V
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United States Office of
Environmental Protection Emergency and
Agency Remedial Response
c/EPA Superfund
Record of Decision
Vertac, AR
SEP 191934
EPA/ROD/R06-93/080
June 1993
PB94-964201
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VSj!77
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
1445 ROSS AVENUE, SUITE 1200
DALLAS, TX 75202-2733
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Vertac, Incorporated
Jacksonville, Arkansas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Vertac, Incorporated site, Jacksonville, Arkansas, which was
chosen in accordance with CERCLA, as amended by SARA, and, to the
extent practicable, the National Contingency Plan. This decision
is based on the Administrative Record for this site.
The State of Arkansas concurs with the selected remedy.
ASSESSMENT OP THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE REMEDY
This ROD is for the Vertac Onsite Operable Unit 1, which includes
most of the above-ground media, such as buildings, process
equipment, process vessel contents, spent activated carbon,
miscellaneous drummed wastes (including Remedial Investigation
wastes), shredded trash and pallets, and PCB transformer oils.
The major components of the selected remedy include:
Onsite incineration of F-listed process vessel contents,
shredded trash and pallets, and miscellaneous drummed
wastes (except Remedial Investigation (RI) wastes such as
used personal protective clothing and trash).
Off-site incineration of transformer PCB oils.
Onsite incineration and/or reactivation and reuse of
spent carbon.
If feasible, off-site treatment, disposal, or reuse of
demonstrated non-F-listed process vessel contents (such
as spent caustic, hydrochloric acid, kerosene/fuel oil,
etc.) or onsite incineration.
I.'"*' Printed on Recycled Paper
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Off-site recycle/reuse of decontaminated process
equipment (such as tanks, structural steel, pumps, etc.),
to the maximum extent practicable.
Onsite consolidation/containment of debris resulting
from demolition of buildings (except the supervisor's
office building, bagged soil storage building, and
wastewater treatment plant building that would be left
intact for continued use), and process equipment that is
not practicable to be recycled/reused, and some
containerized materials (RI wastes) in a RCRA Subtitle C
landfill.
Treatment residues - Incinerator ash and salt disposal
shall be consistent with the disposal of ash and salt
generated by onsite incineration of drummed wastes
currently in progress. The United States Environmental
Protection Agency (EPA) is in the process of developing
and selecting a disposal option for the ash and salt
being generated at the Vertac facility.
Decontamination residues - Onsite incineration of used
solvents, filter spools, etc. Onsite treatment and
discharge of contaminated water.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal
element.Because this remedy results in hazardous substances,
pollutants, or contaminants remaining at the site above levels that
allow for unlimited use and unrestricted exposure, EPA shall review
the remedial action no less often than every five years after
initiation of the selected remedial action.
Date *0& D*
Regional Administrator
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VERTAC, INCORPORATED
Record Of Concurrences For Onsite Operable Unit 1 ROD
M'. S. Ramesh, Remedial Project Manager
Superfund Enforcement - Ar/La Section (6H-EA)
Verne McFarland,Chief
Information Management Section (6H-MC)
For Peer Review Committee
Bill Luthans, Chief
Superfund Enforcement - Ar/La Section (6H-EA)
)
Sam Becker, Chief
Superfund Enforcement Branc
Mel McFarland, Attorney \
Waste Enforcement, ALON Section (6C-WA)
Pamela Phillips, Acting Chief
Waste Enforcement Branch (6C-W)
George R. Alexander, Jr.
Regional Counsel (6C)
Allyn M. Davis, Director
Hazardous Waste Management Division (6H)
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THE DECISION SUMMARY
VERTAC ONSITE OPERABLE UNIT 1
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TABLE OF CONTENTS
Section Title Page
1 Site Name, Location, and Description 1
1.1 Site Name and Location 1
1.2 Description 1
2 Site History and Enforcement Activities 5
2.1 Site History 5
2.2 Site Investigations 7
2.3 Enforcement History 9
3 Highlights of Community Participation 11
4 Scope and Role of Operable Unit 12
5 Summary of Site Characteristics 13
5.1 Land Use/Population 13
5.2 Geology 14
5.3 Ground Water 18
5.4 Surface Water 18
5.5 Remedial Investigation Findings 19
6 Summary of Site Risks 34
7 Description of Alternatives 39
7.1 Alternatives 39
7.2 ARARs 57
8 Summary of Comparative Analysis of Alternatives 72
8.1 Threshold Criteria 72
8.2 Primary Balancing Criteria 74
8.3 Modifying Criteria 77
9 The Selected Remedy 77
10 Statutory Determinations 84
11 Documentation of Significant Changes 89
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LIST OF FIGURES
Figure No^ Title Page
1-1 Site Location Map 2
1-2 Site Map 3
1-3 Site Process Areas 4
5-1 Land Use Zoning Map 15
5-2 Geologic Map of the Site 17
5-3 Location of Buildings 27
7-1 Conceptual Layout of Alternative 2 42
7-2 Storage Building Conceptual Design 43
7-3 Clay-Lined Consolidation Unit 45
7-4 Double-Lined Consolidation Unit 47
7-5 Conceptual Layout of Alternative 3 52
7-6 Conceptual Layout of Alternative 4 56
7-7 Conceptual Layout of Alternative 5 58
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LIST OF TABLES
Table No. Title Page
5-1 Site Geologic Formations 16
5-2 F-Listed Process Vessel Contents Analytical 21
Summary
5-3 Non-F-Listed Process Vessel Contents Analytical 22
Summary
5-4 Unknown Process Vessel Contents Analytical 23
Summary
5-5 Spent Carbon Analytical Summary 25
5-6 French Drain Leachate Analytical Summary 26
5-7 Building Wipes Analytical Summary 28
5-8 Building Dust Analytical Summary 29
5-9 Process Equipment Wipes Analytical Summary 31
5-10 Process Vessel Rinsate Analytical Summary 32
5-11 Containerized Soil Analytical Summary 33
5-12 Shredded Trash Analytical Summary 35
5-13 Shredded Pallets Analytical Summary 36
5-14 Transformer Oil Analytical Results 37
7-1 Estimated Capital and O&M Costs 49
7-2 Potential Operable Unit 1 ARARs 61
7-3 National Ambient Air Quality Standards 69
8-1 Individual Evaluation of Alternatives 78
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THE DECISION SUMMARY
VERTAC ONSITE OPERABLE UNIT 1
1. SITE NAME, LOCATION, AND DESCRIPTION
1.1 SITE NAME AND LOCATION
The Vertac, Incorporated Superfund Site (the "site") is located in
Jacksonville, Pulaski County, Arkansas. The site is approximately
15 miles northeast of Little Rock. The approximate location of the
site is shown on Figure 1-1 (United States Geological Survey (USGS)
Cabot, Olmstead, Jacksonville, and McAlmont, Arkansas, 7.5 minute
quadrangle map).
1.2 DESCRIPTION
Cultural features on the site and in the site area are shown in
Figure 1-2. The site is bounded by Marshall Road to the east and
the Union-Pacific Railroad to the west. Further west of the
railroad tracks, the land is used for industrial/commercial
purposes. The Little Rock Air Force Base occupies land farther to
the north. Residential areas are immediately to the south and east
of the site.
Land comprising the site consists of two parcels (Figure 1-2,
Parcel 1 and Parcel 2) that were acquired at different times.
Parcel 1, which contains the central process area, is approximately
93 acres and has been in nearly continuous industrial use since
1948. Parcel 2, which is approximately 100 additional acres to the
north, was purchased by Vertac in 1978. In 1979, the 2,4,5-T waste
storage shed was built. The storage shed was built adjacent to the
Regina Paint Building, which today is believed to contain the empty
Vertac 2,4,5-T waste drums. Parcel 2 does not contain production
facilities. The central process area is wholly enclosed within a
chain link fence that surrounds most of Parcels 1 and 2.
Topographically, the land has moderate relief, sloping from about
310 feet above mean sea level (MSL) in the north to approximately
260 feet near the southwestern corner. The central process area is
located on a flat-topped, south plunging topographic nose bounded
by Rocky Branch Creek on the west and Marshall Road on the east.
Land on the west side of Rocky Branch Creek has not been used for
manufacture or disposal and is generally isolated from the central
process area by the creek. Land in the northern parts of the site
has not been used for manufacture and is generally upslope from the
central process area.
The central process area is separated into 11 sub-areas according
to where operations took place while the plant was active (Figure
1-3). The sub-areas and their former uses include:
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^
=^ Little Rock »-
' \§:Air ForceBase
LOCATION
Source U S Geological Survey
75 Minute Series
Olmstead. AR(1987)
Cabot AR (1987)
Jacksonville, AR (1987)
^^^^^^^^^^^^^
Scale in Feet
Jacksonville, A (198
McAlmont AR(1975)
FIGURE 1-1 SITE LOCATION MAP, VERT AC SITE
JACKSONVILLE, ARKANSAS
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Maintenance Area - Used for equipment repairs and storage
of equipment, parts, and some process raw materials.
Formulations Area - Used for the storage of raw and
finished product (large warehouse and some process
vessels).
Former Chlorination Plant Area - Used in the
manufacturing of 2,4-D.
Existing Chlorination Plant Area - Built in the early
1980s and replaced the former Chlorination plant.
Esterification Plant - Used to add alcohols to increase
the solubility of the herbicide in water.
Dalapon (1,1, l-trichloropropionic acid) Production Area -
Used in the manufacturing of Dalapon.
Recycle Liquor Storage Area - Currently used to store
drums generated by ongoing site activities.
Recovery Plant - Used in the treatment of process wastes.
2,4-D wastes were recovered and drums containing 2,4-D
wastes were washed.
2,4,5-T Production Area - Used in the manufacturing of
2,4,5-T.
Waste water Treatment Plant - Formerly used to treat
process waste water, and currently used to treat ground
water and surface water from the central process area.
Acid Plant - Chlorophenols were reacted with acetic and
monochloroacetic acid to form phenoxyacetic acid
herbicides.
The Regina Paint Building, located in Parcel 2, is the only study
unit located outside of the Central Process Area that is included
in Onsite Operable Unit 1.
2j_ SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 SITE HISTORY
The first facilities on the site were constructed by the United
States Department of Defense (DOD) in the 1930s and 1940s. These
facilities were part of a munitions complex that extended beyond
the present site boundaries. In 1948, the Reasor-Hill Company
purchased the property and converted the operations to manufacture
insecticides such as DDT, aldrin, dieldrin, and toxaphene. During
the 1950s, Reasor-Hill manufactured herbicides such as 2,4-
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dichlorophenoxyacetic acid (2,4-D), 2,4,5-trichlorophenoxyacetic
acid (2,4,5-T), and 2,4,5-tricholrophenoxypropionic acid (2,4,5-
TP) , which is also called Silvex. Drums of organic wastes were
stacked in an open field immediately southwest of the production
area, and untreated process water was discharged from the western
end of the plant to Rocky Branch Creek.
Hercules Powder Company, now known as Hercules Incorporated
(Hercules), purchased the Reasor-Hill property and plant in 1961
and continued to manufacture and formulate herbicides. The drums of
organic wastes that were in the open area southwest of the central
process area were buried in the 1960s by Hercules in what is now
referred to as the Reasor-Hill Landfill. From 1964 to 1968,
Hercules produced the herbicide Agent Orange, a 2,4-D/2,4,5-T
mixture for DOD. Hercules discontinued operations at the site in
1971.
From 1971 to 1976, Hercules leased the plant to Transvaal, Inc., a
predecessor company of Vertac Chemical Corporation (Vertac).
Transvaal resumed production of 2,4-D and intermittently produced
2,4,5-T. Organic wastes from these manufacturing processes were
stored and then buried onsite in the 1970s by Transvaal in what is
now referred to as the North Landfill or the Hercules/Transvaal
Landfill. Transvaal purchased the property and plant from Hercules
in 1976. In 1978, Transvaal underwent a Chapter XI bankruptcy
reorganization, and ownership of the site was transferred to the
new company, Vertac, which is the present owner.
Arkansas Department of Pollution Control and Ecology (ADPC&E)
issued an order in 1979 that required Vertac to improve its
hazardous waste practices, and in 1980, the United States
Environmental Protection Agency (EPA) and ADPC&E jointly filed suit
in federal district court against Vertac and Hercules. A Consent
Decree entered into by EPA, ADPC&E, Vertac, and Hercules in January
1982, required that an independent consultant assess the conditions
of onsite wastes and develop a proposed disposal method for the
wastes. The proposal, called the "Vertac Remedy," was deemed by
EPA to be unsatisfactory. The court decided in favor of the
proposed remedy, which was implemented in summer 1984 and completed
in July 1986. As part of the remedy, the Vertac plant cooling
water pond was closed, and sediment from this unit was removed and
placed in an above-ground vault. The Reasor-Hill and
Hercules/Transvaal Landfills were capped, and a french drain and
leachate collection system were installed around the burial
(landfills) area. Ground water monitoring wells were also
installed, and a ground water monitoring program was initiated.
Vertac operated the plant until 1986. In January 1987, Vertac
abandoned the site, leaving about 29,000 drums of 2,4-D and 2,4,5,-
T wastes. Many of these drums were leaking. EPA and Hercules then
took over management of the site. This management has included the
maintenance and overpacking (placing a leaking drum in a larger new
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plastic drum) of nearly 29,000 drums of organic material by EPA.
Hercules has operated the treatment plant that treats ground water
collected in french drains, which were constructed by Vertac
downgradient of the landfills as a part of the Vertac Remedy, and
surface water runoff collected in ditches that drain to sumps. The
water treatment plant treats surface water runoff and ground water
by phase-separation followed by adsorption through granular
activated carbon. Additionally, a series of drainage ditches and
sumps, which surround the central process area, collects surface
runoff and pumps it to the water treatment plant. The treated
water is piped to the West Waste water Treatment Plant, owned and
operated by the City of Jacksonville, and is then discharged into
Bayou Meto.
Currently, there are no manufacturing operations at the site. At
the time operations were shut down, Vertac "mothballed" the plant.
Mothballing involved flushing process lines and draining many of
the process vessels. However, many vessels and tanks still contain
residues. Continuing activities at the site include operation of
the water treatment plant by Hercules.
The Vertac, Incorporated site was added to the National Priorities
List (NPL) of hazardous waste sites in 1982. Once the site was
placed on the NPL, Superfund money became available to study the
contamination problems at Vertac and find ways to correct them to
protect public health and the environment, pursuant to CERCLA.
2.2 SITE INVESTIGATIONS
Previous investigations performed at the site began in April 1978,
when Vertac participated in a nationwide survey of potential dioxin
sites. Three recent activities that are of importance in
formulating the site characterization activities are:
1. Beginning in March 1987 and continuing through April 1988, EPA
performed an inventory of the process vessels (storage tanks,
chemical reaction vessels, etc.) in the central process area. The
inventory consisted of:
Vessel identification.
Geometric shape.
Volume.
Content level, volume, phase.
Content visual description.
Analytical data (specific vessels).
This inventory revealed that approximately 213 vessels were onsite.
Of the total, 73 of the process vessels were determined to be
empty. Of the 140 process vessels that were not empty, 96 were
sampled and analyzed for 2,4-D, 2,4,5-T, and/or 2,3,7,8-TCDD
(TCDD). The remaining 44 process vessels were not sampled because
they contained material associated with a known process, such as
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manufacture of 2,4,5-T, water treatment, etc. Because sampling was
performed as a general assessment, not every vessel onsite was
sampled.
Of the 96 vessels sampled, 46 vessels contained TCDD at a
concentration greater than the detection limit of 0.3 part per
billion (ppb). TCDD concentrations ranged from non detect to 960
ppb. Concentrations of 2,4-D ranged up to a maximum concentration
of 200,000 parts per million (ppm).
Samples of insulation from the outside of 52 insulated process
vessels were collected for asbestos analysis. Asbestos was not
found in any of these samples.
Samples were also collected from selected buildings, building
components, and roofing materials for asbestos analysis. A total
of six bulk samples were analyzed for asbestos and five tested
positive. The locations and the reported results are:
Boiler feed water pump =>3% Amosite.
No. 3 boiler =>2% Chrysotile.
Dalapon Pad Area =>20% Chrysotile.
Formulations Building roof tile =>!!%
Chrysotile.
Formulations Building wall tile =>ll%
Chrysotile.
Since February 1, 1987, U.S. EPA has managed onsite wastes,
including trash and pallets. The trash included floor sweepings,
scrap metal, packaging material, personal protective clothing, and
other wastes typically generated in an industrial setting. EPA
shredded the trash and placed it into 1.7-cubic-yard polyethylene-
lined, nylon bags. An estimated 643 bags were generated. No
previous analytical data characterizing the trash were available.
The trash was considered to have been homogenized during the
shredding process, which cut the trash into small pieces. During
shredding, the trash was staged in a common area, shredded, and
later transferred into the bags.
EPA also shredded 9,906 pallets and placed them into an estimated
675 polyethylene-lined, nylon bags with a capacity of 1.7 cubic
yards. The bags of shredded pallets were generated with the trash.
No previous analytical data characterizing the shredded pallets
were available. After shredding, the pieces of the shredded
pallets were staged in a common area and later were transferred
into the bags.
2. The removal project performed by Hercules in the fall of 1988,
under the terms of an Administrative Order on Consent, involved
excavating residential surface soils contaminated with TCDD at a
concentration > 1 ppb. Approximately 2,700 cubic yards of soil
were excavated and stored in approximately 1,630 polyethylene-
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lined, nylon bags (1.7-cubic-yard capacity). TCDD concentrations
for most residential soils ranged from 1 to 10 ppb. Other site
soils were also excavated and placed in bags. These soils came
from onsite surface drainage areas that were excavated, and from
the excavation for surface drainage collection sumps. TCDD
concentrations in these onsite soils ranged from 100 to 200 ppb.
The soils were collected in a common staging area and later
transferred to the 1.7-cubic-yard bags. The excavating, staging,
and transferring resulted in thorough mixing of soils. The soils
are considered homogenized and the TCDD concentrations are expected
to be similar among bags. These bags are currently stored in a
warehouse built by Hercules, located near the boiler house, and
were sampled during Operable Unit I Remedial Investigation.
3. In July 1989, Hercules signed an Administrative Order (AO) On
Consent with EPA to conduct a Remedial Investigation/Feasibility
Study (RI/FS) for the Vertac onsite areas. Since the contamination
problems at the Vertac onsite areas are complex, the onsite RI/FS
was divided into two operable units. Onsite Operable Unit 1
consists of above-ground media, such as buildings, process
equipment, etc. Onsite Operable Unit 2 addresses soils and ground
water. RI/FS for Onsite Operable Unit 1 was completed in March
1991. The findings of this investigation are detailed in Section 5
(Summary of Site Characteristics) of this ROD.
2.3 ENFORCEMENT HISTORY
A Potentially Responsible Party (PRP) search was not conducted
since the Agency knew the identities of former owners, operators,
and some generators of waste at the Vertac site, and since
litigation was already going on prior to CERCLA activities.
However, CERCLA Section 104(e) information request letters were
mailed in March 1990 and later to several companies, some of which
had "tolling agreements" with the Vertac Chemical Corporation
and/or Hercules Inc.
The following is a chronology of enforcement activity at the Vertac
site:
1. Litigation was filed in 1980 under RCRA Section 7003 and other
statutes by the United States and the State of Arkansas
against Vertac Chemical Corp. and Hercules Inc. (the
"Parties"). In January 1982, EPA and the State of Arkansas
entered into a Consent Decree with Vertac Chemical Corp. and
Hercules Inc. in the litigation for developing a remedial plan
for certain onsite and off-site areas. After EPA invoked
dispute resolution and a hearing on the remedy, the court
ordered the implementation of the "Vertac Remedy" in July
1984. (See Site History for a discussion of the action
taken.)
2. In July 1986, pursuant to an agreement between the parties and
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entered by the court, Vertac established a Trust Fund, as part
of a bankruptcy agreement. Vertac placed $6,700,000 in this
fund to be used to remediate portions of the plant. A
$4,000,000 letter of credit was later added to this Trust
Fund. Both EPA and the State of Arkansas have access to this
fund, and it is being used to incinerate the 29,000 drums.
3. In August 1986, EPA issued a Unilateral Administrative Order
to all PRPs to require posting of warning signs and the
fencing of portions of the West Waste water Treatment Plant
and certain areas of Rocky Branch Creek. This work was
performed by Hercules.
4. In January 1987, EPA issued a notice letter to Vertac Chemical
Corp. that required Vertac Chemical Corp. to continue
operation and maintenance of leachate collection and treatment
system.
5. In June 1988, EPA signed an Administrative Order on Consent
with Hercules to allow Hercules to implement fine grid
sampling for off-site areas.
6. In September 1988, EPA signed an Administrative Order on
Consent with Hercules that required Hercules to remove
contaminated soils from residential yards.
7. In July 1989, EPA signed an Administrative Order on Consent
with Hercules that required Hercules to conduct the onsite
Remedial Investigation/Feasibility Study (RI/FS).
8. In March 1990, EPA sent CERCLA Section 104(e) information
request letters to several companies which had been involved
in business deals with Vertac Chemical Corp. and Hercules
Inc., including "tolling agreements".
9. In July 1990, EPA sent General Notice letters to the PRPs
regarding the proposed off-site remedial plan and other site
actions.
10. In February 1991, the District Court entered a Consent Decree
between the United States and the "Phoenix Parties," which are
companies related to Vertac Chemical Corp., and which carried
on the remaining business of Vertac under their names after
Vertac abandoned the site. Hercules appealed entry of the
Consent Decree to the Eighth Circuit Court of Appeals, which
upheld entry of the Consent Decree in April 1992. Under the
terms of the Consent Decree, the Phoenix Parties have
contributed $1,840,000 to the RCRA Closure Trust Fund, and
will contribute a percentage of pre-tax profits for 12 years,
in return for a release from liability.
11. Hercules Inc. had opposed the United States' efforts to select
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a remedy for the off-site area at Vertac. This opposition
included a motion filed in September 1992, to enforce 1982
RCRA Consent Decree. The parties were ultimately unable to
resolve their differences regarding this motion. In June
1992, the trial court entered an order denying Hercules'
motion to enforce the Consent Decree, and allowed EPA to use
CERCLA procedures to select remedies for Vertac.
12. The United States added CERCLA section 107 cost recovery
claims against Hercules, The Dow Chemical Company and Uniroyal
Chemical Limited of Canada in a complaint filed in March,
1992. By order of the trial court in June 1992, this
complaint was administratively closed, and the claims asserted
against Hercules, Dow and Uniroyal were consolidated with the
existing litigation. Other parties, including BASF AG,
Standard Chlorine and Velsicol, have been added to the
litigation as third-party defendants,
13. Special notice letters for Remedial Design/Remedial Action
(RD/RA) for the off-site areas were sent to the PRPs in August
1992. No good faith offers were received in response to this
letter. A subsequent special notice letter was sent in
December 1992, to the PRPs after EPA revised the scope of
remedial work at the off-site areas. Negotiations regarding
this work did not result in an RD/RA Consent Decree.
14. Discovery in the liability phase of the ongoing litigation has
been completed. Pre-trial motions and negotiations are
underway. The case has been set for trial on the issue of
liability beginning on November 1, 1993. Following this
trial, phases II and III will deal with the government's costs
and apportionment of liability among the defendants,
respectively.
15. Although it is not specifically enforcement-related, two
separate citizens' suits have been filed seeking to halt
incineration of dioxin still bottom wastes stored at the
Vertac Site. The first suit, filed in 1990 by the National
Toxics Campaign and others, resulted in denial of plaintiffs'
request for a preliminary injunction against incineration.
The second suit, filed in October 1992, by the Arkansas Peace
Center and others, resulted in both a temporary injunction and
a preliminary injunction prohibiting incineration being
issued. The preliminary injunction is being appealed to the
Eighth Circuit Court of Appeals, which has issued a stay of
the preliminary injunction.
li HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Vertac site was completed in
1983. This plan lists contacts and interested parties throughout
government and the local community. It also establishes
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communication pathways to ensure timely dissemination of pertinent
information. Numerous fact sheets, open houses and workshops have
been conducted on the Vertac site. A satellite community relations
office was established in Jacksonville in July 1990 to provide easy
access to documents and information. The Vertac Site Remedial
Investigation and Focused Feasibility Study For Operable Unit 1
was released to the public in March 1991. This document was made
available at five local repositories (Jacksonville City Hall,
Public Library, Police Courts Building, Air Force Base Library, and
ADPC&E in Little Rock). The Administrative Record for this
operable unit is maintained at EPA in Dallas, the Jacksonville City
Hall and the Arkansas Department of Pollution Control and Ecology
in Little Rock.
A Technical Assistance Grant (TAG) was awarded by EPA in 1989 to a
citizens group called Jacksonville People With Pride Clean Up
Coalition (JPWPCUC). This award was challenged by citizens groups
that competed for the grant, who alleged that JPWPCUC was funded by
the Potentially Responsible Parties (PRPs) for Vertac. Upon
investigation by EPA, the grant was annulled after it was
determined that the JPWPCUC TAG application listed their source of
matching funds as a bank account shared with their larger "parent"
group, the Jacksonville People With Pride. This parent group had
indeed accepted monetary contributions from Vertac PRPs, and since
these funds were not distinct from those of JPWPCUC, EPA determined
that a possible conflict of interest could exist, resulting in
annulment of the TAG in December 1991.
TAG availability was again advertised in January 1992, and the
grant was awarded to the Concerned Citizens Coalition (CCC) in
April 1993 after considerable effort by EPA to facilitate
consolidation of four competing citizen groups. CCC is currently in
the process of soliciting for a Technical Advisor.
The proposed plan for this operable unit was released on February
13, 1993. A public comment period was held from February 22 to
April 23, 1993. In addition, an open house was held on February
13, 1993 and a public meeting was held on April 13, 1993 to present
the results of the Remedial Investigation/Focused Feasibility Study
and the proposed plan. All comments received by EPA prior to the
end of the public comment period, including those expressed
verbally at the public meeting, are addressed in the Responsiveness
Summary section of this Record of Decision. Thus, public
participation requirements of CERCLA Sections 113 (K) (2) (B) (i-v) and
117 have been satisfied.
4j_ SCOPE AND ROLE OF ONSITE OPERABLE UNIT 1 WITHIN SITE STRATEGY
Since the Vertac Superfund Site is very large and complex, the site
is divided into the following operable units:
Vertac Remedy - As required by the 1984 Consent Decree, the Vertac
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plant cooling water pond was closed and sediments from this unit
were removed and placed in an above-ground sediment vault. The
burial areas (landfills) were capped and a french drain and
leachate collection system were installed around the burial areas.
Ground water monitoring wells were also installed and a ground
water monitoring program was initiated.
Vertac Off-Site - This Record of Decision, signed in September
1990, addresses the clean-up of the off-site areas that were
contaminated as a result of untreated and partially treated surface
and underground (city sewer) discharges of waste water and other
releases from the plant. EPA has issued a Unilateral Administrative
Order (UAO) to the PRPs for conducting RD/RA for this operable
unit.
Drummed Wastes Incineration - When Vertac abandoned the plant in
1987, approximately 29,000 drums of 2,4-D and 2,4,5-T wastes were
left onsite. In 1989, ADPC&E signed a contract to have these
drummed wastes incinerated onsite. EPA provided incineration
support, and has performed an engineering evaluation/cost
analysis (EE/CA) for incineration support. Incineration of these
wastes began in fall 1990. EPA also signed an action memorandum in
September 1992, selecting incineration of these drummed wastes.
ADPC&E terminated the incineration contract in early June 1993.
EPA has taken over this drum incineration project.
Onsite Operable Unit 1 - In July 1989, Hercules Inc.(a Potentially
Responsible Party) signed an Administrative Order on Consent, with
EPA to conduct a Remedial Investigation/Feasibility Study
(RI/FS) for above-ground items, such as buildings, process
equipment, tanks and their contents, shredded trash and pallets,
and bagged soils (removed from dioxin contaminated residential
yards). This RI/FS was completed in March 1991.
Onsite Operable Unit 2 - This operable unit addresses surface and
subsurface soils, underground storage tanks and piping and ground
water. Hercules is conducting an RI/FS for this operable unit
under the terms of the above-mentioned Administrative Order on
Consent and this RI/FS is scheduled for completion by September
1994. This operable unit is expected to be further divided into
two operable units (soils and ground water operable units).
The Onsite Operable Unit 1, the subject of this ROD, addresses the
onsite above-ground units. The contaminated media (tank contents,
spent carbon, drummed wastes, buildings and equipment, etc.) in
this operable unit poses principal and low level threats. The
purpose of this response is to address risks posed by this operable
unit's media.
5_._ SUMMARY OF SITE CHARACTERISTICS
5.1 LAND USE/POPULATION
13
-------
The Vertac site is zoned industrial and is located within the City
of Jacksonville. Land use zoning near the Vertac plant is shown on
Figure 5-1. The portion just south of the Vertac plant site,
between Marshall Road and the Missouri-Pacific railroad tracks,
south to West Main Street, is residential, a combination of single-
family homes and apartments. The section immediately west of the
railroad tracks and north of West Main Street is undeveloped. The
area between West Main Street and South Redmond Road is commercial
and light industrial. Just south of South Redmond Road is
undeveloped, uninhabited land that includes the Jacksonville Sewage
Treatment Plant, DuPree Park, and Lake DuPree. The rest of the
area is either farmland, mainly irrigated rice fields in the area
south of Jacksonville and Bayou Meto, woodlands, or residential.
There is substantial suburban residential development on the strip
of higher ground along Highway 161 and in the area north of Bayou
Meto.
The population growth of Jacksonville has been as follows: 1950 -
2,474; 1960 - 14,488, 1965 - 18,078; 1970 - 19,832; 1980 - 26,788;
and 1990 - 29,101.
5.2 GEOLOGY
The site lies in the transition zone between the Coastal Plain and
the interior Highlands Physiographic Provinces. The surficial
geology of the Coastal Plain Province in the region surrounding the
site is dominated by a westward thinning wedge of unconsolidated
sediment consisting of the Tertiary Age Claiborne Group, Wilcox
Group, and Midway Formation.
The Claiborne Group and the Wilcox Group are undifferentiated along
the fall line that occurs in the site area. The wedge onlaps the
rocks of the Pennsylvanian Age lower Atoka Formation, which
dominates the geology of the interior Highlands Province in the
region surrounding the site. Quaternary alluvium and terrace
deposits occur locally along drainages in both provinces and are
more common in the Coastal Plain Province. A generalized summary of
the geologic formations surrounding the site is presented in Table
5-1. A map of the site geology is presented in Figure 5-2.
The contact between the Tertiary Age sediments and the
Pennsylvanian Age rocks occurs along a regional trend of northeast
to southwest and is present in the area of the site. On a local
scale, the trend of the contact depends on the current erosional
surface and the paleotopographic surface of the Atoka Formation.
The strike of the Wilcox Group sediments and the Midway Formation
tends toward the northeast/southwest. The dip of the sediments is
low and oriented toward the southeast. The Midway Formation was
deposited onto the irregular and weathered surface of the Atoka
Formation, which was folded and fractured during the late stages of
the Alleghenian orogeny. The Atoka Formation was later uplifted and
weathered. In the area of the site, the strike of the beds in the
14
-------
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Land Use Zoning Map
Vertac Operable Unit 1
15
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Atoka Formation trends N70°W and dip is about 35°NE. The Atoka
Formation outcrops along Rocky Branch Creek on the western side of
the site.
5.3 GROUND WATER
This ROD does not address the ground water contamination issues.
Onsite Operable Unit 2 ROD, scheduled for December 1994, will
address ground water contamination. Ground water investigation has
indicated that contamination has not migrated to off-site areas.
The city of Jacksonville does not use ground water as a source of
drinking water, but receives water from Little Rock.
The ground water in the region surrounding the site occurs in both
the overburden and the underlaying bedrock. The overburden and
bedrock are generally not considered important sources of ground
water supply near the site. Ground water supplies in the region are
obtained from the unconsolidated sands and gravels in the Tertiary
and younger Quaternary sediments. Most ground water is produced
from wells completed in sands within the Wilcox Group and basal
sands and gravels within the Pleistocene alluvium and terrace
deposits. Yields from these deposits can range up to 2,000 gallons
per minute. Ground water in the unconsolidated sediments is present
in the primary intergranular pore space. Some domestic ground water
supplies are obtained from Atoka Formation. Yields can range up to
10 gallons per minute. Ground water in the bedrock is present in
the fractures and partings within the rock. A summary of the water-
yielding characteristics is presented in Table 5-2.
The hydrogeology in the area of the site is influenced by the
location of Rocky Branch Creek, the french drain, the central
ditch, and the hydraulic characteristics of the overburden,
weathered rock, and bedrock.
5.4 SURFACE WATER
This ROD does not address the surface contamination issues. Off-
site ROD, issued in September 1990, addressed the surface water
contamination problems and proposed a remedy.
There are two major drainageways in the area, Rocky Branch Creek
and Bayou Meto. Minor drainageways are intermittent streams that
flow into Rocky Branch Creek and Bayou Meto in the spring or during
periods of heavy rainfall.
Rocky Branch originates near the northern boundary of Jacksonville
and flows generally south, traversing the Vertac plant property
along the west side. About two miles south of the plant it empties
into Bayou Meto. Being a young stream, Rocky Branch is
characterized by low sinuosity, low levels of suspended sediments,
and a high bed-load potential. Channel deposits are predominantly
silt and clay.
18
-------
Bayou Meto begins in the Atoka Formation approximately one mile
northwest of Jacksonville. About 130 miles southeast of
Jacksonville, Bayou Meto empties into the Arkansas River.
5.5 REMEDIAL INVESTIGATION FINDINGS
Onsite Operable Unit I consists of the following above-ground
materials:
Contents and residues that are in process vessels.
Miscellaneous containerized (drummed or bagged) materials
that are currently stored onsite, including spent carbon,
french drain oily leachate, shredded plant trash,
shredded pallets, excavated soil, and other containerized
disposables (this does not include those drummed wastes
currently being incinerated).
Process buildings and structures.
Process equipment (i.e., storage tanks, reactors, piping,
pumps, etc.).
Materials used to construct, add to, and maintain the
chemical processing units and buildings (i.e., asbestos
siding and insulation, and PCBs in electrical equipment) .
Contents of Process Vessels
During the process vessel inventory in 1989, a total of 270 vessels
were found. Of the 270 vessels, 175 were empty (based on readings
from a nonintrusive level detector). 95 process vessels that were
not empty were categorized into vessels containing F-listed wastes
(based on historical information and labels on vessels) (46) ,
vessels containing non-F-listed wastes (31), vessels containing
unknown wastes (6), and vessels in active use (12). The Resource
Conservation and Recovery Act (RCRA) lists hazardous wastes fron
non-specific sources (such as waste halogenated solvents,
herbicides manufacturing wastes, etc.) as F-wastes. The process
vessel inventory is presented in Appendix A of the Vertac Site
Remedial Investigation and Focused Feasibility Study for Onsite
Operable Unit 1.
F-Listed Vessel Contents
This category includes 2,4-D product and waste, 2,4,5-T products
and waste, discarded raw materials like chlorophenols, toluene,
etc. and spent alcohols. Out of the 46 vessels believed to contain
F-listed wastes, 17 were sampled for physical and incinerability
characteristics of the material contained within the vessels. The
physical nature of the material varied greatly; vessels contained
19
-------
solids, tar, sludges, organic liquids, and aqueous liquids.
Thirteen vessels contained more than one phase. The
incinerability characteristics also varied widely; including BTU
(measure of heating value), ash, and moisture content. Table 5-2
lists the ranges and median values of analytical results. Total
volume of F-listed vessel contents was estimated at 104,700
gallons.
Non-F-Listed Vessel Contents
This category includes materials such as tetrachlorobenzene,
caustic soda, hydrochloric acid, dimethyl amine, kerosene/fuel oil,
etc. Of the 31 vessels believed to contain non-F-listed wastes, 9
vessels were sampled. These vessels contained material that was
typically single phase. With the exception of one sample, the
analytical data generally did not indicate the presence of
trichlorophenol or 2,3,7,8-TCDD, which supports the initial
characterization of the contents of these vessels as non-F-listed
materials. Some of the material contained high values for BTU and
chlorides. Table 5-3 is a summary of the analytical results for the
non-F-listed vessels. Total volume of non-F-listed vessel contents
was estimated at 69,400 gallons.
Unknown Vessel Contents
This category includes materials of unknown origin. Of the 6
vessels containing materials of unknown origin, only 5 were sampled
(because the sixth vessel contained material similar to one of the
vessel sampled). Three of the vessels contained weathered
hydrocarbon residues, probably derived from petroleum, based on
infrared (IR) scans performed on these samples. The physical
nature of the materials varied greatly, including aqueous liquid,
organic liquid, tar, and soil. 2,3,7,8-TCDD was detected in four
of the seven samples analyzed. With the possible exception of one
(2.4 ppb 2,3,7,8-TCDD), the vessel contents display chemical
compositions that would support listing the contents with the
non-F-listed category. The BTU and chloride values are similar to
those of the other vessel contents. The analytical results are
summarized in Table 5-4. Total volume of unknown vessel contents
was estimated at 23,110 gallons.
Spent Carbon
Spent carbon (generated from treatment of aqueous phase of leachate
collected in the french drains) drums inventoried totalled 502.
The physical nature of the spent carbon was a solid, although a
high moisture content was present. The analytical data showed that
the spent carbon contained organic compounds, including toluene,
di- and tri- chlorophenols, naphthalene, 2,4-D, and 2,4,5-T at
concentrations over 1,000 ppm. The analytical data showed that the
spent carbon is relatively homogeneous, even between the drummed
and bulk carbon. The spent carbon has a high heating value, above
20
-------
TABLE 5-2
F-USTED PROCESS VESSEL CONTENTS ANALYTICAL SUMMARY
CONCENTRATION
RANGE (a)
METALS mo/ka
Arsenic ND-130
Barium ND - 82.8
Calcium ND - 22200
Chromium ND - 38.5
Lead ND 35.7
Magnesium ND-818
Potassium ND - 221
Sodium ND - 53400
PHYSICAL PARAMETERS
Ultimate Analysis (Wt %)
-Carbon 0.41 - 73.4
-Hydrogen 0.46 - 5.97
-Oxygen 20.5 - 97.2
Nitrogen 0.03 - 0.62
-Sulfur ND - 0.13
Melting Point (F) 195-1865
Percent Ash (Wt %) ND - 79.4
Percent Moisture (Wt %) ND - 95
Heating Value (Btu/lb) ND - 1 6000
Total Chlorides (mg/kg) 1 700 -420000
-Inorganic Chlorides 200 - 52000
-Organic Chlorides ND - 420000
NOTES:
MEDIAN
VALUE (b)
mg/kg
19
0.44
17.2
11.6
7.1
13
47.5
1350
62.4
4.18
32.2
0.13
0.06
204
1.3
45
6100
49000
800
158000
(a) Only those metals with detected concentrations greater than
1 mg/kg are included in this summary table.
(b) The median value for each analyte is determined using
detected concentrations only.
VOLUME BREAKDOWN
VESSELS CONTAINING F-USTED MATERIAL * 46
TOTAL F-USTED PROCESS VESSEL CONTENTS = 104700 gal.
-TOTAL UQUIDS = 25400 gal
-TOTAL SOUDS = 30800 gal
-TOTAL UQ/SOL = 48500 gal
21
-------
TABLE 5-3
NON-F-LISTED PROCESS VESSEL CONTENTS ANALYTICAL SUMMARY
CONCENTRATION
RANGE (a)
MEDIAN
JfALUE (b)
VOC»
Chloroform
Toluene
Ethylbenzene
Xylenes
BNAa
2,4-dichlorophenol
1,2,4-trichlorobenzene
Naphthalene
2,4,6-trichlorophenol
Pentachlorophenol
2-methylnaphthalene
Phenanthrene
Anthracene
Pyrene
Tetrachlorobenzene
HERBICIDES
2,4-D
2,4,5-T
DIOXIN
2.3,7.8-TCDD
METALS
Arsenic
Barium
Calcium
Chromium
Magnesium
Pota»*ium
Sodium
PHYSICAL PARAMETERS
Ultimate analytic (Wt %)
-Carbon
-Hydrogen
-Oxygen
-Nitrogen
-Sulfur
Melting point (F)
Percent aah (Wt %)
Percent mowture (Wt %)
Heating value (Btu/Ib)
Total 'chloride* (mg/kg)
-Inorganic chloride*
Organic chloride*
mg/kg
ND-41
NO-590
NO-40000
ND-110000
mg/kg
NO-1000
NO-5600
NO -360
NO-5000
NO-8700
NO-1800
NO-560
NO-560
NO-200
NA(C)
mg/kg
ND-400
NO ^7
ng/g
ND-OJ21
mg/kg
NO-31.4
NO -1.3
NO-75.1
NO-233
NO-78.4
NO-439
NO-687000
0.52 - 78.3
18.0-97.0
0.02-1.96
NO -0.53
321 -685 (d)
NO -14.9
NO -95
ND- 18300
NO -660000
300-80000
ND- 660000
mg/kg
0.24
0.93
2
4.7
mg/kg
7.5
5600
130
0.37
8700
1800
560
560
200
610000
mg/kg
17
0.079
ng/g
0.21
mg/ka
18.9
1.3
24.7
9.9
4.8
138
78.5
5.36
5.1
892
0.07
0.04
321
0.3
80
4500
1400
300
1100
NOTES:
(a) With the exception of dioxin, only thoee chemical parameter* with
detected concentration* greater than 1 ppm are ummarized above.
(b) Only detected concentration* we ueed when determining the median value.
(c) Only one aampfewa* analyzed for tetrachlorobenzene.
(d) Value* lea* than 32 F are not Included.
VOLUME BREAKDOWN
VESSELS CONTAINING NON-F-USTED MATERIAL - 31
TOTAL NON-F-USTED PROCESS VESSEL CONTENTS - 69400 gal
-TOTAL LIQUIDS - 53420 gal
-TOTALSOUDS - 5790 gal
TOTAL UQ/SOL * 10190 gal
22
-------
TABLE 5-4
UNKNOWN PROCESS VESSEL CONTENTS ANALYTICAL SUMMARY
CONCENTRATION
RANGE (a)
MEDIAN
VALUE (b)
VOC«
riethylene chloride
Acetone
Chloroform
Tetrachloroethane
BNAa
Jen2oic acid
PESTICIDES/PCBa
Oieldrin
4,4'-DDE
Endrin
4,4'-DOD
4.4'-DOT
HERBICIDES
2,4,5-T
DIOXIN
2,3.7.8-TCDD
METALS
Arsenic
Jarium
Calcium
Chromium
Magneeium
9otM«ium
Sodium
PHYSICAL PARAMETERS
Ultimate analytic (Wt %)
-Carbon
-Hydrogen
-Oxygen
-Nitrogen
-Sulfur
Melting point (F)
Percent a»h (Wt %)
Percent moisture (Wt %)
Heating value (Btu/lb)
Total chloridee (mg/kg)
-Inorganic chloridee
-Organic chloridee
mg/kg
ND-1
NO-74
ND - 3.5
ND-5.1
mg/kg
ND-3600
mg/kg
ND-1.5
ND-1.5
ND-4.1
ND-7.7
ND-12
mg/kg
ND - 9.1
ng/g
ND - 2.4
mg/kg
ND - 26.3
ND - 28.7
22.8-2560
ND-261
18-244
ND -215
29.6-9810
1.43-81.3
0.78-4.62
15.1-97.5
0.05 -0.39
ND-0.83
192-1432 (c)
NO-85.3
4-96
ND-14800
ND- 470000
ND-4600
ND-424000
mg/kg
1
0.014
0.031
5.1
mg/kg
3600
mg/kg
0.017
0.014
4.1
0.011
0.12
mg/kg
9.1
ng/g
0.51
mg/kg
2Z9
13.2
353
2.5
61.7
161
62.8
58.3
2.96
37.7
021
025
1400
12.1
7
11200
1400
400
1000
NOTBS:
(a) With the exception of dloxin, only thoee chemical parameter* with
detected concentration* greater than 1 ppm are summarized above.
(b) Only detected concentration* are used when determining the median value.
(c) Value* leas than 32 F are not included.
VOLUME BREAKDOWN
VESSELS CONTAINING UNKNOWN MATERIALS - 5
TOTAL UNKNOWN PROCESS VESSEL CONTENTS - 23110 gal
-TOTAL LIQUIDS - 7870 gal
-TOTAL SOUDS - 15240 gal
23
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7,500 BTU/lb. The ash content varied between the bulk and drummed
carbon samples. The bulk carbon exhibited a higher ash content,
probably because solids removal (filtration) prior to carbon
treatment did not take place until 1987, when spent carbon began to
be stored in drums. Because the spent carbon generated prior to
1987 did not experience prefiltration, it is believed to contain
higher grit and iron concentrations, thus having a higher ash
content. Approximately 59,000 gallons of spent carbon (bulk and
drummed) were inventoried. Analytical results are summarized in
Table 5-5.
Containerized Materials/French Drain Oily Leachate
377 drums (55 gallons drums) were inventoried. The majority of
these drums contained various materials resulting from the
installation and maintenance of the french drain system for
leachate collection and Remedial Investigation wastes (discarded
tyvak suits, etc.). The sample (and duplicate sample) of the
french drain oily leachate showed high levels of toluene (above 10
wt%), 2,3,7,8-TCDD, di- and tri-chlorophenols, and
chlorophenoxyherbicides. Table 5-6 is a summary of analytical
results for oily leachate.
Process Buildings
Figure 5-3 shows the locations of the buildings (administrative,
manufacturing, warehouse, machine shop, etc.) . These buildings were
sampled for surface contamination (wipe samples) and contaminated
dust. With the exception of the Dalapon boiler, all of the wipe
samples from the interior and exterior surfaces of the process
buildings showed 2,3,7,8-TCDD; the exterior levels were generally
lower than the interior levels. The T-Product Storage Building and
the Change House showed 2,3,7,8-TCDD concentrations an order of
magnitude higher than the other onsite buildings sampled. Also,
the Regina Paint Building is anticipated to be contaminated by
2,3,7,8-TCDD because of the many empty 2,4,5-T waste drums being
stored inside the building. 2,3,7,8-TCDD was also found in all the
dust samples that were taken inside the process buildings. Tables
5-7 and 5-8 present the summary of analytical results of wipe and
dust samples.
An estimated 1,100 empty drums are within the Regina Paint
Building. 2,3,7,8-TCDD was found in the wipe sample collected from
a drum located near the door.
The volume of debris resulting from demolition of buildings is
estimated at 13,680 cubic yards.
Process Equipment
Process equipment includes process vessels (tanks, reactors, etc.),
piping, pumps, etc. 2,3,7,8-TCDD (from wipe samples) was generally
24
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TABLE 5-5
SPENT CARBON ANALYTICAL SUMMARY
CONCENTRATION RANGE (a) MEDIAN VALUE (b)
VOCt
Methylene chloride
Acetone
1,1-dichloroethene
Chloroform
Benzene
Toluene
Chlorobenzene
Xylenee
BNAj
Phenol
2-chlorophenol
1,4-dichlorobenzene
Benzyl alcohol
2-methylphenol
4-methylphenol
Benzole acid
2,4-dichlorophenol
1 ,2,4-trichlorobenzene
Naphthalene
4-chloro-3-methylphenol
2,4,6-trichlorophenol
2,4,5-trichlorophenol
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T
DIOXIN
2,3.7.8-TCDD
METALS
Arsenic
Barium
Cadmium
Calcium
Chromium
Lead
Magnesium
Potassium
Sodium
PHYSICAL PARAMETERS
Ultimate analysis (Wt %)
Carbon »
-Hydrogen
-Oxygen
-Nitrogen
-Sulfur
Percent ash (Wt %)
Percent moisture (Wt %)
Heating value (Btu/lb)
Total chlorides (mg/kg)
-Inorganic chlorides
-Organic chlorides
NOTES:
mg\kg
NO -1.3
NO - 2.3
0.66-1
7.7-14
1.7-2.8
4100-5100
1-1.7
0.79-1.2
mg\kg
270-280
930-960
16-17
80-88
51-60
51-60
NO-38
13000-150000
68-85
1900-2000
ND-20
1500-1600
4800-5500
mg\kg
13000-140000
610-640
1900-2300
ng/g
1.9-2.6
mgVkg
NO -23.9
3.8-92.5
NO -1.1
190-2140
4.5-61.1
NO -30.4
74.2-175
NO -537
126-1970
60.6-64.8
3.12-423
29.8-34.8
0.96-1.12
0.01-0.08
3.5-28.9
10-42
7600-11400
26000-70000
400-4000
23600-69600
(a) With the exception of dioxin, onty those chemical
mg\kg
1.3
2.3
1
14
2.8
5100
1.7
1.2
mg\kg
280
960
17
88
60
60
38
150000
85
2000
20
1600
5500
mg\kg
140000
640
2300
ng/g
2.6
mg/kg
23.9
52
1.1
436
7.9
30.4
119
333
162
64.3
4.06
30.5
1.01
0.04
4.7
31
7800
27000
600
26400
parameters with
detected concentrations greater than 1 ppm are summarized above.
(b) Only detected concentrations are used when determining the median value.
VOLUME BREAKDOWN (a* of 06 October 1989
TOTAL QUANTITY OF SPENT CARBON - 59010 g
-BULK STORAGE - 21360 gal
-DRUM STORAGE - 37650 gal
25
-------
TABLE 5-6
FRENCH DRAIN LEACHATE ANALYTICAL RESULTS
VOCs (a)
Chloroform
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chloroberuene
Etnylbenzene
Xylenes
BNAs
2,4-dichlorophenol
1 ,2,4-trichlorobeazene
2,4,6-trichlorophenol
2,4, 5-trichlorophenol
PESTICIDES/PCBt
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T
DIOXIN
2,3,7,8-TCDD
METALS (b)
Barium
Beryllium
Calcium
Chromium (c,d)
Magnesium
Potassium
Sodium
PHYSICAL PARAMETERS
Ultimate analysis (Wt %)
' -Cartxxi
-Hydrogen
-Oxygen
-Nitrogen
-Sulfur
Melting point (F)
Percent ash (Wt %)
Percent moisture (Wt %)
Heating value (Btu/lb)
Total chlorides (mg/kg)
-Inorganic chlorides
-Organic chlorides
HE-FD-DC1-OLD-01
mg/kg
8.8 J
3.6
33J
45
100000
84
190
310
mg/kg
22000
8100 U
8100 U
40000 U
ND
mg/kg
6400
1100
3300
ng/g
21
mg/kg
74.8 J
0.26 J
524 J
73.1 J
37.2 J
305 J
536J
56.2
4.03
39.5
0.13
0.18
MA
1.8
2-4 (e)
10500
280000
200
280000
HE-FD-DC1-OLD-02
mg/kg
5J
2.8 J
19J
27
110000
52
110
190
mg/kg
22000
7100 J
9500
40000 J
ND
mg/kg
7200
1400
4000
ng/g
1200
mg/kg
67.4 J
0.26 J
281 J
69.6 J
43.2 J
522J
521 J
56.5
3.98
39.2
0.15
0.21
NA
1.2
2-4 (e)
10800
290000
300
290000
26
-------
27
-------
TABLE 5-7
BUILDING WIPES ANALYTICAL SUMMARY
2,3,7,8-TCDD RANGE
PROCESS BUILDING
Dalapon boiler
Product storage
Contractors building
T-product storage
Acid
Boiler house
Change house
Formulations
Maintenance shop
Parts storage
Laboratory area
Wastewater treatment plant
Chemical storage
Regina paint (residue)
Regina paint (drum wipe)
Maintenance garage
NOTES:
(a) Only detected concentrations are
value (no detection limits).
(ng/sq m)
ND-2.1
1.4-56
1.1-32
23-2360
13.8-260
37
1.3-1870
3-31.5
3-62
4.1 -430
75
9.8
1.3-4
91 mg/kg
121000
28
MEDIAN
VALUE (a)
0.3
4.2
13.6
480
62
37
930
12.5
35
76
75
9.8
4
91 mg/kg
121000
28
used in determining the median
28
-------
TABLE 5-8
BUILDING DUST ANALYTICAL RESULTS
2,3,7,8-TCDD
SAMPLE ID BUILDING (ng/g)
HE-PB-009-VAC-01 Maintenance Shop 18
HE-PB-009-VAC-02 Maintenance Shop 18
HE-PB-010-VAC-01 Parts Storage 61J (a)
HE-PB-011-VAC-01 Administration 88
HE-PB-013-VAC-01 Supervisors 12
HE-PB-014-VAC-01 Glass/Instrument Shop 29
NOTES:
(a) HE-PB-010-VAC-Q1 was spiked in the laboratory. The recovery
was less than the QC limit in the spiked samples. Therefore
the reported result for the unspiked sample was qualified
as estimated.
J «= Estimated value.
29
-------
not detected on the exterior surface of the process vessels, and
the levels on the interior surfaces varied, exceeding 100 ng/m* on
one sample. The analytical data from the process vessel rinsate
samples varied. Three of six of the samples showed low or
nondetectable levels of toluene, chlorinated phenols,
chlorophenoxyherbicides, and 2,3,7,8-TCDD, while the other three
samples showed these compounds one or two orders of magnitude
higher. 2,4-D was the only compound reported in all the samples.
Tables 5-9 and 5-10 present the summary of wipe and rinsate samples
analytical results.
The volume of debris resulting from demolition of process equipment
is estimated at 10,080 cubic yards.
Asbestos Characterization
The asbestos characterization included the buildings, piping within
the buildings, and the major outdoor pipe runs onsite. Of the 12
buildings surveyed, 11 buildings contained asbestos; the Dalapon
boiler building did not. Most of pipe and fitting insulation
sampled was found to contain asbestos. Siding shingles, roof
shingles and floor tile samples also contained asbestos. The
outdoor asbestos characterization focused on pipe runs and fittings
in the major process areas. The general conclusion was that, while
much of the outdoor insulation appeared to be fiberglass, asbestos
was present in the pipe and fitting insulation throughout the
central process area.
Containerized (bagged) Soils
Contaminated soils removed from residential yards and a drainage
ditch onsite are bagged and stored onsite in a steel building. The
analytical results for the bagged soils were within a consistent
range for all the samples, indicating a general homogeneity.
Chlorinated phenols, chlorinated benzenes, and
chlorophenoxyherbicides were present at nondetectable to low
levels. 2,3,7,8-TCDD was detected in all samples at levels ranging
from 13 to 55 ppb. The bagged soils exhibited very low BTU values.
Table 5-11 presents the soil analytical summary.
The total volume was estimated at 2770 cubic yards.
Shredded Trash and Pallets
After Vertac abandoned the site in 1987, EPA (under removal action)
collected and shredded trash and pallets that were scattered
throughout the plant. The shredded trash and pallets, placed in
plastic bags, are stored on site under a tarpaulin cover. The
analytical results for the shredded trash and pallet samples showed
variability over several orders of magnitude. 2,3,7,8-TCDD was
reported in all samples at levels ranging from 1.9 to 4100 ppb.
The pallet samples generally showed higher levels of 2,3,7,8-TCDD
30
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TABLE 5-9
PROCESS EQUIPMENT WIPES ANALYTICAL RESULTS
SAMPLE 10 PROCESS VESSEL
INTERIOR
HE-PE-001-WPI-01
HE-PE-002-WPI-01 (a)
HE-PE-002-WPI-02 (a)
HE-PE-003-WPI-01 (a)
HE-PE-004-WPI-01 (a)
HE-PE-005-WPI-01 (a)
HE-PE-006-WPI-01 (a)
HE-PE-007-WPI-01 (a)
EXTERIOR
HE-PE-001-WPE-01
HE-PE-002-WPE-01
HE-PE-003-WPE-01
HE-PE-004-WPE-01
HE-PE-005-WPE-01
HE-PE-006-WPE-01 (b)
HE-PE-007-WPE-01
HE-PE-007-WPE-02
HE-PE-008-WPE-01 (b)
HE-PE-009-WPE-01
HE-PE-010-WPE-01
EPA-35
EPA-18
EPA-18
EPA-1
T-367
T-357
R-405
T-527
EPA-31
T-503
T-432
T-139
R-404
T-316
T-201
T-201
R-362
EPA-1 6
EPA-26
2,3,7,8-TCDD 2,3,7,8-TCDD
(ng) (ng/sq m)
5.5
0.54 U
1.4 U
1 J
1.3 U
29
2.8 J
19U
0.34 U
0.23 U
0.41 U
0.97 U
0.36 U
1.8 U
0.62 U
0.8 U
26J
0.84
0.6
22.0
2.2 U
5.6 U
4.0 J
5.2 U
116.0
11.2J
76.0 U
1.4 U
0.9 U
1.6 U
3.9 U
1.4 U
7.2 U
£5U
3.2 U
104.0J
3.4
2.4
31
-------
TABLE 5-10
PROCESS VESSEL RINSATE ANALYTICAL SUMMARY
VOCs
Toluene
BNAs
2-chlorophenol
2,4-dichlorophenol
2,4,6-trichloropheno)
2,4,5-trichlorophenol
4-chlorophenol
2,6-dichlorophenol
2,3,6-trichlorophenol
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T
DIOXIN
2,3,7,8-TCDD
NOTES :
(a) Only detected
CONCENTRATION
RANGE
ug/L
ND-810
ug/L
ND-57
ND -5700
ND-1600
ND-2100
ND-280
ND-530
ND-43
ug/L
3.3 - 49000
ND-2800
ND - 4700
ng/L
ND-86
concentrations are used when determining the
MEDIAN
VALUE (a)
ug/L
1.8
ug/L
8
6
260
1300
13
80
43
ug/L
250
220
2.1
ng/L
0.51
median value.
32
-------
TABLE 5-11
CONTAINERIZED SOIL ANALYTICAL SUMMARY
CONCENTRATION
RANGE
MEDIAN
VALUE (a)
CHLORINATED
BEf.-ZENES/PHENOLS
2,4-dichlorophenol
2,4,5-trichlorophenol
Tetrachlorobenzene
HERBICIDES
2,4-0
2,4,5-TP
2,4.5-T
DIOXIN
2,3,7,8-TCDD
PHYSICAL PARAMETERS
Percent a*h (Wt %)
Percent moisture (Wt %)
mg/kg
NO 0.39
ND 0.41
NO -5.6
mg/kg
0.2S 5.1
0.034-1.6
0.23 - 3.9
ng/g
13-55
mg/kg
ND-14.4
1.8-3.6
47.5-647
0.22-0.95
ND-1.2
603-3490
7.5-25.1
3.5-152
12-18.5
288-819
2-6.1
ND-573
ND-0.31
15.5-64.1
17.6-35.8
76.9 - 82.6
10-17
mg/kg
0.21
0.18
2.5
mg/kg
0.46
0.11
0.54
ng/g
23
mg/kg
5.8
2.4
55
0.46
0.77
997
8.3
5.2
14.3
359
4.4
269
021
60.1
21
80.9
14
NOTES:
(a) Only detected concentration* are uted when determining the median value.
VOLUME BREAKDOWN
TOTAL aUANTTTY OF CONTAINERIZED SOIL - 2770 cubic yarde
33
-------
while the trash samples generally showed higher levels of
chlorophenoxyherbicides. Tables 5-12 and 5-13 present the shredded
trash and pallets analytical summary.
The total volume of shredded trash and pallets is estimated at
2,240 cubic yards.
Electrical Equipment
PCBs were detected in five of the eleven transformers sampled. All
five of those transformers are owned by Arkansas Power and Light
Company (AP&L). Of those five, PCBs were detected above 50 ppm in
four transformers, and above 500 ppm in one transformer. Table 5-14
presents transformer oil analytical summary.
The volume of PCB oil is estimated at 1 cubic yard.
6_._ SUMMARY OF SITE RISKS
The National Oil and Hazardous Substances Contingency Plan (NCP),
promulgated on March 8, 1990, states that EPA expects to:
1. Use treatment to address the principal threats posed by a site,
wherever practicable.
2. Use engineering controls, such as containment, for wastes that
pose a relatively low long-term threat or where treatment is
impracticable.
3. Use a combination of methods, as appropriate, to achieve
protection of human health and the environment. In appropriate site
situations, treatment of principal threats posed by a site, with
priority placed on treating waste that is liquid, highly toxic or
mobile, will be combined with engineering controls (such as
containment) and institutional controls as appropriate, for
treatment residuals and untreated waste.
4. Use institutional controls such as water use and deed
restrictions to supplement engineering controls as appropriate for
short-and long-term management to prevent or limit exposure to
hazardous substances.
Principal threat wastes are those source materials considered to be
highly toxic or highly mobile that generally cannot be reliably
contained or would present a significant risk to human health or
the environment should exposure occur. They include liquids (such
as liquid waste contained in drums or tanks) and other highly
mobile materials (such as surface soil containing high
concentrations of contaminants of concern that are mobile due to
wind entrainment, volatilization, or surface runoff) or materials
having high concentrations of toxic compounds (such as buried
drummed non-liquid wastes or soils containing significant
34
-------
TABLE 5-12
SHREDDED TRASH ANALYTICAL SUMMARY
CONCENTRATION
RANGE
MEDIAN
VALUE (a)
CHLORINATED
ENZENES/PHENOLS
-chlorophenol
,4-dichlorophenol
,4,6-tnchlorophenol
,4,5-trichlorophenol
4-chlorophenol
,6-dichlorophenol
etrachlorobenzene
HERBICIDES
!,4-D
:.4.5-TP
:,4,5-T
DIOXIN
:,3,7.8-TCDD
METALS
Antimony
Arsenic
larium
leryllium
Cadmium
Calcium
Chromium
Copper
L«ad
Magneaium
Nickal
'otaaaium
Sodium
Zinc
PHYSICAL PARAMETERS
Percent aah (Wl %)
Percent moiature (Wt %)
Heating value (Btu/lb)
Total chloridea (mg/kg)
-Inorganic chloridea
Organic chloridea
mg/kg
NO - 5.8
NO-25000
NO-25000
NO -21000
ND-11
ND-150
60-100000
mg/kg
11-44000
ND-75
2.8-6500
ng/g
1.9-120
mg/kg
NO - 27.3
NO - 0.64
3.3-68.6
NO-0.31
NO-1.4
1030-37300
3-31.5
5.4-103
1.6-58.1
89.9-3350
1.9-28.2
NO-404
369-4060
21.1-418
1.1-49.6
3-61
NO -10600
NO -30000
ND-12000
NO-29800
mg/kg
3.8
170
67
49
11
14
330
mg/kg
6300
18
74
ng/g
5.1
mg/kg
5.8
0.41
55
0.19
0.77
997
8.3
12.1
14.3
359
4.4
113
746
32.5
5.5
37
3200
8800
600
7600
NOTES:
(a) Only detected concentration* are uaed when determining the median value.
VOLUME BREAKDOWN
TOTAL QUANTITY OF SHREDDED TRASH - 1150 cubic y arda
35
-------
TABLE 5-13
SHREDDED PALLETS ANALYTICAL SUMMARY
CONCENTRATION
RANGE
MEDIAN
VALUE (a)
CHLORINATED
BENZENES/PHENOLS
2-chlorophenol
2,4-dichloroph«nol
2,4,6-trichlorophenol
2,4.5-trichlorophenol
4-chlorophenol
2,6-dichlorophenol
2,3,6-trichloroph«nol
Tetrachlorobenzene
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T
DIOXIN
2,3,7,8-TCDD
PHYSICAL PARAMETERS
Percent a»h (Wt %)
Percent moieture (Wt %)
Heating value (Btu/lb)
Total chloridee (mg/kg)
-Inorganic ehlorid**
-Organic chloride*
mg/kg
ND-45
NO-1000
ND-290
19-530
ND-85
NO-160
NO-24
12-170
mg/kg
NO-2200
NO-65
ND-560
ng/g
2.5-4100
mg/kg
NO 5.3
1.9-212
105-1010
0.53-1.7
0.99 - 3.8
ND - 5.8
NO-296
ND-1.9
ND-0.89
ND-0.67
23.7-2000
6.6-20.1
0.3-3
15-50
4300-7700
ND-21000
ND-700
ND-20300
mg/kg
4.9
210
40
75
5.4
27
9.4
27
mg/kg
220
29
45
ng/g
27
mg/kg
3.7
52
453
0.8
1.3
1.3
75.6
12
0.89
0.67
101
9.9
0.6
36
4800
6800
700
6100
NOTES:
(a) Only detected concentration* are ua«d when determining the median value.
VOLUME BREAKDOWN
TOTAL QUANTITY OF SHREDDED PALLETS - 1090 cubic yarda
36
-------
TABLE 5-14
TRANSFORMER OIL ANALYTICAL RESULTS
AROCLOR AROCLOR AROCLOR
TRANSFORMER 1016 1254 1260
OWNER (mg/kg) (mg/kg) (mg/kg)
HE-EE-001-OLD-01
HE-EE-001-OLD-02
HE-EE-002-OLD-01
HE-EE-003-OLD-01
HE-EE-004-OLD-01
HE-EE-005-OLD-01
HE-EE-006-OLD-01
HE-EE-007-OLD-01
HE-EE-008-OLD-01
HE-EE-009-OLD-01
HE-EE-010-OLD-01
HE-Eb-011-OLL»-01
AP&L
AP&L
AP&L
AP&L
AP&L
AP&L
AP&L
AP&L
Vertac
Vertac
Venae
Vertac
NOTES:
(a) Reanalyzed to obtain lower quantitation
120U
120 U
SOU
60 U
74
11 U
12 U
12 U
11 U(a)
11 U(a)
11 U(a)
11 U(a)
240 U
240 U
120 U
120 U
10
22U
24 U
24 U
22U(a)
22U(a)
22U(a)
22U(a)
limits. Refer to Section 2,2.2 for
560
570
360
210
48 U
22U
6
24 U
22U(a)
22U(a)
22U(a)
22U(a)
method.
37
-------
concentrations of highly toxic materials). No "threshold level" of
toxicity/risk has been established to equate to "principal threat".
However, where toxicity and mobility of source material combine to
pose a potential risk of 10"3 or greater, generally treatment
alternatives should be evaluated.
Low level threat wastes are those source materials that generally
can be contained and that would present only a low risk in the
event of release. They include source materials that exhibit low
toxicity (soil with concentrations not greatly above reference dose
levels or that present an excess cancer risk near the acceptable
risk range), low mobility (such as surface soil containing
contaminants that generally are relatively immobile in air or
ground water) in the environment, or are near health based levels.
Some of Onsite Operable Unit 1 media, such as liquids, semi-
liquids/solids, and sludges contained in process vessels, PCB oil
in transformers, oily leachate stored in drums, spent carbon, and
shredded trash/pallets, fit into the category of principal threat
wastes and since treatment is practicable, they must be treated.
The contaminants of concern in this category of wastes are dioxins,
PCBs, herbicides (2,4-D and 2,4,5-T), chlorophenols, and
tetrachlorobenzene. The debris resulting from the demolition of
buildings, process equipment, miscellaneous drummed wastes (such as
used tyvak suits, some RI wastes, etc.) are low level threat wastes
and therefore should be contained using engineering controls. The
primary contaminant of concern in these types of wastes is
asbestos.
The baseline risk assessment is a four-step process. The first
step, data collection and evaluation, identifies contaminants
present in the environmental media soil, ground water, surface
water, air, fish, etc. of the site. The second step, toxicity
assessment, uses the results of years of research and testing of
the effects of chemicals on the health of people and animals to
decide which of the contaminants found on site might pose a health
threat. The third step, exposure assessment, defines which pathways
(e.g., using the ground water for drinking and showering or eating
the fish) might bring the contaminants into contact with people.
The final step, risk characterization, brings the information from
the first three steps together to determine the potential severity
of health threats from the site.
The baseline risk assessment provides the basis for taking action
and indicates the exposure pathways that need to be addressed by
the remedial action. It serves as the baseline indicating what
risks could exist if no action were taken at the site. This section
of the ROD reports the results of the risk assessment conducted for
this operable unit.
Because this operable unit's media are contained in storage
vessels, drums, plastic bags, etc., currently there is no exposure
38
-------
pathway for this operable unit's media to the public, and therefore
a traditional baseline risk assessment is not feasible. A
traditional baseline risk assessment will be performed for the site
as part of Onsite Operable Unit 2, which includes surface soils and
ground water. Human health and ecological risks associated with the
surface water, off-site soils, and other contaminated off-site
media were addressed in the Vertac Off-site Record of Decision,
issued in September 1990.
Exposure to the public, however, could occur from a catastrophic
release. Therefore, a reasonable maximum catastrophic release
scenario was developed to assess the potential risk from such a
release and to assess the need for remedial action. Because the no
action alternative cannot ensure that the property could not be re-
zoned for residential or commercial purposes, uncontrolled human
contact with the Onsite Operable Unit I media is possible. Based on
the 2,3,7,8-TCDD (dioxin) concentrations found in Onsite Operable
Unit 1 media, human exposure to concentrations in excess of those
considered acceptable (for example, the acceptable 2,3,7,8-TCDD
concentration level for soils in residential or recreational areas
is l ppb) could occur.
To evaluate potential risk from the Site, a scenario was considered
whereby a catastrophic release of toxicants would occur from some
of the more heavily contaminated Onsite Operable Unit I media. A
fire scenario was selected for this purpose based on the available
analytical data for Onsite Operable Unit I media. The scenario
involves the burning of the trash and pallets that are stored under
a black PVC tarp and within a bermed area at the west end of the
Formulations Building. Shredded trash and pallets contain high
concentrations of 2,3,7,8-TCDD, herbicides, chlorophenols, and
tetrachlorobenzene. If a person (receptor) at the fence line
inhaled the smoke for a 12-hour period, the calculated excess
cancer risk from inhalation of 2,3,7,8-TCDD would be 1.9E-04 (1.9
excess cases in 10,000). Similarly, the risk posed by 2,4,6-
trichlorophenol during this 12-hour period would be equivalent to
5.4E-11 (5.4 excess cases per 100 billion people). These risk
calculations include only the inhalation pathway; risk resulting
from deposition of contaminants on soils, in surface waters, or
entry into the food chain were not evaluated as part of this
particular scenario.
It DESCRIPTION OF ALTERNATIVES
7.1 ALTERNATIVES
The alternatives for Onsite Operable Unit I include:
Alternative 1: No action.
Alternative 2: Onsite secure storage with onsite lined
consolidation/containment unit.
Alternative 3: Off-site incineration with onsite lined
39
-------
consolidation/containment unit.
Alternative 4: Onsite incineration with onsite lined
consolidation/containment unit.
Alternative 5: Onsite incineration with off-site
disposal.
The majority of the alternatives present center around two remedial
components: incineration and consolidation/containment.
ALTERNATIVE 1; NO ACTION
The no action alternative for Onsite Operable Unit I media at the
Site provides a basis for comparing existing site conditions with
those resulting from implementation of the other proposed
alternatives. Under the no action alternative, no additional
measures would be used to remediate contaminant sources. Access to
the site would be prohibited only by the existing site fence.
Therefore, public access would only be passively restricted. No
institutional controls, facility maintenance, or monitoring would
be implemented.
Implementing no remedial activities for the Onsite Operable Unit I
media at the Site allows the existing contaminant sources to remain
in place. The potential for exposure to contaminants is not
reduced in this alternative.
There are no capital or operation and maintenance costs associated
with this alternative.
ALTERNATIVE 2; ONSITE SECURE STORAGE WITH ONSITE LINED
CONSOLIDATION/CONTAINMENT UNIT
The onsite secure storage alternative would involve interim storage
that complies with standards for the more hazardous contents of
process vessels and drums onsite. This storage would be an interim
remedy that would be used until more cost-effective and efficient
remedial technologies become available. The major components of
this alternative include:
Construction of a storage building capable of containing
the process vessel contents and drummed onsite wastes
(spent carbon, french drain oily leachate, and other
containerized materials). PCB transformer oils and
compacted Regina Paint Building drums would also be
stored in this building.
Construction of a permanent (long-term) above-ground,
lined consolidation/containment unit, and packing of the
asbestos-containing materials and the demolition debris
into the unit.
Abatement (removal and disposal) of friable asbestos-
40
-------
containing materials (ACM) , including pipe insulation and
possibly building shingles/tiles.
Emptying the contents of the process vessels into
compatible containers.
Demolition of the buildings and process equipment
(including emptied process vessels) in the central
process area and the Regina Paint Building to the ground
surface, with the exception of the bagged soil storage
building and the bermed and tarped area containing bagged
trash and pallets. These latter facilities would
continue to function as interim storage units. The
demolition debris and process equipment would be put into
the consolidation/containment unit. The active water
treatment plant would not be demolished.
Periodic inspection of the container storage building and
the consolidation/containment unit.
Figure 7-1 presents a possible location and the major components of
Alternative 2.
Container Storage Building
The container storage building to be constructed onsite would be
for interim secure storage of process vessel contents, spent
carbon, french drain oily leachate, PCB transformer oil, and
miscellaneous drummed wastes. To store these materials, a 400-ft
x 100-ft facility has been conceptually designed. The conceptual
design features are shown in Figure 7-2.
After the container storage building is operational, waste-
containing drums being stored within the central process area,
including contents transferred to compatible containers from
vessels, would be transported to the container storage building.
Empty drums within the Regina Paint Building would be crushed and
overpacked in 85-gallon drums. Once all of the drums have been
removed from the central process area, the process vessel contents
would be recontainerized and stored. Because of the wide range of
materials within the vessels, ranging from liquids (aqueous and
organic) to crystalline solids and soils, numerous removal
techniques would be required to collect the vessel contents, such
as digging, shoveling, gravity draining, heating/slurrying, and
pumping. Safe removal of vessel contents may be extremely
difficult because of limited access and the mixed, multiphase
material in some vessels. Once a vessel is emptied, the contents
would be transferred to a new container for loading into the
container storage building. Care would be taken to make sure that
the contents are placed into compatible containers (i.e., stainless
steel, polypropylene, or glass lined) because many of these
materials are highly corrosive.
41
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42
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ACO Channel Slop*
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Dram Constructed
of Polyester Concrete
or Equal
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Smoke Detector
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Roof Ventilators
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For Roof Ventilator - Typ.
G73-566
6* Curb
Side View
FIGURE 7-2 CONTAINER STORAGE BUILDING
CONCEPTUAL DESIGN
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PCB transformer oils would also be collected in drums and stored in
the container storage building. The transformers that do contain
PCB-contaminated oils would be de-energized, drained,
decontaminated (if possible), and refilled if they are planned to
remain in use. After refilling, the transformer could be put back
in service, if needed. The new contents would be checked after an
equalization period to confirm the PCB concentration is less than
50 ppm.
The capacity of the storage building is approximately 4,000 drums
(assuming 4 rows of 36 pallets per row, stacked 2-high, containing
4 drums each, per bay). The building consists of 4 bays.
Onsite Consolidation/Containment Unit
An above-ground, lined, consolidation/containment unit would be
constructed and filled to provide long-term isolation of building
materials, process equipment, and containerized soils, trash, and
pallets. The lined consolidation/containment unit would be
constructed onsite to contain approximately 30,000 cubic yards of
site debris, including any asbestos-containing material. Two types
of consolidation/containment units (single lined and double lined
units) are proposed in Alternative 2.
Single Liner Unit
The first design scenario for the consolidation/containment unit
would be a clay-lined/clay-capped unit similar to the vault
constructed onsite in 1985. This unit has been conceptually
designed as follows (Figure 7-3) :
The unit would be constructed entirely aboveground.
To accommodate the 30,000 cubic yards of debris to be
generated, the foot print of the unit would need to be
approximately 300 ft x 300 ft. The foot print would rest
upon a 5-foot clay base.
The unit would be approximately 30 feet high, sloping
upward at a maximum rate of 3:1.
A leachate collection system would rest above the single
clay liner and collect into a sump. The sump would be
drained or pumped to the onsite treatment plant.
Upon closure, a 3-foot thick clay cap would be placed
over the unit. Venting of the unit through the clay cap
would be necessary to release gases from the
biodegradation of organic material, particularly wood.
Emissions through the vents may require treatment. Top
soil would be placed on the cap to promote vegetation and
to keep the cap intact.
44
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Double Liner Unit
The second design scenario for the consolidation/containment unit
would be a double-liner system with leachate collection and
detection systems. This unit would comply with RCRA design
standards. The conceptual design of this unit is similar to the
unit described above, with the following exceptions (Figure 7-4):
The leachate collection liner system would consist of two
liners, a leachate collection system, and a leachate
detection system. The top liner would be a compatible,
flexible membrane liner at least 60 mils thick (minimum
requirement). The conceptual alternative for the
consolidation/containment unit uses an 80-mil thick liner
to provide a stronger, more puncture-resistant barrier.
The bottom liner would be a composite made of a
compatible, flexible membrane liner (80 mil) on top of
3 feet of clay.
The leachate collection system would rest above the top
liner and the leachate detection system would rest above
the bottom liner.
Once constructed, the lined consolidation/containment unit would be
able to accept the demolition debris.
Asbestos Abatement
Asbestos abatement (removal and disposal) would be performed as
part of the demolition. Based on the current National Emission
Standards for Hazardous Air Pollutants (NESHAPs) asbestos criteria,
asbestos-containing materials (ACM) found onsite were present in
friable and nonfriable forms. Friable asbestos was present in
insulation on some piping and fittings, and as vessel and breaching
insulation in the boiler house. Nonfriable asbestos was present in
roofing and siding shingles and in floor tiles. Some asbestos-
bearing insulation is present inside buildings. Additional onsite
characterization may be required during remediation to delineate
ACM, where uncertainty exists, unless it is determined that all of
the insulation will be handled as ACM.
Demolition
Buildings, process equipment, and piping within the central process
area would be demolished to ground surface (foundation level) , with
the exception of the building containing the bagged soil and the
area containing bagged trash and pallets, and the water treatment
plant. The materials would be wetted during demolition.
Demolition would occur using conventional construction equipment.
The Regina Paint Building outside the central process area would
also be demolished and consolidated. The estimated volumes (after
volume reduction) of the debris are as follows:
46
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Buildings and structures - 5,600 cubic yards
Piping - 1,200 cubic yards.
Process vessels/reactors - 7,700 cubic yards.
Miscellaneous debris - 8,100 cubic yards.
The estimated total volume of debris generated from demolition
activities for this alternative would be approximately 22,800 cubic
yards. After demolition, the debris would go through a volume
reduction step where materials would be further cut and crushed to
increase the bulk density and minimize any long-term settlement in
the consolidation/containment unit. Debris would then be hauled to
the lined consolidation/containment unit for packing. Soils could
be used to fill void spaces within the consolidation/containment
unit and minimize settlement.
Pretreatment
Pretreatment of the building and equipment surfaces may be
beneficial in reducing the amount of contaminants packed into the
consolidation/containment unit and in reducing the amount of
contaminated dust that could be generated during demolition. If
implemented, pretreatment may include a scraping, dusting, wiping,
and vacuuming steps for the buildings and/or a steam-cleaning step
for the process equipment. A solvent rinse/wipe may also be used
on a limited basis, if areas of visible staining are present.
Pretreatment is not required to meet the risk-based target
concentration levels for 2,3,7,8-TCDD (for industrial scenario),
but may be useful in reducing potential cosolvents, where
structural conditions permit. Decontamination may be performed to
remove dust and particulates from exposed surfaces.
Steam cleaning may be used to decontaminate equipment with visible
organic staining. Steam cleaning would be performed to remove dust
and soluble organic compounds from visible surfaces. Those pieces
of equipment exhibiting visible staining may be solvent-wiped if
steam cleaning were unsuccessful in removing the staining.
Bagged Soils, Trash/ and Pallets
The final component of Alternative 2 would be the continued storage
of the bagged soils and the bagged trash and pallets. The bagged
soil storage building was constructed in 1988 and is in good
condition. Because onsite interim storage is the emphasis of this
alternative, the bagged soils would remain in their current storage
locations. The same rationale would hold true for the bags of
trash and pallets that have been placed in a concrete bermed area
and covered with a PVC tarp.
The total capital costs and operation and maintenance costs for
this and alternatives 3, 4, and 5 are summarized in Table 7-1.
48
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EVALUATION OF ALTERNATIVE 3; Off-site INCINERATION WITH ONSITE
LINED CONSOLIDATION/CONTAINMENT UNIT
This alternative would involve the transport of those wastes that
could be considered a principal threat to an off-site incinerator
permitted to treat dioxin-contaminated materials. Those materials
(low level threat wastes) that could be consolidated would be
packed in a lined consolidation/containment unit on site. The main
components of this alternative include:
Emptying of process vessels, bulk storage containers, PCB
transformers, and re-containerizing the contents in
containers suitable for transport to an off-site
facility.
Compaction of the metal drums located inside the Regina
Paint Building and placement into 85-gallon overpack
containers.
Loading of the above materials, as well as the drummed
materials (spent carbon, french drain oily leachate, and
other containerized materials), for transport on semi-
trailers to an off-site hazardous waste incineration
facility.
Construction of a permanent (long-term), above-ground,
lined consolidation/containment unit onsite and packing
of the asbestos-containing materials, and demolition
debris, into the unit.
Asbestos abatement of friable asbestos-containing
materials, including pipe insulation and possibly
building shingles/tiles.
Demolition of the Central Process Area to the ground
surface, with the exception of the active water treatment
plant. The Regina Paint Building would also be
demolished.
Periodic inspection of the consolidation/containment
unit.
Shredded trash and pallets and containerized soils are
evaluated as part of both the onsite
consolidation/containment and the off-site incineration
technologies.
Option A: The shredded trash and pallets and
containerized soils would be packed into the
consolidation/containment unit along with the
demolition debris, and any asbestos-containing
materials.
50
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- Option B: The shredded trash and pallets and
containerized soils would be loaded onto semi-
trailers for transport to an off-site hazardous
waste incineration facility.
- Option C: The shredded trash and pallets would be
packed into the consolidation/containment unit and
the containerized soils would be loaded onto semi-
trailers for transport to an off-site hazardous
waste incineration facility.
Figure 7-5 illustrates a possible layout of the onsite components
within Alternative 3.
Materials to be transported to an off-site incinerator would be
carefully containerized and loaded onto semi-trailers for transport
to the incineration facility. Transportation distances are unknown
at this time. The onsite media that are candidates for off-site
incineration include:
Vessel contents (approximately 900 tons, assuming 1,800
Ibs/cubic yard).
Spent carbon (approximately 140 tons, assuming 900
Ibs/cubic yard).
French drain oily leachate (approximately 15 tons,
assuming 2,000 Ibs/cubic yard).
PCB transformer oils (approximately 1 ton, assuming 2,000
Ibs/cubic yard).
Drummed materials (approximately 165 tons, assuming 1,500
Ibs/cubic yard).
Trash (approximately 520 tons, assuming 900 Ibs/cubic
yard).
Pallets (approximately 660 tons, assuming 1,200 Ibs/cubic
yard).
Containerized soils (approximately 2,100 tons, assuming
1,500 Ibs/cubic yard).
A maximum of approximately 4,500 tons of contaminated material
would be transported off-site for treatment. Assuming a
semitrailer can haul 15 tons per load, it would require 300 trips
to transport the above materials to an off-site treatment facility
(Option B) . If the trash, pallets, and soils are to be packed into
the lined consolidation/containment unit, only 1,220 tons of
contaminated material would be transported off-site for treatment
(Option A) . This would require only 80 trips to the off-site
treatment facility. If the trash and pallets are to be packed into
the lined consolidation/containment unit, only 3,300 tons of
contaminated material would be transported off-site for treatment
(Option C) . This would require 220 trips to the off-site treatment
facility.
PCB transformer oils would also be collected in drums. The
51
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52
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transformers that contain PCB-contaminated oils would be de-
energized, drained, and decontaminated.
The 1,100 empty metal drums currently being stored in the Regina
Paint Building would be compacted and placed in 85-gallon overpack
drums. Compaction would be performed under wet conditions using a
drum crusher. It is assumed that 10 crushed 55-gallon metal drums
could fit into one 85-gallon overpack drum. This activity would
generate approximately 110 drums to be shipped for off-site
treatment.
After wastes to be incinerated off-site have been removed, onsite
remedial actions would begin. Before demolition/consolidation of
buildings and equipment in the central process area, as well as the
Regina Paint Building to the north, the lined
consolidation/containment unit would be constructed onsite to
contain approximately 30,000 cubic yards of site debris, including
any asbestos-containing material and the containerized soils
onsite. Two consolidation/containment unit scenarios are proposed
for Alternative 3. The first scenario would be a single clay-
lined/clay capped unit with leachate collection similar to the
vault constructed earlier onsite. The second
consolidation/containment unit scenario being considered would be
a double-liner system with leachate collection and detection
systems. This unit would closely resemble a RCRA-type facility.
Both of these scenarios have been conceptually described under
Alternative 2.
Once the consolidation/containment unit is constructed and
operational, all asbestos abatement, demolition, packing,
pretreatment, and monitoring/inspection activities would begin.
These activities have been described in detail under Alternative 2.
EVALUATION OF ALTERNATIVE 4; ONSITE INCINERATION WITH ONSITE LINED
CONSOLIDATION/CONTAINMENT UNIT
This alternative would involve onsite incineration of some of the
more hazardous materials (principal threats) and consolidation of
the other materials (low level threats) in an onsite
consolidation/containment unit. This alternative resembles
Alternative 3 except that the incineration would be performed
onsite instead of off-site. This alternative would comply with the
CERCLA requirements for the treatment of principal threats (process
vessel contents, spent carbon, french drain oily leachate, PCB
oils, and shredded trash/pallets). The major components of this
alternative are:
Onsite incineration of the process vessel contents, spent
carbon, french drain oily leachate, PCB transformer oils,
shredded trash/pallets, Regina Paint Building drums
(empty), and other containerized materials.
53
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Asbestos abatement for friable asbestos-containing
materials. These materials would include pipe insulation
and possibly building shingles/tiles.
Demolition of the buildings and equipment in the central
process area and the Regina Paint Building to the ground
surface. This includes buildings, piping, debris, and
process equipment, except for the water treatment plant.
Construction of a permanent (long-term) aboveground lined
consolidation/containment unit, and packing of the
demolition debris, and asbestos-containing materials into
the unit.
Delisting of the incinerator residues and packing the
solids (salts) and ash into the consolidation/containment
unit.
Periodic inspection of the consolidation/containment
unit.
Shredded trash and pallets and containerized soils are
evaluated as part of both the onsite
consolidation/containment and incineration technologies.
Option A: The shredded trash and pallets and
containerized soils would be packed into the
consolidation/containment unit along with the
demolition debris and asbestos-containing
materials.
Option B: The shredded trash and pallets and
containerized soils would be incinerated onsite
along with the other incinerable media.
Option C: The shredded trash and pallets would be
packed into the consolidation/ containment unit and
the containerized soils would be incinerated
onsite.
Option D: The shredded trash and pallets would be
incinerated onsite and the containerized soils would
be packed into the consolidation/containment unit.
Option E: The shredded trash and pallets would be
incinerated onsite and the containerized soils would
be removed from this operable unit.
Option F: The shredded trash and pallets would be
consolidated onsite and the containerized soils
would be removed from this operable unit.
54
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Figure 7-6 illustrates a possible layout of the components within
Alternative 4.
In Alternative 4A, materials including the process vessel contents,
spent carbon, french drain oily leachate, PCB transformer oils, and
Regina Paint Building drums would be thermally treated in an onsite
incinerator. In Alternative 4B, shredded trash and pallets and
containerized soils would also be incinerated onsite. In
Alternative 4C, the media in Alternative 4A plus the containerized
soils would be incinerated onsite. Materials would be removed from
the vessels and brought to the incinerator staging area in
temporary storage containers (drums or other compatible
containers). Materials that are already containerized (spent
carbon, french drain oily leachate, shredded trash, and shredded
pallets) would also be brought to the staging area. The Regina
Paint Building drums would be shredded or compacted using a drum
compactor and brought to the incinerator staging area.
Buildings and equipment in the Central Process Area would be
demolished. The bags of shredded trash and shredded pallets would
be removed from their current location in preparation for packing
into the consolidation/containment unit (Option A) or incineration
(Option B) . Asbestos abatement and construction of the
consolidation/containment unit would occur during demolition. The
bags of contaminated soil will be removed from their location in
preparation for packing in the consolidation/containment unit.
The construction of the consolidation/containment unit would be the
same as described in the above alternative. The design of the unit
(single- or double-lined) would determine the need for
pretreatment. If a single, clay-lined unit is chosen, pretreatment
of the materials (buildings, process vessels, piping, and debris)
prior to consolidation would proceed as described previously. The
containerized soils would be consolidated with the other materials
without any pretreatment.
EVALUATION OF ALTERNATIVE 5: ONSITE INCINERATION WITH OFF-SITE
DISPOSAL
This alternative would involve incineration of all materials
characterized during Onsite Operable Unit I and disposal of the
delisted incineration residues in an off-site landfill. This
alternative offers a permanent remedial solution for each media,
although implementation and cost of this solution may be
prohibitive. The major components of this alternative are:
Asbestos abatement of friable asbestos-containing
materials. These materials would include pipe insulation
and possibly building shingle/tiles.
Demolition of the buildings and equipment in the central
process area and the Regina Paint Building to the ground
55
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surface. This includes buildings, piping, debris, and
process equipment, except the water treatment plant.
Onsite incineration of Onsite Operable Unit I materials.
This includes process vessel contents, french drain oily
leachate, spent carbon, PCB transformer oils, shredded
trash, shredded pallets, Regina Paint Building drums,
non-asbestos-containing building materials, process
equipment, process piping, containerized soils, other
containerized materials, and debris.
Delisting of incinerator residues and disposal of these
residues in an off-site landfill.
Figure 7-7 illustrates a possible layout of the components within
Alternative 5.
The building and equipment central process area and the Regina
Paint Building would be demolished as described previously. The
shredded trash, shredded pallets, and containerized soils would
also be removed from their current storage locations to
incineration. Asbestos-bearing materials would be removed prior to
demolition for off-site disposal.
Materials will be brought to the incinerator staging area for
mixing and/or size reduction. Process vessel contents would be
removed from the vessels as described previously and brought to the
incinerator staging area in temporary storage containers (drums or
other compatible containers). Materials that are already
containerized (spent carbon, french drain oily leachate, trash,
pallets, and containerized soils) would also be brought to the
staging area. The Regina Paint Building drums may be compacted
using a drum compactor near the Regina Paint Building or brought to
the staging area (for compaction or shredding) . The incinerator ash
and any other residue would be delisted and sent to an off-site
landfill. Once delisting is complete, the incinerator residues
would be able to be disposed at an off-site sanitary landfill.
7.2 ARARS
The Super fund Amendments and Reauthorization Act (SARA) of 1986 and
the National Contingency Plan (NCP), revised March 8, 1990,
provides that the development and evaluation of remedial actions
under the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA or Superfund) must include a
comparison of alternative site responses to applicable or relevant
and appropriate Federal and state environmental and public health
requirements (ARARs).
Identification of ARARs must be done on a site-specific basis. The
NCP and SARA do not provide across-the-board standards for
determining whether a particular remedial action will produce an
57
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adequate remedy at a particular site. Rather, the process
recognizes that each site will have unique characteristics that
must be evaluated and compared to those applicable and relevant
requirements that apply under the given circumstances. In
accordance with the requirements of the NCP, the remedial action
selected must meet all ARARs unless a waiver from specific
requirements can be granted.
For remedial actions performed under SARA, permits for compliance
with the Resource Conservation and Recovery Act (RCRA), National
Pollutant Discharge Elimination System (NPDES), and Clean Air Act
(CAA) regulations for onsite remedial actions are not required.
However, CERCLA and SARA do require that the selected alternative
meet relevant and appropriate regulatory standards or performance
levels where possible, even though a permit is not required.
Relevant and appropriate regulatory standards address problems or
situations sufficiently similar to those encountered at a CERCLA-
regulated site. Therefore, their use is well-suited to the
particular site of concern. ARARs are defined as follows:
Applicable requirements are those cleanup standards,
standards of control, and other substantive environmental
protection requirements, criteria, or limitations
promulgated under federal environmental, state
environmental, or facility siting law, that specifically
address a hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstance found at
a CERCLA site.
Relevant and appropriate requirements are those cleanup
standards, standards of control, and other substantive
environmental protection requirements, criteria, or
limitations promulgated under federal or state law that,
while not "applicable" to a hazardous substance,
pollutant, contaminant, remedial action, location, or
other circumstance at a CERCLA site, address problems or
situations sufficiently similar to those encountered at
a CERCLA site.
ARARs may be divided into the following categories:
Chemical-specific requirements are health- or risk-based
concentration limits or ranges in various environmental
media for specific hazardous substances, pollutants, or
contaminants. These limits may take the form of action
levels or discharge levels.
Location-specific requirements are restrictions on
activities that are based on the characteristics of a
site or its immediate environment. An example would be
restrictions on wetlands development.
59
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Action-specific requirements are controls or restrictions
on particular types of activities in related areas such
as hazardous waste management or waste water treatment.
An example would be RCRA incineration standards.
The chemical-specific, location-specific, and action-specific ARARs
for Onsite Operable Unit I media at the site are listed in Table
7-2, and described in more detail in the remainder of this section.
FEDERAL ARARs
Resource Conservation and Recovery Act fRCRAl
RCRA requirements may be applicable to the Vertac site because some
of the contaminated materials found at the Vertac site are
considered RCRA-listed wastes. Regulations promulgated under RCRA
generally provide the basis for identification and management of
hazardous waste and establish technology-based requirements for
active or proposed hazardous waste facilities. RCRA facility
design standards may also be consulted if appropriate for wastes
other than RCRA wastes containing significant hazardous
constituents.
Chemical-Specific Requirements
Because of the range of chemicals detected at the site, including
solvents, herbicides, and 2,3,7,8-TCDD, numerous chemical-specific
requirements exist. According to 40 CFR § 261.31 (hazardous wastes
from non-specific sources), some of the wastes, specifically the
contents of the F-listed process vessels, would be given the
hazardous waste numbers of F02X (F020, F022, F023, F026, or F027).
These waste numbers are described and defined in 40 CFR § 261.31.
2,3,7,8-TCDD is produced as a byproduct during the manufacture of
herbicides. These potentially dioxin-containing F-listed wastes are
labeled "acutely hazardous wastes" (40CFR § § 261.30 (d) and
261.31).
Some of the other materials characterized during this operable unit
investigation may also be characterized as listed or characteristic
RCRA wastes. These wastes would be defined as follows:
Materials that are F-listed, such as spent alcohols and
solvents, but are not defined by the F-listed
classifications previously described. These materials
would be listed as F001-F005 wastes.
Materials, such as the contents of the non F-listed
tanks, may be listed, as defined in 40 CFR § 261.33, as
discarded commercial chemical products, of f-specif ication
species, container residues, and spill residue thereof.
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Table 7-2
Potential Operable Unit I ARARs for the Vertac Site
CHEMICAL-SPECIFIC
Resource Conservation and Recovery Act (RCRA)
Toxic Substances Control Act (TSCA)
Safe Drinking Water Act (SDWA)
Clean Water Act (CWA)
Clean Air Act (CAA)
Arkansas Water and Air Pollution Control Act
Noncriteria Air Pollution Control Strategy
LOCATION-SPECIFIC
Resource Conservation and Recovery Act (RCRA)
Arkansas Hazardous Waste Management Code
Arkansas Solid Waste Management Code
ACTION-SPECIFIC
Resource Conservation and Recovery Act (RCRA)
Toxic Substances Control Act (TSCA)
Safe Drinking Water Act (SDWA)
Clean Water Act (CWA)
Clean Air Act (CAA)
Arkansas Hazardous Waste Management Code
- Arkansas Solid Waste Management Code
Arkansas Water and Air Pollution Control Act
TO-BE-CONSIDERED (TBC)
City of Jacksonville Ordinances 604, 620, 684, and 877
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Materials considered RCRA characteristic wastes. RCRA
characteristic wastes are defined in 40 CFR § 261 Subpart
C as wastes displaying the characteristics of
ignitability, corrosivity, reactivity, or toxicity.
Residues from the treatment of a listed RCRA hazardous
waste are themselves considered a RCRA hazardous waste
unless delisted. Residues resulting from the
incineration of the F02X materials would be considered F-
028 wastes (40 CFR § 261.31).
The residues of materials in containers would be subject to the
above criteria unless the container is empty (40 CFR § 261.7).
It is important to note that the definitions of the F023 and F026
listings apply to the wastes only. Therefore, a strict
interpretation of these definitions indicates the vessel, or
container, would not be a listed waste.
There are other materials that contain small concentrations of
dioxin that would not be specifically listed as wastes under RCRA.
Furthermore, some materials investigated may not be considered
hazardous, but due to the nature and public awareness of the site,
it is unlikely that an off-site facility would accept these
materials.
Although some of the materials onsite may be defined as RCRA
hazardous wastes, the regulations pertaining to the dioxin-
containing F-listed wastes are more stringent than for the other
wastes. For example, 99.9999 percent (six 9s) destruction removal
efficiency (ORE) is required for incineration of these dioxin-
containing wastes, while only 99.99 percent (four 9s) DRE is
required for most other wastes. Regulatory requirements for the
land disposal of these materials are also more stringent than for
other wastes.
Location-Specific Requirements
Location-specific ARARs within RCRA may be applicable to the siting
of any onsite treatment or storage alternative. RCRA states that
any facility within a 100-year flood plain must be designed,
constructed, operated, and maintained to prevent washout. Washout
is described as "the movement of hazardous waste from the active
portion of the facility as a result of flooding". RCRA also
requires that the treatment, storage, or disposal of a hazardous
waste must not be conducted within 200 feet of a fault that has had
displacement within the Holocene time (40 CFR § 264.18).
Action-Specific Requirements
Because of the potential hazards associated with dioxins, action-
specific ARARs related to the remediation of dioxin wastes are
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especially stringent. Action-specific ARARs are usually technology
or activity-based requirements or limitations on actions taken with
respect to hazardous wastes. These requirements may be triggered
by the particular remedial action that is selected to accomplish
the selected alternative. Because there is more than one
alternative action for the Vertac site, many different requirements
may be applicable.
Corrective Action Provisions
The revised corrective action-related regulations under subtitle C
of RCRA (40 CFR § 260) became effective on April 19, 1993. The
revised regulations introduces the concept of corrective action
management units (CAMUs) and temporary units for remediation wastes
to provide facilities with wider range of remediation alternatives,
while assuring reliable, protective, and cost-effective remedies.
The Vertac Superfund Site is widely contaminated and has been
designated as and Area of Contamination (AOC), the equivalent of a
CAMU. As such, contaminated debris amenable to
consolidation/containment within the AOC may be pretreated and
consolidated without incurring placement or triggering the
applicability of Land Disposal Restrictions.
Incineration
Incineration of a RCRA hazardous waste is regulated under 40 CFR §
264 Subpart o. These regulations call for an analysis of the waste
feed (40 CFR § 264.341), and for the disposal of all hazardous
wastes and residues, including ash, scrubber water, and scrubber
sludge (40 CFR § 264.351). In addition, the regulations set the
following performance standards for incineration (40 CFR §
264.343); including:
For dioxin containing wastes (F-02X), achieve a
destruction and removal efficiency (ORE) of 99.9999
percent (six 9s) for each principal organic hazardous
constituent (POHC) designated under 40 CFR § 264.342 in
the permit. DRE for dioxins is demonstrated during a
trial burn using a POHC more difficult to incinerate than
dioxin.
Reduce hydrogen chloride emissions to 1.8 kg/hr or 1
percent of the HC1 in the stack gas before entering any
pollution control device.
Not release particulate matter in excess of 180 mg/dscm,
corrected for the amount of oxygen in the stack gas.
The ability to meet these performance standards must be
demonstrated during the trial burn period.
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Furthermore, monitoring of various parameters during operation of
the incinerator is required (40 CFR § 264.347). These operating
parameters include:
Combustion temperature.
Waste feed rate.
An indicator of combustion gas velocity.
Carbon monoxide emissions.
Finally, fugitive emissions must be controlled (40 CFR § 264.345)
either by:
Keeping the combustion zone totally sealed.
Or maintaining a combustion zone pressure lower than
atmospheric pressure.
Land Disposal Restrictions
There are presently no regulations that specifically govern the
destruction efficiency for non-thermal treatment of dioxin-
containing wastes. A land disposal restriction (land ban) was
enacted under RCRA effective on November 7, 1986 (40 CFR § 268.31) .
The land ban stipulates that no untreated dioxin-containing wastes
(as defined in 40 CFR § 261.31) may be land disposed. Treatment
standards for hazardous debris, effective on November 16, 1992 (40
CFR § 268.45), requires that hazardous debris must be treated prior
to land disposal unless EPA determines under 40 CFR § 261.3(e)(2)
that the debris is no longer contaminated with hazardous waste or
the debris is treated to waste specific treatment standard provided
in this subpart for the waste contaminating the debris. Land
disposal restrictions are not applicable to onsite debris, e.g.,
equipment, buildings, or other materials, consolidated within the
"area of contamination" (AOC) . An AOC is defined as the areal
extent of contiguous contamination. RCRA requires that the
treatment of wastes that are subject to the ban on land disposal
attain levels achievable by the best demonstrated available
technology (BDAT). A treated material is required to have less
than 1 ppb TCDD, as measured by the Toxicity Characteristic (TC)
test, prior to disposal in a RCRA-permitted landfill.
The land disposal restrictions apply to the storage of certain
hazardous wastes onsite. These restrictions prohibit the onsite
storage of "banned" wastes for longer than 1 year unless the
owner/operator can prove that the extended storage is solely for
the purpose of accumulating enough waste for proper treatment.
Delisting
If the material (i.e., residues from incineration) can be delisted,
it would no longer be considered a RCRA hazardous waste, the land
ban would not apply, and the material could be placed in any
permitted solid waste landfill. Metals content within the
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incinerator ash roust also be considered before the ash could be
placed into a solid waste landfill. Metals content within the ash
would be measured by the TC test to determine if the ash would be
considered a RCRA characteristic waste. After delisting, if the
ash leachate concentrations are less than TC standards, treatment
residues would be disposed in a solid waste landfill.
Hazardous Waste Landfills
Minimum technology requirements (MTR) are not applicable within an
AOC, but may be relevant. Therefore, technical requirements for a
consolidation unit may, but are not required to, consider relevant
and appropriate certain design guidance (for covers/caps, drainage,
liners, stability, etc.) pertaining to RCRA facilities. RCRA-
specific requirements for a hazardous waste landfill are presented
in 40 CFR § 264.300 (Subpart N), which could be considered relevant
and appropriate to the consolidation unit. 40 CFR § 264.301 states
that a RCRA landfill must have two or more liners that are
designed, constructed, and installed to prevent migration of wastes
out of the landfill to the adjacent soil or subsurface soil or
ground water during the active life of the landfill.
Leachate collection systems are required above and between the
liners that are designed, constructed, maintained, and operated to
collect and remove any leachate from the landfill.
Furthermore, RCRA presents requirements for dioxin-containing
wastes. In order to place dioxin-containing wastes into a
landfill, the landfill must be operated in accordance with a
management plan for these wastes that is approved by the Regional
Administrator (40 CFR § 264.317). Approval of the management plan
would be based on the following factors:
The volume, physical, and chemical characteristics of the
waste, including migration potential.
The attenuative properties of the underlying and
surrounding soils.
The effectiveness of additional treatment, design, or
monitoring requirements.
Finally, RCRA also presents monitoring, inspection, surveying,
record-keeping, closure, and post-closure care requirements (40 CFR
§ § 264.303-264.310).
Container storage
Because container storage in a storage facility is a potential
alternative for the Vertac site, RCRA requirements pertaining to
such a storage facility may be considered relevant and appropriate.
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The container storage regulations under RCRA apply to owners and
operators of hazardous waste facilities that store containers of
hazardous waste.
According to these regulations, containers of RCRA hazardous waste
must be:
Maintained in good condition (40 CFR § 264.171).
Compatible with hazardous waste to be stored (40 CFR §
264.172).
Closed during storage (except to add or remove waste)(40
CFR § 264.173).
Container storage areas must be inspected weekly for deterioration
(40 CFR § 264.174) and have a containment system that is designed
and operated in accordance with 40 CFR § 264.175. In addition,
containers of ignitable or reactive waste must be kept at least 50
feet from the property line (40 CFR § 264.176). Furthermore,
incompatible materials must be kept separate and separated by a
dike or other barrier (40 CFR § 264.177). Finally, at closure,
hazardous waste and residues must be removed from the containment
system and containers and liners must be decontaminated or removed
(40 CFR § 264.178).
Storage of dioxin must be in accordance with 40 CFR § 268, Land
Disposal Restrictions. When such storage occurs beyond 1 year, the
owner/operator has the burden of proving that such storage is
solely for the purpose of accumulating sufficient quantities to
allow for proper recovery, treatment, and disposal (40 CFR §
268.50) .
Toxic substances Control Act (TSCA)
The Toxic Substances Contract Act (TSCA) regulates hazardous
chemical substances and mixtures deemed to present an unreasonable
risk to human health and the environment. The only identified
substances at the Vertac site that may be regulated under TSCA are
PCBs and asbestos. The asbestos regulations are identical to
NESHAPs regulations and are outlined under the Clean Air Act.
The PCBs of concern at the site are within four active transformers
located throughout the site. Under TSCA, as of October 1, 1990,
the use of network PCB transformers with secondary voltages equal
to or greater than 480 volts, including 480/227 volt systems, in or
near commercial buildings is prohibited. Also, the use of any
retrofilled PCB transformer is limited to use until October 1, 1990
(40 CFR § 761.30).
Regulations for the disposal of PCBs are also promulgated in 40 CFR
§ 761. In general, all PCBs of 500 ppm or greater must be disposed
of by incineration in incinerators in compliance with the
performance standards in 40 CFR § 761.70. PCB concentrations
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between 50 and 500 ppm may be disposed of by incineration, high-
efficiency boiler, or in a chemical waste landfill. Empty
transformers must be disposed of by incineration or chemical waste
landfill provided the transformer has been rinsed with a solvent.
Large PCB-containing capacitors (containing more than 3 Ibs of
dielectric fluid) must also be disposed of by incineration (40 CFR
§ 761.60). Storage of PCBs is also limited to 1 year (40 CFR §
761.65) .
Clean Water Act (CWA)
The Clean Water Act (CWA) requirements may be applicable because
incineration or pretreatment may generate fluids that need to be
treated and discharged. The CWA applies to point-source direct
discharges into navigable waters and indirect discharges to a
publicly owned treatment works (POTW). In the case of indirect
discharges to a POTW, the POTW sets forth pretreatment standards.
Clean Air Act (CAA)
Because asbestos was found in building and insulation materials
onsite, remedial activities must be designed to comply with the
NESHAPs regulations in the Clean Air Act (CAA). NESHAPs provides
procedures for controlling asbestos emissions during demolition (40
CFR § 61.147) and during disposal (40 CFR § 61.156). Highlights of
NESHAPs pertaining to asbestos (Subpart M) include:
Discharge no visible emissions of asbestos particulate
material to the outside air.
Friable asbestos is to be removed or contained prior to
or during demolition, unless unsafe structural conditions
exist.
When a facility component coated with friable asbestos is
being taken out in sections, adequate wetting of the
material must be performed before any cutting or
disjoining occurs.
An active, commercial waste disposal site is required to
cover the asbestos waste daily with 6 inches of compacted
nonasbestos-containing material.
Proposed amendments to the NESHAPs (54FR912; January 10,
1989) indicate that non-friable asbestos that may be
broken during demolition must also be removed prior to
demolition, except where unsafe structural conditions
exist.
Remedial technologies that could result in air emissions would have
to be designed so that emissions meet Federal or state air-emission
standards. Currently, NESHAPs regulations do not specifically
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address emissions from hazardous waste sites.
National Ambient Air Quality Standards (40 CFR Part 50) have also
been developed for particular pollutants under the Clean Air Act.
These standards are included in Table 7-3.
STATE ARAR3
Arkansas Hazardous Waste Management Code
The Arkansas Hazardous Waste Management Act of 1979 and the
Arkansas Resource Reclamation Act of 1979 are known together as the
Arkansas Hazardous Waste Management Code (the "Code"). This Code
resembles the Federal Hazardous Waste Management Regulations.
These ARARs are discussed in Subsection 4.1. The Arkansas
Hazardous Waste Management Code does contain siting criteria
(Section 5) for a hazardous waste management facility. Such a
facility may not be sited in the following areas:
An active fault zone.
A "regulatory floodway" as adopted by communities
participating in the National Flood Program.
A 100-year flood plain.
A recharge zone of a sole source aquifer designated
pursuant to the SDWA.
Wetland areas that are inundated or saturated by surface
water or ground water.
In addition, no permit shall be issued for a hazardous waste
landfill facility or surface impoundment if such a facility is
located in the following areas:
Areas of high earthquake potential.
Areas having a soil that would be classified as vertisol.
Areas in which a stratum of limestone or similar rock of
an average thickness of more than 1 meter lie within 30
meters of the base of the proposed liner system.
Areas in which the liner bottom or in-place barrier soil
is less than 10 feet above the historically high water
table.
Areas near a functioning private or public water supply
that would constitute an unacceptable risk to the public
health or safety.
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TABLE 7-3
NATIONAL AMBIENT AIR QUALITY STANDARDS
POLLUTANT
STANDARD
AVERAGING
PERIOD
REGULATORY
STATUS (a)
Sulfur oxides
Paniculate matter
Carbon monoxide
Ozone
Nitrogen oxides
Lead
Primary
Primary
Secondary
Prim. & Sec.
Prim. & Sec.
Prim. & Sec.
Prim. & Sec.
Primary
Secondary
Prim. & Sec.
Prim. & Sec.
12-month arith. mean
24-hour average (b)
2-hour average (b)
Annual arith. mean
24-hour average
8-hour average
1-hour average
Max daily 1-hour avg.
1-hour average
12-month arith. mean
Quarterly mean
80 ug/cu. m (0.03 ppm)
365 ug/cu. m (0.14 ppm)
1300 ug/cu. m (0.5 ppm)
50 ug/cu. m
150 ug/cu. m
9 ppm (10 mg/cu. m) (c)
35 ppm (40 mg/cu. m) (c)
0.12 ppm (235 ug/cu. m) (d)
0.12 ppm (235 ug/cu. m) (d)
100 ug/cu. m (0.05 ppm)
1.5 ug/cu. m
NOTES:
(a) National short -term standards are not to be exceeded more than once in a calendar year.
(b) National standards are block averages rather than moving averages.
(c) National secondary standards for carbon monoxide have been dropped
(d) Maximum daily 1 -hour average: averaged over a 2-year period, the expected number of days above
the standard must be less than or equal to one.
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Areas one-half mile from any occupied dwelling, church,
school, hospital, or similarly occupied structure.
Areas where the active portion of the facility is less
than 200 feet from the facility's property line, and less
than 300 feet from right-of-ways for roads and utilities.
Section 13 of the Code includes performance standards in addition
to the provisions of 40 CFR 264, 265, and 270. Within Section 13,
it states that when it is technically feasible, destruction of
hazardous waste should be accomplished by incineration utilizing
currently available technology. No acutely hazardous waste shall
be disposed in landfills in the State of Arkansas.
Arkansas Solid Waste Management Code
Section I of Appendix A of the Arkansas Solid Waste Management Code
pertains to friable asbestos material. The regulation states that
asbestos material wastes shall be handled in accordance with
NESHAPs Regulations in the removal, containerizing, storage, and
transporting of materials. Additionally, Arkansas Class III and
Class IV landfills (facilities for the disposal of inert
nonputrescible and approved process wastes only) could not accept
asbestos material wastes.
The State of Arkansas requires the following permitting and
operational standards when planning/designing a solid waste
landfill within the state:
Testing - Geological characteristics would be required to
indicate soil conditions, ground water elevation and
movement, and subsurface characteristics.
Equipment - Verification of proper equipment available to
properly operate the landfill facility.
Geologic Structure - The subsoil and lithological
structure shall be such that there is reasonable
assurance that leachate from the landfill will not
contaminate the ground waters or surface waters of the
state.
Sedimentation and Surface Water Control - The surface
contour of the area shall be such that surface runoff
will not flow through/into the fill area.
'- Water Table - Landfill operations will maintain a safe
vertical distance between deposited refuse and the
maximum seasonal water table elevation and shall include
such measures necessary to prevent contamination of the
ground water.
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Flooding - Sites subjected to flooding shall be avoided.
Site Improvement - The following physical improvements
shall be made before a landfill site is placed in
operation.
The site shall be adequately fenced, with an
entrance gate that can be locked and posted.
All weather operational roads shall be provided.
Arrangements shall be made for fire-protection
services.
Operation - All operations of the landfill shall be in
accordance with the approved plans and the Arkansas Solid
Waste Management Code.
Arkansas Water and Air Pollution Control Act
Arkansas air and water quality regulations resemble the national
standards set forth by the U.S. EPA under the Clean Air and Clean
Water Acts, but require preconstruction review by the state. In
addition, Section 5 of the Arkansas Air Pollution Control
Regulations outlines specific limitations for particulate emissions
from new or modified sources. These limits are based solely on the
amount of material being processed (Ib/hr).
Arkansas Noncriteria Air Pollutants Control Strategy
ADPC&E has also implemented an evaluation of the emissions of
proposed emission of noncriteria air pollutants from all sources in
order to determine if a permit should be issued or if an existing
source should be required to retrofit control equipment. The
Noncriteria Air Pollutants Control Strategy (NAPCS) is based upon
Threshold Limit Values (TLVs) for chemical substances adopted by
the American Conference of Governmental Industrial Hygienists
(ACGIH).
According to NAPCS, the predicted ambient air concentration of
gases and vapors is considered acceptable if it is less than 1/100
of the ACGIH TLV. The ambient concentration is determined by using
appropriate atmospheric dispersion models over a 24-hour average.
The spacing between receptors used in the model is 100 meters (in
the area of the highest concentration). The NAPCS may consider 8
and 24-hour averages, first highs, as well as annual averages for
use in assessing risk.
TLVs have been established for the following contaminants of
concern:
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Compound TLV
2,4-D 10 mg/m3
2,4,5-T 10 mg/m3
Toluene 375 mg/m3
Phenol 19 mg/m3
As stated in the NAPCS, when the substance emitted is a particulate
compound and persistence in the environment is expected, the
predicted annual average concentration is considered acceptable if
it does not exceed the dosage mass of the LD50 (lethal dose for 50%)
expression divided by 10,000.
TO-BE-CONSIDERED (TBCs)
City of Jacksonville Ordinances 604, 620, 684. and 877
Existing operations at the Vertac site involve the pretreatment of
water collected in the french drain system and water collected in
the surface water diversion ditch system. This treated water is
then combined with sanitary waste water and discharged to the
Jacksonville West Publicly Owned Treatment Works (POTW). POTW
influent must meet pollutant limitations on metals, chlorinated
phenols, chlorophenoxyherbicides, and 2,3,7,8-TCDD as outlined in
City Ordinance 877. POTW effluent must meet secondary taste and
odor standards before being discharged to Bayou Meto. Taste and
odor standards for chlorophenols range from 0.1 ug/L (4-
chlorophenol) to 2.0 ug/L (2,4,6-trichlorophenol).
£i SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The nine criteria for evaluation of an alternative are categorized
into three groups: threshold criteria (overall protection of human
health and environment and compliance with ARARs), primary
balancing criteria (long-term effectiveness and permanence,
reduction of toxicity, mobility, or volume through treatment,
short-term effectiveness, implementability, and cost), and
modifying criteria (state and community acceptance). The threshold
criteria must be satisfied in order for an alternative to be
eligible for selection. The primary balancing criteria are used to
weigh major tradeoffs among alternatives. The modifying criteria
are taken into account after public comment is received on the
proposed plan.
8.1 THRESHOLD CRITERIA
Overall Protection of Human Health and Environment
This evaluation criterion involves consideration of the overall
protection of human health and the environment. The overall
assessment of protection draws on the assessments conducted for
other evaluation criteria, especially long-term effectiveness and
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permanence, short-term effectiveness, and compliance with ARARs.
Evaluation of the overall protectiveness of an alternative focuses
on whether a specific alternative achieves the remediation
objectives and describes how risks posed through each potential
exposure route addressed in the Focused Feasibility Study are
eliminated, reduced, or controlled through treatment, engineering,
or institutional controls. This evaluation also allows for
consideration of whether an alternative poses any unacceptable
short-term impacts.
All of the alternatives, except Alternative 1 (no action), provide
adequate protection of human health and the environment.
Alternatives 3 and 4 provide a high degree of overall
protectiveness because the principal threats are destroyed through
incineration, and low level threats are contained in a disposal
vault that will isolate the low level threats from exposure
pathways and ensure no migration from the unit. Alternative 5
provides a high degree of overall protectiveness by destruction of
all organic pollutants by incineration. Alternative 2 provides
protection by isolating hazardous material and keeping them out of
exposure pathways. However, Alternative 2 is not a permanent
solution and may eventually result in a release because some of the
wastes are corrosive liquids.
An ambient air monitoring program will be implemented to help
ensure overall protectiveness, including the short term
effectiveness of waste handling and incineration that may result in
fugitive emissions.
Compliance With ARARs
This criterion is used to determine how each alternative complies
with applicable and relevant regulations that include chemical-
specific, location-specific, and action-specific ARARs.
Alternatives 3, 4, and 5 will comply with all ARARs provided they
are properly implemented. Alternatives 3, 4, and 5 require
compliance with ARARs such as operating requirements for an
incinerator and performance requirements during remedy
implementation. Upon completion of the remedies, Alternatives 3,
4, and 5 will also comply with ARARs for treatment standards and
for disposal of treatment residuals. Alternative 2 would not
comply with RCRA storage ARARs if the material is stored for longer
than 1 year; however, it is considered an interim remedy and could
qualify for a waiver from ARARs. Alternative 1 would not comply
with ARAl-^- ,j. hazardous waste would be stored on site in a
manner that does not meet storage requirements. Alternative 1
would not meet EPA policy of using 1 ppb of dioxin as an action
level in areas of unrestricted public access and 20 ppb of dioxin
as an action level in industrial areas.
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8.2 PRIMARY BALANCING CRITERIA
Long-Term Effectiveness and Permanence
This evaluation criterion involves consideration of the long-term
effectiveness and performance of the alternative once it has been
implemented. The evaluation focuses on the presence of receptors,
magnitude of the remaining risk from untreated waste or treatment
residues, adequacy, and reliability of controls that are used to
manage treatment residuals or untreated waste.
Alternative 2 was not designed as a permanent solution and would
not be effective in the long-term because the materials of most
concern remain onsite untreated. These materials contain liquid
and corrosive wastes which present a high probability for release
if left onsite indefinitely.
Alternatives 3 and 4 offer a high degree of long-term effectiveness
and permanence. Both of these alternatives contain an incineration
component and a consolidation/containment component. By
incinerating principal threats (vessel and drum contents), the
source of additional contamination is destroyed. The residuals of
incineration, salt and ash, are dry, inert, and contain very low
levels of contaminants. The onsite consolidation/containment unit
would provide long-term effectiveness for the low level threats and
asbestos containing materials. These wastes do not contain liquids
or high concentrations of waste and can be contained without
significant risk of migration.
Alternative 5 offers the highest degree of long-term effectiveness
and permanence because all media of concern would be thermally
treated to destroy contaminants. After treatment, materials would
have to be delisted and permanently disposed off-site in a solid
waste landfill. If residuals can not be delisted, disposal would
need to be in a RCRA Subtitle C hazardous waste landfill, provided
the treatment standards have been met.
Short-Term Effectiveness
This evaluation criterion involves consideration of the short-term
effectiveness of the alternative during construction and
implementation. The evaluation focuses on the protection of the
community and the onsite personnel during implementation of
remedial measures, potential environmental impacts, and the time
required to achieve remedial response objectives.
Alternative 1 is anticipated to have the greatest short-term
effectiveness since no action is required. Of the alternatives
requiring action, Alternative 2 presents the least amount of risk
to workers, the community, and the environment because Onsite
Operable Unit I media are contained onsite with the least amount of
effort. Some particulate emissions from construction/demolition
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activities are anticipated during implementation; however, dust-
control methods would reduce this risk. Alternative 3 would involve
all of the short-term risks of Alternative 2, plus the risks
associated with transporting the more hazardous materials off-site.
Alternative 4 also includes all of the risks of Alternative 2 plus
the risks associated with onsite incineration. The short-term risk
to the neighboring community associated with Alternative 5 centers
around incinerating all media within this operable unit. This
would entail a long-term incineration project, with risk associated
with operation of the incinerator and materials handling for size
reduction to facilitate feed of multiple materials to the
incinerator.
Any of the Alternatives 2, 3, 4, and 5 will also require
implementation of an ambient air monitoring program to detect and
protect against the impact of fugitive emissions during remedy
implementation. Ambient air monitoring and a site specific risk
assessment performed as part of the ongoing incineration of drummed
wastes at the Vertac Site indicate that onsite incineration can be
performed in a manner that does not pose unacceptable risk to the
community.
Reduction of Toxicitv. Mobility, and Volume of Contaminants
Consideration of this evaluation criterion is a result of the
statutory preference for selecting remedial actions that
permanently and significantly reduce the toxicity, mobility, and
volume of the contaminants and associated media.
The following factors are considered in this evaluation:
The treatment process and materials.
The amount of hazardous materials.
The degree of reduction in toxicity, mobility, or volume.
The degree to which treatment will be irreversible.
The type and quantity of materials that remain after
remediation.
Alternative 1 will not reduce toxicity, mobility or volume of the
contaminants at the Site since no treatment or additional
containment is performed.
Alternative 2 would reduce the mobility of the contaminants.
However, this reduction would be through containment, not
treatment. Mobility may not be permanentlv reduce with Alternative
2 since wastes are liquid and ' i: * eventually be
released from the storage unit. Pretreatment would reduce toxicity
of some of the media being consolidated/contained onsite.
Alternatives 3, 4, and 5 use thermal treatment to reduce the
inherent hazards posed by the contaminants of concern at the site.
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Alternatives 3 and 4 would reduce toxicity, mobility, and volumes
for the principal threats. Pretreatment would reduce the toxicity
of the low level threats being consolidated/contained onsite.
Alternative 5 would achieve the greatest reductions in toxicity,
mobility, and volume because all media would be incinerated.
Incineration yields salt and ash as a treatment residue. However,
the salt and ash occurs at a lower mass than the organic waste
feed, is dry, not chemically reactive, and contains hazardous
constituents at concentrations much lower than the waste
incinerated.
Implementabilitv
This criterion establishes the technical and administrative
feasibility of implementing an alternative. Technical aspects
evaluated for each alternative include: construction and operation
activities, reliability of the technologies involved, ease of
undertaking additional remedial action, and monitoring after
completion of activities. Administrative concerns include
establishing contact with appropriate agencies to implement
remedial actions (e.g., obtaining permits for construction and
operation of a treatment unit). Availability of materials and
equipment needed is another factor that must be considered when
evaluating implementability of an alternative.
Alternatives 2, 3, 4,and 5 all contain technologies that are proven
and commercially available. Alternative 2 would be the easiest to
implement because no treatment would take place. Alternative 3
would require locating an off-site facility permitted and willing
to treat dioxin-containing wastes. Also, difficulties may arise in
transporting the materials to the off-site facility. Alternatives
4 and 5 would be more difficult to implement compared to
Alternative 2 because of facility requirements for the onsite
incineration component. There is strong opposition to incineration
among some members of the community that has resulted in several
lawsuits attempting to halt incineration. This ongoing litigation
will make onsite incineration more difficult to implement than
Alternative 2.
Cost
A remedial program must be implemented and operated in a cost-
effective manner and must mitigate the environmental and human
health concerns at the Site. In considering the cost-effectiveness
of the various alternatives, the following categories are
evaluated:
Capital CostsThese costs include expenditures for
equipment, labor, and materials necessary to install
remedial actions. Indirect costs may be incurred for
engineering, financial, or other services not directly
involved with installation of remedial alternatives, but
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necessary for completion of this activity.
Operating and Maintenance CostsThese costs include
post-construction expenditures incurred to ensure
effective implementation of the alternative. Such costs
may include, but are not limited to, operating labor,
maintenance materials and labor, rental equipment,
disposal of residues, and administrative, insurance, and
licensing costs.
Cost is assumed to be the critical factor in deciding among
alternatives that are in compliance with ARARs or that are better
than risk-based health standards. Costs for Alternative 2 range
from $ 19.9 to $ 21.5 million. Costs for Alternative 3 range from
$ 24.2 to $ 53.6 million. Costs for Alternative 4 range from $ 20.8
to $ 38.7 million. Alternative 4F had the lowest total cost, at
approximately $ 20.8 million. Alternative 5 had the highest total
cost, at $ 169.2 million, due to the amount and type of materials
incinerated.
It should be noted that costs associated with Alternatives 3, 4 and
5 assume that incineration residuals are delisted and disposed in
the consolidation unit onsite or off-site as solid waste.
Additional treatment at additional cost would be required if
residuals cannot be delisted.
8.3 MODIFYING CRITERIA
State Acceptance
The State of Arkansas has commented on the proposed plan. The
State is in general agreement with the proposed plan.
Community Acceptance
All comments received have been addressed in the responsiveness
summary, which is attached to this Record of Decision.
Table 8-1 summarizes the evaluation of alternatives.
9j_ THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives using the nine evaluation
criteria, consultation with the Arkansas Department of Pollution
Control & Ecology, and public comments, the EPA has determined that
Alternative 4, Option E (w.i^h the Changes described below) is the
most appropriate remedy for the Vertac site Onsite Operable Unit 1.
The selected remedy uses treatment to address principal threats and
consolidation/containment to address low level threats posed by
this operable unit media. The treatment selected is incineration.
Incineration is the best demonstrated available technology for
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dioxin wastes. Onsite incineration (except for non-F-listed wastes)
was selected because of the CERCLA preference for onsite remedies
and the current estimates indicate that off-site incineration would
cost about $ 2000 more per ton of waste. Consolidation/containment
of low level threat wastes will be within the area of contamination
defined by the site boundaries. A RCRA subtitle C landfill will be
constructed within the area of contamination. A RCRA subtitle C
landfill is required to minimize the potential for migration of
contaminants and to improve long-term effectiveness of the remedy.
A subtitle C landfill is also required because some of the wastes
to be consolidated and contained on site contain contaminant levels
above the best demonstrated available technology treatment
standards and the ground water table occurs at shallow depths. The
selected remedy consists of the following:
l. Contents and residues that are in process vessels - This media
is a principal threat and therefore shall be treated. The remedy
shall be onsite incineration for F-listed wastes. Incineration
shall be performed by an incinerator with 99.9999% destruction
removal efficiency (DRE) based on trial burn results. Demonstrated
non- F-listed wastes shall be transported to a RCRA permitted off-
site facility for treatment/disposal (if feasible) and/or
incinerated onsite. Demonstrated uncontaminated raw materials, such
as caustic, kerosene/fuel oil, etc., shall be shipped off-site for
recycle/reuse or treatment/disposal (if feasible) and/or
incinerated onsite. This flexibility in treatment/disposal,
recycle/reuse for demonstrated non-F-listed wastes and
uncontaminated raw materials in an off-site permitted facility is
built in to reduce remediation costs (since non-F-listed wastes can
be incinerated in a commercial facility with 99.99% destruction
removal efficiency). Both process knowledge and analytical
confirmation that dioxin levels are below the detection limit shall
be the performance standards to demonstrate that a particular waste
or raw material is non-F-listed.
2. Spent carbon - This media is a principal threat and therefore
shall be treated. The remedy shall be onsite incineration and/or
onsite regeneration/reuse. Regenerated carbon shall be used solely
in the onsite leachate collection/treatment system and shall not be
shipped for off-site use.
3. Containerized (drummed) wastes - Onsite incineration of drummed
franch drain oily leachate, spent Butyl-T, recovery waste, 2,4-D
drum wash waste, and used filters (from Phase 2 waste water
treatment, french drain, and sumps), since these materials are
principal threat wastes. Consolidation of drummed RI waste (such as
used cyva": suits, discarded glassware, and trash) in an onsite RCRA
Subtitle C landfill, since this waste poses a low level threat. A
remedy for the containerized mud and sediments collected from
manholes, drains, leaf filter, and drilling will be proposed during
the Onsite Operable Unit 2 remedy selection process (reasoning for
this deferment is provided under the remedy for bagged soils)
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4. PCB oils in transformers - This material poses a principal
threat and the TSCA regulations require incineration. Since the
estimated quantity of PCB oil is small (1 cubic yard) and a trial
burn is required for a PCB incinerator, this media shall be shipped
to an off-site permitted facility for incineration.
5. Shredded pallets - This media is a principal threat waste
because the sampling results indicate that this waste is
contaminated with herbicides and dioxin (average concentration of
2,3,7,8-TCDD is about 549 ppb, with a range of 2.5 to 4100 ppb).
Therefore, shredded pallets shall be incinerated onsite.
6. Shredded trash - This media poses a principal threat because of
high concentrations of chlorophenols (25,000 ppm maximum),
tetrachlorobenzene (100,000 ppm maximum), and herbicides (44,000
ppm 2,4-D maximum)present in this media. Therefore, this media
shall be incinerated onsite.
7. Buildings - This media poses a low level threat after removal of
friable asbestos. The buildings mainly contain porous media (such
as asbestos siding, shingles, wood, sheetrock, etc.). For off-site
Recycle/reuse of building materials, the building materials must be
decontaminated using the treatment standards set forth in the
hazardous debris rule (40 CFR § 268.45). This rule requires removal
of at least 0.6 centimeters of surface layer and to further ensure
removal of contaminants that may be absorbed to depths beyond 0.6
centimeters, the rule requires removal of virtually all staining
that could be indicative of the presence of toxic contaminants.
This decontamination process, if implemented, poses unacceptable
short-term risks. Therefore, the buildings (except the bagged soil
storage building, which will continue to store bagged soils, the
supervisor's office building, which will continue to be used by the
site maintenance personnel, and the waste water treatment plant
building, which will continue to be used for treatment of leachate
collection system water) shall be demolished and the debris shall
be consolidated/contained in an onsite RCRA subtitle C landfill.
8. Process equipment (including drums in the Regina Paint
Building)- After the removal of process vessel contents, this
media poses a low level threat. Since this media is made up of
mostly metal objects, it should be decontaminated and shipped off-
site for recycle/reuse. Therefore, the process equipment shall be
decontaminated utilizing treatment standards for hazardous debris
(40 CFR § 268.45), to the maximum extent practicable, and shipped
off site for recycle/reuse. The treatment standards for hazardous
debris require the use of abrasive blasting, high pressure steam
an:? wat: r sprays, -aj.er/detergent washing, liquid phase solvent
extraction, etc. to clean the surface so that residual staining is
limited to no more than 5% of each square inch of the surface area.
Debris resulting from demolition of equipment that cannot be
decontaminated, utilizing the maximum extent practicable criteria
(determined,in part, by integrity, degree of corrosion, safety
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considerations, etc.)/ shall be consolidated/contained in an onsite
RCRA subtitle C landfill.
9. Bagged Soils - Since the bagged soils (excavated from
residential yards and an onsite drainage ditch) are similar to
onsite contaminated surface soils that will be addressed in the
Onsite Operable Unit 2, remedy selection for this media is
deferred. A remedy for these bagged soils will be selected, along
with the onsite soils, during the remedy selection process for
Onsite Operable Unit 2.
10. Friable asbestos containing materials - After removal from the
buildings and process equipment following NESHAPs regulations, this
media shall be consolidated/contained in an onsite RCRA Subtitle C
landfill.
11. Residues from decontamination activities - Spent solvents
generated from decontamination activities shall be incinerated on
site. Waste water generated from decontamination activities shall
be treated onsite and discharged to the Rocky Branch Creek.
12. Onsite incinerator ash and salt - EPA is in the process of
developing and selecting a disposal option for the ash and salt
generated by onsite incineration of 29,000 plus drums. Disposal of
ash and salt that would be generated by onsite incineration of
Onsite Operable Unit 1 media shall be consistent with the remedy to
be selected for the ash and salt from the current onsite
incinerator.
The remedy shall also require implementation of an ambient air
monitoring program during remedial action to measure and protect
against excessive fugitive emissions that may pose a threat to the
community or the environment.
The estimated remedial cost for the selected remedy is $ 28.5
million. The annual O&M (inspection) cost is estimated at $ 15,000
per year. A better estimate of the annual O&M cost will be provided
in the site O&M plan (developed during remedial design).
Since all the media addressed in this operable unit would be
treated onsite, treated, reused, or disposed off-site, or
consolidated in an onsite RCRA Subtitle C landfill, the ARARs (such
as RCRA regulations for incinerators, landfills etc.) specify the
performance standards and cleanup levels.
10. STATUTORY DETERMINATIONS
Under CERCLA section 121, EPA must select remedies that are
protective of human health and the environment, comply with
applicable or relevant and appropriate requirements (unless a
statutory waiver is justified), are cost-effective, and utilize
permanent solutions and alternative technologies or resource
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recovery technologies to the maximum extent practicable. In
addition, CERCLA includes a preference for remedies that employ
treatment that permanently and significantly reduce the volume,
toxicity, or mobility of hazardous wastes as their principal
element. The following sections discuss how the selected remedy
meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through treatment of principal threat wastes (process vessel
contents, spent activated carbon, shredded trash and pallets, PCB
transformer oils, and miscellaneous drummed wastes), through
containment of low level threat wastes (asbestos, debris resulting
from the demolition of buildings and some equipment,etc.) in a RCRA
Subtitle C landfill, and through decontamination and off-site
recycle/reuse of process equipment to the maximum extent
practicable.
Treatment of the highly contaminated wastes will eliminate the
continued threat of exposure to the most toxic contaminants of
concern (dioxins, chlorophenols, tetrachlorobenzene, herbicides
such as 2,4-D and 2,4,5-T, toluene, and PCBs) via direct contact
with or ingestion/inhalation of these wastes. Since the principal
threat wastes are contained in tanks, plastic bags, etc., the exact
risk to the public cannot be quantified. However, the cancer risk,
from just one release scenario, assuming that trash/pallets would
catch fire and a receptor at the fenceline would inhale smoke for
a 12-hour period, is estimated at 2xlO"4. By treating these
principal threat wastes, the cancer risks from exposure will be
reduced to less than IxlO'6. This level falls within the EPA's
acceptable risk range of IxlO"4 to IxlO"6.
Short-term threats associated with the selected remedy can be
controlled by proper design and implementation. In addition, no
adverse cross-media impacts are expected from implementation of the
selected remedy.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy of incineration, decontamination and off-site
recycle/reuse of process equipment, and consolidation/containment
of this operable unit media will comply with all applicable or
relevant and appropriate requirements (ARARs) , if properly designed
and implemented.. The ARARs for the selected remedy are presented
below.
Chemical Specific ARARs;
RCRA
A. TSD able to accept material
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TSCA
A. PCBs
CAA
A. Asbestos
B. NAAQS
Arkansas Water and Air Pollution Control Act
A. Particulate emissions from new or modified sources
Arkansas Noncriteria Air Pollutants Control Strategy
A. Ambient air criteria
1. TLV/1000
2. LD50/10,000 for particulates
Location Specific ARARs
RCRA
A. Location stds. (40 CFR 264.18)
1. Floodplains
2. Seismic considerations
Arkansas Hazardous Management Code
A. Hazardous waste management facility siting stds.
1. Fault zone
2. Regulatory floodway
3. Floodplain
4. Recharge zone of sole source aquifer
5. Wetland areas
B. Hazardous waste landfill siting stds.
1. High earthquake potential
2. Vertisol soil
3. Limestone > 1 meter thick within 30 meter
4. Bottom liner > 10 ft above historically high water
table
5. Near a functioning water supply that would pose an
unacceptable risk
6. Within 1/2 mile of occupied dwelling
7. within 200 ft of facility boundary
8. Within 300 ft of right-of-way
Arkansas Solid Waste Management Code
A. Solid waste landfill design/planning
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1. Proper geologic conditions
2. Proper hydrogeologic conditions
3. Floodplains
Action Specific ARARs
RCRA
A. Incineration (40 CFR Subpart O)
1. 99.9999 % ORE
2. HCl emissions < 1.8 kg/hr
3. Particulates emission < 180 tons/dscm
4. Monitoring
B. Landfills (40 CFR 264 Subpart N)
1. Construction stds.
2. Operating and monitoring stds.
3. Closure requirements
4. Post-closure requirements
C. Land Disposal Restrictions (40 CFR § 268)
1. Alternative treatment standards for hazardous debris
CWA
A. Treatment Standards and Effluent Limitations for Direct
Discharge
B. Pretreatment Standards for Discharge to a POTW
TSCA (40 CFR 761)
A. Treatment/storage/disposal of PCBs
CAA
A. Demolition
1. Asbestos release
B. Disposal requirements for asbestos
Arkansas Hazardous Waste Management Code
A. Destruction of hazardous wastes by incineration where
feasible
B. No acutely hazardous wastes in landfills
Arkansas Solid Waste Management Code
A. Solid waste landfill design/planning
1. Proper geologic conditions
2. Availability of proper equipment
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3. Sedimentation and surface water control
4. Site improvements (roads, fencing, etc.)
5. Operation in accordance with approved plan
Arkansas Water and Air Pollution Control Act
A. Preconstruction review
To Be Considered fTBCs)
City of Jacksonville Ordinances 604, 620, 854, 877
A. POTW influent limitations on metals, chlorinated phenols,
chlorophenoxyherbicides and TCDD
B. Secondary taste and odor stds. for POTW effluent
Cost Effectiveness
EPA believes this remedy will eliminate the risks to human health
at an estimated cost of $ 28.5 million. The selected remedy
provides an overall effectiveness proportionate to its costs, such
that it represents a reasonable value for the money that will be
spent.
The selected remedy assures a much higher degree of certainty that
the remedy will be effective in the long-term because of the
significant reduction of the toxicity, mobility, and volume of the
wastes achieved through treatment of wastes, recycle/reuse of
process after decontamination, and consolidation and containment of
debris resulting from demolition of buildings and some equipment in
a RCRA Subtitle C landfill.
utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable
EPA has determined that the selected remedy represents the maximum
extent to which permanent solutions and treatment technologies can
be utilized in a cost-effective manner for this operable unit. Of
those alternatives (alternatives 3,4, and 5) that are protective of
human health and the environment and comply with APxARs, EPA has
determined that this selected remedy provides the best balance of
trade-offs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility, or volume achieved through
treatment, short-term effectiveness, implementability, cost, while
also considering the statutory preference for treatment as a
principal element and considering state and community acceptance.
The selected remedy treats the principal threats posed by the
highly contaminated wastes, achieving significant 2,3,7,8-TCDD,
chlorophenols, tetrachlorobenzene, 2,4-D, 2,4,5-T, toluene, and
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PCBs reductions. This remedy provides the most effective and
implementable treatment of any of the alternatives considered. The
selection of treatment of the highly contaminated wastes is
consistent with program expectations that indicate that highly
toxic and mobile wastes are principal threats and a priority for
treatment and often necessary to ensure long-term effectiveness of
a remedy.
Preference for Treatment as a Principal Element
By treating the process vessel contents, spent carbon, shredded
trash and pallets, miscellaneous drummed wastes, and PCB oils, the
selected remedy addresses the principal threats posed by the site
through the use of treatment technologies. By utilizing treatment
as a significant portion of the remedy, the statutory preference
for remedies that employ treatment as a principal element is
satisfied.
11. DOCUMENTATION OF SIGNIFICANT CHANGES
A proposed plan was released for public comment in February 1993.
The proposed plan identified onsite incineration of vessel
contents, spent activated carbon (with option for onsite
regeneration and reuse), miscellaneous drummed wastes, shredded
trash and pallets, and PCB oils, and onsite consolidation and
containment of the debris resulting from demolition of buildings
and equipment. EPA reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments, it was determined that provisions should be made for off-
site treatment/disposal and recycle/reuse of some of the
demonstrated non-F-listed vessel contents (non-F-listed wastes such
as dalapon wastes, and uncontaminated raw materials such as
hydrochloric acid, sodium hydroxide, kerosene/fuel oil, etc.) to
reduce remediation costs, to decontaminate process equipment for
off-site recycle/reuse to the maximum extent practicable, since
recycle/reuse benefits the environment, and for consolidation and
containment of some drummed (containerized) RI wastes (such as used
personal protective clothing, trash, etc.) in the onsite RCRA
Subtitle C landfill, since this type of waste poses a low level
threat. These changes are a logical outcome of the discussion of
EPA's goals for site remediation in the proposed plan.
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RESPONSIVENESS SUMMARY
VERTAC ONS1TE OU 1 ROD
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