total 30.31
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7.6 Mid-South Wood Products, Mena, Arkansas
7.6.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.6.2 Summary of Comments and Response
The commenter noted a potential threat to valuable stream
fisheries.
In response, Mountain Fork River is considered a critical
habitat for the leopard darter and a value of 3 was used in the
original scoring for distance to a critical habitat accordingly. In
addition, surface water use was assigned a value of 2 for
recreational fishing. Therefore, the concerns of the Department of
the Interior have already been taken into account.
Review of this facility revealed rounding errors in the
calculation of scores. Scores have been adjusted accordingly,
The original migration score for this facility was 45.43.
Based on the changes noted above, the HRS scores for Mid-South Wood
Products are:
Ground Water 76.53
Surface Water 20.98
Air 0
Total 45.87
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7.7 Vertac, Inc., Jacksonville, Arkansas
7.7.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.7.2 Summary of Comments and Response
A. D. Little, Inc. noted that the distance to a fresh water
wetland was "less than two miles" which should score as 0, but was
scored as 3 on the worksheet; and that there was an arithmetic error
in scoring the "targets" section of the air route resulting in a
category score of 21 rather than 24.
According to the HRS, distance to a fresh water wetland should
score 0 if greater than one mile. The documentation for the ^
original scoring does list the distance to a sensitive environment
as less than 2 miles. However, contamination of Bayou Metou has
been documented by EPA for most of its length from the Vertac site
to the Arkansas River. Bayou Metou passes through the State of
Arkansas Bayou Metou Wildlife Management Area (WMA) in Arkansas
County. As explained in Section 4.5 of the HRS (47 FR 31236),
"distance to a sensitive environment refers to the distance from the
hazardous substance (not the facility boundary) to an area
containing an important biological resource or to a fragile natural
setting that could suffer an especially severe impact from
pollution." Since contamination has been substantiated in this
7-16 *
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section of Bayou Metou and it flows through the WMA the "distance
from the hazardous substance" is zero and the highest score of 3
applies for the distance to a sensitive environment. No score
change occurs.
An addition error was made in the targets category of the air
route score. The correct score for this category is 24 rather than
21 which was originally entered.
Review of the scores for this facility revealed another
arithmetic error in the matrix score for the distance to nearest
well/population served. The score was incorrectly entered as a 12.
The correct score for a population served of 5.3 and a distance to
nearest well of 1 mile is 8.
The U.S. Department of the Interior noted that the principal
contaminants at this site include dioxin, pesticides, herbicides,
and PCB's; and that contaminants have been discharged into the Bayou
Metou Wildlife Management Area.
Dioxin and Trichlorophenols were evaluated under waste
characteristics and the site was scored for dioxin, which scores the
maximum 18. Evaluating the other contaminants listed would not
raise the score.
The effect of the contaminants on the WMA are taken into
consideration in the scoring of distance to a sensitive environment
as 3, which is discussed above.
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The original migration route score for this facility was
64.96. Based on the changes noted above, the route scores for
Vertac, Inc., are:
Ground Water 28.57
Surface Water 94.55
Air 55.38
Total 65.46
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7.8 Bayou Bonfouca, Slidell, Louisiana
7.8.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.8.2 Summary of Comments and Response
The commenter noted the potential for downstream surface water
contamination to reach Lake Pontchartrain with potential effects on
recreational and commercial fishing and wintering wildfowl. This
information was considered by including a factor score of 3 (the
highest) for the distance to a sensitive environment in developing
the original HRS scores for this facility.
Reviewing the documentation of this site revealed discrepencles
between the score indicated by the documentation and the scores
entered on the HRS scoresheet. Information currently available to
Region VI personnel provided the basis for the following score
changes.
Permeability of the unsaturated zone should be 1 (rather than 2
as originally scored) because the material is silty clay
(47 FR 31224). The volume of hazardous substance, 12,978 cubic
yards, should score 8 (rather than 6 as originally scored)
(47 FR 31229). Ground water use is drinking water, sole source
rather than commercial industrial, so ground water use should score
3 rather than 1 (47 FR 31231). The ground water use change resulted
from choosing the deep (150 foot) aquifer as the aquifer of
concern. Surface water target population is 0, rather than 750 as
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originally documented, so the combined score for population
served/distance to water intake downstream is 0.
Based on the above changes, the ground water route should score
46.67 rather than 54.00 and the surface water route should score
21.82 rather than 33.57.
The original migration route score for this facility was
36.75. Based on the changes noted above, the MRS scores for Bayou
Bonfouca are:
Ground Water 46.67
Surface Water 21.82
Air 0
Total 29.78
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7.9 Cleve Reber, Sorrento, Louisiana
7.9.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.9.2 Summary of Comments and Response
The commenter noted that this site drains into an extensive
wooded swamp which is an important habitat for wildfowl. This
information was considered by giving a score of 3 for distance to a
sensitive environment in developing the original HRS scores for this
facility.
The original migration score for this facility was 48.80. No
new technical information was submitted and no change in score was
required. The HRS scores for Cleve Reber are:
Ground Water 42.45
Surface Water 29.09
Air 66.92
Total 48.80
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7.10 Old Inger, Darrow, Louisiana
7.10.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.10.2 Summary of Comments and Response
The commenter noted that fish and wildlife resources are of
limited significance in the area of this facility.
In response, the site is within one-half mile of a Federally
designated wetland and was properly given a score of 3 for distance
to a sensitive environment according to criteria set forth in the
HRS.
The original migration score for this facility was 48.98. No
new technical information was submitted and no change in score was
required. The HRS scores for Old Inger are:
Ground Water 79.59
Surface Water 29.09
Air 0
Total 48.98
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7'11 Homestake, Milan, New Mexico
7.11.1 List of Commentary
NPL-215 Covington and Burling, Attorneys for United Nuclear
and Homestake Mining Company. 2/28/83.
NPL-221 Stephenson, Carpenter, Grout and Olmsted, Attorneys
for Homestake Mining Company. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.11.2 Summary of Comments and Response
Homestake Mining Company stated that an injection-collection
system now in operation prevents releases to ground water. They
also stated that other sources could have released the detected
contaminants.
As a remedial action, the injection-collection system is not
considered in applying the HRS to the facility. As explained in the
preamble to the final NPL, facilities are scored to reflect site
conditions prior to any remedial action. Further, despite the
system, the commenter indicates that 4 or 5 wells still contain
elevated levels of selenium. Ground water isoplots developed by
Homestake Mining Company clearly show that the sources of
contamination are the tailings ponds on the Homestake property.
Homestake Mining Company indicated that the hazardous waste
quantity value overstates the amount that can migrate to ground
water and that the toxicity and persistence values are also
overstated. Toxicity is overstated because only 4 or 5 wells exceed
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state standards and persistence because uranium and selenium are
removed by the alluvial soil.
The HRS indicates that hazardous waste quantity "includes all
hazardous substances at a facility as received" with a. non-zero
containment value. Since the tailings include hazardous substances,
the entire amount should be included for determining hazardous waste
quantity. The weight given to the hazardous waste quantity factor
in the HRS reflects the fact that generally only a portion of the
quantity is likely to migrate. This relationship in the HRS was
established after thorough analysis and consideration of comments on
the HRS, and has already been promulgated as part of the NCP.
For use in the HRS, the toxicity factor is to be derived from
Sax which gives both selenium and uranium high toxicity ratings. In
the HRS, toxicity is evaluated according to the physical and
chemical properties of the substance identified, not according to
the levels of concentration of the substance as observed.
Therefore, compliance with standards for levels of concentration is
not relevant to scoring for toxicity. Persistence is evaluated on
its biodegradability as outlined in the HRS. Since both are metals,
the HRS assigns a persistence value of 3. Containment of
contaminants by natural mechanisms is uncontrolled and often
uncertain and is not, therefore, considered in HRS scoring.
Homestake Mining Company stated that the nearest well using
the aquifer of concern is greater than 2000 feet distant and
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protected by the Injection-collection system. It is further main-
tained that the Towns of Grants and Milan do not use the shallow
aquifer of concern and so should not be included in population
served. In addition, because of the injection-collection system,
the Broadview acres wells are not affected. The 4 or 5 wells
exceeding New Mexico Quality Control Commission (NMWQCC) standards
for uranium and selenium serve 20 people.
Again, the company-supplied isoplots clearly show the areas of
contaminated ground water. Approximately 38 private wells are
located in the contaminated portion of the aquifer. Therefore, the
distance to the nearest well drawing or formerly drawing from the
aquifer of concern is 0.
The subdivisions (Broadview Acres, Murray Acres, and Felicia
Acres) are included in the Towns of Grants and Milan. These
subdivisions draw water from the aquifer of concern. The population
used in the scoring, 835 people, is the calculated population of the
affected subdivisions. The promulgated HRS requires counting of all
people using the aquifer of concern within three miles, even if the
wells drawn from are not yet contaminated. The proximity of these
wells to the site creates the possibility that future contamination
may occur.
A number of comments were offered regarding the scoring of the
air route. EPA does not believe that sufficient data exist to
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indicate an air release is occurring, and, therefore, the score for
this pathway has been reduced from 43.59 to 0.
The U.S. Department of the Interior noted that a stream from
the sewage plant runs through two reservations three miles away.
This concern was taken into account in the original scoring of the
site.
Homestake Mining made numerous allegations challenging the
constitutionality and legal adequacy of CERCLA, the HRS, and the
process for including the site on the NPL. No explanation or
documentation for these conclusory allegations was provided by the
commenter, and therefore no response is possible except to note that
EPA believes CERCLA to be constitutional and has followed all
appropriate procedures in developing the HRS and NPL pursuant to
that statute.
The commenter also contended that sites of radioactive mine
and mill tailings should, as a policy matter, be excluded from the
NPL. The Agency's position with respect to such sites is explained
in the preamble to the final NPL.
The original migration score for this facility was 42.29.
Based on the changes noted above, the HRS scores for Homestake are:
Ground Water 59.18
Surface Water 0
Air 0
Total 34.21
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7.12 South Valley, Albuquerque, New Mexico
7.12.1 List of Commenters
NPL-152 William N. Farren III, Esquire, AmeriGas, Inc.
2/18/83.
7.12.2 S""""ary of Comments and Response
The commenter noted that the area of concern was designated
the "South Valley" site during the early stages of the New Mexico
Environmental Improvement Division (NMEID) investigation and that
technical data developed during the NMEID investigation as well as
several thorough studies by environmental consultants, clearly
demonstrate that the South Valley area definition should be
substantially narrowed; that regional and site specific
hydrogeological conditions are such that it is clear that neither
operations nor conditions at certain locations, including the
Amerigas property, could have contributed to the city well problems;
that refinement of the site designation of South Valley is warranted
and, if appropriate, separate consideration of Amerigas property;
and that the National Priorities List be reviewed for site
designations that are in reality only broad geographic areas that
were initially selected on a preliminary basis.
As the commenter noted, additional information concerning
ground water contamination has been generated since the area of
concern was designated based on the NMEID investigation. However,
the investigation is still on-going. At the present time, the data
that have been generated are not sufficient to completely define the
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hydrogeologic conditions existing at the site. For example, there
has been no testing during pumping of major wells, which might
affect the flow of ground water. The Agency believes that until the
flow of water under a wider range of conditions has been determined,
the site should not be redefined.
The designation of the South Valley site does not imply that
Amerigas is responsible for the contamination or that the
contamination originated on the Amerigas site. Further, as stated
in the legislative history of CERCLA [Report of the Committee on
Environment and Public Words, Senate Report No. 96-848, 96th Cong.,
2d. Sess. 60 (1980)]:
The priority lists serve primarily informational pur-
poses, identifying for the states and the public those
facilities and sites or other releases which appear to
warrant remedial actions. Inclusion of a facility or
site on the list does not in itself reflect a judgment
of the activities of its owner or operator, it does not
require those persons to undertake any action, nor does
it assign liability to any person.
Refinement of the site designation has not been shown to be
warranted in light of the informational purpose which priority lists
serve, as noted above. The HRS, as established by EPA, considers as
a single site the areas where hazardous substances or contaminants
have been deposited as well as any contaminated areas that can be
reasonably related to the deposited substances. The accuracy of
site boundaries has been established and reeaxmined in successive
scoring and review efforts from proposal to review of comments and
final listing.
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A draft report, "Organic Ground Water Pollutants in the South
Valley of Albuquerque, New Mexico" by the New Mexico Health and
Environment Department (December 1982) completed after the initial
scoring indicated that 1,1,2,2-tetrachloroethane was found in a soil
boring (#SV-10) taken on May 18, 1982. This contaminant rates a 3
for toxicity and a 3 for persistence, resulting in a. matrix value of
18. The original scoring was based on the toxicity and persistence
of bis-ethylhexyl phthalate with a matrix value of 15.
The original migration score for this facility was 35.57.
Based on the changes noted above, the HRS scores for South Valley
are:
Ground Water 73.08
Surface Water 0
Air 0
Total 42.24
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7.13 United Nuclear Corporation, Church Rock, New Mexico
7.1.3.1 List of Commenters
NPL-188 Carpenter, Grout and Olmstead, Attorneys for United
Nuclear Corporation. 2/25/83.
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
7.13.2 Summary of Comments and Response
A. D. Little, Inc. commented that the use of surface water for
livestock watering had been scored by EPA as drinking water with a
value of 3, but it seemed more appropriate to have been categorized
as food production with a value of 2. The commenter is incorrect.
The surface water use was correctly assigned a value of 2 in the
original scoring.
All of the following comments were made on behalf of United
Nuclear Corporation. United Nuclear Corporation stated that ground
water use has been scored a 3, implying that no alternative
unthreatened water source is available. According to the commenter,
an equivalent alternative exists through the use of other local
wells, given that it is common practice in the area for individuals
to cart water from the nearest well should their own well become dry
or be rendered useless (i.e., due to contamination).
In response, use of such other wells cannot represent an
alternative unthreatened source as implied by the value of 2. One
reason for this is that the necessity to haul the water or construct
another means of conveyance does not meet the HRS requirement that
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an alternative source be available with "minimal hookup require-
ments." The other is that other wells drawing from the same source
as a contaminated well cannot be considered "unthreatened."
The commenter questioned the location and number of wells used
to develop the ground water targets score.
Based upon information supplied by USGS, EPA personnel
concluded that the Rio Puerco is not a hydraulic barrier. A further
check into the proximity to the site of the wells questioned
indicates that four of the wells are within a 3 mile radius of the
site and so should be counted. These are small community wells and
are conservatively estimated to serve three families each. Assuming
3.8 people per family, a subtotal of 46 results. Adding this amount
to those served from wells not in contention results in a total
population of 114. The distance to the nearest well, 15T303, is 1.5
miles. The matrix value for these two values is 12. No score
change was required.
The commenter noted that observed release to surface water was
scored based on a 1979 dam spill that was cleaned up to the
satisfaction of regulatory agencies; studies have shown no health
impact from the spill.
The HRS states that observed release should be scored if "...
direct evidence of release has been obtained (regardless of
frequency) ..." Such a release is an indication of the probability
of exposure to hazardous substances. As explained in the preamble
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to the final NPL, sites are scored on the basis of the original
conditions at the site, and cleanup actions are not taken into
account for purposes of listing. If cleanup actions have reduced
the hazard presented by a site, this will be determined by further
investigation after listing and will be taken into account in
determining what response, if any, is appropriate, and the priority
for any actual response.
The commenter contended that data indicating release of
natural uranium to the air were erroneously used to score observed
release in the air route. The commenter addressed a single high
value of lead-210.
These were not the data used to evaluate the air route. The
data used indicated higher uranium levels after commencement of
milling operations than before the mill was built. The earlier data
taken three miles from the site were used as an indication of
background levels of natural uranium.
The original migration score for this facility was 30.36.
Based on the above response to comments, the score remains
unchanged. The HRS scores for United Nuclear Corporation are:
Ground Water 42.86
Surface Water 10.91
Air 28.33
Total 30.36
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7ซ14 Tar Creek, Ottawa County, Oklahoma
7.14.1 List of Commenters
NPL-219 McKenna, Conner and Cuneo on behalf of Eagle-Picher
Industries, Inc. 2/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
7.14.2 Summary of Comments and Response
Eagle-Picher provided extensive comments which are grouped by
subject to facilitate the clarity of response. Responses follow
each set of grouped comments.
Eagle-Picher noted that Congress did not intend for the
Federal government to become involved under CERCLA in this or other
mining related sites; and that it is beyond EPA's legal authority
under CERCLA to list the Tar Creek, Oklahoma site or any similar
mining related sites on the priority list.
EPA has determined that the authority to respond to releases
of mining wastes does exist in CERCLA, and therefore such sites will
be included on the NPL. The rationale for this decision is
presented in Part VI of the preamble to this rule.
Eagle-Picher argued that the Tar Creek, Oklahoma site is not,
as a matter of scientific and technical fact, a "priority site" for
response or remedial action under CERCLA. In response, inclusion in
the NPL is based on the objective use of the Hazard Ranking System.
Eagle-Picher believes that the HRS model used by EPA to
generate the proposed priority list contains far too many overly
7-33
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conservative assumptions and opportunities for the exercise of
primarily subjective judgements to represent a valid tool for the
analysis required to formulate a meaningful priority list.
The HRS was proposed for public comments in the Federal
Register in the spring of 1982 and promulgated on July 16, 1982 as
part of the National Contingency Plan (40 CFR 300). Response to
comments appear in the preamble to the National Contingency Plan (47
FR 31188). As stated in the preamble, the HRS is a suitable
procedure to provide a detailed evaluation of particular threats
presented by the release and to determine placement on the NPL.
Eagle-Picher argued that mine wastes in the Tri-state mine
field area present no threat to human health and that the Tar Creek
site is not the type of "top priority among known response targets"
which Congress intended to include on the NPL; that the flow from
Tar Creek has no measurable effect on the chemical water quality of
either the Neosho River or Grand Lake; and that the discharge of
mine water to Tar Creek has had no significant adverse impact on the
Neosho River-Grand Lake water system.
In response, as stated in the National Contingency Plan (47 FR
31186-31187), the role and importance of the HRS and NPL must be
kept in perspective. The NPL, which will include at least 400
releases, is merely the first step in considering a release for
Fund-financed remedial response, and, therefore, can only be based
on estimates of the potential of harm from the sites. If a release
7-34
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is included on the NPL but a later remedial investigation discloses
the hazard to be less significant than originally thought, a
decision may be made not to provide Fund-financed remedial response.
Eagle-Picher stated that the available data do not document an
observed release to ground water from the site; that neither Hittman
Associates nor the Task Force (of the Oklahoma Water Resources
Board) have collected data on water in the Boone formation outside
the abandoned mines. Thus, there is neither direct analytical
evidence nor qualitative evidence of a release of mine water from
the mines to the Boone formation. Eagle-Picher noted that by
claiming an observed release to the Boone formation EPA seems to be
saying that the material being released (acid mine water) and the
ground water into which it is supposedly being released (acid mine
water in the abandoned mines) are the same thing. No data have been
adduced which demonstrate that acid mine water in the abandoned
mines has been released into the ground water. Consequently, it is
improper to score the ground water route for the site on the basis
of an "observed release."
In response, the hydrological descriptions of the area
provided in the Hittman Report and by the Task Force adequately
explain the origin of the mine water as being the waters in the
Boone aquifer. As such, a direct hydrological connection exists
between the mine water and the Boone aquifer. Based on this
information, the Agency belives that the mine water constitutes
7-35
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ground water. The documented contamination of the mine water,
therefore, constitutes a release to ground water, and scoring on the
basis of an observed release is proper.
Eagle-Picher claimed that review of the Documentation Record
for the ground water route reveals that EPA does not claim there has
been an observed release to the Roubidoux aquifer. Rather, the
Documentation Record states that there has been contamination of the
Boone aquifer. If there is no observed release to the Roubidoux
aquifer EPA's instructions for the HRS require that the "route
characteristics" and "containment" rating factors be scored for the
ground water route.
In response, an observed release to the Boone aquifer has been
documented in the Hlttman Report. The report also documents the
existence of bore holes which are a. direct connection between the
Boone and Roubidoux aquifers. Since a direct connection between the
aquifers exists, scoring a direct release to the Roubidoux aquifer
rather than scoring "route characteristics" and "containment", is
proper.
Eagle-Picher contended that the Roubidoux formation is an
enclosed aquifer separated from other water bearing formations by
highly impervious geological formations in which fissures and cracks
tend to be sealed by secondary cementation; that no empirical data
are presented in the Hittman Report to demonstrate that mine water
is migrating to the Roubidoux formation through "boreholes," thus
7-36
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the assertion that mine water can migrate to the Roubidoux formation
through boreholes is simply speculation and not based on any
scientific or technical data; that cracks and fissures in the
geological formation separating the Boone and Roubidoux formations,
whether naturally occurring or man-made, are "healed" by secondary
cementation; that similar chemical reactions would prevent
significant migration of any water which might reach the Roubidoux
formation through such cracks and fissures prior to sealing by
secondary deposition; and that the abandoned wells and boreholes are
not a likely mechanism for the introduction of any significant
amount of mine water into the Roubidoux formation.
In response, the information contained in the HRS
Documentation Records indicates that although soil permeability
between the Boone and Roubidoux aquifers ranges from 10 to
10 cm/sec, numerous boreholes interconnect the interlying
formations, including the Boone and Roubidoux formations. While the
Hittman report does not present empirical data demonstrating the
migration of water to the Roubidoux formation through the boreholes,
that scenario developed in the Hittman report was based on accurate
data and sound technical judgement. Reasonable inferences based on
data are necessary and appropriate for purposes of listing sites to
determine where future response action is necessary. The commenter
provided no data indicating the extent to which the abandoned wells
and bore holes have been "healed" by secondary cementation. A
7-37
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necessary step in supporting the lack of direct connection between
the aquifers would be to provide data which showed the complete
"healing" of the bore holes. This has not been done by the
commenter. Until that can be done, the abandoned wells and
boreholes remain likely mechanisms for migration of waters between
the aquifers.
Eagle-Picher contended that since actual data have now been
collected, the Hittman Report must be regarded as theoretical and
out of date and that the draft Task Force Summary, a source of data
for the HRS Documentation Record, is out of date since the Oklahoma
Water Resources Board has published a final version of the report.
In response, the Hittman Report is not theoretical. It
contains and uses actual sampling data taken at the site. Nor is it
out of date. It was published in 1981. The final version of the
Oklahoma Water Resources Board's report is consistent with the
previously published studies and confirms the score for this site.
Eagle-Picher questions the maximum score for all items under
rating category 4, "waste characteristics," and rating category 5,
"targets," for the ground water route and surface water route.
The Agency believes that the responses given in the HRS
scoring were valid and consistent with HRS instructions.
Information supporting these scores is provided in the HRS
Documentation Record.
7-38
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Eagle-Picher believes a score of 2 for the "surface water use"
item under the "targets" rating factor represents an overestimate of
the case. Mine water entering Tar Creek has absolutely no impact on
any protected uses, including recreation.
In response, this factor does not attempt to determine any
impact of a release of contaminants to surface waters. It only
assesses the use of the surface water downstream. This use is
appropriately represented by the assigned value of 2 for
recreational use.
Eagle-Picher noted that no investigation has been undertaken
to identify all the potential sources of the periodic elevation of
particular chemical parameters in Tar Creek.
The commenter noted that the site must be rescored using
up-to-date data. As pointed out by the commenter, EPA relies on
data as recent as 1982. A review of additional data presented by
the commenter has not produced any data that refute the data or
assumptions relied upon by EPA and discussed above. As discussed in
Part VIII of the preamble to the final NPL, EPA believes that once a
site has been proposed, commented upon, and a final score
calculated, re-scoring of the site is neither necessary or
appropriate. Any new data will be considered in determining the
appropriate response, if any, for listed sites.
The U.S. Department of the Interior noted that lead, zinc,
cadmium, asbestos, and other toxic metals contaminate the water and
soil; that potential carcinogens affect local population.
7-39
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In response, the site was scored using cadmium, which results ^^
in the highest score of 18 for toxicity/persistence. Population
affected is evaluated in the HRS targets categories.
Review of this facility revealed rounding errors in the score
calculation.
The original migration score for this facility was 58.20.
Based on the changes noted above, the HRS scores for Tar Creek are:
Ground Water 100.00
Surface Water 10.91
Air 0
Total 58.15
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7.15 Harris (Farley Street), Houston, Texas
7.15.1 List of Commenters
NPL-54 J. B. Smith, Attorney, Dow Chemical.
NPL-67 7th Period Texas History Class at Wilkinson Middle
School, Mesquite, TX. 1/5/83.
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
7.15.2 Summary of Comments and Response
The Seventh period Texas history class of Wilkinson Middle
School, Mesquite, Texas, support the cleanup of hazardous waste
disposal sites.
Dow Chemical contended that there is no evidence of an
observed release to ground water because no measurements were taken
and because the listed contaminants could come from other sources.
In response, on June 17, 1982, personnel of the Texas
Department of Water Resources (DWR) sampled 4 monitoring wells at
the Harris site. GC/MS analysis found peaks associated with
ethylbenzene, styrene, 1-methyl styrene, propenyl benzene, indene,
naphthalene, benzo(b)thiophene, 1,1-biphenyl, etc. in Well #1 at the
site. While not giving numerical results, these qualitative results
demonstrate that a release of these substances to ground water has
occurred, which is sufficient to assign the value for an observed
release.
Dow Chemical suggested that the toxicity/persistence value is
inaccurate since neither phenol nor indene, which were used to score
7-41
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this factor, were detected in any sampling. In. response, phenol was
detected in a core sample of well FS-3 installed by FIT on
May 12, 1982. This was reported in a handout at the Enforcement
Meeting held at EPA Region VI on November 8, 1982.
The hazardous waste quantity was thought by Dow Chemical to be
overstated. Disposer files do not indicate that all the wastes
collected were taken to the Harris site. In addition, the common
practice for disposing of the wastes was open burning in pits. This
would significantly reduce the amount of wastes at the site.
EPA believes that the disposer used the Farley Street site
exclusively from April 10 to May 31, 1958. Shipping records show
that the amount listed, 550 tons, was collected during that early
period. It was deduced that this quantity was taken to Farley St.
The period of dumping was based on interviews with the disposer's
wife and former employees, and on the lease for the site. The
promulgated HRS requires that quantity be scored "as received."
This is so regardless of whether it is burned on site because of the
possibility that migration from the received quantity may begin
before burning or other disposition takes place. The reasoning for
this position is similar to why the HRS score is based on original
conditions at a site rather than after cleanup, as explained in the
preamble to the final NPL.
The commenter also stated that alternative unthreatened water
supplies are available. According to the commenter, the nearest
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water main is at the intersection, of Genoa-Red Bluff Road and S.
Burke Road. This is a city of Pasadena water main. The site, in
the City of Houston, is approximately 1/2 mile to the south. The
Agency does not believe that this situation constitutes "mininal
hook-up" as required for a value of 2 under ground water use. The
same situation exists for the Ellington Air Force Base tying into
the city of Houston's water main.
The commenter also contended that the Pasadena Westside Well
#2 is located outside the 3-mile radius considered in the HRS and
that the Ellington Air Force Base wells may not be in the same
aquifer.
By using a map developed by the state of Texas, the Agency
determined that the Pasadena Westside Well #2 is located within the
3 mile radius. Potable wells in the area draw from the same
formation, the Gulf Coast Aquifer, and, therefore, the Ellington Air
Force Base wells should also be included. The value for distance to
nearest well/population served remains 35.
The commenter also stated that documentation for data
indicating 277 people using ground water within 3 miles of site is
not given. This includes "40 plotted wells" and the "Genoa Trailer
Park."
The data were derived from two sources. First, an EPA
memorandum dated December 6, 1982 concerning drinking water wells in
the Genoa-Red Bluff Road area and second, a tracing of a State of
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Texas map showing the wells located within the 3 mile radius.
A. D. Little, Inc. noted that data were collected for the
surface water and air routes but the scores were not calculated.
In response, EPA's first HRS evaluation of August 16, 1982
included surface water and air routes. However, follow-up
evaluation of the site by EPA personnel revealed insufficient
information to evaluate the surface water and air pathways. A new
HRS score was developed on December 2, 1982 and this latter score
was used for ranking the Harris site for the proposed NPL.
The original migration score for this facility was 33.94.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Harris (Farley Street) are:
Ground Water 58.71
Surface Water 0
Air 0
Total 33.94
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8.0 REGION VII
8.1 Aidex Corporation, Council Bluffs, Iowa (07IA001)
8.1.1 List of Commenters
NPL-301 Stu Nicholson, KETV-CH7, Omaha to Katie Biggs, Region
VII (telecom). 12/20/82.
8.1.2 5<"iary of Comments and Response
The commenter expressed concern regarding the dangers of the
site and provided certain preliminary information.
The Agency will examine the information provided by the
commenter and determine if any appropriate remedial action is needed.
The original migration score for this facility was 31.63. No
new technical information was submitted and no change in score was
required. The HRS scores for Aidex Corporation are:
Ground Water 54.63
Surface Water 3.02
Air 0
Total 31.63
8-1
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8.2 Pico, Des Moines, Iowa
Renamed: Des Moines ICE, Des Moines, Iowa
8.2.1 List of Commenters
NPL-150 Lawrence K. Sandness, Secretary and General Counsel,
Dyneer Corporation. 2/18/83.
NPL-162 H.E. McCarville, Secretary, Dyneer Corporation.
2/23/83.
NPL-297 Mike Valdi, Merridith Corporation; to Alice Fuerst,
Region VII (telecom). 12/21/82.
NPL-298 Lawrence K. Sandness, Secretary and General Counsel,
Dyneer Corporation. 2/18/83.
8.2.2 Summary of Comments and Response
The Agency has renamed this site as Des Moines TCE because
although the Dico Company is believed to have contributed to the
ground water contamination, no formal identification of responsible
parties has been made, and other possible sources are being
investigated.
Mr. Sandness of Dyneer Corporation commented that the City of
Des Moines has installed a new water supply system in addition to
the two existing systems to supplement the need of Des Moines for
additional drinking water. Since this system was built as an
additional and also to serve as an alternate water supply, the
commenter stated that this new system and the other existing system
that draws from the Racoon River constitute alternate sources for
drinking water not threatened by the ground water contaminant.
Therefore, the commenter stated that the ground water use factor in
8-2
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the Hazard Ranking System (HRS) should be given a value of 2 rather
than 3 presumably on the basis that the sources constitute an
"alternate unthreatened sources presently available" as described in
Section 3.5 of the HRS (47 FR 31230).
In response, the Agency has concluded that while an attempt has
been made to cut off the supply of contaminated water, a complete
cutoff has not been achieved, probably due to the age and the unique
nature of the contaminated water system. The threatened system, a
gallery system, receives its raw water from an underground pipe with
perforation to allow water infiltration from the Raccoon River, and
it is difficult if not impossible to cut off the water
infiltration. Des Moines relies heavily on the water drawn from the
gallery system, and it would create a significant financial burden
for the city if it is forced to shut off completely the entire
gallery and rely on the alternate source. The financial burden is
predicted because the gallery receives high quality water through
the filtering effect of alluvium, but the new system is a direct
river intake on the Des Moines River requiring additional water
treatment. The HRS specifies that to be considered an alternate
unthreatened source for purposes of assigning a score of 2 rather
than 3 the score must be "presently available" with "minimal hook up
requirements." (HRS Section 3.5, 47 FR 31230-1, July 16, 1982).
Therefore, because of the significant financial burden associated
with the use, the new water system cannot be considered an alternate
unthreatened source for purposes of HRS scoring.
8-3
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The agency has changed the toxicity/persistence value under
both the ground water and surface water routes from 12 based on
trichloroethylene to 18 based on mercury. This was due to the
detection of mercury in the ground water during the recent field
investigation. Mercury has a toxicity value of 3 and a persistence
value of 3. In addition, it was found that the surface water use
value should have been 2 instead of 1 since it has recreational use.
The original migration score for this facility was 28.91.
Based on the changes noted above, the HRS scores for Des Moines TCE
are:
Ground Water 73.08
Surface Water 3.19
Air 0
Total 42.28
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8.3 Arkansas City Dump, Arkansas City, Kansas (07KS001)
8.3.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
8.3.2 Summary of Comments and Response
The commenter expressed concern over potential food chain
impacts to the bald eagle and Arkansas darter, a state threatened
species.
The Agency reviewed the file material on this facility, and did
not reveal the presence of any bald eagles or other Federal
endangered species within the distance criteria specified in the
HRS. State endangered or threatened species are not considered in
developing HRS scores.
The Agency review, however, did reveal an error in the
toxicity/persistence factor. The correct value for benzo(a)pyrene
is 18 rather than 12, and the scoring has been revised accordingly.
The original migration score for this facility was 4.23. Based
on the above response to comment, the HRS scores for Arkansas City
Dump are:
Ground Water 6.12
Surface Water 7.27
Air 0
Total 5.49
8-5
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8.4 Doepke Disposal, Johnson County, Kansas
8.4.1 List of Commenters
NPL-299 Terry Diehl, citizen, to Katie Biggs, EPA Region VII
(telecom). 12/23/82.
NPL-300 Johnson County Water District to Katie Biggs, Robert
Morley and David Wagoner, EPA Region VII (telecom).
12/21/82.
8.4.2 Summary of Comments and Response
Ms. Diehl expressed concern about the Johnson County Water
District water supply. No change in score was required.
Johnson County Water District (JOCO) representatives expressed
concern regarding a newspaper article in which it was suggested that
dioxin may be present at this facility.
Review of this facility by the Agency reveals no Information to
support this suggestion. No change in score was required.
JOCO also suggested that surface water flow patterns might be
affected by on-going construction activities and ice. However,
insufficient information is provided to fully explain the intent of
the comment. A review of the facility by the Agency suggests that
the construction activities would cause no change in HRS scoring.
The original migration score for this facility was 47.46. No
new technical information was submitted and no change in score was
required. The final HRS scores for Doepke Disposal are:
Ground Water 18.50
Surface Water 80.00
Air 0
Total 47.46
8-6
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8.5 Tar Creek, Cherokee County, Kansas
Renamed: Cherokee County, Cherokee County, Kansas
8.5.1 List of Commenters
NPL-220 McKenna, Conner & Cuneo on behalf of Eagle-Picher
Industries, Inc. 2/28/83.
NPL-302 Richard Fyle, attorney, to Alice Fuerst, Region VII
(telecom). 1/10/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
NPL-L28 McKenna, Conner & Cuneo. 5/18/83.
8.5.2 Summary of Comments and Response
The Agency has renamed this site as Cherokee County, Kansas in
order to eliminate the confusion that presently exists because two
sites with the same name are on the proposed NPL.
Mr. Fyle had no site specific comment, only requested informa-
tion. The following discussion pertains to the Eagle-Picher
Industries, Inc. comment s.
The commenter stated that the Cherokee County, Kansas, site
should not be included as a priority site presumably on the basis
that:
(1) the background data on ground water and surface water
pertains to the Tar Creek, Oklahoma site rather than the Kansas
site, but were allegedly used to rank the Kansas site according to
the HRS.
8-7
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(2) The background data on air route allegedly pertain to an
area some 12 to 15 miles away from the site and were collected in
1971, and, therefore, are irrelevant and outdated.
(3) No scientific studies of the Kansas site have been
conducted and no technical data have been collected to support the
inclusion of the site on the NPL.
(4) The language and intent of CERCLA prohibits its
application to mining sites in general and the Cherokee County,
Kansas site in particular.
The Agency, upon reexamining the existing information in the
file, agrees with the commenter that additional data needed to be
collected to more accurately define the character and extent of the
contamination problem in Cherokee County, Kansas, and that the
original HRS score of 66.74 should be revised.
EPA has, therefore, obtained new data specifically reflecting
the conditions at the Cherokee County, Kansas site. Consideration
of these new data did not result in any change of rating factor
values or scores for the ground water or surface water pathways.
The air route was changed to zero because it was determined that the
air data previously used was collected while a smelter was
operating. The emissions from the smelter probably increased the
concentration of particulate matter in the air and, thus, invali-
dated the accuracy of the sampling.
8-8
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EPA has determined that the authority to respond to releases of
mining wastes does exist in CERCLA, and therefore such sites will be
included on the NPL. The rationale for this decision is presented
in Part VI of the preamble to this rule.
The U.S. Department of the Interior expressed concern over
potential impact on the Bald Eagle, Neosho Madtom, Peregrine Falcon,
Gray Bat, as well as state threatened and endangered species that
occur in the Neosho River Based on which Tar Creek is a tributary.
In response, insufficient information was provided to determine
whether a critical habitat for these species is located within the
distance limitations specified in the HRS. Therefore, no HRS score
revision can be made at this time.
The original migration score for this facility was 66.74.
Based on the changes noted above, the HRS scores for Cherokee County
are:
Ground Water 100.00
Surface Water 10.91
Air 0
Total 58.15
8-9
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8.6 Times Beach, Times Beach, Missouri
8.6.1 List of Commenters
NPL-TB1 Dorothy Mendenhall. 3/3/83.
NPL-TB2 7th Grade Civics Class, Smithton, MO. 3/21/83.
NPL-TB3 James J. Higgins. 3/21/83.
NPL-TB4 Nina Snowden. 3/21/83.
NPL-TB5 Maria McReynolds. 3/21/83.
NPL-TB6 S. Sgt. James P. Sowders. 3/21/83.
NPL-TB7 Michelle Biermann. 3/21/83.
NPL-TB8 Zandra Grubbs. 3/21/83.
NPL-TB9 John and Susan Weber. 3/21/83.
NPL-TB10 Jean B. Olson. 3/21/83.
NPL-TB11 Mrs. William Kohl. 3/21/83.
NPL-TB12 Mrs. Virgie Hance. 3/21/83.
8.6.2 Snmniary of Comments and Response
None of the above commenters made reference to the listing of
Times Beach on the NPL or the application of the HRS to this
facility.
Comments were split between those requesting Federal assistance
and/or in support of the Federal purchase of Times Beach and those
opposed to this action.
The original migration score for this facility was 40.08. No
new technical information was submitted and no change in score was
required. The HRS scores for Times Beach are:
Ground Water 68.84
Surface Water 8,36
Air 0
Total 40.08
8-10
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8.7 Phillips Chemical, Beatrice, Nebraska
8.7.1 List of Commenters
NPL-4 B. F. Ballard, Director, Environmental Control
Branch, Phillips Petroleum Company. 12/21/82.
NPL-21 Phillips Chemical Co., Phillips Petroleum Company and
EPA Region VII meeting notes. 1/5/83.
NPL-149 J. J. Moon, Manager, Division Environmental and
Consumer Protection, Phillips Petroleum Company.
2/18/83.
NPL-237 David A. Wagoner, EPA Region VII, copy of file
correspondence. 1/7/83.
NPL-296 James W. Bauer, General Manager, Beatrice Board of
Public Works. 1/25/83.
8.7.2 Summary of Comments and Response
Mr. Bauer requested that the Beatrice Board of Public Works be
involved in any discussions relative to this site. No technical
information was submitted and no changes in HRS score result. The
following comments were from Phillips Petroleum Company.
Phillips Petroleum Company indicated that ground water
monitoring at the demineralization pond should not be used in
evaluating inactive disposal facilities (closed landfills) because
the wastes disposed at the landfills are entirely different than the
disposed wastes at the pond. In addition, the landfills are several
hundred feet from the pond and may not be upgradient from the pond.
In response, monitoring data from the demineralization pond
were not used in evaluating this site. The ground water route is
scored for potential for migration rather than for observed release.
8-11
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The commenter felt that the HRS score was an error due to the
site's remote location (i.e. distance from nearby rural homes,
industry, or public water supply).
The Agency agrees that the location of site is important in
determining the HRS score and that certain factors in the HRS take
this concern into account, i.e., distance to nearest well, distance
to water intake, and population served. However, EPA disagrees that
the site is remote from homes and public water supplies. In fact,
further analysis of those factors has led EPA to increase the score
for the ground water route. The information EPA used in this
scoring is discussed later in this section.
The commenter suggested that the permeability of the unsatu-
rated zone factor should be assigned a value of 1 rather than 2
based on the boring and laboratory log of soil samples submitted by
the commenter.
Soil logs listed in Phillips' response to EPA's letter #3007
dated October 31, 1980, indicate that gravel, coarse sand, and fine
sand are located at a depth of 8 to 22 feet in Test Well No. 6403.
This well is located closer to the disposal pits than Core Boring 7,
which shows clayey sand at a depth of 8 to 13 feet. These two
borings, located nearby, indicate that the underlying soils differ
in character. The value for gravel and coarse/fine sand is 3; the
value for clayey silt is 1; as indicated in the HRS. Use of a value
8-12
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of 2 reflects an average of the variability of the permeability
conditions at the site.
The commenter also suggested that ground water containment
should be assigned a value of 1 rather than 3 presumably on the
basis that soils are typically of low permeability at the site.
Furthermore, the method of disposal was not likely to disturb the
clays, and run-on and run-off controls preclude ponding.
In this route, containment refers to means used to prevent
contaminants from entering ground water. From the information given
in the test wells and core borings listed in the preceeding comment,
the soil in which the wastes were disposed does not constitute an
impermeable liner which is required for a containment value of 1.
However, the Agency recognizes the landfills preclude ponding, as
evidenced by surface run-on and run-off control, and the value of 2
for containment was assigned instead of 3.
The commenter contended that the toxicity/persistence score for
this site, 18 was in error because the Agency based it on the
chemical monoethylamine (MEA) which was not present at the site.
Instead, the commenter contended that the disposal substance was
monoethanolamine, which has a moderate toxicity rating according to
Sax. On this basis, they contended that the toxicity/persistence
value should be 15 or less.
In response, the 1,1,1-trichloroethane listed as disposed at
the site is being used rather than monoethanolamine to rate toxicity
8-13
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and persistence. The toxicity/persistence value for this compound
is 2 for toxicity and 2 for persistence. The matrix value is 12.
The commenter offered data to show that hazardous waste
quantity should be assigned a value of 3, rather than 7, for ground
water and surface water, based on the fact that only 113.5 tons of
wastes are hazardous out of the total of 1293 tons.
EPA agrees that Phillips records demonstrate that only 113.5
tons of the total wastes disposed are hazardous. The resulting
total of 113.5 tons receives a value of 3 for hazardous waste
quantity. The HRS scores have been adjusted accordingly.
The commenter stated that surface water containment should be
assigned a value of 0, rather than 1 because the landfills on site
preclude runoff and have diversion control that prevent the run-on
of stormwater.
Information in the site file indicates that some wastes were
spread directly on the ground without cover although there is a
diversion system. The containment value of 1 was appropriate.
The commenter stated that surface water may be contaminated by
other parties.
In response, the Agency scored this pathway based on potential
for migration to surface water rather than for observed release.
Therefore, other possible sources of contamination would not affect
HRS scores.
8-14
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In addition to the suggested revisions proposed by the
commenter, the Agency found that there are residences and buildings
near the site which may have private wells (based on their apparent
lack of city water service) which could not readily be supplied with
an alternate water supply. It appears city water lines would have
to be extended a mile or more. The ground water use assigned value
was changed from 2 to 3.
The Agency also received information from the Nebraska State
Health Department and from the City of Beatrice which confirms that
the City of Beatrice receives its drinking water supply from a
series of alluvial wells. Because of the need to develop a
nationally uniform scoring system that could be used to score a
large number of sites with the data commonly available, the HRS does
not specifically take into account such level of detail as flow
gradients when determining the target population. This position is
explained more fully in the preamble to the final National
Contingency Plan at 47 FR 31190. The recent information indicates
the nearest of these wells is 4000 feet (upriver) from the Phillips
site. These wells are located in the floodplain alluvial deposits
of the Big Blue River upriver and upgradient of both the city of
Beatrice and of the Phillips site. Based upon this information the
city wells are ranked as targets under the ground water route. The
municipal wells serve an estimated population of 13,000 which
8-15
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results in the maximum score of 40 for ground water targets; this is
up from 36 on the initial ranking.
The original migration score for this facility was 29.97.
Based on the changes noted above, the HRS scores for Phillips
Chemical are:
Ground Water 28.2i
Surface Water 1.26
Air 0
Total 16.32
8-16
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9.0 COMMENTS ON REGION VIII SITES
9.1 California Gulch, Leadville, Colorado
9.1.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83
9.1.2 Summary of Comments and Response
The U.S. Department of the Interior noted that this site
appears to affect water resources at a reclamation facility. This
information was evaluated in developing the original HRS site score.
Subsequent to scoring this site for the proposed NPL, EPA
received monitoring data from a domestic well that shows cadmium and
zinc contamination. These data confirm an observed release in the
ground water route which substantiates the maximum score 45 where
the previous score based on route characteristics was 36.
The original migration score for this facility was 51.94.
Based on the change noted above, the HRS scores for California Gulch
are:
Ground Water 59.18
Surface Water 76.36
Air 0
Total 55.84
9-1
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9.2 Denver Radium, Denver, Colorado
9.2.1 List of Commenters
NPL-182 Louis R. Perriere, Administrator, Denver Community
Development Agency. 2/24/83.
9.2.2 Summary of Comment and Response
The commenter supported the inclusion of Denver Radium on the
NPL.
Review of this facility revealed rounding errors in the score
calculation. The necessary corrections have been made.
The original migration score for this facility was 44.00.
Based on the change noted above, the HRS scores for Denver Radium
are:
Ground Water 26.12
Surface Water 40.97
Air 58.85
Total 44.11
9-2
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9.3 Sand Creek, Commerce City, Colorado
9.3.1 List of Commenters
NPL-169 K. S. Valis, President, Colorado Paint Co. 2/22/83.
9.3.2 Summary of Comment and Response
The Colorado Paint Company contended that its landfill acreage
should not be considered as part of the Sand Creek site because the
landfill is shallow, was closed in 1973, and no hazardous materials
have been detected in landfill soil samples. The acreage owned by the
Colorado Paint Company has been included as part of the Sand Creek
site based upon two sources of information. First, EPA Form 8900-1,
"Notification of Hazardous Waste Site Form," submitted by a
transporter who delivered waste to the landfill, indicates that
hazardous wastes were dumped at the site. Secondly, hazardous
substances have been detected in a ground water sample taken
immediately adjacent to and downgradient from the landfill property.
This ground water contamination is attributable to the landfill.
Additional comments addressed the presence of methane and methane
evaluation and control systems at the landfill. Methane has not been
designated as a hazardous substance under CERCLA and its presence was
not considered in scoring this facility.
The ground water route score for Sand Creek has been raised based
on a review of the distance to nearest well/population served rating
factor. Wells tapping the aquifer of concern are located onsite
rather than 2 to 3 miles distant as originally reported, thereby
9-3
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raising the value of this factor from 20 to 40.
The original migration score for this facility was 37.00. Based
on the change noted above, the HRS scores for Sand Creek are:
Ground Water 100.00
Surface Water 25.45
Air 0
Total 59.65
9-4
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9.4 Woodbury Chemical, Commerce City, Colorado (08C0014)
9.4.1 List of Commenters
NPL-182 Louis R. Perriere, Administrator, Denver Community
Development Agency. 2/24/83.
9.4.2 Summary of Comment and Response
The commenter supported the inclusion of Woodbury Chemical on
the NPL.
The commenter noted that construction of an industrial park
across the street from this facility could increase the target
population by 300 people. Only existing populations are considered
in determining the size of the potentially exposed population.
Therefore, the information presented in this correspondence did not
necessitate a change in the HRS score for this site.
Review of the score for this facility revealed rounding errors
in the calculation of scores. Scores have been adjusted accordingly.
The original migration score for this facility was 45.00.
Based on the change noted above, the HRS scores for Woodbury
Chemical are:
Ground Water 73.33
Surface Water 25.45
Air 0
Total 44.87
9-5
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9.5 Anaconda Minerals Company, Anaconda, Montana
9.5.1 List of Commenters
NPL-225 Paul M. Kaplow, Manager, Environmental and Regulatory
Affairs, Atlantic Richfield Company. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
9.5.2 Summary of Comments and Responses
Atlantic Richfield Company noted that, while metals have been
detected in ground water above background levels, they have not been
detected above the levels set for Primary Drinking Water Standards.
It was suggested that too much weight is given to the observed
release of heavy metals without regard to concentration or to
whether concentrations exceed Primary Drinking Water Standards.
ARCO claimed that offsite impacts on water and air quality are
negligible even though the site scores high on the NPL.
In response the HRS assigns a value for an observed release
because it is an indication that substances can migrate from the
site and that more may do so in the future, not because the release
observed is itself a health threat. Therefore, as stated in
Section 3.1 of the HRS, 47 FR 31224, an observed release is scored
whenever the substances are detected in concentrations higher than
background levels. Available data demonstrate that releases have
occurred in all three migration pathways and this was reflected in
the original scoring of the facility.
The commenter asserted that non-hazardous surface water
discharges from the site are regulated under Montana's NPDES permit
-------
system. The Agency has not considered these discharges in scoring
the Anaconda facility. Only uncontrolled discharge points have been
considered.
The commenter indicated that surface particulates are subject
to state air quality control and that they have been or are being
eliminated. As explained in Part VII of the preamble to the final
NPL, EPA computes HRS scores and lists sites on the basis of
conditions existing before any response actions are taken in order
to represent the full scope of the original problem presented by a
site. If EPA determines that a site is cleaned up so that no
further response is necessary, EPA will delete the site from the
list, as discussed in Part VIII of the preamble to the final NPL.
EPA has not yet made such a determination with respect to the
Anaconda Minerals site, but will continue to examine conditions at
the site to determine whether deletion is appropriate. For sites
that remain on the list, any cleanup activities conducted pursuant
to formal agreements with EPA are acknowledged on the final NPL by
notation in the "Voluntary or Negotiated Response" category.
The U.S. Department of the Interior noted concern that
migratory birds may ingest heavy metal from this site. There is no
documented mortality. This concern is reflected in the scoring of
the site.
9-7
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The original migration score for this facility was 58.71.
Based on the response to comments above, the score remains
unchanged. The HRS scores for Anaconda Minerals Company, Anaconda
are:
Ground Water 83.67
Surface Water 40.00
Air 41.41
Total 58.71
9-8
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9.6 Milltown, Milltown, Montana (08MT004)
9.6.1 List of Commenters
NPL-11 J. Howard Toole, Missoula County Democratic Party
Chairman. 1/14/83.
NPL-136 Jerry J. Bromenshenk, Associate Professor of
Research, Environmental Studies Laboratory,
University of Montana. 2/13/83.
NPL-109 Peter M. Rice, Faculty Affiliate, University of
Montana. 2/04/83.
NPL-17 Barbara Evans, Chairman, Missoula County Board of
Commissioners. 1/12/83.
NPL-16 Mike Kadas, Representative, District 95, Montana
State House of Representatives. 1/12/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
NPL-L19 C. Nimlos, Environmental Chairperson,
Soroptimists-Missoula North. 3/11/83.
Milltown area residents:
NPL-12 Doris & John Wood
NPL-13 Gary Le Deau
NPL-14 S. Gascione
NPL-15 Tony Moore
NPL-19 Peggy M. Brownlee
NPL-20 Donny & Melody Fuchs
NPL-22 Carol Marks (and class)
NPL-23 Mandy Fuchs
NPL-24 Rita Milligan
NPL-25 Steve Smutko & Mary Corcoran
NPL-32 Sharon & John D. Smith
NPL-34 Sharon Rogers
NPL-35 Debra Entzel
NPL-39 Mrs. Charles Jacobson
NPL-57 Gloria E. Nyquest
NPL-58 Mr. and Mrs. Stroh
NPL-76 Kathy E. Johnston
NPL-82 C. B. Pearson
NPL-84 Mr. & Mrs. James Dixon
and Mrs. Julia Van Hall
9-9
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NPL-85 Lauretta Gaydos
NPL-86 Ruth Gross
NPL-87 Robert D. Oakley
NPL-88 Mr. & Mrs. Lee Hurt
NPL-89 Deborah Anderson
NPL-97 Nancy Hell
NPL-100 Maria Young
NPL-101 Anonymous Missoula
Valley Water user
NPL-103 Marlee Miller
NPL-105 Genevieve F. Spaulding
NPL-110 Don J. Feist
NPL-115 Dave Libieholm
NPL-116 Willard & Helen Manghan
NPL-117 Mrs. Donald W. Anderson
NPL-118 Elaine Anderson
NPL-119 Mrs. B. 0. Anderson
NPL-120 Ron Selden
NPL-121 Lisa Fleischer
NPL-122 Lorrain Rocha-Brownel
NPL-123 Anonymous
NPL-124 David A. Koteche
NPL-126 Robert Harrington
NPL-130 Philip M. Barrett
NPL-140 Robert W. Gray
NPL-173 Colleen M. Carew
NPL-245 Dana McMurray
NPL-L9 Jim Norgaard
9.6.2 Summary of Comments and Responses
All commenters supported inclusion of Milltown on the National
Priorities List, especially so that Superfund money can become
available to provide clean drinking water.
Messrs. Bromenshenk and Rice provided additional technical
information regarding arsenic concentrations in sediments behind
Milltown Dam and in area wells. The Agency believes this
information was accurately reflected in the original HRS score for
this facility, as the toxicity/persistence of arsenic was used to
score the surface water and ground water pathways.
9-10
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The same commenters indicated that the source of the arsenic
and possibly other heavy metals in the Clark Fork River appears to
be sediments derived from smelting and mining operations in the
Anaconda/Butte area. The commenters noted that the entire section
of the Clark Fork River between the Silver Bow site and Milltown is
probably contaminated and the problem should be viewed in this
context, rather than as several site-specific problems. The
available data suggest that the sources of contamination of these
sites may be common. The Agency and other interested parties are
currently considering a consolidated approach to the various Clark
Fork River sites. Should future studies substantiate a link in
sources of contamination, the Agency can consolidate the affected
sites.
The U.S. Department of the Interior noted that migratory birds
may ingest heavy metals from this site. This concern was reflected
in the scoring of the site.
The original migration score for this facility was 43.78.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Milltown are:
Ground Water 59.18
Surface Water 47.27
Air 0
Total 43.78
9-11
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9.7 Silver Bow Creek, Silver Bow/Deer Lodge Counties, Montana
9.7.1 List of Commenters
NPL-225 Paul M. Kaplow, Manager, Environmental and Regulatory
Affairs, Atlantic Richfield Company. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
9.7.2 Summary of Comments and Responses
Atlantic Richfield Company commented on Silver Bow Creek and
the Anaconda Minerals facility. They did not comment specifically
on Silver Bow Creek other than to say that the site should be
deleted from the list. The commenter did not provide any data which
would justify changes in the HRS scores for this site.
The U.S. Department of the Interior notes that migratory birds
may ingest heavy metals from this site. This concern was reflected
in the scoring of the site.
Review of this facility revealed rounding errors in the score
calculations. The original migration score for this facility was
63.80. Based on the change noted above, the HRS scores for Silver
Bow Creek are:
Ground Water 79.59
Surface Water 76.36
Air 0
Total 63.76
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9.8 Whitewood Creek, Whitewood, South Dakota (08SD001)
9.8.1 List of Commenters
NPL-192, NPL-234 William G. Langston, Corporate Counsel,
Homestake Mining Company. 2/25/83.
9.8.2 Summary of Comments and Response
The commenter stated that no observed release to ground water
above background level was demonstrated and that the high score for
the site resulting from the value assigned for this observed release
is invalid. The data from a number of wells were reviewed for the
original scoring and release of arsenic above background levels was
substantiated in six of the 76 wells monitored by the South Dakota
survey along Whitewood Creek, Belle Fourche River, and a part of the
Cheyenne River. Therefore, no change in scoring is required based
on this comment.
The commenter states that an observed release of arsenic to
ground water "... has not occurred and cannot reasonably be expected
to occur, in light of the documented geochemical removal mechanisms
..." The geochemical removal mechanisms the commenter refers to are
oxidation and solubilization followed by coprecipitation with
hydrous iron oxides, aluminum, and calcium. In response, while it
is likely that some arsenic is being removed from the aqueous
environment through this precipitation reaction, some of the arsenic
remains mobile in the ground water. It is this mobilized arsenic
that was detected and serves as the basis for the observed release
to ground water.
9-13
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The commenter noted that the toxicity value for arsenic should
be 0 because arsenic is not listed in Sax or NFPA. The commenter
presented consultant reports to indicate that arsenic is removed
from ground water by geochemical means and is not a problem. Page
388 of the 5th edition of Sax lists arsenic and describes its
toxicity. As demonstrated by the observed releases to ground water,
arsenic can stay mobilized in ground water. Thus, the
toxicity/persistence factor value was scored correctly.
Another consultant's report was presented which stated that the
process by which arsenic is altered from a non-toxic to a toxic
specie is methylation, a process that will not occur in the
environment of the Whitewood Creek tailings piles. In response,
methylation is only one process by which arsenic can be transformed
to toxic compounds. Other processes, such as oxidation, will result
in other toxic compounds and can occur in the Whitewood Creek
environment.
The commenter noted that no evidence is given on quantity of
hazardous material. The estimate that the quantity of tailings
exceeds 2500 tons is based on 2000 tons per day discharged for 50
years. In view of this discharge rate, based on information
provided by the South Dakota Department of Health, the maximum value
of 8 was appropriate.
The commenter said that the maximum population exposed to
ground water is 100. A conservative analysis of the wells located
9-14
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within a 3 mile radius indicates a well users' population of close
to 1000. In addition, the South Dakota Office of Water Rights has
stated that a minimum of 1000 acres is irrigated with ground water.
Using the ratio of 1.5 people per acre, per the HRS, this equates to
an additional 1500 people. Based on a population of 1000 to 3000,
and a distance of zero (the contaminated wells are part of the site)
the distance/population value is 30 for ground water.
The commenter contends that the observed release to surface
water is not appropriate because, "... the evidence shows clearly
that the level of contaminants does not exceed the background level
..." The score of 45 for observed release to surface water is based
on analyses of the tailings piles contained in the creek which are
in constant interaction with the surface water of the creek.
The commenter also indicated that the surface water population
should be 100 or less. The surface water target population score is
based upon 1000 acres which are irrigated using water from Whitewood
Creek. This information was supplied by the South Dakota Department
of Water and Natural Resources.
The commenter noted no evidence to support the value for
distance to a sensitive environment. The documentation concerning
the wetland has been verified and updated and the factor value of 3
remains unchanged.
The commenter contended that the population affected by direct
contact was overstated. As explained in the preamble to the final
9-15
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NPL, direct contact score is not considered in the listing of the
site on the NPL.
The commenter made numerous allegations challenging the
constitutionality and legal adequacy of CERCLA, the HRS, and the
process for including Whitewood Creek on the NPL. No explanation or
documentation for these conclusory allegations was provided by the
commenter, and therefore no response is possible, except to note
that EPA believes CERCLA to be constitutional and has followed all
appropriate procedures in developing the HRS and NPL pursuant to
that statute.
The commenter also contended that mining sites should not be
included on the NPL. EPA has determined that the authority to
respond to releases of mining wastes does exist in CERCLA, and
therefore such sites will be included on the NPL. The rationale for
this decision is presented in Part VI of the preamble to this rule.
The commenter noted that there is not one site but a number of
discrete sites, each of which must be evaluated separately. Section
104 (d)(4) of CERCLA authorizes the Federal government to treat two
or more non-contiguous facilities as one for purposes of response,
if such facilities are reasonably related on the basis of geography
or on the basis of their potential treat to public health, welfare,
or the environment. CERCLA does not speak to this issue with
respect to the listing of sites on the NPL. Since the NPL lists
sites "... for the purpose of taking remedial action, ..."(CERCLA
9-16
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Section 105 (8)), listing is sufficiently related to the response
function that EPA can treat several sites as one for purposes of
listing as well. Given that the locations making up this site are
part of the same operations, involving the same wastes, and are in
close proximity to each other, treating these as a single site for
purposes of listing on the NPL appears preferable, for reasons
discussed in Part VI of the preamble to the final NPL.
The commenter also stated that Whitewood Creek should not be
listed prior to the completion of various studies now underway. In
response, the existing documentation was reviewed and judged to be
sufficient to warrant inclusion of Whitewood Creek on the NPL as a
problem site. Further, it is noted that Whitewood Creek is the
state's designated top priority for cleanup action. Any more
detailed information developed as a result of pending studies will
be considered by EPA in determining whether the listed site warrants
response action, and in determining what such action should be.
Review of this facility revealed rounding errors in the
calculation of the total HRS score. The original migration score
for this facility was 59.50. Based on the changes noted above, the
HRS scores for Whitewood Creek are:
Ground Water 79.59
Surface Water 76.36
Air 0
Total 63.76
9-17
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9.9 Baxter/Union Pacific, Laramie, Wyoming
9.9.1 List of Commenters
NPL-196 Karl R. Morthole, Union Pacific Law Department.
2/24/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
9.9.2 Summary of Comments and Responses
The first commenter stated that the response status for this
site should be changed from E (enforcement) to V (voluntary or
negotiated response). The commenter notes that there is presently
no federal enforcement action pending and that a formal agreement
between Union Pacific and EPA Region VIII will be reached shortly.
As the formal agreement discussions are still pending, the
appropriate response status for this site is D (to be determined).
However, this status will be changed to V (voluntary or negotiated
response) if the agreement is signed.
The commenter stated agreement with the observed release to
ground water score and the toxicity/persistence and hazardous waste
quantity values for the ground water and surface water pathways.
The commenter also agreed with the population served/distance to
water intake downstream value for the surface water pathway. These
values have been used to compute the HRS score for this site.
The Union Pacific Law Department contended that the Fergusen
well should not be included as a potential target because: (1) it
is upgradient; (2) it is in a deeper aquifer separated by a
9-18
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confining layer from the aquifer of concern; and (3) it shows no
contamination. Because of the need to develop a nationally uniform
scoring system that could be used to score a large number of sites
with the data commonly available, the HRS does not specifically take
into account such level of detail as flow gradients when determining
the target population. This position is explained more fully in the
preamble to the final National Contingency Plan at 47 FR 31190.
Available data demonstrate that the well in question is screened
from 25 to 75 feet from the ground surface and is, therefore,
drawing water from the identified aquifer of concern. The absence
of current contamination does not remove the well from consideration
in determining distance to nearest well; the requirement is only
that the well be drawing from the aquifer of concern. Therefore,
use of the Ferguson well for the distance to nearest well value is
legitimate and appropriate.
Union Pacific further contended that there is no observed
release to surface water because benzene contamination occurs both
upstream and downstream, indicating that the plant is not the source
of the contaminant. In lieu of an observed release to surface water
Union Pacific provides suggested values for the route
characteristics and containment rating factors.
Qualitative identification of pentachlorophenol and
polyaromatic hydrocarbons (phenanthrene, anthracene and chrysene) by
HPLC/fluorescent interference detection in river sediment samples
9-19
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served as the basis for observed release. Benzene was not con-
sidered. Although quantitative identification of these compounds
has not been accomplished, strongly substantiated qualitative data
are sufficient evidence of release as stated in the HRS. The
identified compounds were positively linked to the site based on the
finding that contaminant concentrations at the site and downstream
of the site were greater than those in samples taken upstream from
the site. Based on all available information, no change in score is
appropriate.
The U.S. Department of the Interior expressed concern for
potential impacts on the Laramie River and associated ponds. These
concerns were reflected in the site score.
Review of this facility revealed rounding errors in the
calculation of the total HRS score. The original migration score
for this facility was 37.00. Based on the changes noted above, the
HRS scores for Baxter/Union Pacific are:
Ground Water 59.18
Surface Water 25.45
Air 0
Total 37.24
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10.0 COMMENTS ON REGION IX SITES
10.1 Indian Bend Wash Area, Scottsdale-Tempe-Phoenix, Arizona
10.1.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of Interior. 3/17/83.
10.1.2 Summary of Comments and Response
The Department of Interior noted that ground water
contaminated with chromium and trichloroethylene is near the Salt
River Indian reservation. The Bureau of Reclamation notes that this
site appears to affect water resources at a reclamation facility.
This information is already reflected in the HRS score. No
additional technical information was presented that would alter the
site score.
The hazardous waste quantity was raised from zero to one
because of an observed release to ground water. This rescoring is
in accordance with the HRS supplemental instructions of
July 29, 1982 that mandate a score of one for an unknown quantity
that has resulted in an observed release.
The original migration score for this facility was 40.02.
Based on the change noted above, the HRS scores for Indian Bend Wash
Area are:
Ground Water 73.08
Surface Water 0
Air 0
Total 42.24
10-1
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10.2 Mountain View Mobile Home, Globe, Arizona
10.2.1 List of Commenters
NPL-28 Mrs. James S. lannello, resident. 1/19/83.
NPL-65 Mrs. James S. lannello, resident. 1/29/83.
NPL-95 The Central Arizona Association of Governments.
1/31/83.
NPL-111 Catherine Scott, resident. 2/03/83.
NPL-135 Eunice West, resident. 2/13/83.
NPL-151 Catherine Antkowiak, relative of residents. 2/18/83.
NPL-159 Vada Campbell, relative of residents. 2/16/83.
NPL-161 Eunice West, resident. 2/17/83.
NPL-259 The Central Arizona Association of Governments.
1/31/83.
NPL-267 Eunice West, resident. 2/27/83.
NPL-286 Sherry Right, relative of resident. 2/28/83.
10.2.2 Summary of Comments and Response
The commenters supported the listing of this site on the NPL.
No additional technical information was presented that would alter
the site score.
Agency review has resulted in the rescoring of the air route
for this site. The population matrix for the HRS air pathway is
intended to reflect the relationship between the size of the
population potentially affected and the distance of that population
from the facility. In this case, the population matrix was
originally assigned a value of 18 based on approximately 7,000
10-2
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residents of Globe, Arizona, within the 4 mile radius specified in
the HRS user's manual. Review of this facility, however, revealed
that a more appropriate value for this matrix is 21, based on the
130 residents of Mt. View Mobile Home, nearly adjacent to the site.
The original migration score for this facility was 26.46.
Based on the change noted above, the HRS scores for Mountain View
Mobile Home are:
Ground Water 0
Surface Water 0
Air 52.31
Total 30.24
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10.3 Tucson International Airport, Tucson, Arizona
10.3.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of Interior. 3/17/83.
10.3.2 Summary of Comments and Response
The commenter noted that ground water from the contaminated
aquifer is used as drinking water on the San Xavier Indian
reservation. This concern was already reflected in the
distance/population value of 40 and the ground water use value of 3.
The original migration score for this facility was 57.80. No
new technical information was submitted and no change in score was
required. The HRS scores for Tucson International Airport are:
Ground Water 100.00
Surface Water 0
Air 0
Total 57.80
10-4
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10.4 19th Avenue Landfill, Phoenix, Arizona
10.4.1 List of Commenters
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of Interior. 3/17/83.
10.4.2 Summary of Comments and Response
The Department of Interior noted that chemical wastes
contaminate the Gila River during flood season and, in turn, may
enter the ground water aquifer that is used at the Gila River Indian
reservation, six miles from the site. In response, the surface
water pathway was scored zero due to the absence of any target
population within the 3 mile distance prescribed by the HRS.
However, the concern for ground water was already addressed by the
use of the maximum value (40) for distance/population.
The original migration score for this facility was 54.27.
Based on the above response to comments, the score remains
unchanged. The HRS scores for the 19th Avenue Landfill are:
Ground Water 93.88
Surface Water 0
Air 0
Total 54.27
10-5
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10.5 Aerojet, Rancho Cordova, California
10.5.1 List of Commenters
NPL-5 Dan W. Brown, Group Director Public Affairs, Aerojet
General Corporation. 12/21/8?.
10.5.2 Summary of Comments and Response
The commenter was concerned that the press release referred to
hazardous waste "... including herbicides, arsenic, and rocket
propellant..." whereas, the primary chemical of concern is
tricholoroethylene. The press release has been modified to reflect
the fact that trichloroethylene is the primary chemical of concern.
The original migration score for this facility was 54.63. No
new technical information was submitted and no change in score was
required. The HRS scores for Aerojet are:
Ground Water 93.88
Surface Water 10.91
Air 0
Total 54.63
10-6
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10.6 Celtor Chemical, Hoopa, California
10.6.1 List of Commenters
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of Interior. 3/17/83.
10.6.2 Summary of Comments and Response
A. D. Little noted that the documentation shows an observed
release for ground water and none for surface water but that the HRS
scores show the reverse: no observed release for ground water and
an observed release for surface water. The commenter is correct
that there was an inconsistency between the documentation and the
HRS scores. The documentation was revised for final scoring, but
the revised copy was inadvertently left out of the docket. The
revised documentation did not show a documented release to either
ground water or surface water. The scoring sheet, which was checked
to indicate an observed release to surface water, was thus also in
error. However, even without consideration of an observed release,
the original surface water score is supported on the basis of the
original values assigned to containment and route characteristics
rating factors. Thus, no change in the surface water score is
necessary because of this error.
The Department of Interior noted that the Trinity River
supports Indian fishing at the Hoopa Valley Indian Reservation. The
Bureau of Reclamation notes that this site appears to affect water
10-7
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resources at a reclamation facility. The site score already
reflects this information.
The Department of Interior also noted that the site is used as
a children's playground on the Hoopa Valley Indian Reservation. The
direct contact worksheet reflects this exposure mode but direct
contact is not used in computing the overall site migration score.
The original migration score for this facility was 30.31.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Celtor Chemical are:
Ground Water 51.29
Surface Water 10.91
Air 0
Total 30.31
10-8
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10.7 Coast Wood Preserving, Ukiah, California
10.7.1 List of Commenters
NPL-144 Gene Pietila, Coast Wood Preserving Inc. 1/10/83.
NPL-156 Gene Pietila, Coast Wood Preserving, Inc. 2/17/83.
10.7.2 Summary of Comments and Response
The commenter stated that the plant should not be included in
the list of Superfund sites, because between 1972 and 1980 it
operated in compliance with all known regulations. In 1980, the
company changed wood storage policy, at the request of the
California Water Quality Control Board North Coast Region Staff,
which resulted in the concentration of stormwater runoff in such a
way that the plant's discharge order was violated. The commenter
continued "Simply put, CWP became a violator not by accident or
intent but by a new interpretation of policy by regulatory agency."
In response, CERCLA policy implementation is not affected by
changing policies in state or local agencies. In addition, listing
of a site does not establish or reflect the liability or responsi-
bility of any potentially responsible parties. Therefore, consider-
ation of this site for the NPL by virtue of the HRS score is valid
and appropriate.
Coast Wood Preserving expressed the opinion that efforts have
been made to rectify all environmental impacts and that the scores
assigned do not reflect the present conditions. EPA computes HRS
scores and lists sites on the basis of conditions existing before
10-9
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any response actions are taken in order to represent the full scope
of the original problem presented by a site, as explained in Part
VII of the preamble to the final NPL. If EPA determines that a site
is cleaned up so that no further response is necessary, EPA will
delete the site from the list, as discussed in Part VIII of the
preamble to the final NPL. EPA has not yet made such a
determination with respect to the Coast Wood Preserving site, but
will continue to examine conditions at the site to determine whether
deletion is appropriate. For sites that remain on the list, any
cleanup activities conducted pursuant to formal agreements with EPA
are acknowledged on the final NPL by notation in the "Voluntary or
Negotiated Response" category.
The commenter criticized the validity of the soil contamina-
tion data which was referenced in connection with the ground water
pathway. In response, even if these data are not reliable, this
does not affect the score, because these soil contamination data
were used only as further verification of the ground water sampling
data. These ground water sampling data are themselves adequate to
support the score for the ground water pathway.
The commenter also disputed the containment reference
documented for the ground water route. However, as is the case for
the soil contamination data, the containment factor did not
contribute to the final ground water score, because the pathway was
scored or the basis of an observed release to ground water.
10-10
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The commenter disputed the toxicity/persistence value insofar
as sodium dichromate dihydrate is usexi in the process rather than
chromic acid. However, the toxicity/persistence value was not
assigned on the basis of the use of a particular chromium compound
at the site, but rather on the basis of the presence of hexavalent
chromium. On this basis, the value of 18 for toxicity/persistence
is correctly assigned.
The commenter stated that the documentation which indicated a
value of 8 for hazardous waste quantity was incorrect, and that the
correct value was 2, based on the amount of approximately 25 tons of
hazardous waste disposal during the life of the plant. In response,
the Agency in fact assigned a factor value of 2 for waste quantity
in the original scoring, although it developed its estimate in a
somewhat different manner (based on concentration of chromium in the
contaminated soil). The comment apparently results from the
inclusion in the documentation of some material indicating a factor
value of 8. The Agency acknowledges that this portion of the
documentation was erroneous, and that the correct value is 2.
However, because the Agency used a value of 2 in its original
evaluation of this facility, no change is necessary.
The commenter noted that ground water flows to the southeast,
that contamination has been shown to have spread approximately 600
feet southeast from the retort area, that the bulk of the population
resides upgradient from the site, and that there are no domestic
10-11
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wells In the area of migrant labor housing. In response, HRS
considers populations using water withdrawn within a 3 mile radius,
regardless of gradient. Because of the need to develop a nationally
uniform scoring system that could be used to score a large number of
sites with the data commonly available, the HRS does not
specifically take into account such level of detail as flow
gradients when determining the target population. This position is
explained more fully in the preamble to the final National
Contingency Plan at 47 FR 31190. The value for distance to the
nearest well indicates the potential for the contamination of
drinking water from the contaminated aquifer and is based on a
distance of 1,000 feet to the Willow County Water Service Area
well. The reference to wells in the area of migrant labor housing
has been removed from the docket. Because no wells from this area
were included in the original calculation of population served no
change in score results.
The commenter noted that the actual area of irrigated land
affected by contamination is at most 20 acres rather than the 9,830
acres estimated in the HRS documentation. The HRS, however, scores
potential for contamination as well as actual contamination and
therefore includes all acreage irrigated with water withdrawn within
a 3 mile radius of the site. The estimate of 9,830 acres reflects
this irrigated acreage.
10-12
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The commenter stated that all releases to the surface water
route have effectively been halted. Therefore, the observed release
to surface water should be scored zero. As explained previously,
the Agency does not consider remedial actions in calculating HRS
scores. Instead, scores are computed on the basis of conditions
existing before any response actions are taken. Therefore, the
surface water pathway observed release is valid.
During the review of documentation and scoring, EPA noted that
the ground water use value should have been 3 rather than 2 since
the water is used for drinking with no readily available
unthreatened alternative source.
The original migration score for this facility was 42.02.
Based on the changes noted above, the HRS scores for Coast Wood
Preserving are:
Ground Water 76.92
Surface Water 8.39
Air 0
Total 44.73
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10.8 Iron Mountain Mine, Redding, California
10.8.1 List of Commenters
NPL-3 T. W. Arman, Iron Mountain Mines, Inc. 11/18/82.
NPL-141 T. W. Arman, Iron Mountain Mines, Inc. 3/15/83.
NPL-153 T. W. Arman, Iron Mountain Mines, Inc. 2/18/83.
NPL-190 T. W. Arman, Iron Mountain Mines, Inc. 2/25/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of Interior. 3/17/83
10.8.2 Summary of Comments and Response
Iron Mountain Mines, Inc. objected that mine water drainage,
the result of natural leaching, was being treated in the same
category as man-made chemicals. The main focus of CERCIA is the
abatement of threats to human health or the environment, not whether
the threat is or is not naturally occurring. In any case, EPA
believes that the "natural leaching" was made possible because
mining activities exposed ore to air and water. Regarding the
general issue of listing mining waste sites on the NPL, EPA has
determined that the authority to respond to releases of mining
wastes does exist in CERCLA, and has made the policy decision to
include such sites on the NPL. These issues are discussed in Part
VI of the preamble to the final NPL.
The commenter stated that Iron Mountain Mines is not an
abandoned mine and that continuous mine and metal recovery
operations have taken place since 1880. In response, the reference
10-14
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to abandoned mines has been removed from the sitr. description. The
operating status is not relevant to the application of the HRS to
this site.
The same commenter noted that the HRS scoring was based on
studies 8 to 14 years old and that the metal content of the mine
water drainage has been decreasing, at least partially because of
processing this water for copper removal. EPA scored sites for
inclusion in the NPL on the basis of the hazards that existed before
any response actions were initiated. The preamble to this rule
provides further information in this regard.
Iron Mountain Mines, Inc. presented estimates of the annual
loads of copper, zinc, and cadmium from the site and stated that the
potential daily cadmium impact to the Sacramento River is 25 pounds
rather than 50 pounds. In response, the scoring of observed
releases is based on analytical results showing discharges above
background, and is not affected by the quantity or concentration
level of the release observed. The reference to 50 pounds of
cadmium appears in the summary description of the site and was not
used for scoring purposes.
The same commenter stated that the ground water target value
should be reduced to zero because "... there are no wells involved
and the nearest population is four miles away ..." In response, the
Supervising Engineer of the Regional Water Quality Control Board has
confirmed that 6 to 12 homes (23 to 46 people) in the vicinity of
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the site use ground water as their only source of drinking water.
The nearest of these wells is 2000 feet from a tailings pile. The
appropriate value for distance to nearest well/population served,
based upon this data is 10 and the ground water pathway score is
correct.
With respect to surface water release, the same commenter
maintained that natural dilution of runoff was disrupted at the
timeof the building of Shasta Dam and that the problem has existed
since that time. In addition, the commenter states that many other
mining properties contributing substantially greater drainage
quantities lie upstream from Iron Mountain Mines. The Agency has
reviewed the data, and the observed release was based on
measurements in Slick Rock, Boulder, Flat, and Spring Creeks that
are not affected by the Shasta Dam. Sufficient data exist,
including those supplied by the commenter, to attribute observed
releases of heavy metal contaminants to the Iron Mountain Mines
site. The percentage of total contaminant loadings contributed by
the facility is not a relevant consideration in the evaluation of a
facility for purposes of developing a HRS score. It was not
necessary to use the additional data from the January 1983 U.S.
Geological Survey study cited by the commenter. It should be noted
that this area was selected as the preferred study area in the
region because it represents the state's most serious water quality
problems associated with mining activities.
10-16
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The commenter also contends that the surface water pathway
score should be significantly reduced. The maximum values for
toxicity/persistence, hazardous waste quantity, and targets were
used to score this site. The commenter states that "... there is no
conceivable way that such ratings could be applied to Iron Mountain
Mines." Rather than suggesting alternate values for each of these
elements, the commenter states that "... possibly a rating of 12 not
26 would even be high but at least it would be more realistic ..."
for the waste characteristics factor. As the commenter has not
provided any data to substantiate these suggested value changes, the
values will remain unchanged because the original values used to
score the surface water pathway are supported by data, as reflected
in the documentation record.
The commenter continued by noting that Spring Creek enters the
Sacramento River four miles upstream from the supply intake of the
City of Redding rather than the 2 miles reported in the HRS. In
response, boundaries of a site for purposes of the HRS extend to and
include all areas where contaminants have come to be located, not
just the area where they originally were deposited. This approach
is supported by the broad definitions of "facility" and "release" in
the statute (CERCLA Section 101(9) and (22)). Elevated levels of
cadmium have been detected at the water supply intake for the City
of Redding. The distance, therefore, from the site to the intake is
10-17
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considered 0 and the population served/distance to water intake
downstream matrix is properly assigned a value of 40.
The commenter also presented a number of reasons for saying
that surface water contamination does not present a significant
hazard. The commenter said the Shasta County Health Department has
never had any problems with heavy metals in the river water.
Further, he adds that over 99 percent of the metals in solution from
Spring Creek precipitate naturally into metallic form at the mouth
of the creek and would remain there harmlessly if they were not
carried into the Sacramento River mainstream by the tail race from
the Spring Creek powerhouse. The commenter also stated that any
downstream samples should be filtered of solids before assaying
because only minerals in solution can be considered harmful. In
response, it is noted that total heavy metal concentrations in the
surface water of Boulder, Slick Rock, Spring, and Flat Creeks are
the basis for the observed release to surface water. These total
metal measurements are appropriate to the HRS because the intent of
the HRS is to evaluate the potential and known threats to the
environment and its inhabitants. Both precipitated and dissolved
heavy metals provide such threats.
Finally, the commenter objected to the fact that various
remedial actions and plans implemented by Iron Mountain Mines, Inc.
were not taken into account in the scoring. EPA computes HRS scores
and lists sites on the basis of conditions existing before any
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response actions are taken in order to represent the full scope of
the original problem presented by a site, as discussed in Part VII
of the preamble to the final NPL. If EPA determines that a site is
cleaned up so that no further response is necessary, EPA will delete
the site from the list, as discussed in Part VIII of the preamble to
the final NPL. EPA has not yet made such a determination with
respect to the Iron Mountain Mines site, but will continue to
examine conditions at the site to determine whether deletion is
appropriate. For sites that remain on the list, any cleanup
activities conducted pursuant to formal agreements with EPA are
acknowledged on the final NPL by notation in the "Voluntary or
Negotiated Response" category.
The Bureau of Reclamation notes that this site appears to
affect water resources at a reclamation facility. The original HRS
score for this site reflects this situation.
The original migration score for this facility was 56.16.
Based on the above response to comments, the score remains
unchanged. The HRS scores for Iron Mountain Mine are:
Ground Water 38.78
Surface Water 89.09
Air 0
Total 56.16
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10'9 MGM Brakes, Cloverdale, California
10.9.1 List of Commenters
NPL-1 Harding Lawson Associates on behalf of MGM Brakes.
11/08/82.
NPL-55 Heller, Ehrman, White and McAuliffe, Attorneys for
MGM Brakes. 1/14/83.
NPL-93 Heller, Ehrman, White and McAuliffe, Attorneys for
MGM Brakes. 1/18/83.
NPL-145 Harding Lawson Associates on behalf of MGM Brakes.
2/11/83.
NPL-146 Harding Lawson Associates on behalf of MGM Brakes.
2/14/83.
NPL-175 Harding Lawson Associates on behalf of MGM Brakes.
2/24/83.
NPL-218 A. D. Little, Inc. Report to FMC Corporation. An
Analysis of the Hazard Ranking System and the
National Priority List. 2/83.
10.9.2 Summary of Comments and Response
A. D. Little noted that an observed release to ground water
was documented by the analyst yet was scored as 0 on the worksheet.
A review of the documentation showed that PCB analyses of soil
samples were documented and ground water samples were not. There-
fore, the observed release was appropriately assigned a value of 0.
MGM Brakes contended that PCBs are adsorbed to soils and are
immobile in soil/water systems such as exist at the site. The deep
migration of PCBs through the soil column at the site is attributed
to the organic solvent ethylene glycol which is no longer released
and which is highly degradable and no longer present to cause
10-20
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further migration. Further, the commenter argues that PCBs are
biodegradable and are contained at the site due to natural
conditions. The commenter concludes that the ground water
containment value should be 0 rather than 3. In response, a
containment value of 0 is assigned only if the hazardous substances
are underlain by an essentially impermeable barrier and an adequate
leachate collection system and diversion system are present. Since
the adsorptive capacity of the soil cannot be considered to fit the
definition of an impermeable barrier, and since no leachate
collection or diversion systems were present at the time of past
releases, a containment score of 3 is appropriate. In addition, the
discharge of hydraulic fluids containing PCBs directly to the ground
also supports the assignment of a 3 for containment.
The commenter presented vertical soil permeabilities of the
unsaturated zone, developed by the commenter's consultant, which
9 7
ranged from 7.22 x 10 to 2.51 x 10 cm/sec. Based on these
data, EPA is rescoring this factor from 3 to 1 using the maximum
permeability which was supplied by the commenter's consultant.
In the process of reevaluating the ground water route
characteristics, two errors in scoring from the recorded
documentation were corrected. The value assigned to depth to the
aquifer of concern was raised from 2 to 3 to reflect a depth of
approximately 8 feet and the value for net precipitation was raised
from 0 to 1 to reflect a net precipitation of -5.7 inches.
10-21
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The same commenter stated that the hazardous waste quantity
should have been scored as 4 rather than as 7 based upon an estimate
of the quantity of casting wastes disposed of. This estimate was
based on an assumption that each casting machine produced 1 and 1/2
barrels of waste per month, or a total of at most 1,000 barrels. In
response, the value of 7 accurately reflects the estimate of 7,783
drums of hydraulic fluid. This quantity was derived using the
volume of contaminated soil and the average concentration of PCB in
that soil to estimate a volume of PCB laden hydraulic fluid which
was initially deposited on the soil.
The commenter doubted the existence of shallow wells and also
stated that ground water use should be scored as 1 rather than as
2. Review of the documentation confirmed the existence of these
shallow wells. This review also resulted in the ground water use
factor value increasing from 2 to 3 based on the fact that some
people using this shallow aquifer as a drinking water supply have no
alternate unthreatened source.
The commenter also said that the distance to nearest
well/population served should have been scored between 6 and 12
rather than 30. The commenter suggested a value of 2 for distance
to nearest well and a value of 1 or 2 for population served. In
response, the reported distance to the nearest well is between 2001
feet and one mile (located along the Russian River) which is
assigned a value of 3. As indicated by the commenter, this factor
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was originally incorrectly assigned a value of 4. The value for
population served is based upon a summation of three factors: (a)
the South Cloverdale Water Corporation supplies water to 100
households (equivalent to 380 people), (b) the Duscho Water Company
supplies water to an additional 6 to 8 households (23 to 30 people),
and (c) an estimated 646 acres are irrigated with this ground water
(equivalent to 969 people). These three populations total 1372 to
1379 people, a value of 3 for population served. The matrix value
for the indicated population served and distance values is 24 rather
than 30 because of the change in value assigned to distance to the
nearest well.
The commenter also noted that surface water use should have
been scored as 1 rather than as 3. The commenter justified this
proposed change by stating that sampling of the surface water at the
intake points has detected no contamination. As stated in the HRS,
47 FR 31236, the surface water use and population of interest are
determined according to whether water is taken from surface waters
within a distance of three miles from the location of the hazardous
substance. The existence of the intake points within that distance
indicates that the associated population is threatened by the
possibility of contamination, and actual current contamination,
therefore, need not be shown. A value of 3 is appropriate based on
several downstream withdrawals for drinking water use within 3 miles
of the facility.
10-23
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The commenter objected that the description of the MGM Brake
site in the press release seriously misrepresented the conditions
and the potential hazard of the site. The press release has been
revised.
The original migration score for this facility was 34.52.
Based on the changes noted above, the MRS scores for MSM Brakes are:
Ground Water 47.49
Surface Water 36.71
Air 0
Total 34.70
10-24
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11.0 COMMENTS ON REGION X SITES
11.1 Arrcom (Drexler Enterprises), Rathdrum, Idaho
11.1.1 List of Commenters
NPL-244 Thomas L. Puree, Director, Department of Health and
Welfare, State of Idaho. 2/24/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of the Interior. 3/17/83.
11.1.2 Summary of Comment and Responses
The Department of Health and Welfare, State of Idaho,
requested that the facility be retained on the NPL if more rapid
progress can be made under CERCLA than is currently being made under
RCRA. In response, inclusion on the NPL makes that site eligible
for, but does not guarantee, funding under CERCLA. Such status does
not affect actions taken under other legislative authorities.
The U.S. Department of the Interior noted that this site
appears to affect water resources at the East Green Acres
reclamation facility. The potential impact on that facility was
considered in the original scoring.
Agency review of the surface water route characteristics
revealed an error in the value assigned to the distance to nearest
surface water. Since the documentation record states that there is
no downslope surface water, this factor is not applicable and has
been reduced from 2 to 0. Because this pathway was originally rated
0 due to other rating factor values, this change does not affect
pathway or total HRS scores.
11-1
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The original migration score for this facility was 29.28. No
new technical information was submitted and no change in score was
required. The HRS scores for Arrcom (Drexler Enterprises) are:
Ground Water 50.65
Surface Water 0
Air 0
Total 29.28
4
11-2
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11.2 Bunker Hill, Smelterville, Idaho
11.2.1 List of Commenters
NPL-202 Dr. Ian H. Von Lindern, Consulting Engineer, undated.
NPL-244 Thomas L. Puree, Director, Department of Health and
Welfare, State of Idaho. 2/24/83.
NPL-266 Bunker Limited Partnership. 2/28/83.
NPL-L16 B. Blanchard, Director, Environmental Project Review,
U.S. Department of Interior. 3/17/83.
11.2.2 S<mary of Comments and Response
The comments of Dr. Ian H. Von Lindern were submitted in
support of listing the Bunker Hill site on the NPL. He submitted
unpublished data similar to EPA-documented data.
The comments of Thomas L. Puree supported the listing of the
Bunker Hill site on the final NPL. He encouraged further studies by
the Federal government to study lead exposure in the local area.
The Department of the Interior noted that it is located near
the Coeur d'Alene River which is known to be polluted with lead and
zinc. An aquifer and soil in the area are also contaminated.
The information provided by these commenters was evaluated in
developing the original HRS site score.
The Bunker Limited Partnership commented that the observed
release to ground water should be scored 0 not 45, since the EPA did
not provide adequate data to support their value. EPA's review of
available data shows elevated zinc concentrations downgradient as
11-3
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compared to upgradient. Therefore, the observed release value of 45
is appropriate based on the differences between these measurements.
The Bunker Limited Partnership stated that the observed
release to surface water should be scored 0 not 45, since the EPA
did not provide adequate data to support their value. In response,
documentation that lead, cadmium, and zinc are all present in the
South Fork Coeur D'Alene River at greater concentrations downstream
of Bunker Hill than exist upstream of the site has now been entered
into the record.
The Bunker Limited Partnership continued by stating that the
observed release to air should be scored 0 not 45, since the
original scorer does not utilize current data and since current
levels do not significantly exceed background. In response, it is
noted that the value of 45 is based on data collected during the
1982 sampling period, the most current sampling data available at
the time of the original scoring. Furthermore, consistently higher
concentrations of lead were obtained at stations nearest the Bunker
Hill Facility than at those further away, thereby constituting a
significant release above background.
The Bunker Limited Partnership attributed the lead in
vegetables in neighboring communities to mining and milling dating
back to 1887 rather than to the Bunker Hill site and noted an
estimate of the population exposed by the air route of 8,500 rather
than 21,607. In response, attributing lead in vegetables to the
11-4
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Bunker Hill site is supported by the data. The data demonstrated.
that the concentration of lead in the soil and vegetation decreases
with the distance removed from the smelter. Agency review of the
air route population figures revealed an error in the total
population value of 21,607 people. The 1980 census figures for
population within 1/4 mile of the known contamination totals 10,348
and the air population/distance factor appropriately remains a value,
of 30.
The same commenter stated that the site is not subject to the
provisions,, of CERCLA because the air and water pollution is
regulated under the Clean Water and Clean Air Acts. In response,,
EPA can list sites and respond under CERCLA regardless of whether
there may be jurisdiction under another statute. Furthermore, the
jurisdiction of CERCLA extends to existing and historical deposition
of hazardous materials by air and contaminant seeps which are not
covered under the Clean Air Act or the Clean Water Act. It is
suggested that the commenter refer to the National Contingency Plan,
47 FR 31180 (July 16, 1982).
The Bunker Limited Partnership states that because waste at the
site resulted from smelting operations,- and therefore constitute
waste from mining operations, they are excluded from regulation. . ~,
under RCRA and CERCLA does not -apply. EPA has determined that, the
authority to respond to releases of mining wastes does exist in
CERCLA, and therefore-such sites .will be included on, the NPL. The
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rationale for this decision is present in the preamble to this rule.
The commenter also noted that remedial actions have been taken
and that nothing remains to be done that could be addressed by
CERCLA. In response, it is noted that facilities are scored to
reflect site conditions prior to any remedial action. If EPA
determines that no further response actions are appropriate, the
agency will delete the site from the list, but no such determination
has yet been made.
The original HRS score for this facility was 54.76. Based on
the above response to comments, the score remains unchanged. The
HRS scores for Bunker Hill are:
Ground Water 12.24
Surface Water 40.00
Air 85.00
Total 54.76
11-6'
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11.3 Flynn Lumber Company, Caldwell, Idaho
11.3.1 List of Commenters
NPL-244 Thomas L. Puree, Director, Department of Health and
Welfare, State of Idaho. 2/24/83.
11.3.2 Summary of Comment and Response
The commenter recommended that the facility be removed from
the NPL because no significant health or environmental problems
exist. He further states that the PGP contamination is at a very
low level and would degrade in an estimated 2 years. In response,
the Agency makes determinations of the actual or potential threat to
public health or the environment based on HRS scores. The
concentration of a contaminant and the frequency of release are not
pertinent to the scoring except that concentrations must be above
background levels (47 FR 31224).
An Agency review of the documentation for this site has
resulted in a score change. Under the ground water pathway, the
value for population served has been reduced from 5 to 2 since the
City of Caldwell well draws water from a deeper aquifer (300 to 500
feet) than originally documented and is located outside a three mile
radius of the site. Both these factors reduce the estimated
population served from 24,890 to 290 persons. In addition, the
hazardous waste quantity of 16 cubic yards is correct but should
have been assigned a value of 2 rather than 3. Furthermore, the 23
drums referenced in the documentation record have been deleted since
they were referenced as being empty.
11-7
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Under the surface water route, the same correction has been
made for hazardous waste quantity. Also, the distance to nearest
surface water correctly determined to be 3000 feet was incorrectly
assigned a value of 3 and has been changed to a 2.
The original MRS score for this facility was 41.87. Based on
the changes noted above, the MRS scores for Flynn Lumber Company are:
Ground Water 39.46
Surface Water 4.48
Air 0
Total 22.96
11-8
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11.4 Gould, Inc., Portland, Oregon
11.4.1 List of Commenters
NPL-273 A. H. Larson, Director, Product Development, Gould,
Inc. 2/25/83.
11.4.2 Summary of Comments and Response
The commenter noted that there is no state standard for lead
oxide in Oregon as alleged in the general description of the
facility on the HRS cover sheet. The commenter is correct and. the
HRS cover sheet has been modified to more accurately reflect the
content of the documentation sheets. No change in the HRS score
results from this correction because the incorrect description was
not used in calculating the HRS pathway scores.
The commenter criticized the sampling methods used in
establishing lead contamination of the shallow aquifer, stating that
the samples were not filtered to remove artifically entrained solids
due to the pumping process. Since the ground water route was scored
based on route characteristics rather than on an observed release to
either the shallow or deep aquifer, the criticized data were not
used in the HRS evaluation process.
The commenter objected to the rating of 3 for physical state
saying that it was not supported in the documentation record. In
response, documentation that liquids and sludges (physical state
value of 3) were disposed of at the site has now been entered into
the record.
11-9
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The commenter noted that the ground water use score should be
reduced from 2 to 1 since only a few employees of Northwest Natural
Gas occasionally drink from a private well in an area also served by
public water. The commenter considered this use an unofficial
alternate to city water. In accordance with Section 3.5 of 47 FR ,,
31320 all uses made of ground water drawn from the aquifer of
concern within 3 miles of the hazardous substance are considered.
Since the well is located approximately 1/2 mile from the site, the
value of 2 was appropriate.
The commenter objected to the scoring of an observed release
to the air on two bases: first, any release was caused by response
actions; secondly, the 1982 data, taken after response actions had
been terminated, were not based upon proper sampling protocol. The
scoring of an observed release, however, is based on data taken in
August and September of 1981, after response activities had been
terminated. These 1981 data were taken in accordance with EPA
protocol.
In response to points raised by the commenter concerning waste
characteristics, references to lead oxide dust, sulfuric acid
(HLSO,), and zinc are unsubstantiated and not relied upon in the
HRS evaluation. However, since the waste characteristics category
was evaluated based on lead, there is no resulting change in the
score. The reference to reactive compounds and incompatible
11-10
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substances in the air route is also deleted and this score is
reduced from 1 to 0.
Agency review of the ground water route characteristics
revealed an error in the value assigned to permeability of the
unsaturated zone. This factor has been raised from 0 to 2 based on
sand, silty sand, and fractured bedrock as intervening strata from
the surface'"to the deep aquifer. This information was made
available through additional data gathered by the Agency.
The Agency review of the documentation for this' site
identified an error in the scoring for the surface water use
factor. Sinc'e the original scoring does reference recreational and
fishing use of the Willamette River as well as industrial use of
Donne Lake, the rating factor value of 2 is applicable instead of
the 1 previously assigned.
The original HRS score for this facility was 32.84. Based on
the changes noted above, the HRS scores for Gould Incorporated are:
Ground Water 15.24
Surface Water 10.91
Air 52.31 - -
Total 32.12
11-11
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11.5 Teledyne Wah Chang (Albany), Albany, Oregon
11.5.1 List of Commenters
NPL-78 V. P. De Polx, President, Teledyne Wah Chang Albany.
1/6/83.
NPL-177 V. P. De Poix, President, Teledyne Wah Chang Albany.
75 pages. 12/13/82.
NPL-249 Richard P. Reiter, Supervisor, Hazardous Waste
Operations, Department of Environmental Quality,
State of Oregon. 2/28/82.
NPL-250 Lynn Frank, Director, Oregon Department of Energy.
2/25/83.
NPL-279 James L. Johnson, Jr., State Chairman, Friends of the
Earth, Oregon. 2/12/83.
NPL-284 Richard P. Reiter, Supervisor, Hazardous Waste
Operations, Department of Environmental Quality,
State of Oregon. 2/28/82.
NPL-295 Max Bader, M.D., State Health Officer, Deputy
Administrator, Health Division, State of Oregon.
2/25/83.
11.5.2 Summary of Comments and Response
Teledyne stated that the HRS scoring should have been based on
information contained in The State Energy Facility Siting Council .
order of December 15, 1982. In response, EPA did in fact use
appendices to the Siting Council report and reports that are cited .
by the Siting Council report. -.,
Varipus arguments were presented to demonstrate that the site.,
should not be included in the NPL. Teledyne stated that the old,. ,
sources of radiation at the. site, are covered under other authorities
and that the wastes are generated and stored at the site under an
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NPDES permit. The Oregon Department of Environmental Quality noted
the state authority to issue a site cer-ti-ficate under authority
compatible with CERCLAT. The Oregon Department of Energy stated that
the Oregon Energy Facility Siting Council had investigated Teledyne
v "*ป ^
sludge and that funding under the CERCLA is not required. The
Oregon Department of Human Resources questioned the methodology used
. -r*-
to rank the site and stated that the site should not be considered
for NPL listing. In response to these comments, the releases of
radioactive materials from the site are not excluded from CERCLA and
the site is therefore eligible for listing.: Furthermore the HRS,
score for the site is based upon uncontrolled releases of heavy
I *
metals and chlorinated organics as well as-releases of radioactive
materials. In scoring the site, EPA used the'HRS Methodology
contained in Appendix A of the National Contingency Plan.
Teledyne stated that the. organics found in drinking water do
nofexceed regulatory limits and stated that they do~not constitute
a health hazard. Lead is stated to be below proposed-dfinking water
limits and other heavy metals slightly above these limits. The HRS
assigns a value for an observed release because it is an indicatien.
that substances can migrate from the site and that more may do so in
the" future, not because the release 'observed is itself a health
threat. Therefore, as Stated in Sectioti 3.1 of the HRS, 47 FR:
31224, an observed release is scored whenever" the substances are'
detected in concentrations higher than background levels. The ;
11-13 ;
-------
review of observed release documentation for this site conducted :
since the original scoring shows that such a release has occurred to: ,
the ground water as well as to the surface water and air routes.
The ground water route is now scored for an observed release of
radium-226, barium, cadmium, and methylisobutylketone'measured in :i
ground water samples. This effectively raises the previous route
characteristics/containment, value from 36 to 45.
Teledyne stated that a proposed modification to the scoring '-
system for radioactive substances was used to score this site but
was not available for public comment and was not adopted by rule-
making. In response, although the proposed modification was cited ".
as used in assigning a toxicity/persistence value in the original -
scoring, the site is now scored for cadmium and radium-226, without
use of the proposed modification. These substances rate a 3 for
toxicity in accordance with Sax and a 3 for persistence in
accordance with Section 3.4 of the HRS (47 FR 31229). A matrix
value of 18 for"the ground and surface water routes is appropriate ;: .
as is a toxicity value of 3 for the air route. "' :
Teledyne commented that the target score for ground water
should be 0 rather than 22 since there are no beneficial uses, ^ '
wells, or population in the flow path of the aquifer of concern. - ">'-
The supporting data were reviewed and: the score left unchanged at 22 -'
for 365 persons served with drinking water- (alternative source ^ >'
available) and the nearest well at 2000 feet. ? Bercause x>f> the need. ::;
11-14
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to develop a nationally uniform scoring system that could be used to
score a-large number, of sites with the, data commonly available, the.
HRS does not specifically take into account such level of detail as
flow gradients ;when determining Che target population. This - .
position, is explained more fully in the preamble to the final
National Contingency Plan at 47 FR 31190^. .
Further review of the surface water,, targets documentation
resulted in two additional score changes. The distance to a
sensitivej environment value was reduced. fro,m~3 to 2 since the
wetland is 300 feet from the site, not^adjacetxt as previously
believedi. Further examination by EPA personnel of the population
served/distance to water intake downstream.-5 factor reduced the score
from 20 to 16 tp reflect 829 persons potentially exposed by the use
of water withdrawn to irrigate 552.7 acres 2000 to 2500 feet
downstream. . - ;
Teledyne* stated thatf the target score' for thec air route^ was too
high because, there is no health concern to the population from the
slight release of radon gas. ,, ; .,j.. ;.
In response, EPA has documented data gathered fs$m,alph^a-track
detectors which were placed at eight locations^ over a 2 month t
sampling period in 1980. A ฃotal of 10 iof- the 13 recorded measure- .
ments were eithe.r at p.r above background..-levels.: 3!he release^ is ;
therefore substantiatied^ Values assigned;-to pppulation. potentially
affected by. these releases were derived in -accprdance with
11-15 f
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instructions in the HRS (47 FR 31238). The value for distance to a
sensitive environment has been reduced from 3 to 2 as was done in
the surface water pathway to reflect the fact that the distance to
the freshwater wetland is 300 feet.
The Friends of the Earth expressed concern about the site and
requested information about EPA actions under CERCIA. Listing on
the NFL makes a site eligible for remedial action funding, and EPA
. " ..-,. 5;
will examine the Teledyne Wah Chang site to determine an appropriate
response. The Friends of the Earth provided no technical data that
would alter the score.
The original HRS score for this facility was 48.15. Based on
the changes noted above, the HRS scores for Teledyne Wah Chang are:
Ground Water 44.90 .
Surface Water 47.27
Air 67.56
Total 54.27
11-16
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11.6' Commencement Bay, South Tacoma..Channelป Tacoma, Washington;
11.6.1 'List of Cdmmenters..) -j ..:-
NPL-L16 B. Blanchard, Bisector, ^Environmental Project Review,
U.S. Department of Interior. 3/17/83
11.6.2 Summary of Comments and Response
The commenter noted land and water contamination on the
Puyallup Indian Reservation. The information was already evaluated
in developing the HRS site score.
The original migration score for this facility was 54.63. No
new technical information was submitted and no change in score was
required. The HRS scores for Commencement Bay, South Tacoma Channel
are:
' - - i* - - ^f
Ground Water 93.88
Surface Water 10.91
Air 0
Total 54.63
11-17
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11.7 FMC Corp., Yakima, Washington
11.7.1 List of Commenters
NPL-186 Matthew T. Grover, Director, Environmental Planning :
Department. FMC Corporation. 2/22/83.
NPL-285 Donald Moos, Director, Department of Ecology, State
of Washington. "2/24/83.
NPL-L16 B. Blanchard, Director, Environmental' Project Review1,
U.S. Department of Interior. 3/17/83. ......
11.7.2 Summary of Comments and Response _;,....
FMC stated tna-t the'HRS is, seriously flawed. In response, ict..,
is noted that the HRS is Appendix A of the promulgated National
Contingency Plan and* was proposed for public comment prior to its
promulgation. -"'.- .
FMC presented several arguments to demonstrate that the
t - - - *, .. ' ''
population using the ground water is 765 as opposed to 55,000. They
stated that the City of Yakima.only utilizes ground water for
emergency back-up-supply.and that.these wells have not been used^in
over 3Cyears. They further state that these wells, the domestic
wells in Yakima, and the City of Union Gap wells are either,located,
up-gradient or in a deeper aquifer than the aquifer of concern. In
response, the HRS considers all operable wells in a 3-mile radius,
regardless of frequency of use,. Even whe^e the ground water source
is not currently being usซd, the existence of a well with the f
capability'of supplying a given,population indicates that thevground,
water is a valuable, usable drinking water resource, the
contamination of which would be a significant loss. Furthermore,
11-18
4
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studies Indicate a hydraulic connection between the shallow aquifer
and the deeper Ellensburg formation. The entire population drawing
drinking water from both aquifers within 3 miles of the site was
appropriately included; Because tff '-the need to develop* a nationally
uniform scoring system t:Kat could be use'd-'to score a la^rge'"number of
sites,with the data commonly available, the HRS does not
'-'"I' 1 1 "I" '. - - 5- " !- ,-
~ ' - '- ! - c ' -' ~- -
specifically take intb" account sucR-level- oฃ detail as flow
gradients when determining:, the ,;ta.r^|t_^)p^fl.atloa. TMst position is
explained more fully ihtfee preamble? t a .the .fiaaj. National;,:;,
Contingency "Plan at 47 PR "31190" (July--16:,r. 19B2Xv: However,^ฃhe -.
rating Values assigned to population wtthip-a. three. miJfe ,radius were
established taking into account the likelihood that, because of, , .,
ground water flow, only a portion ฎf-that population would be
affected. Agency review of the documentation for thissite revealed
that there are several 'domestic wells- wiฃMnc-1000 feet of the site
f, f - , .
as compared to within 1/2 mile aง previously referenced* Thi9:, - ,,-
raises the'distance to nearest well/population,served factor, from a
val\ie~ of35Jto: 40. " '- : . . i_ - u.
FMC correctly noife'd that the population/distance value fpr
surface water "should be 6 rather than 10 (apparently .a-typographical
error) and "the score has-been'changed ad
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liquids were disposed at the .site. This information had been .;
documented correctly but scored incorrectly in the proposal..
FMC stated that they had,been told-by EPA:thatrtheir site was
of low priority, and the Washington Department of Ecology noted that
FMC has taken remedial actions and~that serious contamination of the
ground water is now unlikely. Both commenters state that the site
should be deleted from the NFL. In response, initial information
collected by EPA in an overview study appeared to show that limited
-: -- - '-' - - - ' " . i.r . ; _' -.--- -vrr-i,
contamination would present low priority problems at the site.
However, after detailed studies were initiated by EPA and new data
were collected and analyzed, the site was then scored based on its
potential hazardous environmental impacts. It is .noted that
' ' i * V : rf
facilities are scored to reflect site conditions prior to any
remedial action/.- In addition, EPA's current policy is ..that if the
HRS score places a site on the NPL, the site must remain on the list
until EPA-determines that no further response actions are..-,
appropriate, or any other.criteria-for deletion are met5 as
discussed in Part VIII of the preamble to the final NPL.
"The UvS..Department of. the Interior noted potential-
contamination of ground water that is used for drinking on a nearby
Indian reservation. This concern-was reflected in the original site
- f
score.
'-'-*" . * _j ' _ . V* 7 '> -" " "
The original HRS score for this facility was 32.18. Based on
the changes noted above, the HRS scores for FMC Yakima are:
Ground Water 66.67
Surface Water 7.83
Air 0 - - -
Total 38.80
11-20
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11.8 Harbor Island -(Lead), Seattle, Washington;
11.8.1- List'of Gommeaters " ;, -.
NPL-199 '!*.P. Hime-, Chief 1 Chemist, Technical Services
Department, RSR Corporation. 2/25/83.
11.8.2 Summary of Comments and Response
*"' ' "' -""^~tT ~ ' '. ': ' -' c, >':..
The commenter commented principally that the quantity of
''---- r .'1.. - v.. ; . , :..^:ij ,, ,:
hazardous waste was overstated and should have been scored a 4
1 ..,-." ^ Z .. ซปc Ifv.
rather than an 8. The data have been reviewed and the value of 8 is
appropriate for 3716 tons of hazardous material. The calculations
.'.'.'', Jti. ' ..."".?,'. ~^. "v -f. ,--. -
used to derive this figure differ from those proposed by the
"*'' ' - * - '~' . . * "" ' . v .; i'WT
commenter in that:
'-..'. '. " ;, - -..', -' ; . i _. _
o a soil density of 1.8 g/cc used to convert volume to mass
is more-appropriate .than the .I', ton * 1 -cubit* yard -rule of, ,t
thumb used by the commenter
T '- - --i - "J '- '. r, .^ : -, ..'i . , ,fc-.
o the commenter did not consider the total quantity of
hazardous waste (fly-ash containing !35,percent lead).
Instead, the quantity of lead alone was used. This is not
" inl accordance with the HRS. As explained InaBart 73^1-of
the preamble to the final NFL, waste quantity includes all
waste deposited at a*esite*.not just thfe quantity of. . .,/:.-.
hazardous constituents in the waste. As the waste was
deposited in the form of flyaah, the appropriate waste ;
quantity is the quantity of flyash.
_ > .- ', .1 v*1-
o the depth of contamination is six inches rather than the
three inches proposed by the commenter. The.contamination
is confirmed to the 6 inch depth.
' ' ~ ' $'' "-' r '- - - ' t " ,. . ./(_ .- 3.
o most current data show the average lead content in the soil
-*-'-: -to be 3.4 percent as opposed to "the 1.35 percent - suggested
by the commenter.
The total acreage over which the waste was deposited is
~l "J': <: "- ' '" ' -- - ^ -. -. -- , : ._ : >'
changed from 40 acres used by the original scorer to 31.26 acres on
- ' 3C , ' :)-,.'. ,,v " . ;- ;-, .. -
the basis of data presented by the commenter. This change is
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reflected in the waste quantity calculation.
The commenter assigned the toxic!ty/persistence of lead.a 15
rather than an 18, and the toxicity of lead by the air and direct .,
contact routes a 2 rather than .a 3. . The correct values are 18 and 3
according to HRS scoring instructions. .. .,
The commenter assigned the depth to aquifer of concern for the
ground water route 0 because the ground.water is not used. In
response, lack of usage is irrelevant to the depth.factor and is
accounted for in the usage factor. The depth is nearly 0 .feet and ,
the correct value is a 3.
The commenter assigned the target population by the air route
a 27 rather than 30. Agency review of current information from the
Puget Sound Air Pollution Control Agency indicates that the
population potentially exposed within 1/4 mile is 2500 persons;
therefore, the correct value is now 24.
The commenter proposed revised scores for the fire and
explosion worksheet and the direct contact worksheet. The total
site score and the site's eligibility for inclusion on the National
Priority List is based solely on the ground water, surface water,
and air routes of exposure, and does not consider the direct contact
and fire and explosion pathways. However, the comments have been
taken under consideration. The commenter changed the fire and
explosion route from 0 to 5.83. However, in accordance with Section
7.0 of 47 FR 31239, the fire and explosion route is scored only when
11-22
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the site has been certified by a fire marshalr as 'presenting-a
significant threat "or-there is a demonstrated threat'based on field
observations. The"correct value is therefore 0. The'direct contact
route was changed "from 5(5 to 22.22 by the -commenter, who stated that
no documentation exists for the observed incident. 'rEPA "references :
documented cases of: elevated lead levels in wo"rlฃฃrts'children and
families. The^dlrect contact route score, therefore,"is 50.00v
The original-HRS score' for this facility wts 41.79. Based on
the changes noted aBovej the HRS scores for Harbor Island ฃead are:
Ground Water 0 -j re-
Surface Water 10.91
v Air " ' 58.85' '-' :^ =- ' ' '> - ~
Total 34.60
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11.9 Kaiser Mead, Mead^ Washington . , , , '
11.9.1 List of Commenters.. ...... . , . ..,,
NPL-139 J. V. Day;, ^ice.President, Corporate ,,-,,;.
Environmental Affairs, Kaiser Aluminum and
Chemical Corporation,. 2/14/83.. -, . .
NPL-285 Donald. W^Mops,. .Director, Department of Ecology,
State "of Washington. 2/24/83.
11.9.2 Summary of Coimnerits'and Res'ponse
' -,i., .-' ".: - - i ,;?..", f . : -. <, , ",:>v' , .. ". i '.
The State of Washington requested that this facility be
deleted from'the tipl* since Kaiser Aluminum is"financially capabe of
responding to the problem and has been actively working to resolve
the ground water contamination, in response, CERCLA does not
indicate that the ability of a private party to clean-up a site is a
i , . , ', :'..' : "*c' . .. '"',<'. = ' ."?;
criteria for determining priorities. As implemented by EPA, sites
-.: .- '.-.. '.': :. : . v ' ' .5,:-"
are listed on the NPL according to whether they meet criteria
published in the National Contingency Plan, July 16, 1982. The
Agency evaluated the Kaiser Aluminum, Mead Works facility on the
basis of these criteria and has determined it eligible for inclusion
on the NPL. The ability of Kaiser Aluminum to respond to the
problem will be taken into ^account by EPA in determining the
appropriate actions for cleanup of the site.
Kaiser Aluminum and Chemical Corp. stated that the use of a
3-mile radius to describe population at risk from ground water
exposure is arbitafy and results in an incorrect score. Contam-
ination is claimed to be confined to a narrow band about 2.5 miles
-------
long exposing only IS families to totaJ^'cyanid* levels in excess of
0.2 mg/1 due to contamination of the a<|*&ฃeฃ.- -
Section 3.5 of the HRS sta'ters that the ground water target
- > *ฃ*..-. , .: ,j i -r ". . - :irrr
population is determined by the Veil or "Wells "within three miles of
f 1 <- .- ' f- ? O t
the hazardous substances." This"radius was dhosen as a general
J ,V' 4 +-1. $ ', . . .,
estimate, applicable to all sites, for purpose of scoring the range
if""''! ฃ '' " '_ J C ''>.*' * ' : *"" *"* > , >
within which grpund water may be affected. The relative value the
-=' ,-.."'.?- ;, , - " ' . JK . . ' ' ,'J i>J<~ . '
HRS assigns to various sizes of population .already takes into.
account, without the need for specific data on ground water flow,
-' ' - * .'-' ' - ~~!" '- 'f - - '
the likelihood that not all the people using water within that area
' " .' ' . : . I >~, -V . ." 3
will be affected. In any case, the three mile radius and the
relative values to be assigned are set forth in Section 3.5,.47 FR
31229 (July 16, 1982), and have already been subject to public
comment and promulgated. Underground flow gradients are not
considered, for reasons explained in Part VII of the preamble to the
final NFL. Based upon these instructions, the population is
'" i ,- . ',"' ~n i.i. . r . -ซ'. " ->ฃ-' '" .'. :,-.'".' * :?.' 1 :
correctly established at 5491 people. This population, in
conjunction with the distance to nearest well factor (assigned a
value of 3 for 3/4 to 1 mile), yields a matrix score of 32 rather
O r'.w " ..."-' .' ; '
than 24 as originally calculated; the difference based solely upon
correction of a previous calculation error.
- -.ซ . '", . ."l . f: '. r > .5 :.*,~!C . . ' Jv . , '
The commenter further contended that the principal contaminant
ซ . ^" v :, 3-".r: :.* .-, ' s' J; . ., ' - - : . - ' " . '- . ) '
is a relatively non-toxic complex metallorcyanide which,cannot
disassociate in the aquifer. The commenter suggests that the
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toxicity value should be no greater than 1 and that the toxicity/
persistence value should be 6 r-atheซ---thaa' 18 -de adsiga&d-.-^-.:.,:
In response, the toxieity^pera^latence-va-itte ~wa* baSedcdn'"the
contaminant, total cyanide. Section-3-*4- of -47 -FR-4i229 States'that
the"most'hazardous substance at the^facility that could migrate to
the ground , or ..surf ace. water, is-.used-to., de|ermine, the waste _ , -,,
characteristics score. Therefore, the toxicity value" for total
cyanide is 3 and the persistence, value is 1, resulting in a matrix
score of 12. ,,,_. ; r r_f .. ,u - -, - .^ ,. .. , <
, Kaiser.Aluminum^claimed that the targets score for .surface
water should- be,4 rather than., 13. The surface watfr -use has been
rescored frpm 3, .ta 2~ becaus^. the use. of, the- springs for domestic
water has been dropped as a,part of the.surface water scoring. . M
Although no, manrmade wellhead is used, the,.character of -the water
reflects the ground water route rather than the surface,, water -. ,
route. Data do show, however,, tha%. the Little. Spokane ฃ.$yei; is used
for. irriga,tipn4 thereby, resulting, JLn the, scpre ,o,f 2,. Jhis ctiange
lowers -the,sujrface water targets, value from. 13 to 1Q., - , ,,.
The .original HRS score for this fa.cility was ^.2r6;. ... Based .on
the changes, noted ,^boye, the B^S ,scopes for^Kaiser Mead ..are: ,
.
Surface Water 13.99
. ,, ,_ . .
Total 38.07
; .'; .. ; .-, . ' :C', ,.!.; -j:j :.*- -;.-;. 3 -_".
11-26
TS- n
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11.10 Pesticide,.Pit. Yakima. ..Washington - . .e.
"^"^*^!*"i^H"W^^ \ ' r !r . 7" * ฃ
, Renamed;., Pesticide Lab. .Yakima, Washington
-> - :>ซ:^.ป, .' f >' -it j.. ' L' f j r ".''.* "_. i.. *".? ,' ..-1 i
11.1041 .Lis|: of Cotnmenters
'-.. . r-'I.-j >?; ..IE : * ' *';.> :::--. -. . ,r ^.trf. '
.. NFL-28,5 D. W. iJoos, IJirectpr, Department of Ecology, State of
' ' 4" Washlngtbn. -'2/24/83. 'ฃ "' " ' '-' :fec' ~'
NPL-Fl ^tf. t'^COX, '!le|ional iatainistratbr, Agricultural7 T* ^7
Research, Western Division, USDA. 2/17/83.
"; " -.ฃ-.' f~-. '- =- c iv'-i.-, T. :." . - ..-;. i.j "&lii,:. .. -a-.d'
NPL-L16 B. Blanchard_, Director, Environmental Project Review,
-: -r ;;:U.S.5 Department of'lnteribr/- 3717/83; ; ;- c r-0i"
11.10.2 Summary of Comments and Response
The State of Washington noted thati; the Agricultural1 Research
Laboratory is a' Federal facility and cannot' W placed on the NPL. '
In response, thiis site is* on^ieasetrian^and^ therefore, is "- - Jfc
appropriately incl&dfed otf '-the NPL. "The : exclusion clause1 for ^federal
facilities currently applies1 only to1 land esfeluslvely owned- by ;the
federal government. ;" : ~: ' ' ' - -"* -' - ~
The USDA tolnneTiteT noted that" the* aquifer appears tt> be
deeper^ than ^21 feet, Viit did not present1 aiiy technical b'a'sii^ ^bt3 his
conclusion. In response, the" HRS scoring" instructions' dttfin^ "the
depth to "the dquif ef <>f concern" as the vertical measure :f rom the
lowest point of the hazardous subifftancPe to" the highest seWonVr"" -' '
level of the saturated zone of the aquifer^of concerh". ^Ttfe ;v^2tue of
,.t "^ J W i_-ฃl*^i;r
3 was assigned for an estimated distance of 14 to 19. :~
The USDA commenter noted that no DDT has been used at the
site since 1967 and that the value of 18 for toxicity/persistence
istoo high. In response, a number of pesticides disposed to the
11-27
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drain field, regardless of when they were disposed, warrant a value
.!-.'--. -- '-'-,*:. :.r::. Tin-;- ?, i ฃ. \L .-^iv. - ;f '.; ~sc.r
of 18 for toxicity/persistence. Specifically, lindane is an, example .
y~,...;r. ;,: .;ฃ t , ซ !' -" : .. ~_ '... ''.:^~. -,~l. ."?- ฃ=1 '
of such a pesticide.
.- ; .. \i i . . :.*.llc: I":-. .~~ ,; f r -.. .".;- "ฃ3?v; ;/,,:- r,v' ';
The USDA commenter disputed the ground water targets value
",-,' - , ',- ' _ - ;;,,./ r,'"'/- ."" r,?, ' "?;*-' i> - "' -!"" ""' ' ~"- " ~SJ"f
stating that there is insufficient justification for the score. 1st
r:': .> ur- " - ..o.. J :" . . err ;c-,.t:.- T : : -- - ' v i ฃ>ซ...: *c' '3v-' R-v
response, the values of 3 for ground water use and 35 for distance
I.. ; :.*:;*-at ... ' .ฃ'. .' s-.'r: * ' : :nc .lr^..r:ift.:.fc ?>;' ^ ^ or
to nearest well/population served are considered appropriate
the fact that a backup well serving the entire population pฃ Jakima
lies within the 3 mile radius. - . -..
With respect to the surface water route, the USDA_commenter ,
noted that the drain field containment value should be reduced
either to 0 or 1 stating that, since it is a covered underground
system, it should be compared to: (a) a landfill with adequate
" ""., "".f . ,, ' " T1 '
cover material, receiving the score of 0; or (b) a waste pile, piles
covered, waste unconsolidated? diversipn or containment .system not
adequate, receiving the score of 1, The commenter further states ^
that the value of 2 for distance to surface water is not appropriate
since the contents of the drain field do not reach any tsurface
streams via runoff.
In response, the value of 2 for distance^ to nearest surface
water is correctly based on a distance of 2000 feet. The Agency
believes that the potential for surface runoff to the creek does
exist should there be any over-flow. Determining a value for
,jr-' fv . .. - . Jr -1': *.<-?- ??Ii-. s.i- ":'- ??:.: f- ^ ^- -."riii
containment under the surface water route is difficult since the HRS
11-28
o <,. ;
-------
doeVnbt specifically address subsurface septic tanks with drain-
fields. ~ the "drainfi'eld is just below the surface and has no runoff
diversion system and no surface runoff collection system should
there be any overflow. The Agency believes that this rating factor
is Vest assigned a value of 3 to reflect the situation in comparison
to the HRS"instructions for scoring surface impoundments and
landfills." ^ ""'' '* '" * '"""" '"'"""' '"**
' * "During" the" Agency review of the documentation for this site,
the surface water population served/distance to water intake factor
value was changed. The population served remains 101 to 1000 (747
persons) but the distance,"originally thought to be 8000 feet, has
- ,_ , ,; , - ., _.,. ,: s;r . l.: 7;, -..rlSU ^i*tif..: .:-,*..;<- i. TSI
cooperating "in*efforts to resolve any potential problems and,
therefore, should"be deleted from the NPL. In response, EPA's
current policy is that if Vhe HRS score places a site on the NPL,
,"tl -_ <..:-,- l' , liJc ฃ.., fJio, "ST-* *: - -. '-- v -T -" r.affl';JB:-
the site must remain on the list until EPA determine that no further
11-29
-------
response actions are appropriate, or any other criteria for deletion
are met, as discussed in Part VIII of the preamble to the final NPL.
The Department of the Interior supports listing of this site
on the NPL. The DOI noted that pesticide (DDT) contamination in the
Naches River is affecting an Indian fishery and there is a potential
ground water pollution problem.
In response, the commenter did not submit any technical data
to link pesticide contamination in the Naches River to the Pesticide
Lab. Any reported fish kills are not addressed in the NPL. The
Agency believes that the potential for ground water contamination
has been properly evaluated through the ground water pathway score
and supporting documentation.
The original HRS score for this facility was 33.50. Based on
the changes noted above, the HRS scores for Pesticide Lab, Yakima
are:
Ground Water 48.12
Surface Water 16.12
Air 0
Total 29.33
11-30
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