United Slates
Environmental Protection
Agency
Office o»
Emergency and
Remedial Response
EPA/ROO/R01 -89/034
May 1989
&EPA
Superfund
Record of Decision
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50272-101
REPORT DOCUMENTATION
PAGE
11. REPORT NO. 12-
EPA/ROD/ROl-89/034
3. A8dp18n1'8 ACC888Ion No.
4. Title and Subdtle
SUPERFUND RECORD OF DECISION
Pinette's Salvage Yard, ME
First Remedial Action - Final
7. AUlhOf(.)
5. Report 0..
05/30/89
..
.. IWfonnl"ll Organization Rapt. No.
8. Perfonnlng Org.lnlzatlon Nama and Add...
10. ProjKtITuklWort< UnI1 No.
11. Contract(C) Of Grant(G) No.
(C)
(G)
12. Sponaorl"ll OrganlutJon Nama and Addr8A
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report . P8r1od Covered
Agency
800/000
14.
15. Supplement..., No"'.
16. Ab8tract (Umlt: 200 worda)
The Pinette's Salvage Yard site is located approximately one mile southwest of the town
of Washburn, Aroostook County, Maine, in the northeast corner of the State. The site
consists of a vehicle repair and salvage yard and an adjacent undeveloped area
containing wetlands. Land surrounding the site is used for residential, general
industrial, and agricultural purposes. An undeveloped forest and a wetlands area are
also adjacent to the site. The water supply for the approximately eight to ten
residences located within a one-half mile radius of the site is obtained from private
wells located in the deep, bedrock aquifer below the site. Municipal wells, used to
supply the drinking water to the residents of Washburn, are located one mile northeast
of the site. In June 1979 three electrical transformers were removed from Loring Air
Force Base by a private electrical contractor and allegedly brought to the site where
they ruptured while being moved from the delivery vehicle. Approximately 900 to 1,000
gallons of dielectric fluid containing PCBs spilled directly onto the ground. A removal
action was performed in late 1983 which included excavation and offsite disposal of 800
yd3 of PCB-contaminated soil from the site. Subsequent investigations at the site
revealed the presence of a wide range of PCB concentrations in the surface and
subsurface soils. The highest levels of PCBs are in the general area of the transformer
(See Attached Sheet)
17. Document Analyala L DncrIp1Df8
Record of Decision - Pinette's Salvage Yard, ME
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene), Organics (PCBs), metals (lead)
b. Idantifter8l~Endad T-
c. COSA T1 FIeIdIGroup
16. Avallabllty St...-
18. S8a81ty a- (11118 AaporQ
None
20. S8a81ty a- (11118 P8ge)
Nnn/Olo
21. No. of .....
71
22. Price
See ANSl-Z3I.18
s.~onllt-
(forlMlly NTJS.35)
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EPA/ROD/ROl-89/034
Pinnette's Salvage Yard, ME
First Remedial Action - Final
16.
Abstract (continued)
fluid spill. Surface migration of PCBs extends as far as the undeveloped land adjacent
to the salvage yard. In addition, soil contaminated with chlorinated benzenes was
found in the spill area. The total volume of contaminated soil above 5 mg/kg PCBs and
containing other organics is approximately 2,200 yd3. Detectable concentrations of
PCBs and benzene compounds were identified in both the shallow and deep aquifers
localized within and slightly downgradient of the spill area. This remedy is designed
primarily to address soil contamination and, to the extent practicable, ground water
contamination at the site. The primary contaminants of concern affecting the soil and
ground water are VOCs including benzene; organics including PCBs; and metals including
lead. .
The selected remedial action for this site includes excavation and offsite
incineration of 300 yd3 of soil containing greater than 50 mg/kg PCBs; excavation and
onsite solvent extraction of 1,700 to 1,900 yd3 of soil containing between 5 and 50
mg/kg PCBs and other organic contaminants, with offsite incineration of treatment
process effluent and onsite treatment of air emissions; excavation of approximately 500
yd3 of surface soil containing between 1 and 5 mg/kg PCBs to a minimum depth of 10
inches and placement, along with treated soil, in the area where more highly
contaminated soil was excavated, followed by additional soil covering and revegetation;
onsite ground water pumping, and collection via interceptor trenches, with treatment
using filtration and carbon adsorption, followed by discharge of treated water into the
shallow aquifer; access restrictions; institutional controls; and sediment, ground
water, and surface water monitoring. The estimated present worth cost for this site is
$4,367,000 which includes annual O&M costs of $135,000 for years 1-2, $42,000 for years
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50272.101
REPORT DOCUMENT A T10N
PAGE
1. REPORT NO.
EPA/ROD/~01-89/034
2.
3. A8ciPenC'. AcctuIon No.
4. 1118 IN .....
SUPERFUND RECORD OF DECISION
Pinette's Salvage Yard, ME
First Remedial Action - Final
7. Autttorta)
So A8ptrt D...
05/30/89
I.
I. Performing Org8niDlion ~ No.
.. ,.,...... CrQ8Ii101I1011'''''' IN AddN8
10. ~88IIIWCIItI UnIt No.
11. ConInCl(C) OIl GnnI(G} No.
(C)
(0)
12. Spell.... OrpnIudon ...... IN Add!.-
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
12. Type of RIIpCItt . Peftod Cownd
Agency
800/.:Q00
14.
;f
15, ",pp' 1JI8I"" No-
1 :
II. Ab8hCI (LImIt: 2110 WIIfd8)
The Pinette's Salvage Yard site is located approximately one mile southwest of the town
ot Washburn, Aroostook County, Maine, in the northeast corner of the State. The site
consists of a vehicle repair and salvage yard and an adjacent undeveloped area
containing wetlands. Land surrounding the site is used for residential, general
industrial, and agricultural purposes. An undeveloped forest and a wetlands area are
also adjacent to the site. The water supply for the approximately eight to ten
residences located within a one-half mile radius of the site is obtained from private
wells located in the deep, bedrock aquifer below the site. Municipal wells, used to
supply the drinking water to the residents of Washburn, are located one mile northeas~
of the site. In June 1979 three electrical transformers were removed from Loring Air
Force Base by a private electrical contractor and allegedly brought to the site where
they ruptured while being moved from the delivery vehicle. Approximately 900 to 1,000
gallons of dielectric fluid containing PCBs spilled directly onto the ground. A removal
action was performed in late 1983 which included excavation and offsite disposal 0: 800
yd3 of PCB-contaminated soil from the site. Subsequent investigations at the site
revealed the presence of a wide range of PCB concentrations in the surface and
subsurface soils. The highest levels of PCBs are in the general area of the transformf'
(See Attached Sheet)
17. DocuINnt An8lyoi. .. DMcriptOn
Record of Decision - pinette's Salvage Yard, ME
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene), Organics (PCBS), metals (lead)
.
-
b. Id8ndlWal~End8d Tem.
Co COOl." AeldlGI~
18. Avlilabll.., sc.t.......
1IJ. S8curi1y 0... (Thta A8p>r1j
None
20. S8curi1y 0... (Thl. ""1181
Nrmp
21. No. 01 Plgal
n
I
22. Price
(SH AHSl-l:IlI.18)
s.. m.tructi- on R.-
. FORM 272 (4.17)
(F......ny NTI~J5)
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11. ContnlctlGnlnt Number. Insert contract or grant number under which report waa prepared.
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'" GPO
19830 - 381-526(8393)
OPTIONAL FORM 272 BACK
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"'\
--
ROD DECISION SUMMARY
PINETTE'S SALVAGE YARD SUPERFUND SITE
WASHBURN, AROOSTOOK COUNTY, MAINE
MAY 30, 1989
u.S. ENVIRONMENTAL PROTECTION AGENCY
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ContE::nts
I.
II.
III.
IV.
V.
VI.
VII.
VII-I.
IX.
x.
XI.
PINETTE'S SALVAGE YARD SUPERFUND SITE
ROD DECISION SUMMARY
TABLE OF CONTENTS
Paae Number
SITE NAME, LOCATION AND DESCRIPTION................ 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES............ 3
A. Remedial History.............................. 4
B. Enforcement History........................... 5
COMML'NITY
RELATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5
SCOPE AND ROLE OF RESPONSE ACTION.................. 6
SITE CHARACTERISTICS............................... 6
A. soil.......................................... 7
B. Groundwater................................... 8
SUMMARY OF SITE RISKS.............................. 8
DOCUMENTATION OF NO SIGNIFICANT CHANGES............ 10
DEVELOPMENT AND SCREENING OF ALTERNATIVES.......... 10
A. Statutory Requirements/Response Objectives.... 10
B. Technology and Alternative Development
and screening............................... 11
DESCRIPTION/SUMMARY OF THE DETAILED AND
COI~PARATIVE ANALYSIS OF ALTERNATIVES............... 13
A. Source Control (SC) Alternatives Analyzed..... 13
B. Management of Migration (MM) Alternatives
An a 1 y zed. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1 7
THE SELECTED REMEDY................................ 19
A. Description of the Selected Remedy............ 19
B. Rationale for Selection/Cleanup Goals......... 22
1. Source Control........................... 23
2. Management of Migration.................. 25
STATUTORY DETERMINATIONS........................... 26
A. The Selected Remedy is Protective of Human
Health and the Environment.................. 27
B. The Selected Remedy Attains ARARs............. 28
C. The Selected Remedial Action is Cost-
E f f ect i ve. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
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XII.
.. - .." .....
:-',
D. The Selected Remedy ut1l1zes Permanent
Solutions and Alternative Treatment or
Resource Recovery Technologies to the
Maximum Extent Practicable.................. 33
E. The Selected Remedy Satisfies the Preference
for Treatment as a principal Element........ 33
STATE
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PINETTE'S SALVAGE YARD SUPERFUND SITE
ROD DECISION SUMMARy
LIST OF FIGURES/TABLES/ATTACHMENTS
Fiaure Number/Title
paae Number
1-1. Site Location Map................................... ~
1-2. Site Vicinity Map................................... 1B
1-3. Location of Geologic cross-Sections................. 2A
1-4. Geologic cross-Sections............................. 2B
1-5. Property Boundaries................................. 3A
1-6. Extent and Depth of PCB Contaminated Soil
(1 ppm or greater).............................. 7A
1-7. Supplemental Remedial Investigation
Monitoring Well Locations....................... 8A
1-8. Organic Contamination/Shallow Aquifer............... 8B
1-9. Organic Contamination/Deeper Aquifer................ 8C
Table Number/Title
1-1. Summary of Chemicals of Potential Concern........... 9A
1-2. Summary of Potential Human Health Risks............. 9B-9D
1-3. Merging of SC and MM Alternatives................... 13A
2-1. Potential Chemical-Specific ARARs and
Criteria, Advisories and Guidance............... 28A-28D
2-2. Potential Location-Specific ARARs and
Criteria, Advisories and Guidance............... 28E-28G
2-3. Potential Action-Specific ARARs..................... 28H-28P
Attach!r.ents
A.
B.
C.
Pinette's Salvage Yard NFL Site Administrative Record Index
Pinette's Salvage Yard NPL Site Responsiveness Summary
Pinette's Salvage Yard Site-Specific PCB Soil Risk
Calculations and Cleanup Level
Pinette's Salvage Yard NPL Site State of Maine Declaration
of Concurrence Letter
D.
i
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I
DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Pinette's salvage Yard
Washburn, Aroostook County, Maine
STATEMENT OF PURPOSE
This decision document presents the selected remedial action
for the Pinette's Salvage Yard site, located in Washburn, Maine.
This decision was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent
practicable, the National contingency Plan (NCP); 40 CFR Part 300
et sea. (1988). The Regional Administrator has been delegated
the authority to approve this Record of Decision.
The state of Maine has concurred on the selected remedy and
determined, through a detailed evaluation, that the selected
remedy is consistent with Maine laws and regulations.
STATEMENT OF BASIS
This decision is based on the administrative record compiled
for this site which was developed in accordance with Section
113(k) of CERCLA. The administrative record is available for
public review at the Washburn Town Offices in Washburn, Maine,
and at the EPA Region I Waste Management Division Record Center
in Boston, Massachusetts. The attached index (Attachment A to
the ROD) identifies the items which comprise the administrative
record upon which the selection of the remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Pinette's salvage Yard site is a
comprehensive approach for complete site remediation of the
principal threats posed by the site. This approach includes both
a source control and management of migration component, as
described below:
The Source Control Component entails:
Off-site Incineration of PCB-contaminated Soils Greater Than 50
DDm: and On-site Solvent Extraction of Additional PCB- and
Orqanic-contaminated 50ils.
EPA will address soil and, to the extent technically
practicable, groundwater contamination at the site by excavating
and treating a total of approximately 2,000-2,200 cubic yards of
-------
.
established for this site.
More specifically, those soils contaminated with greater
than 50 parts per million (ppm) PCBs will be excavated and
transported to a thermal destruction incineration facility
located off-site. The extremely high temperatures attained.
during incineration should destroy at least 99.9999% of all the
organic contam.inants contained in this soil.
Soils containinq between 5 and 50 ppm PCBs, and soils
contaminated with other organic chemicals will also be excavated
and treated. These soils will be treated at the Pinette's site
using a solvent extraction technology. This process involves the
use of a solvent to remove PCBs and other organic chemicals from
the soil. The solvent extraction process is expected to achieve
at least a 95 to 99% reduction in the original concentration of
contaminants in the soil at the Pinette's site.
EPA will continuously monitor the soils after treatment to
ensure that all cleanup criteria are met. If soils remaining
after the initial extraction step do not meet EPA's target
cleanup goals, these same soils will be re-introduced into the
solvent extraction process. The liquid PCBs and other organic'
chemicals extracted from the soil by this process will be
collected and transported off-site to a TSCA-licensed
incineration facility. Residual water from the process will be
pumped into storage tanks for treatment by a portable carbon unit
located on-site or by some other acceptable means of treatment.
During on-site solvent extraction, exhaust gases from the process
will be treated by air pollution control devices to ensure that
appropriate health and safety and air quality requirements are
being met.
Prior to full-scale implementation of the solvent extraction
process on the Pinette's site, a pilot test will be conducted to
establish the optimum operational settings for the extraction of
those contaminants specific to the Pinette's site, and to verify
that soil residues from the process are nonhazardous. After the
pilot studies determine the optimum treatment scheme, full-scale
operation will proceed. After the soil residues from the process
are found to be nonhazardous, they will be placed back into the
on-site excavated areas.
Additionally, removal of PCB-contaminated surface soils
containing greater than 1 ppm (but less than 5 ppm) to a minimum
depth of 10 inches will occur at the site. This volume of soil
(approximately 500 cubic yards) will be moved to the areas
resulting from the prior excavation of the original 2,000-2,200
cubic yards described above. These soils will be consolidated
into the on-site excavation, followed by the replacement of those
nonhazardous soil residues resulting from the on-site solvent
extraction process. All site areas, including those undergoing
this additional consolidation activity, will be covered with new
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Finally, access to the site will be temporarily restricted
using fences and by posting warning signs during the excavation
and treatment activities performed: any junk vehicles/debris
hindering site remediation activities will be removed from the
site; institutional controls, and long-term monitoring of the
salvage yard to detect future contaminant releases to the .
environment will be established; public education programs will
be conducted; additional groundwater monitoring wells will be
installed; disposal/treatment of wastes generated during the
remediation activities will occur; and on-site surface water and
sediments will be monitored after overall site remediation is
completed.
The Management of Migration Component includes:
EXDedited Groundwater Collection and Carbon AdsorDtion Treatment.
EPA will actively address groundwater contamination at the
site by utilizing groundwater collection and carbon adsorption
treatment. The system will first entail construction of shallow
interceptor trenches and deep extraction wells to collect the
contaminated groundwater. Collected groundwater will then be
pumped through a granular filter to remove suspended/colloidal
particulate matter.
Following this preliminary filtration step, the groundwater
will be treated by carbon adsorption, which uses activated carbon
to remove the organic contaminants found in the groundwater. All
treated groundwater will then be discharged back into the shallow
aquifer through the use of shallow recharge trenches. The entire
aquifer collection system should extract approximately eight to
sixteen gallons per minute for approximately two years.
Additionally, EPA will recommend the establishment of
institutional controls on the site groundwater. These
recommended controls would include a complete prohibition on the
use of the on-site groundwater for drinking water purposes both
during and, if necessary, following overall site remediation.
,
DECLARATION
The selected remedy is protective of human health and the
environment, attains all Federal and most state requirements that
are applicable or relevant and appropriate (ARAR) to this
remedial action and is cost-effective. This remedy will however,
require a CERCLA section 121(d) (4) (C) waiver from a State ARAR
due to the technical impracticability from an engineering
perspective of collecting particulate-bound PCB's from the
groundwater at the site. This remedy satisfies the statutory
preference for remedies that employ treatment and that reduce the
toxicity, mobility or volume as a principal element and utilize
permanent solutions and alternative treatment technologies to the
-------
Additionally, because the remedy could likely result in hazardous
substances (PCBs) remaining in groundwater on-site above health-
based levels, a review will be conducted (at a minimum) within
five years after commencement of the remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
~~~ ~(// I'r~f'
Date I
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SITE NAME: pinette's Sa1vaqe Yard
LOCATION: Washburn, Aroostook County, Maine
DESCRIPTION:
The Pinette's Salvage Yard (PSY) site is located on Gardner Creek
Road (a.k.a. Wade Road) approximatel~ one mile southwest of the
town of Washburn, Aroostook County, Haine, in the northeastern
corner of the state (see Figures 1~1 and 1-2). The town of
Washburn has a current estimated pQpulation of 2,200 residents,
and consists of various family-owned and operated stores, an
elementary school and high school, Town Hall and medical center.
A portion of the Pinette's Salvage Yard (PSY) site is privately
owned and operated by Roger J. Pinette and his family as a
vehicle repair and salvage yard. Damaged vehicles are stored
and/or dismantled, from which recovered parts are sold, on an
infrequent basis at present. This portion of the site is
situated within the parcel of land currently owned by Roger J.
Pinette and Cynthia C. Pinette (granted, with warranty covenants,
as joint tenants) which consists of 9.45 acres.
The remainder of the PSY site consists of an area south of
Gardner Creek Road where contamination has come to be located
through surface water runoff from the salvage yard area located
north of the road. This smaller area is part of a larger tract
of land that is privately owned by A.E. Albert Farms, Inc. It is
currently undeveloped and for sale.
Land use within a one mile radius of the site consists of
residential, general industrial, agricultural and undeveloped
forest and wetlands. Residential zoning (with a one acre minimum
lot size) and agricultural zoning predominates adjacent to the
PSY site. other areas along Gardner Creek Road consist of
residential homes both northeast and southwest of the site;
agricultural areas north and south of the site (as well as
surrounding areas); wetlands to the northeast, northwest, and
south of the site: and general industrial facilities located near
Main Street in Washburn and the intersection of Gardner Creek
Road. To the southwest of the site, Gardner Creek Road becomes a
dirt road and eventually separates into several logging roads.
The forests in this area are used for lumber production, and
numerous hunting camps have been established for recreational
outings.
Natural resources at the site and in surrounding areas include
ground water, surface water, fish and game, agriculture,
wetlands, and forests.
Approximately 8-10 residences housirig 20-30 people are located
within a half mile radius of the site. Many of these residents
obtain their water from private wells which are primarily located
in the deep, bedrock aquifer near the site. The majority of
residents located within the town of Washburn obtain their
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Pa~e lA
CANADA
c:.~'.c.""
v~~ -
'Q~ ,
~ -- 161
~~ ~((,
~\
)~
CANADA
I
I
I
REFERENCE: ASSOCIATION,
MERICAN AUTOMOBILE E 1987 EDITION I
A MAP OF MAIN I
HIGHWAY
I": 10 MILES.
@
I
10 20
o MILES
SCALE IN
RE I-I
FIGU MAP
SITE LOCAT10~E YARD SITE
PINETTE'S SALVA REPORT
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Page lB
REFERENCE:
U. S. G.S. 7.~' TOPOGRAPHIC QUADRANGLE MAP
WASHBURN, MAINE. DATE OF PHOTOGRAPHY
EDITED: 1984, SCALE: I" = 2000 '.
@
LEGEND:
.
DIRECTION OF FLOW
o
2000
SCALE IN FEET
I
4000
FIGURE 1-2
SITE VICINITY MAP
PINETTE'S SALVAGE YARD SITE
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ROD DECISION SUMMARY
Pinette's Salvage Yard
page 2
wells used to supply potable water to these residents are located
approximatp.ly one mile northeast of the site on Church street in
Washburn and are approximately 100 feet deep.
The surface water bodies in the area of the site consist of the
Aroostook River, Gardner Creek, Gardner Creek Branch, and Salmon
Brook (see Figures 1-1 and 1-2). Fishing, trapping, and duck
hunting are the primary recreational activities conducted at
these locations.
The PSY site is located approximately 1,500 feet northwest of the
Aroostook River, as shown on Figure 1-2, a major waterway in
northern Maine that is used as a natural and recreational
resource. Regional and local planning officials have
successfully completed a recent $60 million effort to clean up
the Aroostook River. This extensive cleanup effort has produced
better water quality, enabling the public to use the river for
boating and swimming, and as a potable water source in certain
areas. Atlantic salmon and trout, both environmentally sensitive
and selective species, are now found in the Aroostook River
indicating that the water quality is excellent.
The wetlands, agricultural and woodland areas surrounding the
site are used primarily for such activities as hunting, trapping,
horseback riding, snowmobile and motorcycle riding, and camping.
The agricultural areas are predominately used for potato and pea
farming. Some farms in the area raise cattle, horses, and other
livestock. Various animals such as moose, bear, deer, mink, and
waterfowl have been observed in the areas surrounding the site.
The remedial investigation field work performed at the PSY site
identified several additional site-specific characteristics as
described below:
o ground surface elevations range from approximately 480 to
470 feet above mean sea level (msl) north of Gardner Creek
Road, and 475 feet above msl or less south of the road where
the topography becomes steeper;
o surface water drainage flows south to southeast on the
western portion of the site, and approximately due east on
the eastern portion of the site prior to discharging into
individual culverts located under Gardner Creek Road:
o four (4) distinct lithologic soil units exist (see Figures
1-3 and 1-4) including: surface soils (alluvium), a
clay/silt confining unit, a sequence of glacial till/glacial
outwash, and a bedrock unit (consisting of an upper,
weathered and fractured zone, and a deeper, less fractured
bedrock zone);
-------
4"
.'11
A" /'
--
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t
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APPROM'WUE SPill AREA
DWW-I
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---- --------------------------
. - - _.. - - - - - - - - - - - -... -- - - - - - - - - - - - - - - - -. - -
- - .- -- .-- - - p. - -. - - - - - _0 - - - _. - - -.. - - .. - - - - -- -
- - - - -- - - - -... - - - - - - - - - - - - - - - - - - ~.".
- - - - .. - - - .. . - - .- - - - - - - - - - - - - - - - - - - - - - -
- - - - - -- - - - - - -- - - - - - - - - - - - .. - _.- - - - - --
------------------------------ --_.--
..---------------------------
- - - - - - - - - - - - - - - - - - - - -.. - - - - - - - - -
.--------------------------- --
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- -. - - - - - - - - - - - - - - - - - - - - - - - --.. - - - -
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410
I
.'
IIQIU:
SOO
SOO
APPIIOXIIIIAU IPlll AII(A
1 GAIIO"E II Cl!U.
IIDAD
DIIIW-'
iTF
I.
Interpretltlons Ire blsed on
dltl obtllned fr08 wldel,
SpiCed explorltlons. Actull
subsurflce conditIons In
arels not explored .1' dIffer
fr08 thol. shown due to
geo1oglc 'Irlltlonl,
Depth Ind thlckn.ss of thl
soIl Ind rock strltl
Indlclted on the Geologic
(rosS-SectIons Ir.
generlilled fr08, Ind
Interpollted between, the
test borings. Infor.ltlon on
Ictull subsurfici condltlonl
exlstl onl, It the test
borln9 10Clt lon,
410
410
:;
..
.
..:
...
~
8 410
...
~
...
...
...
z.
410
- -
----------------------
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------------------------
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-~~~~::~~~- -... -~."~~-~-~::- f~ - .-: .~~:~::~~}~~~- ;=-~~~{~~
440
---- --
- - -- - - - - .. - - - - - -- - -
440
. - - - -- - - - - - - -.- - - - - - - -- - -
410
~~~~===2?:'- e~-~=~- ~-==~
- - - - - - -- - - -- - -~ - .-
- - - --- ___n___-
----~-----
- - -- - - _.
- - - - - _. - - - - - - - - -- - - - - - --
-n-- -- ~ - ~--_.-
- -- - - ~. - - - - - -- - - -- - - - - -- -- - -
-- - - - -- -. --.
----- -------.
-.-- - - - -
---- ---.- -- .-- --- --
--.- - -- - - .- -- - n .- -- -
-- ------_. __n___-
- - - - - - - - - - _. -
- - - . - _.-
- - - - - - -- - - -- - - - .
-- - - - ~ - -
. - - - -. - - - - - - - - - - < -
- - - - - - - - _.- ,- - - - - - - -.
~ - -- -, - - .- -< - - -- -- -
.-------.
.-----------.-. ----
- - - .- '- - - - - -- - -. - --
----------
- - -- - - - - - - - - .- - -
410
---------
Page
28
A' '00 !!!!!tit
4- Wlter 1.v.Is ..Isured
August 5, .988
.10 -...- Wlter table (Inferred)
~ Sind Ind grlv.I, Ilttl.
to 10.. slit
480 ILZZ:J 'II' Ind silt, cia,
~ 'Ilclli till. grlv.l.
sind, sIlt and cia,
440 L--:'- ~ I 8edrock
410
Approxl.lte contlct between
frlctured bedrock (lbovI)
Ind coftPetent bedrock
(belowl. Dished where
Inferred.
~
Inverted water tlble
symbol Indlcltes bOtt08
of uppermost siturited
cll' and sIlt, cll'
lIyer.
o
100
SO
_IlOHUl ICALI IN P'EET
IAPPIIOJl I
FIGURE 1-4
GEOLOGIC CROSS-SECTIONS
A-A' AND 8 -8'
"H(TU'S UlVAI( TAllO 11f(
-------
. .
ROD DECISION SUMHARY
pinette's salvage Yard
page 3
o wetland areas consist of the eastern pond/drainage ditch,
the weE~ern pond and those areas west-northwest of the site,
the "gr:;.undwater breakout" area south of Gardner Creek Road,
and a large area located adjacent to Gardner Creek Road
approximately 300 feet east-southeast of the site;
o two (2) distinct aquifers (shallow overburden and glacial
till/fractured bedrock) are separated by an intervening clay
layer;
o the clay layer separating the two aquifers is found at a
depth of 2 to 6 feet below the ground surface, extends to
depths of up to 12 to 16 feet, and va~.es in thickness from
2 to 3 feet in the northern portion of the site (where it
may become discontinuous) to greater than 10 feet in the
southern portion of the site north of Gardner Creek Road;
o the clay unit has low permeability (approximately 2x10-7
em/see) relative to the overlying alluvial aquifer, and
therefore is an aquitard allowing limited downward movement
of groundwater and contaminant transport; .
o the clay unit (aquitard) creates a "perched" groundwater
condition in the shallow alluvial aquifer, resulting in a
saturated thickness ranging from two to three feet; the base
of the shallow aquifer crops out south of Gardner Creek Road
which results in the discharge of groundwater in the
"groundwater breakout" area; and
o the clay unit (aquitard) also in turn creates semi-
confined conditions in the underlying glacial till/fractured
bedrock zone.
A more complete description of the site can be found in the Final
Supplemental Remedial Investigation (SRI) report (Ebasco, 1989a).
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The main portion of the PSY site is presently operating
infrequently as an automobile and scrap metal salvage yard.
salvage operations typically consist of a fleet of three (3) tow
trucks and a garage/workshop. The salvage yard is owned and
operated by Roger J. pinette and his family who reside
approximately 200 yards west of the garage area (see Figure 1-5).
The site currently contains between 100 to 150 junk automobiles
arranged in rows, piles of scrap metal, and other assorted
-------
J
.-
- _L
COREY
PROPERTY
(
" /./,.-r-",
'/
.----~ po'fltl'
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APPROXIMATE'--/ CULVERT
/ SPilL AREA
~
DROST
PROPERTY
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o
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. -- ~'. / ( '8"' CULVEIIT
/ ....--~ \
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GROUNOWATEII .
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PLUGGED CULVERT
~
-t-
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o
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Page
3A
PIlDPIIITY LINE
ITIIUr.TUII[
VIOl: fA TlDN
LIMITS
.
UTILITY POL I
ArPROI'MATE
DEfiNED 81 SPILL AIIEA AS
NUS I ~IT
@
o
~oo
100
SCALE IN fEET
FIGURE 1-5
PROPERTY B
P'NETTE'. OUNOARIES
. SALVAGE
fEASI8IL"Y STUD YARD SITE
-------
ROD DECISION SUMMARY
Pinette's salvage Yar4
page 4
A.
Remedial History
In June 1979, three electrical transformers from Loring Air Force
Base located near Limestone, Maine, were removed from the base
under a written agreement with a private electrical contractor
hired by the base. Allegedly, the transformers were brought to
the PSY site where they apparently ruptured while being removed
from the delivery vehicle which had transported them.
Approximately 900 to 1,000 gallons of dielectric fluid containing
polychlorinated biphenyls (PCBs) spilled directly onto the
ground. The approximate spill area is shown on Figure 1-5.
After being contacted by the electrical contractor in November
1979, the Maine Department of Environmental Protection (DEP)
determined in April 1980 that the site was contaminated with PCBs
and associated volatile organic contaminants (VOC's). Additional
sampling by the Maine DEP in August 1981 and the USEPA in May
1982 confirmed the presence of PCB contamination at the site. In
December 1982, the site was placed on the National Priorities
List (NPL) making it eligible to receive federal Superfund monies
under CERCLA for the conduct of investigations and cleanup
actions.
On October 4, 1983, EPA Region I authorized an Immediate Removal
Action (IRA) for the PSY site. Approximately 1,050 tons (800 cu.
yds.) of PCB-contaminated soil and assorted debris were removed
for disposal during the period from October 4 to November 4,
1983. The IRA was performed to excavate those soils grossly
contaminated by PCBs (i.e., soils containing 50 parts per million
[50 ppm] or greater of PCBs, as determined by on-site analysis).
Those soils that were excavated were then transported to the
Model City, New York secure hazardous waste landfill facility.
In 1985, a Deletion Remedial Investigation (DRI) was performed at
the PSY site to determine if any residual PCB contamination
existed and whether this residual contamination was reduced
sufficiently to warrant the deletion of the site from the
National Priorities List (NPL). This investigation resulted in
the determination by the USEPA, in consultation with the Maine
DEP, that the site was not suitable for deletion from the NPL.
The results of the DRI were released to the public in October
1987.
Based on the levels of residual PCB contamination discovered
during the DRI, the USEPA, in consultation with the Maine DEP,
determined that a supplemental Remedial Investigation (SRI) was
warranted at the PSY site. The Supplemental RI was performed
using a two-phased appro~ch. The Phase I field investigations
were performed from September 1987 through November 1987. The
-------
ROD DECISION SUMMARY
Pinette's salvage Yard
page 5
Phase II investigation. The purpose of the Phase II
investigation was to address any outstanding data requirements
and objectives so that the data would be of sufficient quality
and quantity to support the preparation of a Feasibility study
(FS). Phase II field activities were completed in November 1988.
The Final Supplemental Remedial Investigation and Public Health
Evaluation Report (Ebasco, 1989a), and the Draft Final
Feasibility Study Report (Ebasco, 1989b) were distributed for
public comment in March 1989. A more detailed description of the
site history and response actions undertaken at the site are
presented in these reports.
B.
Enforcement History
On March 6, 1989, EPA notified four (4) parties who o~ned or
operated the facility, generated hazardous substances that were
shipped to the facility, arranged for the disposal of hazardous
substances at the facility, or transported hazardous substances
to the facility of their potential liability with respect to the
site.
In addition, technical comments presented by the PRPs during the
public comment period were submitted in writing, and are included
in the Administrative Record. To date, special notice has not
been issued in this case.
III.
COMMUNITY RELATIONS
Throughout the site's history, community concern and involvement
has been low. EPA has kept the community and other interested
parties apprised of site activities through an informational
meeting, fact sheets, press releases and a public meeting.
Additionally, EPA has conducted several television interviews and
has been available to the public during all site visits.
In June 1988, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about and involved in the remedial activities
being performed at the site.
The Agency published a notice and brief analysis of the Proposed
Plan for the PSY site in the local newspapers on March 8, 1989
and made the Proposed Plan, Final Supplemental Remedial
Investigation and Draft Final Feasibility study reports available
to the public through the Administrative Record located at the
Washburn Town Offices and at EPA's offices in Boston. It should
be noted that notice of the waiver from compliance with the State
of Maine's groundwater Maximum Exposure Guideline (MEG) for PCBs
-------
ROD DECISION SUMMARY
Pinette's Salvage Yard
page 6
On March 14, 1989, EPA held an informational public meeting to
discuss the results of the Supplemental Remedial Investigation
'and the cleanup alternatives presented in the Draft Final
Feasibility Study, and to present the Agency's Proposed Plan.
The Agency also answered questions from the public during this
meeting.
From March 15, 1989 to April 14, 1989, the Agency held a 30-day
public comment period to accept public comment on the
alternatives presented in the Draft Final Feasibility Study and
the Proposed Plan, and on any other documents previously released
to the public. On April '11, 1989, the Agency held a public
hearing to accept any oral comments. A transcript of this
hearing, as well as written comments received at the hearing, and
the Agency's response to these comments are included in the
attached responsiveness summary (Attachment B to this ROD).
IV.
SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy was developed by combining components of
different source control alternatives and a management of
migration alternative to obtain a comprehensive approach for'
overall site remediation. In summary, this response action will,
to the extent practicable, address the principal threats posed by
the site through excavation and treatment of approximately 2,000-
2,200 cubic yards of contaminated soils, and collection and
treatment of contaminated groundwater on the site.
V.
SITE CHARACTERISTICS
The Supplemental Remedial Investigation (SRI) performed at the
PSY site fro~ September 1987 through November 1988 was designed
to attain the following objectives: (1) conduct a comprehensive
characterization of the nature and extent of contamination in the
various media at the site; (2) perform an evaluation of present
and future health risks and environmental impacts resulting from
the contamination at the site; and (3) collect sufficient data to
be used in preparing a Feasibility Study (FS) to screen potential
remedial technologies and assemble and evaluate potential
remedial alternatives for the site.
Chapter 1 of the Draft Final Feasibility Study (Ebasco, 1989b)
contains an overview of the results obtained from the SRI, while
further details regarding sample locations, sample methods and
sample analysis are provided in the Final Supplemental Remedial
Investigation and Public Health Evaluation report (Ebasco,
1989a). The significant findings of the remedial investigation
-------
ROD DECISION SUMMARY
Pinette's Salvage Yard
page 7
A.
Soi1
Soil sampling during both Phase I and II of the Supplemental RI
field work revealed the presence of a wide range of PCB
concentrations in the surface (0 to 6 inch interval) and
subsurface (6 inch to 6 foot interval) soils. These contaminated
soils were predominantly found to be confined to an elliptical
area measuring approximately 150 feet by 80 feet located north of
Gardner Creek Road (see Figure 1-6), and in the same general area
as the original transformer dielectric fluid spill (see Figure 1-
5) .
The maximum surface soil concentrati of PCBs within the area
north of Gardner Creek Road was 92 p~ ~s per million (ppm) at a
location approximately 220 feet north ~f the road. The overall
geometric mean surface soil concentration from the approximately
30 surface soil samples obtained from the area north of the road
was 2.1 ppm. Maximum subsurface soil concentration of PCBs was
11,000 ppm found at a depth interval of 6 inches to 2 feet below
the ground surface, and also located approximately 200 feet north
of the road.
The migration (transport) of PCBs identified in soils located
north of Gardner Creek Road has apparently occurred, to a limited
extent, due to the surface water runoff/drainage and the
topographic features found at the site. This surface migration
(transport) of PCBs has resulted in some contamination to the
south of the road within the approximate area of the
wetland/groundwater breakout, as shown of Figure 1-6. The ?:B
contamination in this area is restricted to the top ° to 6 '~hes
of soil which covers an elliptical area measuring approxim2 ;ly
50 feet by 90 feet. The maximum PCB concentration found i~ ~his
area was 12 ppm, while the geometric mean concentration of 10
samples was 0.44 ppm. No subsurface soils (6 inches or deeper)
were found to contain any PCBs greater than 1 ppm.
Additional organic contaminants of concern found in soils at the
site included chlorobenzene, 1,4-dichlorobenzene, 1,2,4-
trichlorobenzene, benzene, and chloromethane. These organic
compounds were predominantly detected in the subsurface,
saturated soils at a depth of 2 to 6 feet, and primarily within
the same elliptical area north of Gardner Creek Road where the
PCBs in both the surface and subsurface soils were identified.
The maximum concentration of these organic compounds was 260
parts per billion (ppb), chlorobenzenei 5.1 ppm, 1,4-
dichlorobenzene; 510 ppm, 1,2,4-trichlorobenzenei 18 ppb,
-------
'"
../
- 48.
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~
477
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.
Page 7 A
ill!.!!!!:
,........, ..IIr.. WHrllr or"TH TO orr"UT I
~ ...... "CI CONcrNTII..T.ON IUII,..cr .,
o TO z ,ru '110" GIIOUNO IUII'..C[
- ..11[.. WHEII[ O[..TH TO O[[P[ST I
,.... I'CI COHCEH",.."OH SUII'..C[ "
Z TO 4 'ErT '110" GIIOUHO IUII'''CE
,........, &IIr.. wHEllr DEPTH TO OEE"EST ,
~...... ..CI COHC[HTII""OH $UII'..C[ IS
4 TO . ,rET 'liD" GIIOUHO IUII''IC[
_"liE" WHEIIE OE'TH TO DEEPEST I
...... "CI COHCEHTII""OH IUII'&CE IS
. TO 8 'EET '110" GIIOUHO ,uII,..cr
.&IIr.. OF COIIIT&NIIII..TIOIII &T
. I"OOT OlpTH IS "SSUNIO TO
Ir ZEIIOI
IU.t :
1.
Interpretations are based on
data 'ro. widely spaced
e.plorat1ons. Actual
conditions 81' dl"lr 'rD8
those shown dUI to variations
In wastl deposition and
cont..lnant transport
paUlrns.
@
.
° 100
50
seAL[ III '1[1'
/-
--
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.-""
FIGURE 1-6
EXTENT AND DEPTH OF PCB
CONTAMINATED SOIL C I PPM OR
"'"UTI" SA4.VACII "AIIO SITE
'IA'18IUT\' ,TUO" I!eI'OIIT
-------
ROD DECISION SUMMARY
pinette's Salvage Yard
page 8
B.
Groundwater
During the Supplemental RI, a total of 19 monitoring wells were
installed throughout the PSY site area at nine separate locations
(see Figure 1-7). The majority of these monitoring wells were
installed as two-well clusters with one well screened in the
shallow overburden aquifer, and the second well at the base of
the glacial till (above the bedrock). Only one well (identified
as BMW-5, located at the approximate center of the original
transformer spill area) was installed into the bedrock, and
screened from approximately 12-27 feet below the interface of the
bedrock and glacial till.
Groundwater samples were collected from each of the 19 monitoring
wells during either Phase I or II field work. In the case of
well cluster SMW-5/DMW-5/BMW-5, three complete rounds of samples
were obtained for analysis. Additionally, both filtered and
unfiltered groundwater samples for PCB analysis were obtained on
two to three separate occasions from well cluster SMW-5/DMW-
5/BMW-5 and SMW-7/DMW-7. .
As shown of Figures 1-8 and 1-9, detectable concentrations of
PCBs, benzene, chlorobenzene, 1,4-dichlorobenzene, ~,2,4-
trichlorobenzene, and chloromethane were identified within both
the shallow, and deep till/bedrock aquifers at the site (with the
exception of chloromethane, detected only in the deep
till/bedrock aquifer). These detectable concentrations of
organic chemicals were found to be localized within and slightly
downgradient of the spill area, but north of Gardner Creek Road.
The concentrations of PCBs identified on Figures 1-8 and 1-9
represent the results from unfiltered groundwater samples, since
no detectable concentrations of PCBs were identified in filtered
samples also obtained at the site.
Based on the distribution of the organic contaminants depicted in
Figures 1-8 and 1-9, it is apparent that the benzene and
chlorinated benzene compounds are slowly migrating with the
groundwater towards the south-southeast from the spill area.
However, the distribution of PCBs detected in the groundwater is
limited only to the approximate spill area. This is principally
due to the relative immobility of PCBs in groundwater, since PCBs
tend to adhere tightly to soil particles.
VI.
SUMMARY OF SITE RISKS
As part of the Supplemental Remedial Investigation (RI) for the
PSY site, a Public Health Evaluation (PHE) was performed to
estimate the probability and magnitude of potential adverse human
-------
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IntuCTUllf
VfGfTATI~ LIMIT'
UTILI" POlf
IIOHITOIIIHO WEll locaflON
'HAllOW aOUlfER
110"'10111"0 WEll lOCAT......
OffP aOu.,EII
IfOIlOCK II~ITOIlINO WfU.
lOCA fI~
f.,STINO TOPOOlla"",c CON1OUA
1I0Tf.
SHV.6A 'S . repl.ce.ent well 'nst,"ed
during Phlse II. SHY.6 WIS destroyed
during the 'nst.11.tlon 0' OHW.6.
@
o
100
110
FIGURE 1- 7
SuPPLEMENTAL REMEDIAL INVESTIGATION
MONITORING WELL LOCATIONS
'"HE UE', ,AlVaGE "'"0 'lTf
-------
":~.\" ~2\~.~:~ ,",. . - ,;;~;:::~-"'-1.. '. ~". l J /~
, ~ ~ \..-- ~......,.... ~, /1//'-----------------.
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' SPill AAfA ' , "7 ,OA"AO
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Chlorobenl.n. S9 // /", AND PAAK'NO........ " '." ~-- J/UJ .
1,4-Dtchlorobtnlnne 26' 'I0Il"'-' /., " '1" I.. ,-"'TA ""wIEnIE
I,Z,4-Trlchlorobenun. 34 , V- ,./... ) ~ ,"£5'O(NCE
Aroclor-1260~] :< ,,: r";
--;:::::::::::: / '. <,," , : --- O"AlllEL
~ - 5"""8 , , 'I ' ., O"'IIE
g- ~~~~~~:.nzene 8934' SIoIIW -, // A' ~ ~1III--:W~2 (\ ., ~~~~\~:~:y \ \. .
1,4.Dtchlorobenun. 1--+ .
1.2.4-Trlchlorobenun. 950 . '... ': "
Aroclor-1260 0.66 ';' '- ,--'8'" CUllinT
~~ ' :
"7~
-------
.
/
(
/
//
1,4-Dlchlorobenzene
1.2,4-Trlchlorobenlene
)\
---'
91
/
-~-
-- A" ;:>.-;;'---
./
/'
/
-
/
.<--
. 'r--
""---~
------
-------' '
.60
.-
-
410
"
--
TOPOGRAPHIC ..APPINO OEV(LOPfO
FRO" GROUND SURVfYING 8Y
o A 8l.CIISTONE, 1988
"CAl ( .": 20'
. A8'S
POBe 81\
LEGEND:
.
1,4-DI~hlorobenlen.
I,Z,4.'~rlchlorobenun.
Monitoring well
10c~tlon Ind risk -
or ~~zlrd-engpnderlng
contl_lnlnts detected
In shlllow Iqulfer
IIOnltorln9 wells
slMpI.d August I
through 5, 19R8, Ind
th.lr concentrltlons,
In PP8, or If not
detected, Indlelt.d
by "( Dl",
3
45
~
APPAOXIIIIATE SPIll A"EA AS
DEFINED 81. NUS/FIT
NOTE'
Only contl.lnlnts detenlln.d In the
Public Hellth (vllultlon (Se~tlon 6.0)
to .ng.nder gr'lt.r thin 10-
upperbound ..e.ss Ilfetl~ clnc.r risk
or hlzlrd Inde. grelter that 1.0 Ir.
111ustrlted. R.fer to the Supp1ementl1
Re~dlll Inv.stlgltlon Report Tlbles
for CDMp1.t. list of orglnlc and
Inorglnlc contl.lnlnts Ind their
concentrations.
@
0 100
'0
SCAl( IN HET
FIGURE 1-8
ORGANIC CONTAMINATION I
SHALLOW AQUIFER
rU'fnf', UlYAIE YAIIO '''I
-------
, '\ .. .0 ~ J ~
":-'" :\ ...,' ,.". / j
-4" \\~'\'~~'" .-;\.~E:~Fr~''--; / V~
"'->""\.. '-"'I: ~[~1 ~.-. OM".-9 "'" ~f\\
SPill ARfA , . ~
~~~~::::ethan. ~~~ /<:.,~ GR:Vn DH'V: \, i ';
Vinyl Chlorld. 4 "BMW'~ / ',AND PAA'UNO, ',I \
l,l,4-Trlchlorobenlln. 3 .~ ' / - " .-- ;I' I
Aroclor-llliO 7.4 ... " CLACIAL TILL:
Chlorobenzen. 9 OMW-~ '
/
-------
ROD DECISION SUMMARY
Pinette's salvage Yard
page 9
contaminants associated with the site.
Twenty-six (26) contaminants of concern, as listed in Table 1-1,
were selected for evaluation in the PHE. These contaminants
constitute a representative subset of the contaminants identified
at the site during the Supplemental RI. The 26 contaminants were
selected to represent potential onsite hazards based on toxicity,
concentration, frequency of detection, and mobility and
persistence in the environment.
Potential human health effects associated with the contaminants
of concern in the surface and subsurface soils (both north and
south of Gardner Creek Road) and the onsite groundwater were
estimated quantitatively through the development of several
hypothetical exposure scenarios. Incremental lifetime cancer
risks and a measure of the potential for noncarcinogenic adverse
health effects were estimated for each of the various exposure
scenarios developed for the site. Exposure scenarios were
developed to reflect the potential for exposure to hazardous
substances based on the characteristic uses and location of the
site. Factors of special note that are reflected in the Public
Health Evaluation are that the site is located within an area of
both residential/agricultural uses, the contaminated areas are
unrestricted to either human or environmental receptors, and
potable groundwater in the area of the site is obtained through
private wells.
As su~~arized from the information shown in Table 1-2, the
potential human health risks associated with the PSY site are as
follows:
o frequent human contact with and incidental ingestion of
soils contaminated with PCBs may be associated with an
increased cancer risk over a lifetime (70-years) of exposure
(especially under the maximum plausible exposure case) i and
o an increased cancer risk and/or other adverse human health
effects may be posed in the future if onsite groundwater,
left untreated, were used as a drinking water source over an
individual's lifetime.
Additionally, an approximation of the extent of environmental
impacts due to potential exposures by environmental receptors in
the area of the PSY site was performed during the SRI. The major
conclusion from this assessment was as follows:
o environmental risks to terrestrial wildlife (such as birds
and mammals) may exist from exposure to PCB-contaminated
-------
Page 9A
TABLE 1-1
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN
PINETTE'S SALVAGE YARD SITE
FEASIBILITY STUDY REPORT
Chemical Soil Sediment Ground Water
~:
Aroclor-1260 X X X
Chlorinated Benzenes:
Chlorobenzene X X
l,2-Dichlorobenzene X X
l,3-Dichlorobenzene X X
l,4-Dichlorobenzene X X
1;2,4-Trichlorobenzene X X
Mononuclear Aromatic Hydrocarbons:
Benzene X
Toluene X X
HaloQenated Aliohatic Hydrocarbons:
Chloromethane X
Methylene chloride X
Chloroethane X
Ketones:
Acetone X X X
2-Butanone X
Polynuclear Aromatic HvdrocarboB1:
Total noncarcinogenic PAHsa X Xd
Total carcinogenic PAHsa XC
Phthalate Esters:
bis(2-Ethylhexy1}phthalate X X
Di-n-octylphthalate X
Di-n-butylphthalate X X
Pesticides:
4,4'-000 X
4,4'-DOE X
4,4'-00T X
Metals:
Antimony X
Arsenic X X
Beryllium X
Chromium X
Lead X X
a Individual PAHs are listed as carcinogenic or noncarcinogenic according to
IARC (1983)
b Benzo(g,h,i)perylene, fluoranthene, phenthrene, pyrene.
c Benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,
d benzo(k)fluoranthene, chrysene, indeno(1,2,3-c,d)pyrene.
-------
TABLE 1-2
SUMMARY OF POTENTIAL HUMAN HEALTH RISKS
PINETTE'S SALVAGE YARD SITE
FEASIBILITY STUDY REPORT
Upperbound Excess Indexb Chemicals Contributing to
lifetime Cancer Riska Ifazard Maximum Cancer Hazard
Risk Index
Exposure Pathway Average Maximum Average Maximum (>10-7) (>1.0)
Present Site and land Use Conditions:
Contact w1th Ons1te Surface 5xlO-8 lxlO-4 lxIO-3 9xlO-2 PCBs (1.0xI0-4)
Soil by Workers PAHs (1.2xlO-6)
Arsenic (4.1xIO-6)
Contact with Surface Soil 3xIO-7 6xIO-5 4xIO-3 lxlO-1 PCBs (S.9xIO-5)
North of Gardiner Creek Road PAHs (7.0xIO-7)
by Children Arsenic (l.3xIO-6)
Contact with Surface S011 2xlO-7 lx10-5 h10-3 3xlO-2 PCBs (7.7xI0-6)
South of Gardiner Creek Road Arsenic (2.1xIO-6)
by Children
Inhalation of Volatilized 5xlO-9 5xIO-7 hIO-S lx10-4 PCBs (4.7xI0-7)
Organics by Dnsite Workers
Inhalation of Volatilized 4xIO-6 6xlO-6 5xlO-4 8xIO-4 peBs (S.3xlO-6)
Organics by Nearby Residents PAHs (1.8xIO-7)
Inhalation of Fugitive Ousts 4xlO-I4 2xIO-I2 NC Ne
by Onsite Workers
Inhalation of Fugitive Ousts 2xIO-13 4xlO-12 NC NC
by Nearby Residents
"Q
III
OQ
III
\0
-------
Table
Page 2
1-2
Exposure Pathway
Average
Maximum
Average
Maximum
Chemicals Contributing to
Maximum Cancer Hazard
Risk Index
(>10-7) (>1.0)
Upperbound Excess
lifetime Cancer Riska
Hazard Indexb
Future Site and Land Use Conditions:
Contact with Surface Soil by 3x10-6 Sxl0-4 6x10-3 IxlO-1 PCBs (4 .4xlO-4)
Future Onsite Residents PAHs (S.7xlO-6)
Arsenic (2.OxlO-S)
Ingestion of Ground Water 2x10-4 SxlO-3 3xlO-1 2 PCBs (S.lxIO-3\
from the Shallow Aquifer DCB (S.6xlO-5)
TCB (1.4)
Ingestion of Ground Water NC 7x10-2 2xlO-1 4xlO-1 PCBs (6.6xIO-2)
from the Deep Aquifer DCB (1.7xlO-S)
Ingestion of Ground Water NC ZxIO-3 NC IxlO-1 PCBs (1.4xIO-3)
from the Bedrock Aquifer Benzene (2.~XIO-4)
CM (6.3xlO- )
Contact with Sediment 7x10-8 lxlO-6 2x10-3 2xlO-2 PCBs (S.3xlO-7)
from the Eastern Onsite Pond Arsenic (6.8xIO-7)
by Children
Contact with Sediment from 4x10-7 lxlO-5 6x10-3 7xlO-2 PCBs (2 .6xlO-6)
the Drainage Swa1e by PAHs (2.8xI0-6)
Children Arsenic (7.5xI0-6)
O'd
Contact with Sediment from 2x10-7 6x10-6 5x10-3 5xlO-2 PCBs (1. 4xl 0-6) II>
00
the Breakout Area by PAHs (3.0xlO-6) AI
\0
-------
Table
Page 3
1-2
Upperbound Excess
lifetime Cancer Riska
Uazard Indexb
Exposure Pathway
Average
Maximum
Average
Maximum
Chemicals Contributing to .
Maximum Cancer Hazard
Risk Index
(>10-7) (~1.0)
Contact with Sediment from
the Western Ons1te Pond
by Children
NC
HC
NC
3xlO-6
a
The upperbound excess lifetime cancer risk represents the additional probability that an individual may
develop cancer over a lO-year lifetime as a result of the exposure conditions evaluated.
The hazard index indicates whether or not exposures to mixtllre~ of noncarctnogentc chemicals may result 1n
adverse health effects. A hazard index less than one indi t adverse human health effects are
unlikely to occur.
b
DCB - 1,4-dichlorobenzene
TCB - 1.2,4-trichlorobenzene
CM - chloromethane
NC - not calculated
"0
PI
OQ
(1)
\0
-------
ROD DECISION SUMMARY
Pinette's salvage Yard
page 10
A more complete discussion of the potential human health risks
and enviro~mental impacts from the PSY site can be found in
section 6.0, Public Health Evaluation, of the Supplemental
Remedial Investigation report (Ebasco, 1989a).
VII.
DOCUMENTATION OP NO SIGNIPICANT CHANGES
EPA adopted a Proposed Plan (preferred alternative) for
remediation of the PSY site on March 8, 1989. No significant
changes have been made to the selected alternative since that
time based on public comments.
VIII.
DEVELOPMENT AND SCREENING OF ALTERNATIVES
A.
statutory Requirements/Response objectives
Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response to
releases of hazardous substances were conducted in accordance
with CERCLA as enacted in 1980 and the revised National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) ,
40 CFR Part 300 (1988), promulgated in the Federal Register on
November 20, 1985. Although EPA proposed revisions on December
21, 1988 to the NCP to reflect SARA, until those proposed
revisions are finalized, the procedures and standards for
responding to releases of hazardous substances, pollutants and
contaminants shall be in accordance with section 121 of CERCLA
and to the maximum extent practicable, the current NCP.
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
relevant and appropriate environmental standards established
under federal and state environmental laws unless a statutory
waiver is invoked; a requirement that EPA select a remedial
action that is cost-effective and that utilizes permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and a
statutory preference for re~edies that pe~anently and
significantly reduce the toxicity, mobility, or volume
hazardous substances over remedies that do not achieve
results through treatment. Response alternatives were
to be consistent with th~se Congressional mandates.
of
such
-------
ROD DECISION SUMMARY
Pinette's Salvage Yard
page 11
A number of potential exposure pathways were analyzed for risk
and threats to public health and the environment in the Public
Health Evaluation for the PSY site. Guidelines in the Superfund
Public Health Evaluation Manual (EPA, 1986) regarding development
of risk analyses for remedial alternatives were used to assist
EPA in the development of response actions. As a result of these
assessments, remedial response objectives were developed to
mitigate existing and future threats to public health and the
environment. These response objectives are:
o provide adequate protectiveness to human health against
risks associated with direct contact or incidental ingestion
of contaminants in the surface and subsurface
soils/sediments, and from current and potential future
migration of contaminants from soils to groundwater,
sediments and surface water:
o provide adequate protectiveness to human health from
potential risks associated with inhalation of VOCs and PCBs
potentially released from the site:
o provide adequate protectiveness to human health from risks
associated with potential future consumption of groundwater;
o provide adequate protectiveness to the environment,
including plants and terrestrial and aquatic wildlife, from
potential adverse impacts associated with contact with
contaminated surface soils/sediments, and from current and
future distribution of contaminants migrating in
groundwater, sediments, and surface water:
o ensure adequate protection of groundwater, air, and
surface water from the continued release of contaminants
from soils/sediments; and
o comply with chemical-specific, location-specific, and
action-specific ARARs and other guidance for surface and
subsurface soils, groundwater, air, and surface water for
both existing and future site conditions.
B.
Technology and Alternative Development and Screening
CERCLA, the NCP, and EPA guidance documents including, the
"Guidance on Feasibility Studies Under CERCLA" dated June 1985,
the "Interim Guidance on Superfund Selection of Remedy" [EPA
Office of Solid Waste and Emergency Response (OSWER)], Directive'
No. 9355.0-19 (December 24, 1986), and the Interim Final
"Guidance for Conducting RIs and FSs under CERCLA," OSWER
Directive No. 9355.3-01," set forth the process by which remedial
-------
ROD DECltION SUMMARY
pinette's salvage Yard
page 12
requirements and quidance documents, treatment alternatives were
developed for the site ranging from an alternative that, to the
degree possible, would eliminate the need for long-term
management (including monitoring) at the site to alternatives
involving treatment that would reduce the toxicity, mobility, or
volume of hazardous substances as theiT principal element. In
addition to the range of treatment alternatives, a containment
option involving little or no treatment and a no-action
alternative were developed in accordance with section 121 of
CERCLA.
section 121(b) (1) of CERCLA presents several factors that, at a
minimum, EPA is required to consider in its assessment of
alternatives" In addition to these factors and the other
statutory directives of Section 121 of CERCLA, the evaluation and
selection process was guided by the EPA document "Additional
Interim Guidance for FY'87 Records of Decision" dated July 24,
1987. This document provides direction on the consideration of
SARA cleanup standards and sets forth nine factors that EPA
should consider in its evaluation and selection of remedial
actions. The nine factors are:
1.
Overall Protection of Human Health and the Environment.
2.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
3 .
Long-term Effectiveness and Permanence.
4 .
Reduction of Toxicity, Mobility or Volume.
5.
Short-term Effectiveness.
6.
Implementability.
7.
Cost.
8.
state Acceptance.
community Acceptance.
9.
Chapter 4.0 of the Draft Final Feasibility study identified,
assessed and screened technologies based on their effectiveness
and implementability at the PSY site. These technologies were
combined into source control (SC) and management of migration
(MM) alternatives. Chapter 5.0 in the Draft Final Feasibility
Study presented the remedial alternatives developed by combining
-------
ROD DECISION SUMMARY
Pinette's Salvage Yard
page 13
into the categories required by OSWER Directive No. 9355.0-19 (as
stated above). An initial screening of these remedial
alternatives was conducted in Chapter 6.0 of the Draft Final
Feasibility study to narrow the number of potential remedial
alternatives for further detailed analysis while preserving a
range of options. Each remedial alternative was then evaluated
in detail in Chapter 7.0 of the Draft Final Feasibility study
based upon the nine criteria also identified above.
In summary, of the twelve (12) source control and management of
migration remedial alternatives screened in Chapter 6.0, ten (10)
were retained from this screening process. Table 1-3 identifies
these 10 individual remedial alternatives, and the resulting
sixteen (16) overall site remediation alternatives that were
retained for detailed analysis.
IX.
DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE ANALYSIS
OF ALTERNATIVES
This section presents a narrative summary and brief evaluation of
each alternative according to the evaluation criteria described
above. A detailed comparative assessment of each remedial
alternative can be found in Chapter 8.0 OI the Draft Final
Feasibility Study.
A.
Source Control (SC) Alternatives Analyzed
The source control alternatives analyzed for the site include a
minimal no-action alternative (SC-l): two containment
alternatives which primarily contain the contamination by capping
or landfilling (SC-2 and SC-4); and four treatment alternatives
which treat the contamination by either chemical or thermal
treatment methods (SC-5, SC-7, SC-S, SC-9). It should be noted
that the approximate present worth costs stated below are based
upon a 5 pprn PCB soil cleanup level and the soil cleanup levels
associated with protection of groundwater at the site.
Furthermore, these costs are solely for the corresponding
technology identified (i.e., no combination
technologies/alternatives are provided herein).
SC-1
Minimal No-Action
Approximate Present Worth Cost:
$654,000.
This alternative would involve no remedial action of the
contaminated soils at the site. However, this alternative would
entail installing a fence and posting warning signs around areas
of the contaminated soils, obtaining land use restrictions, and
conducting public education programs to inform the public about
-------
Page 13A
TABLE 1-3
MERGING OF SC AND MM ALTERNATIVES
PINETTE'S SALVAGE YARD SITE
FEASIBILITY STUDY REPORT
MM ALTERNATIVES
MM-l MM-Z MM-3
Expedited
Hi nimal Ground Water Ground Water
SC ALTERNATIVES No-Action Coll ect i on Collection
SC-l Minimal No-Action SR-l NCI NCI
SC-2 Capping with Slurry Wall SR-2-1 NCZ NCZ
SC-4 Offsite Landfill SR-4-1 SR-4-Z SR-4-3
SC-5 Incineration3 SR-5-1 SR-5-2 SR-5-3
SC-7 Solvent Extraction SR-7-1 SR-7-3 SR-7-3
SC-8 Dechlorination .5R-8-1 SR-8-Z SR-8-3
SC-9 In Situ Vitrification SR-9-1 SR-9-2 NC4
SR:
Site Remediation Alternative
NC: lhis combination of SC and MM aJternatives is Not Compatible - see
footnotes belo~.
1
SC Alternatives 4, 5, 7, 8 and 9 also include PCB action levels of 1,
2, lQ and 50 ppm for contaminated solids.
Ground water collection and treatment without a complementary SC component
would not provide an adeGuat~ level of protection.
NOTE:
2
As capping is a full contain~~nt alternative, ground water extraction and
treatment is considered not ccm~~t~~~ due to t~e limited amount of
horizontal inflow and vertical percolatioo.
3
4
Onsite for 1, 2 and 10 ppm action levels, offsite for 50 ppm action level.
Alternative MM-3 is not compatible with Alternati.ve SC-9 due to the
presence of a vitrified mass where the two additional trenches in MM-3
-------
ROD DECISION SUMMARY
Pinette's salvage Yard
page 14
long term monitoring program would be instituted through the
installati~n of additional monitoring wells; groundwater, surface
water and sediment sampling; and conducting a review of site
conditions every five years.
This alternative would not provide overall protection of human
health and the environment at the site, and would not comply with
ARARs. Additionally, this alternative does not use treatment as
a principal element, and consequently, there would be no
reduction in the toxicity, mobility, or volume of contaminants
present on the site.
8C-2
CaDDinq with Slurry Wall
Approximate Present Worth Cost:
$1,140,000.
This alternative would involve placing an impermeable cap over
the contaminated soils and constructing a slurry wall extending
into the low permeability clay layer underlying the site. The
cap would consist of approximately four inches of asphalt with
approximately 12 inches of stone underneath the asphalt.
Included within the stone layer would be a single layer of
synthetic waterproof material. In order to minimize the areal
extent of the cap, areas of contamination that are less than
approximately two feet thick would be consolidated under the area
to be capped.
In addition to the cap, a two-foot thick slurry wall extending to
a depth of approximately 8 to 10 feet below the ground surface
would be placed around the perimeter of the cap. The slurry wall
would be installed to redirect groundwater flow away from the
contaminated soils underlying the cap. Additionally, EPA would
recommend establishing land use restrictions; fence and post
warning signs at the site: conduct public education programs:
install additional groundwater monitoring wells; monitor
groundwater, surface water and sediment over the long term; and
conduct a review of site conditions every five years.
The goal of this alternative is to reduce the potential risks
associated with direct contact and/or incidental ingestion of the
contaminated soils, and to reduce the mobility of these
contaminants by isolating and minimizing the amount of
precipitation that could infiltrate into the contaminated soils.
However, since no treatment of the contaminated soils would be
employed under this alternative, no reduction in the toxicity or
volume of contaminants would be achieved. This alternative would
comply with ARARs, but the cap design would not be consistent
with the current RCRA cap design guidance, although it does
provide a similar degree of protectiveness at less cost.
Finally, although this alternative uses readily available
-------
.
ROD DECISION SUMMARY
pinette's Salvage Yard
page 15
not a permanent remedy: this would require long term monitoring
and maintenance, and the potential exists for additional
replacement costs should the cap leak or fail.
SC-4
Off-site Landfill
Approximate Present Worth Cost:
$2,200,000.
This alternative would involve excavating and dewatering the
contaminated soils, and then disposing of the soils at RCRA-
and/or TSCA-approved off-site hazardous waste landfi11(s).
During the excavation activities, temporary fences would be
constructed to reduce access to these excavated areas. The
excavated areas would be filled with clean soil, regraded, and
revegetated to return these areas to their original condition.
EPA would also conduct public education programs: install
additional groundwater monitoring wells: and monitor groundwater,
surface water and sediment for several months following
completion of this alternative.
The goal of this alternative is similar to that of SC-2, except
that the contaminated soils would be removed from the site and
placed in an off-site landfill. This alternative' would meet
ARARs and, since excavation of contaminated soils is a key
component of this alternative, the potential for continued
migration of contaminants to the groundwater at the site would be
significantly reduced. However, this alternative may pose
potential short-term risks to the public health and the
environment during excavation and transportation to the landfill
location(s), and potential long-term risks at the landfill(s)
themselves. In addition, no reduction in the toxicity, mobility
or volume of wastes would be realized through this alternative
since no treatment is employed. Furthermore, off-site disposal
without prior treatment to the maximum extent practicable is not
a remedial alternative favored by CERCLA.
SC-5
Incineration
Approximate Present Worth Cost:
$3,540,000.
This alternative would involve the excavation of contaminated
soils, and the thermal treatment of these soils either on-site or
off-site. [Note~ see section x, THE SELECTED REMEDY, for a
discussion of the off-site incineration alternative; costs shown
above are solely for on-site incineration). Thermal treatment of
contaminated soils would involve extremely high temperatures
which would destroy approximately 99.9999% of the contaminated
organic chemicals in the soil. Following excavation at the site,
the backfilling, regrading, revegetation and additional
recommended activities discussed above for SC-4 would be
-------
ROD DECISION SUMMARY
Pinette's Salvage Yard
page 16 .
This alternative would achieve the goals of reducing the
principal threats identified at the site by treating and
permanently destroying the contaminated soils and thereby
significantly reducing the toxicity, mobility and volume of these
soils. This alternative would also comply with all ARARs,
provide for long-term permanence, and be protective of human
health and the environment both in the soils and groundwater.
However, this alternative may involve certain short-term risks
from the excavation of soils and the ensuing increase in traffic
in the area which would require engineering/institutional
solutions to prevent the release of contaminants from the site.
SC-7
On-Site Solvent Extraction
Approximate Present Worth Cost:
$1,600,000.
This alternative is a component of the overall source control
remedial alternative selected for the site. Refer to Section X,
THE SELECTED REMEDY, for a discussion of this alternative.
8C-8
On-site Dechlorination
Approximate Present Worth Cost:
$2,375,000.
This alternative would involve excavating the contaminated soils
and mixing them in a stainless steel reaction vessel with a
combination of chemicals forming a reagent, KPEG (potassium
polyethylene glycol), which is capable of detoxifying PCBs
through the removal of chlorine atoms from the PCB molecule. The
mixture is then heated to increase the rate of reaction of the
PCBs, and to drive off the volatile organics (VOCs) from the
soil. The VOC vapors generated are then captured with carbon
filters before release to the atmosphere. Decontaminated soils
resulting from this process would then be placed back on-site
within the original excavated areas, and the contaminated reagent
disposed of off-site at a licensed incineration facility.
The goal of this alternative would be to provide protection of
public health and the environment by detoxifying the principal
threat at the site posed by direct contact/incidental ingestion
of PCB-contaminated soils, while complying with ARARs. In
addition, dechlorination would provide for a significant
reduction in the toxicity, mobility and volume of contaminants
and would incorporate an alternative treatment technology, as
preferred by CERCLA. However, implementation of the
dechlorination process would require the construction of a mobile
treatment unit for which no fUll-scale, demonstrated unit
currently exists. Finally, the reliability and long-term
effectiveness of this innovative treatment technology includes,
at present, some degree of uncertainty since only small-scale
laboratory and pilot-scale tests have been performed with
-------
ROD DECISION SUMMARY
pinette's salvage Yard
page 17
KPEG-reagent and/or
soil. Furthermore,
would be similar to
SC-S. .
biphenyl compounds remaining in the treated
short-term risks from excavation of soils
those discussed for alternatives SC-4 and
SC-9
In-Situ Vitrification
Approximate Present Worth Cost:
$2,780,000.
This alternative would involve excavating and consolidating a
small quantity of contaminated soils on-site, and then placing
electrodes into the soils to be treated (vitrified). A high
power electrical current "would be passed from the electrodes to
the soil, resulting in the melting and transformation of the soil
into a glass-like material. This process would destroy and/or
volatilize the organic contaminants in the soil, and would
bind/fuse any inorganics present into the solid matrix. Any VOCs
emitted from the process would be captured at the ground surface
through the placement of a stainless steel hood over the area
being treated. These vapors would then be passed through a
treatment system which would involve air pollution control
equipment such as scrubbers and filters. Following treatment,
EPA would also conduct activities very similar to those described
under SC-2 above regarding land use restrictions, etc. .
If successfully employed, this alternative would meet all ARARs
and would be protective of human health and the environment since
the organic contaminants in the soil would be destroyed.
Additionally, the toxicity and mobility of these organics would
be significantly reduced while, at the same time, the final
volume of material treated would be reduced by approximately 30
to 40 percent; therefore, the area undergoing vitrification would
require backfilling and regrading with clean soil. This
alternative, however, while utilizing an alternative treatment
technology as preferred by CERCLA, has only been demonstrated in
the treatment of PCB-contaminated materials on one occasion
during a small-scale laboratory test. Therefore, the
implementability and long-term effectiveness of this technology
at full-scale includes some degree of uncertainty which would
require extensive additional laboratory and on-site testing.
Finally, it is possible that due to the limited number of full-
scale, commercially-available units currently operational at this
time, their availability may pose a problem during implementation
of this alternative.
B.
Management of Migration (MH) Alternatives Analyzed
Management of migration alternatives address contaminants that
have migrated from the original source of contamination. At the
Pinette's Salvage Yard (PSY) site, organic contaminants have
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ROD DECISION SUMMARY
Pinette's salvage Yard
page 18'
into the on-site groundwater. However, this contamination does
not impact the groundwater past the site boundary. The
management of migration alternatives evaluated for the PSY site
include a minimal no-action with monitoring alternative (MM-l):
and two active groundwater collection and treatment alternatives
(MM-2 and MM-3).
Based on the distribution of the organic contaminants identified
at the PSY site, it is apparent that the benzene and chlorinated
benzene compounds are slowly migrating with the groundwater
towards the south-southeast from the site. However, the
distribution of PCBs detected in the groundwater is limited to
the approximate spill area. This is principally due to the
relative immobility of PCBs in groundwater, since PCBs tend to
adhere tightly to soil particles.
MH-1
Minimal No-Action
Approximate Present Worth Cost:
$604,000.
This alternative would consist of land use (deed) restrictions
and the recommended imposition of institutional controls to
completely restrict the use of groundwater at the site.
Additionally, public education programs would be established to
inform the public about the hazards present at the site, and a
long-term monitoring program would be instituted to evaluate
changes in contaminant concentrations in groundwater, surface
water and sediments. The site would also be re-evaluated every
five years to monitor and assess the need to implement additional
re~edial actions at the site.
This alternative would be easily implementable but would not
provide overall protection of human health and the environment or
attain AR~s (or provide grounds for invoking a waiver) at the
site. However, over the long-term (likely greater than 10
years), some of the principal threats posed by the contaminated
groundwater, excluding that associated with PCBs, would likely
dissipate as natural attenuation dilutes and disperses the more
volatile contaminants found in the on-site groundwater.
Additionally, this alternative would not reduce the toxicity,
mobility or volume of contaminants since no treatment is
involved.
MH-2 Approximate Present Worth Cost:
Groundwater Collection and Treatment $1,137,000.
This alternative would consist of the installation of collection
trench(es) located in the shallow aquifer, if necessary, and
extraction welles) located in the deep aquifer on the site. The
collected groundwater would then be pumped through a treatment
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ROD DECISION SUMMARY
pinette's Salvage Yard
page 19
suspended/colloidal particulate matter, and a carbon adsorption
unit (using activated carbon) to treat/remove the organic
contaminants found in the on-site groundwater. All treated
groundwater would be discharged back into the shallow aquifer
through the use of shallow recharge trenches. The entire system
should extract approximately three to six gallons per minute for
approximately five years.
This alternative would consist of components similar to MM-l,
such as deed restrictions as described above. However, this
alternative would involve treating the contaminated groundwater
to the maximum extent practicable, and should result in achieving
the response objectives within a shorter time period.
Additionally, a significant reduction in the toxicity, mobility
and volume of several of the organic contaminants in the
groundwater is anticipated using easily implementable materials
and services involved with this alternative. However, a waiver
from compliance with one state ARAR, the Maine Maximum Exposure
Guideline (MEG) for PCBs, would likely need to be invoked due to
the technical impracticability from an engineering perspective of
collecting the particulate-bound PCBs from the groundwater to a
level that meets state drinking water standards. (See section X
(8) (2) of the ROD for a discussion of this issue.)
MH-3 Approximate Present Worth Cost:
Expedited Groundwater Collection and Treatment $947,000.
This alternative is a component of the overall remedial
alternative selected for the site. Refer to section X, THE
SELECTED REMEDY, for a discussion of this alternative.
x.
THE SELECTED REMEDY
The selected remedial action for the PSY site is a comprehensive
approach for overall site remediation which involves combining
components of different source control alternatives (SC-5 and
SC-7) and a management of migration alternative (MM-3). This
comprehensive approach is necessary in order to achieve all the
response objectives established for site remediation and to meet
legal requirements.
A.
Description of the Selected Remedy
The following discussion presents the likely sequence of events
for the implementation of the selected remedy:
Fencinq: The first part of the selected remedy will involve
temporarily restricting access to the site during all site
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,
ROD DECISION SUMY~Y
Pinette's Salvage Yard
page 20
6-foot high chainlink fence topped with barbed wire around the
perimeter of the contaminated areas of the site, and where
support equipment/facilities are to be located in order to
perform the selected remedy. The fence will be equipped with
appropriately sized gates for controlled access, and warning
signs posted at 100-foot intervals along the fence.
Soil Excavation and Treatment: This source control component
comprises the majority of the selected remedy. This component
consists of excavating approximately 2,000 to 2,200 cubic yards
of PCB/other organic chemically-contaminated soils and treating
these soils either off-site through incineration or on-site using
solvent extraction.
Prior to the excavation of these contaminated soils, precautions
will be used to ensure proper drainage of storm water away from
the site. Erosion control in the form of silt fences will be
installed to prevent uncontrolled movement of contaminated,
excavated soils. Following the installation of these
sediment/erosion control structures, clearing and grubbing will
be performed on the vegetated portions of the site (especially
south of Gardner Creek Road).
Excavation will then proceed initially on those soils presently
known to be contaminated with PCBs at concentrations greater than
50 parts per million (ppm). These soils (approximately 300 cubic
yards) will then be dewatered using draining beds installed on
the site. Following this dewatering step, these soils will be
processed (as needed) to reduce the maximum particle size
reqJired by the remedial incineration contractor (typically 1 to
1-1/2 inches). These soils will then be loaded into either 30
gallon fiberboard drums or larger rolloff containers. Selected
samples will be taken of these soils to ensure that all
appropriate regulatory requirements are met prior to
decontaminating the trucks that will be used to transport these
soils to the off-site, TSCA-permitted incineration facility.
Excavation will then resume in order to remove those soils
currently known to be containing between 5 and 50 ppm PCBs
(approximately 1,300-1,400 cubic yards), and those soils
contaminated with other organic chemicals (benzene,
chlorobenzene, etc.) in excess of the groundwater protection
cleanup levels (approximately 400-500 cubic yards). These soils
will be treated on the PSY site using a solvent extraction
technology which involves the use of a solvent to extract the
PCBs and other organic chemicals from the soil. An on-site
mobile laboratory will be utilized during this entire process to
determine the contaminant concentrations in both the soil fed to
the solvent extraction unit and the solid residue leaving the
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.
ROD DECISION SUMMARY
pinette's salvage Yard
page 21
liquid PCBs and other organic chemicals extracted from the soils
by this process will be collected and transported off-site to a
TSCA-licensed incineration facility. Residual water from the
process will be pumped into storage tanks for treatment by a
portable carbon unit located on-site or other acceptable means of
treatment. During on-site solvent extraction, exhaust gases from
the process will be treated by air pollution control devices to
ensure that health and safety and air quality requirements are
being met.
Prior to full-scale implementation of the solvent extraction
process on the site, a pi:lot test will be conducted to establish
the optimum operational settings for the extraction of those
contaminants specific to the PSY site, and to verify that soil
residues from the process are nonhazardous. After the pilot
studies determine the optimum treatment scheme, full-scale
operation will proceed.
Additionally, removal of PCB-contaminated soils containing
greater than 1 ppm (but less than 5 ppm) to a minimum depth of 10
inches will occur at the site. This volume of soil
(approximately 500 cubic yards) will be moved to the areas
resulting from the excavation of the original 2,000-2,200 cubic
yards undergoing treatment as described above. These soils will
be consolidated into the on-site excavation prior to the likely
replacement of those nonhazardous soil residues resulting from
the on-site solvent extraction process. All site areas,
including those undergoing this additional consolidation
activity, will be covered with new native soil containing less 1
ppm PCBs, regraded, and revegetated in order to return each area
to its original condition.
Manaqement of Miqration: The management of migration portion of
the selected remedy involves the utilization of groundwater
collection and treatment following contaminated soil excavation,
as described above. This groundwater system will entail the
construction of one or more shallow interceptor trenches and one
or more deep extraction wells to collect the contaminated on-site
groundwater. Collected groundwater will then be pumped through a
granular filter to remove suspended/colloidal particulate matter
in the groundwater. .
Following this preliminary filtration step, the groundwater will
be treated by carbon adsorption, which uses activated carbon to
remove the organic contaminants found in the groundwater. All
treated groundwater will then be discharged back into the shallow
aquifer through the use of recharge trenches. The entire aquifer
collection system will collect approximately eight to sixteen
gallons per minute for approximately two years. Note that this
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ROD DECISION SUMMARY
Pinette's Salvage Yard
page 22
considerable detail during the design of the entire groundwater
collection and treatment system.
Institutional Controls/Environmental Monitorinq: In addition to
temporarily restricting access to the site during site
remediation, the selected remedy includes (at a minimum): (1) the
removal from the site of any junk vehicles/debris hindering site
activities, (2) establishing institutional controls, and
providing long-term monitoring of the salvage yard to detect
potential future contaminant releases to the environment, (3)
implementing public education programs (public meetings and
presentations) to increase public awareness about the hazards at
the site, (4) installing additional monitoring wells and
monitoring groundwater, surface water and sediments. To the
extent required by law, EPA will review the site at least once
every five years after the initiation of remedial action at the
site if any hazardous substances, pollutants or contaminants
remain at the site to assure that the remedial action continues
to protect human health and the environment. EPA will also
evaluate risk posed by the site at the completion of the remedial
action (i.e., before the site is proposed for deletion from the
NPL). Finally, if particulate-bound PCBs are determined not to
be completely collected to meet the State ARAR (MEG) for drinking
water (see Section X (B) (2) of the ROD), an institutional control
would be recommended for the complete prohibition on the use of
the on-site groundwater for drinking water purposes.
B.
Rationale for selection/Cleanup Goals
The rationale for choosing the selected alternative is based on
the assessment of each criteria listed in the evaluation of
alternatives section of this document. In accordance with
Section 121 of CERCLA, to be considered as a candidate for
selection in the ROD, the alternative must have been found to be
protective of human health and the environment and able to attain
ARARs unless a waiver can be i~voked. In assessing the
alternatives that met these statutory requirements, EPA focused
on the remaining evaluation criteria, including, short term
effectiveness, long term effectiveness, impleluentability, use of
treatment to permanently reduce the toxicity, mobility, or
volume, and cost.
EPA also considered nontechnical factors that affect the
implementability of a remedy, such as state and community
acceptance. Based upon this assessment, taking into account the
statutory preferences of CERCLA, EPA selected the remedial
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ROD DECISION SUMMARY
pinette's Salvage Yard
page 23
1.s.
Source Control
The source control portion of the remedial action is designed
primarily to address the soil contamination and, to the extent
technically practicable, the groundwater contamination at the
site by excavating and treating the source areas of
contamination. This source control remedy will, in turn, prevent
potential direct human and environmental contact with
contaminated soils at the site and prevent or minimize future
migration of contamination from the contaminated soils to the
groundwater.
a. 80i1 Target Cleanup Levels
PCBs are the most significant components of the contaminated soil
at the PSY site, and they represent 90 to 95% of the
current/future excess lifetime cancer risk to humans. Therefore,
EPA has established target cleanup goals for PCBs at this site
based upon a future, residential-use exposure scenario for humans
involving direct contact and incidental ingestion of contaminated
soils. The assumptions that were used to develop EPA's site-
specific PCB cleanup goal for the PSY site are provided in
Attachment C to this ROD. The results of these exposure/risk
calculations indicate that a lifetime, future use, excess cancer
risk level of 1 X 10-5 (one in one hundred-thousand) corresponds
to a PCB target cleanup level of 6 ppm.
However, based upon c~ raised by the state of Maine DEP (in
consultation with thei: :-~nt of Human Services-DHS), the
ultimate soil target cleoI.~~ .evel for protection of public
health at the PSY site was determined to be no greater than 5 ppm
anywhere on the site. The state requested this slightly more
stringent target cleanup level because the site-specific risk
assessment conducted by the DHS, using more conservative exposure
assumptions than EPA's, indicated that a greater degree of
cleanup was necessary at this site to satisfy State of Maine
policy and gain state acceptance.
Excavation of soils to this target cleanup level and treatment by
off-site incineration and on-site solvent extraction to this
level, as described above, will significantly reduce the risks
associated with the site to a level that is protective of public
health. Additionally, off-site incineration of those PCB-
contaminated soils greater than 50 ppm, and on-site solvent
extraction of those PCB-contaminated soils between 5 and 50 ppm,
will satisfy all ARARs, provide a permanent remedy favored under
Section 121 of CERCLA, and ensure adequate protectiveness into
-------
ROD DECISION SUMMARY
Pinette's Salvage Yard
page 24.
Furthermore, in order to provide adequate protectiveness to the
environment, including plants and terrestrial/aquatic wildlife,
EPA (in consultation with the u.s. Department of the Interior,
Fish & Wildlife Service) determined that no soils containing
greater than 1 ppm PCBs should remain in surface soils where
contamination would be readily accessible to terrestrial
wildlife. Therefore, PCB-contaminated surface soils containing
greater than 1 ppm but less than 5 ppm located anywhere within
the top 10-inches of soil on the site will be moved into the
excavated areas described above. These soils will be placed into
the previous excavation prior to the likely replacement of the
solid nonhazardous residue generated from the on-site solvent
extraction process. All site areas, including those undergoing
this additional consolidation activity, will eventually be
covered with new soil containing less than 1 ppm PCBs and
revegetated. This approach will ensure that even if those soils
contaminated with between 1 and 5 ppm PCBs were ever disturbed by
potential future activities at the site, the PCB levels at the
surface will likely be less than 1 ppm due to mixing with clean
soil. This cleanup goal and approach is also consistent with the
TSCA PCB Spill Cleanup Policy (40 CFR 761 Subpart G) for
nonrestricted access areas.
Furthermore, soil cleanup levels for the PSY site were developed
(and verified for adequacy) based on the leaching potential of
contaminants from site soils into groundwater. This involved
calculating the concentrations in site soils required to achieve
groundwater target cleanup levels. The approach to developing a
list of =roundwater contaminant levels from which to derive soil
cleanup ~vels was to utilize regulatory criteria for individual
conta~i -ts. The EPA has determined that the Federal Maximum
Contam: .~ Levels (MCLs) ard/or the State of Maine's Maximum
Exposur. .:~idelines (MEGs) ~re the ARARs to be used for this site
to the E:~ent that they have been established for the individual
contaminants at the site.
Based on the results of the leaching model performed for the PSY
site, the following cleanup levels for contaminants in soils were
determined:
Contaminant
Soil Cleanup Leve: for Groundwater Protection
Benzene
Chlorobenzene
l,4-Dichlorobenzene
Chloromethane
l,2,4-Tri-
chlorobenzene
PCBs
260 ppb (unsaturated); 0.42 ppb (saturated)
12,000 ppb (unsaturated); 20 ppb (saturated)
26,000 ppb (unsaturated); 42 ppb (saturated)
30 ppb (unsaturated); 0.05 ppb (saturated)
4,836 ppm (unsaturated); 7.8 ppm (saturated)
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.
ROD DECISION SUMMARY
Pinette's salvage Yard
page 25
Additional details regarding the leaching model and these results
can be found in Chapter 3.0, Volume 1 of the Draft Final FS and
Appendix B, Volume II of the Draft Final FS.
In summary, specifically for those PCBs in soil at the PSY site,
the soil target cleanup level was determined to be 5 ppm, maximum
value based upon the future potential risks from direct contact
and incidental ingestion of soils rather than from the results
obtained from the leaching model for the protection of
groundwater at the site.
~
Manaaement of Miaration
The management of migration portion of the selected remedial
action is designed primarily to provide adequate protectiveness
to human health from increased cancer risk and/or other adverse
human health effects associated with potential future use of on-
site groundwater, if left untreated. This is especially
important since all residents living in the immediate vicinity of
the site use residential well water as a potable drinking water
source and no municipal water supply system currently serves
these residents. Additionally, the continued presence and/or
migration of the other organic contaminants in the on-site'
groundwater could potentially mobilize the relatively immobile
particulate-bound PCBs also present in the groundwater.
a. Groundwater Target Cleanup Levels
The evaluation of groundwater target cleanup levels focused on
the current level of groundwater contamination at the site, the
current and potential future-use of the groundwater, and the time
required to achieve the overall site remediation goals. The
Superfund Public Health Evaluation Manual, EPA's Groundwater
Protection Strat~1Y, and the state of Maine's Bureau of Water
Quality Control -ggulations aided in the development of
groundwater reme~iation target levels for the site.
Based on the contaminants found in the groundwater on the site,
and as discussed further in Section XI of the ROD, Statutory
Determinations, the following contaminants and their respective
MCL or State of Maine MEG were identified as appropriate
groundwater cleanup goals:
Contaminant
MCL/MEG
Benzene
1,4-Dichlorobenzene
Chlorobenzene
PCBs
5 ppb
27 ppb
47 ppb
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ROD DECISION SUMMARY
Pinette's Salvage Yard
page 26
Additionally, a groundwater target cleanup level for 1,2,4-
trichl~rob~nzene of 680 ppb was established based upon the
reference dose for this compound (2 X 10-2) such that possible
lifetime exposure to this level would not be expected to result
in any adverse human health effects. Finally, groundwater
cleanup goals were established for lead (5 ppb), based on the
currently proposed MCL for lead, and for chloromethane (10 ppb),
based upon the analytical detection limits of this compound in
water.
In summary, the groundwater target cleanup levels for the site
are considered protective of human health and the environment.
However, achievement of these goals, as well as compliance witt
all Federal and State ARARs, is considered unlikely at present
for the particulate-bound PCBs present in the groundwater.
Because the PCBs in the groundwater at the PSY site have been
found to be adsorbed onto soil particles, they are likely to be
difficult to collect for groundwater treatment. While EPA will
collect and treat as much of the PCBs as is technically feasible,
it may be impossible to collect enough particulate-bound PCBs in
order to reach the target cleanup goal. Therefore, in accordance
with Section 117(a) (2) of CERCLA, EPA is invoking a waiver from
compliance with the State of Maine Maximum Exposure Guideline for
PCBs of 0.5 ppb based on the technical impracticability from an
engineering perspective of attaining this level. This however,
does not render the selected alternative of expedited collection
and treatment of the groundwater ineffective, since several other
organics currently exceed ARARs and these organics are considered
more carcinogenic to humans than PCBs. In addition, treatment of
the other organics will aid in preventing and/or minimizing the
migration potential of the PCBs presently in the groundwater.
Furthermore, in evaluating the balancing criteria for the
selection of a remedy for this site, EPA considers the expedited
ground~ater collection and treatment alternative the most cost-
effective, while at the same time requiring the least amount of
time to attain the cleanup goals for those other organics in the
groundwater (except PCBs).
XI.
STATUTORY DETERMIN~TIONS
The remedial action selected for implementation at the Pinette's
Salvage Yard (PSY) site is consistent with CERCLA and, to the
extent practicable, the NCP. The selected remedy is protective
of human health and the environment and attains ARARs to the
extent technically practicable. The selected remedy also offers
the best combination of effectiveness, implementability, and cost
in comparison with the other alternatives that provide the same
level of protection. The selected remedy is consistent with
-------
ROD DECISION SUMMARY
pinette's salvage Yard
page 27
~
a permanent solution and for treatment which reduces the
toxicity, mobility, or volume as a principle element.
Additionally, the selected remedy utilizes alternative treatment
technologies to the maximum extent practicable.
A.
The Selected Remedy is Protective of Human Health and
the Environment
The selected remedy for the PSY site will permanently reduce the
risks presently posed to human health and the environment by the
contaminated soils and, to the maximum extent practicable, by
groundwater.
The soil cleanup levels to be attained through excavation and
treatment will reduce the risks associated with the soils to a
level protective of human health and the environment. The target
cleanup levels address the risks from direct contact and
incidental ingestion of contaminated soils. In addition,
treatment of the soils will also protect groundwater from
additional contamination by removing the sources of the
contamination. The Draft Final Feasibility study identified six
compounds in the soils requiring remediation: PCBs, benzene, 1,4-
dichlorobenzene, 1,2,4-trichlorobenzene, chloromethane, and
chlorobenzene. The selected remedy (incineration of soils
containing greater than 50 ppm PCBs and solvent extraction of the
remaining soils contaminated above target levels) will reduce the
risks associated with all six compounds to a level protective of
human health and the environment. This level is within the 10-4
to 10-7 cancer risk range that EPA has determined to be
protective of human health.
The groundwater target cleanup levels established for the site
are the Federal MCLs and/or Maine MEGs for benzene, 1,4-
dichlorobenzene, chlorobenzene, and lead, the Maine MEG for PCBs,
and risk-based or analytical detection limits for 1,2,4-
trichlorobenzene and chloromethane, respectively. EPA has
determined that the attainment of MCLs in groundwater at the site
is protective of human health and the environment. The MEG for
PCBs is not technologically attainable, but EPA is recommending
the use of institutional controls at the site to prevent
consumption of or other contact with the PCB-contaminated
groundwater. with these institutional controls in place, the
PCBs remaining in the groundwater at the site will not pose a
threat to the public health or environment. Nonetheless, five-
year reviews will be conducted at the site to ensure attainment
of the protective exposure levels.
The groundwater treatment method selected (expedited collection
and treatment) will reduce the concentrations of all
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ROD DECISION SUMMARY
Pinette's salvage Yard
page 28
cleanup levels. Removal of these organic contaminants in the
groundwater (excluding PCBs) will also reduce the potential for
mobilizing the current particulate-bound PCBs, thereby ensuring
that the PCBs will remain in on-site groundwater and that they
will not migrate to nearby surface waters or current and
potential sources of drinking water.
B.
The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and
appropriate Federal and state requirements that apply to the
site, with the possible exception of the state limitation on PCB
levels in drinking water (the Maine MEG). Since no technology
exists which can ensure collection of the particulate-bound PCBs
in order to meet the Maine MEG, EPA is invoking a waiver of this
ARAR on the ground that its attainment is technically
impracticable from an engineering standpoint. However, the
groundwater at the site will be treated for all organic
contaminants of concern, including PCBs to the degree that is
technically practicable.
Federal environmental laws which are applicable or relevant and
appropriate to the selected remedial action at the site are:
Resource Conservation and Recovery Act (RCRA)
Toxic Substances Control Act (TSCA)
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Clean Air Act (CAA)
Occupational Safety and Health Act (OSHA)
Table 2-1 lists potential chemical-specific Federal and State
ARARs and gives a brief synopsis of the requirements. This table
also includes those chemical-specific advisories, guidances,
policies, etc. which, while not ARARs, are to be considered (TBC)
in setting target cleanup levels at the site.
Table 2-2 lists potential location-specific ARARs and TBCs for
the site, along with a synopsis of these requirements. Finally,
Table 2-3 lists action-specific ARARs and TBCs for the remedy
selected for the site, as well as those other remedial
alternatives considered.
A brief narrative summary of the ARARs follows.
1.
Action-specific ARARs
The source control portion of the remedial action will involve
-------
edia
GROUND ~ATERISURFACE YATER
R
irement
F~ral
Re-gulatorv
Re
-------
Table 2-1
Page 2
Media
State
.egulatory
.eq.Jlr~ts
R eQU i r emf'n t
EPA Core I nogen
Assessment Group
Pot~y factors
USEPA Ground Vater
Protection Strategy .
USEPA Polley State.ent.
August, 1981..
Msloe OEP, Bureau of
Oil and Halerd0u8
Materiels Control
U8 M.R.S.A..
Section 1317 fLHg..
Chepter 8(0)
Maloe OEP, Bureeu of
land Ouallty Control
U8 M.R.S.A..
Chapter 3, Protection
end IIPpt' OVet8e0t of
Vater, Section 420)
Statu-;
To Be
Considered
To Be
Considered
Appllcabte
Applicable
R~irement Synopsis
Carcinogenic effects present the MOst
up-to-date information on cancer risk
potency derived frOlll EPA's cancer
assessment group (CAG).
Identifies gromd water q.J8lity to be
8Chleved e1Jrlng remedial actions based
on aquifer characteristics end ~e.
This rule Identifies certain subetances
as halardoue Matter. discharges of which
are lubject to discharge removel.
notification. reportlno. and other
requirements I.nter 38 "...S.A.. Section
1117. et. s~. and rut.1 adopted
thereumr.
Thll regulation strlct'v prohibits the
deposit, ~ischarge or apill, directlv or
Indirectly Into the "f~'nd gromd or
surface weters or tidal waters of this
state, or on the Ice thereof. or on the
banks thereof 50 that the 5- NY ftow
or be washed into such weters. or In
such -.nner thet the drainage therefrOlll
....y flow into such waters. any of the
fol lowing substances: .rcury or any
compound containing .rcury. toxic or
halardous substances. radiological.
chemical. or biological warfare agents.
Consideration in the RiffS
(PA carcinogen potency factors are used to
compute the Individual Incr~tal cancer
risk resulting frOlll exposure to certain
compounds .
The req.Jlre.ents of thll polley will be
considered and eveluated when developing
re.edlal alternatlvel.
These req.Jlrementl are conslltent with the
USEPA regulat ions pronul,ated I.nter Sect I on
311 of the Clean Vater Act and published in
'0 CfR 116. These requirellleou wi I I be used
to identify all compounds found at the 81te
that are considered to pose a present or
potential danger to the people of the Itate
or to It I netural envlr~t when deposited
on Iind or discharged on or Into water of the
atate or .-blent air.
These regulations wit I be coneldered 'n the
developnent of alternetlvea In respect to the
control of runoff frOlll the alte and
dllchargea frOlll the alt. that ..y result frOlll
onelt. tr.atMent facll'tl...
(
o
-------
hbte2~
Page 3
Media
Irement
R
Maine DEP, Bureau of
Vater Quality Control
(38 M.R.S.A.,
Article U,
Vater Cla.slflcatlon
progr.)
Maine DEP, Bureau of
Vater Duality Control,
polley No. 10, -'he
Discharge of Hazardous
S\betancu to Ground
Vatera of the State-
Status
Appl I cable
To Be
Considered
R
I.
'his regulation declares that It I. the
state". objective to restore end
maintain the che8lcal, physical and
biological integrity of the state's
wotera and to pres~rve certain prl.tine
state waters. 'h~ regulation seta
forth: (1) that th~ discharge of
pollutants into th~ waters of the Itate
be ell.inated wher~ appropriate; (2)
thot no pollutants be discharged into
any waters of the state without first
being giv~ the degr~ of treatment
necessary to allow those waters to
attain their classification; and (J)
that water ~llty be .ufflcl~t to
provide for the protKtlon and
propagation of fish, shellfish and
wildlife and provide for rKreatlon In
and on the weter.
The board wit I deny appUcat Ions for
waste discharge llc~e. for the
dlecharge to ground waters of substances
desigNited by the board to be haurdoua
wh~ such slbstance. are pres~t In
conc~trationa exceeding ground water
levell which occur Nlturally In the
area. Exetl'f)t ion -y be granted If the
ground water Is treated to reduce
concentrations of pollutants discharged
to below the level considered safe for
drinking water. .
.
I
Conslderat
'hll regulation ..Ill be considered o...ring the
devel~t of alternatives that will Involve
the dischlrge of treated waterl to the
lurface or ground ..ater. Vater ~llty
levell for aurface water. and ground ..ater
..Ill be coneldered a. a .Inl- level.
'hll requlr~t Indicate. .lnlMUm level of
ground ..ater treataent that would be required
to achieve .afe drinking ..ater .tandards to
provide adecfJate protection for treatlllent
dl.chargee.
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hbl~ 2-1
Page I,
fled I a
AIR
federal
bgulatory
1~lr~U
Sht~
Regulatory
1~lremenU
R eQU I renrn t
Maine DEP, Depert~t
of HumBn S~rvices,
Bur~au of H~alth,
10.11,1,A OMR 231, .ul~.
R~lating to Drinking
Uat~r, Section 7A.
Maine DEP, Bureeu of
Uater Ouallty Control,
Regulations,
Chapter S67.
Maine DEP, Depert~t
of Human S~rvice.,
Bureau of Health,
10.11,1,A CMR 233,
Rul~s R~latlng to
Testing of Private
Uat~r Systems for
Pot~ntlally Hazardous
ContllllllnanU,
A~1x c.
CM . National AilbIMt
Air Quality Standards
(NMOS) . 1,0 CfR SO.
Maine DEP, Bur~au of
Air Ouallty Control,
Ambi~nt Air Ouallty
Standards
(13 M.R.S.A., Section
S~, Ch8pt~r 110)
Status
Relevant end
Appropriate
Rei evant end
Appropriate
lei ~vant end
Appf" opr late
bl~vant and
Appropriate
Applicable
ReQlIi rement Synops II
Maine M..inun Contlllllln8nt Lev~ls (MCLI)
hav~ been promulgated for a nt.nber of
contlllllinants in water. UhM the state
l~v~ls are more stringent than federal
levels, the state levell will be used.
Rule. for th~ Land 'Application of Sludge
and RelldJah apply to appllution of
municipal or Industrial IIudg~s or
r~sidJais (establish ..xl~
concMtntion I i.ltl for I~ _tall end
PCBs).
M8II1- exposure guldellnel (MEG.) and
action lev~l. exist for numerous
Inorganic and organic c~s In
wat~r. UhM the levell are ~re
stringent than the federal levell, the
Itate levels will be uaed.
Thele Itandards were prl..rlly developed
to regulate Itack and 8Uto.oblle
_llIlonl.
Thll regulation estabilihes ambient air
quality standards that are ..xl-
l~v~11 of a partlcullr pollutant
penlitted In the -lent air.
Consideration In the II/FS
PrI..ry drinking water Itandarda wi I I be uaed
to let ground water cleanup levell.
These rulel Ire not applicable aa no
lIU'Iicipai or IrdJstrlal sludge will be
appl led as part of a retMdv. Howev~r, the
lI..itl Ihould be considered a5 potentlat
lolt cleanup levela for h~avv _tall and
PCBI.
Uhen ground water deanup tevell are
deten8lned for the Plnettels lite, the llare
atrlngent regulatory atandarda will be used.
St8ndards for particulate ..tter wit I be uaed
when as.el.lng exclvatlon and _llslon
controll for lolt trest~t. Standards are
considered potentlaUy relevant and
appropriate a. they provide net lonal rather
than lite..peclfic tl.ltl.
During remedial activities, the 21,-hour
..xl- particulate conce~tratlon must be
..intained betow 150 ug/. and annual
geometric _an of the 21,'~our concentration
Ihould not exceed 60 ug/-. The use of dust
suppressantl ..y be neeesiary to ~intaln
those levetl.
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Site Feature
"EHANDS
Federal
Regulatory
Requl re_nta
State
Regulatory
Requlre_ntl
Re ul elllent
C"A-Sectlon 404
Maine, DEP, Burelu of
Land Quality Control
(38 M.R.S.A., Section
1301 .t. ,eq., Chapter
401)
Maine DEP, Bureau of
Land Quality Control
(38 M.R.S.A., Chapter
3, Section 405.410)
Maine DEP, Bureau of
Oil and Hlzardoul
Material I Control (30
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Table
Page 2
2-2
Site feature
UATER BODIES
State
Regulatory
Requlre~ent.
R~qulrement
Maine DEP, lure au of
land Ouallty Control
(3ft M.R.S.A., Chapter
3, Article 2, Section
~21)
Maine DEP, Bureau of
land Ouallty Control
(3ft M.R.S.A., Chapter
J, Section ~25
et,seq,)
Maine DEP, Bureau of
Uater Ouality Control
(3ft M.R.S.A., Chapter
3. Protection and
Improvement of Vater,
Article ~A. Uater
Classification
Progr.., Section 46~)
Maine DEP, Bureau of
Uater Ouality Control
(3ft M.R.S.A., Chapter
J, Protection and
Improvement of Vater,
Article ~A, Uater
Clas.lflcatlon
Progr.~, Section 465)
Maine DEP, Bureau of
Uater Quality Control
(3ft M.R.S.A., Chapter
3, Protection and
Improvement of Vater,
Article ~A, Uater
Classification
Progra~, Section 467)
Status
Applicable
Applicable
Applicable
Appllc.ble
Applicable
Requirement SynoDsls
No boundary of any public or
private solid wa.te disposal area
shall lie clo.er than 300 feet to
any classified body of surface
water. Also known a. the Three
Hundred foot Law.
Thl. requlre..nt .peclfle. that any
dredging, filling, or erecting
activity on the land adjacent to
any river, .trea. or brook .hall
not unreasonably Interfere with the
natural flow or lower the quality
of any water.,
Cla..lflcatlon of Maine Uater. .
general provl.lon. regulating
discharge. of pollutant.,
antldegradatlon policy. 10 direct
diacharge of pollut.nt. to watera
with a drainage area etO .quare
.lles.
These regulation. .et
cla.sificatlon. for freah .urface
water.. lake. and ponds, e.tuarlne
and marine water.. and ground
water. The regulations e.tabllsh
guidelines for u.age. and quality
o' the watera to be met or
.aintained.
Thi. regulation provides a
classification of all major river
basins and .eg.ent. thereof within
the state boundaries. These .a;or
river classification categories
correspond with the fresh water
classification. o. Article 'A.
Section 465. which establl.h
guidelines for u.ages and quality
of the water. to be .et or
.alntalned.
Consideration In the 11/15
During the development of alternative., effect.
on nearby .urface water. will be evaluated.
Effecta on the Ue.t Iranch of Salmon Brook or
'ardiner Creek Br.nch will be con.ldered If
con.tructlon or cleanup actlvltle. IMpact these
area..
Thl. regulation will be con.ldered during the
development of alternative. that will Involve
the dlachar,e of treated water. to the .urface
or ,round water.
Cleanup level. for ground water and aurface
water will be aet to per.lt discharge of or Into
the .urface water., ,round water or wetland. of
the .tate In accordance with the.. regulation..
DI.charge. .ade to lurface waterl of the .tate
.hould be of a quality that will not degrade the
quality of the Aroostook River or tributary
thereof.
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Teble
Pege }
2-2
Ite feeture
'.
Re ulre~ent
Meine OEP, Bureeu of
Yeter Quality Control
(}8 M.I.S,A.. Chapter
3, Protection and
l~prove8ent of Yater.
Article 'A, Yater
Clesslflcetlon
Progre8, Section 468)
Meine OEP. Bureau of
Yeter Quality Controt
(]8 M.R.S.A., Chapter
3, Protection and
l.prove~ent of Yater.
Article 'A. Yater
Clesslflcatlon
Progra.. Section 470)
OTHER NATURAL IESOURCES
Stete
Regulatory
Requlre~entl
Meine OEP. Bureau of
lend QUlllty Control
(]8 M.I.S.A., Chapter
3, Section '81,490)
Meine OEP. Bur.au of
lend Quality Control
(]8 M.R.S.A., Chapter
3, Section 371-311)
Status
Appllceble
Apptlcable
Appltcable
Applicable
II
The Yest Branch of Selmon Creek Ind
Gerdiner Creek Irl ctassifled al
Clas. B water under the stlte wlter
quality standardl.
Clasllflcatlon of Ground V.tar.
All ground water .h.ll be
cl.ssifled .s not lell then GV.A.
GV'A Ihall be of luch a quality
th.t It can be uled for pubtlc
water luppllel.
The developMent clnnot adverlely
Iffect exiltlng Ulel, Icenic
chlrecter. or nlturll resourcel In
the 8Unlclpall~y or In neighboring
.unlclpalltlel.
Thll require.ent deflnel the
natural relourcel to which the Iitl
locltlon ICt Ippllel.
,
(
le8edial Ictlonl Ihould not result In tbe
degradation of wlter qUlllty clesslflcation.
le-edlll Ictlonl Ihoutd not relult In the
degradation of ground wlter classification.
le8edl.I Ictlon. Ihould ItlO be con.ldered for
.qulfer rl.toratlon. when Ipproprlate.
The develOp8ent of re..dlll Itternltlves witt
conllder thl. requlre..nt.
I...dllt atternltlve. wltl be devetoped to
consider thel' nltur.l relources.
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TABLE 2-3
POTfNTIAl ACTION-SPECIFIC ARAAS
PINETTE'S SALVAGE YAAD SITE
fEASIBiliTY STUOY REPORT
Act I one s)
ARARs
AU
OSHA-General lndu8try Standards (29 CfA
1910)
AU
OSHA-Safety end Health Standards (29 CFA
1926)
AU
Resource Conservation and Aecovery Act
(ACRA), ICRA Subtitle C, 40 CfR 260
AU
OSHA-Aecord Keeping, I~rtlna end
Related R~I.tlone (29 CfR ,~)
AU
ICRA . Standards for Owner./Qpereto~1 of
Per~ltted Haz.rdous Vaate faeilitle' (~O
CFA 2~.10-2~.18)
AU
RCAA . Prepar~sl and Pre~tlon t~O
CfR 2~.30-2~.31)
AU
IICRA . Cont Ingeney Plan and flllerger1ty
proc.dures (40 CFI 264.50.26A.56)
AU
ICRA - Ground Vatar Protection (40 tfR
2~.90-2~.109)
AU
RCAA - Mllcellaneoua Unit. (40 CfR
2~.600-264.999)
AU
RCRA - CIDlure end Poat-Closure (40 CfR
2~.110-264.120)
Status
Applicable
Appllcabl e
Relevent and
Appropriate
Applicable
Relevent end
Appropriate
Relevent end
Appropriate
Aelevent end
Appropriete
Aelevent and
Appropriate
Aelevent end
Appropriate
Relevent .nd
Appropriate
ReQUiremP.nt Synopsis
These regulations specify the a-hr. tiMe-weighted average
concentration for worker exposure to various organic compounds.
Training rrquirement. for workerl at hazardous waBte operations
are specified In 29 CfR 1910.120.
This regulation speciflee the type of safety rqulpnent end
proUdures to be foUowed cklrlng lite retlledlat ion.
RCRA regulates the generation, transport, treatMent end dlspoBal
of ~'zardous waste. Hazardous lubstancel fro. remedlel actions
will be disposed of at facilities In compliance with Subtitle C
of RCRA. No ACRA - lilted hazardous wastes have been Identified
on-ilte. Therefore, theee regul.tlons are considered relevant
and appropriate.
'"II r~lat Ion outt lne. the record Iteepl", and reporting
rtqul rementl for an e.ployer U'VJer OSHA.
G~t.1 facility requlre.ents outline general wast. analysis,
8ec","lty IDeBlUrel, Inspections, and training requlre.enu.
,hla regulation outlines the requlre.ents for s.fety IqUlpMent
8hd aplll control.
Thl. regulation outlines the requireMents for eMergency
ptatedures to be used fottowlng eaploslOhl, fires, etc.
Thll regulation details requlre.ents for a ground wet.r
...ltorlng progr. to be InstaUed at the site.
Thele Itandards are applicable to .Iscellaneoua units not
previously defined U'VJer exlltl", RCRA regulations for treet~t,
Itorage, and dllposal unit..
Thll regulation details lpeclflc requlreMentl for clolure and
post-closure of hazardous waite facilities. Because of lite
characterlltles, only portions of the closure requlrenentl ~y be
epproprle t e.
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Tebt e
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Actlon(s)
AU
AU
AU
'1
ARAR!!
Maine DEP Bureau of Olt and Hazardous
Materlall Control (38 M.R.S.A., Section
1311 ~, Chapter. 800-802).
Mal ne DEP, lurelU of 011 and Haurdous
Haterlala Control (38 M.R.S.A., Section
1301 ~, Chapterl 850, 851, 853-
857)
Maine DEP, Bureau of Vater Quality
Control (38 "...S.A., Chapter 3. Article
2, Sect Ion 420)
AU
Maine DEP, lureau of Water Quality
Control (38 M.R.S.A., Chapter 3,
Protection and I~oveeent of Water,
Article 4A, Water Clasllflcatlon
Progr.., Section 470)
Excavation
CAA - NAAQS for Total Suspended
pftrtlculate. (40 Cf. 50.6)
RCRA - land Ian (40 CfR 268)
CUA - Regulations on Disposal Site
Detenalnatlons Under the Water Act (40
CfR 231)
Maine DEP, Bureau of Air Quality
Control, Ambient Air Quality Standards
(38 H.R.S.A., Section 584, Chapter 110)
Status
Apptleabte
Apptl eabl e
Applicable
Applicable
Relevant and
Appropriate
To be
considered
Relevant and
Appropriate
Applicable
( .
I~irement Synopsis
legulatlons apply to Identification and control of dllcharge of
hazardous ..terlat..
The rules provide . c~ehenslw progr- for the handling,
Itorage, and recordkeeplng at hazardous waste facltltles. They
lupplement the RCRA regutatlons.
No person, flna, corporation, or other legal entity shall place,
deposit, discharge. or spill Mercury or toxic or hazardous
lubstances, either dlrectty or Indirectly, Into the Inland ground
or surface waterl. tidal waterl, on the Ice, or on the banks
thereof, 10 that the lame ..y flow or be washed Into luch waterl,
or In luch ...-ner that the drainage therefr08 .y flow Into such
waten.
Ground water II classified under the Milne Itandards to allow the
state to ..nage It I lorfaee waterl and ,round water 10 as to
protect the qual It, of these waterl. legutatlons establish water
quality Itandards for direct or Indirect dllehargel to ~lfen.
1h11 regulltlon lpeclfles .....- prl.ry and l.condery 24-hr.
concentrations for particulate .Uer. fugitive GJit _Isslona
fr~lite excavation activities 8USt be .Intalned below 260
ug/. (prl.r, Itendard). Regulation let I MUonsl 11.1 tat Ions
and II therefore relevant and appropriate.
After November 8. 1988, ~V8lent of excavated RCRA-hazardous
..terlah to new locations and placelllel\t In or on land wit I
trigger land disposal re.trlctlons (for non-CERClA actions).
CERClA actions will be regulated ~r thla requirelllent beginning
on Novenber 8, 1990. No RCRA~Illted or eharacterlltle hazardous
wastes known to exllt on-lite: therefore, thll requirement Is
onl y to be cons ldered.
These regulations appl, to all existing, propoled, or potential
disposal altes for dllchargel of dredged or fill ..terlal into
U.S. waterl, which Include wetlands.
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This regulation established eMblent air quality Itandards that
are I118xi- levell of a particular poUutant penaltted In the
-------
hble 2- 3
Page j
~ctlon(8)
Capplng-Vaste In
Place
ARAR8
RCRA - l8ndfl'la (40 CfR 2~.]10(a»
CAA - NAAQS for Particulate Matte~ Les.
then 10 Mlcrone In DI.-eter (40 CfR Part
50, Appendix J)
CAA - NAAQS for Tot.' Suspended
Partlculatea (40 Cf. 50.6)
RCRA - Genera' St8ndarda (40 Cft
2~.117(c»
Status
le'event and
Appropriate
le'evant and
Appropriate
"'event and
Appropriate
le'event and
Appropriate
Requlrrment Synopsis
Placement of . cap over Maste requlrea . cover dP.slgned and
constructed to:
-Provide long-ten8 .Inl.llatlon of .Igratlon of 'Iqulds through
the capped area;
-function with .Inl.ua ..Intenance;
-Promote drainage and .Inl.ile erosion or abrasion of the cover;
-Accommodate lett'lng and lubsldence 10 that the cover'a
Integrity is ..Intaloed;
-Havl.' a pef'8eabH Ity '"a than or equal to the penneabH Ity of
any bottOlll liner .yat.. or natura' stbsoH. present-
Thll regu'atlon lpeclfles ..xl8U8 annua' arithmetic 8Ian and
..xi~ 24-hour concentrations for particulate ..tter less then
10.icrona In dl...ter. legulatlon let a natlone' '1.ltatlons and
II therefore relevent and appropriate.
This regulation lpeclfl.. ..xl8U8 prl_ry 8nd lecondary 24-hr.
concentratlone for particulate ..tter. fugitive Gat ..Inlons
fr~llte excavation actlvltlll _t be ..Int.loed below 260
ug/. (prl..ry .tandard). Regu'atlon let. natlona' II.ltatlone
and II therefore re'.vent 8nd appropriate.
leltrlctl POlt-c'osure UI. 0' property.. nec...ery to prevent
d88age to the cover.
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Tabte
Pege I.
2-'
Actlon(s)
Cle8l\ Ctosure
(RMOVet)
ctosure with Yaste
In Piece (Hybrid
Ctosure)
Ground Yater end
Surfece Yater
Monitoring
Onelte \/..t.
Tr.atlllMt and
Dhcharge
ARARs
RCRA - Gener.l Standards (1.0 CFR
2610.111)
DOT Rutel for Transportation of
Hazardous Matlrlatl (49 CFR Pertl 101,
11t.1-1n.558)
Proposed Rute 52 fR 8112 (March 19,
,9ft 7)
RCRA . Ground Yater Protection (1.0 CFR
2610.97)
Maine DEP, Bureau of Yater Quatlty
Control, Regulatlona. Chapter 543
Maine DEP, Bureau 0' Yater Quetity
Control. Regutatlona. Chapter 582
Status
Retevent end
Appropriate
Relev8l\t and
Appropriate.
To Be
conaldered
For GrOlrd
Yater:
Retevant and
Approprlete for
Surface Yater:
To Ie
conaldered
Retev8l\t and
Appropr late
Appl fcabte
c'
ReQUirement Synopsis
Generat perfonnanc:e atandard requlrel .Inl.llatlon of need for
further ~intenance and controt; .ini.iletion or eti.lnetlon of
post-ctosure escape of hazardous welte, hazerdOus constltuentl.
leechete, cont..inated I'tnIff. or h.lardOus waste decOlllp08ltlon
prcdJc:tl. Atso requires disposal or decont_lnation of
equipment. atruc:tures. and soltl.
Thil regutatlon outllnel procedures for the pechglng. lebet Ing.
88ftlfelting. and trensportlng of hez.rdOus ..terl.l..
Requirel reftlOvat of -Jorlty of cont.lnated _terlall. Also
requirel apptlution of cover and polt-closure .onltorlng based
on expolure pethway(l) of concern.
General requlre8ef'ltl for Irouod ..ter .onftorlng.
Thll regutation prOhlbltl the Injection of hllardous yaste Into
or above weter-bearlng fOrMtlons via a new Cla.. IV wt I. The
tUbturfece dilcharle Into or through a Cl.II IV wll that woutd
cause or at tow the IIOVe8ef'It of fluid Into en underground 80urce
of drinking water that ..y relutt In a violation of any Maine
PriMary Drinking Yater Standard. or which -y otheryile adverlely
. affect hUIIBn heaUh. II prohibited.
These rutel provide lafeguards for fresh and lalt water fauna In
lakes and rlverl of the Itate by estabtlshlng In-Itre.. 11.ltl on
teMP8rature Increasel resulting fro. thenR8l dllcharges.
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Tebl~ 2-3
Pag~ 5
Act I on(S)
ConstructIon and
Operation ot Onslt~
landti II
. .
ConstructIon end
Operation of Onslte
IncInerator
ARARI
Maine DEP, Bur~au of ~at~r Quality
Control, Regulations, Chapter 567
RCRA . tandtilla ('0 eFR 264, Subpart N)
RCRA - tand Ban ('0 eFR 268)
TSCA . DI.~al Ret.I
III
(JQ
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IV
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Table
Pege 6
2-r
~~tlon(s)
:
Offllte Disposal of
Solid lI8Itea
ARARt
Cleen Air Act (CAA) . Matlonal ABbient
Air Ou8llty St8nd8rds (MAACS) (40 CfR
50)
Interl. IICRA/CERClA Guidance on Mon-
Contiguous Site. end Onsite Management
of ~a.ta end Treated Re.ldue (USEPA
Polley State.ent M8rch 27, 1966)
CAA - MAAQS for Particulate Matter Les.
Than 10 Microns In Dlaneter (40 CfR Part
50, Appendix J)
Maine DEP, Bureau of Air Quality
Control, Alllblent Air Quality Standards
(}8 M.R.S.A., Section 584, Chepter 110).
Maine DEP, Bureau of Air Quality
Control, Hex.valent ChrOMIUN particulate
E~illion Standard (}8 M.R.S.A., Section
585, 585A, Chapter 135)
Maine DEP, Bureau of Air Quality
Control, Incinerator Particulate
E~lllion Standard (38 M.R.S.A., Section
585, 585A, Chapter 104)
Standardl Applicable to Transporters of
Hazardous lIalte - RCRA Section 3003, 40
CfR 262 end 263.
StatU$
Relevant and
Approprlete
To Ie
Considered
Relevant end
Appropriate
Applicable
Applicable
Applicable
Relevant end
Appropriate
,
(
Reo'" rMent Synops i.
Applies to ..jor .tatlonary .ource. such a. trelt.ent units that
have the potential to tIIlt aignlficent ~u of pollutents auch
aa MOx' S02' CO, leed, -.ercury end particulates (_e than 250
tons/year). Regulations under CAA do not apeclflcally regulate
tIIission. fraa hazardous weste Inclneratora, but It la likely
thet Prevention of Slgnlflclf'lt Deterioration (P$O) prcwlalons
would apply to en onslte treetlllet'lt facH ity. Regulation seU
n-tionel li.ltatlons and I. therefore relevant and appropriete.
If a treatlRmt or atorage uni t la to be constructed for ons I te
reardiel action, there should be a clear Intent to dla.8ntle,
re8Qve, or close the unit after the CERCLA action la completed.
Should there be plans to accept conmerclal va.ta at the facility
after the CERCLA ve.te haa been proceaaed, It la EPA policy thlt
a IICRA pe~1t be obtained before the unit la constructed.
Thi. reguletion apeelflea ...1- ennuel arlthlaetlc .en end
...i- 24-hour concentrations for particulate ..tter.
Regulation aeta n-tlonal II.it.tlons end la therefor. relevant
8nd appropriate.
Thl. retUl.tlon estebllthea 8Mblent .Ir quality atandards that
are ..xi- levell 0' a particular pollutent per8Uted In the
Mblent .Ir.
E.tabilihe. a 11.ltatlon on the 880Unt of total Chr08lu. fr08 any
potential .aurce of he.avllent chr08lu. until a technique for
...urlng he.avalent chr08lu. cen be de8on8trated.
Eatabllahel I li.itatlon on the emount of particulate ..tter
allowed to be eMitted 'ro. each 0' lever.I categories end .Izea
0' inclneratora, and a II.ltatlon on the capacity 0' tIIiaslons
'r08 all inclneratora.
Establishes the responsibility 0' off.ite transporter. of
hazardous welte in the handling, transportltion, end ..nagement
0' the waste. Re~"'rea a IIIIInlfeat, record keeping, end Innedlate
action In the event 0' a dilcharge of hazardous vaat.. On-site
wastes are not RCRA hazerdOus ..teriala end therefore this
reguletlon I. relevant end appropriate.
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Table 2-3
Page 1
Actlon(s)
AAARe
EPA Interi. Policy for Planning and
Impl~tlng CEAClA Aes~se Actions.
Propoled Rule, 50 fA 459}} (Novrmber 5,
1985)
DOT Aul.. for Tr8nlpOrtetion of
Hlzardoul "iterlill (49 CfR Pertl 107,
171.1-1n.5S8)
TSCA - Dllpo.ll Requlre.entl
(40 CfR 761.60 - 761.19)
OnIlte ~eter
Tr'ltllent and
Dllcharge
Nltl~l Pollution DI.cherge EII.lnetlon
Syate8 (NPDES) (40 CfR 122)
Status
To Be
Conaidered
At! levant Ind
Approprilte
Applicable
Applicable
Requirement synopsis
Discusses the need to consider treet.ent. recycling. end reuse
before offaite lend disposel I. used. Prohibit. use of e RCRA
flcility for offllte 88nage8ent of SUperfund wlste. If It hla
significent RCAA violltlons.
This regulation outlines procedJre. for the packaging. lebellng,
..nifesting, and transporting of hlzlrdOus ..terill.. for PCB - .
cont_inated aoll.. reguletlons would be relevlnt end approprl.te
for indivldJel ahiJ8t!"t. contelnlng lell thin 10 pomda of PCB.
(Reportable Quantity).
Elteblilhel treat.ent end dilposil requlreMentl for PCI. in loll.
for III Ilternativel which Include the dilturbanee of PCI-
cont..lneted loi I contelnlng 80re than 50 PJI8 PCBI.
Regulltes the dischlrge of wlter Into public lurflce weterl.
AMong other things, ..jor requirellef'lts are:
-Use of best .vailabl. technology (BAT) ec~lc.lly achievable
I. required to control toxic end nonconventlonel pollutantl. UI'
of best convent ionel pollutant control technology (BCT) II
required to control conventlonsl pollutlnt.. Technology-based
li.itatlons may be deter.lned on e ceae-by-ce.. basil.
-Applicable feder.lly epproved atate water quality .tenderds MUSt
be cGq)lied with. Thel. Itenderds ..y be In 8ddltlon to or ..:Ire
atringent than other federel .tandards under the OWl'.
-The dilcharge MUSt confor. to applicable water quality
requirementl when the dl.char.. affecta a atete other than the
certifying atate.
-The diachlrge ~t be conslltent with the requlrellef'lta of a
water quality I118nagement plln approved by EPA.
.Oischerge limitltions .ust be eltabllshed for all toxic
pollutantl that are or ..y be dllchlrged at level. greater than
that which can be achieved by technology-baled Itanderds.
-Oilcharge ~t be 8Onltored to a.lure cu.pllance. Ol.charger
will lIIOr'Iitor:
-The II1II'1 of each pollutant.
-The volume of effluent.
-frequency of discharge end other ...lureMent. a. appropriate.
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Yeble 2- ~
Page 8
~ctlon(s)
AllAh
Propol8d St8nderda for Control of
E~iBBion' of Volatile Organici . 52 'R
37'8 (February S, 1987)
Toxic Pollutant Effluent Standards ('0
CFR 129)
Maine OEP, 8ureau of Water OUIllty
control~ Re9Ulatlone. Chaptar 54]
Maine OEP," Bureeu of Water OuIllty
Control, Polley Mo. 10, -The Dllcharge
of Hlzardous Substances to Ground Waterl
of the State-
Maine OEP, Bureau of Land ouallty
Control (38 M.R.S.A.. Chapter 3. Section
371-377)
Status
To Ie
Cons ldered
Relevant aOO
Appropriate
Relevant and
Appropriate
To Ie
Coneldered
Applicable
.
.
lecJUlretnmt Synopsis
-Approved test .thods for "aste constltuentl to be 8Qf1ttored
8IJSt be followed. Detaned requlremmtl for analytical procedu-
res and qual ity controll are provided.
Onsite discharges to lurface waterl are eXe8pt fr08 procedural
"POES permit requlretDef'ltl. (Section 121 of SARA eXelliptl onelte
CERCLA activities fr08 obtaining pe~ltl. However. the
lubstantlve requirement. of the pe~lt 8Ult be ..t.) Offllt.
discharges would require an MPOES pe~lt.
-Monitor and report resultl (.inl8U8 of at lealt annually).
-Comply with additional conditions such a.:
-Duty to ~itlgate any adverse effects of any discharge: and
-Proper operation and ..Intenante of treat.ent ayate88.
Prescrlbel proposed standards for VOC .Iaalons fr08 unltl luch
aa air .trlppera.
Regulates the dltcharge of the following pollutanta:
aldri~/dleldrln. DDT. endrln. toxsphene. benzidine. and PCBI.
Thlt regulation prohibita the Injection of hazardOue waste Into
or above water-bearing fot1l8t1one via. new Clas. IV well. The
lubsurface ditchlrge Into or through a CI.la IV well that would
cause or al low the ~t of fluid Into an ~rlrCU1d lource
of drinking water that ..y result In a violation of any Maine
Prl_1")' Orlnklng "ater Standard. or which -y otherwlae adversely
.ffect hunen health, II prohibited.
The ~rd will denv Applications for waate dllcharge licenses for
the dilcharge t~ qround waterl of aubstancel dealgnated by the
board to be h"18rdous tlhen luch IlJIatances are pre.ent In
concentrat Ions exceeding ground water levell tlhlch occur
naturaUy In the area. ExeqJtlon -y be granted If the ground
water II treated to reduce the concentrations of pollutantl
discharged to below the level coneldered life for drinking water.
Developments wi" ha". a .Inl..l adverse IlIIp8Ct on the natural
envlronMnt. Activities that discharge or ..y discharge
pollutantl to ground water ..y not be loc.ted on sand or gravel
deposlU.
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Table 2-)
Page 9
Actlon(s)
AIlARs
Maine DEP, Bureau of Vater OU8llty
Control (33 M...S.A.. Chapter 3, Article
2, Section 41'.A)
Maine oEP, Bur.au of Vater OU8llty
Control. .~I.tlona. Chapter 582.
Status
Aflpll cabl e
Applicable
R~lrement Synopsis
Regulates the dilcharge of any pollutantl. Specifies that the
discharge, either bv itself or In coMbination with other .
discharges, will not lower the quality of any clarslfied body of
water below such clasliflcatlon. The discharoe witl be subject
to effluent li.itatlons that require application of the best
practicable treat8ent.
These ruin provl. .afeguard8 for fresh and lalt water fllU\8 In
lakes and rivers 0' the atate bv eatablilhlng In-Itre.. 11.lta on
temperatura resultlno fro. the,..l dilcharoea.
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ROD DECISION SUMMARY
pinette's salvage Yard
page 29
"-
site, with some of the contaminated soil being transported off-
site for incineration and the remainder (majority) being treated
on-site through a solvent extraction process. The management of
migration portion of the remedy will involve the construction of
interceptor trenches and extraction wells 'to collect groundwater,
the installation of a treatment system to remove particulates and
organic contaminants, and the construction of trenches on-site
for the recharge of treated water back into the ground.
a.
Federal
The Resource Conservation and Recovery Act (RCRA) governs the
transportation. storage, treatment and disposal of hazardous
wastes. Although the PSY site does not have RCRA-hazardous
wastes, many RCRA requirements address the same kinds of actions
that will be taken at the PSY site and are therefore relevant and
appropriate to the implementation of the selected remedy. EPA
will comply with the substantive provisions of RCRA regulations
governing: standards for Owners and Operators of Hazardous Waste
Treatment, storage and Disposal Facilities, General Facility
Standards (40 CFR 264.10-264.18): Preparedness and Prevention (40
CFR 264.30-264.37); Contingency Plan and Emergency Procedures (40
CFR 264.50-264.56): Releases From Solid Waste Management Units
(groundwater protection) (40 CFR 264.90-264.109); Closure and
Post-Closure (40 CFR 264.110-264.120, as interpreted by EPA
guidance for use at CERCLA sites where RCRA closure is relevant
and appropriate but not applicable); and Miscellaneous Units (40
CFR 264.600-264.999). In addition, for those soils being
transported off-site for incineration, EPA will comply with
relevant and appropriate RCRA regulations for Standards
Applicable to Generators and Transporters of Hazardous Wastes (40
CFR 262 and 263) and Department of Transportation Rules for
Transportation of Hazardous Materials (49 CFR Parts 107, 171.1-
172.558) .
Under the Toxic Substances Control Act (TSCA), soils contaminated
with PCBs at concentrations greater than 50 ppm that are disposed
of after February 17, 1978 must be disposed of in accordance with
40 CFR 761 Subpart D. Since the PSY site contains PCBs at
concentrations over 50 ppm, and since disposal will occur after
1978 as part of the remedial action, TSCA regulations are
applicable to the selected source control action once excavation
takes place. These regulations require treatment by incineration
or its destruction equivalent, or chemical waste landfi11ing.
EPA's selected remedy will meet this requirement through the
incineration of soils contaminated above 50 ppm at an off-site
TSCA-permitted facility.
The TSCA PCB spill Cleanup Policy (40 CFR 761 Subpart G) is not a
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ROD DECISION SUMMARY
Pinette's Salvage Yard
page 30
not an ARAR at the PSY site but is a TBC. The Policy requires
that spills of PCBs at unrestricted access sites be cleaned. up to
a level of 10 ppm, with a minimum of 10 inches of soil removed
from the surface of the entire spill area and replaced with soil
containing less than 1 ppm PCBs. EPA will be consistent with the
first requirement by excavating and treating all soils above 5
ppm PCBs: EPA will also be consistent with the second, to the
extent appropriate, by removing the surface soils in the first
ten inches that are contaminated with 1-5 ppm PCBs and
- consolidating these soils in the hole left by the primary
excavation, well below surface level. The remainder of that hol~
will be filled with soil that has been treated to the target
cleanup levels through the solvent extraction process, and the
surface of the site will be covered with clean fill and
revegetated.
Regulations under the Occupat:~nal safety and Health Act (OSHA)
apply to the conduct of the remedial action as it involves
workers at the site. EPA will comply with OSHA regulations
including the General Industry Standards (29 CFR 1910): Safety
and Health Standards (29 CFR 1926); and the substantive
provisions of the Record Keeping, Reporting and Related
Regulations (29 CFR 1904).
The National Primary and Secondary Ambient Air Quality Standards
(40 CFR Part 50), promulgated under the Clean Air Act, are
relevant and appropriate to the selected remedy. During the
excavation and treatment of contaminated soils at the PSY site,
and during the groundwater treatment, air emissions will be
monitored and the NAAQS attained through the use of appropriate
air pollution control equipment.
The selected remedy will also meet Clean Water Act requirements.
No pollutants or any other materials will be discharged to
surface waters. The removal of contaminated soils from the
wetland area of the site (south of Gardner Creek Road) will
comply with the regulations and guidelines under section 404 of
the Act. EPA will avoid degradation of the wetland to the
maximum extent possible and will restore tte area affected by the
remedial action.
b.
State
The selected remedy will also attain action-specific Maine ARARs,
including the Maine Freshwater Wetlands Act (38 M.R.S.A., chapter
3, sections 405-410): the Maine Hazardous Waste Regulations at 38
M.R.S.A. sections 1301 et seq., chapters 850, 851, 853-857,
sections 1317 et seq., chapters 800-802, and chapter 3, article
2, section 420: Groundwater Protection Regulations at 38 M.R.S.A.
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ROD DECISION SUMMARY
pinette's Salvage Yard
page 31
standards at 38 M.R.S.A. section 584, chapter 110. In addition,
construction of groundwater monitoring wells will comply with
Maine DEP, Bureau of Water Quality Control regulations, chapter
543, which apply only to injection wells but are relevant and
appropriate to the proposed remedy.
2.
Chemical-specific ARARs
In determining which contaminants at the PSY site required
remediation, EPA consulted both Federal and state ARARs as well
as other criteria for protectiveness. As a result, EPA has set
target cleanup goals for six soil contaminants (PCBs, benzene,
1,4-dichlorobenzene, 1, 2, 4-trichlorobenzene, chloromethane, and
chlorobenzene) and seven groundwater contaminants (PCBs, benzene,
1,4-dichlorobenzene, 1, 2, 4-trichlorobenzene, chlorobenzene,
chloromethane, and lead).
While no ARARs apply to any of the soil contaminants and/or
cleanup levels established for the PSY site, it should be noted
that EPA's target cleanup level for PCBs in the soil is .
consistent with the TSCA Spill Cleanup Policy which is TBC. The
selected cleanup levels are also consistent with one other TBC,
the Maine Rules for the Land Application of Sludge and Residuals.
ARARs for the groundwater contaminants at the PSY site include
the Federal Maximum contaminant Levels (MCLs) promulgated under
the Safe Drinking Water Act (40 CFR 141.11-141.16) and the state
of Maine's MCLs (10-144A CMR 231) and Maximum Exposure Guidelines
(MEGs) (10-144A CMR 233). Both the MCLs and MEGs are legally
applicable only at the tap and not to an aquifer directly.
Since, however, the groundwater at the PSY site is classified as
Class IIB under the EPA groundwater protection strategy and must
be considered a possible source of drinking water, the Federal
MCLs are relevant and appropriate in setting cleanup levels.
Similarly, Maine classifies all groundwater in the state as a
minimum Class GW-A, suitable for drinking water, making the State
MCLs and MEGs also relevant and appropriate. The selected
groundwater remedy at the PSY site will meet the standards set by
these ARARs, except that the Maine MEG for PCBs cannot be
attained. Neither the groundwater remedy chosen, nor any other
treatment method of which EPA is aware, is capable of ensuring
the collection of the particulate-bound PCBs for treatment to the
required state ARAR. Those PCBs which are collected with other
contaminants will be treated, but PCB levels are expected to
remain above the State MEG. EPA is therefore invoking a waiver
of that state ARAR on the ground that its attainment is
technologically impracticable from an engineering perspective.
Air emissions from the site will comply with the NAAQS for
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ROD DECISION SUMMARY
Pinette's Salvage Yard
page 32
EPA Interim Policy for Planning and Implementing CERCLA Response
Actions, Proposed Rule, 50 FR 45933 (November 5, 1985), a TBC.
3. Location-specific ARARs
As part of the source control portion of the remedy, EPA will be
excavating some contaminated soils from one wetland area, the
groundwater breakout area south of Gardner Creek Road. EPA will
avoid degradation of this wetland to the maximum extent possible
and will restore the area affected by the remedial action. The
remedial action will comply with section 404 of the Clean Water
Act and with standards set by Maine requirements, including the
Maine Freshwater Wetlands Act (38 M.R.S.A. chapter 3, sections
405-410) and the Maine Hazardous Waste Management Rules (38
M.R.S.A. sections 1301 et sea., chapters 401, 800-802, 850, 851,
853-857). The remedial action will also comply with the Wetlands
Executive Order (EO 11990), which is not an ARAR (because it is
not a promulgated requirement) but is binding on EPA as a Federal
agency. EPA has consulted with the u.s. Fish and Wildlife
Service concerning the effect of the proposed remedy on the
wetland area, as directed by the Fish and Wildlife Coordination
Act.
The other wetlands identified in the site area will not be
directly affected by site remediation activities, and EPA will
ensure their protection through any necessary sedimentation and
erosion controls.
The remedial action will also comply with the Maine Site Location
Law (38 M.R.S.A. chapter 3, sections 481-490), which prohibits
adverse impacts on certain natural resources.
C.
The Selected Remedial Action is Cost-Effective
Of those remedial alternatives that are protective and attain
ARARs, EPA selected a remedy that is cost-effective in mitigating
the risks posed by the soil and groundwater in a reasonable
period of time.
The capital cost of the source control component is estimated to
be $3.42 million with no long-term annual O&M costs anticipated.
This total capital cost is comprised of approximately $1.96
million for off-site incineration and $1.46 million for on-site
solvent extraction. This cost is higher than that of some of the
other alternatives and other combinations of alternatives
evaluated; however, none of the less expensive technologies can
ensure (with the same degree of certainty) that the treated soil
will reach the target cleanup goals. Thus, while technologies
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ROD DECISION SUMMARY
pinette's Salvage Yard
page 33
extraction alone are cheaper than the selected combination of
source control alternatives, they do not provide the same degree
of confidence over the long-term. On the other hand, the
selected source control remedy is less expensive than the only
other equally effective alternative, on-site incineration of all
soils.
The capital cost of the management of migration component of the
selected remedy is estimated to be $310,000. Annual O&M costs
are expected to decrease from an estimated $135,000 during the
first two years, to $42,QOO during years 3 through 5, and to
$20,000 for years 6 to 30; the approximate total present worth
costs are $947,000. This cost is less than that of the other
effective alternatives studied, and will treat the target
contaminants to the target levels in a shorter "period of time.
D.
The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable
Both the source control and management of migration components of
the selected remedy are expected to provide permanent solutions
to the contamination problem at the PSY site. Solvent extraction
permanently removes PCBs and the other contaminants of concern
from the soil, while incineration destroys these contaminants
almost completely. As a result, remediation of the site soils
will permanently reduce the risks associated with exposure to the
soils to levels protective oi human health and the environment.
In addition, removal of the soil contaminants will reduce the
source of groundwater contaminants, increasing the effectiveness
of that component of the remedy.
Both incineration and solvent extraction are alternative
treatment technologies; thus, the selected remedy also satisfies
the requirement that the remedy selected utilize alternative
treatment or resource recovery technologies to the maximum extent
practicable.
The management of migration portion of the remedy also utilizes a
treatment method which will result in the permanent removal of
most target contaminants. Through the collection and treatment
of the contaminated groundwater, this remedy ensures that the
groundwater leaving the site is restored to a level protective of
human health and the environment. Use of institutional controls
will also ensure that the on-site groundwater poses no risk.
E.
The Selected Remedy satisfies the Preference for
Treatment as a principal Element
. .
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ROD DECISION SUMMARY
Pinette~s Salvage Yard
page 34
contaminants and treating the rest of the soil above the target
cleanup levels through a solvent extraction process, the selected
re~l~dy addresses the principal threat posed by the site soils
through the use of treatment technologies. In addition, the
principal threat posed by groundwater contamination at the site
will be addressed primarily through treatment of the groundwater.
The selected remedy thus satisfies the preference for treatment
as a principal element of the Superfund remedy.
%11.
STATE ROLE
The State of Maine, Department of Environmental Protection (DEP)
has reviewed the various alternatives and has indicated its
support for the selected remedy. The State has also reviewed the
Supplemental Remedial Investigation, Public Health Evaluation,
and Feasir~lity Study to determine if the selected remedy is in
compliancc~ith applicable or relevant and appropriate State
environmental laws and regulations. The State of Maine concurs
with the selected remedy for the Pinette's Salvage Yard site. A
copy of the declaration of concurrence is attached as Atta~hment
D to this ROD. In accordance with Section 104 of CERCLA, the
State of Maine is responsible for at least 10 percent of the
costs of the remedial action, including all future maintenance.
. . - _. - ...
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ATTACHMENT A
PINETTE'S SALVAGE YARD SUPERFUND SITE
ROD DECISION SUMMARY
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Pinettes Salvage Yard
NPL Site Administrative Record
Index
Compiled: January 27, 1989
Updated: March 10, 1989
ROD Signed: May 30, 1989
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
EBASCO SERVICES, INC.
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.c
Introduction
This document is the Index to the Administrative Record for
the Pinette's Salvage Yard National Priorities List (NPL) Site.
Section I of the Index cites site-specific documents, and Section
II cites guidance documents used by EPA staff in selecting a
response action at the site.
The Administrative Record is available for public review at
EPA Region I's Office in Boston, Massachusetts, and at the
Washburn Town Hall, Main Street, Washburn, Maine 04786.
Questions concerning the Administrative Record should be
addressed to the EPA Region I site manager.
The Administrative Record is required by the Comprehensive,
Environmental Response, Compensation, and Liability Act (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act
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.
section I
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1.0
2.0
ADMINISTRATIVE RECORD INDEX
for the
Pinette's Salvage Yard NPL site
Pre-Remedial
1.12
Hazard Ranking Package
2.
1.
"Documentation Records for Hazard Ranking
System," EPA Region I (May 9, 1983).
"Documentation Record for Hazard Ranking system"
(Adjusted Final), EPA Region I (May 24, 1983).
Removal Response
2.1
2.3
correspondence
1.
Memorandum from Daniel Granz, EPA Region I to
Barbara Ikalainen, EPA Region I (September 23,
1982). concerning PCBs in Washburn, Maine.
Sampling and Analysis Data
1.
PCB laboratory results of Washburn wells, town
water and river water samples, Laboratory
Services, Maine Department of Environmental
Protection (November 3, 1982).
Memorandum from David McIntyre, EPA Region I to
John Hackler, EPA Region I (December 20, 1982).
Concerning PCB laboratory results 9f soil and
surface water samples collected from Pinette's
Salvage Yard.
Memorandum from Peter Kahn, EPA Region I to
Donald Berger, EPA Region I (November 22, 1983).
Concerning air sampling investigation for PCBs at
Washburn, Maine.
2.
3.
*
other Sampling and Analysis Data may be reviewed,
by appointment only, at EPA Region I, Boston,
Massachusetts.
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".
3.0
2.5
On-Scene Coordinator Report
1.
"On-Scene Coordinator's Report of Immediate
Removal Activities," EPA Region I (October 4,'.
1983 - November 4, 1983). (Confidential Business
Information redacted).
Remedial Investigation (RI)
3.1
Correspondence
1.
2.
3.
Memorandum from R. Ninesteel, NUS corporation to
W.R. Adams, D. Threlfall and E.D. Escher, NUS
Corporation (January 17, 1983). Concerning
Washburn Ramp site Visit.
Memorandum from Bill Wall, NUS Corporation to
Karl Hartner, Anna Nazar, John Newton, Gil Meyer,
Gary smith and Robin Smith, NUS Corporation
(January 26, 1983). Concerning site Description
Washburn RAMP.
Letter from George Latulippe, NUS Corporation to
Don senovich and Don Brenneman, NUS Corporation
(January 30, 1985). Concerning Work Plan
Memorandum.
Letter from Liyang Chu, NUS Corporation to"
Michael Jasinski, EPA Region I (October 1, 1987).
Concerning revisions to the Final Field
Activities Summary Report.
Letter from Liyang Chu, NUS Corporation to
Michael Jasinski, EPA Region I (October 8, 1987).
concerning the delivery of the Final Field
Activities Summary Report.
Letter from Michael Jasinski, EPA Region I to
Mrs. Floyd Drost, Washburn resident (November 6,
1987). Concerning access to collect sample of
residential well.
Letter from Michael Jasinski, EPA Region I to
Margaret Chapman, Washburn resident (November 6,
1987). concerning access to collect sample of
residential well.
Letter from Michael Jasinski, EPA Region I to
Rita Pinette, Washburn resident (November 6,
1987). Concerning access to collect sample of
residential well.
4.
5.
6.
7.
8.
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3.1
"w
.
3.2
Correspondence (cont'd)
9.
10.
11.
12.
13.
14.
Letter from Michael Jasinski, EPA Region I to Mr.
and Mrs. Terry Thompson, Washburn resident'
(November 6, 1987). Concerning access to collect
sample of residential well.
Letter from Michael Jasinski, EPA Region I to Mr.
and Mrs. Roger Pinette, Washburn resident
(November 6, 1987). Concerning access to collect
sample of residential well.
Letter from Michael Jasinski, EPA Region I to
Stephen Cox, ICF Technology, Inc. (January 11,
1988). concerning the preparation of Pinette's
Site Phase II Remedial Investigation and
Feasibility Study.
Letter from Stephen Cox, ICF Technology, Inc. to
Michael Jasinski, EPA Region I (May 25, 1988).
Concerning minor deletions in the Phase II Work
Plan for the Remedial Investigation and'
Feasibility study.
Letter from Mic~ael Jasinski, EPA Region I to
Richard Gleason, Ebasco Services, Inc. (June 30,'
1988). Concerning approval of Final Work Plan
dated May, 1988 and Draft Field Operations Plan
dated May, 1988 for the Phase II Remedial
Investigation and Feasibility study.
Memorandum from Michael Jasinski, EPA Region I to
Richard Gleason and Lee Dixon, Ebasco Services,
Inc. and Stephen Cox, ICF Technology, Inc. (July
22, 1988). Concerning request to change
groundwater analysis plans.
Sampling and Analysis Data
1.
2.
3 .
Memorandum from Valerie Tillinghast, NUS
Corporation to John Rendall, EPA Region I (April
14, 1986). Concerning results of analysis of
tapwater samples obtained from residences near
Pinette's Salvage Yard.
Letter from John Rendall, EPA Region I to Rita
Pinette, Washburn resident (April 21, 1986).
Concerning analytical results of residential well
samples.
Letter from John Rendall, EPA Region I to Floyd
Drost, Washburn resident (April 21, 1986).
Concerning analytical results of residential well
samples.
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3.2
",
3.4
sampling and Analysis Data (cont'd)
4.
5.
6.
7.
Letter from John Rendall, EPA Region I to
Margaret Chapman, Washburn resident (April 21;
1986). Concerning analytical results of
residential well samples.
Letter from John Rendall, EPA Region I to Wilson
Chapman, Washburn resident (April 21, 1986).
concerning analytical results of residential well
samples.
Letter from John Rendall, EPA Region I to Roger
Pinette, Washburn resident (April 21, 1986).
Concerning analytical results of residential well
samples.
Letter;from John Rendall, EPA
Richardson, Washburn resident
Concerning analytical results
samples.
Region I to Sheldon
(April 21, 1986).
of residential well
Interim Deliverables
1.
"Remedial Action Master Plan (RAMP)," NUS
Corporation (September 1983). (via transmittal
letter from Dennis Escher, NUS Corporation to
Elliot Thomas EPA Region I on September 20,
1983) . (Confidential Business Information.
redacted) .
"Final Field Operations Plan Remedial
Investigation Phase I," ICF Technology, Inc. for
Ebasco services, Inc. (October 1987).
"Draft Technical Directive Memorandum," ICF
Technology, Inc. for Ebasco Services, Inc.
(February 1988). (via transmittal letter from
Russell Boyd, EBASCO Services, Incorporated to
Michael Jasinski, EPA Region I on February 18,
1988) .
"Project scoping Meeting Phase II Remedial
Investigation/Feasibility study," Ebasco
Services, Inc. and ICF Technology, Inc. for EPA
Region I (March 4, 1988).
"Final Field operations Plan Remedial
Investigation Phase II," ICF Technology, Inc. for
Ebasco Services, Inc. (May 1988). NOTE:
Oversize "Boring, Well and Sample Location Map
Plate" is available for review, by appointment
only, at EPA, Region I, Boston, Massachusetts.
2.
3 .
4.
5.
-------
3.4
.,
3.6
3.7
Interim Deliverables(cont'd)
"Appendix D - Letter Addendum to Address
outstanding Agency Comments," Stephen A. Cox, .
REM-III site Manager, ICF Technology, Inc. (dated
November 10, 1988), addendum to the Phase II
Final Field Operations Plan of May 1988.
Remedial Investigation (RI) Reports
6.
1.
2.
3.
"Final Field Activities Summary Report Volume I,"
NUS Corporation (September 30, 1987).
"Final Field Activities Summary Report Volume
II," NUS corporation (October 8, 1987). NOTE:
Volume II consists of oversize "Plates 1-5" and
is available for review, by appointment only, at
EPA, Region I, Boston, Massachusetts.
"Final Supplemental Remedial Investigation and
Public Health Evaluation Report - Pinette's
Salvage Yard Site - Volume I," Ebasco Services,
Incorporated (March 1989).
"Final Supplemental Remedial Investigation and
Public Health Evaluation Report - Pinette's
Salvage Yard site - Volume II - Appendices,"
Ebasco Services, Incorporated (March 1989).
"Final Supplemental Remedial Investigation and
Public Health Evaluation Report - Pinette's
Salvage Yard Site - Volume III - Appendices,"
Ebasco Services, Incorporated (March 1989).
"Pinette's Salvage Final Supplemental RI Errata
Addendum," EPA Region I (May 1989).
4.
5.
6.
Work Plans and Progress Reports
1.
"Work Plan for Pinette's Salvage Yard Remedial
Investigation," NUS Corporation (September
1985) .
Memorandum from Liyang Chu, NUS Corporation to
David Frasca, EPA Region I (October 25, 1985).
Concerning proposed scope of work for second
round of sampling.
Memorandum from Liyang Chu, NUS Corporation to
John Rendall, EPA Region I (May 14, 1986).
Concerning proposed scope of work for third round
of sampling.
"Final Work Plan Phase I Remedial Investigation,"
ICF Technology, Inc. for Ebasco Services, Inc.
(October 1987).
2 .
3.
4.
-------
".
-
4.0
3.7
3.9
Work Plans and Progress Reports (cont'd)
5.
"Final Work Plan Phase II Remedial Investigation
and Feasibility study," ICF Technology, Inc. for
Ebasco Services, Inc. (May 1988). NOTE: Oversize
"Appendix C (Location Map) and Appendix D .
(Project Schedule) are available for review, by
appointment only, at EPA, Region I, Boston,
Massachusetts.
"Field Change Request Number 10," ICF Technology,
Inc. (July 22, 1988). concerning plans to modify
well installation procedures to include deep
bedrock monitoring.
6.
Health Assesments
1.
"Preliminary Health Assessment for Pinette's
Salvage Yard Site," Agency for Toxic Substances
and Disease Registry (ATSDR), U.S. Public Health
Service (via transmittal letter from Stephen D.
Von Allmen, United States Department of. Health
and Human Services to Linda Murphy, EPA Region I
(April 20, 1989).
Feasibility study (FS)
4.1
4.4
4.6
Correspondence
1.
Memorandum from J. Winston Porter, USEPA to
Regional Administrators Regions I, II, III, IV,
and IX (February 15, 1989). Concerning the
Delegation of selection of remedy authority for
Records of Decision scheduled for signature
during the 2nd quarter of fiscal year 1989.
Interim Deliverables
"Remedial Investigation (RI)/Feasibility Study
(FS) scoping Meeting," Ebasco Services, Inc. and
ICF Technology, Inc. (August 17, 1987).
Feasibility Study (FS) Reports
1.
1.
"Draft Final Feasibility Study Report - Pinette's
Salvage Yard site - Volume I," Ebasco Services,
Incorporated (March 1989).
"Draft Final Feasibility Study Report - pinette's
Salvage Yard site - Volume II - Appendices,"
Ebasco services, Incorporated (March 1989).
2.
-------
-,
5.0
4.6
4.9
Feasibility study (FS) Reports (cont'd)
3.
"Pinette's Salvage Yard Site Draft Final
Feasibility Study Errata Addendum," EPA Region I
(May 1989).
"Draft Final
section 2.0,
Site Town of
EPA Region I
4.
Feasibility Study Report - Volume I,
Revision I - Pinette's Salvage Yard
Washburn, Aroostook county, Maine,"
(May 1989).
Proposed Plans for Selected Remedial Action
1.
"EPA Proposes Cleanup Plan for the Pinette's
Salvage Yard Superfund Site," EPA Region I (March
1989).
Record of Decision (ROD)
5.1
5.2
5.3
Correspondence
1.
Letter from Merrill Hohman, EPA Region I to Alan
Prysunka, Maine Department of Environmental
Protection (August 5, 1988). Concerning the
notification of upcoming events prior to the ROD
process. Attachment B, OSWER Directive 9234.1-
01, can be reviewed at EPA Region I, Boston,
Massachussetts.
Applicable or Relevant and Appropriate Requirements
(ARARs)
1.
Cross-Reference: Letter from Dean C. Marriott,
Commissioner, State of Maine Department of
Environmental Protection to Michael R. Deland,
EPA Region I (May 24, 1989). concerning Maine
Department of Environmental Protection's
concurrence with EPA Region I's Remedial Action
remedy selection for the Pinette's Salvage Yard
Site, including the State's requirements for
concurrence. [Filed and cited as entry number 1
in 5.4 Record of Decision (ROD) as Attachment DJ.
Responsiveness Summaries
1.
Letter from Dean C. Marriott, Maine Department of
Environmental Protection to Michael Jasinski, EPA
Region I (April 11, 1989). Concerning review and
comments on the Proposed Plan, the Remedial
Investigation and Feasibility Study.
-------
".
9.0
5.3
5.4
Responsiveness Summaries (cont'd)
Letter from Charles R. Smith, Regional Civil
Engineer, Department of the Air Force to Michael
R. Deland, EPA Region I (April 13, 1989).
Concerning comments on the clean up plans for
PCBs.
Letter from Rebecca L. Hewett, Maine Department
of Environmental Protection to Michael Jasinski,
EPA Region I (April 14, 1989). Concerning
Addendum to Pinette's Salvage Yard Superfund Site
Testimony dated April 11, 1989.
Letter from Rebecca L. Hewett, Maine Department
of Environmental Protection to Michael Jasinski,
EPA Region I (April 14, 1989). Concerning review
comments on Pinette's salvage Yard Draft Final
Remedial Investigation, Feasibility Study and'
Proposed Plan dated March 1989.
Cross-Reference: "Responsiveness Summary," EPA
Region I (May 1989) [Filed and cited as. entry
number 1 in 5.4 Record of Decision (ROD) as
Attachment B].
Record of Decision (ROD)
2.
3.
4.
5.
1.
"Record of Decision - Remedial Alternative'
Selection," EPA Region I (May 30, 1989). .
State Coordination
9.1
Correspondence
1.
Letter from Michael R. Deland, EPA Region I to
the state Planning Office of Maine (February 19,
1985). Concerning notification of Pinette's
Salvage Yard as a proposed Superfund site.
Letter from Harold Kimball, State Planning Office
of Maine to Nancy Piligian, EPA Region I (April
26, 1985). Concerning certification of
Intergovernmental Review of proposed Superfund
site application.
Letter from Merrill S. Hohman, EPA Region I to
Alan Prysunka, Maine Department of Environmental
Protection (December 23, 1988). Concerning the
State's involvement in the estimation of health
risks.
2 .
3 .
-------
9.1
..
Correspondence (cont'd)
4 .
5.
Letter from Rebecca L. Hewett, Maine Department
of Environmental Protection to Mr. and Mrs. Roger
Pinette (January 9, 1989). concerning telephone
conversation regarding results of contaminated
well water.
Letter from Rebecca L. Hewett, Maine Department
of Environmental Protection to Michael Jasinski,
EPA Region I (February 16, 1989). Concerning
review comments on the Draft Proposal Plan for
the Pinette's Salvage Yard site.
11.0 Potentially Responsible Party (PRP)
11.9
.
PRP-Specific correspondence
1.
Letter from William Adams, EPA Region I to
Kathleen Bouchard, Avon C. Brown, Inc. (September
17, 1980). Concerning subpoena and requirement
to submit information regarding transportation
and disposal of transformers removed from Loring'
Air Force Base.
Letter from William Adams, EPA Region I to Joseph
Bellanceau (September 17, 1980). Concerning
subpoena and requirement to submit information
regarding transportation and disposal of
transformers removed from Loring Air Force Base.
Letter from william Adams, EPA Region I to
Francis Bellanceau (September 17, 1980).
Concerning subpoena and requirement to submit
info~ation regarding transportation and disposal
of transformers removed from Loring Air Force
Base.
Letter from William Adams, EPA Region I to Kirk
Soderberg, Soderberg Construction (September 17,
1980). concerning subpoena and requirement to
submit information regarding transportation and
disposal of transformers removed from Loring Air
Force Base.
Letter from William Adams, EPA Region I to Iver
Soderberg, Soderberg Construction (September 17,
1980). Concerning subpoena and requirement to
submit information regarding transportation and
disposal of transformers removed from Loring Air
Force Base.
2.
3.
4.
5.
-------
.
11.9 PRP-specific Correspondence (cont'd)
6.
".
7.
8.
.
9.
10.
11.
12.
13.
Letter from William Adams, EPA Region I to Roger
Pinette, Pinette's Salvage Yard (September 17,
1980). Concerning subpoena and requirement to
submit information regarding transportation and
disposal of transformers removed from Loring Air
Force Base.
Letter from william Adams, EPA Region I to Warren
Gibbs, Northern Electric Company (September 17,
1980). Concerning subpoena and requirement to
submit information regarding transportation and
disposal of transformers removed from Loring Air
Force Base.
Letter from william Adams, EPA Region I to ~oseph
Bellanceau (October 14, 1980). concerning
subpoena and requ~remen~ to submit information
regarding transportation and disposal of
transformers removed from Loring Air Force Base.
Memorandum to File (July 8, 1983). Concerning-
EPA Region I and U.S. Air Force Meeting-Agenda
with respect to the chronology of events at
Pinette's Salvage Yard.
Notice of Potential Liability and Request for
Information from Merrill S. Hohman, EPA Region I
to Paul Philbrick, Elco Electric, Incorporated
(March 6, 1989).
Notice of Potential Liability and Request for
Information from Merrill S. Hohman, EPA Region I
to Roger J. and Cynthia C. Pinette (March 6,
1989) .
Notice of potential Liability and Request for
Information from Merrill S. Hohman, EPA region I
to Mrs. Rita Pinette (March 6, 1989).
Notice of Potential Liability and Request for
Information from Merril S. Hohman, EPA Region I
to Mr. Iver Soderberg, Soderberg Construction
Company (March 6, 1989).
Notice of potential Liability and Request for
Information from Merrill S. Hohamn, EPA Region I
to Mr. Joseph Bellanceau (March 6,1989).
Notice of Potential Liability and Request for
Information from Merrill S. Hohman, EPA Region I
to Mr. Gary Vest, Deputy Assistant Secretary of
the Air Force, united States Air Force (March 6,
1989) .
14.
15.
-------
11.9
".
PRP-Specific Correspondence (cont'd)
16.
17.
18.
Routing and transmittal slip from David M.
Webster, EPA Region I to David Hopkins, Jr.,
United states Air Force, Loring Air Force Base,
Maine (March 21, 1989). concerning transmittal
of copies of Pinette's Salvage Yard site Proposed
Plan and notice letter to the Air Force.
Letter from Bernard Landman, USEPA to Lt. Col.
Laurent R. Hourcle, United states Air Force,
Bolling Air Force Base, Washington, D.C. (March
29, 1989). Concerning USAF's participation in
the cleanup of the Pinette's Salvage site to be
appropriate under the law.
Letter from Lt. Col. Laurent R. Hourcle, United
States Air Force, Bolling Air Force Base,
Washington, D.C. to Merrill S. Hohman, EPA Region
I (April 21, 1989). Concerning united States Air
Force response to EPA's Notification of Potential
Liability.
13.0 community Relations
13.1
Correspondence
1.
Telephone Notes (November 16, 1982). Barbara
Ikalainen, EPA Region I and Merrill Hohman, EPA
Region I. Concerning placement of temporary
cover and submittal of Hazard Ranking System
(HRS) score for consideration on the National
Priority List.
Telephone Notes (May 18, 1983). David Piebinan,
EFA Region I and Susan Kimball, WGAM-TV Presque
Isle, ME. Concerning occurrence of a meeting
between EPA Region I, Maine Department of
Environmental Protection, and the U.S. Air Force.
Telephone Notes (September 17, 1987). Michael
Jasinski, EPA Region I and Susan Bernard, WGAM-TV
Presque Isle, ME. concerning receipt of fact
sheet and future schedule of events.
Telephone Notes (September 18, 1987). Michael
Jasinski, EFA Region I and Susan Bernard, WGAM-TV
Presque Isle, ME. concerning filming of the
field crew and an interview with Michael
Jasinski.
2.
3 .
4.
-------
.
13.1
.~
.
13.2
Correspondence (cont'd)
5.
Letters from Michael Jasinski, EPA Region I to
Sheldon Richardson, Washburn Town Manager; James
Barressi, Northern Maine Regional Planning'
Commission; Gerry Bouchard, owner of Washburn
Food Mart; Roger Crouse, Chairman of Washburn
Planning Board; Mr. and Mrs. Terry Thompson,
Washburn residents; Daryl Sperrey, Washburn
resident; Mrs. Floyd Drost, Washburn resident
(October 7, 1987). concerning appreciation from
EPA Region I for information relating to
development of a Community Relations Plan.
Letter from Kathleen James, EPA Region I to
Sheldon Richardson, Washburn Town Manager (June
,3, 1988). Concerning receipt of the Community
Relations Plan.
Letter from Russell Boyd, Ebasco Services, Inc.
to Paul Knittel, EPA Region I (June 6, 1988).
Concerning receipt of the Final Revised Community
Relations Plan.
Letter from Michael Jasinski, EPA Region I to Mr.
and Mrs. Roger Pinette (March 8, 1989).
concerning new test results of drinking water
samples collected on January 11, 1989 including a
copy of the analytical data'sheets generated by
the EPA laboratory.
6.
7.
8.
Community Relations Plan
1.
"community Relations Plan for Washburn, Maine
Pinette's Salvage Yard". (via routing slip from
Dave Pickman, EPA Region I to Susan Santos, EPA
Region I on April 26, 1983). Concerning removal
action.
"summary of Remedial Action Master Plan for
Washburn, Maine,". Concerning removal action.
"community Relations Plan for Immediate Removal
at Pinette's Salvage Yard Site," Washburn, Maine.
Schedule of Community Relations Plan Interviews
(September 24 and 25, 1987). Concerning remedial
action.
"Final Revised Community Relations Plan Pinette's
salvage Yard-Washburn, Maine," ICF Technology,
Inc. for Ebasco Services, Inc. (June 1988).
Concerning remedial action.
2.
3.
4.
5.
-------
13.3
".
13.4
13.5
News Clippings/Press Releases
"Environmental News," Concerning the Allocation
of $200,000 from Superfund to Remove PCB-
Contaminated Soil from Pinette's Salvage Yard,
EPA Region I (october 12, 1983).
"Superfund Cleanup to Beqin at Pinette's Salvage
Yard," EPA Region I (October 12, 1983).
"Environmental News," Concerning the Removal of
PCB-contaminated Soil from Pinette's Salvage
Yard, EPA Region I (November 7, 1983).
EPA - Environmental News, "EPA Announces Public
Meeting on Preliminary Cleanup Recommendation for
Pinette's salvage Yard Site," EPA Region I (March
6, 1989).
"The United states Environmental Protection
Agency Invites Public Comment on the Feasibility
study and Proposed Plan for the Pinette's Salvage
Yard Site in Washburn, Maine and Announces the
Availability of the site Administrative Record,"
EPA Region I (March 8, 1989). .
Public Meetings
1.
2.
3.
4.
5.
1.
Cross-Reference: Transcript, Public Hearing
(April 11, 1989) [Filed and cited as entry number
1 in 5.4 Record of Decision(ROD) in Attachment
B] .
Meeting Agenda, EPA Region I, Town of Washburn,
Maine, Public Informational Meeting (includes 20
graphics presented at the meeting).
2.
Fact Sheets
1.
"Superfund Program Fact Sheet for Pinette's
Salvage Yard site in Washburn, Maine," EPA Region
I (September 1987). .
"Superfund Program Fact Sheet for Pinette's
Salvage Yard site in Washburn, Maine," EPA Region
I (November 1987). (via transmittal letter from
Michael Jasinski, EPA Region I to Sheldon
Richardson, Town Manger, Washburn, Maine.)
"Superfund Program Fact Sheet for Pinette's
Salvage Yard site in Washburn, Maine," EPA Region
I (June 1988).
2 .
3.
-------
16.0 Natural Resource Trustee
16.1
-.
16.4
correspondence
Letter from Kenneth Finkelstein, National Oceanic
Atmospheric Administration to Michael Jasinski,
EPA Region I (October 9, 1987). Concerning
potential for National Oceanic Atmospheric
Administration resources to be impacted in the
Aroostook River.
Letter from Kenneth Finkelstein, National Oceanic
Atmospheric Administration to Michael Jasinski,
EPA Region I (November 5, 1987). Concerning
sampling of sediments/soils in the drainage
system~
Trustee Notification and Selection Guide
1.
2.
1.
"Trustee Notification Form," EPA Region. .1
(July 7, 1987).
Letter from Merrill Hohman, EPA Region I to
Sharon Christopherson, National oceanic
Atmospheric Administration (July 20, 1987).
Concerning EPA Region I notification about
potential damages to natural resources under
NOAA's jurisdiction. .
Letter from Merrill Hohman, EPA Region I to
William Patterson, Department of the Interior
(July 20, 1987). Concerning EPA Region I
notification about potential damage to natural
resources under DOI's jurisdiction.
2.
3.
17.0 Site Management Records
17.4
Site Photographs/Maps
1.
Draft Property Map, EPA Region I (1986). (Based
upon NUS corporation Research and Field Map).
*
The records cited in entry numbers 2 through 15
may be reviewed, by appointment only, at EPA
Region I, Boston, Massachusetts.
2 .
3-1/2" x
Heaviest
3-1/2" x
Heaviest
1986) .
5" Color Photograph Illustrating
contamination (April 1986).
5" Color Photograph Illustrating
contamination and Standing Water
Area of
(April
Area of
3 .
-------
.
17.4
site Photographs/Maps (cont'd)
4.
. -
5. .
6.
7.
8.
9.
. 10.
11.
12.
13.
14.
15.
3-1/2" x 5" Color Photograph Illustrating the
Field with a Groundwater Outbreak Located Across
the street from Pinette's Salvage Yard (April'
1986).
3-1/2" x 5" Color Photograph Illustrating Sample
Collection Activities Using a Power Auger (May
1986) . .
3-1/2" x 5" Color Photograph Illustrating the
Power Auger in Use (May 1986).
3-1/2" x 5" Color Photograph Illustrating the
Collection of a Soil Sample from a Hand Auger
(May 1986).
3-1/2" x 5" Color Photograph Illustrating the
surveying of Sample Points (May 1986).
3-1/2" x 5w Color Photograph Illustrating the NUS
Corporation Sampling Van (May 1986).
4" x 6" Color Photograph Illustrating the Field
with a Groundwater outbreak Located Across the
Street from Pinette's Salvage Yard. (August 12,
1988) .
4" x 6" Color Photograph Illustrating Approximat~
Spill Area. (August 12, 1988).
4" x 6" Color Photograph Illustrating Drainage
Swale Emanating from Larger On~site Pond.
(August 12, 1988).
4" x 6" Color Photograph Illustrating the End of
the Drainage Swale located Near the Culvert.
(August 12, 1988).
4" x 6" Color Photograph Illustrating Gravel
Driveway and Garage On-site and Spill Area.
(August 12, 1988).
4" x 6" Color Photograph Illustrating the Larger
of the Two On-site Ponds. (August 12, 1988).
17.8
State and Local Technical Records
1.
Notes (author unknown) to Jack Krueger, Maine
Department of Environmental Protection (August 5,
1981). Concerning sample collection activities
on July 29, 1981.
Memorandum from Tom Potter, Maine Department of
Environmental Protection to John Krueger, Maine
Department of Environmental Protection
(August 11, 1981). concerning organic chemical
analyses of samples from the Washburn Transformer
Fluid Spill Investigation.
2.
-------
'17.8
"-
-
state and Local Technical Records (cont'd)
3.
Letter from Jack Krueger, Maine Department of
Environmental Protection to Andrew Lauterback;
EPA Region I (August 12, 1981). Concerning'
concentrations of PCBs and chlorinated benzenes
at the Washburn, Maine, Pinette site. .
Letter from Jack Krueger, Maine Department of
Environmental Protection to Andrew Lauterback,
EPA Region 1 (October 22, 1981). Concerning
summary of the technical" aspects and cost
estimate of the PCB clean-up at Washburn, Maine,
Pinette site.
4.
-------
".
section II
Gui4ance Documents
-------
"
PINETTE'S SALVAGE YARD
NPL SITE ADMINISTRATIVE RECORD
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston,
Massachusetts.
General EPA Guidance Documents
1.
2.
3.
4.
"Appendix D - Protection of Wetlands: Executive Order
11990,. 42 Federal Reqister 26961 (1977).
Memorandum from John W. Lyon, Toxic Substance Division,
USEPA to Sanford 'W. Harvey, Jr., Enforcement Division, EPA
Region IV (August 3, 1979). concerning applicability of PCB
regulations to spills which occurred prior to the effective
date of the 1978 regulation.
u.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Community Relations in Superfund:
. Handbook (Interim Version) (EPA/HW-6), September 1983.
A
u.s. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Guidance on Feasibilitv studies
under CERCLA (Comprehensive Environmental Response. .
Compensation. and Liability Act) (EPA/540/G-85/003), June
1985.
5.
u.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Guidance on Remedial Investiqations
under CERCL~ (Comprehensive Environmental Response.
Compensation. and Liability Act) (EPA/540/G-85/002), June
1985.
6.
"National oil and Hazardous Substances Pollution contingency
Plan," Code of Federal Requlations (Title 40, Part 300),
1985.
7.
u.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Superfund Remedial Desiqn and
Remedial Action Guidance (OSWER Directive 9355.0-4A), June
1986.
8 .
U.S. Environmental Protection Agency. Office of Research
and Development. Hazardous Waste Engineering Research
Laboratory. Handbook for Stabilization/Solidification of
Hazardous Wastes (EPA/540/2-86/001), June 1986.
-------
.
General EPA Guidance Documents (cont'd)
9.
10.
-
11.
12.
.
13.
14.
15.
Comprehensive Environmental Response. Compensation. and
Liabilitv Act of 1980, amended October 17~ ~986.
u.s. Environmental Protection Agency. Office of Emergency
and Remedial Response. Superfund Publgc Health Evaluation
Manual (OSWER Directive 9285.4-1), DctoDer ~9B6.
U.S. Environmental Protection Agency. Of£ioe of Emergency
and Remedial Response. Draft Guidan-~ ~ Femedial Actions
for contaminated Groundwater at Superf~ Sites (OSWER
Directive 9283.1-2), October 1986.
u.S. Environmental Protection Agency. O£fice of Solid Waste
and Emergency Response. Interim Guid~~ce on Superfund
Selection of Remedv (OSWER Directive 9355.0-19), December
24, 1986.
u.s. Environmental Protection Agency. Office of Solid
and Emergency Response. Data Oualitv Db1~ctives for
Remedial Response Activities: De~elopment Process
(EPA/540/G-87/003), March 1987.
"Part 761 - Polychlorinated Biphenyls 'PCBs) Manufacturing,
Processing, Distribution in Commerce, a.nd.Use Prohibitions,"
40 Code of Federal Requlations 194 (July 1, 1987).
Waste
16.
Memorandum from J. winston Porter to Addressees ("Regional
Administrators, Regions I-X; Regional ~ounsel, Regions I-X;
Director, Waste Management Division, Regions, I, IV, V, VII,
and VIII; Director, Emergency and Remedial Response
Division, Region II; Director, Hazardous Waste Management
Division, Regions III and VI; Director, Toxics and Waste
Management Division, Region IX; Director, Hazardous Waste
Division, Region X; Environmental Services Division
Directors, Region I, VI, and VII"), (July 9, 1987).
Concerning interim guidance on compliance with applicable or
relevant and appropriate requirements).
Memorandum from Stephen Joyce and Jamie Katz, EPA Region I
to Herrill Hohman and Patricia Meaney, LPA Region I (July
24, 1987). Concerning the evaluation of the Toxic
Substances Control Act (TSCA) Requirements as Applicable or
Relevant and Appropriate Requirements (ARARs) for the Re-
Solve, Inc. Superfund site.
-------
General EPA Guidance Documents (cont'd)
17.
"-
18.
19.
20.
21.
22.
u.s. Environmental Protection Agency. Office of Health
Environmental Assessment. A Compendium of Technoloqies
in the Treatment of Hazardous Waste (EPA/625/8-87/014),
September 1987.
Memorandum from Denise M. Keehner, Chemical Regulation
Branch, USEPA to Bill Hanson, site Policy and Guidance
Branch, USEPA (October 14, 1987). Concerning comments on
the PCB Contamination-Regulatory and Policy Background
Memorandum.
and
Used
"Guidelines for PCB Levels in the Environment," The
Hazardous Waste Consultant, pp. 26-32
(January/February"1988).
Memorandum from Christopher Zarba, USEPA to Jane Downing,
EPA Region I (April 11, 1988). Concerning the application
of Interim sediment critieria values at Sullivan's Ledge.
Superfund site.
u.s. Environmental Protection Agency. Office of Emergency \
and Remedial Response. Draft Guidance on Remedial Actions
for contaminated Groundwater at Superfund sites (OSWER
Directive 9283.l-2), April 1988.
"Summary of the Requirements: Land Disposal Restrictions
Rule," EPA Region I (no date listed).
Pinette's Salvaqe Yard NPL site specific Guidance Documents
1.
2.
"Classification of Surface Waters," Maine Department of
Environmental Protection (September 1979).
"Project Summary: Report on the Feasibility of APEG
Detoxification of Dioxin-Contaminated soils," Albert Klee,
Charles Rogers, and Thomas Tiernan, EPA Region V (April
1984).
3 .
u.S. Environmental Protection Agency. Office of Health and
Environmental Assessment. Risk Analvsis of TCDD
contaminated Soil (EPA-600/8-84-031), 1984.
4 .
Record of Decision, Wide Beach, New York, EPA Region II, New
York, New York (September 30, 1985).
-------
site specific Guidance Documents (cont'd)
5.
'-
6.
7.
8.
9.
10.
11.
12.
13.
14.
"Project Summary: Destruction of PCBs-Environmental
Applications of Alkali Metal polyethylene Glycolate.
Complexes," Frank J. Iaconianni, EPA Region V (December
1985).
"Chemical Reaction of Polychlorinated Biphenyls on Soils
with Poly(Ethylene Glycol)/KOH," D.J. Brunelle and Daniel
A. Singleton, General Electric corporate Research and
Development (1985).
"PCB Destruction: A Novel Dehalogenation Reagent,"
Alfred Kornel and Charles Rogers, EPA Region V (1985).
Enforcement Decision Document, Pepper Steel, Florida, EPA
Region IV, Atlanta, Georgia (March 19, 1986).
u.S. Environmental Protection Agency. Office of Health and
Environmental Assessment. Development of Advisorv Levels.
for Polvchlorinated Biphenvls (PCBs) Cleanup (OHEA-E-187),
May 1986.
"Ground Water Classification system," Land and Water
Resources Council (May 1986). .
"In Situ vitrification of PCB-Contaminated Soils," Electric
Power Research Institute (EPRI) (prepared by Battelle,
Pacific Northwest Laboratories) (October 1986).
"Guidelines for Ground-Water Classification under the EPA
Ground-Water Protection stategy," USEPA (December 1986).
"Chemical Destruction of Chlorinated Dioxins and Furans,"
(Abstract) EPA Region 5, Charles J. Rogers & Alfred Kornel,
EPA Region V (1986).
"Project Summary: PCB Sediment Decontamination-
Technical/Economic Assessment of Selected Alternative
Treatments," Ben H. Carpenter, EPA Region V (March 1987).
15.
"Project Summary: Catalytic Dehydrohalogenation: A Chemical
Destruction Method for Halogenated organics," EPA Region V
(March 19B7).
16.
"PCB spill Cleanup Policy," (40 CFR Part 761), Federal
Reqister, (April 2, 1987).
-------
site sDecific Guidance Documents Ccont'd}
17.
"-
18.
19.
20.
.
21.
22.
23.
"Chemical Destruction ofHalogenatedAliphatic Hydrocarbons"
(United states Patent Number 4,675,464), Charles J. Rogers
and Alfred Kornel, EPA Region V (June 23, 1987).
Memorandum (to Water Division Pinette's Superfund Site
Review Team,) EPA Region I from Anthony Pisanelli, EPA
Region I (August 18, 1987). Concerning handout from
Pinette's Feasibility Study (FS) scoping Meeting.
Record of Decision, Liquid Disposal, Incorporated, utica,
Michigan, EPA Region V, chicago, Illinois (September 30,
1987).
U.S, Environmental Protection Agency. Office of Solid Waste
and Emergency Response. The Superfund Innovative Technoloqy
Evaluation Proqram: Proqress and Accomplishments
(EPA/540/5-88/001), February 1988.
Memorandum from Alfred Kornel, EPA Region V to Charles J.
Rogers, EPA Region V (June 24, 1988). Concerning analysis
of KPEG/Guam Soil PCB Detoxification from the Guam Field
Test.
Letter from James E. Hansen, Geosafe Corporation to Mlchael
Jasinski, EPA Region I (July 13, 1988). Concerning
information on in situ vitrification Technology.
Record of Decision, Rose Disposal Pit, Lanesborough,
Massachusetts, EPA Region I, Boston, Massachusetts
(September 23, 1988).
24.
"Laboratory Scale Testing Report: KPEG Processing of Wide
Beach Development site Soils," Galsen Research corporation
(September 30, 1988).
25.
Letter from Alfred Kornel, EPA Region V to Charles J.
Rogers, EPA Region V (October 13, 1988). concerning Guam
II, Retreatment of Guam Soils and the continuation of APEG
for PCB Detoxification.
26.
Letter from Lanny D. Weimer, Resources Conservation Company
to Angelo L. Masullo, ICF Technology, Incorporated (December
16, 1988). Concerning technical paper entitled "Basic
Extractive Sludge Treatment (B.E.S.T.)* - Demonstrated
Available Technology."
-------
site specific Guidance Documents (cont'd)
27.
"-
28.
29.
30.
31.
.
32.
1
"PCB Sediment Decontamination Processes Selection for Test
and Evaluation," Ben H. Carpenter, Engineering Research
Applications and Donald L. Wilson, EPA Region V (1988)..
"Evaluation of the B.E.S.T.* Solvent Extraction Sludge
Treatment Technology Twenty-Four Hour Test," Gerard W.
Sudell, Enviresponse, Incorporated (no date listed).
"Guidance for Compliance with Requirements of the Safe
Drinking Water Act," Chapter 3 of the Draft Clean Water
Act/Safe Drinking Water Act (CWA/SWDA) Volume of the
Superfund Compliance Manual (no date listed).
"Draft Standard Review Plan Information Requirements" (no
date listed).
"A Summary of Bioassay Tests on APEG Byproducts," (no date
listed).
"Field Experience with the KPEG Reagent," (Abstract) Alfred
Kornel, Charles J. Rogers and Harold Sparks, EPA Region V.
-------
J~
".
ATTACHMENT C
PINETTE'S SALVAGE YARD SUPERFUND SITE
ROD DECISION SUMMARY
SITE-SPECIFIC PCB SOIL
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
SUGGESTED HUMAN HEALTH RISK-BASED SOIL TARGET
CLEANUP LEVELS FOR THE PINETTE'S SALVAGE YARD SITE
Key contaminant(s):
PCBs
-.
Exposure of concern:
70 years-lifetime
soil ingestion, plus
frequency of contact
body weight 70 kg
dermal contact
100 days/365 days
Effect of concern:
cancer
Target risk level:
10-5 PCBs (total)
Exposure Parameters:
soil ingestion rate: 100 mg/day (see
attached OSWER Directive 9850.4)
oral absorption-soils: 30% semi-VOCs
dermal contact rate: 500 mg soil/day
dermal absorption-soils: 5% semi-VOCs
Soil Intake averaged over a lifetime:
Oral Intake
+
Dermal Intake
SI = [(100 mg soil/day x 0.30) + (500 mg soil/day x 0.05») x
[100 days % 365 days] x [1 % 70 kg] x [70 yrs % 70 yrs]
SI = [(30 mg soil/day) + (25 mg soil/day)] x [100 days %
365 days] x [1 % 70 kg] x [70 yrs % 70 yrs]
SI = 0.22 mg soil/kg body-weight/day
lifetime
over a
70 yr
Target Risk Level = 10-5 PCBs (total)
PCB Target Chronic Daily Intake
=
[PCB target risk level %
PCB potency factor)
CDI (PCBs) =
[10-5 % 7.7 (mg
PCB/kg/day}-1]
1.3 x 10-6 mg PCB/kg/day
CDI (PCBs) =
Target Cleanup Level (PCBs)
=
[PCB target chronic daily
intake (CDI») % soil intake
(5I) ]
=
[1.3 x 10-6 mg PCB/kg/day %
0.22 mg soil/kg/day]
Target Cleanup Level (PCBs) -=
6 ug PCBs/g soil -= 6 pprn PCBs
(@ 10-5 total target risk
-------
"
.,: '.'..,
O.'~ t
/ ~;.;, OJ
1~3
~.., . ~.
'.. .,
'. "'0' \-
UNITEO STATES ENVIRONMENTAL PROTECTION AGENCY
WASI-IINGTON. O.C. 20~60
JAN 2 7 Ise;
..... .... ....
-,.:.: ....:.;.~ ....; :0.':':::'.: --::;
"0
OSWER Directive 9850.4
HrMO RANt) t]X
SUBJECT:
Interim,.. Fina~dance
~. Wi~stin ~rter
Assistant~dministrator
Reqional Administrators
Reqions I-X
tor Soil Inqestion Rates
FROM:
TO:
Executive
8m""!. ry:
Risk assessments are conducted at Supertund sites as part ot
Remedial Investiqations required by the Proposed National
Contingency Plan, and may be conducted at RCRA faciliti.s
undergoing corrective action as described in the soon-to-be
Proposed RCRA Corrective Action Rule, to estimate the risk from
exposure to substances. Within the risk assessment, an exposure
assessment is performed which is based on various exposure
assumptions such as 50il ingestior, r~t.s. This interim final
quidance provides recommended soil ingestion rate a~sumptlons c:
0.2 gram per day tor children aged 1 year through 6 years and 0.1
gram per day for older age groups, in the absence ot site
specific data.
I~troduotion t~~ !~c~~round:
CUrrartt Aq~c:y quidance that might be used within the OSWER
proqrama f~ developinq risk assessments provides ranqes ot
difl~ren~ C~11 1nqcction rates. However, no quidance is provided
reqardinq ~ c:lcction ot an ingestion rat. trom within these
range.. In Crt18t' to promote cons istency wi thin Agenc... quidanc8
and the UCQ ot realistic, conservative exposure scenario.
throughout the CERCLA and RCRA proqrams, this in~erim final
quidance provides specified assumption~ to bQ mado tor soil
-------
2
OSWtR Oir. 9850.4
I~teri. riB.1 au1~.nce tor 8011 I~qe.t1on Rate.:
.
.()
This interim tinal quidance supersedes previous progra~
related guidance (Superfund Public Health Evaluation Manual,
October, 1986, OSWER Directive 9285.4-01) only with reterence to
soil inqestion rates and should be used by regional statt .._~ are
responsible tor conducting and evaluating risk assessments In
OSWER related proqrams. This interim tinal quidance is based on
the most recent reliable data available on soil ingestion rates.
It may be revised to retlect new data the Agency may review tha~
would signiticantly attect risk assessment results.
In developing exposure scenarios used in program risk
assessments, a soil ingestion rate of 0.1 grams per day should be
used for adults and a 50il ingestion rate of 0.2 grams per day
should be used to~ children who are one year through six years ot
aqe. These rates are based on the most recent reliable data
reviewed by th- A~ency, and represent reasonably cons~~/Qtive
values. This guidance does not address children who 8xnlbit -
abnormal mouthing behavior (pica). The occurrence ot pica
behavior and the associated rates ot soil ingestion have not be.n
well detined. Without this intormation, risk cannot be
quantitied tor children with pica behavior.
There may be cases where site- or facility-specitic data
exist on soil ingestion rates or the occurrence ot pica behavior
ot children. In these cases, deviation from this quidance may be
appropriate. However, the data supporting this deviation should
be provided within the related risk assessment. It the data are
provided by the potentially responsible party in the Supertund
program or the owner/operator in the RCRA program, these data
should be review~d and verified by tho risk assessment experts in
the Reqions, who may also choose to consult with Headquarters.
Contact.:
It th4r. are any general questions regarding this interim
tinal qui4~o, plea.. contact Sherry Sterling, eFTS) 382-4826,
ot my .tat~~ 'or program specific information, the following
statt may ~~ contacted:
RCRA
CERCLA/Furld
CERCLA/Entorce~ent
Alec McBride (FTS)382-7045
Dave Bennett (FTS)475-9486
-------
~
. .
.'
cc:
'"
J
OSWER Directive 9850.4
Bruce Diamond, OWPE
Henry L. Longest II, OERR
Sylvia Lovrance, OSW
Timothy Fields, ERD
Stephen Lingle, HSED
Russell H. Wyer, HSCO
Joseph Carra, PSPD
David Bussard, WHD
Lloyd Guerci, CED
Susan Bromm, RED
Directors, Waste. Management Divisions, Regions I, IV, V,
VII, VIII"
Director, Emergency and Remedial Response Division, Reqion
II
Directors, Hazardous Waste Management Divisions, Region III
VI
Director, Toxics and Waste Management Division, Region IX
Director, Hazardous Waste Division, Region X
CERCLA Branch Chiefs, Regions I-X
-------
~t
ATTACHMENT D
PINETTE'S SALVAGE YARD SUPERFUND SITE
ROD DECISION SUMMARY
STATE OF MAINE DECLARATION
-------
MAV-26-89
FRI
16:29
MAINE
DEP
P.02......03
\,,~\1\O"'&tI-t
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. .,.., . .. ", ;:;
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.-
..~
STATE OF MAINE
Department of Environmental Protection
.-A'III ~'HX: RAY eUI\.(\I'IO. 140SP,TAJ. 5TnEET. AUOUSTA
M"I\. "DOnfU: $'111. 140.". 51.lion 17. ~u".. ~W
20702"'7188
JOHN It. "cIlS"""", JIt.
GOVcn.,OA
DUN Co M"",,'on
COIoI...r:;SIONCR
Hay 24. 1989
Michael Deland
Reglon~l Administrator
I
U. S. EPA i
Region I (RAA~2203)
J. r. Kennedy'Federal
Boston. Massachusetts
Bldg.
02203-2211
REI Pinette SalvAge Yard Site in Washburn, Maine
Dear Mikel
The Maine Department of Environmental Protection (Department) hat reviewed the
Hay 3. 1989 D~.ft Record of Decision (ROD) with regard to the Remedial Action
remedy selectIon lor the Pinette's Salvage Yard Site in Washburn, Haine. .
I . .
Bued on that' revieW', the Department concurs with the selected remedy of
off.site incineration lor soils contaminated at levels greater than SO ppm,
PCBt, on-sitt solvent extraction for soils contaminated with PCB levell between
5 to SO ppm, burial of soill contaminated with PCB levels between 1 and S ppm,
and expedited! groundwater recovery and treatment. This concurrence is bS81!d
upon an underatanding that.
A.
The D~partment will be afforded reasonable opportunity to review and
approve of operational designs and monitoring plans for the site cleanup;
An institLtional control (e.g. deed restriction) be establi9hed on the site
that restricts or prohibits the instsllation of groundwater wells e~cept 85
necessary'to effect t.he site clean up, or the excavation or disturbing of
coil in a~y and all areas on the site where PCB-contaminated coils were
excavated',
t
I
The sroun~water extraction and treatment system will be designed to remo~e
and lreat all identified contaminants present in the groundwater. including
without limitation, PCBs. ~ile the Department recogni~e9 that achieving a
groundwater cleanup level of 0.5 ppm for PCBs may be technically
impracticable, the Department will defer judgement on this iS6ue until the
treatment system ha9 been designed and installed and its elfectiveneS9
evaluated by my staff.
\
B.
c.
: I
i
i
-------
M A,V - 26- e 9
FRI
16:29
,..AINE
DEP
P.0:3/0:3
-2-
~
-J
The Deparlment'. financial obligations for this Site, when committed .fter
completion and review of the remedial design, will be limited to a maxImum
of ten (lb) percent of the costs of the remedial action, including a11
future ma}ntenance. Based upon the draft ROD, the Department" share of
the coet,lwill be approximately $423,000. The Department will aslume
financial respon.ibility for operalion or maintenance of the groundwater
extractio~ and treatment system, beginning with the eleventh (11th) year
after co~enc~ment of operation of 8uch s,stem. Ihould continued operation
be required to meet tne established cleanup g0816. Those funds will be
allncated'by the Department from the Uncontrolled Hazardous Substance Sitt.
Bond Acco~nt.' ,
As a final no~e. it i. the Department'~ understanding that the Town of Washburn
has reviewed .nd 18 supportive of the proposed remedy selection.
D:
Sincerely,
D~(Ph-;,v
CO~n11SSIONER ,
I
, .
DCM/ei
-------
y
..J
ATTACHMENT B
PINETTE'S SALVAGE YARD SUPERFUND SITE
ROD DECISION SUMMARY
-------
EPA WORK ASSIGNMENT NUMBER: 148-1L34
EPA CONTRACT NUMBER: 68-01-7250
EBASCO SERVICES INCORPORATED
FINAL RESPONSIVENESS SUMMARY
PINETTE'S SALVAGE YARD SUPERFUND SITE
\-;ASHBURN, Y..AINE
t1AY 1989
Prepared By:
Approved By:
~X:Q~
-------
TABLE OF CONTENTS
PREFACE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
"'"
I.
O\~R\~EW OF THE PREFERRED ALTERNATIVE AND OTHER REMEDIAL
ALTEPJ,ATIVES CONSIDERED IN THE FEASIBILITY STUDY.......... 3
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS ......... 4
III. SUMY~Y OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS ............... 5
A.
B.
STATE OF MAINE COMMENTS......................... 5
COMMENTS FROM THE PRPs.......................... 8
IV.
SID~~Y OF C."m;CERNS RAISED BY A LOCAL OFFICIAL DURING THE
FORY.AL COl-!11""i.NT PERIOD AND :I}\f'ORMhL QUESTION AND ANSWER
PERIOD OF THE April 11, 1989 PUBLIC HEARING AND EPA
RESPONSES TO THESE COMMENTS...............~.............. 11
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES AT THE PINETTE'S
SALVAGE YARD SITE
ATTACr~~NT B - COKPLETE TEXT OF STATE OF MAINE COMMENTS
ATTACHME~~ C - COY.FLETE TEXT OF PRP COMMENTS
ATTACHY.ENT D - COMPLETE TEXT OF THE PUBLIC HEARING TRANSCRIPT
-------
Preface
The U.S. Environmental Protection Agency (EPA) held a public
comment period between March 15, 1989 and April 14, 1989 for
interested parties to comment on the supplemental Remedial
Investigation (supplemental RI), Feasibility study (FS), and
Proposed plan for the Pinette's Salvage Yard superfund site. The
supplemental RI, released by EPA in March 1989, examined the
nature and extent of contamination at the site. The FS, also
released by EPA in March 1989, examined and evaluated various
cleanup options, called remedial alternatives, for addressing the
contamination at the site.
EPA announced its preliminary recommendation of a preferred
alternative for the cleanup of the site in the proposed Plan
issued at the start of the public comment period.
The purpose of this Responsiveness Summary is to document
EPA responses to the comments and questions raised during the
public comrnent period. EPA considered all of the comments
sUIT~arized in this document before selecting a final remedial
alternative for the Pinette's Salvage Yard site.
This Responsiveness Summary is divided into the following
sections:
I.
overview of the Preferred Alternative and other
Re~edial Alternatives Considered in the Feasibilitv
StudY - This section briefly outlines the remedial
alternatives, including EPA's preferred alternative,
that are described and evaluated in detail in the FS
and the Proposed Plan.
II.
Eackaround on Communitv Involvement and Concerns
section provides a brief history of the site and
cor.~unity interests and concerns regarding the
Pine~te's Salvage Yard site.
- This
of
III. SummarY of Comments Peceived Durina the Public Comment
Period and EPA Responses to These Cor.rnents - This
section sum~arizes both written and oral comments
received by EPA during the public cor~ent period and
provides EPA's responses to them. These comments are
organized in two categories: A) cor.~ents from the
State 0: p.aine (excluding those pertaining to the
supplemental RI which are included in Attachment E) ;
and B) comments from potentially responsible parties
(PRPs) .
-------
IV.
.~
This Responsiveness Summary also includes the following
attachments:
Attachment ~ - This attachment lists the commun:~y relations
activities conducted by EPA during the recent rewedial
efforts performed at the Pinette's Salvage Yard site.
Attachment B - This attachment consists of the complete text
of ~ritten comments offered by the state of Maine.
~ttach~ent C - This attachment includes the complete text of
~ritten comments received from PRPs.
Attachment D - This attachment consists of the complete text
of the April 11, 1989 Public Hearing transcript.
~ttach~ent E - This section contains EPA's responses to
Final supplemental RI comments.
-------
I.
OVERVIEW 01 THE PREFERRED ALTERNATIVE AND OTHER REMEDIAL
ALTERKATIVES CONSIDERED IN THE FEASIBILITY STUDY
EPA'S Preferred Alternative for tbe Pinette's Salvage Yard site
EPA has developed a comprehensive three-part cleanup plan
to address soil and groundwater contamination at the Pinette's
Salvage Yard site. The preferred alternative is a combination of
two source control (SC) alternatives designed to address the soil
contamination problems at the site and a management of migration
(MM) alternative designed to address the migration of groundwater
contamination at the site.
EPA's preferred alternative involves the excavation and
treatment by off-site incineration and on-site solvent extraction
of the PCB- and other organic chemical-contaminated soils until
they meet required target cleanup levels. In addition, the
overall site remedial alternative involves collection and
treatment by carbon adsorption of the contaminated deep
groundwater. The shallow groundwater will be treated (if
necessary) following soil excavation.
Other Alternatives Evaluated in tbe Feasibility study
The FS prepared by EPA for the pinette's Salvage Yard site
identifies and evaluates three MM alternatives and seven SC
remedial alternatives for achieving EPA's cleanup objectives for
the site.
The proposed Plan, which identifies the alternatives EPA
reco~~enced for the site, also contains brief descriptions of
each 0: the al~ernatives considered in detail in the FS. These
SC and }~ alternatives, including the preferred alterna~ives
identified in the Proposed plan, are listed below. More complete
descriptions of these alternatives are contained in the FS and
Proposed Plan for the site, which are available as part of the
Administrative Record for the site at the ~ashburn Town Offices
and the EPA Records Center at 90 Canal Street, Boston,
Massachusetts.
1. SOw~CE CONTROL ALTERNATIVES
The purpose of implementing an SC alternative at the
Pine~te's Salvage Yard site is to address soil contamination,
which is considered to be a source of groundwater contamination.
The FS for the Pinette's Salvage Yard site evaluated the seven SC
alterna~ives listed below.
Fl. y.inimal No-Action
#2. On-Site capping with Slurry Wall
#3. Off-site Landfill of Contaminated Soils
*4. Incineration (included in EPA's Preferred SC
-------
#5.
#6.
#.7.
Alternative)
On-site Solvent Extraction (included in EPA's Preferred
SC Alternative)
On-site Dechlorination
In-Situ Vitrification
2.
~JU~AGEMENT OF MIGRATION ALTERNATIVES
The FS also evaluated three MM alternatives to
migration of contaminants by collecting and treating
ground~ater to prevent the spread of contamination.
alternatives are listed below.
manage the
contaminated
These
#.1.
#.2.
~3.
Minimal No-Action
Groundwater Collection and Treatment
Expedited Groundwater Collection and
Prefe=red MX Alternative)
Treatment (EPA'S
II.
BACKGROUND ON COMMUNITY I~~OLVE~XNT AND CONCERNS
In June 1979, three electrical transformers were brought to
the Pinette's Salvage Yard site from Loring Air Force Base,
located near Limestone, Maine. The transformers were alleged to
have been ruptured at the site, spilling an estImated 1,000
gallons of dielectric fluid containing pOlychlorinated biphenyls
(P~Bs) onto ~~e soil. Residents first became aware of possible
contamination pro~lerns at the Pinette's Salvage Yard site shortly
a:ter the spill occurred.
Prelirnina~ investigations by the Maine Depart~ent of
Environmental ~otection (DEP) revealed that hundreds of gallons
of PCBs were spilled at tne site, rather than a small spill, as
was initially rep~rted by the local news media. According to
several local officials, residents' anger directed against the
government and the Air Force Base increased as Loring officials
apparently refused to acY~owledge any responsibility for the
spill or take any part in cleanup efforts.
EPA and DEP attempts to include Loring Air Force Base in
plans for the investigation and cleanup of the spill delayed any
significant action at the site until pressure from federal and
state elected officials helped initiate preliminary site
investigations by the DEP ana EPA in 1982.
Though to~n officials report that residents ~ere angered by
the situation at the site prior to EPh's re~oval action in 1983,
residents did not formally organize to force EPA to take action.
According to regional and local officials and citizens, there are
no major civic or environmental organizations that are
particularly visible or active in the Aroostook County region.
-------
Bet~een the time that EPA completed the removal action in
late 1983 and the present, the site has generated little interest
or co~~ent among residents. This lack of interest can be
attributed to the perception that, since the removal action, the
site does not present a threat to public health or the
environment.
III.
SUYY~Y OF COYYXNTS RECEIVED DURING THE PUBLIC COY~ENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS
This Responsiveness Summary summarizes the comments
received by EPA concerning the supplemental RI, the FS and the
Proposed Plan for the Pinette's Salvage Yard site. Three sets of
written comments were received from the State of Maine, and one
set was received from the potentially responsible parties (PRPs).
Copies of the hearing transcript are available in the site
hdrninistrative Record located at the Washburn Town Offices and
the EPA Records Center in Boston, Massachusetts. The hearing
transcript is also included in Attachment D to this document.
The comments are summarized and organized into the
following two sections: A) Comments from the State of Maine; and
B) Comments from PRPs.
A.
STATE OF Y~INE COYYXNTS
The full text of comments offered by the State of Maine is
appended as Attachment B to this document.
A.
Co~~e~ts o~ the p~ooosed Plan
Co~me~t 1. The Maine Department of Environmental Protection
(DEP) stated at the public hearing that they concur with
EPA's selection qf the MM Alternative *,3: Expedited
Ground~ater Collection and Treatment. However, the DEP
expressed the belief that, to be certain that all
groundwater contamination from this site has been fully
remediated, residential wells near the site must be
included in the assessment of the site that will be
performed within five years following the completion of the
remediation program.
EPA's ReSDor.se: EPA agrees with this comment, particularly
since all residents along Gardner Creek Road are p=esen~ly
relying on private residential well water for drinking
water purposes, and no municipal water supply is currently
available near the site. Accordingly, as section 121(C) of
CERCLA indicates, those residential wells located in close
proximity to the site will be included in the review of the
-------
site conditions and selected remedial actions no less often
than each 5 years after the initiation of the remedial
actions to assure that public health and the environment
are being protected.
Comment 2. The DEP stated at the public hearing that they
concur with the combination of SC Alternatives #4: Off- .
site Incineration and t5: On-Site Solvent Extraction, as
proposed by EPA. However, the DEP advocates imposition of
an institutional control on the site that prohibits any and
all excavated areas from being disturbed for any reason
without the prior written approval of the DEP commissioner.
EPA's Response: EPA understands that DEP's comment is
based on a risk assessment that uses different assumptions
than those EPA used in determining the potential risks to
human health at the Pinette's site. Based on EPA's site-
specific risk assessment, the Agency has determined that
the institutional control proposed by the DEP is not
necessary to protect human health. The target cleanup
level selected for PCBs in soil at this site (5 (parts per
~illion) ppm, maximu~ value anya"here on the site) will
ensure protection of public health, even if the surface
soils are disturbed.
Comment 3. DEP stated that, because the DEP continue$ to
be active in all site-related studies and decisions, EPA
should note on all public documents that decisions are
being made "in conjunction with the DEP." .
EPA's Response: EPA agrees with DEP's comment, and wishes
to acknowledge the DEP's valuable input provided throughout
the RI/FS/ROD process for this site. EPA will therefore,
whenever appropriate, make the necessary insertion to all
future documents to indicate the DEP's active role in the
Pinette's site activities.
Cor.\!':'\ent 4. The DEP observed that the "subsequent sampl ing
of the well" referred to on page 5 of the Proposed Plan
under the residential well water section, occurred in
January 1989, not in December 1988.
EPA's Response: EPA acknowledges this comment by DEP, and
will make the required correction when referring to this
matter in the future. Additionally, the ROD has
accordingly corrected this oversight.
Co~!':'\ent 5. The DEP requested that EPA clearly state that
sol vent extraction ....ill be conducted lion-site," to clarify
that it will not be performed off-site, and to reduce
possible confusion with incineration, which will be
performed off-site.
-------
B.
EPA's Fesponse: EPA agrees with DEP's clarification as
noted herein. The solvent extraction process included in
the selected remedy for this site will occur within the
Roger pinette property located along Gardner Creek Road;
whereas, the off-site incineration of soils containing
greater than 50 ppm PCBS will occur at a TSCA-perrnitted
incineration facility such as those located in Texas and
Illinois.
Comment 6. The DEP asked that EPA ensure that items
defined in the Glossary be in bold print in the text and
vice versa.
EPA's Fesponse: EPA generally complied with this
suggestion in the Proposed Plan for the Pinette's Salvage
Yard site; however, EPA agrees that in a few instances, due
to oversight, this was not properly accomplished. To the
extent that this co~ment is suggesting that the same
approach be taken for the ROD, EPA notes that the purpose
of a Proposed Plan is to explain the proposed remedy to the
public and invite comment. The glossary is included there
to explain the meaning of terms to laypersons in order to
assist them in preparing comments. A glossary will not be
included in the ROD.
Comrnent 7. The DEP urged EPA to pursue any and all
po~entially responsible parties, particularly Loring Air
Force Base.
EPA's Response: EPA issued four general notice/information
request/dernand letters and two information request le~ters
on March 6, 1989 to potentially responsible parties
involved in the Pinette's site. Most parties have
responded to these letters, including the Department of
Defense (DOD), as of May 1, 1989. These responses are
being reviewed and assessed by EPA regarding the
enforcement/liability case involving each of these parties.
EPA will continue to keep DEP involved and informed of
EPA's decisions on this matter as they occur.
Comments on the Draft Final Feasibilitv Study (FS)
Comment 1. The DEP stated that they do not agree with the
risk assessment in the Draft Final FS. The DEP, in its
January 1989 co~~ent letter (Co~~ents f.1e, lf and 8)
advocated the use of more conservative risk assessment
assumptions and continues to recommend their use at the
pinette's site.
EPA's Respo~se: EPA believes that the use of the risk
assessment assumptions advocated by the state, which were
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, ,
, .'
, .
. ,
, .
. '.. . . . .
:, ::~:',:.~;;,~:. ;:~,;;: .',,:::://,.; '~",,,,~/, .~:;~~::,: :\t<;< '::::~:(:i~\f" ::J\~;/ :~;~:';'>~:~ ':~r::,;S:;~,,~:.)X/ ;:::' ,:\,~,>,~::<~:.: :,',i;,;{~ 'j:- .:..X<;":/";'~'.;~: '".'\",':;.;':, :.: : '.
';.' ;":." ':.: ,"," ' , C;:,c;:m~,ic;le:re,~',?y . ,E.F~ an". ,ar,~, pr,es,ented . i~ Vol ~t!\e I I -Append ix A
" of the "FS ,., would result,.ln- an,:ovetest1.m.ate ,o~ the. current
and/or,potential future risks present at the Pinette's
Salvag~ Yard site. Eo~ever, EPAalso understands that the
. " ' ., ','.. DEP's pref~re,nc~ tor, satisfying..t1:leir ~tate's p'";lbl~c health
policies must be setiously considered 1n ~stabl1.sh1.ng .
'cleanup levels,atthis,site." This was discussed among EPA
and DEP staff on several occ,asions and was' the maj or reason
for establishing the ultimate target cleanup level for PCBs
at this site at 5 ppm, maximum value. Nonetheless, EPA
notes that the, risk assesspent it conducted for this site
was performed in accordance with the requirements of CERCLA
(as amended by SARA), the NCP, and all current Agency-wide
policies and directives.
. ~
B.
COY~ENTS FROM THE PRPs
written comments were submitted by the U.S. Department of
Defense, Department of the Air Force - one of the PRPs at the
site. The full text of these written comments is appended as
Attachment C of this document. Below is a summary of these PRP
comments and aetailed EFA responses to these comments.
Comment 1. The Air Force expressed their belief that the
target cleanup level for PCBs (5 ppm) for soil seems
unusually strict. specifically, the Air Force asked what
additional level of protection for human health and the
environment would be achieved by the proposed PCB cleanup
level of 5 ppm, as compared with the TSCA residential
standard of 10 ppm. The Air Force also asked how much
additional soil would have to be removed and what
additic~al c~sts would be incurred in meeting the 5 ppm PCB
level ins~ead of the TSCA standard of 10 ppm.
EPA's Re~~onse~ EPA disagrees with the Air Forces' belief
that the PCB target cleanup level selected for the
Pinette's site is unus~ally strict, given the results of
EPA's risk assessment for the site. Based upon the risks
to public health that EPA (in consultation with the DEP)
identified at this site and concerns further raised by the
state, it is clear that the site-specific target cleanup
level of 5 ppm FCBs in soil is warranted for the protection
of future public health. Additionally, EPA has determined,
through consultation with the U.S. Department of the
Interior, Fish & wildlife Service, that the 10 ppm PCB
cleanup level advocated by the Air Force would not be
protective of the envircnmen~ at the Pinette's site.
Furthermore, the TSCA level stated by the Air Force is not
considered a "standard" according to the PCB Spill Cleanup
Policy (40 CFR 761 subpart G) or an Applicable or Relevant
and Appropriate Requirement (ARAR) at the Pinette's site.
In fact, the spill policy states that "... The policy
"
-------
applies to spills which occur after May 4, 1987," and "...
spills which occurred before the effective date of this
policy are to be decontaminated to requirements established
at the discretion of EPA, usually through the regional
offices." Furthermore, it should be noted that the PCB
Spill Cleanup policy states that in addition to
decontaminating soil to 10 ppm PCBs by weight, a minimum
depth of 10 inches be excavated and replaced with clean
soil, i.e., containing less than 1 ppm PCBs.
Additionally, in response to this comment, the 5 ppm PCB
target soil cleanup level selected specifically for the
Pinette's site corresponds to a total lifetime excess
cancer risk ofaxlO-6. In comparison, the TSCA level
referenced here by the Air Force of 10 ppm PCBs would
result in a 2xlO-5 lifetime excess cancer risk or an
incremental increase in risk of 2.5 times that at 5 ppm for
the protection of public health at this site. (Refer to
Attachment C of the ROD which identifies the exposure
assumptions used to develop these risk calculations).
In response to the remainder of the Air Force's comment,
the 5 ppm target cleanup level for PCBs in soil also
involves excavation of approximately 1600 cubic yards while
a 10 ppm cleanup level would involve the excavation of
approximately 1200 cubic yards. This increase of
approximately 400 cubic yards results in a corresponding
increase of approximately $200,000 total capital cost for
the source control portion of the overall remedial action.
Com~ent 2. The Air Force remarked that it is unlikely that
the aquifer can be used as a drinking water source,
particularly since EPA admits it would be technically
irnFracticable to remove particulate-bound PCBs from
ground~ater at the site. The Air Force noted that the ris}:
assessment identifies direct contact with PCB-contaminated
soil by humans and wildlife as the major hazard associated
with the site and sta~ed that capping the site with clean
fill material would prevent casual contact ~ith PCB-
contaminated soil. The Air Force asked that EPA respond to
these concerns before implementing the proposed remedy for
the Pinette's site.
EPA's ResDonse: Under section 121 of CERCLA, the EPA must
comply with the Applicable or Relevant and Appropriate
Re~~ireL.ents (k~s) under both Federal and State laws in
selecting a remedy for a site. For the Pinette's site,
these ~~s require EPA (in consultation with the DEP) to
treat the aquifers as potential sources of drinking ~ater.
Removal and eventual treatment of the other groundwater
contaminants at the Pinette's Salvaae Yard site is vitallv
important because they migrate fast~r than do PCBs, and may
-------
contaminate currently unaffected do~nstream areas (thereby
extending the existing bounds of the plume of
contamination). Removal of the other organics would also
prevent off-site migration of the PCBs, because their
presence would increase the mobility of the PCBs in the
qroundwater. Furthermore, the capping alternative
suggested by the Air Force would seriously limit all
potential future uses of the site and would not meet
congress' mandated preference under CERCLA for treatment to
the maximum extent practicable. In addition, the capping
alternative would not fully protect the groundwater from
the source of contamination which currently exists at
levels above federal and state safe drinking water
standards.
Comment 3. The Air Force recommends a site remedy that
consists of achieving a PCB cleanup level of 10 ppm to
conform with the TSCA residential standard: removal and
incineration of contaminated soils as described in the
Proposed Plan: covering the excavated area with clean fill
material: and, fencing the site.
EPA's ResDonse: The remedy recommended by the Air Force
would not be protective of human health and the
environment. Without a groundwater remedy, the Air Force's
recommendation would not be protective of human health
because it would not address the contamination present in
the on-site groundwater and the likelihood of future off-
site contamination through migration. In addition, EPA's
evaluation of environmental risks at the site indicates
that a soil cleanup level of 10 ppm PCBs would not be
p~otective of the environment. Finally, the PCB Spill
Cleanup Policy, which is the basis of the Air Force's
recommended, alternative cleanup level, requires excavation
of the top ten inches of all contaminated soil (not just
that contaminated over 10 ppm) and the placement of clean
soil over the excavated areas.
Comment ~. The Air Force asked how did EPA develop the
soil and groundwater cleanup levels, especially for PCBs.
EPA's ReSDonse: This comment has been addressed in detail
in Sections X and XI of the ROD and through EPA'S responses
contained herein to PRP Comment 1, F~P Comment 3 and State
of Maine Comment 1 under B. Draft Final FS.
co~~ent S. The Air Force asked how the proposed remedy
balances cost-effectiveness and protection of the
environment.
EPA's ReSDonse: Section 121 of CERCLA, as amended by ShR~,
requires EPA to select a remedy that is both cost-effective
-------
and protective of human health and the environment. EPA
selected target cleanup levels that would ensure
protectiveness of hu~an health and the environment. EPA
then analyzed a number of remedial alternatives for their
ability to meet these target levels, as well as for their
ability to ~eet other statutory require~ents and .
preferences contained in CERCLA section 121. (See Sections
VIII through XI of the ROD). Of the alternatives which ~et
these criteria, EPA selected a remedy which would be cost-
effective. A full discussion of the protectiveness and
cost-effectiveness of the proposed remedy is contained in
section XI of the ROD.
Comment 6. The Air Force asked to what extent the proposed
site remedy would involve readdressing the same area that
was cleaned up by EPA's 1983 removal action.
EPA's Resoonse: In 1983, EPA removed approximately 1,050
tons of PCE-contaminated soils and debris from the spill
area. At that time, EPA targeted for removal only those
soils contaminated with more than 50 ppm PCBs. EPA
undertook this removal action to address an imminent and
substantial danger to the public health and welfare. Ey
contrast, the current re~edial action seeks to ensure the
long-term protection of human health and the environment,
taking into account all site contaminants (rather than just
PCEs) and both soil and groundwater contamination. Thus,
the proposed remedy will address not only the PCE
conta~ination remaining in the spill area following the
1983 removal action, but also the entire range of problems
posed by contamination in all parts of the site.
Fu~~herrnore, whereas the removal action simply abated an
ir~ediate threat, the proposed remedy will ensure the
protection of hurnan health and the environment in
accordance with the cleanup standards and requirements of
section 121 of CERCLA.
IV.
SUYY~RY OF CONCERNS RAISED BY A LOCAL OFFICIAL DURING THE
FORY~L COM¥.ENT PERIOD AND I~70~~L QUESTION ~~ ANSWER
FERIOD OF THE AFRIL 11, 1989 FUBLIC HEARING AND EPA
RESPONSES TO THESE COYY~~~S
The following se~tion summarizes questions asked by a local
official after the close of the portion of the April 11, 1989
~ublic hearing devoted to accepting forr..al public comment. EPA
~s responding to these informal questions in this docw~ent to
address issues of concern to the cOIT~unity that were not raised
as part of the formal public comment process.
CODment 1. A local official stated his concurrence with
the State of Maine's comment that an institutional control
-------
on use of the site should be instituted following complete
remediation of the site.
EPA's Response: Please refer to EPA's response to the
State of Maine Comment 2 under A. Comments on the Proposed
Plan.
Co~~ent 2. One local official remarked that the time
required for remediation seemed somewhat lon?
EPA's Response: The 3-5 year time frame st~ted in the
Proposed Plan for completion of the overal: site remedial
action is based upon several assumptions ~~:ch include not
only the design engineering of the remedy, but also the
administrative requirements that EPA is required to
satisfy. These administrative requirements include, for
example, procurements for soliciting contractors capable of
carrying out the remedy, access to the property to
undertake the remedy, and the necessary permits involved
(if any) in implementing the remedy. EPA anticipates that
these administrative hurdles will be addressed within the
next year so as to begin the remedial action during the
'Summer of 1991 (the next construction season in the
~ashburn, Maine area).
Comment 3. One local official expressed his support and
co~endation for both EPA's and DEP's efforts at the
Pinette's Salvage Yard site.
EP~'s Response: EPA would like to express its appreciation
for the efforts that this local official has provided to
both agencies throughout the recent Remedial Investigation,
Feasibility Study, and Record of Decision process.
Co~~ent 4. A local official reauested a clarification
regarding the need for a waiver~for the groundwater at the
site.
EPA's Response: The waiver being recommend~d for the
F:nette's site grc~ndwater is based upon the present
determination that ccllection of particuJate-bound PCBs
will be technically impracticable from ~'. engineering
perspective. Therefore, compliance with the State of
Maine's Maximum Exposure Guideline (MEG) for PCBs of 0.5
parts per billion (ppb) would require a waiver. This
waiver would involve the use of an institutional control
(e.g., deed restriction) to prevent consumption of or ether
contact with the PCB-contaminated groundwater at the site
so that it would not pose a threat to the public health or
environment. However, EPA has determined that the
groundwater at the site will be treated to meet the
Applicable or Relevant and Appropriate Requirements (~~s)
-------
for all other contaminants in the groundwater that exceed
their respective Federal and/or State ARARs. This is
required since several of these other organic contaminants
are more mobile than PCBs and therefore may potentially
mobilize the current particulate-bound PCBs. It is also
required because several of these organics are classified
as more carcinogenic than PCBs. This, however, will not
preclude the treatment of the PCBs in the groundwater at
the site to the maximum extent practicable and/or
technically feasible in an attempt to achieve the ARAR for
PCBs.
-------
ATTACHMENT A
COXXUNITY RELATIONS ACTIVITIES AT THE
PINETTE'S SALVAGE YARD SITE
WASHBURN, MAINE
The co~~unity relations activities conducted by EPA at the
Pinette's Salvage Yard site during the recent remedial activities
are listed below:
o
September 1987 - EPA released a fact sheet to infonn the
public about t~e preliminary findings of the Deletion
Remedial Investigation (RI) conducted during August
1985-1986.
o
September 24-25, 1987 - EPA met with residents and local
officials in Washburn to learn about citizens' concerns
regarding the pinette's Salvage Yard site.
o
November 1987 - EPA issued an Infonnation Sheet
announcing the availability of the Final Field
Investigation Report.
o
June 1988 - EPA prepared a revised community Relat'ions
Plan to provide an update of community concerns, and
community relations and remedial activities.
o
June 1988 - EPA issued a Fact Sheet describing the Phase
II Field Investigation at the Pinette's Salvage Yard
Site.
o
June 29, 1988 - EPA held an Availability Meeting to
address citizens' concerns.
o
Ma~ch 1989 - EPA issued 0 public notice to announce the
time and place of the Feasibility Study (FS) public
informational ~eeting for the site and to invite public
comment on the FS and Proposed Plan.
March 1989 - EPA mailed the Proposed Plan announcing
EPA's preferred alternative for addressing contamination
at the site to all those on the site mailing list.
o
o
March 6, 1989 - EPA issued a press release to anno~nce
the public meeting announcing the preliminary
recor.~endation of a cleanup alternative for the
Pinette's Salvage Yard site. '
o
March 14, 1989 - EPA held a public informational meeting
-------
to discuss the results of the FS and the Proposed Plan.
o
April 11, 1989 - [PA held an info~,al public hearing to
accept comments on the remedial alternatives evaluated
in the FS and Proposed Plan.
March 15 - April 14, 1989 - [PA conducted a public
cor.~ent period to receive comments on the FS,
supplemental RI and Proposed Plan.
o
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ATTACHMENT B
COMPLETE TEXT OF STATE OF MAINE COMMENTS
.0
-------
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STATE OF MAINE
Department of Environmental Protection
IIAIN OFFICE: RAY 8UILOING. HOSPITAL STREE'T. AUGUSTA
IIAIL ADDRESS: Slate HouH S,a..ol'\ 17. Augu"a. 04333
207 .28~ 76a1
JOHN II. "cI(ERNAN. .III.
GO.ERNOR
OEAN C. ....RRIOn
COMMISSIONER
April 11, 1989
Mr. Michael Jasinski
Remedial Project Manag~r
U. S. Environmental Protection Agency
Waste Management Divisinn (HPS-CANl)
J. F. K. Federal Building
Boston, Massachusetts 02203
i1ECEIVnD
~ r11' 89
r.~E ~ \'1' 'I: ASTE
r.~:"::~:::.:~;~T :'R'!..:~CH
Dear Mr. Jasinski:
The Maine Department of Environmental Protection (DEP) wishes to thank the
U. S. Envirorunental Protection Agency for the oppol'tunity to comment on the
Proposed Plan for the Pinette's Salvage Yard Superfund~ite in Washburn, Maine.
The DEP has reviewed the proposed plan and the Remedial Investigation and
Feasibility Study and offers the following comments and suggestions.
Sincerely,
..f'2g# 1.1/ .13PF~.A"~'
v"" ,," .
W
Dean C. Harriott J
COBBI S S IOtlER
DCM/~g
cc:
-------
.
TESTIMONY OF DEAN C. MARRIOTT
CO~~ISSIONER, DEPARTMENT OF ENVIRONMENTAL PROTECTION
ON EPA'S PROPOSED PLAN FOR THE PINETTE'S SALVAGE YARD SITE
MY NAME IS REBECCA HEWETT..
I AM AN EMPLOYEE OF THE MAINE DEPARTMENT OF
ENVIRONMEHTAL PROTECTION AND THE SITE MANAGER FOR THE PINETTE'S SALVAGE YARD
SITE.
1 WILL BE PRESENTING THE TESTIMONY OF DEAN C. MARRIOTT, COMMISSIONER OF
THE DEPARTMENT OF ENVIRONMENTAL PROTECil0N, ON BEHALF OF THE MAINE DEPARTMENT
OF ENVIRONMENTAL PROTECTION CONCERNING EPA'S PROPOSED PLAN FOR REMEDIATION OF
THE PINETTE'S SITE.
THE MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) HAS REVIEWED THE
SUPPLEMENTAL REM~DIAL INVESTIGATION AND FEASIBILITY STUDY FOR THE PINETTE'S
SALVAGE YARD SUPERFUND SITE AND OFFERS THE FOLLOWING COMMENTS ON THE U. S.
ENVIRONMENTAL PROTECTION AGENCY'S (EPA) PROPOSED PLAN FOR SITE REMEDIATION,
WHICH INCLUDES BOTH MANAGEMENT OF MIGRATION (HM) FOR GROUNDWATER AIm SOURCE
-------
HANAGEP..;:rn OF MIGRATION (GROUNDWATER) ALTERNATIVES :'
THE DEP CONCURS WITH THE HANAGEMENT OF MIGRATION (MM) REMEDY 13:
EXPEDITED
GROUNDWATER COLLECTION AND TREATMENT, AS PROPOSED BY EPA.
THE DEP UNDERSTANDS
THAT 11M , 3 VILL EXTRACT CONTAMINATED GROUNDWATER, TREAT THE GROUNDWATER TO
COMPLY WITH FEDERAL AND STATE ARARS (APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS) AND REINJECT THE TREATED GROUNDWATER INTO THE GROUND.
IF,
FOLLOWING IMPLEMENTATION OF THE GROUNDWATER REMEDY, IT IS DOCUMENTED AND
DETERMINED THAT tHE PCB-GROUNDWATER ARAR ESTABLISHED BY THE STATE OF HAINE (0.5
PPB) IS H'OT BEIUG MET AS A RESUl.T OF SUSPENDEO/COLLODIAL PARTICULATE BOUND
PCBS, THEN AN INSTITUTIONAL CONTROL MUST BE ESTABLISHED FOR THE SITE THAT
PROHIBITS THE CONSTRUCTION AND USE OF ANY AND ALL GROUNDWATER ~~LLS WITHIN THE
SITE AREA.
IN REGARDS TO THE CONTAMINANT (TE'TRACHLOROETHYLENE) DETECTED IN ONE (1)
RESIDENTIAL WELL NEAR THE SITE DURING THE PHASE II FIELD WORK BUT NOT IN A
SUBSEQUENT SAMPLE COLLECTED AND ANALYZED IN JANUARY 1989, CONSEQUENTLY, IT WAS
NOT ADDRESSED IN THIS SITE REMEDY, AS PROPOSED.
THE STATE OF MAINE FEELS THAT
THIS WELL AND THE OTHER RESIDENTIAL WELLS NEAR THE SITE MUST BE INCLUDED IN THE
ASSESS~"'..ENT OF THE SITE THAT WILL BE PERFOR..I1ED WITHIN FIVE (5) YEARS FOLLOWING
THE COMPLETION OF THE SITE REMEDIATION (SC AND HM) 10 BE CERTAIN THAT ALL
-------
SOURCE CONTROL ALTERNATIVES
THE DEP CONCURS WITH THE COHBINATION OF SOURCE CONTROL (SC) REMEDIES 14:
INCINERATION (OFF-SITE) AND #5:
ON-SITE SOLVENT EXTRACTION, AS PROPOSED BY
EPA.
AS PRESENTED, THE DEP UNDERSTANDS THAT THE SC REMEDY WILL CONSIST OF THE
FOLLOw"1NG:
A.
OFF-SITE INCINERATION OF PCB-CONTAMINATED SOILS GREATER THAN 50 PARTS
PER MILLION (PPM);
B.
ON-SITE SOLVENT EXTRACTION OF SOILS CONTAMINATION \nTH PCBS BETWEEN
5-50 PPM AND ORGANIC CHEMICALS (BENZENE, CHLOROBENZENE, AND OTHERS);
NOTE~
IT IS ESTIMATED tRAT THE REMOVAL OF THE SOILS DESCRIBED IN A. AND B.
ABOVE WILL RESULT IN THE EXCAVATION OF APPROXIMATELY 2,200 CUBIC YARDS.
c.
PCB-CONTAMINATED SOILS G~ATER THAN 1 PPM AND LESS THAN 5 PPM WILL BE
EXCAVATED TO A MINIMUM DEPTH OF TEN (10) INCHES AND PLACED IN THE
EXCAVATIONS RESULTING FROM THE REMOVAL OF SOIL DESCRIBED IN A. AND B.
ABOVE.
D.
THE SOILS TREATED ON-SITE BY SOLVENT EXTRACTION THAT ARE DETERMINED TO
BE FULLY TREATED (I.E. HEETS CLEAN UP STANDARDS FOR PCB'S AND
ORGANICS) WILL BE PLACED IN THE EXCAVATIONS OVER THE SOILS DESCRIBED
-------
E.
. ALL SITE AREAS EXCAVATED BECAUSE THEY CONTAIN GREATER THAN 1 PPM AND
LESS THAN 5 PPM PCB CONTAMINATION WILL BE COVERED WITH SOIL CONTAINING;
LESS THAN 1 PPM PCBS AND REVEGETATED.
THE DEP ADVOCATES THAT AN INSTITUTIONAL CONTROL MUST BE PLACED ON THE SITE THAT
PROHIBITS ANY AND ALL EXCAVATED AREAS FROM BEING DISTURBED FOR ANY REASON (I.E.
GRAZING, FA~~ING, HOUSE FOUNDATION, ETC.) WITHOUT THE PRIOR WRITTEN APPROVAL OF
THE DEP'S COMMISSIONER.
THE REASON FOR THIS INSTITUTIONAL CONTROL IS TO
PROHIBIT ANY AND ALL DISTURBANCE OF THE CLEAN SOIL LAYER WHICH ACTS AS A BUFFER
TO PROTECT THE PUBLIC FROM EXPOSURE TO PCB-CONTAMINATED SOILS.
IF THE BUFFER
LAYER IS DISTURBE~, PROTECTION OF PUBLIC HEALTH CAN NOT BE ASSURED.
FINALLY, THE DEP URGES THE EPA TO PURSUE ANY AND ALL POTENTIALLY RESPONSIBLE
PARTIES (PRP'S), IMPARTICULARLY LORING AIR FORCE BASE (LORING) FROM WHOM THE
TRANSFOR¥..ERS COPlTAINING PCB OIl. ARE BELIEVED TO HAVE ORIGINATED.
THE STATE OF
MAINE WILL BE EXPENDING TEN PERCENT OF THE REMEDIATION COSTS FOR THIS SITE
BECAUSE RESPONSIBLE PARTIES ARE NOT TAKING RESPONSIBILITY FOR THEIR ACTIONS
~nICH RESULTED IN THE SITE BECOMING CONTAMINATED.
-------
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STATE OF MAINE
Depar1ment of Environmental Protection
MAl" OFFICE: RAY BUllOI"'G. HOSPITAl STREET. AUGUSTA
MA,. ADDRESS: s,... HOYse S,..,on 17. A...g....,.. 04333
207.289-7&88
JOHN ~ IIj!cr.E"N"", J".
GOVER"'OR
DUN C. M"~~IOTT
COMMISSIONER
April 14, 1989
/(liClil't7l1D
~ 2 S. 89
Mt&I'T
MJ.NJ..G=.,,.. W~S7'E
-"/.:/i7 e-
'ft!;t:C/1
Mr. Michael Jasinski
Regional Project Manager.
U.S. Environmental Protection Agency
Waste Management Division (HPS-CAN1)
J.F.K. Federal Building
Boston, HA 02203-2211
RE: Review Comments (Draft Final RI/FS/PP
Superfund Site in Washburn, Maine.
-(Jc.ihL
Dear t1t.- Ta:dI"l3ki:
dated March 1989) Pinette's Salvage
The Maine Department of Environmental Protection (DEP' has reviewed the
follo~ing documents for the Pinette's Salvage Yard Superfunc Site in Washburn,
Maine:
1.
Final Supplemental Remedial Investigation and Public Health Evaluation
Report (Volumes 1,11, & III) dated March 1989,
2.
Draft Final Feasibility Study Report (Volumes I & II) dated March
1989, and
3.
EPA Proposes Cleanup Plan
Site dated March 1989.
for the Pinette's Salvage Yard Superfund
Review comments for each of the three (3) documents listed above are attached
(Attachments I,ll, and 111).
If you have any questions please call me at (207)289-2651.
. POr1land .
REGIONAL OFFICES
. Bangor.
-------
Page 2
On behalf of the DE?, I thank you for the opportunity to actively
participate in the decision making process for the remediation of the Pinette's
Salvage Yard Site.
Sincerely,
.;{du~- ;;( -IJe-O'~
REBECCA L. HEWETT
Division of Licensing & Enforcement
Bureau of Oil & Hazardous Materials Control
RLH:djp
bhjasinsk
-------
Attachment I
Maine Department of Environmental Protection (DEP) Review Comments on the Final
Supplemental Remedial Investigation and Public Health Evaluation Report (SRI)
(Volum~s 1.11. and III) dated March 1989.
The ~EP submitted review comments to EPA on the Draft SRI (dated October
1988) in 8 letter dated December 7, 1988. The following comments from the
December 7, 1988 letter were not addressed in lhe Final SRI dated March 1989:
A.
General Comments I 3.4 and 6. and
B.
Specific Comments I 11, 12, 21 and 24.
Of the Draft SRI Comments listed in A and B above. the following are important
and must be addressed:
1.
Specific Co~ent I 6 - A fi~al definition of the Site which includes
an a.eal description is important as we are nearing the Record of
Decision (ROD) stage of the investigation and a specific Site
definition is needed.
2.
Genera~ Comments' 11 and 12 - The DEP ma ains,that in addition to
the two (2) mechanis~s described In the F. 1 SRI to explain the
presents of contaminants in the s'~i-conf~',~d till/bedrock aquifer. a
third mechanism is possible and should be included. The shallow
aluvial aquifer and the semi-confined till/bedrock aquifer are at
least minimially connected hydraulically and that the continuous clay
layer ~~ich separates the two (2) aquifers acts as a partially
effective barrier.
The remaining comments pertain directly to the Final SRI.
3.
Explain in more detail the source of the acetone contamination that is
present in the drainage swale Korthwest of the culvert (near Rita
Pinette's residence).
4.
Tab1es 3-11 and 3-12 - Amend the units for the inorganic analytical
results to read mg/kg instead of ug/kg.
5.
Table 6-1 - Amer," the maximum detected concentration of _ead in
surface soils Nc:th of Gardiner Creek Road to read 103 mg/kg instead
of 28 mg/kg.
6.
Table 6-3 - Amend the maximum detected concentration of lead in
surface soils South of Gardiner Creek Road to read 60 mg/kg instead of
53 mg/kg.
7.
-------
. .
Attachment II
Maine Department of Environmental Protection (DEP) Review Comm~nts on the Draft
Final Feasibility Study (F5) Report (Volumes I and II) dated March 1989. .
The DEP submitted review comments to EPA on the Draft FS (dated December
1988) in a letter dated January 21, 1989. Presently, DEP has concurred on
EPA's proposed cleanup standards for the Site. However, the DEP does not agree
with the risk assessment assu~p~ions used 8S a basis to calculate current and
future risks to human health and the environment presented in the Draft Final
FS. The DEP, in its January 19S9 comment 1etter (Commentw , Ie, lf, and 8)
advocated the use of more conservative risk assessment assumptions and
continues to recommend their use at this Site in assessing health and
-------
. "
.. .
Attachment III
Haine Department of Environmental Protection (DEP) review comments on the "EPA
Proposes Clean up Plan for the Pinette's Salvage Yard Superfund Site in .
Washburn, Maine dated Harch 1989.
1.
Page 3, Site History, Paragraph 5, Sentence 2 - Add "in conjunction
with the DEP" after EPA. The DEP has been and is presently involved
with site activities and, therefore, our involvement should be stated.
2.
Page 4, Paragraph 4, Sentence 1 - Same as comment 1 above.
3.
Page 4, Paragraph 5, Bullet 1 - As previously stated in DEP's comment
letter on the Draft' Proposed Plan (PP) dated February 16, 1989
(Comment 19), ~he DEP believes that the shallow and deep overburden
aquifers are at le&st min~ally connected.
4.
Page 5, Residential Well Water, Paragraph 2, Sentence 2 - The
"Subsequent sampling of this well" occurred in January 1989 not
December 1988.
s.
Page 17, Paragraph 1. Sentence 2 - As stated
DEP's Draft PP comment letter dated February
before Solvent extraction to clarify that it
off-site as the incineration will.
in Comment 124 of the
16, 1989, add 'on:site'
will not be perfo,rmed
6.
Pages 18-20, Glossary - Ensure that the items defined in the Glossary
are in bold print in the text and vice versa (i.e. "Hydrogeologic" and
"Upgradient" are in bold type within the text [Page 4] but not defined
in the Glossary while "Institutional Controls' and 'Solvents' are
-------
.. ". ... '''.o,.: .:'. ;'.~..,:.-~,:..
. .
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STATE OF MAINE
Department of Environmental Protection
MAIN OFFICE: AU BUILDING. HOSPITAL STRE~. AUGUSTA
MAIL AOOIIE$$: Slat. HOUN S.a"Oft 17, AuOUI'L 0Q33
207.257W
...-- .
JOHN II. McKERNAN, JR.
GOVERNOR
DUN C. ..AIIIIIIO"
COMMISSIONER
April 14, 1989
liECEl V ED
API? 2 S. 8~
Mr. Michael Jasinski
Regional Project Manager
U.S. Environmental Protection AReney
Waste Management Division (HPS-CAN1)
J. F. K. Building
Boston, HA 02203-2211
ME & VT \"A
A:Af.iA::;~l. '''I'~ ,"\STE
- '/1;/.1 Sr.ANCH
RE: Addendum to Pinette's
1989. . -L
-11)~
Dear l1r T3 Ii iR~ki I
Salvage Yard Superfund Site Testimony Dated April 11,
As David Boulter, Maine Departmpnt of Environmental Protection (DEP) and
David Webster, U.S. Environmental Protection Agency (EPA) discussed at the
Pinette's Salvage Yard Superfund Site Public Hearing on April 11, 1989, the DEP
understands that during the Management of Migration (groundwater) remediation
1. The groundwater will be treated for both PCB's and organics.
2. Separate technologies may be required to treat both PCB's and
organics.
3. It may not be technically feasible to meet the State of Maine ARAR
for PCB's (0.5 ppb) in groundwater.
4, The groundwater will be treated for PCB's to the degree that is
technically practical.
If you have any questions call me at (207)289-2651.
Sincerely,
il~ ~-Ib~
REBECCA L. HE~~TT
Division of Licensing & Enforcement
Bureau of Oil & Hazardous Materials Control
RLH:djp
bhjasinsk
ee: Dean C. Marriott, DEP
\
REGIONAL OFFICES
... B..___- ...
-------
ATTACHMENT C
COMPLETE TEXT OF PRP COMMENTS
-------
I '.
DEPARTMENT OF THE AIR FORCE
REGIONAl. CIVIL ENGINEER, EASTERN REGION (HQ AFESC)
17 'O"S~ STJlUT. LW.
AnAHTA. GEORGIA 3C»3~'
13 April 1989
Mr Michael R. Deland
Regional Administrator
U. S. EPA, Region I
JFK Federal Building (BPS-1)
Boston MA 02203-2211
Dear Mr Deland
I am writing on behalf of the U. S. Air Force in response to EPA.s proposed
cleanup plan for the Pinette~s Salvage Yard Superfund Site. The Air Force
believes the target cleanup level for PCBs (5 ppm for soil and groundwater)
is too strict, especially when compared to established cleanup standards.
Under the requirements of the Toxic Substances Control Act (TSCA), PCBs in
residential/commercial areas must meet a cleanup standard of 10 ppm. The
TSCA policy also requires the excavated area to be capped with a minimum of
10 inches of clean material (less than 1 ppm PCB). Tbe policy further states
that EPA believes the level of risk posed by a PCB level of 25 ppm in the soil
at an industrial/restricted access facility would not present significant
risks either to the typical worker or to the general public.
EPA admits that it is technically impracticable to remove particulate-bound
PCBs from groundwater at the site. It therefore seems unlikely that the
aquifer can be used as a drinking water source. Further, the risk assessment
identifies direct contact with PCB contaminated soil by humans and wildlife as
the major hazard associated with this site. Capping the site with clean fill
material would prevent casual contact with PCB contaminated soil. In view of
our concerns, we ask that EPA respond to the attached questions before imple-
menting the proposed remedy for the Pinette.s site.
We recommend a site remedy that consists of the following: adopt a PCB clean-
up level of 10 ppm to conform with the TSCA residential standard, remove and
incinerate contaminated soils as proposed in the plan, cover the excavated
area with clean fill materia!, and fence the site. This approach would pre-
vent human or wildlife contact with PCB co~taminated soil and provide a long
term remedy that is both environmentally sound and cost effective. Our point
of contact for the Pinette.s site is Mr Ron Joyner, 404-331-6776.
Sincerely
~.~
Regional Civil Eng[~~r:..
~ - . "'-- ~ 1t--.i '- - -
,. ~ r -'---- ,
11~; .-- :1
I * -...; I ,-, .
I ~ t,-., ,..; ..
.;{ W L_._.__-j L.....
ReGION 1
OFFICE 0;= T~=
c'=~'r.'.,.. " '. .
1 Atch
Questions
cc:
HQ USAF/LEEV/JACE
HQ SAC/DEVC
-------
. .
,.
. f
QUESTIONS ON PINETTE'S SALVAGE YARD SUPERFUND SITE
1. How did EPA develop the soil and groundwater cleanup levels, especially
for PCBs, for the Pinette's site?
2. What additional level of protection for human health and the environ-
ment will be achieved by the proposed PCB cleanup level of 5 ppm, as compared
with the TSCA residential standard of 10 ppm?
3. How much additional soil will have to be removed to meet the PCB level of
5 ppm instead of the TSCA st~ndard of 10 ppm? What additional costs will be
incurred?
4. How does the proposed remedy balance cost effectiveness and protection of
the environment?
5. To what extent will the proposed site remedy involve readdressing the same
area that was cleaned up by EPA's 1983 removal action?
-------
ATTACHMENT D
COMPLETE TEXT OF THE PUBLIC HEhRING TRANSCRIPT
-------
2
3
4
5
10
11
12
13
14
15
. -........
STATE OF MAINE
'l'OWN OF Wl\SH8URN
"ROOSTOOK. SEO.
6
7
PUBLIC HEARING
8
9
EPA PRDPOSES:
CLEANUP PLAN FOR THE PINETTE'S SALVAGE
YARD SUPERFUND SITE
Taken before Lee H. Wyman. a Notary Public in and for
the State of Maine on the f1tr ~ay of April, 1989 at the
Wa£hburn Municipal Building. Wa~hburn. Maine co~nencing at
16
approximately 7:15 P.M. pursuant to notice given.
17
18
19
20
AROOSTOOK LEGAL REPORTERS
23
P. O. BOX 1287
24
CARIBOU. ~~INE 04736
207-498-2729
-------
TAB L 11:
o F
2
3 DAVID WEB~TER 3
4 MICHAEL JASINSKI 7
~ 5 REBECCA HEW~TT 13
\
6 SHELDON RICHARDSON 11
'7 DAVID BOULTER 18
8
. 9
10
11
12
13
14
15
16
17
18
I
19 I
20
21
22
23 I
2.:
25
-------
3
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
.' ,.
3
April 11. 1989
"
5
DAVID WEBSTER:
We'll
6
~tart the m~eting now.
Good evening.
My name is
, 7
David Webster.
I'm here from the United States
8
Environmental Protection Agency, Region I. in
9
Boston. Maccachusetts.
My current pocition with
10
EPA i~ Section Chief for tbe Maine and Vermont
11
Superfund Section of tne Waste Management Divi£ion.
12
My rezponsibilities include managing,
13
l1npl~mentation of th~ r~m~dial Superfund PrC?gram in
14
the State of Maine.
I will 5ery~ as chairman of
15
the meeting tonight and I want to welcome you all
16
here.
17
~e purpose of tonight's hearing is to formally
18
accept your comments on the remedial investigation,
19
risk as~essment, feasibility Etudy and proposed plan
20
for remediation at the Pinette Salvage Yard, Superfun0 ,
21
Site, located here in Washburn. Maine.
EPA will also
22
accept your comments on a waiver regarding the extent
23
of ground water remedy which we will be describing
24
tonight.
25
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4
PINETTE"S SALVAGE YARD - WASHBURN, MAINE
2
3
EPA ztaff end aleo from the Maine Department of
4
Environm~ntal Protection.
seated to my left iz
5
Michael Jaeineki who i6 the !:ite remedial project
6
manager for the United States Environmental Protection
7
Agency"
Here from the Maine Department of
8
Environmental Protection are David Boulter(Sic).
9
the director of licensing and enforcern~nt and
10
Reb~cca Hewett. site manager from the State of Maine.
11
Before I begin the formal part of this ~vening:s
12
procedure. I'd like to describe to you the format
13
for hi::. he£lring.
Essentially the evening will be
14
etructured into four parts.
First. Mike Jasinski
15
will give you a brief overview of the proposed plan.
16
~.s many of you may know,
EPA r~presentatives made a
17
detailed presentation of the plan at an informational
IE
meeting which was held here on March 14th.
Following
19
Mi)
-------
5
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
3
that time I will ask you to identify yourEelf.
4
Also if you have not Eeen them yet, we have mad~
5
available for you copies of the propoEed plan for
6
the eite on the table at the front of the room.
7
Once I've called you to make a comment, if you would
B
step forward to the podium, we'd appreciate it.
S\''\
9
thet everyone can have a chance to Epeak who might
10
want to. I will reserve the right to limit the eral
11
comment to ten minutes.
This may not be a problem
12
'but if it looks like we're running particularly
13
lat~. I may have to impose that restriction.
In
14
that case.
I ask you to zurnrnarlze t1'le mr.)st in.portent
15
points you wish to mflke this evening and provide
16
EPA wi th a copy of the full te::
-------
l
6
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
3
not be able to respond tonight to your comm~nt~
4
or que~tion::.
However. after I close the
5
formal part of the hearing. we will remain available
6
informally to answer any questions you have on
i s::.ues
7
=aieed this evening or on other aspects of the
\
8
feaEibil1ty study of proposed plan.
A:: you may
9
alrendy know, the public cClmmr~nt period for the
10
proposed plan opened on March 15th and runs
11
through April 14th.
If you wish to submit written
11
commp-nts, I encourage you to do so.
They must be
13
postmarked no later than April 14th and mailed to
14
our office in Boston.
The appropriate addre~s for
15
our office can be found on page two of the propo~ed
16
plan.
At the conclusion of the meeting tonight,
17 :
please see one of us from EPA if you have que~tionz
1 E
on the process
for making written comments.
Any
19
oral comments we receive tonight and those we
20
receive in writing during the co~~ent period will be
21
responded to in a document we call the Response
22
and the Suroroary.
This summary will be included with
23
the decision document or record of decision that EFA
24
prepares at the conclusion of the comment period.
25
In the record of decision, EPA will explain which
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7
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
:3
clean up alternatives have been selected for the
A
Pinette Salvage Yard site.
I know I've pr~zent~d a
5
lot of information to you, are there any ~lestion~
6
on the format for this evening or anything el~~ I'v~
7
said on the procedures1
If not, I again want to
8
encourage each of you wi~hing to conunent
to drJ so
9
tonight orally or in writing to EPA before April
10
14th.
At thi~ point. I'd like to turn it over to
11
Mike Jasinski who will open with e briet overview
12
of the proposed plan for the Pinette site.
Mike.
13
MICHAEL JASINSKI: Tha~k you,
14
Dave.
I'd like for thoze of you who hav~ a copy
15
of the prc'posed plan to turn to pages eight thrClilgh
16
ten whicn basically outlines EPA's pr~ferred
17
alternative to the Pinette Salvage Ya=d £ite.
J
~ 6 1
Es~entially EPA has preliminarily proposed
19
in this plan a comprehensive three P8=t clean
20
up rr~medy for the s1 te to include 5011 and ground
21
water contamination.
Referred alternative
22
combines two source control alternatives designed
23
to address the soi1 con~amination and a ground water
24
alternative dc~1gned to addres~ the migration of
2S
g~ound water contDm1nation at the site.
As page
-------
e
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
~
p.ight of the proposed plan outlines, the fir~t key
4
component of the source control remedy involv~£
',5
off site incineration of PCB contaminated soils
6
greater than fifty parts per million and on eite,
7
solvent extraction of PCB and other organic
8
chemicala present at the z1te.
9
Essentially this source control alternative
\0
i~
broken down into several minor components.
11
First of all. EPA proposes to address the soil and
12
to the extent practicable the ground water
13
contamination at the site by excavating approximately
14
twenty-two hundred cubic yards of contaminated soil.
15
Those 50115 that are found to contain PCB.~
16
greater than fifty parts per million will be
17
transported off site to a location where an
1 ~ '/
v I
!
incineration facility is available.
Those are
19
similar to those po~sibly in Texas and Illin01s.
20
for ...~xam?le.
Those s0115 that contain betw~en fiv~
21
parts per million and fifty parts per million PCB's
22
and any other soils contaminated with organics such
23
as benzene and chlorobenzenes will undergo solvent
24
extraction.
25
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9
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
3
es~entially involves the extraction of organics
4
from the Eolid or soil into a liquid form for
5
ev~ntual treatment in a liquid incineration
6
similar to the fifty part per million soil that will
7
be burned also.
8
Another component of the source control
9
remedy would be to evaluate the soils that remain
10
from the solvent extraction prOC~5g on a continuous
11
basis before and after treatment to ensure that
12
our clean up criteria are met.
PCB's. as I
13
mentioned. that are extracted and any of the
14
organics that are also extracted from those
S\.iilz
15
will be taken to an off site facility for
16
incineration.
Any soils from the solvent extraction
17
proceBs that are treated through our clean up
18
goals that we have established on page five of
19
the proposed plan which mainly is for the PC8'~
20
at five parts per million. will be treated and
21
assuming that all soils are non-hazardous will be
22
put --and consolidated back in the excavated areas
23
from which we took the tw~nty-two hundred cubic yards
24
out of the site.
Additionally we are also proposing
25
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10
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
'2
:I
one and less than five parts per million, approximately..
4
five hundred cubic yards. to a minimum depth of
5
ten inches and consolidate those 60ils in the same
6
"
excavation from which the twenty-two hundr.ed cubic
7
yards were originally taken.
That will undergo the
8
solvent extraction and incineration off site.
9
Finally, EPA would restrict access to the site
10
using fences and warning ~ign~ during the
II
remediation and treatment proce~s.
We are going
to
12
require that some of the junk vehicles that hinder
13
any of the ~ite remediation at the Pinette Salvage
Id
Yard are removed.
We will recommend establishing
15
institutional controls to monitor the site {or any
16
future releases from any vehicles or a~y salvage
17
equipment at the site.
And we will monitor
18 !
19
surface water and sediments on a continuous
basis
for the first couple of mQnt115 of the procezs.
That
20
ezzentially outlinez the source control component
21
of the overall site remedy.
22
The ground water portion of the remedy involves
23
ground water collection using a multiple component
2~
system; tha t
is the installution of shallow
25
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11
PINE'l'TE'S SALVAGE YARD - WASHBURN. MAINE
2
:
deep ground water extraction wells for the collection
4
. of the contaminated ground water within the Eite
5
proper.
That collected ground water would b~ pump~d
6
to granular filters for pretreatment and scr~ening
7
and eventually sent through the primary treatment
8
system which iB carbon absorption which uses activat~d
,9
carbon to remove the organics that we are intending
10
on remediating in the ground water such as the
11
benzene and chlorobenzenes.
All the treated ground
12
water that meet our initial goals of State of Maine
13
cri teria as well as federal maximum contamin,ant
14
level~ will be reintroduced into the shallow aquifer
15
through recharge trenches on the site proper.
16
A part of the ground water remedy involves
17
institutional controls on the site ground water during
18
our remediation.
That is. a ban on -- prohibiting the
19
use of the on site ground water for drinking water
21
purpones dur ing clean up and 1 f necezsary. recommendi f" .
I
the installation of either filtration units on any!
I
20
22
new residential wells in place on the site or a
23
complete ground water prohibition.
One key component
24
of the ground water remedy involves a waiver which
25
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12
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
3
offering for public comment.
The waiver essentially
4
is a waiver from's State of Maine regulation.
'J'he
5
r~qulation is for PCS's and ground water.
We are
6
going during this proces~ of the proposed plan for
7
public comment because at this stage due to technical
8
snd prsctibility reasons of extracting the PCB's in
~
ground water we are looking for B waiver from the
10
State of Maine PCB Standard and therefore in
11
scc()rdcJnce wi th our laws, EPA 15 providing the public
12
the opportunity to comment on that waiver during
13
the remaining public comment period process.
The
1~
overall remedy as it's bro)
-------
13
PINETTE'S SALVAGE YARD - WASHOURN, MAINE
2
3 ,
4
I'd like to ask Rebecca Hewett from Maine DEP to make
a presentation on behalf of the Stat~.
5
REBECCA HEWETT:
I 'm pr(~sentlng
'6
testimony of Dean C. Marriott, Coltuuicsioner.
7
DPpartment of Environmental Protection on EPA's
8
propoEed plan for the Pinette Salvage Yard.
9
My name iz Rebecca Hewett.
I am an employee of
10
the Maine Department of Environmental Protection and
11
the site manager for the Pinette's Salvage Yard
12
1;,1~ .
I will be presenting ~he testimony of Dean
13
c. Marriott, Commissioner of the Department of
14
Environmental Protection. on behalf of the Maine
1'5
Department of Environmental Prot~ction concerning
16
EPA's proposed plan for remediation of the Pinette'~
17
Salvage Yard site.
18
"The Maine Department of Environmental
19
Protection.
(DE?), has reviewed the s~P?le~ental
20
remedial investigation and feasibility study for
21
the Pinette's Salvage Yard Superfund Site and
22
offers the following comments on the U. S.
23
Environmental Protection Agency's,
(EPA). propose>d
24
plan for site rem~diation. which includes both
25
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14
PINETTE'S SALVAGE YARD - WASHBURN, Mt..! NE
2 I
~
control alternatives.
4
Management of migration (groundwater)clternatives:
5
the DEP concurs with the manag~ment of migration, (MM),
6
remedy numb~r three.
Expedited groundwater collection
7
and treatment, as proposed by ErA.
The DEP under~tand~
8
that management of migration number three will extract
'9
contaminated groundwater, treat the groundwater to
10
comply with f~der81 and ~tate ARARS, epplicabl~ or
11
relevant nnd appropriate requirement~, and reinject thp.
12
treated groundwater into the ground.
I f, following
13
implementation of the groundwater remedy,
it is
14
documented and determined that the PCB groundwater
15
ARAR e~tabli~hed by the State of Main~, five part~
16
per billion, is not met
as a
r~~ult of ~u~pcnd~d/
17
collodiall particulate bound PCB'~,
then iln
18
institutional control must be establi~hed for th~
19
site that prohibits the construction and u~e of any
,0
and all g~oundwater wells within the ~ite area.
21
In r~gards to the contaminants,
trichloro-
22
ethylene, detected in one re~idential well near the
23
site during the phaGe 2 field work but not
in
24
~ub~equent samples collected and analyzed in
25
January of 1989, consequently it
-------
lS
PINETTE'S SALVAGE YARD - WASHBURN. ~AINE
2
'3
1n this site remedy 8S proposed.
The State of Maine
4
teels that thi~ well and the other residential w~ll~
5
n~ar the site must be included in the a~~e~~ment of
7
the site that will be performed within five year~
following the completion of the site remediation.
6
8
the source control and the management of migration.
9
to be certain that ell groundwater contamination
10
from this Bite has been fully remediated.
11
Source control alternatives.
The UEP
concur:;;
12
with the combination of source control remedi~~.
13
number four. incineration off site and number
14
five. on site solvent e~traction as proposed by EPA.
15
A!3 presented.
the DEP understands that the source
16
control remedy will consist of the following:
17
A.
Off site incineration of PCB
18
contaminated soi15 greater than 50 parts per million.
19
B.
On site solvent extraction of ~oilE
20
contamination with PCB's between five and fifty
21
parts per million and organic chemicals such BE
22
benzene and chlor.oben~ene.
23
It iE estimated that the soilE described in
24
A and B above will re5ult in the excavation of
25
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16
PINETTE.S SALVAGE YARD - WASHBURN. r".AINE
2
3
c.
PCB co~~aminated coils greater than one
'-
4
part per million and less than five parts per
5
million will be excavated to a minimum depth of ten
'6
inches and placed in the excavations re~ulting from
7
the removal of soils described 1n A and B above.
8
D.
The ~oil~ treated on site by solvent
9
extraction that are determined to be fully tr~Bted.
,10 '1
11
i. e.. they meet clean up standards for PCB's and
organic~. will be placed in the excavations over the
12
~01l~ descr1ben i~ C above.
13
E.
All site areas excavated because they contu'
14
greater than one part per million and less than five
~5
parts per million PCB contamination will be covered
16 I
17 I
18 ,
I
with zoil containing less than one part per
million pcals and revegetated.
The DEP advocates that an institutional control
19
roUE'. t
be placed on the site that prohibits any and all
20
excavated areas from being disturbed for any rea~on
21
such as grazing, farming. house foundations. et
22
cetera. without prior written approval from the
23
DEP's Commissioner.
24
The reason for this institutional control is to
25
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17
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
3
layer which acts as 8 huffer to protect the public
4
from expozure to PCB contaminated 60ils,
If the
5
buffer layer i~ disturbed. protection of public health
6
cannot be assured.
7
Finally. the DEP urges the EPA to pursue any and
8
all potentially responsible parties and particularly
9
Loring Air Force Base from whom the transformers
10
containing PCB oi1s are believed to have originated.
11
The State of Maine will be expending ten percent of
12
. .
the remediation cost~ for this site because responsible
i3
parties are not taking re~ponsibility for their actionz
14
which resulted in the site b~coming contaminated.
15
Dean C. Marriott."
DAVID WEBSTER:
'I'hsnk you.
16
17
We will now take any comments which you may have
18
regarding the proposed plan
or the studie~ on the
19
site.
Sheldon Richardson.
Maybe you can introduce
20
yourself.
SHELDON TIrCHARDSON:
Yes.
21
22
My name is Sheldon Richardson and I am the town
23
manager of Washburn.
After the preliminary
24
hearing in March, the council routinely discuss~d
25
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18
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
~
of clean up and we certainly concur with that.
The
4
council certainly has not heard the te~timony of
5
Dean C. Marriott tonight but I certainly would
6
concur with that also in terms of the State of
7
Maine issuing those kinds of restrictions; particularly
8
as to the institutional control on the site after
. 9
the work is done.
Basically that's all I have to
10
say.
We certainly are pleased with the preferred
11
method of clean up and satisfies. we believe. the
12
needs of the State of Maine and this community.
DAVID WEBSTER:
Thank you.
. 13
1.1 ,
Anybody el~e with to make a comment?
DAVID BOULTER:
I'm
15
16
David--if I could just have a point of clarification
17
for the audience here and for the record.
It's our
I
18 I
understanding--first of all, David Boulter speaking
19
from the State of Maine DEP.
It's
our understa~cing
20
that EPA is requesting a waiver of the State ARAR
21
with respect to PCS's and I wanted to make it cl~ar
22
that ~uch a waiver does not mean that we will not be
23
looking to treat PCB's. but th~ l~v~l of clean up
24
may not be technically feasible such that we would
25
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19
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
~
1 just wanted clarification on that point from
4
you, if that's accurate.
DAVID WEBSTER:
I can take
5
and respond to the commcntz after I clos~ the
6
formal part of the hearing and I'll be happy to
7
to that'in what looks like a very fOhort amount
8
1; . I
of time, okay?
DAVID BOULTER:
m
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20
I
, 1
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
3
this site, we're not assured one hundred percent
that we can attain that ARAR.
Your ARAR of .5
4
5
PPB PCB's.
That's not precluding us from treating
6
the groundwater because we have deal with it for
7
benzene and chlorobenzene which exceed not only
8
your ARAR but our own federal &tandard~ for
9
protection of public health.
So there's two phases
10
to that.
We're going to treat the groundwater for
11
two reasons.
The (unintelligible word)organics
12
1n the groundwater as well as the PCB's.
We're
not a~sured. ourselves. we. can get to the .5 level
13
14
for PCG's.
We feel confident we can contain
15
the (Unintelligible word)organics.
We're asking
16
for the waiver up front basic~lly because we may
17
need to invoke that in the future because we can't
18
attain the standard.
DAVID BOULTER:
I just
19
20
wanted a clarification.
50 it's clp.ar that you
21
will be treating for PCS's but the level that we
22
may reach may be different from the standard.
that's all 1--.
23
MICHAEL JASINSKI: Let'~
24
25
say it comes down--.
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21
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
. 3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
SHELDON RICHARDSON:
Okay,
the lcv~ls that we're talking about. is that
the levels being eafe for drinking water?
MICHAEL JASINSKI: Yes.
SHELDON RICHAIIDSON:
Okay.
What 1s the federal standard?
MICHAEL JASINSKI: We don't
have a Etandard.
50 we havp. to therefore comply
to their stl.mdard which
is--.
SHELDON RICHARDSON:
Do
all states have a standard now"
Some mayor may
not.
DAVID BOULTER:
A good many
of the states do.
Th~ difficulty here,
i t 1 ("j(".Iks
like. the PCB's won't remove themselv~s from th~
~,oil. so--.
MICHAEL JASINSKI: We may
not be able to flush them out.
That's what
our problem is. in the groundwater. bedrock
in the site proper.
SHELDON RICHARDSON:
And
that'~ the
reason
that--since that's not going
to happen.
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2~
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
institutional control.
:!
REBECCA HEWETT:
That's
4
5
right.
'l'ha t 's correct.
MICHAEL JASINSKI: We hope
6
if all worke out fine, that we won't need an
7
institutional control or a waiver and the groundwater
8
will be drinkable, if--.
9
SHELDON RICHARDSON: What
10
11
would your waiver be requesting. whatever you
feel that's rea~onable, that you cannot get?
12
MICHAEL JASINSKI:Well.
13
under our regulations. we can go for six different
14
types of waivers under the CIRCLA(SIC)law.
Ones
15
for--you know. you can provide better protection
16
17
using an alternative treatment method. not attain
that ARAR. and there's a list of them in the
18
statute under clean up standardz. c~ction :21.
19
This one is for t~chnical and practibility fram
20
an engineering perzpective.
to ~xtract the
pcs.s
21
from groundwater.
22
REBECCA HEWETT:
Because
23
they're adhered to the 8011.
24
25 1
DAVID WEBSTER:
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23
PINETTE'S 5ALVAGE YARD - WASHBURN. MAINE
2
basically we're required by the statute to comply
~
with all applicable or relevant appropriate fed~ral
.t
standards or state standards.
If we look at it
5
and we say gee. I don't know if it's technically
6
practicable to do it. that's one reason for saying
7
I can't:m~et all of the requirements.
I have to
8
say 1n my remedy yes. it fulfills the law. I
'V
meet all the requirements.
If there's a good reason
10
w~y you can't such as technical impractibility or
11
you choose not to. you can invoke the waiv~r but
12
we want to make Eure people are aware of it.
I
13
think one W
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24
'\
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
the salvage yard itself which is where the site
3
is defined as the spill.
Or pretty much.
It's
4
not anything north of --up towards some of the
"
5
re~idential wells in the area.
It's going to be
6
a fairly localized control or otherwice it
7
would possibly be invoked after we determine that
8
we need to invoke a waiver or institutional control
9
or otherwise.
10
SHELDON RICHARDSON:
The
11
time sequence s~ems a little bit long to me,
12
three to five years for some of it.
That pushes
13
the procezz to what, fifteen years plus?
That
1~
seems like a long time.
Maybe it isn't.
Maybe
15
I'm jU5t--.
16
MICHAEL JASINSKI: That
17
could be the high ~ide too, possibly. Sheldon.
18
If all
goes well,
we could be designing the
19
remedy within the ney.t--with1n the fall or winter
20
and then once we design the remedy, we've got to
21
implement the remedy and then the coordination
22
~ffort and the subcontracting efforts and once we
23
do what we have to do fc~ the--you know, it's got to
24
be a stage
proces~
for one thing. Fir.st we've
got to
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25
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
dig up the Boils, we've got to figure out what
3
amount 1s going to be over fifty we'll have to ship
4
off ~1te before we can start doing anything with
5
the solvent extraction, let alone touch the ground-
6
wat~r.
The first thing is to remediate the soils.
7
8
So it's a phased thing.
DAVID WEBSTEI{:
A lot of--
9
to be fran]<., are inEtitut10nal adrn1ni~tratlve
'too.
10
We have an enforcement, one, that DEP alluded to
11
and we're not exactly ~ure where that's going to .
12
take uz right now.
And that could be pro~racted.
13
Hopefully it won't be.
When you get in to going
14
into the remedy. there may be permits involv~d
15
or exactly how these institutional controls g~t
16
implementt:d and we may be back as]dng for your
17
assistance at that point on a local level but often
18
the results aren't
necessarily the engineering
19
reason~ but administrative onez.
50mp.times when
20
the government agencies get involved with doing
21
the work, there are procurements as far as seeing
22
that all permits are in place beforehand.
Sometimes
23
there are bid protests.
I think that we've learned
24
a lot in the process and one is to not promise
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I .
26
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
speedy turn arounds on something that have a lot
3
of aspects beyond our best control.
4
SHELDON RICHARDSON:
Well.
s
not only that. I think a lot of timec it tak~s
6
the bureaucracy a long time to make a decision
7
because you have to cover every single facet.
8
If you don't. somebody is going to chew you out
9
for that.
Obviously ~hat's juct the way the
10
American system works and it works that way from
11
the local level all the way up through. b~lieve me.
12
If you make the wrong decision as part of a project.
13
you're going to get really chewed out by som~body
14
and no one likes that.
So if we try to do it right,
15
sometimes it does take longer.
16
MICHAEL JASINSKI: One key
17
administrative one may be right away. getting
18
eccess to that property.
That may be a battle.
19
SHELDON RICHARDSON:
That
20
very well could be.
21
DAVID BOULTER:
You expect
22
23 I
that to be a factor. then?
MICHAEL JASINSKI: It could
24
be a potential factor in doing the remedy. getting
-------
27
PINETTE'S SALVAGE YARD - WASHBURN, MAINE
2
into the prop~rty.
We have never obtained any
3
written acceas to \hat property, only verbal
4
acces&.
to date.
5
RF.BECCA HEWETT:
You tried
6
to get that before.
7
MICHAEL JASINSKI: Now
8
we're going to have to get it in writing before
9
we start doing things.
10
DAVID BOULTER:
We can
11
~.r:lp in thQt regard.
12
SHELDON RICHARDSON:
Is
13
there a pr('")c~££ that the State can gC) t.hrough?
14
DAVID BOUL'I'ER:
Yt':~.
15
DAVID WEBSTER:
As well
16
a5 EPA through the ~tatute but it involves
17
judgez and federal marshals and thing~ th3: are
18
not--don't happen overnight.
19
SHELDON RICHARDSON:
I
20
ju~t think you peo~le have done--we have no
21
qualm~ sbout what EPA or DEP has cone.
We
22
get a little di£couraged at times but other than
23
that,
I think the approach has been pretty darn
24
grJod.
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28
PINETTE'S SALVAGE YARD - WASHBURN. MAINE
2
DAVID WEBSTER:
Any other
3
comments. qup.st1ons?
50 thank you and 1'11 close
4
the informal part of the hearing as well.
5
6
7
END OF HEARING
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
-------
2
3
4
S
6
7
8
9
10 .---
11
12
13
14
1S
16
17
18
19
20
21
22
23
24
25
29
C E R T I F I CAT ION
I HEREBY CERTIFY THAT the foregoing 1& a true and
correct transcript of the record of proce~dings held
on the afore-designated hearing date.
c;;:!..ILd~ ~~CA,
-------
ATTACHMENT E
EPA'S RESPONSES TO FINAL SUFPLE~ENTAL RI COY.XENTS
-------
1)
RESPONSES TO COMMENTS FROM STATE OF MAINE DEP
PINETTE '.~ £ ALVAGE FINAL SRI
December 7. 1988 - General Comment No.3 - Include in the
appropriate sections (3.0. 4.0 and 5.0) of the report a
routine description of the protocol and procedures used to
obtain qroundwater and soil samples.
The Supplemental Remedial Investigation contains general
methodologies for:subsurface borings, geophysical
investigations, well construction details, surface and
subsurface sampling intervals. Because the Phase I and II
Work Plans and Field Operation Plans provide substantial
details on specific sampling methodologies, it was
determined that such information would be superfluous in
the SRI report. Ho~ever, a general reference to the
planning documents was inadvertently omitted from Section
1.4 of the report. Entries have been made on the SRI
Errata Addendum to note these references.
2)
December 7. 1988 - General Comment No.4 - Include in the
appropriate sections (3.0. 4.0 and 5.0) of the report on
explanation of the mechanism(s) for laboratory
contamination of both soil and water samples with methylene
chloride. acetone. etc.
The specific mechanisms for potential laboratory or
sampling - induced contamination of soil and water samples
are conjectural. The text makes several references to
these. In section 3.3, Page 96, referring to soil
analyses, ketones are noted as common laboratory chemicals
introduced during field or laboratory decontamination
procedures. Phthalates are noted to be potentially caused
by use of plastic and rubber products during sampling or
analysis. Methylene chloride was not addressed
specifically on Page 96; an Errata Addendum entry has been
made to note that methylene chloride is a common laboratory
solvent which may have been introduced to samples by
incomplete hardware decontamination or careless laboratory
storage and housekeeping.
Errata Addendum entries for section 4.8 have been noted to
address trace levels of acetone and methylene chloride in
-------
An Errata Addendum entry has been made for Section 5.1.3 to
address acetone detected in Phase I surface water samples
and laboratory blanks.
In section 5.2.2, Page 186, the occurrence of methylene
chloride and acetone in sediment samples is addressed. An
Errata Addendum entry has been noted to add a sentence to
the fourth paragraph to address potential laboratory
sources of methylene chloride. The occurrence of moderate
levels of acetone in eastern drainage swale sediments is
currently addressed in the section 5.2.2 text on Page 186.
1l. December 7. 1988 - General Comment No.6 - Provide a final
definition of the site which includes an areal
descriotion. The DEP requests that in addition to the
spill area. the Site includes other areas of known
contamination reqard1ess of the source.
Under Section 105 (a) (8) (B) of CERCLA, an NPL site is
defined by the scope of a release or threatened release,
not by precisely delineated boundaries. Further, the site
includes not only the area where hazardous substances have
been "deposited, stored, disposed of or placed," but also
where any such substances have "otherwise come to be
located." (See Section 101 (9) of CERCLA.) Accordingly,
EPA has provided a description of the PSY site in the ROD
(see page 1) which includes all areas of known
contamination related to the release EPA and the State of
Maine identified during the NPL listing process. To the
extent that other, unrelated areas of contamination are
discovered elsewhere in the site vicinity (e.g., the PCE
detected in one sampling of Roger Pinette's well), the
State may request that these be evaluated for future
inclusion on the NPL.
4)
December 7. 1988 - Specific Comment No. 11 - Paqe 104,
Section 4.6. Bullet 1 - Re-evaluate and modify this
conclusion. The unconfined alluvial aquifer and the
~-confined olacial till/fractured bedrock aquifer must
be at least minimallY connected since PCBs and
chlorobenzenes have miqrated into the lower aquifer system
and a neqative vertical qradient exists between the two
aquifers.
- Specific Comment No. 12 - Paqe 104,
section 4.6. Bullet 2 - Re-evaluate and modifY this
conclusion. The clay confining unit is only a ootentiallY
effective barrier, since PCBs and chlorobenzenes have been
detected in the lower aquifer. .
April 14. 1989. Comment No.2 - (Specific) comments No. 11
-------
mechanisms described in the Final SRI to explain the
~~sen~e of contaminants in the semi-confined till/bedrock
ife . a third mechanism is possible and should be .
included. The shallow alluvial aauifer and the .
semi-confined till/bedrock aauifer are at least minimallY
connected hYdraulicallY and the continuous clay layer which
separates the two (2) aauifers acts as a partiallY
effective barrier.
The comments were originally issued pertaining to
conclusions included in the Draft SRI (October 1988) which
stated: a) that the alluvial and glacial till/bedrock
aquifers are not in hydraulic communication in the vicinity
of the spill, and b) that the clay confining unit beneath
the alluvial aquifer acts as an effective barrier to
vertical migration of contaminants from the upper aquifer
to the lower aquifer and as an aquitard causing'''perched''
conditions in the upper aquifer. section 4.8 was revised
significantly between the Draft and Final documents to
address these concerns: however, further clarification is
provided herein and in the SRI Errata Addendum.
The Final SRI addresses potential contaminant migration
from the upper to lower aquifer on Pages 166-167. On page
166, paragraph six, the clay confining unit is described as
"relatively impermeable". It should be noted that the clay
confining unit is characterized as an "aquitard" and not as
an "aquiclude" in recognition of the limited permeability
of the unit.
Mechanisms for leakage through the clay confining unit are
discussed on page 167, paragraph one and paragraph three.
A primary mechanism for contaminant migration may have been
breaching during the IRA excavation activities to the north
of and within the spill area. Recharge to the lower
aquifer in the approximate spill area, allowing potential
contaminant transport, is proposed to be a result of
several potential mechanisms: including thinning and
possible stratigraphic discontinuity of the clay unit north
of the spill area, leakage through the clay unit due to
thinning or breaching at the IRA dewatering trench: and
potential structural discontinuities in the clay unit.
The potential for contaminant migration by direct aqueous
flow through the clay confining unit is limited by the low
permeability and thickness of the unit. Although this
transport mechanism is considered to be of limited
significance relative to the alternative mechanisms
discussed above, Maine DEP is correct in noting that this
possibility should be addressed in the SRI text.
Therefore, Errata Addendum entries have been prepared to
-------
5)
The assertion by Maine DEP that the upper and lower
aquifers are "at least minimally connected hydraulically"
is addressed by the aquitard/aquiclude distinction and the
above-presented discussion. In addition, as discussed in
paragraphs three and four of Page 167, south of the
SMW/DMW-1 and -9 clusters, the clay unit thickens to become
an effective aquitard as clearly evidenced by the distinct
, elevation differences of piezometric heads and downward
vertical gradients between the two aquifers. Therefore,
from a hydrologic standpoint, the "minimal hydraulic
connection" between the upper and lower aquifers is
considered to be insignificant in the areas south of the
upgradient well clusters.
December 7. ~988 - Specific Comment No. 21 - section 6.0 -
Expand the dermal contact estimates for children to include
exposure to legs alonq with hands and arms.
Upon consideration of the geographic location and climate
of the Washburn area, EPA determined that the soil exposure
scenario for children employed in the Public Health
Evaluation involving exposure to hands and arms was
appropriate, and determined that a revision of calculations
of risks due to direct contact should not be performed.
Instead, the SRI was modified to incorporate a
semi-quantitative discussion (page 251, first paragraph)
which noted that an assumption of leg exposure would
increase the skin exposure area by a factor of two, thereby
approximately doubling the calculated risk, but resulting
in a similar order of magnitude, and therefore
insignificant effect on the plausible maximum case risk.
6)
December 7, 1988 - Specific Comment No. 24 - Paqe 149.
Table G-9 - Add lead as a contaminant of concern in soils.
Table 6-2 on Page 133 indicates that lead is present above
backqround and reqional backqround concentrations.
Analysis of lead analytical data from surface and
subsurface soils indicated that concentrations were similar
both north and south of Gardner Creek Road. If lead were a
site-related contaminant, it would be expected that
concentrations would be diluted with transport to the
south, and hence, surface soil concentrations would be
lower to the south than to the north. In addition,
subsurface and surface lead concentrations were similar,
suggesting no pattern of contamination or accumulation.
Geometric mean concentrations of soil lead were all within
regional and site-specific background levels. In
consideration of several factors, it was concluded in the
SRI that lead is not a site-related contaminant of concern
in soils, as the weight of evidence suggests that it is
-------
7)
8)
9)
A~ril 14. 1989 - Final SRI Comment No.. 3 - Explain in
~etail the source of the acetone contamination that is
RT.e$~~t in the drainaqe s~a1e northwest of the culvert
(near Rita Pinette's residence).
more
As discussed in Section 5.2 of the SRI, acetone was
detected in sediment samples at a frequency and range of
concentration indicating a specific source of contamination
to the drainage swale. Because no pattern of acetone
contamination was detected in the Source Characterization
field investigation, any discussion of a source for the
acetone contamination is conjectural. As noted in Table
3-13 on page 100, acetone is used as a solvent for rubber,
plastics, lacquers, varnishes, cement, paint removers, and
storage of acetylene gas. Potential sources of
contamination anticipated to be used in a facility such as
the Pinette's Salvage Yard could be acetylene gas
cylinders, solvents or paint thinner. The distribution of
sediment contamination s~ggests that run-off of salvage
yard contamination into the drainage swale may have caused
the sediment contamination.
April 14. 1989 - Final SRI Comment No.4 - Tables 3-11 and
3-12 - A~end the ~nits for the inorqanic analvtical results
to read mq/kq instead of uq/kq.
This correction has been noted in the Errata Addendum.
April 14. 1989 -
maximum detected
north of Gardner
mq/kq.
Final SRI Comment No. S - Amend the
concentration of lead in surface soils
Creek Road to read 103 mq/kq instead of 28
This correction, along with a re-ca1cu1ated geometric mean,
has been noted in the SRI Errata Addendum.
10)
April
Amend
soils
of S3
14. 1989 - Final SRI Comment No.6 - Table 6-3 -
the maximum detected concentration of lead in surface
south of Gardner Creek Road to read 60 mq/kq instead
mq/kq.
This correction has been noted in the SRI Errata Addendum.
11)
April 14. 1989 - Final SRI Comment No.7 - Paqe 219. Label
the top of this paqe as "Table 6-9".
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