X
v
United States Office of
Environmental Protection Emergency and
Agency Remedial Response
SERA Superfund
Record of Decision:
Pagano Salvage, NM
EPA/ROD/R06-90/058
September 1990
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-90/058
3. Redplerrft Accretion No.
4. TMeendSubme
SUPERFUND RECORD OF DECISION
Pagano Salvage, MM
First Remedial Action - Final
5. Report Dele
09/27/90
7. Au*or(i)
(. Performing Orgenlation Rept No.
9. Performing Orgtinlzatfon Nun* »nd AddiM*
10. Protect/Tuk/Work Unit No.
11. ContrmcHC) or Gr«rrt(C) No.
(C)
(G)
12. Sponsoring OrgmiuUon NMIM and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Typo ol Report * Period Covorad
800/000
15. Supplementary NolM
1*. Abetect (Unit: 200 worde)
The 1.4-acre Pagano Salvage site is in Los Lunas, Valencia County, New Mexico, and
consists of a family-run salvage business and a residence. During 1983, salvage
operations at the site included purchasing "high technology" scrap material from Federal
facilities such as transformers, drums containing waste fluids, and capacitors. Site
inspections in 1984, 1985, and 1986 revealed several areas of soil contamination in the
yard due to leaks from scrap materials, which released PCB-contaminated oil into the
soil. These areas included two surface burn areas, a stained soil area, and a surface
pool of oil. In 1990, EPA removed approximately 5,100 cubic yards (i.e., soil in excess
of 10 mg/kg PCBs based on TSCA cleanup policy) of contaminated soil and debris for
disposal in an approved RCRA facility offsite. Soil containing less than 10 mg/kg PCS
was covered with a 10-12 inch soil cover. Soil sampling has confirmed that this removal
has resolved the PCB contamination at the site and EPA proposes no additional remedial
action. Based on this rationale, there are no primary contaminants of concern affecting
this site.
The selected remedial action for this site is a no action remedy with ground water
monitoring for one year at the request of the State.
PERFORMANCE STANDARDS OR GOALS: Not applicable.
17. Document Anelyeie a. Oeecriptere
Record of Decision - Pagano Salvage,
First Remedial Action - Final
Contaminated Media: None
Key Contaminants: None
NM
edTorme
e. COSATI FMoYGroup
1*. AveJIeMKySUM
19. Security due (Trite Report)
None
20. Security Oaee (Trite P»go)
None
21. NbolPegee
21
22. Price
(See ANSI-Z3*.ia)
SM ftMtruclfone on tt» wne
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-3S)
Dtp*v%rwnt of ConMMf CA
-------
DECLARATION FOR TEE RECORD OF DECISION
FAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
SEPTEMBER 1990
Further Action Not Necessary For Protection
And Five-Year Review Is Not Required
SITE NAME AND LOCATION
Pagano Salvage Site
Los Lunas, Valencia County, New Mexico
STATEMENT OF BASIS AND PURPOSE
This decision document presents the rationale for determining that
further remedial action will not be required at the Pagano Salvage
Site. This decision is in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 as
amended by the Superfund Amendments and Reauthorization Act of
1986, and the National Contingency Plan (40 CFR Part 300). The
decision is based on the administrative record for this site, and
includes the results of the removal action conducted by the
Environmental Protection Agency's (EPA's) Emergency Response Branch
from June 1989 through January 1990.
DESCRIPTION OF EPA SITE ACTIVITIES
EPA's remediation activities at the Pagano Salvage site consisted
of removing approximately 5,100 cubic yards of soil and debris
contaminated with PCBs in concentrations exceeding health-based
levels. Remaining low levels of PCBs (less than 10 ppm) were capped
with a minimum 10 to 12-inch soil cover. All contaminated soil and
debris removed from the site were disposed of at a permitted
facility authorized to receive such wastes pursuant to the Toxic
Substances Control Act (TSCA) and the Resource Conservation and
Recovery Act (RCRA). Detailed information on EPA's removal
activities at the site are contained in the On-Scene Coordinator's
report titled "Emergency Removal Action", dated August 10, 1990.
The removal action meets TSCA cleanup standards for nonrestricted
access areas contaminated with PCBs and for residential
nonrestricted access requirements as outlined in EPA's Guide on
Remedial Actions at Superfund Sites with PCS Contamination, dated
July 1990.
-------
DECLARATION STATEMENT
The removal action conducted by EPA from Jure 1989 through January
1990 at the Pagano Salvage site is protective of human health and
the environment and complies with Federal and State requirements
that are legally applicable or relevant and appropriate for sites
contaminated with PCBs. During the removal action, EPA evaluated
various remedial alternatives prior to selecting off-site disposal.
These planning activities combined with the fact that all
contamination above health-based levels was removed, negated the
need for a remedial investigation/feasibility study at the site.
The removal action addresses all concerns associated with the high
concentrations of PCBs at the site and provides for unrestricted
residential usage. Therefore, consistent with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1986 as
amended, and the National Contingency Plan, I have determined that
as a result of EPA's removal action conducted from June 1989
through January 1990, no further remedial action will be warranted
at the Pagano Salvage site to ensure protection of human health and
the environment.
Because remaining PCB concentrations do not exceed health-based
levels, the five-year facility review will not be required at the
Pagano Salvage site.
The State of New Mexico, through the New Mexico Environmental
Improvement Division, concurs with EPA's no further action
proposal. EPA Headquarters also agrees with the recommended
proposal.
At the State's request however, a minimum of one more set of ground
water samples will be taken from the onsite monitoring wells and
the surrounding residential wells. Based on the results of this
sampling, additional sampling may be conducted. EPA will sample up
to a year after the Record of Decision has been signed. After the
one year period, additional sampling, if necessary, will be
conducted with State funds.
Robert E. Laytdn Jr., P.E. Date
Regional Administrator
U.S. EPA - Region 6
-------
DECISION SUMMARY
PAGANO SALVAGE SITE
RECORD 07 DECISION
SEPTEMBER 1990
-------
TABLE OF CONTENTS
Title Page
I. Site Name and Location 1
II. Site History and Enforcement Activities 2
III. Highlights of Community Participation 3
IV. Response Action 3
V. Site Characteristics Before Remediation 4
VI. Summary of Site Risks After Remediation 5
VII. No Further Action Recommendation 6
VIII. Documentation of No Significant Change 7
IX. Remedy Selection Criteria .' 7
X. Responsiveness Summary 8
LIST OF TABLES AND FIGURES
Table/Figure Page
Summary of Site Activities, Table 1 14
Location Hap, Figure 1 16
Site Map, Figure 2 17
-------
DECISION SUMMARY
FAGANO SALVAGE SITE
RECORD O? DECISION
I. SITE NAME AND LOCATION
The Pagano Salvage site is located at 102 Edeal Road, Los
Lunas, Valencia County, New Mexico (Figure 1). The site is
used to operate a salvage business and as a residence for
Mrs. Mary Pagano. The site covers approximately 1.4 acres and
is bordered by Edeal Road to the east, residential property
to the north, the Peralta Riverside Drain to the vest, and the
Wittwer Lateral to the south (Figure 2). The Peralta Riverside
Drain converges with the Otero Drain approximately 1.5 miles
north of the Pagano site. These drains are part of the Rio
Grande drainage and flood control network. A 10-foot high
flood control levee is located just west of the Pagano site,
between the Rio Grande and Peralta Drain. The Wittwer Lateral
is an interior irrigation return flow ditch. The Pagano site
is generally flat with a ground slope of less than 5 percent.
Surface water runoff from the site flows west to southwest
into the Peralta Riverside Drain.
The ground water table at the site is generally encountered
at 5 to 6 feet below ground surface but varies seasonally with
the water levels in the Wittwer Lateral. Ground water
elevations taken from the monitoring wells, Wittwer Lateral,
and Peralta Riverside Drain indicate that the ground water
flow is generally froin east to west towards the Peralta Drain.
Additionally, the ground water readings indicate that the
Wittwer Lateral acts as a ground water recharge to the area
east and south of the site. The Pagano site is located on two
major aquifers. The uppermost aquifer is located in a Rio
Grande floodplain alluvium deposit approximately 120 feet in
thickness and consisting of sands, silts, clays, and gravels.
The Santa Fe Group aquifer underlies the floodplain alluvium
deposit and is 500 to 5000 feet thick and composed of
terrestrial sediments consisting of interbedded sand, silt,
clay and conglomerate. Based on geological conditions, the
two aquifers are apparently in complete hydraulic connection.
Local private wells located near the Pagano site area
typically range in depths from 40 to 160 feet. Other ground
water wells within a 3-mile radius range in depths from 200
to 600 feet.
The Pagano site lies in a rural area of scattered farms and
residences. Agricultural land uses consist of cattle grazing
and cultivation of alfalfa for use as cattle and horse feed.
-------
There are no known grain crops or vegetable crops for human
consumption raised in the immediate site area. Outside of the
Pagano Salvage operations, there are no other industrial or
commercial activities within one mile of the site. Approxi-
mately 30 persons live within a one-half mile radius and there
is a total residential population of approximately 1000 within
a two mile radius of the site.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Mr. Carmen Pagano began the salvage business at the site in
the early 1960's and ran it until his death in 1982. Following
Mr. Pagano1s death, the business was acquired and is still
operated by his stepson, Mr. David Peluchette. The upper third
part of the salvage site was leased from Ben Smith and the
rest is owned by Mrs. Carmen (Mary) Pagano. Salvage operations
at the site consisted, in part, of purchasing "high technol-
ogy" scrap materials from Federal facilities including the
Rocky Mountain Arsenal, White Sands Missiles Range, Kirkland
Air Force Base, and Sandia National Laboratories (SNL). In
June and July 1983, Mr. Peluchette purchased transformers,
drums with waste fluids, and capacitors from SNL as part of
a salvage lot. Several of the transformers and capacitors, and
possibly fluid from 55-gallon drums, leaked polychlorinated
biphenyl (PCB) contaminated oil while they were stored at the
Pagano Salvage site.
A Resource Conservation and Recovery Act site inspection
performed by the New Mexico Environmental Improver ant
Division (NMEID) in September 1984, identified several areas
in the salvage yard that were contaminated with PCBs. These
included two surface burn areas (where wire was placed on the
ground and its insulation burned off using the contaminated
transformer oil) with PCB concentrations of 57 ppm and 96 ppm,
a stained soil area with 130 ppm of PCBs and a pool of oil
with 590 ppm of PCBs.
EPA contractors performed field investigations at the site in
September and October 1985. These investigations confirmed the
presence of PCBs in site soils and identified salvaged materi-
als that contained waste oil contaminated with PCBs. All
salvaged materials containing PCB contaminated oil were
removed by SNL during several cleanup operations. PCB
contaminated materials stored at the SNL facility were in turn
disposed of by ENSCO, Sandia's PCB disposal contractor.
In March 1987, a Hazard Ranking System (HRS) analysis was
performed for the Pagano site. The HRS analysis is the method
by which EPA determines the eligibility of a site to qualify
for proposal to the National Priorities List (NPL). The NPL
is EPA's list of the most serious uncontrolled or abandoned
hazardous waste sites identified for possible long-term
-------
remedial response using money from the Trust Fund. The Pagano
site was proposed to the NPL on update 7 in June 1988 and
promulgated on October 4, 1989. A summary of site activities
is included on Table 1.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Proposed Plan for the Pagano Salvage site was released to
the public on August 15, 1990 and copies locally maintained
at the Los Lunas Public Library. This document was made
available to the public as part of the administrative record.
The administrative record was available for review at the EPA
library in Region 6 and at the NMEID offices in Santa Fe. The
notice of availability of the Proposed Plan and the
administrative record was published in the Valencia County
News on August 12, 1990. The public comment period was held
from August 15, 1990 through September 14, 1990. Although a
public meeting was not scheduled, a statement was made in the
published Proposed Plan that a public meeting would be held
if requested. Although no requests for a meeting were made,
EPA met informally with county officials and other interested
parties. A response to the comments received during the
public comment period will be included in section X,
Responsiveness Summary.
This document presents EPA's recommendation that no further
remedial action is warranted at the Pagano Salvage site, in
Los Lunas, New Mexico. This recommendation is made in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act (SARA) and, to
the extent practicable, the National Contingency Plan. The
decision for the site is based on the administrative record.
IV. RESPONSE ACTION
EPA's earlier response action at the Pagano Salvage site was
to address the PCB contaminated soils. The high concentrations
of PCBs (500 ppm or greater) present in on-site soils, prior
EPA's removal action, posed imminent and substantial risks to
human health and the environment, as documented by the action
memoranda, dated March 23, 1989, for the site. Additionally,
there was a potential risk of PCB contamination migrating from
the surface soils to the shallow ground water zone or being
transported by runoff to the adjacent surface drains. EPA's
removal action, detailed in the On-Scene Coordinator's report
titled "Emergency Removal Action", dated August 10,1990, and
discussed in this Record of Decision, mitigates the risk
associated with current and future ingestion, inhalation, and
dermal exposures to PCB contaminated soil at the site. By
removing the high concentrations of PCBs and capping
remaining residual levels (less than 10 ppm), the potential
-------
for PCBs to migrate into the ground water or surface drains
at concentrations above health-based levels has been
eliminated. Additionally, PCBs are highly insoluble in water
and have a hig
-------
pathways in which individuals could become exposed at the site
(assuming pre-removal conditions):
o Ingestion, inhalation, and dermal exposure to contaminants
in on-site soils,
o Ingestion exposure to contaminants which may migrate from
the surface to the ground water table,
o Dermal exposure to contaminants from off-site sediments
(if significant migration occurred), and
o Ingestion of contaminated fish from the Peralta Riverside
Drain (assuming significantly elevated concentrations were
found).
VI. SUMMARY OF SITE RISKS AFTER REMEDIATION
The remediation level for PCBs at the Pagano site was based
on the Toxic Substances Control Act cleanup level of 10 ppm
(assuming removal of 10 inches of soil and replacement with
clean soil). This level meets the requirements for
unrestricted access areas and represents approximately a one
in one hundred thousand (1 x 10 ) excess cancer risk. This
risk level means that one person in one hundred thousand,
assuming daily ingestion of .0001 kg/day of PCBs at a
concentration of 10 ppm for 70 years, is at risk of getting
cancer. This level is consistent with EPA's regulatory goal
of ensuring protection to an excess cancer risk of between
1 x 10"* and 1 x 10"6.
The need for additional remedial actions was evaluated based
on unrestricted residential usage as outlined in EPA's Guide
on Remedial Actions at Superfund Sites With PCB Contamination
dated July 1990. The guide recommends a soil cover at sites
containing over 1 ppm but less than 10 ppm PCBs to provide
unrestricted access at residential sites. The soil cover is
recommended because Mrs. Pagano has a residence at the salvage
site. EPA's removal action addressed all of these concerns by
removing approximately 5,100 cubic yards of contaminated soil
and debris and capping remaining low levels (less than 10 ppm
PCBs) of PCBs with minimum a 10 to 12-inch soil cover. These
activities will mitigate risk associated with ingestion,
inhalation, and dermal exposures to the remaining residual
levels of PCBs. No ground water contamination has been
detected and none is expected to occur since PCBs are highly
insoluble and have an affinity to soil particles.
During EPA's removal action, numerous soil samples were taken
during the different removal phases. Ground water samples from
the site monitoring wells were taken after the removal action
was completed. According to the test results, the contaminated
-------
soil was removed such that the remaining soil did not exceed
specified health-based levels (less than 10 ppm PCBs) and no
ground water contamination was detected. Therefore, the
potential exposure pathways for surface and ground water
were addressed.
Off-site sediment samples were also taken, primarily from
identified off-site flow pathways, and not found to contain
appreciable concentrations of PCBs (less than 0.5 ppm). Based
on these test results it was found, subsequent to the Health
Assessment, that these sediments did not present a significant
environmental or human health risk.
PCB concentrations were found in edible portions of fish
sampled from the Peralta Drain at levels generally below 1.0
ppm and up to a maximum of 1.7 ppm. These concentrations are
below the Food and Drug Administration (FDA) "advisory level"
of 2.0 ppm and well below the "action level" of 5.0 ppm. Since
the source of high concentrations of PCBs has been removed
from the site and the remaining low levels capped to
significantly reduce the potential for migration, it is not
expected that an increase in bioaccumulation will occur in
fish from PCB contamination associated with this site.
VII. NO FURTHER ACTION RECOMMENDATION
Under the Superfund Program, studies are conducted at NPL
sites to characterize the nature and extent of contamination
and to determine the most feasible cleanup approaches. At
this site, EPA's removal action (soil removal) conducted from
June 1989 through January 1990, achieved the environmental and
health based cleanup objectives. These objectives consisted
of removing all soil contaminated with PCB concentrations
exceeding TSCA's cleanup level of 10 ppm and providing for
unrestricted residential usage. By removing soils
contaminated with PCB concentrations greater than 10 ppm and
capping remaining low levels, the removal achieved the
remediation goals for the site. Therefore, based on the
removal action and past site investigations, no additional
cleanup alternatives are required and EPA proposes no further
remedial action at the Pagano Salvage site.
The State of New Mexico through the New Mexico Environmental
Improvement Division has concurred with EPA's proposal at the
Pagano Salvage site. With their concurrence, the State has
requested that additional ground water samples be taken from
the site monitoring wells and surrounding residential wells
to confirm that no PCB contamination of the shallow ground
water table has occurred. This ground water monitoring will
be conducted by EPA for up to a year after the Record of
Decision has been signed. Any sampling performed after the one
year period will be conducted by the NMEID.
-------
Request for deletion of the Pagano Salvage site from the
National Priorities List will not be made until the ground
water sampling has been completed and the samples show no
significant site related contamination. IF PCB concentrations
above health-base levels are detected, EPA in coordination
with NMEID, will address the site accordingly.
Long-term management controls with regard to maintaining the
integrity of the soil cover are not considered necessary.
Under a worst case scenario of cap erosion or loss of
integrity and subsequent human exposure, a significant health
threat would not result. Remaining soil concentrations of
10 ppm are within EPA's regulatory acceptable health risk
range, even considering a lifetime of exposure.
VIII.DOCUMENTATION OF NO SIGNIFICANT CHANGE
The Proposed Plan for the Pagano Salvage site was released for
public comments from August 15, 1990, through September 14,
1990. The Proposed Plan recommended, that as a result of EPA's
removal action at the site, no further remedial action was
warranted at the site. EPA reviewed all written comments
submitted during the public comment period. Based on these
comments, it was determined that no significant change to
EPA's proposal, as originally identified in the Proposed Plan,
was necessary.
IX. REMEDY SELECTION CRITERIA
The following evaluation criteria were used to determine the
effectiveness of the past removal action to adequately protect
public health and the environment.
Overall Protection. The EPA removal provides overall
protection of human health and the environment. The high
concentrations (500 ppm or greater PCBs) of PCBs were removed
to safe levels (less than 10 ppm PCBs) through excavation of
contaminated soil and replacement with clean soil. This will
provide for a long-term solution to the past PCB contamination
problem at the site.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs). ARARs are the Federal and State
requirements that a selected remedy must meet. EPA's removal
action met all of the Federal ARARs (TSCA cleanup action
levels and RCRA disposal regulations) for PCB contamination
removal. No State ARARs more stringent than Federal ARARs were
identified.
Long-Term Effectiveness and Permanence. By removing and
disposing of soils contaminated with PCB concentrations
-------
greater than 10 ppm in a RCRA permitted facility, the removal
provides a permanent reduction of contaminated *°ils at the
site and the soil cover will prevent/mitigate mobility of PCBs
(ability of the remaining low levels of PCBs to move to off-
site locations or to adjacent drainage ditches). Remaining low
concentration of PCBs (less than 10 ppm} meet health-bas--
level requirements.
Short-Term Effectiveness. The protection to human health and
the environment during soil removal operations was addressed
by restricting access to the site. Additional safeguards used
consisted of monitoring the air in and around the site to
detect and address air emissions during the cleanup.
Implementability. EPA's cleanup activities were relatively
easy to implement. Construction equipment for removal and
disposal of contaminated soils and debris are readily
available.
Cost. The estimated.cost of the cleanup and related
activities is approximately $2.75 million as of -Tune 1990.
State Acceptance. The State of New Mexico, through the New
Mexico Environmental Improvement Division, has concurred with
EPA's proposal for the site. Although no PCBs were detected
in the soil samples taken during and after the monitoring well
installation,respectively, the NMEID has requested that
confirmatory water samples be taken from the monitoring wells
and adjacent residential wells before requesting deletion of
the Pagano Salvage site from the National Priorities List.
Community Acceptance. Community acceptance of EPA's proposal
for the site was favorable and is included in Section X,
Responsiveness Summary.
X. RESPONSIVENESS SUMMARY
Valencia County officials and representatives for the Pagano
Salvage site agree that EPA's removal action removed site
contaminants to health-base levels and concur with EPA's
recommendation that no further remedial action is warranted
at the Pagano Salvage site. The New Mexico Environmental
Improvement Division has provided formal concurrence with the
proposed action.
Integration of Comments Received from representatives
(Attorney Peter V. Domenici, Jr. and consultant Douglas G.
Brookins) for the Pagano Salvage site on the Proposed Plan.
No comments were received from the local community or other
parties.
8
-------
1. comment: Mr. Peluchette also purchased drums from
Sandia National Laboratories (SKL), which
often contained fluids of an unknown nature.
Response: We agree that drums were also purchased from
SNL and this will be added to the report.
2. Comment: No mention is made of the areas at Pagano
Salvage Yard (PSY) where PCB-containing drums
were stored, and where high surface PCBs were
encountered. Further, it has not been confirmed
if PCB-containing oils were actually used to
burn insulation off wire.
Response: The contaminated areas referenced in this
comment are the areas that were initially
identified as being contaminated with PCBs.
Subsequent field investigations (part of the
Pagano administrative record) documented high
levels of PCB contamination at other locations
at this site. Based on the high PCB
concentration levels found at the burn areas,
it was concluded that oil contaminated with
PCBs had been used to burn insulation off of
wire.
3. Comment: If PCB levels of threat to public health were
confirmed in September-October 1985, why was
no immediate order given for site cleanup at
that time?
Response: Sampling performed in the Fall of 1985 was of
a preliminary nature. More detailed investiga-
tions were conducted from 1987 to 1988 from
which soil data was obtained at various depths,
sediment samples tested from the adjacent
surface drains, and water samples tested from
the surface drains and from the adjacent
Peralta Drain. The results of these detailed
investigations illustrated the need for
a Time Critical Removal Action due to the high
potential of contaminating the shallow ground
water table and adjacent drainage systems.
4. Comment: This statement (site formally added to the NPL)
ignores the fact that SNL posed a formal
challenge to the HRS score.
Response: The challenge posed by SNL was addressed in a
memorandum dated June 28, 1989, Subject;
Support Document for Final Rule #6. This
information is a matter of public record.
-------
Comment: There may have been PCBs in capacitors at
PSY, but, so, too, were PCB sources such as
transformers, transformer cases (one which
contained PCBs), fluid-bearing drums (and
possibly totally corroded drums).
Response: Drums containing waste fluids will be added
to the report.
Comment: No fish were tested away from the site drain
area, i.e. we (Pagano representatives)h ve no
idea what background PCB levels in fish are
up-and down-stream from the site. Without
this information, no origin-specificity can
be given for the PCBs in the fish as
reported.
Response: According to the information available, it is
not unreasonable to assume that the Pagano
Salvage site is the source of PCB
contamination in the fish sampled. Sediments
contaminated with PCBs were detected in at
least three locations in the Pe-alta Drain
immediately to the west of the agano site.
Since PCBs are known to bioaccuraulate in fish
and other aquatic organisms, it was
therefore, concluded that the fish sampled
may have been contaminated with PCBs found in
the site sediments. Other sourc-s of this
contamination are not readily E parent.
Comment: While PCBs were distributed widely at PSY,
they were not everywhere present at levels
in excess of 10 ppm (TSCA cleanup action
level).
Response: Correct. It was not stated that PCBs were
"present everywhere" in levels exceeding 10
ppm, the report states that PCBs were present
"throughout" the site.
Comment: No reason has been given for EPA having
waited four years before initiating an
emergency removal.
Response: Prior to conducting the remedial action,
additional analytical information was
necessary. Once this information was
collected and analyzed a decision was made
on the need for an emergency action.
10
-------
9. Comment:
After starting the removal process/ EPA
quickly over ran its budget, and a several
month delay resulted, with large piles of PCS
bearing dirt precariously positioned for
maximum off-site transport by wind, etc. If
the threat was so real, why this delay?
Response: The delay occurred in trying to obtain
additional funds to complete the removal
action. As the soil data summary indicates
(OSC's report), most of the soil contaminated
with high concentrations of PCBs had been
removed by the time the delay occurred. EPA
is unaware of information showing off-site
contamination occurred due to this delay.
10. Comment:
Response:
11. Comment:
Response:
12. Comment:
Response:
The ATSDR report should have been prepared in
1985.
The report was prepared as soon as detailed
site information became available.
The differences in the physiologies of mice
and rats are so extreme that laboratory
testing of one cannot be used to predict the
behavior of the other; and certainly
extrapolating either rat or mice data to
humans is unwarranted.
It is routine medical practice to test
potential carcinogens substances on mice and
rats to determine the potential affects on
humans. This is consist with EPA risk
guidance which often use data from laboratory
animals to estimate human cancer risks.
I (Pagano consultant) submit that the
exposures from eating, breathing and direct
touching of PCB contaminated materials are
far less than EPA suggests.
As detailed in ATSDR's Health Assessment
dated December 20, 1989, the site posed a -
current and potential health threat. This
information was used in concert with TSCA
regulations to determine the need for and
level of contaminant cleanup.
11
-------
13. Comment:
Off-site PCB levels have all been determined
to be slight, and in view of the virtually
complete removal of all PCB bearing soils at
PSY, it is totally uncalled for to suggest
any further PCB accumulation off site due to
material from PSY.
Response: This statement is correct. As stated in the
Proposed Plan and Record of Decision, since
the removal action ad:-essed the soil
contamination, off-site migration of residual
PCB contamination is not anticipated.
14. Comment: I (Pagano consultant) doubt "that a
significant increase in bioaccumulation of
PCBs in fish will occur", in fact it hasn't
been determined if filL Accumulation has
occurred.
Response: Although bioaccumulation was not firmly
established from the fish sampled, it is a
known fact that bioaccumulation of PCBs
occurs. The potential for bioaccumulation to
occur was evident due to the high
concentrations of PCBs present ar the site
and the fact that sediment samples, however
low, also identified PCB contamination.
15. Comment: I (Pagano consultant) am perplexed as to why
an additional groundwater study will be
carried out; the statements show no
groundwater contamination, and removal of
possible contaminants takes away the
source(s). Therefore, what is achieved by
more sampling?
Response: Ground water sampling will be conducted to
confirm that indeed no PCB contamination of
the ground water has occurred. One round of
sampling is inconclusive especially
considering the local stratigraphy and
potential for gradient reversals.
16. Comment: Pagano (Pagano Salvage Yard) questions why
additional ground water sampling may take 3
to 6 months.
Response: The time period mentioned for ground water
sampling is only an estimate. Sampling will
be conducted as work schedules allow and as
requested by NMEID.
12
-------
17. Comment: Were air monitoring results taken veil away
from site for background determination? If
not, why not? And if so, where are the data.
Response: Air monitoring results are presented in the
OSC's report dated August 10, 1990,
Attachment Gl and locations of air monitoring
station are shown on Attachment G2. Recorded
levels were below the National Institute for
Occupational Safety and Health exposure
limits of 0.5 mg/m .
13
-------
TABLE 1
BUMKXRY OF SITE ACTIVITIES
Date
Sept. 1984
Fall 1984
June 1985
Sept. and
Oct. 1985
March 1987
June 1988
Sept. 1988
Oct. 1988
Action Taken
NMEID conducts a RCRA
site inspection.
SNL removes 37 large
capacitors, a box of
small capacitors,
55 gallon drums
and an unknown
quantity of oil
stained soil.
SNL removes six
capacitors.
EPA conducts site
investigation.
EPA conducts
resampling at site.
Pagano site proposed
to the National
Priorities List.
EPA samples fish from
Peralta Riverside
Drain.
SNL removes additional
drums from site.
of Results
Several areas identified
that were contaminated
with PCBs.
PCB contaminated oil
in the capacitors and
drums was identified as
the source of
contamination and
removed .
Capacitors overlooked
during initial remedial
action were removed.
Investigations confirmed
the presence of PCBs in
the soil.
Resampling performed to
conduct a Hazardous
Ranking System analysis.
The site scores high
enough in the HRS
analysis to be
proposed to the NPL.
Fish found to have low
level concentrations of
PCBs.
Additional 55-gallon
drums containing waste
oil contaminated with
PCBs were removed from
the site.
14
-------
Date
Oct. 1988
June 1989
Action Taken
EPA conducts soil
sampling.
Summary of Results
Sampling shoved that
PCBs were distributed
throughout the site
surface soils. These
results prompted EPA to
pursue a Time-Critical
Removal Action for the
site.
EPA begins Time-
Critical Removal
Action.
Oct. 1989
Jan. 1990
Pagano Salvage site
promulgated to the
National Priorities
List.
EPA completes Time-
Critical Removal
Action (soil removal).
Aug. 1990
EPA issued Proposed
Plan.
EPA removes a minimum of
10 to 12-inches of soil
from the entire site. A
total of 5100 cubic
yards of contaminated
soil and debris are
removed and disposed of
off-site at a permitted
facility.
The Proposed Plan
recommends that no
further remedial
action is considered
necessary*
15
-------
16
-------
figurt 2
SPTEMAP
V»*ne« C«ui«lf -
17
------- |