urmeo States
Environmental Protection
Agency
'
unica OT
Emergency and
Remedial Response
EPAiROO/ROV85/012
September 1985
ERA Superfund
Record of Decision:
-------
d
" TECHNICAL REPORT DATA
"1 (PleDle reDd Instructions on the reverse before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/ROl-85/0l2
.. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 30, 1985
Picillo Farm, RI 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
8. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
115. SUPPLEMENTARY NOTES
16. ABSTRACT
The Picillo Farm site is located in Coventry, Rhode Island, approximately 20 miles
southwest of Providence. Drums containing hazardous wastes and bulk wastes were
illegally disposed wi thin an 8-acre area of the picillo Farm over a period of months in
1977 . A series of trenches--the northwest trench, northeast trench, west trench, south
trench, and two slit,trenches--were used for this activity. In September 1977, an
explosion and fire at the site brought the dumping activities to the attention of
regulatory agencies. Since September 1977, a number of investigations and remedial
activities have been conducted at the site. PCBs, organics, and phenols were identi-
fied in onsite soil. .
The selected remedial action includes: disposal of approximately 3,500 cubic yards
of primarily PCB contaminated soils and disposal of approximately 3,000 cubic yards
of primarily phenol contaminated soils onsite in a RCRA/TSCA landfill; and implementa-
tion of site closure activities. Total capital cost for the selected remedial alterna-
tive is estimated to be $841,600 with O&M costs approximately $12,120 for the first
year, $25,648 for years 2-4 and $19,048 for years 5-30 (with the exception of year 16
at $34,048). The recommended remedy will not eliminate the residual ground water at
the site. In addition to this remedy, however, EPA will implement a ground water and
surface water monitoring program and establish risk based standards that are protective
of public health, welfare and the environment. If additional remedial actions are
7. \.v IJC: .~, a KEY WORD
-------
"
INSTRUCTIONS
1,
REPORT NUMBER
Inserllhe EPA reporl number u it Ippears on the cover of the publi-:alion,
LEAVE BLANK
2.
3,
RECIPIENTS ACCESSION NUMBER
Reserved for use by ~a-:h rcporl redpient.
TITLE AND SUBTITLE
Title should indica Ie dearly and briefly the subje-:I-:overa,.: uflhe report, and be disrlay,'d rruminenlly, SL'I suhlillL', if u!!\"d, 11\ ,mali,'r
type or otherwise subordinate il to main litle, When a report is prepared in more lhan \In,' n)lun\C. fL'po'allh,' primary lillL'. add \I,)1:lIn,'
number and indude subtitle for the spec:ific: title.
4,
I,
REPORT DATE
Eac:h report shaD c:arry I dale indic:alinlilltasl monlh'and year, Indkale Ihe hasis UII whid, il was '4.'le,'led (qt.. .M/c' IIlimcc'. Jillc' III
tlpproNl, dtll~ OlIWIMlflfiOll, ~IC,).
PERFORMING ORGANIZATION CODE
Leaye blank.
e.
7.
AUTHORCS)
Give name(s) in .:o>n\lc:nlional order (loll" R. Doe, J. Rolx:rl Doc', c'fc'.), Lisl aUlhur's afliliallull if il .Iiff.'r, fmm Ih.' I,,'rfurmina: ,ifa:alli.
ulion.
..
PERFORMING ORGANIZATION REPORT NUMBER
In8ert if performinl orpnizalion wishes to assiJR thi5 number,
..
PERFORMING ORGANIZATION NAME AND ADDRESS
GiYt name,ltreet. dty,lute, and ZIP c:ode, Lisl no more than IwO levels of an ura:anilaliunal hirear.:hy,
10. PROGRAM ELEMENT NUMBER
Use the prOlflm clement number under which the report was prepared. Subordinale numbL'rs ma)' ~ indu.l,',1 ill l)a"'IIIII,'\\'s.
11. CONTRACT/GRANT NUMBER
InJert contract or panl number under which report was prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Indude ZIP code.
13. TYPE OF REPORT AND PERIOD COVERED
Indicate inlerim fmal, etr., and if applic:able, dales coyered,
14. SPONSORING AGkNCV CODE
Insert appropriate code.
15. SUPPLEMENTARY NOTES
Enter information not induded elsewhere but useful, such as:
To be published in, Supersedes, Supplements, elc.
Prepared ill .:ooperaliun wilh. Transiallull "'', 1',e""III,'d al "UII"""II\\' "'"
11, ABSTRACT
Indude a brief (200 words or ItSs) fac:tual summary of Ihe mosl silCnilkanl informalion ,'untain,'lI ill III,' "'I'url. JIll... ,."",rI millalll\ a
sipificant bibliOlflphy or lileralure survey, mention il here.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS. SeleC:1 from the Thesaurus of J::nlinc:c:rinl! and Scieillilk Terms Ihe pruper auilluri/..:d lerms thai idenlify Ihe majur
concept of Ihe research and Ire sufficiently specifIC Ind precise to be: used as Index entries for cMtaluj:Int!,
(b) IDENTIFIERS AND OPEN.ENDED TERMS. Vse identifiers for project nilml;~, cude names. cquipment cJe\ll!nalurs, cll:, Use "ren'
ended terms written in descriptor form for those subjec:ts for which no descriptor cxists.
(c) COSA Tll'n:LD GROUP. I'ield and poup Issianments are to be: laken "rom Ihe 1965 (,OSI\ 1'1 Suhj,'.:1 ('at"vCIFY l.i5t, Sin.:~ Ihe: n'lI-
jority of documents Ire mUltidisciplinary in nature. the Primary Field/Group n\ialnmenUs) will be: \~,,'ifi,' Llisdrline, arca III' human
endelvor, or Iype of physic:al objec:t. The applic:ation(s) will be cross-refcre:nL'Cd wilh \CL'unLiary I i~'hl/(;rllul' a".vnlll,'lIh Ihal ,,'ill I'lIlIu\\
ahe primary postinl(s),
,.. DISTRIBUTION STATEMENT
Denote releuabilit)' to Ihe public or limilation for reasons other Ihan security fur uamrle "Rclea...: 1;lIlilllih:lI," nle all)! a\lailahilil)' lu
the public:, with address and price, .
1...20, SECURITY CLASSIFICATION
DO NOT submil classified reports 10 the National Tcchnic:allnformation service,
21, NUMBER OF PAGES
Insert Ihe total number of pages. induding Ihis one and unnumbered pages, but exclude dhtribuliun 1i,I, it any,
22, PRICE
Inserllhe price set by the National rechnic:allnformation Service ur Ihe: GO\lcrnmenl Printing Office, il' knuwn,
-------
~ECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site: Picillo Farm, Coventry, Rhode Island
DOCUMENTS REVIEWED
I am basing my de'cision primarily on the followIng documents
describing the analysis of cost-effectiveness of remedial alter-
natives for the Picillo site:
1.
Remedial Investigation/Feasibility Study, Picillo
Hazardous Waste Site, Coventry, Rhode Island, August 1983,
prepared by Tighe' Bond/SCI in association with Leggette,
Brashears' Graham, Inc. and Ecological Analysts, Inc.
2.
Endangerment Assessment and Feasibility Study, Picillo
Site, Coventry, Rhode-Island, March 1985, prepared by
GCA Corporation, GCA/Technology Division, Bedford,
Massachusetts.
3.
Summary of Remedial Alternative Selection.
4.
Community Relations Responsiveness Summary.
5.
State and EPA staff summaries and recommendations.
DESCRIPTION OF SELECTED REMEDY
0Disposal of approximately 3500 cubic yards of primarily
PCB contaminated soils and disposal of approximately 3000
cubic yards of primarily phenol contaminated soils onsite
in a RCRA/TSCA landfill.
.....
° Implementat ion '0-£ site closure act iv it ies.
DECLARATION
Consistent with the Comprehensive Environmental Response
. Compensation, and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 C.F.R. Part 300), I have determined that at
the picillo Farm site disposal of soils contaminated with hazardous
substances in an on-site RCRA/TSCA landfill and implementatio~
of the associated site closure activities is the cost-effective
remedy for the on-site soil contamination and provides adequate
protection of public health, welfare, and the environment.
-------
-2-
I'
The sou~ce cont~ol ~emedy will ~equi~e opetation ~nd maintenance
activities to ensu~e its continued effectivene~~. These ope~ation
and ~aintenance activities will be conside~ed pa~t of the app~ove(
action and eligible fo~ T~ust Fund monies fo~ a pe~iod of one
yea~ f~om the completion of ~emedial actions.
I have also dete~minert that the action being taken is app~o-
p~iate when balanced against the availability of T~ust Fund
monies fo~ use at othe~ sitp-R.
EPA has consulted with the State of Rhode Island conce~ning
the selected source control remedy. Like EPA, the State p~oposes
that the phenol contaminated soils be placed in an on-site RCRA
landfill. The State does not concu~ with EPA's decision that the
3500 yd3 of primarily PCB contaminated soil also be disposed of
in an on-site RCRA/TSCA landfill.
The recommended remedy will not eliminate the residual
g~oundwater contamination at the site. ~PA will implement a -
groundwater and surface wate~ monito~ing program and will establish
risk based standards for the grounrlwater that are protective of
public health, welfare and the environment. Based on this infor-
mation, if additional remedial actions are determined to be
necessa~y, a Record of Decision will be prepared for app~oval of
the future remedial actions.
. 3()
I
I/~.-/Vl.~
. Reg ional Admin istrator
-~
"
-------
~
u
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
Picillo Fa~m Site
Covent~y, Rhode Island
SITE LOCATION AND DESCRIPTION
The Picillo Farm site is located in Coventry, Rhode Island,
approximately 20 miles southwest of Providence and 1 mi]~ south-
west of the intersection of Route 102 and Perry Hill Road. The
site coordinates are approximately 410 41' 20. longitude and
710 42' 45. latitude. The USGS map for the site is the Coventry
Center, RI Quadrangle which was published in 1955 and photorevised
in 1970.
The Town of Coventry, Rhode Island, based on a 1980 census
(Rand McNally, 1980), has a total population of approximately
8,000 people. The site is located in a very rural area with
approximately 30 to 40 dwellings within a 1 mile radius.
,
....
The disposal site consists of approximately 8.0 acres of cleared
land which is surrounded by woodlands and wetlands and slopes to
the northwest towards the Unnamed Swamp. A locus map of the
site is presented in Figure 1. The Picillo Farm site was listed
on the first Superfund National Priority List published in
september, 1983.
SITE HISTORY
.-
Drums containing hazardous wastes and bulk wastes were illegally
disposed within an 8-acre area of the Picillo Farm over a period
of months in 1977. A series of trenches -- the northeast trench,
northwest trench, west trench, south trench, and two slit trenches,
-- were used for this activity. In September 1977, an explosion
and fire at the site brought the dumping activties to the attention
of regulatory agencies.
Since September 1977, a number of investigations and remedial
activities have been conducted at the site. During the Fall of
1979, the Rhode Island Department of Environmental Management
(RI DEM) and the Environmental Protection Agency (EPA) contracted
with Mitre Corporation of Bedford, Massachusetts, to study and
recommend the best methods of cleanup for the site. Mitre conducted
a hydrogeological assessment of the groundwater contamination,
assessed the extent of wastes buried onsite and developed alter-
natives for short-term and long term remedial action. Upon
receipt of the Mitre report, RI DEM contracted with Jetline
-------
.- 2-
Co~po~ation of Stoughton, ~assachusp.tts to cnnduct cleanu~ ~ctiv-
ities. Bxcavation of the no~theast t~ench beuan in Septe~be~
1980, with the final ha~~el count ~eaching 2,314. The ba~~e1s
we~e disposed of in an offsite landfill. Soils f~om the excavati~
activities, contaminated with PCB'~ and othe~ o~ganic contaminants,
we~e stockpiled in the southeast corner of the site and designated
the "PCB.Pile.1I
In Decemher 1980, EPA notified RI DEM it would pay for excavation
costs of the northwest trench with money from the Clean Water
Act 311 Fund. However, due to the unavailability of anticipated
funds, RI DEM assumed funding for the excavation in March 1981
and contracted with Peabody Clean Industries. In June 1981,
Peabody Clean Industries completed excavating the 4,500 barrels
and the contaminated soils buried in the northwest. trench.
Shortly thereafter, EPA funded $250,000 for offsite disposal .of
the barrels and contaminated soils excavated from this trench.
In November of 1981, Ecology and Environment, Inc. (E'E) under~
c~ntract to EPA, submitted a hydrogeologic report providing
additional information on the Picillo site. The following February,
EPA entered into a cooperative agreement with the State for a
remedial work effort. In April 1982, under this agreement, the
State contracted with O.H. Materials of Findlay, Ohio, for the' .
removal of solid wastes. By May 1982, 0.8. Materials's excavation
of the west trench, south trench, and two slit trenches had
resulted in the removal and offsite disposal of 3,300 barrels.
Contaminated soils from this excavation were placed in two stock-
piles at the south end and near the center of the site. Because
of high concentrations of phenols (e.g. 870 ppm) discovered in
the soils, these two piles have been designated the first and
second phenol piles. (The second phenol pile has also been
referred to as the Phase III pile in the Feasibility Study). This
effort completed the removal of buried drums at the site as
identified in the previous studies conducted by Mitre Corporation.
Exploratory excavations were conducted, to confirm Mitre's findings
and no additional drums were discovered.
.
In September 1982,'O~H. Materials began land farmirtg the. first
phenol waste pile and decreased the phenol concentration from -
approximately 870'ppm to 60 ppm. Pilot studies conducted ~ the
biodegradation of the PCB contaminated soils, using comercia11y
available microbes, proved to be unsuccessful. In February
1983, RI DEM contracted the team of Tighe', Bond/SCI, Leggette,
Brashears' Graham, Inc. and Ecological Analysts, Inc. through
the cooperative agreement with EPA. They were tasked to perform
final field investigative studies and to recommend a cost-effective
groundwater discharge, treatment, and recharge system to mitigate
contaminated groundwater originating at the site.
-------
-3-
EPA, with expert assistance from GCA, reviewed the oraft Tighe &
Bond report and conclude~ that more work was required to establish
the types, amounts and disposition of wastes which remain at the
site. Additionally, EPA concluded that more work was needed to
determine the extent of source release and to profile the ground-
water/surface water contaminant plume. GCA's findings were
submitted in a report to EPA in september 1983. Subsequently,
EPA directed GCA to performed an Endangerment Assessment to
characterize the type and extent of contaminants found at the
Picillo site (both onsite and offsite) and assess their associated
hazards. A summary of the report was presented to the public in
June, 1984. In July 1984, GCA was tasked by EPA to conduct an
engineering feasibility study addressing the threat defined in
the Endangerment Assessment. This study was designed to follow
recent EPA RI/FS guidance and to respond to EPA policy concerning
appropriate responses at hazardous waste sites. .
The feasibility study was completed and presented to the public in
April 1985. EPA held a public hearing on the RI/FS and closed~out
the public comment period on May 15, 1985.
CURRENT SITE STATUS
"
Onsite Contamination - Present site features are illustrated in
Figure 2. At this time the site is ungraded and unvegetated with
some areas of the site having undergone erosion. There are
three contaminated soil piles within the site boundaries -- the
PCB, first phenol and second phenol (Phase III) soil stockpiles.
A complete list of hazardous substances identified in the three
soil piles is presented in Volume III, Appendix B of the
Endangerment Assessment and Feasibility Study. The PCB soil
stockpile is approximately 3,500 yd3 in volume and is located
in the Northeast corner of the site. The pile has been extensively
sampled on numerous occasions. The most recent sampling, conducted
in February 1984, showed PCB concentrations ranging from "not
detected" to 180 ppm (Table 1). Levels of contamination were
.not uniformly distributed such that the pile could be segregated.
Volatile organics are also present in the-soils at concentrations
in the high ppb range (Table 2). The PCB pile is covered with A
thin plastic liner to minimize fugative dust and infiltration:
this liner, however, has been badly damaged by the weather.
Similarily, a synthetic liner underlying the pile is thought to
be ruptured as a result of sampling activities.
u
The first phenol stockpile is approximately 2,000 yd3 and is located
in the north end of the site adjacent to the PCB pile. . This:
stockpile has undergone biological treatment which has reduced
phenol concentrations from approximately 870 to 60 ppm. The
contaminated soil is uncapped in the land treatment impoundment.
.
..
-------
-4-
The second phenol (Phase III) pile is a stockpile of contaminated
soil excavated f~om the d~um staging a~ea and is uncove~ed and
unlined. The amount of soil p~esent in this phenol ~ile has
been estimated at 1,000 yd3 and is located approximately in the
cente~ of the site. These soils a~e contaminated with ~e1atively
low levels of volatile o~ganics and high levels of phenols.
Soil samp~es analyzed fo~ contaminants indicate the p~esence of
tetrachloroethylene (290 ppb), xylene (7080 ppb) and ethylbenzene
(455 ppb). Recent sampling by RI DEM indicates the presence of
3430 ppm of phenol and 15,800 ppm of bis (z-ethylhexyl.) phthalate.
Offsite Contamination - Ground and surface water samples collected
from 1979 to the present indicate that a considerable quantity
of pollutants, mainly volatile organic compounds, have been
released into the local groundwater and continue to migrate
downgradient from the site. Two plumes of contaminated groundwater
associated with the Picillo site, have been identified -- the
northwest and southwest plumes. Groundwater in the northwest -
plume discharges to the Unnamed Swamp which empties into Whitford
Pond. The southwest plume discharges to Great Cedar Swamp, which
discharges to Great Grass Pond. Table 3 is a summary of organic
priority pollutant compounds detected in the groundwater. A complete
list of hazardous substances identified in the groundwater is
presented in Volume III, Appendix C of the Endangerment Assessment
and Feasibility Study.
.
Risk Assessment - As presented in the Endangerment Assessment
and Feasibility Study (Volume III, Appendix B and Appendix C),
a substantial concentration of hazardous substances remain at or
near the area where they were originally located and due to
inadequate barriers are continuing to migrate offsite via ground-
water contamination. There are four e~vironmental media through
which people can potentially come into contact with the afore-
mentioned remaining hazardous wastes at the Picillo site7 soils,
groundwa~er, surface water and air.
.
The major exposure route of concern for people and animals residing
near the Picillo site is direct. contact with contaminated soils
or wastes. Although there is presently a 24-hour guard stationed
at the site, this level of security cannot be cost-effectively
maintained. Since there are low-level PCB's as well as phenols
and volatile organics present in the stockpiles direct contact
is an important possible route of exposure, especially for children
and animals. Should repeated contact with the PCB pile occur,
there is the potential for skin adsorption of PCBs ~nd an increased
carcinogenic risk to receptors. Phenols are skin irritants and
prolonged and repeated exposure to these 80ils may result in "
irritation and cracking of skin. Ingestion of contaminated
-------
-5-
have access to the site would consist of teenage~s and young
adults; hike~s, bike ~ide~s, etc., who a~e not likely to ingest
soil. Howeve~, in the unlikely event that ingestion should
occu~, concent~ations of PCBs and phenols a~e well above allowable
concent~ations based on EPA Wate= Ouality C~ite=ia (45 F~ 79318-
79379, Novembe= 28, 1980).
In addition to the risks associated with direct contact or
ingestion of contaminated soils, p=otecting groundwate~ as a
future water supply is of conce~n1 even though grounpwate=
originating at the site is not p=esent1y being used as a
drinking water supply. Leachate containing organic chemical
contaminants from the three soil stockpiles is expected to be a
continued source of groundwater contamination at the site.
Table 5 presents data for contaminants present in soils and
leachate at the pici110 site. Contaminants present in the ground
water at the Picillo site are presented in Table 2. Concentrations
of many of the contaminants in the groundwater are above Ambient
Water Quality Criteria corresponding to an increased cancer -
risk to humans of one in one million (45 FR 79318-79379,
November 28, 1980).
/j
There is no present risk associated with the ingestion of surface
water impacted by contaminants originating at the Pici1lo site
since surface waters in the area are not currently used as potable
water supplies. Surface waters in the area that could potentially
be used as a.water supply include Whitford Pond and Great Grass
Pond. Contaminants present at the inlet to Whitford Pond are
extremely low (Table 6) and are not expected to pose a risk
to its potential use as a water supply considering dilution
effects in the Pond. No contamination has been detected in
Great Grass Pond or the outlet to Whitford Pond. As has occured
in the past, it is expected that most of the contaminated ground-
water will discharge to the swamps which act as an effective
hydrological barrier minimizing contaminant migration into Whitford
or Great Grass Ponds. Similarily, no risk exists from the possi-
bility that people may come into contact with the waters of
. Whitford Pond or Great Grass Pond through sWUmming, boating,
fishing (and fish. consumption); or other water recreation.
Also, because the maximum concentration of chemicals recorded-in
the Ponds are extremely low (or not detected) and have low biocon-
centration factors, fish are not expected to become contaminated
to levels that would pose a risk from ingestion. Thus ingestion
of fish from the Pond is not an exposure route of concern (Table 7).
Besides Whitford Pond and Great Grass Pond, the other surface
waters in the area include the Unnamed Swamp and Great Cedar'
Swamp. The potential of harm to nearby residents who come into
contact with soils, sediments or water in the swamps must be
weighed against the probability of people gaining access to these
areas. Aerial photographs of the site show dense.vegetationJ
-------
-6-
investigation teams have also ~epo~ted difficulty accessing so~e
a~eas of the swamps. In the unlikely event a child, adult, O~
dog we~e to fall into the swamp, exposu~e would be of sho~t-
du~ation to ~elatively low levels of chemicals, in most cases
lowe~ than lppm. Additionally, a pe~son would be expected to
bathe as soon as possible afte~ falling into the Swamp. The
~isk assessment concludes that contact exposu~e to the low levels
of contaminants in the Swamp fo~ short pe~iods of time is not
suspected to present health risks. As such, the risk to di~ect
contact exposure with the Swamp is not expected to pose a health
threat.
Plant and animal life in the marshes and ponds are at risk of
exposure to contaminants leaving the Picillo site via groundwater.
Because of low concentration of contaminants in the ponds, however,
the effects on aquatic life in the ponds is expected to be minim~l.
The Unnamed and Great Cedar Swamp habitats have both received
contamination from the site and will continue to do so as contam-
inated groundwater.from the site discharges to both swamps. Dering
the highest releases to the swamps, some acute or chronic toxicity
to swamp organisms may have occurred (Table 3). As concentrations
in the swamp continue to decrease, the impact to the swamp is
expected to decrease: the availability of a large amount of
similar habitat in the region should allow speedy recolonization
and recovery.
.
.-
People living near the site may also be exposed to contaminants
in the air since volatilization of chemicals is expected to
occur at a soil:air or water:air interface. Distinct chemical
odors are present at the Picillo site and in the Unnamed Swamp.
Nearby neighbors have voiced complaints concerning these odors
during past clean up activities. However, there is little potential
for continued volatilization of chemicals from the waste disposal
soils since there is only a limited amount of exposed volatile.
organics at the site. Volatilization from the groundwater discharge
areas in the swamps, however, may be a source of airborne organics
under certain meteorologic conditions. This exposure route was
evaluated in the Endangerment Assessment and determined not to
pose a.risk to publid health~ -Air-modeling for organics detected
in the Unnamed Swamp was performed to predict potential down~iDd
concentrations under worst case conditions (Table 4). Predicted
levels corresponded with levels detected in 1982 during excavation
of barrels. These values, which are at least three orders of
magnitude lower than threshold limit valves (TLV) levels set to
protect workers, represent worst case conditions which will not
be duplicated since contaminant levels in the swamp are continuously'
decreasing. However, odors may continue to exist thus posing a
-------
(j
-7-
ENFORCEMENT
A numbe~ of potentially ~esponsible pa~ties (PRPs) have been
inentified fo~ the Picillo site. Notice lette~s we~e o~iginally
sent to ten potentially ~esponsih1e pa~ties (PRPs) on Decembe~
15, 1981, and to an adnitional twenty PRPs on Janua~y 20, 1982.
Follow-up. notice 1ette~s we~e sent to a numbe~ of the PRPs on
April 12, 1983 and again on April 17, 1985.
Information requests were sent to different generators on a number
of occasions. A total of seventy requests were sent between
July 22, 1982, and August 5, 1983.
On Friday, Hay 3, 1985, EPA met with the potentially responsible
parties to begin the negotiating process. The EPA informed the
PRPs that it was seeking their comments on the RI/FS and established
the following negotiating schedule:
°Hay 15, 1985
-
public hearing on the RI/FS and close of the
public comment period. The State also
informed the EPA and PRPs they would state
their position on this date.
°July 15, 1985
- Final day for PRPs to make known their
willingness to participate in negotiation.
This date begins the 60 day formal negotiating
period.
°September 1, 1985 -
completion of the 60 day negotiating period.
Comments were received from the generator PRPs at the May 15, 1985,
public hearing. The PRPS generally concur with the offsite
remedial analysis in the feasibility study and endorse the offsite
alternative of No Action.
..
The PRPS do not concur with the onsite recommended alternative and
feel the hypothetical arealistic worst case" used in developing
the feasibility study is unrealistic. They consider the only rjsk
to be from repeated direct contact with the .PCB pile. and that
no risk exists from the .phenol piles.. Therefore, they recommend
the PCB pile be enclosed with a secure fence and possibly capped
with an earth cover seeded with thickets, thorns and poison ivy.
The PRPs contend the recommended alternative of onsite disposal
in a RCRA/TSCA landfill, presented in the feasibility study, is
excessive based on the risks that exist at the site. EPA's .
response to comments recieved from the PRPS can be found in the
attached Responsiveness Summary.
-------
-a-
On May 22, 1985, Rhode Island info~ned EPA of its desi~e to conduct
joint negotiations. EPA and Rhode Island helrl a meeting with the
PRPs on July 19, 1985. Negotiations a~e p~esently continuing witr
the PRPs and the Agency is hopeful that a settlement can be ~eachl
that is acceptable to both EPA and the State.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Although onsite remedies implemented under CERCLA are exempt from
compliance with other environmental laws, one measure used by
EPA in determining whether remedial alternatives at Supe~fund
sites adequately meets the CERCLA test of protecting public
health, welfare, or the environment is whether the alternative
attains the substantive provisions of other applicable federal
public health and environmental standards. In assessing the
technical adequacy of each proposed landfill design at the Picillo
site the agency has used as guidelines the minimum technology
requirements outlined under TSCA and RCRA.*/ Onsite disposal ~f
the contaminated soils in a RCRA/TSCA landtill complies with all
federal regulations with one exception. That exception is that
the bottom of the landfill liner system would not be at least 50
feet from the historical high watertable, as required by 40 CFR
761.75 (b)(3). It is estimated in the feasibility study that
the bottom liner would be approximately 10-15 feet above the
seasonably high ground water table. Under 40 CFR 761.75 (c)(4)
a waiver from a TSCA landfill requirement can be granted provided
the landfill will not present any unreasonable risk of injury to
health or the environment from PCBs.
.
In determining whether the onsite remedy meets the CERCLA test
of being adequately-protective of the public health, welfare, or
the environment, the Agency considered the TSCA fifty foot
requirement and has determined the onsite landfill would be
adequately protective without this requirement being met. A
layered impermeable cap would prevent human contact with wastes
*/ RCRA standards. for hazardous waste disposal facilities are
- listed under 40 CFR Part 264. The requirements a RCRA facility
must meet are outlined in 40 CFR 264 Subpart N and the Hazardous
and Solid Waste Amendments of 1984 (Section 3004 (0) Minimum
Technological Requirements). Alternative SC-2 (offsite disposal
of PCB and phenol soils in a RCRA/TSCA Landfill) and alternatives
SC-5 Consite disposal of PCB and phenol soils in a RCRA/TSCA
Landfill) are the only alternatives considered to be consistent
with these requirements.
-------
-9-
and minimize infilt~ation into the landfill. An i~pe~meable
double bottom line~ with a leachate collection systeM and leak
detection systeM will p~otect against cont~minant mig~ation. .'
Any leachate which may be gene~ated will be collected fo~ p~ope~
d isposa 1.
State haza~dous waste ~egulations p~ohibit the landfilling of
"extremely haza~dous waste" in the State, unless a variance is
granted. Soils with PCB levels in excess of 50 ppm are considered
extremely hazardous waste by the State, as a result, compliance
with State law would require obtaining a variance before the PCB
soils could be landfilled onsite. The State position is they
are unwilling to grant such a variance. Similarly, the Town of
Coventry has indicated that locating a landfill at the Picillo
Farm site would be in violation of a local zoning ordinance. As
stated, EPA legally is exempt from other laws' requirements, .
including State and local laws, in selecting onsite remedies at
Superfund sites. EPA has determined that despite these State
and local laws an onsite landfill would be adequately protective
of public health, welfare and the environment.
.
ALTERNATIVES EVALUATION
Source Control Remedial Alternatives
Onsite sources of contamination have been divided into two
operable units:
(l) PCB soils
(2) Phenol soils
As identified in the National Contingency Plan 40 CFR 300.68 (j),
the objective of the evaluation of alternatives is to select the
"lowest cost alternative that is technologically feasible and
. reliable and which effectively mitigate and minimizes damage to
and prov ides adequat'e protect ion' of publ ic . heal th, welfare or
the environment."
The following criteria, as set forth in the NCP (40 CFR 300.68 (e)(2»,
were assessed in determining appropriate source control remedial
action alternatives:
( i)
The extent to which substances pose a danger to public
health, welfare or the environment.
( i i)
The extent to which substances have migrated or are
contained by either natural or man-made barriers.
..'
-------
-10-
( iii)
The expe~iences and app~oaches used in sirnila~ situations
by State and Fede~al agencies and p~ivate pa~ties.
( iv)
Envi~onmental effects and welfa~e conce~ns.
Sou~ce Cont~ol Alte~natives:
Identification
SC-l
SC-2
SC-3
SC-4
SC-5
. 0
SC-6
,.
Description
P~esent \'Jo~th
Cost
o
No Action
o
o
Disposal of PCB & Phenol
Contaminated Soils Offsite
in a RCRA/TSCA Landfill
52,509,200
o
Close Site
o
Disposal of PCB Contaminated $1,976,000
Soils Offsite in a RCRA/
TSCA Landf ill
o
Disposal of Phenol Contaminated
Soils Onsite in a RCRA Landfill
o
Close Site
o
Disposal of PCB Contaminated $1,838,700
Soils Offsite in a RCRA/TSCA
Landf ill
o
Disposal of Phenol Contaminated
Soils Onsite in a Cap Only
Landf ill
o
Close Site
Disposal of PCB and Phenol
Contaminated Soils Onsite
in a RCRA/TSCA Landfill
$1,033,000
o
Close site
o
Disposal of PCB Contaminated $1,013,300
Soils Onsite in a RCRA/T5CA
Landf ill
o
Disposal of Phenol Contaminated
Soils Onsite in a Cap Only
Landf ill
o
-------
.
~
-11-
The No ~ction alte~native does not meet the ~CP test fo~ cost-
effectiveness in that it wouln not effectively mitigate O~ ~ini~ize
damage to and p~ovide adequate p~otection of public health, welfa~e
o~ the envi~onment. None of the site specific objectives necessa~y
to protect public health, welfa~e o~ the envi~onment, developed
from the risk assessment, would be obtained. Humans and animals
could ha~e direct contact with the wastes. Offsite rnigration of
the wastes would be possible via groundwater contamination,
erosion of contaminated soils, and fugitive air emissions.
Alternative SC-2 involves disposal of PCB and phenol contaninated
soils in an offsite RCRA/TSCA landfill. Since the source would
essentially be removed, offsite disposal of the contaminated soils
would provide adequate protection of public health, welfare and
the environment. However, the availability of RCRA/TSCA (Annex II)
landfill capacity is limited and offsite disposal would use this
valuable capacity without creating new capacity elsewhere. In
addition, the present worth costs for onsite disposal in a RCRA/
TSCA landfill, which EPA considers equally protective of publi~
health, welfare, and the environment, are approximately 50% of
costs associated with alternatives involving offsite disposal.
Because alternative SC-2 does not meet any of the three
Section 101(24) criteria for offsite remedies, EPA legally may
not use. the Fund for such an alternatIve. EPA, however, has no
objection to another party disposing of the PCB pile offsite in
a RCRA/TSCA landf ill. ..'
Alt~rnative SC-3 involves disposing of the PCB contaminated 501ls
in an offsite RCRA/TSCA landfill and disposal of the phenol
contaminated soils in an onsite RCRA/TSCA landfill. EPA considers
this alternative adequately protective of public health, welfare
or the environment. However, since onsite disposal in a RCRA/TSCA
1andfill(~C-5) is less costly and equally protective of public
health, welfare and the environment, the EPA considers it more
cost effec~ive than alternative SC~3.
r
-
Alternative SC-4 involves disposal of PCB contaminated soils off-
site in a RCRA/TSCA landfill and disposal of phenol contaminated
'soi1s onsite in a cap only landfill. The proposed cap design is
presented in Figure 4. The cap only landfill for the phenol -
. .cont~inated soils would not meet Federal guidance used to assess
the minimum technology requirements necessary to protect public
health and the environment (40 CFR 264). Also the cap only landfill
would not adequately mitigate the public health, welfare and
environmental threats posed by the site as outlined in the risk
assessment. In particular, it would not mitigate the threat of
contaminants migrating offsite via groundwater without a bottom
. liner, leachate collection system and leak detection system. .If
there were a failure in the cap, organic chemicals contaminants
could possibly migrate offsite undetected via leachate generation.
-------
-12-
,
Alte=native ~C-5, which involves onsite disposal of the PCB and
phenol contaminated soils in a RCRA/TstA landfill, will p=ovide
adequate p=otection of public health, welfa=e and the envi=onment
Const~uction of the RCRA/TSCA landfill involves well known ~on-
st=uction techniques. The technology employed can be implemented
in a ~easonable time and will have a long useful life. This
alternative meets the minimum technology ~equi~ement to p~otect
public health and the envi~onment as outlined unde~ TSCA and
RCRA. The agency used these requ i~ements as gu idel ines, in
assessing whether the proposed landfill design is ad~quate to
p~otect public health, welfa~e and the envi~onment. A schematic
of a typical RCRA/TSCA landfill is presented in Figure 3. A
layered impermeable cap would prevent human contact with wastes
and minimize or eliminate infiltration into the landfill. An
impermeable double bottom liner with a leachate collection system
and leak detection system will protect against contAminant migration.
Any leachate which may be generated will be collected for proper
disposal. Without the bottom liner, leachate collection system and
leak detection system, if there were a failure in the cap, org~nic
chemical contaminants could possibly migrate offsite undetected
via leachate generation. '
.
Alternative SC-6 involves onsite disposal of the PCB contaminated
soils in a RCRA/TSCA landfill and onsite disposal of the phenol
contaminated soils in a cap only landfill. As with alternative
SC-4, a cap only landfill for the phenol contaminated soils does
not adequately protect public health, welfare and the environment
from offsite migration of contaminants via groundwater. Addition-
ally, this alte~native already involves the construction of a
RCRA/TSCA landfill onsite for the PCB contaminated soils which
is more protective of public health, welfare and the environment.
The costs of placing the phenol contaminated soils in this landfill
are approximately the same as building a separate cap-only phenol
landfill since significant additional excavation would be necessary
to prepare the phenol contaminated soils for a cap. ..
All of the alternatives being considered (excluding no action) would
. be followed by appropriate site closure and postclosure activities.
Closure and post ~l~sure'ac~ivities'will include filling, grading,
fencing, revegetating and mowing the site. Alternatives involying
an onsite landfill would also require installing a runon/runoff
control system, implementing a ground water monitoring program,
and performing any necessary repairs to the landfill that may be
required. Additionally, all appropriate mitigation measures to
minimize airbourne contaminants during construction will be
implemented.
A number of alternative technologies were considered in the'
development of the remedial alternatives. These alternatives
underwent an initial screening process based on 40 CFR 300.68(h)
of the NCP. Alternatives were eliminated if they would not
mitigate identified public health or environmental threats, were
technically infeasible or would not provide substantially greater
public health or environmental benefits compared to less costly
alternatives.
-------
"
-13-
Technologies that we~e conside~e~ an~ excluded f~o~ fu~the~
conside~ation include solidificatio~ of the PC~ ana phenol
waste piles, pe~meable and impe~meable capping of the PCB waste
pile, pe~meable capping of the phenol waste pile, biological
t~eatment of the phenol waste pile, onsite incine~ntion of the
PCB anp phenol waste piles and offsite incine~ation of the PCR
and phenol waste piles.
Solidification of the waste piles was eliminated for the following
reasons: (1) it would not provide no substantially gr~ater public
health or environmental benefits compared to less expensive
alternatives, (2) the questionable effectiveness of the t,echnology
for organic compounds, (3) the 400 percent increase in ~aste
volume and resultant onsite disposal needs, (4) the concern that
the solidified mass will degrade and not provide long-term environ-
mental and public health protection.
Both permeable and impermeable capping of the PCB contaminated
soils and permeable capping of the phenol contaminated soils
were eliminated because they would not effectively mitigate
identified public health and the environmental threats determined
from the risk assessment. Without a bottom liner leak detection
and leachate collection system, contaminants could possibly
migrate offsite undetected via leachate generation. These alter-
natives would not meet minimum technology requirements under
RCRA (40 CFR 264 Subpart N and the Hazardous and Solid Waste
Amendments of 1984), which were considered in assessing the
technical adequacy of the landfill design.
Biological treatment of the phenol contaminated soils was eliminated
based on lack of effectiveness. Although" biodegradation significantly
decreased the concentration of phenol contamination (870 to 60 ppm)
in the 2000 yd3 phenol pile, based on the risk assessment it
was not effective in rendering the pile non hazardous. Therefore,
this alternative is not considered adequately protective under
CERCLA. .
Initially (July 1984)., both onsite and offsite incineration were
eliminated for the PCB and phenol soils due to the high cost and
- environmental problems associated with mobile incineration of
the PCB soils. Due to public comments, State comments and
technology developments EPA reevaluated incineration as a
remedial alternative for the PCB contaminated soils.
The estimated cost associated with offsite incineration of the
PCB contaminated soils and landfilling of the remaining phenol
contaminated soils are $8,689,000 (plus an undetermined cost of
packaging the soils in SS gallon drums). EPA has eliminated'
offsite incineration since it would not provide substantially
greater public health or environmental benefits compared to less
costly alternatives, particularly considering the relatively low
levels of PCBs that are present.
-------
-14-
Technology aovances since F.PA o~iginally conside~ed onsite incin-
e~aticn of the PCB contaminated soils have ~ade this nlte~native
somewhat mo~e att~active than when it was initially eliminated.
The EPA has ~ecently completed a test bu~n fo~ dioxin contaminated
soils and achieved six nines efficiency (i.e. 99.9999%). It
is doubtful, howeve~, the unit will be available fo~ the Picillo
site in the fo~eseeable futu~e because of p~io~ commitments at
othe~ sites. A commercial mobile incine~ato~ has also been
located that has successfully incine~ated contaminated soils.
The operato~s, howeve~, 'do not p~esently hold a TSCA permit,
although a test bu~n fo~ dioxin and PCB contaminated soils is
scheduled fo~ the summer of 1985. Although a TSCA pe~mit isn't
~equi~ed to incine~ate at a Supe~fund site, the Agency would use
the TSCA requi~ements as guidance in assu~ing the incine~ato~ is
adequately protective of public health, welfare and the environment.
It is known that the incomplete incine~ation of PCBs can result
in such toxic pollutants as dioxin, however, the mobile haza~dous
waste incineration units are designed to minimize hazardous
emissions. The incinerators being considered provide long dwell
times and high tempe~atures. In addition, the units a~e equipped
with extensive pollution control equipment and emission monitoring
equipment. Nonetheless, an actual test burn of PCB contaminated
soil is necessary to demonstrate that hazardous emissions are
not being gene~ated.
There is a g~eat deal of variance in the projected costs for
onsite incineration. EPA cost estimates for incineration of
just the PCB contaminated soils, onsite landfilling of the phenol
soils, and site closure are $6,585,000. These costs are based
on present operating expe~ience of PCB soil incineration allowing
for a minimal amount of down time (20%). A more conservative
cost estimate based on 50% down time result in an estimate of
$9,615,000. The only lowe~ cost estimate EPA obtained was
f~om a cOMme~cial mobile incinerator, which estimated the costs
to be $3,000,000 for the same scenario. However, these costs
we~e not based on actual experience with burning PCB contaminated
.soils and did not specifically consider down time, therefo~e,
they are not reliab~e. The commercial incinerator has not completed
a test burn fo~ PCB contaminated soils and were basing these
estimates on non PCB contaminated soils. The additional cost -
associated with sustaining a higher burn temperature, as well as
the additional fuel required to sustain incineration at all with
low level contaminated soils, could result in a significant
increase in these costs. As with offsite incineration, EPA has
eliminated onsite incineration since it would provide no substan-
tially greater public health, welfare, or the environmental
benefits compared to less costly alternatives, particularly
considering the relatively low levels of PCBs that are present.
.
-------
-15-
Offsite Response Alte~natives Evaluation
The following c~ite~ia, as set fo~th in the NCP (40 CFR 300.68(e)(3»,
we~e assessed in evaluating offsite ~e~edial action alte~natives:
( i)
( i i)
(iii)
( iv)
(v)
(v i)
Cont~ibution of the contamination to ai~, land,
pollution p~oblem.
o~ wate~
The extent to which the substances have mig~ated o~ a~e
expected to migrate from the area of their original location
and whether continued migration may pose a danger to public
health, welfare or environment.
The extent to which natural or man-made barriers currently
contain the haza~dous substances and the adequacy of the
barriers.
The extent to which substances pose a danger to public
health, welfare, or the environment.
Environmental effects and approaches used in similar
situations by State and Federal agencies and private parties.
Environmental effects and welfare concerns.
Offsite Response Alternatives:
Identification
Description
Present Worth
Cost
05-1
o
No Action
o
05-2
o
Lim ited Act ion
$
9Q,000
05-3
o
Groundwater Recovery,
Treatment, and Discharge
$3,600,000 -
4,000,000
As the title implies, the No Action alternative, OS-l precludes
any remedial a6tivity. This ~lternative would provide no active
. cleanup of ground and surface water.
. Similar to No Action, Limited Action proposes no active cleanup
of ground and surface water. It differs from No Action in that
additional groundwater wells would be installed and a ground and
surface water monitoring program implemented to establish risk
based standards for groundwater that are protective of public
health, welfare and the environment. This approach is based on
groundwater protection requirements under RCRA necessary to
-------
-16-
p~otect public health and the envi~onment (40 CFR 264, 5ubpa~t f
and the 1984 RCRA Amendments). EPA would use these ~eqlJi~eT"1ents
as guidelines in dete~mining what contaminant levels in the.
g~oundwater must be attained to be adequately p~otective unde~
CERCLA. A final dete~mination on g~oundwater contamination
would be made afte~ these ~isk based standards are established
and assessed.
The third alternative 05-3 involves recovery of ground water,
treatment, and subsequent discharge to the Unnamed Swamp. This
alternative would be technically difficult to implement since
locating the recovery wells or recovery drains in an area of
high contamination and high yield would involve a significant
amount of exploratory work. This alternative may also have an
adverse effect on the wetlands by lowering the levels in the
Unnamed Swamp or Great Grass Swamp during groundwater recovery.
Frequent monitoring and upgrading of the recovery system
may also be required. The ground water treatment system would
involve air stripping, vapor recovery, pH adjustment, sand filtra-
tion, carbon adsorption, and vacuum filtration of sludges. This
treatment system is relatively complex and will require a high
level of operation and maintenance, however, it will be highly
effective at removing contaminants in the effluent such as acetone,
methylene chloride and methyl ethyl ketone (MEK).
A determination regarding the need of implementing this alternative
to protect the public health, welfare or environment cannot be
made until ~isk based standards for groundwater are established.
RECOMMENDED ALTERNATIVE
Section 300.68(j) of the National Contingency Plan (NCP) [47 FR 31180,
July 16, 1982] states that the appropriate extent of remedy shall
be determined by the lead agency's selection of the remedial 'alter-
native which the agency determines is cost-effective. (i.e. .the
lowest cost alternative that is technically feasible and reliable
and which effectively mitigates and minimizes damage to and provides
adequate protecti6~ of public health, welfare, or the environment).
..,
EPA has determined the cost effective source control alternative
to be SC-5 which involves landfilling the PCB and phenol contaminateq
soils onsite in a RCRA/TSCA impoundment. The recommended source
control alternative also involves site closure and post closure
activities including filling, grading, and revegetating the
site, installing a runon/runoff control system, ground water
monitoring, mowing, fence installation and any future repairs
that may be required. As noted above, this remedy complies with
all other environmental laws except the TSCA 50 foot rule, the
State's rule against landfilling PCBs within the State (which is
-------
-17-
based on the TSCA ~ule), and the local o~dinance p~ohibiting
landfills. EPA has conside~ed the fact that t~e p~oposed ~emedy
does not comply with these existing ~equi~ements ~ut has'
dete~mined that, neve~theless, it is adequately'p~otective of
public health, welfa~e and the envi~onment.
The ~ecommended ~emedy will not eliminate the ~esidual g~ound-
wate~ contamination at the site. In addition to this ~emedy,
howeve~, EPA will implement a g~oundwate~ and su~face wate~
monito~ing p~og~am and establish ~isk based standa~ds. that a~e
protective of public health, welfare and the envi~onment
(i.e. limited action). Based on this info~mation, if additional
~emedial actions a~e determined to be necessary, a Record of
Decision will be p~epared fo~ app~oval of the future actions.
COMMUNITY RELATIONS
The affected community has a long history of interest and involve-
ment in this site which began shortly afte~ the site was discove~ed
in 1977.
A local citizens group SAVE OUR WATER (SOW) has been actively
involved since removal activities began in 1980. Until ~ecently,
public opinion of EPA and Rhode Island DEM has been poor with
citizen groups charging the two agencies with "dragging their
feet by studying the site to death" and concern over the lack of
visable action to cleanup the site. Recently, EPA and RI DEM have
made extensive attemps to involve the public and this effo~t has
been widely applauded by the public and has regained some community
confidence.
Community concerns a~e focused in two areas:
(1) Conce~n that that contaminated soils will be left on-site.
The local citizens feel strongly that all the contaminated
soil be disposed offsite.
-(2) Conce~n that contaminated groundwate~ could ultimately affect
the Ouidnick Reservoir. Contamination of Ouidnick Reservo~r
is not seen as a possibility even in the absence of remedial
action. The citizens still favor the pump and treat offsite
(OS-3) remedial alternative.
EFFECT OF SOURCE CONTROL ALTERNATIVES ON WETLANDS
The Picillo Fa~m disposal site consists of approximately 8.0
acres of cleared land near the top of a glacial deposit. Although
the site is not located in wetlands the surrounding lowlands are
comprised of wetlands. Assessment of the hydrogeologic data
available for the site indicates that contaminated ground water
. ,
.' i
, j
-------
-18-
from the site is discharging into the Unnamed Swamp and Great
Cedar Swamp. Present and future impacts on surface water and
ground water in the swamp are expected to be less than those
measured between February 1979 and July 1981 which resulted from
bulk dumping practices. Table 8 provides a comparison of the
levels of contaminants found in the swamp to available acute
and chron~c toxicity data.
The Endangerment Assessment for the Picillo site contains a
review of relevent site and chemical characteristics that could
pose risks to public health, welfare, or the environment, and an
evaluation of those risks. Remedial response objectives were
developed from this assessment and used to identify source control
remedial alternatives. For the purpose of this discussion the.
pertinent source control remedial response objectives used in
selecting the source control alternatives are:
(1) Remedial actions should preclude the infiltration of soil
contaminats into the underlying groundwater.
,
(2) A groundwater monitoring program will be implemented which
is in conformance with the technical requirements of RCRA
Part F-- Ground Water Protection.
(3) Pursuant to RCRA closure requirements, which were used as
guidelines, a hazardous waste landfill facility shall be
closed in a manner that R[m]inimizes or eliminates, to the
extent necessary to prevent threats to human health and the
environment, post-closure escape of hazardous waste, hazardous
waste constituents, leachate, contaminated rainfall, or
waste decomposition products to the ground or surface waters
or to the atmosphere.R
-
...
Implementation of the source control alternatives would not take
place in or adversely affect a floodplain or wetland. Tne-source
'control alternative is designed to preclude the offsite migration
of contaminants to tbe wetlands. Closure activities will in
part include grading. and revegetating the site. As a result,
the source control '~lternative would have the consequence of not
impacting the~et1ands at all, but rather preventing offsite
migration of ~ontaminants to the Unnamed Swamp.
, ~
OPERATION and MAINTENANCE
A number of post closure operation and maintenance (O&M) activities
will be required at the site. Operation and maintenance activities
associated with the source control remedy (08-5 onsite disposal in
a RCRA/TSCA landfill) include mowing, revegetation, annual inspection,
'.
-------
-19-
e~osion cont~ol, d~ainage maintenance, sample collection and
analysis (fo~ g~oundwate~ ~onito~ing p~og~arn), fence ~eplacement
and any othe~ necessa~y ~e~ai~s. p~ojected O&M costs a~e estimated
from the FS as follows:
Year l: Sl2,l20/yea~
Yea~ 2-4: S25,648/yea~
Year 5-30: $l9,048/yea~ ($34,048 fo~ yea~ 16)
Well replacement afte~ 15 years will result in an additional cost
of $15,000 during year 16 resulting in an O&M cost of $34,048 for
that yea~. The total p~esent worth fo~ source control operation
and maintenance is estimated at $191,400.
operation and Maintenance activities will be considered part of
the approved action and eligible for Trust Fund Monies for a
period of one year from the completion of remedial actions.
The State has made a conditional commitment to provide the operation
and maintenance costs associated with the disposal of the phenol
contaminated soils in a onsite RCRA/TSCA landfill after the
first year of implementation. The State's funding mechanism is
the Hazardous Waste Response Bond Account, and the Rhode Island
Department of Environmental Management is the State Agency
responsible for 0 & M.
FUTURE ACTIONS
The recommended remedy will not eliminate the residual ground-
water at the site. In addition to this remedy, however, EPA
will implement a groundwater and surface water monitoring program
and establish risk based standards that are protective of public
health, welfare and the environment.
-
To develop these ris~based standards the Agency will use an
approach based on the groundwater monitoring and corrective action
standard (40 CFR 264, Subpart F and the 1984 RCRA Amendments).
The RCRA groundwater regulations require the setting of groundwater
protection standards, which are levels that are protective of
human health and the environment. Corrective action is required
if these levels are exceeded. The groundwater protection standards
of RCRA require that certain contamination levels be attained:
background levels, maximum contaminant levels (MCL's) or alternate
concentration limits (ACL's). ACL's are site specific levels
that are demonstrated to be protective of human health and the
environment. Using this approach, the Agency will establish
risk based standards for the groundwater that are protective of
public health, welfare and the environment.
Based on this information, if additional remedial actions are
determined to be necessary, a Record of Decision will be prepared
for approval of the future remedial actions.
. '
-------
Community Relations Responsiveness Summary
Picillo Farm Site
Coventry, Rhode Island
Introduction
This responsiveness summary for the Picillo Farm Site documents concerns raised
during the Superfund remedial planning process and the public comment period
on the feasibility study, and how EPA considered and responded to these concerns.
Activities Conducted Prior to the Feasibility Study Comment Period
Before 1981, most community relations activities were conducted informally by
the State. Official interaction with the community was conducted through the
Town Council and later also with Save Our Water (SOW), formed by area resi-
dents in 1980. SOW became the primary group representing concerned citizens
and became an important point of contact between the community and involved
agencies.
A Community Relations Plan (CRP) was drafted in December 1981 by ICF, Inc.,
for use during removal actions at the site. This CRP was revised by the State
in June 1982 to accompany the cooperative agreement, signed in February 1982.
.Written and verbal updates on site activities were issued periodically by the
State to concerned citizens.
In April 1984, EPA and the State conducted interviews with town officials and
several concerned citizens. These interviews were followed by a public meeting,
held on May 7, 1984, which was organized by SOW. Approximately 30 citizens
attended this meeting. A second pUblic meeting was held by EPA in June 1984
to present the results of the remedial investigation and the initial endanger-
ment assessment. Information obtained from these interviews and public meetings
was used by EPA and the State to update the CRP in October 1984. An expanded
mailing list of interested parties was developed during the CRP revision.
Concerns Raised Prior to the Feasibility Study Comment Period
-The predominant concern voiced by members of the community was over potential
health effects to area residents as a result of air emissions, groundwater
contamination and general offsite migration of contaminants. Citizens
expressed fear that drinking water supplies could become contaminated and
that odors emitted from the site were toxic. .
\)
A major concern was over the lengthy process of remediating site conditions
and a perception from citizens that EPA and the State failed to communicate "
to the community adequately during remedial activities. The status and fate
of 50ils contaminated with PCBs was of great concern to residents.
Another major concern cited by area residents regarded the future ownership
of the site property. Many citizens expressed concern that the Picill0
family would retain ownership of the land and use it in the future. Citizens
requested that the government -- local, State, or Federal -- take control of
the land.
-------
Additional concerns were voiced about the effects of fractured bedrock on
groundwater pl~me migration and the effects of contamination on the unnamed
swamp, private wells, the Quidnick Reservoir, the proposed Big River Reservoir
Project and nearby cranberry bogs.
As a result of concerns raised by the community regarding exposure to air
emissions, EPA conducted air modeling to determine potential impacts resulting
from exposure. EPA examined potential impacts to groundwater, and the
feasibility of groundwater treatment. The remedial investigation was revised
to examine effects on nearby cranberry bogs and to determine whether the
public was coming in contact with site contaminants or drinking polluted
groundwater. The endangerment assessment was also expanded to address other
risk factors.
Activities Conducted During the Feasibility Study Comment Period
The final RIfFS was released to the public on April 8, 1985. Copies of the
report were available at the Coventry Town Hall Library and at the Rhode
Island Department of Environmental Management in Providence. A copy of the
report was also sent to SOW.
A public meeting was held on April 23, 1985, at the Western Coventry School
in Coventry at 7:00 p.m. for the purpose of explaining the RIfFS.
Approximately 20 citizens attended the meeting. An eight page fact sheet
summarizing the Feasibility Study was distributed at the meeting.
In response to concerns raised at the meeting, EPA agreed to extend the
public comment period from May 1, 1985, to May 15, 1985.
A public hearing was held at the Western Coventry School at 7:00 p.m. on'May
15, 1985, to officially receive comments from the community. Approximately
25 citizens attended the hearing. Testimony was provided by 1 town official,
1 State official, 9 citizens, and 1 State Representative.
Concerns Raised During the Feasibility Study Comment Period
A summary of all. comments received by EPA during the public comment period is
provided in the attached pages, along with the corresponding agency response.
Comments were received from the community, the State of Rhode Island and the
potentially responsible parties (PRPs).
Remaining Concerns
EPA will continue to keep the community apprised of site activities, and
informed during design and construction of the selected alternative. Whether
ownership of the land will be transferred from the present owner will need to
be established. Containment of contaminated soils on site should mitigate
any future impacts to groundwater. Future land use of the site and adjoining
area could also become a community concern.
. ,
. .
-------
Additional concerns were voiced about the effects of fractured bedrock on
groundwater plume migration and the effects of contamination on the unnamed
swamp, private wells, the Quidnick Reservoir, the proposed Big River Reservoir
Project and nearby cranberry bogs.
Agency Response to Concerns Raised Prior to the Feasibility Study Comment
Period .
As a result of concerns raised by the community regarding exposure to air
emissions, EPA conducted air modeling to determine potential impacts resulting
from exposure. EPA examined potential impacts to groundwater, and the
feasibility of groundwater treatment. The remedial investigation was revised
to examine effects on nearby cranberry bogs and to determine whether the
pUblic was coming in contact with site contaminants or drinking polluted
groundwater. The endangerment assessment was also expanded to address other
risk factors.
Activities Conducted During the Feasibility Study Comment Period
The final RIfFS was released to the public on April 8, 1985. Copies of the
report were available at the Coventry Town Hall Library and at the Rhode
Island Department of Environmental Management in Providence. A copy of the
report was also sent to SOW.
A public meeting was held on April 23, 1985, at the Western Coventry School
in Coventry at 7:00 p.m. for the purpose of explaining the RIfFS.
Approximately 20 citizens attended the meeting. An eight page fact sheet
summarizing the Feasibility Study was distributed at the meeting.
In response to concerns raised at the meeting, EPA agreed to extend the
public comment period from May 1, 1985, to May 15, 1985.
A public hearing was held at the Western Coventry School at 7:00 p.m. on May
15, 1985, to officially receive comments from the community. Approximately
.25 citizens attended the hearing. Testimony was provided by 1 town official,
1 State off1c1a1, 9 citizens, and 1 State Representative.
Concerns Raised During the Feasibility Study Comment Period
A summary of a11 comments received by EPA during the public comment period is
provided in the attached pages, along with the corresponding agency response.
Comments were received from the community, the State of Rhode Island and the
potentially responsible parties (PRPs). .
Remaining Concerns
\i
EPA will continue to keep the community apprised of site activities. and
informed during design and construction of the selected alternative. Whether
ownership of the land will be transf~rred from the present owner will need to
be established. Containment of contaminated soils on site should mitigate
any future impacts to groundwater. Future land use of the site and adjoining
area could also become a community concern.
. .
".
-------
.
\
COMMUNITY COICERN
RESPONSE
1.
Onsite Disposal
Generally oppose disposing of PCB and phenol
contaminated soils on site. No long-term
security; breakdown of landfill could result
1n contamination of drinking water. It is
the Coventry Town Counc11'~ policy that all
hazardous waste should be removed from the
site and stored at a TSCA approved landfill.
As long as offs1te storage is available, it
should be used. leaving waste ons1te
will present risk of human contact.
Could also affect the proposed Big River
Reservoir Project and the Moosup River
watershed. Storage of contaminants onsite is
unacceptable and illegal. Fractured bedrock
at site makes it inappropriate for onsite
disposal; site is also close to an earthquake
zone; leakage could contaminate
groundwater. Should be cheaper to truck
contaminants offsite to an existing landfill
than to build a new one 1n Coventry.
Rodents could chew through l1ning of land-
f111; presents hazard from ons1te disposal.
Problem has existed for six or seven years;
site should have precedence over s1tes in
Massachusetts for the reaoval and disposal of
PCBs off site. Should make Picillo Farm a
model of hazardous waste cleanup by removing
all contaminated materials from the site.
Job started before should be finished now.
o A long term groundwater monitoring pro-
gram will be implemented to monitor
groundwater quality.
Onsite disposal of the PCB pile is expected
to be a safe and reliable remedial action for
disposal of the PCB and phenol contaminated
soils for the following reasons:
o A layered impermeable cap will prevent
human contact with wastes and minimize
or eliminate infiltration into the land-
fill.
o An impermeable double bottom liner with
a leachate collection system and leak
detection system will protect against
contaminant migration.
o Site closure activities including provid-
ing runon/runoff controls, regrading and
revegetating the site, and limiting access
with a fence will reduce erosion and
assure the long term integrity of the
landfill.
-------
CCIIUIln COICERII
RESPOIISE
1.
Onsite Disposat (continued)
Creating a landfill at the Picill0 Farm Site
is in violation of the Town of Coventry
Zoning Ordinance. Creating a landfill for
the disposal of PCBs on site would violate
TSCA requirelents that groundwater be More
than 50 feet frOll 1 andft1 1- . S ta te .
regulations prohibit the const~uction of a
PCB landfill at the site. A landfill cannot
be legally constructed at this site.
o Any potential damage to landfill liners
by burrowing an1mals or other causes can
be prevented by routi~e inspection and
Maintenance of the lahdfi".
The site poses no threat to the proposed Big
River Reservoir since the two areas are
separated by a major surface water divide.
The site also poses no threat to the Moosup
River Watershed since the site is far removed
from the Moosup River. In addition. a
RCRA/TSCA landfill would not be adversely
impacted by the presenc~ of fractured bedrock
beneath the site.
Under section 101(24) of CERCLA an offsite
alternattve is a penlissible remedy only if
the offsite action would acc08plish one or
more of the following three objectives:
(a)
(b)
(c)
Is .ore cost-effective than other
remedial act tons.
Will create new capacity to manage
hazardous substances in addition to
those located at the affected
facn ity.
Are necessary t~ protect pub11c
health or welfare or the env1ronment
frOM a present or potential risk
which MaY be created by further.
exposure to the continued presence of
the contaminated materials.
..
-------
CCIIUIln aIICERI
R£SPOIS£
1.
Onsite Disposa1 (continued)
Because offsite land disposal does not meet
any of these three objectives, EPA has deter-
mined the cost effective source control
alternative to be onsite fand disposal of the
PCB and phen01 conta.inated sofls. Onsite
disposal in a RCRAITSCA landffll and offsite
disposal in a RCRA/TSCA landf111 are con-
sidered equa"y protective of public health.
welfere, and the environment. However. costs
for onstte disposal of PCB conta.inated soils
in an onsite RCRA/TSCA landfill are approx-
imattl1 58 percent less than offsite disposal
in a p'r8itted RCRA/TSCA landfill. The
Agency fl aware that the proposed landfill
does not Meet the 50 foot hydrologic
condition listed under 40 CFR 761.75 of TSCA
and would be in violation of'state and local
laws. Legally, EPA is eXe8pt from other
laws' requirements in selecting an onsite
remedy under CERClA (i.e., Superfund).
Instead. the Agency legally is required to
detenltne whether the onsite remedy meets the
CERClA test of being adequately protective of
the pub1tc health, welfare or the
enviroft8ent. The EPA in ..king its
detennin8tion, considered the TSCA regu-
lationS 85 well IS other Federal, State
and 10ca1 laws. With the exception of
the hydraulic condition. the proposed
landfill design exceeds the PCB landfill
.
- .
-------
COIIIJIITY COIICERJI
RESPOIISE
1.
Onstte Dtsposal (continued)
requireMents listed under TSCA. The
Agency has determined that onsite land
disposal is the cost effective remedy and
meets the CERCLA test of belng adequately
protective of public health, welfare, and
the environment.
A more in depth summary of the rationale for
the chosen remedial alternative. as well as
why other alternatives were not chosen, can
be found in the .Risk Assessment."
"A1terhat1ves Eva1uation" and "Recommended
Alternatives" section of the ROD.
-------
CCIIIJIIln. COIICERII
RESPOIISE
'.~
2.
Treatlent of Conta8inated Groundwater
. . .
ImpleMentation of 05-3. Groundwater Recovery,
Treatment, and Discharge, would hasten
groundwater cleanup. Grou~dwater should be
treated and cleaned.
. ,
Although the proposed recovery and treatment
alternative may reduce the amount of con-
taminated groundwater that 4ischarges to the
Unnamed Swamp and bedrock spring, implementa-
tion of this alternative is not expected to
significantly hasten groundwater cleanup. As
stated on p. 8-3 of Volume 2 of the RifFS,
contaminant concentrations are ultimately
controlled by source persistence. Due to the
potentially widespread distribution of con-
taminants in the unsaturated zone and the
site location near a groundwater divide,
residual source re80val was considered to be
technically and economically infeasible.
Under natural conditions of precipitation,
flushing, dispersion and decay, plume concen-
trations will continue to decline as the
original 8aSS of contaMinants at the source
is depleted. A determination will be made 00
whether corrective leasures are necessary for
the groundwater once groundwater standards
that are protective of public health, wel-
fare, and the environment are established for
'the site.
. .
-------
COIIIJIln COICER..
RES POISE
..
3.
Need for Govern.ent Entities to Take Control
'O'rOwnersMp of Lind
Ownership of, or responsibility for the site
should be taken by the State or the Federal
government. EPA should buy surrounding
properties. If Mr. Ptcillo regains control
of the land, EPA and State will have no
control over land use, or could be restricted
fro. having access to the sit~: Government
should buy the property. Town should buy the
property.
As a policy, EPA does not take ownership of
Superfund sites, but funds cleanup activ-
ities. EPA does not expect. an access problem
to develop. However, the Agency acknowledges
the community concerns regarding ownership.
The final offstte remedy mly require institu-
tional controls over groundwater use. EPA is
considering the need for institutional con-
trols, including providing funds to have an
acceptable party assume ownership of the
site. If additional remedial actions are
determined to be necessary, including
institutional controls, a Record of Decision
will be prepared for approval of future
remedial actions.
-------
CCIIIhIln COIICERII .
RESPONSE
4.
Failure of Agencies to Meet Prior Commitments
Citizens expressed the opinion that EPA had
informed the Town of Coventry that all
hazardous materials at the Picil,o Fann would
be removed. Some members of the community
expressed frustration that the Agency was not
upholding this perceived commitment.
The selected remedy outlined in the. Record
of Decision, constitutes" a cbmplete source
cleanup within the regulatory guidelines
under CERClA and the NCP. EPA has stated
that the site will be completely cleaned up
pursuant to CERClA and the NCP and is still
very much committed to this goal.
II
-------
COIIIJIIITY COICER..
RESPONSE
---
5.
Extension of C088ent Period
Citing extensive delays tolerated by members
of the community, ctttzens expressed concern
that EPA fatled to provide adequate time to
review the Feasibi1ity Study during the
public COMment period.
It is EPA policy to allow for a 21 day public
comment period on the Feasibility Study. Due
to public concern at the April 23, 1985
public meeting, the public tomment period was
extended one week and the date for the public
hearing was moved from May I, 1985, to May 15,
1985.
, .
-------
COIIIIIII1' CORCERN
RESPONSE
6.
Groundwater Monitoring
Sink wells in 3600 circle around site in
1 mile radius and test wi~ most recent
equis-ent for 50 years. '.
The alternate groundwater monitoring program
proposed in , this comment' is not appropriate
for the hydrogeologic setting at the Picill0
site. Wells positioned in a one-mile radius
from the site would all be situated in dif-
ferent subbasins from the one in which the
site is located. Ideally, monitoring wells
would be positioned near the disposal area to
reflect changes in source release mechanisms.
As part of the source control remedy, a 10ng~
term groundwater MOnitoring program wil. be
implemented to monitor the 1andfill. Under
RCRA guide1ines, the landfill would be moni-
tored tor 30 year'. Also, the Agency will
evaluate ~hether groundwater correction
measures are needed. In the interim, a
groundwat.r and surface water monitoring
program ~i'l be implemented and risk based
standards protective of groundwater will be
establ1 sited. .
For e1th.r monitoring program, arbitrarily
setting I \ime period for ~Impling and
Inalys1s 01 50 years would not be necessary.
.
,
.
.
.
"
.,
-------
COIIIJIln COICERII
RESPOIISE
7.
Site Security
Rural nature of the area .akes site security
a concern. EPA cannot assure site security.
There is no guarantee of long-term security.
No fence is .people proof.. Despite risks
associated with the swamp. it is not even
posted with a warning sign.
The long-terM security 8easures whi~h will be
implemented at the site 'are-outlined in the
Record of Decision Summary. Long-term
security will include fencfng the eight acre
site. Security fences are typically chain-
link fences which have several strands of
barbed wire along the top. A fence will be
of sufficient height and strength to deter
people from climbing over or breaking through
the fence. Signs will also be posted along
the fence to warn humans of the danger from
hazardous waste. Regular inspections will
also be conducted by regulatory officials.
"
'..
-------
ClllUlln COIICERN
. RESPCIISE
8.
Future Development
If other ho8es are. built, their wells could
become contaminated~' Nine homes have been
built on Route 102 and four homes on
Logbridge Road; new wells have been drilled
for each hOle. Could this affect the
groundwater situation? If More private wells
are installed, groundwater-flows could
change, contaminating other wells. Future
develop8ent could deplete groundwater and
create reverse flow. Real Estate interests
are telling clients everything is cleaned up.
The area is critical for future Rhode Island
water developlent, including the proposed 8ig
River Reservoir Project.
Development of new homes near the Pic1110
site co,",ld alter the groundwater flow regime
as described in GCA's RI/FS document (April,
1985). However, groundwater withdrawal rates
associated with do.estic wells along Logbridge
Ro.d are typically low and are not expected
to significantly alter existing flow patterns
near the site. Development along Route 102
is not expected to pose a risk since this
area is hydraul tca11y upgradient and at a
greater distance from the site than Logbridge
Road. The Agency will also continue to
monitor groundwater and surface water to
detect Iny changes in groundwater quality.
As described in C08ment No. I, the Big River
Watershed will not be impacted by the Picill0
site.
Regarding the constructton of an ons1te land-
fill, CERCLA funds would be used for the dis-
posal of onstte sotl contamination only. .
Therefore, the landfill would only be
designed to hold the volume of those
conta.tnated soils. Additionally, as part of
the alternative, the landfill would be closed
and periodically inspected precluding the
disposal of an1 other wastes. within it.
If EPA creates a landfill at the site, could
this be used as a regional landfill? Could
Mr. Picillo regain control of a landfill
operation in the communtty?
"
-------
cellunn COIIC£RI
RESPOIISE
9.
Health Effects
No health study his been conducted. Can EPA
guarantee the c088unity that they have not,
or will not, be affected by contaminants on
site? Is there the potential for synergistic
effects froM che.icals at the site?
Psychological effects hav~ taken their toll.
EPA does not conduct health studies~ Health
studies are conducted by"the" Center for
Disease Control (CDC) in Atlanta, Georgia.
CDC has reviewed the Risk Assessment, and
associated data, for the Picill0 site. Their
findings to date have been that a health
survey is not warranted at this time. There
could be synergistic effects associated with
combinations of contaMinants present at the
Picillo site. However, the source control
remedy is designed to preclude exposure to
the contaminated soil stockpiles.
"
-------
".
STATt alltElITS
RESPONSE
1.
Onsite Disposal
State opposes disposal of PCBs onsite because
site is located near a swamp, because ground-
water is less than 50 feet from the proposed
landfill and because the site cannot be
secured from public access. As long as off-
site storage is available,-RIDEM recommends
the PCBs be disposed of offs1t~.
EPA acknowledges this State ~omment'and has
considered it in the decision-making process.
The Agency rational for choosing onsite dis-
posal in a RCRA/TSCA landf1l1 is outlined in
comment '1 of the community concerns.
A more in-depth summary of the rationale for
the chosen remedial alternative can be found
in the .Cons1stency With Other Environmental
laws,- .Alternatives Evaluation,. and "Recom-
mended Alternatives. sections of the ROD
summary.
The Stite of Rhode Island has regulations
under the Rhode Island Hazardous Waste Man-
agement Act which prohibit the landf1ll1ng of
extremely hazardous waste in Rhode Island due
to the fact that groundwater is within
50 feet of any possible site. Under Stite
law, PCB conta81nated soils over 50 ppm are
considered extre.ely hazardous waste. The
State 15 not in a position to grant a vari-
ance for this position and, therefore, the
landfill cannot be legally built. As a
result, the offs1te re.edy 15 the cost effec-
tive alternative; the onsite remedy is not
feasible due to state regulations and should
not be considered.
The State does not feel that landfilling of
phenol conta.inated soi15 in an onsit. RCRA,
facility poses a hazard to public hea1th or
the enviro..ent.
-------
.
STATE CCllEIITS
RESPONSE
2.
TreatMent of Conta.inated Groundwater
Because the RI/FS states that groundwater.
conta.ination has reached a MaxiMum level and
will decline, the State accepts that the
groundwater does not need to be treated.
However, the site should ~1n on the NPL
for at least 15 years until natural cleaning
is cOMplete, or until the trend of ground-
water conta.inat1on decline is'eyident.
Groundwater .onitoring shou1d be Maintained
for 30 years in c08pliance with RCRA require-
Ments. Alternate concentration liMits should
be set for sa.ples taken froM .0nitor1ng
wells at the property line; if these liMits
are exceeded, EPA should deterMine what
.1t1gative .easures should be taken.
EPA acknowledges the State's comment regard-
ing the length of time the site should remain
on the "PL. However, deterMining the number
of years the site will reMatn on the NPL is
outside the scope of this ROD.
EPA also acknowledges the State's comments
regarding groundwater contaMination. EPA
will iMplement a groundwater and surface
water Monitoring program to enable the Agency
to establish risk based standards for ground-
water (i.e., alternate concentration limits)
that are protective of public health, wel-
fare, and the environMent. The compliance
points for these -risk based- li8its, possi-
ble groundwater treat8ent, and the length of
the groundwater Monitoring period will be
detenlined once these standards are developed.
Based on this inforMation, if additional.
remedial actions are necessary, a Record of
Decision w111 be prepared for approval of the
future remedial action.
"
it
.
-------
STATE tOMMElITS
RESPONSE
3.
Need for Government Entities to Take Control
or Ownership of Land
The State of Rhode Island does not feel that
ownership of the site is needed because the
State has access to the land, which is all
that fs required. .
EPA acknowledges State concetn over State
ownership of the site. As a policy, EPA does
not take ownership of Superfund sites, but
funds cleanup act1vities.Contr01ling
groundwater use may require institutiona1
contro1s, including providing funds to have
an acceptable party assume ownership of the
site. EPA is considering the need for
institutional controls, including providing
funds to have an acceptable party assume
ownership of the site. If institutional con-
trols are necessary to control groundwater
use, a Record of Decision will be prepared
-------
STATE CClllE1ITS
RESPORSE
4.
Site Security
Post or restrict those areas where contamt-
nated groundwater MaY be reaching the
surface. .
The EPA has considered and generally concurs
with the State's connent' re~rding securi ty
measures. long-term securi~y measures which
will be implemented as part",Df the source
control remedy include fencing and posting
the site.
The rural nature of this area will not allow
anybody to prevent pub1tc a~cess into thts
a rea.
"
-------
. .
PRP CClIIEIITS
RESPCIISE .
1.
. .~
Extension of Public Comment Period
Requested and were denied an extension of the
comment period to the end of May 1985.
Accordingly, PRPs reserve the right to
challenge at any later proceeding the RIfFS
and its analyses, conclusions, and data base.
It is EPA policy to allow for a 21 day public
comment period on the Feasibtlity Study. Due
. to pub 11 c concern at the April 23, 1985
public meeting, the public comment period was
extended one week and the date for the public
hearing was moved from May I, 1985, to May
15. 1985. .
-------
PRP COMMEIITS
RESPOIISE
2.
Offsite Remedial Alternative
Generator PRPs consider that the concentra-
tions of contaMinants released offsite do not
present, nor have ever presented, credible
risk to human health, welfare, or the
environMent. Generator PRPs endorse the
selection of 05-1 No Actton as the Remedial
Alternative. .
EPA acknowledges this recommendation and has
considered it in the decfsio~-mak1ng process.
Protecting groundwater as l,poss1ble future
drinking water supply is of ' concern. Migra-
tion of organic chemical contaminants via
leachate frOM the three contaminated soil
stockpiles is exptected to be a continued
source of groundwater contaMination at the
site. A deterMination will be made on whether
corrective measures are needed for the ground-
water once groundwater Standards that are
protective of pub1ic health. welfare, and the
environMent 're ettab1tshed fot the site.
-------
pap COMMENTS
RESPONSE
3.
Realistic Worst Case Scenario is Flawed
The 8Realistic Worst Case8 is seriously
flawed. It is:not realistic because the
assumed 60 soil contacts is not supported and
seems extremely unlikely. The maximum PCB
soil concentration used was not determined by
a USEPA standard published a~alytical method
and, therefore, is not reliable for
establishing the dose. If the 8Iximum PCB
concentration detenlined by standard USEPA
methods froB March 1984 saMples is used
together with an assumption of only. nine
total soil contacts, the worst case scenario
results in a one in one 8il1ion cancer risk
which, as stated in the RI/FS, is considered
an acceptable level. Even if the
hypothetical 8Realistic Worst Case8 scenario
is correct, the on1y risk results from
repeated direct contact with a 8hot spot.8
A screening procedure utilized by 'the EPA
Region I laboratory to determine the quantity
of PCBs in s011 at the P1c1ll0 Site was
utilized for s011 samples collected on
February 9, 1984. Of the 92 samples analyzed
by the screen1ng procedure, random samples
were collected and analyzed by the EPA PCB
protocol method for sediment/s011 analysis
for extractable organic compounds from the
Revised Draft of Concensus Organics
protocol - 11/30/83 (latoille, USEPA, 27
March 1984).
The screening Method yielded a max1mum PCB
s011 concentration of 180 ug/gm (ppm). When
the saMe sample was analyzed by the protocol
method, a level of 123 ug/gm (ppm) was'deter-
m1ned. Using the 180 ug/gm value as the con-
servative.axi.WI concentrat10n 1s not inap-
propriate for deterM1ning risk. However,
even if the protocol value of 123 ug/gm is
ut11ized as the maxt.um PCB concentration 1n
the Realist1c Worst Case Scenar10, a risk of
1.1 x 10-5 (instead of 1.5 x 10-5) 1s deter-
mined. The 1.1 1n 100,000 1ncreased cancer
risk, exceeds the 10-6 risk level by a factor
of 11 as opposed to 15. Thus, regardless of
whether one assumes 180 ppm or 123 ppm as the
max1mum PCB contamination, an unacceptable
risk 1s determined to exist.
To develop the Realtst1c Worst Case Scenar10
for direct contact with the PCB pile, the
-------
PIP COfIU:R'S
RESPOftSE
3.
Realistic Worst Case Scenario is Flawed
~
~'
population which. would MOst likely come into
contact with the. pile was assumed. Although
the site is guarded, it is possible that area
residents, especially teenagers, may access
the site from access points other than the
controlled gate and cli.b on the PCB pile, or
use it for dtrt bike riding or other activ-
ities. Observations of trespassers,
especially teenagers, has been reportedly
observed by cOMMunity residents in the past.
It waS assu.ed the age group who would most
realistically use the site for these
activities Would be a young male between the
ages of 10 through 16. Therefore, the
exposure period was assumed to be six years.
10 loilcontacts per year is reasonable in a
Rea1isttc Worst Case Scenario due to the
nature of the activities expected at the.
Picil10 site and the age group performing
the8. A one year exposure period with 9
contacts is not reasonable for a realistic
worst case since the realistic worst case
should be designed to enCOMpass what could
occur for the population specified, i.e.. to
deter8ine the maxi8um exposure potential for
the population of concern.
"
-------
PI, CClIJ[I'S
RESPONSE
4.
Recommended Alternative
Oppose use of RCRA/TSCA facility for disposal
of conta.inated 8Iterials onsite. The PCB
pile was created fr08 the spoils of the North-
east Trench. Eighty percent of the materials
in the Northeast Trench were uncontained at
the ti.e of cleanup in 1980. , This indicates
that the bulk of the PCBs were released to
the environMent during and prior to 1980 with
no ill-effects to health and safety. RIDEM
disposed of the heavily conta8inated soil and
stockpiled only the slightly contaminated
s01'. The 8Phenol Pile8 was successfully
treated onsite and does not pose a risk. No
more than 25 gallons of PCBs re8lin in the
8PCB Pile.8 This results in an average con-
centration of .uch less than 50 ppm. More
than 25 gallons of PCBs were released during
dumping and during cleanup, yet the naturally
occurring conditions onsite prevented any
threat to hU81n health, welfare, and the
environ8ent. SC-S, Landfill in RCRA/TSCA
Facility, is not Justified by the risk pre-
sented. There i5 no legal requirement for
these Materials to be disposed of in an
RCRA/TSCA landfill. The PCB pile is not
regulated by TSCA because the average PCB
concentration is less than 50 ppn. EPA policy
(6-PCB-9) allows cOlpositing of samples. so
the average is the appropriate measure of PCB
concentration. Data also suggests that natural
biodegradation of PCBs is occurring. The
generator group is willing to test a saMple
fr08 the PCB pile to determine if biodegrada-
tion is taking place.
.
EPA acknowledges the PRPs comments' regarding
onsite disposal in a RCRA/TSCA landfill and
has considered them in the decision-making
process. The Agency rationale for the
selected remedy is outlined in the ROD
su_ary.
A RCRA/TSCA landfill and the associated
impermeable cap, leachate collection system,
. and leak detection system 1s necessary to
adequately protect the public health, .
welfare, and the environment. A layered
imper8eable Cip would prevent human contact
with wastes and Mini.ize or eliminate
infiltration into the landfill. An
impermeable double bott~ liner with a
leachate collection system and leak detection
syste. wil protect against contaminant
migration. Site closure activities include
providing runon/runoff controls. regrading
and revegetat1ng the site. and liMiting
access with a f.nce. These will reduce
erosion and assure the long-term integrity of
the landfill.
Simply covering the PCB pile with 8thickets,
thorns. or poison ivy8 will not adequately
protect the public health. welfare. and the
environment. This proposed remedy only
addressed the threat of direct contact with
-------
PIP COMMEITS
RESPONSE
4. Recom.ended Alternative (continued)
The risk associated with the site could be .
easily re.edtated through the elimination of
future contact with conta8inants. The PCB
pile could be covered wtth earth and seeded
with thickets, thorns, or poison ivy to pro-
vide an additional degree of.security. The
priMary defect of the RI/FS i~ ~he failure to
address a securi ty/cover type relledy. The
recGn8ended alternative SC-S, RCRA/TSCA land-
fill, provides no additional protection from
hUian and ant8l1 contact. The only risk to
be avoided is a potentia1 heal th concern
arising froM repeated direct contact with
trespassers; the creation of a RCRA/TSCA
landfill 15 not the appropriate remedy to
avoid this risk.
As stated 1n the RI/FS, there are also risks
to public health and the ~nvrronment through
direct contact with the phenol pile. Also,
organic chemical contamination 1n both the
PCB and phenol contaMinated soil is expected
to provide a continued source of contamina-
tion to the groundwater, preventing it from
being used as a potable water supply. A more
in depth explanation of the risks associated
with the site is present~d in the 8Risk
AssesSMent- section of the ROD summary. Even
as just a det.rent againt direct contact with
the PCB contamtnated soill, the proposed
remedy is 'severely inadequate. Erosion would
quickly reduce the integrity of such a cap
and leave the conta8inated soils exposed. A
properly constructed landfill will require
regradtng of the site, providing erosion con-
trols, and the use of adequate Materials to
assure the long-terM integrity of the land-
fi 11 .
The PRPs hlv' also stated that the PCB
contaMinated 50ils are not considered a TSCA
waste sinc. the average concentration of PCBs
is under 50 PPM. Although CERClA is exempt
from other env1romllntal law1, one measure
used by EPA in deterMining whether a remedial
alternative at Superfund sites adequately
meets the CERClA test of protecting public
health, welfare, and the environment is
whether the alternative attatns the
substanttve provisions of other applicable
federal pUblic health and environmental
standards. The applicable TSCA requiremer'
II
-------
PRP CClMENTS
RESPOIISE
4. RecGR8ended Alternative (continued)
are 11sted under 40 CFR 761. TSCA 'reguhtes
PCB wastes over 50 PPM. "The contaminated
. soils represent a mixture 01 wastes from bulk
dumping activities and leaking drums. These
soils cannot be further composited to obtain
a PCB value under 50 PPM. Since levels of
contamination were not uniformly distributed
such that the pile could be segregated, the
entire stockpile would be considered a TSCA
waste. EPA draft pOlicy 6-PCB-9 addresses.
the extent of cleanup and does not allow for
the compositing of saMples to obtain levels
under 50 PPM. The draft pOlicy states that
improperly disposed of PCBs shall be cleaned
up to b.ckgtbund levels unless these levels
are not practicably attainable using normal
cleanup methods.
As stated. EPA has deterMined that disposing
of the PCB and phenol contaminated soils in a
RCRAfTSCA landfil1 is necessary to meet the
CERCLA test of being adequately protective of
public health, welfare, and the environment.
Regarding the possible biodegradation of
PCBs, a pilot study was conducted in 1982 by
O.H. Materials using commercially available
microbes and proved to be unsuccessful as
stated on page 2-4 of the RIfFS.
..
-------
PIP COIIIEITS
RESPOISE
5.
I.pacts froM Construction Activities
The activity of creating a RCRAITSCA landfill
will entail risks to workers by construction
activity and the surrounding population by
fugitive dust. The RI/FS does not address
these risks. These risks, coupled with the
destruction of the 8'croorga~is. habitat, far
outweigh any perceived benefit in Moving the
piles twice and creating a RCRA/TSCA
landfi11.
Regarding the construction of a RCRA/TSCA
landfil', the RI/FS considere~ the creation
of potential adverse affect~.. It is unlikely
that 100 percent efficiency of dust control
can be attained with any technology.
However, to reduce the risks to workers
during remediation, an effective health and
safety program would be i.plemented. In
addition, to .ini.he worker injury and
ensure worker safety with the use of heavy
equipMent, EPA would require that adequate
worker safety Measures be i.plemented.
Construction of a secure RCRA/TSCA landfill
onsite would not present any adverse effects
to the .icroorganis8 habitat in the nearby
swa8p ecosysteMs. Therefore, the
i.ple.entation of the reconlended alternative
SC-5 is not expected to result in adverse
i.pacts which cannot be readily controlled;
but will result in .itigating the risks posed
by the PCB and. phenol piles.
-------
TABLE 1, SUMMARY OF SAMPLING ACTIV1TIE~; OF PCB-CONTAMINATED SOILS AT PI CILLO S lTE
--
Average Standard No. of % of
Saaplins "0. of Concen!ration. Deviation, MaxilDU1D Samples Sa.ple8
Date 5..,le8 x S Concentration '> 50 pp. >50 ppm Comments
I
8/26/80 1 700 700 1 100-. .Comp08ite HE
trencha
\: 54.5 48 91.3 2 67 '''Tall mound -
Phase Ib
7/13/81
70.2 45 122 1 33 Shallow mound -
Phase 111 b
7/25/81 4 79.3 30 124 4 100 Soil BoringsC
6/25/82 5 41.1 35 100 1 20 Four quadrants
plu8 composited
7/19/83 5 7.4 3.9 13.2 0 0 Not con8idered
repre8entative
according to John
Leo R1 DEHe
2/09/84 92 36.8 31.0 180 15 16 EPA PCB Resultsg
2/09/84 9 33.7 20.2 74.5 '1 11 R1 OEM Results
for 9 composited
....ple8f
aRI OEM .aaplinl reported in RiSSI (lO/aO).
brranklin Relearch Inltitute la.plinS reported in Pytlevlki (8/81).
cUB EPA Resion 1 laaplina reported in Ecology and Enviroft88nt Inc. (11/81).
dO.H. Material. .a.plins reported in Platha. (1/83).
eaI OEM .aaplinl reported in Muller (7/83). .
fRI OEM .aaplinl and 8naly.i. reported in Hartley (3/84).
IUS'IPA 181ion 1 analy.i. reported in Lattaille (3/84).
-------
TABLE 2.
VOLATILE ORGANIC COMPOmD CONTENT IN pcn PILE AT PICILLO SlTf.:a
. :.=...~ .~: ~
Averageb Standardb No. of samples Per':cnt sar.;i11es
Maximum showing greater showing grt:1ter
concentration, deviation, concentration, than detection than detection
Parameter ppb ppb ppb limit 4 limit
l,l-dichloroethylene 440 440 1 11
l,2-dichloroethane 7,570 7,530 18,500 7 78
.
1,1, I-trichloroethane 4,550 4,220 8,350 7 78
trichloroethylene 4,000 5,040 13,220 8 89
l,l,2-trichloroethane 890 440 1,500 5 56
tetrachloroethylene 3,980 2,500 6,560 8 89
chlorobenzene 930 370 1,510 7 78
benzene 3,770 1,270 5,490 4 44
toluene 46,250 41,860 132,000 9 100
ethylbenzene 8,030 3,630 11,000 9 100
xylene 49,300 21,400 80,500 9 100
aBa.ed on RI DEM, re8ult8 reported in Hartley 1984 for sampling conducted 2/9/84 for nine
.elected 88111p1e. of 92 collected.
bAverale and 8tandard deviation of sample8 greater than detection limit.
-------
TA.BLE 3.. ORGANIC POLLUTAN'"S DETECTED AT THE PICIJ.LO SITE
-- --- -.--
--.. --
Maximum
Ground Water Maximull
Concentrationa Surface Water Surface ""at.'r
Category Compound 3/83 Concentrationb Sampling Dateb
Volatile Benzene 250 970 4/79
Aromatic Toluene 29,800 8,300 ~
3/81
Hydrocarbons Ethy1benzene 1,190 1,100 3/81
Xylene. . 4,510 56,000 2/79
Chlorinated Ch1orobenzene 140 121 6/82
Volatile 1,2-Dich1oroethane 160 NO
Orpnic8 l,l,l-Trichloroethane 23,000 4,600 3/81
l,l-D1ch1oroethane 710 500 3/81
l,l,2-Trich1oroethane 260 NO
1,l,2,2-Tetrachloroethane 10 ND
Ch1oroethane 290 1,700 4/80
Ch1orofol'8 2,100 4,200 7/81
1,1-D1chloroethylene 280 1,408 6/82
Trans-1,2-Dich1oroethy1ene 480 370 12/80
Methylene Chloride 4,840 6,000 12/80
Fluorotrich1or08ethane 1,930 ND
Tetrachloroethylene 420 810 7/81
Trichloroethylene 5,860 1,600 4/80
Carbon Tetrachloride NO 2,200 4/79
"
(continued)
-------
Category
Ketones
Acid
Extractable
Organici
Baae/Neutral.
Extractable
Organics
Others
TABLE 3 (continued)
Maximum
Ground \later Madmum
Concentrationa Surface Water
Compound 3/83 Concentrationb
Acetone 9,080 21 ,100 '. .
Methyl Ethyl Ketone 2,920 1,700 ~
Methyl Isobutyl Ketone 890 3 ....
Phenol. 1,800 NS
2-Nitropheno1 94 NS
2,4-Dimethy1 Phenol 680 NS
Bis(2-Chloroethy1)Ether 53 NS
1,2-Dicblorobenzene 94 NS
Nitrobenzene 170 NS
I8ophorone 260 NS
Naphthalene 11 NS
Bis(2-Ethy1heXy1) Phthalate 15 NS
Tetrahydrofuran 1720 101
PCB-1242c 1.57 NS
.
Surface Water
Sampling Dateb
3/81
3/81
6/81
6/82
.
All values in micrograms per liter (ppb).
NO . Mot detected.
NS . Not aampled.
eReference: Tighe' Bond, 8/83.
baeference: £ & E. 3/83.
cPCBs detected in vell BI-W2.
II
-------
,
TABLt:: 4a. UNNAMED SWAMP AIR t::HISSION MODELING RESULTS
- Maximum
Contaminant Predicted
Level in Downwind
.. .urface Emi..ion . Ambient
Pollutant ,.. vater aate Concentration
Catelory Compound ("Ill) (lb/br) ("af.3)
Aroma t ic Xylene.a 56,000 7.64 359
Hydrocarbon. Benzenea 970 0.15 7.2
Toluenea 6,000 0.88 41.4
Etbyl Benzene 930 0.13 6.1
Chlorinated Carbon Tetracbloride 2,200 0.25 11.5
Volatile Chlorobenzene 121 0.02 0.9
Oraanics 1. 1. l-trichloroethanea 4.400 0.54 24.9
l,l-dichloroethane 500 0.07 3.3
Chloroetbane 1,700 0.30
Cbloroforma 4,200 0.54 25.3
l,l-dicbloroethylene 1,408 0.20 9.1
Metbylene ch10ridea 7, 700 1.16 54.3
Tetracbloroetby1ene 810 0.09 4.1
Trichloroethy~enea 1,600 0.20 9.3
letone. Methyl ethyl ketonea 1,600 0.66 2.9 '. .
alndicator compound..
Data averaging times corre,spond to the length of the monitoring
periods, which are outlined in Volume III, ApPendix D of the
Endangeroment Assessment and Feasibility Study. .
-------
tABLE 4b.
DEtECtED AND PREDICtED OFFSIT! CONCENTRATIONS 0, VOLATILE-ORGANICS
Compound
Ben&ene
Carbon tetrachloride
Chlorobenune
1, 1, I-Trichloroethane
Dich1oroethanes
Chloroform
Dich1oroethy1enes
Ethy1benzene
Methylene chloride
Tetrachloroethylene
Toluene
Trichloroethylene
Xylene.
Methyl ethyl ketone
eCA modelingb
1984
~;i;3d-----;;~~-
eCA offsite8
monitoring 1982
ug/m3C
---------------------
ppbd
NO-19
NO
NO
NO
NO
NO-13
NO
14-140
NO-4S
NO-57
ND-140
NO
ND-S40
Nb-56
NO- 5. 9
0-
7.2
11.5
0.9
24.9
3.3
25.3
9.1
6.1
54.3
4.1
41.4
9.3
358.5
2.9
2.2
1.8
0.2
4.5
0.8
5.1
2.3
1.4
15.4
0.6
10.8
1.7
81.3
1.0
Odor thresholde
-------------------
o.
ppb
ND-2.6
3.5 -34.5
No-12.6
ND-7.7
ND-36.4
ND-124.2
Nb-19.0
~
160
approx. 9.000
approx. 90
100.000
120
100.000
500
90
approx. 10.000
8pprox. 5.000
100
approx.
approx. 3
approx.
10.000
Co-xylene)
10.000
aSource:
CCA, 1982.
bDovnvind concentrates at 3,000 feet from source, worst case.
details.
cReported or calculated units.
dConver.ion at 760 8m Hg, O.C.
~ovest threshold reported, Source:
fND . Not detected.
See Appendix D for modeling
Verschueren, 1983.
-------
TABLE 5. RECENT DATA FOR CONTAMINANT LEVELS IN SOILS AND LEACHATF.S AT
THE PICILLO SITE
~-
110. of ...,1.8
''IU", luaden! llul- 8'-1al
CODceatl"tlaa, ded8Uoa, CODC:eatl',tlOD, p'e8tel' th8a
Cat.1ft7 Co8poaIId "II "II ppll c!etectiOD lIalt Source of S8.plea
&r8etlc 1,1.... 49,300 21,400 80,500 ~. , PCB P11e'
IIJdl'OC8rboe. Ieu- 3,770 1,270 5,490 4 ~ PCB P11e a
fol... 46,250 41,860 132,000 9 ..... PCI P11ea
Itbyl beal8M 8,030 3,630 11,000 9 PCB P11ea
Cblarleated 1,1-dlchloroeth,Ieae 440 440 1 PCB Pile LeachateC
'o18tU. 1,2-dlchloroetha... 7,570 7,530 18,500 7 'CB 'l1.a
Oranlc. Q1arofo" 3 3 1 'CI 'lIe L.achateC
Met"I'" cblorl'. 15 15 1 PCB P11. Leachat.c
frlchloroetb,leae 4,000 5,040 13,'220 8 PCI P11.a
1,1,I-trlchloroetb8.. 4,550 4,220 8,350 7 PCB P11.a
1,1,2-trlchloraethaae 890 440 1,500 5 'CB '11. a
f.tr,chloroath,l- 3,980 2,500 6,560 8 PCI P11.a
Chloro"'''' 930 370 1,510 7 Pel Pl1.a
Acl. th0801 (total .nact,bl..) 57,000 13,400 72 ,000 4 Pheaol P11. b
l1rtacuU. 4-ch1on-31Ithl, phnol 1,980 330 2,300 4 Pheaol PU. b
Or888lc, 2,4-dl8ltbyl phnol 4,680 3,170 9,100 4 'he1l01 P11. b
btnctaU. Q1ol'4ae 30 30 1 'heao1 Pile Leacha:.c
"8t1d.... tCI8 PCl-Arac1ar 1248 36 ,800 :u ,000 180,000 90 PCI 'U.d
...... - U ... a881t. aported 10 llertl., (184) for ...,11.. coadacted 02109184.
...... - U ... n881t. nport" 10 hr'rottl (7183) far ...,11.. c08llact8d 06117/83.
c..- - U ... a881t. nport" 10 hr'rottl (8183) far ...,11.. coedaet" 05/03183.
...... - IP' I'881t. 1'OfDrt" 18 Latt8111. (184) far ...,11118 coa4ac:t" 02'''''84 ., U IDI.
.
-------
t
!'\!3i.~. 6.
CONCENTRATIONS OF ORGANICS IN THE UNNAMED SWAMP AND WHITFORD POND
-
-
Sampling Location
-------------------------------------
Unnamed Swamp
------------------ Whitford Pond
Upstream -------------
Sampling Center of Dam Inlet
Date (PF02a) (PF03) (IWP)
05/07/80 1,700 ND NS
12/09/80 500 ND NS
03/25/81 320 ND NS
06/03/82 ND NS ND
02/01/83 ND NS 1.7
02/09/84 32 7 NS
05/07/80 1,400 NO NS
12/09/80 2,400 ND IfS
03/25/81 1,800 NO NS
06/03/82 224 KS NO
02/01/83 2 NS 1.6
02/09/84 10 1 NS
05/07/80 510 ND NS
12/09/80 200 ND NS
03/25/81 240 ND NS
06/03/82 151 NS ND
02/01/83 ND NS ND
02/09/84 66 BD NS
05/01/80 ND ND NS
12/09/80 ND ND NS
03/25/81 440 3.3 KS
06/03/82 151 NS 7.4
.
. 02/01/83 ND NS 2.7
02/09/84 5 9 NS
05107/80 3.700 tm IS
12/09/80 1,700 ND NS
03/25/81 7. 700 lID NS
06/03/82 70 NS ND
02/01/83 ND IS 2
02/09/84 14 3 NS
(continued)
!ndi:ator COap~UM .
Xylenes
Toluene
Benzene
Chloroform
-------
~~-
1 nd ic a tor Compo\1nd,."
i
1,1, i-trichloroethane
Trichloroethylene
"Total Volatiles"
t
'fABLF. 6 {continued}
Sampling Location
-------------------------------------
Unnamed Swamp
------------------ Whitford Pond
Upstream -------------
Sampling Center of Dam Inlet
Date (PF02a) (PF03) ( IWP)
05/07/80 1,600 ND NS
12/09/80 830 ND NS
03/25/81 870 20 NS
06/03l82 276 NS 2.6
02/01/83 ND NS 3.8
02/09/84 962 15 NS
05/07/80 840 ND NS
12/09/80 250 ND NS
03/25/81 90 1 NS
06/03/82 ND NS ND
02/01/83 ND NS ND
02/09/84 310 ND NS
05/07/80 11,700 ND NS
12/09/80 7,390 ND NS
03/25/81 12,452 102 NS
06/03/82 2,634 NS 10
02/01/83 2 NS 11.8
02/09/84 3,030 54 NS
NS . Not sampled.
ND . Not detected.
All concentrations in ppb.
- Source:
E&E, 1983.
-------
TABLE
1.
SUHHA1lY .OF STANDARDS AND CkITER.tA FOR SUBSTANCES DISCUSSED IN THE TOXICITY PROFILE
=
HUII8n 1 x 10-6 AIIbient vater
cancer risk8 quality criteriab
_-----___r~- ------- ---------------- Acute toxicity OSHA
Fi.h and Fish and level-aquatic standard
Coapound vater Fish only vater Fish only -. or~nisllsc TLvd
~
Benzene 0.66 ppb 40.0 ppb 0.66 ppbe 40 ppbe S.3"ppm 10 ppm
Toluene 14.3 ppm 424 ppm 17.5 ppm 100 ppm
Xylene. -=.---- >10 ppm8 100 ppm
l,l,l-Trichloroethane - 18.4 ppm 1030 pp. 18 ppm 350 ppm
Chloroforll 0.19 ppb 15.7 ppb 0.19 ppbe 15.7 ppbe 28.9 ppm (acute) 25 ppm
1.24 ppm (chronic)
Trichloroethylene 2.7 ppb 80.7 ppb 2.7 ppbe 80.7 ppbe 45 ppm 100 ppm
Methylene chloride 0.19 ppb 15.7 ppb 0.19 ppbe 15.7 ppbe 11 ppm 200 ppm
Methyl ethyl ketone -- >100 ppm8 200 ppm
Methyl isobutyl ketone -- >100 ppm8 100 ppm
Acetone ---- >10 ppa8 1000 ppm
Phenol 300 ppbf 10.20 pp. (acute) 5 ppm
2.56 pp8 (chronic)
2,4-D18ethy1pheno1 400 ppbf 2.12 pplll
(continued)
-------
TABLE 7-'1 (continued)
Human 1 x 10-6 Aabient water
cancer riska quality criteriab
------ ------ Acute toxicity OSHA
Fish and Fish and level-aqua t,1 c standard
Compound water Flah only vater Fish only ',organismsc TLvd
2-Nitrophenol --- 230 ppb
Cresol 5 ppm
Isophorone 5.2 ppm . 520 ppm 117 ppm 5 ppl!l
PCBs 0.79 ppt 0.079 ppt 0.79 ppte 0.079 ptte 2 ppb 1 ppm
aConcentration corresponding to human one in one million increased cancer risk from 1980 Ambient Water
Quality Criteria. - signifiel no carcinogenic assessment based on currently available data. Source:
Federal Regiater, Noveaber 28. 1980.
bSource: Federal Register, Nove_her 25, 1980. Criteria are based on lystell1c toxic effects unless
otherwiae noted. T~_'_~ indicates non priority pollutant, therefore no criteria formulated.
cSource:
Federal Re8ilter, November 28, 1980, unless otherwise noted.
dSource:
Sax, 1981. --- indicates no TLV.
eA8bient Vater Quality Criteria ~.Ied on 1 x 10-6 carcin08enic riak level.
8Ultiply b, 10; for 1 x 10-7 l..el, divide by 10.
fOrl8DOleptic criteria: levell at which taate or odor are i.parted to vater and/or fish.
no huaan health aip.1ficance 8iven to this level.
For 1 x 10-5 level,
There is
.Source:
Ver8cheuren, 1983.
..
-------
"
TABLE 8.
COMPARISON OF SWAMP CONTAMINANT LEVELS TO
TOXICITY LEVELS
. Highe.t Current
,.'
Iwamp .wamp Lowest Lowest
concentra- concentr.- acute chronic
tiona tiona toxicityb toxicityb
Compound (ppm) (ppm) (ppm) (ppm)
Acetone 21 0.066 S.S
Benzene 0.97 ~.3
4.2 28.9 1.2 .
Chlorofora
Methyl ethyl ketone 1.7 70
Methyl i8obuty1 ketone 0.003 460
Methylene chloride 6 11
1, 1, 1-Trich1oroethane 1.6 0.96 18
Trichloroethylene 0.84 0.31 45
Toluene 6 0.01 17.5
Xylenes 56 0.03 1.3
aData from Tables 4-5, 4-6.
~ata from 'EPA Water Quality documents, Federal Register,
November 28, 1980, and a search of AQUIRE in July 1984,
EPA's computerized data base on toxic substances.
,
~
('
.
-------
..
4,QOO tl11
SCALE
QUADRANGLE
LOCATION
Figure 1.
Locus map of the Picillo Farm Site. (Adapted from E & E. 1981).
-------
.
....-:;:". ",,'::::-':::':'--.ee.e , , -,
.' "Ii "...-- -"'- -""" " ---'" --'e' \ \ '.!II"'"
'f .'". .._.~. .......... -....-.... '''.'' '...... "'''-.........-. "''''..',... 't'
' , I ,. ,-......., ---.. "".., , '----. ...-----...... -"...... -..', \ ' ,
-...."-...1 . I " -"""......... .""--............ .........\ '" ','.. ....-....~ -"".", "', .. ,,'. \
_.-- . , \ I '.. 'e__- , ..' "'" ------ ',", .
........... , .. ............... -...., .. ---- ........ - -..., . ' .. . .
.- '... "......,.. -- ..............,
- ---,'" ~ ( ..... -._._,1, \ "'--"'---" "--""--"~' ' ., '
.- .......... -. \ \.. """."-----" ""'.... ..... ,:/ i \ \ \, \ '-',
.- -.. C.. -.. "..- -' \..., ,....... .' I " , .." '.
."""M '.....' " -.-............... "_tel"" -..--..--.......-....., ...... ".". I ,f I \ \ ,," ',.
.. ""... -.... .II! .'t. --.. " .... "., \" ...
...---"....:"....., .. --..' -' .-,..~'" -..-..--- "'-----..--.-.., . ~"'''' ..... ....' l: ~."'\"'I' '\" \',
.- " "'... "'",....--.--- ........-- ..--- "-..--- . '",.. , ..-J.' I ' '..-" . "
..-..#' ...-...........-...- . -----"....-:::'--'....".--..... ................. ..... '" '... ,.':,' ".. .. ~
.- ,........ .....------ -- .",- ---....... --.. -"''''.''.''..', "', '"" ',I, '\ '\' , ,
.. -.......-....-.-- -...-.-- ....-"'-:'-.---'8 .---.. ..... ""'",', I I I""', \, ,
~.. .-- -......-.--:.:::- =.ni;-:::::::::-'::.__....- ..-.....::........... .."tt ..-.. "\, "' ' '''''' '\."" ~ : \ '\, ",,"': I,
' .".. -- . '....-",,,'-:,....... - .--':-"---..- -..---- ._-~ -..... -.." '",- '" . ".. ," ,'\ \' ,
(~ .,.- ....- .....::::-.....:,::::. , .~ - --- -.. -... .-.. ..... '.., , " ".. "....... -"'.. "', " ", ',"","" " '
""'~ .... .-.. ...,.."., . ~..-c..-----"" ... '.... . -. - --« , ' ..
.."", "..~._.... / . ...... ! t r :~'--'_,~.:...:: ".-.eo.- ',io.. .,-,,-.,,:::.~,~~. :/41" '~-""" ~ ,..'" ': ' "
,~, - . , ..' . -.. , \" C'-'--' ---,..~,;;::-._-. " I I... ,- ~~~. ...?:,":-. e..~ . -'- -1' r t-
oo. .' -- ...,.., : J' " .-- ~...._- --"""'--':_~"8ItiL. " ~ , '-!C." --.. ."-"'''......-~.. ... T-' itP,'. - ,
.~ ,~ ~- .-J.' ."';" '.: \~..~. .: .,' ~~;~-....:-..- .-,/:~1-J:J-.~w-."" .: ,.' .../..;.. " "- .:..:, '.. ..._, \
' ""'.. -- ,~, ' '[""'" <" -,-,-. '~... ~ =!. "I ' "'. .... '~' '., '
I ,.A....::s "~''''1' "... '\:~ \..., "'...... "'''''''- '.... ....,..~.......... '-;1 " ,"'''''' :.' / l",,'... ,~ ,',..., ~ .
' ~ - ~ -';:-:0- ..- '........, .. "" . ..",... ..--... ' , ' II ,
,/ , I /..,.- / ~', '. ....,....---.;...;.. -.!'IC- """ .'. ~I\,' ,. \ t. ....-..., .,." . . ' , .. , ,
#"- , ~\, -'- """'.....-.........~,.:................ "'..........J'I,..~,.. .,',- .~ ' . " .. , \ ~
" ,~-, .. '-...:.....- "'-'''''''''''::'-'''':''-''''''''-'''''.'''~=::::.e--.i.U \... ""'.. ., ~""'.... 0 : ,.. ".... .. .. " '
/ ,/ ... - - '-:,:'---;:::=::::::::;:::-:~~~::~<:-':-.::;:::=-., ""1;c.,:-::..,;~:.~"......::......, ",' ':.::>.:..= ',~..." \" .... .... ...
~." ./ " " . ..... ..........,' ."."::';':':;;;:'::':'._~~":.~~-:'';;:.:..--;~'''''\ I\. '''', !-"" "'~.....- -\ J,.. :~!;... I \ \. " '~;.,
/ ,I . I f'''~'''''-''..._--u._.'~';:.:;~ ""',\ \ ',~ " " '1-1'''' ~ ,.'" .. "
/ ,',' ~, .-:,-:t ."'E' ~o I!, , ~.... '- ..:: ,t : .. . \.. \ '.. "'...
... -' " (" .'/ -II ", .: 'I ~ ~, " ":" ", I "",,','
/'" ..' .,' ,,' II ......~" 1,,' ;,:.:..... I;: ~ U ~ \, .. ~ \ J~ ; I' }.......4--.. I ... \'L'\ "..... "..,
./ . , I / .. ' .. I' !7'.....,~ ' ~, of , , ...----,...- ",',
"" ." I ,..-. I ! 1,- -. ~;:"'f '\'! .:;:.::~..~ \. ~ \ \":'.. " ", '''... "".... '-"'"'' ",
... ,.,,, ..~ I '. ...,.. I! ,.._*_rrt. ,'1 " f . ',~\ " \ -"..:..........~_....-. "-', '0.. '"'''' ""..... "", "
.. ..' ., / fT ,........... '/:" , , ''#1'~'"'' f~..,." I ..... ", '" " ',',
,.... /- .. , J. \ 'i l ,",', .::i:#!~:', "'. " ,,"..,..-...-,. """'.... "'... .., "".. "",
..' /" ,/ I "",,,.: "-." i' ! l.. " I (I ~~\:... '''','' '\ \ ',...., , -""........ -""... """''''' """.. '...... "'0
, ... .... , : ' " \ ' " ~", ..., '... \, 4..... -......., ", "',
.".. .#"" .j1l '.. ~~:! ,.,\ ", :\\j \ '. ",.~, ", ", ',.I \ J,I' I r'," -'. '"'' ", ", , ",
.. .' ,- ("t t, , I , 'J , , , '''' ' -"'... ....,
..'" .,. '--' '. /:,. ~j! ...... ~"" 'I, ",j', '."'1.. ""'... ".. '", "'''.. "-
,/ ,'. \ '-',' t ,....,,'....... ~. "":."", '", "....r')o, " '..., " " ".. '"
..... .,' , ... ., .. ~., , I, "','" ......-, '- ---........ 'to - '.. ...,
,:=, , , f.... -,- :,,"!'P--'~~,o '.. ".., \ ... I \!. i\ -J<\ '''', 1---.. ::::==~, '. ", ", ", ",
. .......' , --.- 1':_-- " ..-' ,\ '''. ".:' \ ~ .. to... 'to._""'" ',.., .,. ..--, ,', "'.. "... '... '.. ..
...-.-.... II ~---~:t!I~_:';:;..'=':::.._..-... \ \ 0..... , .:~. -!. - -< k '~"'" ""r..::.....:-f'.. ...-...\ \, \" '''nt~ti.. '... "'...
",_" """--.-.--..=::--:, ' 1 \ ""'-..- ...::-- -., ""... ,....~ ." ','."', 'o. '.. ""', ""
I r \ I , ~ I.. ... -......-..- -......... '" , ''', '... , ','\ . ", '"
,,--. -' .... ,"'------... 'ffl "......-...' -- '0', ,/, '" ~I-t ""',..
-' / ...... "I' , .. -...:3,:--"--.." ,............, " , " , , ..
-.,..-.... . (-----..--... I : ", " '..... '\ "...... ',', \ '1'-" -- , :', ' ", '. . ,
: . :. ,: '.. '- - --.---------- --, '.. "', " , , J-.., ' , ~, . ~ "
I I ',..- .' II' ",,,,, _.".I~I''''' .., '.... 'II "', . .,. , " , ,
: \. --.--....': I:: '...... ...........-..------... ", . ''', '''','' .,+ ... ,. 0' : : : :
...... \ .--....----' I;: "'''-..00''.''.._----- "'\...," '" \ " \4..1 'Y': " :,... " '8
"..... '. ------------- ,. "."-"" " lla.. ~" , -., :: ' ,
.-..... -' -48'-:.::----_--_'*:'fIi, ----......- .. ,"., \ I' ,I , -'~" , , , :
'. - - ~.., . ---.,...... "'" . "\ \ "" I "
",j ,. /-' N' ...--- ..\". '.. , " ",..,._,. ' : I ,
"0__- ---...."". .::::::..... "..,'.. "', \: ,/ \ ,'''' \ I ! : ; ; :'
-a:~-~ ...".2~~."'~r--.-.", ' iB. J8i... " ~t '.. I.. I' '-~~".'-L--..!..--:._~- --
" ,/ ..."'--"'-""'--.. ""'''', " " 7 . 1-' . : I: U!I!t ,
,. (, .... '" , , I .' I
...' I, :..r.", ..-..---... " \ .. 'I .. /' \..,' , '. II: -~...- .-- ........ .
,... h' "', 'I. ..: ..' If " ,'. .. .. '
....., ....-:;~ ( , " ...... " : ' / l / \ ~ I 001. !IIJII1!.\EU=!:N' !
........ ... .''1" ... '. \ .. \ ': ',", " \ \ . . ,0 :
..- ~.., : ff,.-. c{, r.. .. ' , I ' I / ;' ~I' II . " " ' - - ~&:::I ~.:.1.. ...c., ,
.' -.,1:/.1 ..,', I ' , , , ...-..:;.:..... I
..~-~ ..' I ,J: I ~t.1 \ ,~: .it. ' , I ..' ': -;' ~.. -.....-.. I
.. ..' " 'I /:. ( . ! - - _I I ':" I J,I .. I I' --iI'Ii.-=IC'."",,-
: /. l' 'II ,. I I "..-". . ,,' ...- ,_.. , I
( : !~;~\;' ~I : :, ; I i \ : :,' l, j ',.' ---.--.--, I
. " "\' I~ " : ' . I ' \ \ :: '\ I " .-....
... , " , , '" , , I
\ I '1£" " , I , . \ t ' \, " I. , I. - ... ,...., -..
, , ' '---'"''' " . ; : ~ ' " ,\ . ,,~...: 1 .,.. ~....,-
\ . ":.., \ , '----"~"
\ ~', ,,", ~. \ \" ~_..,. '-J~. I ~_.'-",,,
, ~,---",.- . , .. \ , , ,~ ,,~ . - ~ .... 8U. .. ......
' . " \ .. \ \ I 'T" .. I
" ~ ., , . -. '''' - -.-....
~' ,,' '\ , \ I --f.~
.""' .. , .' "'--L-
, '.
Figure
to
2
General present site features (Source:
. Spirito & Associates Inc. for RtDEM).
Dolce.
-~', .~..
-------
!lY
!IE
8"'..11
=
=
=
-~
Ciii1
&iiii
,..
....
-
--
-r.
.-
, .-
, LINER, ':, 'PRIMARY,
, ' ,"'i'. ,"::' ,,' ~~ BEDDING,:':' ,SYNTHETIC':-
,'''i,~ "/.:! .::;..';..':.:: "., LAYER", . ",,' . LINER ' .'
,..:',t'.:'.~. '"/,:8;:.:... . '.~'" :,': :" """8E EN""
.' '....:~~ ~"',: ,~:' :~.:-:~:r,::'i: .. "'< ,,' ";'~: "~ :. "r'OTTEWXETILES
J'" ,,~i""":~~ ."":':'~.:A"':"'~" :. ""~;J.' ,:.'."" ..."', - S8
.', .,.t !.:'...a~",'..~i'....~.(~il,~;.!~'.: 'J.~.J~,.;~I"'1/;I\,,:~,",~... "..~It.:: . '.0 i.. " .'
'.: ' 'i,{f~~'~;I~;:':"~:'~i;,~"l ;:,' ,:l"',~),~!''';!"t(.,,~:, ,;./, ::,,;o';:.,'r'::." "","", '..
" 't,r",,""..4. ..,'.1' ",0'" .. ,. .. ,0. . ',,' ... °o'~' .
;S~ .'! I';'\'~"~;:'" '," ~:')',nf'~I:~", :,: .!. '. ";.': ' ", ' . ".:; .,r,:.. '. ': " :' , '
i"''''' .,~"..,.-.!'r"'''' ;. """ ., ','... .
.'1- . ,. 'f....'S' 1:;,'. :'II" : ".~" "..: ,I I . -' """ ;; "'. 't" :.: ' . ;
~jo;;'I~' I~\ltjtl:~( ,"j), , "':.::'"';',, ' ...; , ".'~I":' .". ,': ,': ;"',~ ',',
~~'-';.~ . :"~~~6~~~. ......'.: 'I'~.....~.:'I":~;'\ "....".:'. . ,,-
~'oj.:, "l"";~\-:"~''';'';C''';'''' j' '.~ ".',\. '-.'ii-"" .t. ,; ,.," ".-re 3
-~' , .~~' ,~"("";':;'!i'"",'~:""J.,~:;"I-;: tj" : ,':"';,:.. 106"
,...."" . ...\,.'~ 3.... ", " ,'. "". '- I ., , "", "
. ::~ ,'j'~r~"'r/.-:J.':'''~\ ",.'ri:'~,r\:" J,':_', '.' 'i',""'" . ,
.;,.~ -o.!,"' 'i'~~.' ..:...~.)' ;",: . J . ~':,. o. :' -, ~ . ; .;.. ".
~ . . l;~ ~':;~~\:):.\.:~; ...;'.. . :.::: : :.. .:'...'~'. ";' I
",..' , ... ~,.,.' "J. 't' ," , ." '. ... t , ,
. t; 'f:~ ;iI'.8I1~,,,'''':i'''',,,.~", .J.:~.:...:. '~t: ~,:'~"r". '.
. au,... F""" 'lC'~r-r&T'nN
L.M' I;.n "",. ...v.. . M. . v, .
~
t
COLLE CTION
OR AI N
"
DRAINAGE LAYER
DRAINAGE LAYER
LEACHETE COLLECTION
LEAK DETECTION
"
Propo8ed RCIA de81Rfted landfill.
-------
..
-
-
-
COYER
-
, .
. .
"
-
-
-
SYNTHETIC
MEM8R ANE
'::{'H?:':::l~~'7'>"'~~' '.':'
'.~
VEGATIYE
COVER
DRAINAG E
~
&
LAYER
,
LAYER
'0
v
v
P1RUre
Propoeed cap de. 11ft.
10
-------
Attachment 1
.
PICILLO ~ SHEET FOR SOURCE CONTROL ALTERNATIVES
A1te=native SC-2:
Disposal of PCB and phenol contaminated soils
offsite in a RCRA/TSCA Landfill
* Direct ~apital Costs
,...
~ Offsite disposal (6500 yd3)
$1,478,300
222,300
- Site closure
* Indirect Capital Costs .
(Engineering 9%, Legal ~nd license/
permits 5%, Contingency 25%)
663,300
* Operations and Maintenance, 30 years
(present worth)
145,300
1$2,509,2001
Alternative SC-3:
Disposal of PCB Contaminated Soils Offsite
in a RCRA/TSCA Landfill
Disposal of Phenol Contaminated Soils
Onsite in RCRA Landfill
* Direct Capital Costs
- Onsite RCRA landfill of phenol soils
- Offsite disposal of PCB soils (3500 yd3)
$212,100
844,500
- Site closure
227,200
* Indirect Capital Costs
500,800
* Operations and Maintenance
191,400
1$1,976,0001
-------
Alte=native SC-4:
Disposal of PCB Contaminar-ed Soils Offsite .
in a RCRA/TSCA Landfill
Disposal of Phenol Contaminated Soils Onsite
in a Cap Only Landfill
* Direct Capital Costs
- Onsite cap-only landfill of phenol
soil s (3000 yd 3 )
~ .
$ 113,300
- Offsite disposal of PCB s6ils (3500 yd3)
, .
- Site closure
844,500
227,200
* Indirect Capital Costs
462,300
* Operations and Maintenance
191,400
\$1,838,700\
Alternative SC-5:
Disposal of PCB Contaminated Soils Onsite
in a RCRA/TSCA Landfill
. Direct Capital Costs
- Onsite RCRA Landdfill (6500 yd3)
- Site closure
$378,200
227,200
. Indirect Capital Costs
236,200
. Operations ,and Maintenance
191,400
1$1,033,0001
-------
Alte~native SC-6:
. J a~q 10 Isaoq( ,
Disposal of'PCB'Cdfttaminated Soil's Onsite
in a RCRA/TSCA Landfill
Disposal of Phenol Contaminated Soils Onsite
in a Cap Only Landfill
. Direct Capital Costs
- Onsite RCRA Landfill fo~ PCB soils
(3500 yd3)
$250,800
- Onsite cap-only landfill for phenol
soils (3000 yd~)
- Site closure
113,300
227,200
. Indirect Capital Costs
230,600
. Operations and Maintenance
191,400
------- |