905R90122
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.5-2161
September 1990
Superfund
_, r . f _. . . OCT091990
Records of Decis»nafllw
Update
Office of Emergency and Remedial Response
Hazardous Site Control Division OS - 220
Intermittent Bulletin
Volumes Number?
Enclosed in this issue of the ROD Update is
a third in a series of five fact sheets on
innovative technologies. This issue also
briefly describes cost estimation for reme-
dial alternatives and discussions on PCB
guidance and the development of a proto-
type RI/FS for municipal landfill sites.
Guidance on Remedial
Actions with PCB
Contamination
Recently the Office of Emergency and
Remedial Response issued A Guide on
Remedial Actions at Superfund Sites with
PCB Contamination, OSWER Directive
9355.4-01 FS. This Fact Sheet summa-
rizes the Guidance on Remedial Actions
for Superfund Sites with PCB Contamina-
tion, OSWER Directive No. 9355.4-01.
(Availability: Superfund Docket. FTS382-
3046 or commercial 202/382-3046.)
This guidance document and companion
fact sheet provide a general framework
fordetermining cleanup levels, identifying
treatment options, and assessing man-
agement controls for PCB residuals. Key
highlights of the PCB framework are out-
lined below.
Establishing Preliminary
Remediation Goals (i.e.. Cleanup
Levels)
When action is necessary to protect human
health and the environment, preliminary
remediation goals are used to define the
area over which the remedial action is
considered and help in the initial effort to
identify viable alternatives. These goals
may be refined throughout the RI/FS
process as more information on the actual
risks posed by site contamination is ob-
tained.
For soils, the concentrations of concern
for PCBs that define the area(s) to be
addressed (i.e., treated or contained) will
depend primarily on the type/extent of
exposure that will occur based on land
use. The recommended soil action level
for sites in residential and industrial areas
are 1 ppm and 10to25ppm, respectively.
(The specific action level within the range
for industrial areas will depend on site-
specific factors.)
Forcontaminatedgroundwater, response
actions that return the groundwater to
drinkable levels should be considered for
groundwater that is potentially drinkable
(i.e., Class IIB). Maximum contaminant
levels (MCL) or non-zero maximum con-
taminant level goals (MCLG) should be
achieved throughout the area of attain-
ment (where relevant and appropriate).
Other potential ARARs include state drink-
ing water standards. The proposed MCL
of .5 ppb PCBs should be considered in
evaluating cleanup goals for drinkable
groundwater.
The cleanup level established for PCB-
contaminated sediment may be based
on direct-contact threats and on expo-
sure assumptions specific to the site.
More often, however, the impact of PCBs
on aquatic life and consumers of aquatic
life will determine the cleanup level. In-
terim sediment quality criteria (SQC)
(available from Equilibrium Partitioning
Approach to Generating Sediment Qual-
ity Criteria, Briefing Report to the EPA
Science Advisory Board, EPA/440/5-89-
002, Office of Water, U.S. EPA, April
1989) have been developed for PCBs
and may be considered in establishing
remediation goals for PCB-contaminated
sediments.
Developing Remedial
Alternatives
The Agency expects that remedial alter-
natives will involve treatment of principal
threats where practicable. Principal
threats generally will include soils con-
taminated at concentrations greater than
100 ppm PCBs for residential sites and
concentrations greater than or equal to
500 ppm PCBs for industrial sites.
Treatment options being used or evalu-
ated for PCB-contaminated soils include
incineration, dechlorination, solvent ex-
traction, biological treatment, in-situ vitri-
fication, and, in some cases, solidifica-
tion. TSCA requires that PCBs at con-
centrations of greater than 50 ppm be
incinerated, treated by an equivalent
method, or disposed of in a chemical
waste landfill. To demonstrate equiva-
lence to incineration, treatment residuals
should contain less than 2 ppm PCBs.
Treatment residuals that contain PCBs at
concentrations greater than 2 ppm must
be disposed of consistent with a TSCA
chemical waste landfill. Where concen-
trations are low, waivers under TSCA of
certain landfill requirements (e.g., liner,
leachate collection) may be warranted.
Low-level threats i.e., materials contami-
nated with PCBs below 100 ppm in resi-
dential areas or 500 ppm in industrial
areas generally should be contained
rather than treated. Long-term manage-
ment will likely be required for treatment
residuals and other low-level contami-
nated materials remaining onsite at con-
centrations above the action level. These
actions are consistent with the program
expectat ionsto treat principalthreats and
contain lower-level threats.
Continued on p. 2
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Continued from p. 1
Exceptions to these guidelines may be
warranted. For example, treatment of
low-level contaminated materials may be
appropriate where small volumes, sensi-
tive environments, or conditions (for
example, f loodplains) make containment
unreliable. Containment of principal
threats may be appropriate where large
volumes, complex mixtures of PCBs and
other wastes, or inaccessibility (e.g.,
PCBs buried below large volumes of other
waste) make treatment impracticable.
Selection of Remedy
The analysis of remedial alternatives is
developed on the basis of the nine evalu-
ation criteria in the NCR (300.430[e][a][iii];
300.430[f][i][i]). Primary tradeoffs for PCB-
contaminated sites likely will result from
the type of treatment selected for the
principal threats and the level of contain-
ment required for low-threat material and
treatment residuals. RODs should in-
clude remediation goals defined in the
FS for each alternative, treatment levels
to which the selected action will reduce
PCBs before redepositing residuals, and
long-term management controls that will
be implemented to contain or lim it access
to PCBs remaining onsite.
For further information, please contact
Jennifer Haley, Hazardous Site Control
Division, FTS 398-8363.
ROD Q & A
How should cleanups of PCB wastes
under CERCLA comply with TSCA
ARARS?
TSCA regulates PCBs at concen-
trations of 50 ppm or greater. Site
managers have several options
regarding ways to manage such
substances. Generally, PCB-regulated
material may be Incinerated, treated
by a method equivalent to incineration
(PCB concentrations must be red uced
to 2 ppm or less), or disposed of in a
chemical waste landfill. However, PCB
liquids at 500 ppm or greater must be
incinerated or treated by an equivalent
method. TSCA allows for PCB-
contaminated dredged material to be
disposed of by a method that is
approved by the Regional
Administrator.
TSCA also contains anti-dilution pro-
Visions that require PCBs disposed of
after 1978 to be considered (for the
purposes of determining disposal
requirements) as if it is in the form and
concentration of the original material.
It has been determined that EPA is not
subject to the anti-dilution provision
at CERCLA sites when the Agency se-
lects a remedy i.e.. EPA will evaluate
remedial actions based on the form
and concentrations of PCBs "as
found" at the she.
Municipal Landfill Study
As part of Superfund's ongoing effort to
increase the quality and timeliness of
remedy selection decisions, OERR de-
veloped a prototype RI/FS for municipal
landfill sites. The objectives of this project
were to streamline the RI/FS process by
providing maximum efficiency and effec-
tiveness to the evaluation and decision-
making process, to provide consistency
across Regions in the way they charac-
terize landfills and evaluate remedial
action alternatives, and to facilitate more
efficient designs. Streamlined method-
ologies have been developed with re-
spect to scoping, site characterization,
risk assessment, and the development of
alternatives.
A number of tools have been developed
to assist the RPM in scoping an RI/FS for
CERCLA municipal landfill sites. These
include a generic conceptual site model,
a table that lists possible, limited field
investigations, and a table of Phase I and
Phase II Rl objectives and the activities
required to meet these objectives. The
study concludes that limited field investi-
gations should be conducted to provide
information to focus future work and that
two phases of field work will usually be
required, particularly for groundwater.
Streamlining Site
Characterization
The study concluded that characteriza-
tion of a landfill's contents is generally
unnecessary, often because remedia-
tion of landfill contents in accordance
with the NCP's expectation is generally
limited to containment alternatives.
It is necessary to characterize hot spots
when documentation and/or physical
evidence indicates the presence and
approximate location of the hot spots and
when treatment of the hot spots is prac-
ticable. (Landfills containing a low vol-
ume of waste may be considered and
characterized as a hot spot.)
Treatment of hot spots is considered
practicable under both these conditions:
Wastes are in a discrete, accessible
location of a landfill and are highly
toxic and/or highly mobile, and a hot
spot is large enough that its reme-
diation will significantly reduce the
risk posed by the site, but small
enough that it is reasonable to con-
sider removal and/or treatment.
Streamlining the
Risk Assessment
To facilitate early action on the most
obvious landfill problems, the baseline
risk assessment could be streamlined
using the following approach (note that
this approach is for landfill contents,
groundwater/leachate, and landfill gas; a
more conventional risk assessment is
required for other media, and the effect of
early action must be factored into any
ongoing risk assessment):
Identify the contaminants of concern
and their concentrations using the
conceptual site model developed
during scoping and the data gener-
ated from the Rl.
Identify the pathways that pose un-
acceptable risk by comparing Rl data
to standards that are potential
chemical-specific ARARs. When
ARARs do not exist, risk-based
chemical concentrations should be
used.
Determine if a chemical in any path-
way exceeds a standard, thereby
triggering remedial action.
Where protective levels for one or
more contaminants are clearly ex-
ceeded, the basis for taking reme-
dial action can be established. Where
obvious exceedances of standards
do not occur, a more detailed, "tradi-
tional" risk assessment may neces-
sary.
Streamlining the Development
of Alternatives
The following points should be consid-
ered when developing remedial action
alternatives:
The NCP contains the expectation
that containment technologies gen-
erally will be appropriate remedies
for municipal landfills because the
Continued on p.4
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EXAMPLES OF RECORDS OF DECISION THAT
ADDRESS POLYCHLORBVATED BIPHENYLS AS A CONTAMINANT OF CONCERN
Site Name, State [ROD Sign Date]
Components of the Selected Remedy
O'Connor, ME [09/27/89]
Excavation and onsite treatment of approximately 23,500 cubic yards of soil and
sediments containing RGBs using solvent extraction; solvent extract will be inciner-
ated offsite; treated soils containing lead levels >248 pm will undergo solidification/
stabilization treatment and offsite disposal; backfilling using dean and treated soils;
pumping and offsite treatment of approximately 195,000 gallons of surface water
containing PCBs; and extraction and onsite treatment of PCB-contaminated (Aro-
chlor 1260) groundwater using filtration/carbon adsorption.
Clothier Disposal, NY [12/28/88]
Cover contaminated soil containing less than 1 ppm PCBs with one foot of clean soil;
installation of rip rap to prevent soil erosion; long-term groundwater, surface water,
air and sediment monitoring; institutional controls including land use and deed
restrictions.
Krysowaty Farm, NJ [06/20/84]
Excavation and offsite disposal of contaminated soils and wastes at an approved
PCB facility; monitoring of onsite wells; provide alternative water supply to affected
residents; post-closure environmental monitoring.
Delaware Sand & Gravel, DE [04/22/88]
Excavation of PCB-contaminated soil at Drum Disposal Area and Ridge Area;
temporary onsite storage followed by onsite mobile incineration of excavated soil and
waste; treatability studies; residual ash will be analyzed and disposed of onsite.
Douglassville Disposal, PA [06/24/88]
Removal, transportation, and offsite incineration of liquid and sludge tank waste; de-
contamination of tanks, piping, processing equipment, and building materials desig-
nated for salvage or reuse to a level not to exceed 100 ug/100 square centimeters
PCBs on the surface; offsite disposal of building rubble; placement of residuals;
residual analysis of solidified soils prior to disposal.
Smith's Farm Brooks, KY [09/29/89]
Excavation of PCB-contaminated soil, waste material, and sediments from site Area
B with onsite incineration followed by solidification/fixation of treatment residuals;
capping of soils in Area A; construction of leachate collection system; access
restrictions; and groundwater monitoring.
Laskin/Poplar Oil, OH [08/09/84]
Excavation and offsite incineration of PCB-contaminated wastewater and oils.
MOTCO, TX [03/15/85]
Excavation and offsite incineration of PCB liquid organics at a permitted TSCA
facility; excavation and offsite disposal of soil with an alkali metal polyethylene
glycolate (APEG) reagent in a batch reactor; pretreatment, if necessary, and
discharge of liquid by-products of treatment to a POTW; APEG feasibility testing will
be conducted during the design phase.
Doepke Disposal Holliday, KS [09/21/89]
Removal and offsite treatment of contaminated liquids ponded under former surface
impoundments; construction of an impermeable multilayer cap over majority of waste
area, including soils contaminated with PCBs; deed and access restrictions; and
groundwater monitoring.
Lorentz Barrel & Drum, CA [09/28/88]
Extraction of PCB-contaminated groundwater and onsite treatment using a pack-
aged ozone-UV system with discharge of treated effluent onsite to a storm sewer.
Northwest Transformer, WA [09/15/89]
Excavation, consolidation, and treatment of soils with PCB concentrations >10 ppm
using in situ vitrification; well abandonment; construction of soil cover; and ground-
water monitoring.
Pre-Treatment
Concentration
200,000 ppm max
Estimated
Volume
23,500 cubic yards
2.7 ppm
300 ppm
49 ppm
6,400 ppm
2,500 cubic yards
4,000 cubic yards
29,722 cubic yards
200,000 gallons
6,100-13,100 ppm
26,200 cubic yards
500 ppm
100 ppm
250,000 gallons
18,000 cubic yards
.07-.393 ppm
6.4 ppm
1-10 ppm
Not stated
Not stated
1,200 cubic yards
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Continued from p. 2
volume and heterogeneity of waste
within landfills will often make treat-
ment impracticable. The NCR also
contains the expectation that treat-
ment should be considered for iden-
tifiable areas of highly toxic or mobile
material posing principal threats.
Treatment of hot spots will therefore
be considered.
Treatment of soils and wastes may
be practicable for hot spots. When
treatment is not practicable or nec-
essary, consolidation of hot spot
materials under a cap is a potential
alternative.
Perimeter containment (i.e., extrac-
tion wells, slurry walls) may be re-
quired to control offsite migration of
leachate from landfill contents and
contaminated groundwater.
Extraction of leachate from landfill
contents and subsequent treatment
for an indefinite amount of time may
be necessary because of continued
contaminant loadings from the
landfill.
Constructing an active landfill gas
collection and treatment system
should be considered in situations
where current or future land use is
residential or at a minimum, where
public access is allowed, or when
the landfill produces excessive odors.
Most landfills will require at least a
passive gas collection system.
To aid in streamlining remedial alterna-
tives, site managers should consider that
the most significant potential ARARs for
municipal landfills include RCRA closure
requirements and any federal or state re-
quirements pertaining to landfill gas emis-
sions.
For more information, please see Con-
ducting Remedial Investigations/Feasi-
bility Studies for CERCLA Municipal
Landfill Sites (Directive 9355.3-11). This
document contains information on scop-
ing, site characterization, and develop-
ment of remedial action alternatives for
municipal landfill sites. This document
may be obtained in November/Decem-
ber from the Center of Environmental
Research Information (CERI) (513) 569-
7562 or FTS 684-7562. Also, please see
Streamlining the RI/FS for CERCLA
Municipal Landfill Sites (Fact Sheet;
Directive 9355.3-11FS). This fact sheet
may be obtained in October from the
Superfund Docket FTS 382-3046 or
(202) 382-3046.
Including Indirect Costs
In RI/FS Cost
Estimates
As remedial alternatives are developed
during the RI/FS, costs must be estimated
for each alternative. Cost estimates in-
clude the cost of purchasing equipment,
excavation, and maintenance. These are
direct costs that are typically included in
RI/FS cost estimates. However, there are
also indirect costs that should be consid-
ered in developing cost estimates. There
are indirect costs associated with capital
as well as O&M costs. Examples of indi-
rect capital costs are for supervision, ad-
ministration, engineering and design
during construction, permitting and legal,
startup, and operator training. Examples
of indirect O&M costs include mainte-
nance, sampling and laboratory fees, ad-
ministration, insurance, taxes, and li-
censes.
For further information, please contact
Susan Cange, Hazardous Site Control
Division (HSCD) FTS 398-8362.
See the CORA Model User's Manuallor
further information. (CORA contact: Kirby
Biggs, HSCD FTS 475-9756.)
For ideas, submissions, or questions concerning the ROD Update, please contact Sharon Frey, Hazardous Site Control Division
at FTS 398-8367. Members of the public may obtain copies by phoning or writing EPA's Public Information Center (PM-211B), 401
M St., S.W., Washington, DC 20460. Phone (202) 382-2080.
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RODS FOR MUNICIPAL LANDFILL SUPERFUND SITES
Region I
Auburn Road Landfill, NH
Auburn Road Landfill, NH
Beacon Heights, CT
Charles George, MA
Charles George, MA
Charles George, MA
Davis Liquid
Iron Horse, MA
Kellogg-Deering Well Field, CT
Landfill & Resource Recovery, Rl
Laurel Park, CT
Old Springfield, VT
Winthrop Landfill, ME
Region II
Combe Fill North, NJ
Combe Fill South, NJ
Florence Landfill, NJ
GEMS Landfill, NJ
Helen Kramer, NJ
Kin-Buc Landfill, NJ
Lipari Landfill, NJ
Lipari Landfill, NJ
Lipari Landfill, NJ
Lone Pine Landfill, NJ
Ludlow Sand & Gravel, NY
Old Bethpage, NY
Port Washington Landfill, NY
Price Landfill, NJ
Ringwood Mines, NJ
Sharkey Landfill, NJ
South Brunswick Landfill, NJ
Volney Landfill, NY
Region III
Army Creek, DE
Blosenski Landfill, PA
Craig Farm Drum, PA
Delaware Sand & Gravel, DE
Dorney Road Landfill, PA
Henderson Road, PA
Henderson Road, PA
Enterprise Ave., PA
Heleva Landfill, PA
Industrial Lane, PA
Moyer Landfill, PA
Reeser's Landfill, PA
Strasburg Landfill, PA
Tybouts Corner, DE
Wildcat Landfill, DE
Wildcat Landfill, DE
Region IV
Airco, KY
Amnicola Dump, TN
Davie Landfill, FL
Goodrich, KY
Hipps Road Landfill, FL
Kassouf-Kimberling, FL
Lees Lane Landfill, KY
NW 58th Street Landfill, FL
Newport Dumpsite, KY
Powersville Landfill, GA
Region V
Belvidere Landfill, IL
Big D Campground, OH
Date
9/17/86
9/29/89
9/23/85
12/29/83
7/11/85
9/29/88
9/29/87
9/15/88
9/29/89
9/29/88
6/30/88
9/22/88
11/22/85
Date
9/29/86
9/29/86
6/27/86
9/27/85
9/27/85
9/30/88
8/03/82
9/30/85
7/11/88
9/28/84
9/30/88
3/14/88
9/30/89
9/29/86
9/29/88
9/29/86
9/27/87
7/31/87
Date
9/29/86
9/29/86
9/29/89
4/29/88
9/29/88
6/01/88
9/29/89
5/10/84
3/22/85
9/29/86
9/30/85
3/20/89
3/30/89
3/06/86
6/29/88
9/30/88
Date
6/24/88
3/30/89
9/30/85
6/24/88
9/03/86
9/30/89
9/25/86
9/21/87
3/27/87
9/30/87
Date
6/29/88
9/29/89
Region V
Bowers Landfill, OH
Bowers Landfill, OH
Cemetery Dump, Ml
Cliffs/Dow Dump, Ml
Coshocton City Landfill, OH
E.H. Schilling, OH
Forest Waste, Ml
Forest Waste, Ml
Fort Wayne, IN
Industrial Excess, OH
Industrial Excess, OH
Ionia City Landfill, Ml
Kummer Landfill, MN
Kummer Landfill, MN
Lake Sandy Jo, In
Liquid Disposal, Ml
Marion/Bragg, IN
Mason County, Ml
Metamora Landfill, Ml
Miami County, OH
Mid-State, Wl
New Lyme Landfill, OH
Ninth Avenue Landfill, IN
Ninth Avenue Landfill, IN
Northside, IN
Oak Grove Landfill, MN
Schmalz Dump, Ml
Schmalz Dump, Ml
Spiegelberg, Ml
Wauconda Sand & Gravel, IL
Windom Dump, MN
Region VI
Bayou Sorrel, LA
Cecil Lindsey, AR
Cleve Reber, LA
Compass Industries, OK
Industrial Waste Control, AR
Region VII
Arkansas City Dump, KS
Conservation Chemical, MO
Doepke Disposal, KS
Fulbright/Sac River Landfill, MO
Minker/Stout/Romaine, KS
Minker/Stout/Romaine, KS
Todtz, Lawrence Farm, IA
Region VIII
Marshall Landfill, CO
Region IX
Jibboom Junkyard, CA
McColl, CA
Operating Industries, CA
Operating Industries, CA
Operating Industries, CA
Ordot Disposal Site, GUAM
South Bay Asbestos, CA
Tucson Airport Area, A2
Region X
Colbert Landfill, WA
Commencement Bay South
Tacoma Channel, WA
Northside Landfill, WA
Date
3/31/89
3/31/89
9/11/85
9/27/87
6/17/88
9/29/89
2/29/84
3/31/88
8/26/88
9/30/87
7/17/89
9/29/88
6/12/85
9/30/88
9/26/86
9/30/87
9/30/87
9/28/88
9/30/86
6/30/89
9/30/88
9/27/85
6/30/89
9/20/88
9/25/87
9/30/88
8/13/85
9/30/87
9/30/86
9/30/86
9/29/89
Date
11/14/86
4/23/86
3/31/87
9/29/87
6/28/88
Date
9/21/89
9/27/87
9/21/89
9/30/88
9/28/87
9/28/88
11/4/88
Date
9/26/86
Date
5/09/85
4/11/84
7/31/87
11/16/87
9/30/88
9/28/88
9/29/88
8/22/88
Date
9/29/87
3/31/88
9/30/89
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