United States . Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01 -90/051
September 1990
<& EPA Superfund
Record of Decision:
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REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Reclplent'e Acceulon No.
PAGE EPA/ROD/ROl-90/051
4. TItle 81111 ~ 5. Report Dete
SUPERFUND RECORD OF DECISION 09/28/90
Kearsarge Metallurgical, NH
6.
First Remedial Action - Final
7. Author(e) 8. Perfonnlng Orgenlzatlon Rept. No.
8. P8rf0nnlng Orgelnlzatlon Nama 81111 Add,... 10. .ProjectlTuklWork Unit No.
11. ConIr8ct(C) or Grent(G) No.
(C)
(G)
1 ~ SporworIng Orgenlzatlon Nama end Addre.. 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementery NoI88
18. Abatrect (Umlt: 200 worde)
The nine-acre Kearsarge Metallurgical site is an abandoned foundry in the town of
Conway, Carroll County, New Hampshire. The site is located within the 100-year
floodplain of the Sa co River. Pequawket Pond borders the site to the south. The site
contains a drainage pipe with four open-bottomed catch basins, two waste piles, a
septic tank and leach field, and forested wetlands. The site was originally operated
as a saw mill but from 1964 to 1982 was operated as a foundry. Wastes generated by
Kearsarge, the foundry operator, included solid wastes such as ceramics and metal
grindings, and hazardous substances including caustic soda, hydrofluoric acid, volatile
organic compounds, and flammable liquids. These were disposed of in the septic system
and in the waste piles. In 1979, the State ordered Kearsarge to stop disposing of
wastes through the septic system. Wastes were subsequently placed in drums and stored
onsite, but Kearsarge removed them in 1982. A hydrologic study in 1982 revealed
contamination of ground water in the upper aquifer underlying the site, a potential
drinking water source. This Record of Decision (ROD) addresses both source control and
management of migration of the contaminated ground water plume. The primary
contaminants of concern affecting the soil, debris, and ground water are VOCs including
TCE; and metals including chromium.
17. Docurnant Analyale L DeecriptolS
Record of Decision - Kearsarge Metallurgical, NH
First Remedial Action - Final
Contaminated Media: soil, debris, gw
Key Contaminants: VOCs (TCE), metals (chromium)
b. Identifier8lOpen.Ended Terma
c. COSA 11 ReIcIIG'1qI
18. Avlllebiity Sletemant 18. Security Cle.. (Thle Report) 21. No. of Pegee
None 245
20. Security Cle.. (Thle Page) ~ Price
Nonp
7)
50272-101
v
(1)0.., "NSl-Z3fI.18)
SH/".trucli"". on Rs""tN
(Formetfy N11S-35)
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EPA/ROD/ROl-90/051
Kearsarge Metallurgical, NH
~irst Remedial Action - Final
Abstract (Continued)
,
The selected remedial action for the site includes removing the septic tank and
contents, followed by offsite incineration and ash dispos~l in a RCRA hazardous waste
landfill; excavating and dewatering approximately 250 cubic yards of leach field soil,
followed by offsite treatment and disposal; excavating 4,650 cubic yards of waste pile
materials with offsite disposal of approximately 4,400 cubic yards in a RCRA solid waste
landfill and offsite treatment and disposal of approximately 250 cubic yards in a
hazardous waste landfill; ground water pumping and treatment by precipitating metals,
air stripping to remove VOCs, using a carbon column to control air emissions from the
air stripper, and discharging treated ground water to a publicly owned treatment works;
and long-term environmental monitoring. The estimated present worth cost for source
control, including O&M, is $3,256,000. The estimated present worth cost for management
of migration is $4,020,000, including an annual O&M cost of $170,000. The total present
worth cost for the remedial action is $7,276,000.
PERFORMANCE STANDARDS OR GOALS: Ground water cleanup levels include TCE 5 ug/l (MCL)
and chromium 50 ug/l (National Interim Primary Drinking Water Regulation). For the
debris, chromium will be remediated to the level of 1,400 ug/kg, based on a Hazard
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(J
REGION
I
Q
RECORD OF DECISION
KEARSARGE METALLURGICAL CORPORATION
CONWAY, HEW HAMPSHIRE
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DECLARATION FOR THE RECORD OF DECISION
Kearsarge Metallurgical Corporation
Conway, New Hampshire
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for
the Kearsarge Metallurgical Corporation Site in Conway, New
Hampshire, 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), the National oil and Hazardous
Substances Contingency Plan (NCP), and 40 CFR Part 300 et seg., as
amended. The Region I Administrator has been delegated the
authority to approve this Record of Decision.
The State of New Hampshire concurs with the selected remedy.
STATEMENT OF BASIS
This decision is based on the administrative record which has been
developed in accordance with Section 113 (k) of CERCLA and which
is available for public review at the Conway Public Library in
Conway, New Hampshire and at the Region I Waste Management Division
Records Center at 90 Canal Street, Boston, Massachusetts. The
Administrative Record Index (Appendix D to the ROD) identifies the
items which comprise the Administrative Record upon which the
selection of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to the public health or welfare or to the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Kearsarge Metallurgical Corporation
Site includes both source control and management of migration (or
ground water control) components to obtain a comprehensive remedy.
The source control remedial measures include:
*
The removal of a septic tank and contents. These materials
will be transported to an off-site incinerator for thermal
destruction.
*
Excavation of approximately 250 cubic yards of contaminatej
leaching field soils. The excavation will remove all soils
that fail to meet the cleanup standards for volatile organi~
compounds and metals. The excavated soils will be dewatere~].
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r,
"
*
licensed RCRA subtitle C facility for treatment and disposal.
Attaining the soil target cleanup levels will eliminate the
potential migration of contaminants from the soils into the
ground water at levels exceeding ground water cleanup goals.
Excavation and off-site disposal of the materials in the two
waste piles. This portion of the remedy provides for the
excavation, treatment, and disposal of two waste piles. The
excavated materials will be placed into containers. If the
materials contain hazardous substances above cleanup levels,
they will be sent to a RCRA subti tIe C hazardous waste
facility for treatment and disposal. Other waste pile
materials will be sent to a solid waste facility or otherwise
disposed of in a manner that will comply with all applicable
federal, state, and local laws.
The management of migration remedial measures include:
*
Active restoration of the ground water aquifer contaminated
with volatile organic compounds (VOCs) using air stripping of
ground water and carbon columns for air emission control.
This component of the remedy will extract and treat ground
water contaminated by the Site. The goal of this remedial
action is to restore the ground water to drinking water
quality. Effluent from the treatment plant will be discharged
to the Publicly Owned Treatment Works operated by the Conway
Village Fire District.
*
Ground water will be extracted by use of either a collection
trench or a number of wells. combinations of trenches and
extraction wells may also be used. Ground water extraction
'would act to halt the migration of contaminants and,
facilitate the removal of contaminants, but would not dewater
the wetlands.
*
The extracted ground water will first pass through a clarifier
which will precipitate any metals contained within the ground
water that either pose a risk to human health or the
environment, or would reduce the effectiveness of the air
stripping unit. Periodically the residue in the clarifier
. will be tested, removed, and disposed of at a licensed
facility which is in compliance with appropriate laws and
regulations. Ground water will then pass from the clarifier
to the air stripping unit for removal of VOCs. The VOCs that
are removed from the ground water will be captured prior to
exhausting air to the atmosphere by carbon filters. These
carbon filters will periodically be removed and either
properly disposed of, or will be regenerated at an off-site
facili ty. The remedy is expected to reach target cleanup
levels in all locations in the aquifer in 10 years.
*
Additional measures include long-term environmental monitoring
throughout the implementation of the remedy to ensure its
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DECLARATION
The selected remedy is protective of the human health and the
environment, attains federal and state requirements. that are
applicable or relevant and appropriate for this remedial action,
and is cost-effective. This. remedy satisfies the statutory
preference for remedies that utilize treatment as a principle
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable.
u
--1 p,f' / f ,;
DatE!
Julie Belaga
Regional Administra or
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{,
I.
"
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
RECORD OF DECISION
KEARSARGE METALLURGICAL CORPORATION
TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION 0 00 0 0 0 0 0 0
A. General Description 0 0 0 0 0 0 0 0 0 0 0 0 0
B. Geology and Hydrogeology of the site 0 0 0 0 0
C. Ground Water Supply. . 0 0 0 0 0 0 0 0 0 0 0
SITE HISTORY AND ENFORCEMENT ACTIVITIES 0 0 0 0 0 0 0 0
A. Land Use and Response History 0 0 0 0 0 0 0 0
B. Enforcement History 0 0 0 0 0 0 0 0 0 0 0 0 0
COMMUNITY PARTICIPATION 0 0 0 0 .
. . . . . .
. . . . .
SCOPE AND ROLE OF THE RESPONSE ACTIONS
SUMMARY
A.
B.
C.
D.
E.
F.
G.
H.
........
OF SITE CHARACTERISTICS. 0 0 0 . . . . . . . 0
Soil. . . . . . . . . . . . . . . . . . . . .
Leachfield Soils and septic Tank. 0 . 0 0 .
Waste Piles. . 0 . . . 0 . 0 . . . 0 . 0 0 0
Ground Water. . . . . . . . . . . . . . 0 . .
Surface Water. . . . . . . . . . . . . . . .
Sediments. . . . . . . . . . . . . . . . . .
Ai r . . . . . . . . . . . . . . . . . . . . .
Structures. 0 0 0 . . . . . 0 0 0 . 0 0 0 0 0
SUMMARY OF SITE RISKS
. . .
. . . .
. . . . . . .
. . .
DEVELOPMENT AND SCREENING OF ALTERNATIVES. . . . . . .
A. Statutory Requirements/Response Objectives. 0
B. Technology and Alternative Development and
Screening. . . . . . . . . . . . . . . . . .
DESCRIPTION OF ALTERNATIVES. . . . 0 . . . . 0 0 . 0 .
A. Source Control (SC) Alternatives Analyzed
B. Management of Migration (MM) Alternatives
Analyzed. . 0 . 0 . . . . 0 0 0 0 . . . . . .
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 0 .
THE SELECTED REMEDY. . 0 . . 0 . 0 0 0 0 0 0
A. Cleanup Levels. . . . 0 . . . 0 . 0
B. Description of Remedial Components 0
. . . . .
. . . . .
. . . . .
STATUTORY DETERMINATIONS 0 0 . . 0 . 0 0 0 . 0 0 . 0 0
A. The Selected Remedy is Protective of Human
Health and the Environment 0 0 0 . . 0 0 0 0 .
The Selected Remedy Attains ARARs . . 0 0 . .
The Selected Remedial Action is Cost-
Effective. . . . . . . . . . . . . . . . . .
B.
C.
1
1
2
3
4
4
6
7
7
8
9
10
11
11
13
14
14
14
15
19
19
20
21
21
25
29
38
38
42
47
47
47
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D.
The Selected Remedy Utilizes Permanent
Solutions and Al ternative Treatment or Resource'
Recovery Technoloqies to the Maximum Extent
P r act i cab Ie. . . . . . . . . . . . . . . . .
The Selected Remedy Satisfies the Preference
for Treatment Which Permanently' and
Siqnificantly Reduces the Toxicity, Mobility
or Volume of the Hazardous Substances as a
Principal Element. ... . . . . . . . . . . .
E.
XII.
DOCUMENTATION OF NO SIGNIFICANT CHANGES.
. . .
. . . .
XIII. STATE ROLE
. . . .
. . . . . .
.........
. . .
APPENDIX A. . . . . . . .Figures
APPENDIX B. . . . . . . .Tables
APPENDIX C. . . . . . . .Responsiveness Summary
APPENDIX D. . . . . . . .Administrative Record Index
APPENDIX E. . . . . . . .State of New Hampshire Declaration
of Concurrence
56
58
58
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SEPTEMBER 28, 1990
1.
SITE NAME, LOCATION, AND DESCRIPTION
A.
General Description
The Kearsarge Metallurgical Corporation (KMC) Site is located in
Carroll County, Conway, New Hampshire. The KMC Site is on Mill
street, approximately one-half mile from the intersection of New
Hampshire Route 16 and West Main street in Conway, New Hampshire.
A locus map showing the general location of the site is included
in Appendix A as Figure 1.
The Site is comprised of two lots, lots 7 and 8, as depicted on Map
27 at the Conway Tax Assessor's Office in Conway, New Hampshire.
Lot 7 covers five acres and consists of forested wetland. The
current owner of lot 7 is Carroll Reed, Inc. through a land trust.
The only structures on lot 7 are a north-south oriented drainage
pipe with four open-bottomed catch basins and the larger of two
separate waste piles. Lot 8 consists of approximately four acres
and contains the two buildings which belong to KMC, the septic tank
and leaching field, the smaller of the two waste piles, and a small
portion of the larger waste pile. No underground storage tanks are
present at the site. A Site map displaying boundaries, lot lines
within the Site, and significant physical features is included in
Appendix A as Figure 2.
The Site is bounded by Pequawket Pond to the south, by lots owned
by New England Embroidery on the west, Conway Supply Company on the
east, Mill Street and Carroll Industries on the northwest, and by
another lot owned by Carroll Reed, Inc. on the North.
The Site is level and varies from four to six feet above the base
level of Pequawket Pond. The Pond level is not static as the Pond
is controlled at a dam further downstream. The entire Site and
portions of adjacent property are within the 100-year floodplain.
Forested wetlands cover much of the eastern portion of the Site,
while the western boundary of the Site is fringed by shrub-scrub
wetlands. No endangered or threatened flora or fauna were 'found
to exist on, or in the vicinity of the site. Also, no sensitive
wildlife habitat was discovered. A map delineating the extent of
on-site and nearby wetlands is included in Appendix A as Figure 3.
Recreational uses near the Site include swimming, boating, and
fishing in Pequawket Pond. Pequawket Pond is not used as a
drinking water source. Drinking water in the area is supplied by
two wells that are 3,000 feet north of the Site and are shown in
Appendix A on Figure 1 labeled "pumping station". These wells dra~
water from a 90' thickness of saturated sand and gravel. The Site
exists in an area consisting of, and zoned for, commercial
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2
exist 600 feet to the north of the Site. Residential areas also
are 300 feet to the south of the site on the other side of
Pequawket Pond. Densely populated residential areas are wi thin
one-half mile of the Site. The population of Conway is. 8,800 and
increases by as much as 86% on a seasonal basis. .
Additional information regarding the characteristics of Conway, New
Hampshire may be found in Section 2.4 of the Remedial Investigation
(RI) conducted by the State of New Hampshire's contractor; Camp,
Dresser, & McKee (COM). Site characteristics, analytical results,
and remedial alternatives have been presented in the following
documents COM has produced for EPA under a cooperative agreement
with the State of New Hampshire:
Remedial Investiqation Report. Kearsarqe Metallurqical
Corporation Hazardous Waste site. Conway. New Hampshire. June
1990.
Feasibility Study Report. Kearsarqe Metallurgical Corporation
Hazardous Waste Site. Conway. New Hampshire. June 1990.
B.
Geology and Hydrogeology of the site
The site lies in a broad region termed the Saco River Valley
subdivision. The confluence of the Saco and Swift rivers lies one
mile down stream from the Site. Peqauwket Brook, which widens to
become Pequawket Pond, flows northward and empties into the Saco
river.
Much of the area consists of metasedimentary and igneous rocks
overlain by a veneer of unconsolidated glacially derived sediments.
These sediments consist of ice deposits such as glacial tills,
glacio-fluvial deposits such as kame, and fluvial deposits that
were subsequent to glaciation such as alluvium.
The two buildings on the Site rest on five to fifteen feet of fill.
This fill consists of medium to fine sand. The fill areas underly
and surround the immediate vicinity of the buildings. The upper
one to two feet of this fill contain large amounts of sawdust
interspersed with the sand and gravel, as the area served as a
sawmill prior to 1964. Unfilled areas have soils consisting of
principally a thin layer of hydric (wetlands) soils and some areas
of a fine sandy loam. The water table at the Site is a variable
boundary that fluctuates with both the seasons and the management
of the level of Pequawket Pond. The depth to ground water may vary
from two to six feet below the ground surface. Underlying the Site
are a collection of unconsolidated alluvial and glacial deposits
that mantle a buried glacial valley. These sediments vary from
ninety to one hundred forty feet in depth and can be separated into
three distinct layers on the basis of composition, structure, and
hydraul ic behavior. The three layers are termed, in order 0 f
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3
sand layer, and the glacial till layer. A cross-section displaying
the position and thickness of each of these units in relation to
site features is depicted in Appendix A as Figures 4a and 4b. The
surficial geology of the area is depicted in Appendix A- as Figure
5. .
u
The uppermost layer (the fine silty sand layer) is comprised of ten
to twenty feet of a homogeneous silty fine sand. Travel times of
groundwater in this unit are approximately fifty feet per year in
both the vertical and horizontal planes. Ground water flow -in the
fine silty sand layer is radial due to the influence of the large
waste pile. The bulk of the contamination is found in the fine
silty sand layer. The ground water flow contours for this upper
contaminated unit are depicted in Appendix A as Figure 6.
Ten to twenty feet below the surface is a layer of silt stratified
with clay and fine sand (the stratified silty sand layer)~ This
layer is identical in composition to the overlying silty sand layer
but is stratified or layered, imparting different hydraulic
characteristics. The stratified silty sand layer is approximately
seventy feet in thickness and underlies the site completely.
Ground water flow in this unit is to the north. Horizontal travel
times of the ground water in this stratified silty sand unit are
on the same order of magnitude as the overlying fine silty sand
layer. The vertical travel times for the stratified silty sand
layer are lower than the fine silty sand layer due. to the
stratification present. The vertical travel times are
approximately two feet per year in the area of the large waste pile
and diminish rapidly to zero feet per year with increasing distance
from the waste pile.
The deepest layer of unconsolidated sediments is a layer of glacial
till. This till is comprised of gravelly silty sand which has
ground water travel times that are slightly faster than the
overlying units (the fine silty sand and the stratified silty sand)
and flow to the north. This unit varies from ten to thirty feet
in thickness over the site.
Bedrock underlying the unconsolidated units is the Conway Granite.
The Conway Granite is relatively un fractured in the area of the
Site and slopes gently downward to the northeast. Fracture trace
analysis performed as a part of this study identified a set of
fractures that roughly trend north-south and east-west: however,
seismic refraction studies in the area of investigation display
consistent and very fast velocities (16,000 to 17,000 feet pe ~
second) which indicates that the bedrock underlying the site is
relatively un fractured and therefore would not serve as a likel:-
conduit for migration of contamination.
c.
Ground Water supply
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4
Village Fire District, for the town of Conway, are approximately
3,000 feet to the north of the Site. Although the site rests upon
the same aquifer that the public drinking water supply wells use,
the Site is currently outside the zone that contributes groundwater
to those wells. The Site is within the zone that contributes
ground water to the municipal wells if a low recharge year occurs
and the wells are pumped at twice their present rate. A low
recharge year is one which has 36 inches, or less, of
precipitation. Average annual precipitation is approximately 40
inches per year. The present pumping rate for the Conway wells is
440 gallons per minute and future pumping conditions (2010) are
projected to be 1,225 gallons per minute. This demqnstrates that
under current conditions, it is unlikely that any of the
contaminants in the ground water at the site will affect the public
water supply wells; however, a threat may be posed to the public
wells under future conditions. No private wells exist within a one
half mile radius of the Site.
A more complete description of the site can be found in the
Remedial Investigation Report on Pages 2-1, 2-2 and 2-11 through
2-24.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Use and Response History
The Site and many of the surrounding properties were operated by
the Kennett Company as a saw mill from 1900 until 1964. During the
period 1964 through 1982 the area of the present day Site was
operated as a foundry by KMC. This foundry produced precision
stainless steel castings. The castings were produced by the
injection of molten steel into ceramic molds, otherwise known as
the investment, or lost wax method. KMC used 1,1,1 Trichloroethane
(TCA) as a solvent in the wax pattern process.
Wastes generated at the site included solid wastes such as spent
ceramic materials, and metal grindings; and hazardous substpnces
such as caustic soda, hydrofluoric acid, volatile organic compounds
(VOCs), and flammable liquids. As a result of their industrial
processes, KMC generated chemical wastes containing high
concentrations of TCA, chromium, hydrochloric acid (HCl), nitric
acid (HN03)' hydrofluoric acid (HF), isopropyl alcohol, and sodium
hydroxide (NaOH). The disposal of hazardous and non-hazardous
substances occurred on the east side of building #1, specifically
the septic system and the waste pile. The septic tank discharged
to the ground via a lower leach field and an upper PVC drainage
pipe. The septic tank and lower leach field are located chiefly
on the KMC side of the line separating lots 7 and 8, while the PVC
drainage pipe was routed from the septic tank on lot 8 to a
discharge point on the Carroll Reed side (lot 7). The PVC drainage
pipe was buried one foot deep and surfaced at its discharge point
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5
Q
drainage pipe and the present position of the leach field are
depicted in Appendix A, Figures 7 and 8 respectively. The
application of an unknown amount of caustic soda, hydrofluoric
acid, chlorinated solvents, and flammable liquids to both the
ground surface and the septic system occurred in the late 1970's.
The waste piles, which are located on both the Carroll Reed and KMC
properties, originated prior to 1970, based on aerial photographs
of the site.
In 1979 the New Hampshire Water Supply and Pollution Control
Commission notified James Eldredge, President of KMC, that the
discharge of wastes to the septic system was not permitted. The
response of KMC was to containerize and store its wastes in and
near building #2. Approximately 17,800 gallons of acid, 54,000
pounds of caustic solids, and 660 gallons of flammable solvents
were accumulated during the period that KMC drummed liquid wastes
generated on-site. KMC was verbally ordered by the EPA and the
New Hampshire Bureau of Solid Waste Management (NHBSWM) to
recontainerize corroded drums in September 1981. KMC took no
action to address these concerns, and in December 1981 a Letter of
Deficiency was issued to KMC by NHBSWM. KMC ceased operations
shortly after the issuance of the Letter of Deficiency. Indian
Head Bank took possession of the property on lot 8 pursuant to its
security agreements for a short period in 1982. The containerized
wastes were ren,oved from the site in response to a verbal order by
the U.S. Environmental Protection Agency (EPA) and the New
Hampshire Bureau of Solid Waste Management (NHBSWM) in June of
1982.
The New Hampshire Bureau of Hazardous Waste Management (NHBHWM)
issued a Notice of Violation and Order of Abatement to KMC and its
former executives to conduct a hydrologic study of the Site in
October 1982. KMC took no action to conduct such a study, and the
State began a hydrologic investigation to characterize the Site.
In December of 1982 monitoring wells, installed by NHBHWM and the
New Hampshire Highway Department, showed significant levels of
chlorinated solvents also known as Volatile organic Compounds
(VOCs) in the ground water. In May 1983 NHBSWM ordered KMC and
its officers to remove the waste piles at the site; however, no
action was carried out by KMC to remove the piles. Further
investigations resulted in a Hazard Ranking Score (HRS) of 40.73,
resulting in the site being added in September 1984 to the National
Priorities List (NPL) of sites to be cleaned up. No remedial
measures have been conducted at the site. The Site has remainej
unoccupied since its abandonment in 1982.
The Remedial Investigation (RI) began in 1985 following the Jul~'
1985 Consent Order of New Hampshire v. KMC. KMC and its insurance
carriers were ordered by the Court to conduct the RI with Stat0
oversight. Geotechnical Engineers Inc. (GEI) of Concord, r;c-.
Hampshire were retained by KMC to conduct the investigation at t:..
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6
documents:
Draft Phase I site Characterization. Remedial
Investiqation/Feasibilitv Study. Kearsarqe Metallurqical
Corporation and Portions of the Carroll Reed Property Conway.
New Hampshire. 1985.
Draft Remedial Investiqation Report. Kearsarqe Metallurgical
Corporation Conway. New Hampshire. Volumes I. II. & III.
December 5, 1986.
Draft Endanqerment Assessment. Kearsarqe Metallurqical
Corporation Site-conway. New Hampshire. March 25, 1987.
Draft Partial Feasibilitv Study Identification of Technoloqies
and Initial Screeninq of Remedial Al ternati ves. Kearsarge
Metallurqical Corporation Site Conway. New Hampshire. April
9, 1987.
Upon completion of these draft documents the insurance carriers for
KMC discontinued funding of the investigation efforts. Following
the review of these draft documents the EPA and the New Hampshire
Department of Environmental Services (NHDES) determined that
additional efforts would be required to complete the Remedial
Investigation (RI) and the Feasibility study (FS) in accordance
with guidelines established under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA). Through a
cooperative agreement reached in Autumn of 1988 between the EPA and
NHDES, Superfund monies were made available for the completion of
the RI/FS by the NHDES Waste Management Division. The firm of
Camp, Dresser, and McKee was selected to be the contractor to
complete the RI and the FS. In June of 1990 the RI and FS were
released to the public along with EPA' s proposed plan for the
remedial actions at the Site. An Action Memorandum which provides
for the removal of seven drums of uncharacterized materials from
the site by EPA was issued on September 25, 1990.
,
A more detailed description of the site history can be found in
the RI of CDM on pages 2-3 through 2-10.
B.
Enforcement History
On June 20, 1990, EPA notified three (3) parties who either owned
or operated the site of their potential liability with respect to
the Site. Negotiations have not commenced with these potentially
responsible parties (PRPs) regarding the settlement of the PRPs
liability at the Site. One of the PRPs has commented on the
proposed plan and submitted an additional alternative which is
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7
III. COMMUNITY PARTICIPATION
'J
Throughout the Site's history, community concern and involvement
has been moderate. EPA has kept the community and other interested
parties apprised of the Site activities through informational
meetings, fact sheets, press releases and public meetings.
During January of 1990 EPA released a community relations plan
drafted by NHDES which outlined a program to address community
concerns and keep citizens informed about and involved in
activities during remedial activities. Prior to that, on August
26, 1985 EPA held an informational meeting in Conway, New
Hampshire, to describe the plans for the Remedial Investigation and
Feasibility Study that was to be conducted by the private parties.
The presentation of the findings of this study occurred on December
18, 1987 in Conway, New Hampshire. KMC discontinued funding for
the RI/FS in 1988. It was determined at that time that additional
work would be necessary to complete the RI/FS begun by KMC and its
contractor GEl. On June 28, 1990 EPA held an informational meeting
in Conway, New Hampshire to discuss the results of the RI/FS that
was conducted under the direction of the State of New Hampshire.
On June 20, 1990 EPA made the administrative record available for
public review at EPA's offices in Boston and at the Conway Public
Library in Conway, New Hampshire. EPA published a notice and brief
analysis of the Proposed Plan in the Conway Daily Sun on June 22,.
1990 and made the plan available to the public at the Conway Public
Library in Conway New Hampshire. EPA mailed copies of the proposed
plan to state and local officials, citizens on the mailing list,
the PRPs, and other interested parties. On June 28, 1990 EPA held
an informational meeting to discuss the results of the Remedial
Investigation and the cleanup alternatives presented in the
Feasibility Study and to present the Agency's Proposed Plan. Also
during this meeting, the Agency answered questions from the public.
From June 29, 1990 to July 28, 1990 the Agency held a thirty (30)
day public comment period to accept public comment on the
alternatives presented in the Feasibility Study and the Proposed
Plan and on any other documents previously released to the public.
The public comment period was extended an additional thirty (30)
days to August 27, 1990 at the request of a PRP. On July 24, 1990,
the Agency held a public meeting to discuss the Proposed Plan and
to accept any oral comments. A transcript of this meeting and the
comments and the Agency's response to comments are included in the
attached responsiveness summary. Also included in the
responsiveness summary are the comments by a PRP. The
responsiveness summary is included as Appendix C.
IV.
SCOPE AND ROLE OF THE RESPONSE ACTIONS
The selected remedy was developed by combining components 0 f
different source control and management of migration alternatives
to obtain a comprehensive approach for Site remediation. In
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summary, the remedy provides for the removal, treatment and
disposal of the components of the two waste piles which are
contaminated with hazardous substances that are above the cleanup
levels, the septic tank with its contents, and the leaching field.
Additionally, the remaining material of the waste piles will be
taken off-site for landfilling at a RCRA subtitle D facility to
minimize risks to human health. These actions constitute source
control and will minimize the addition of contaminants to the
groundwater beneath the Site and eliminate the potential for
exposure to contaminants in these media. The selected management
of migration remedy also provides for the extraction and treatment
of contaminated groundwater. The actions taken under management
of migration will minimize the discharge of contaminants into the
surface water bodies, and control the migration of the contaminated
ground water plume.
This remedial action will address the following principal threats
to human health and the environment posed by the site:
-Further contamination of ground water by source areas
identified at the Site.
-Direct contact with contaminated soil and waste pile
material.
-Inhalation and ingestion of waste pile material.
-The off-site migration of contaminants in ground water.
Remedial activities at the Site are comprehensive and designed to
be a final remedy.
v.
SUMMARY OF SITE CHARACTERISTICS
Chapter 1, Section 1.3, of the Feasibility Study contains an
overview of the Remedial Investigation. Contamination at the Site
is the result of the discharge of VOCs, caustic materials, and
acids to the septic system, the ground surface, and the 'waste
piles. The approximate location of the septic tank, leaching
field, and the larger of the two waste piles are depicted in
Appendix A as Figures 7 and 8.
Analysis of soil, ground water, sediment, surface water, and waste
pile material from the Site and adjacent areas indicate that the
environmental contamination at KMC includes soil contamination in
the leach field, septic soils, ground water contamination, and
actual and potential contamination in the waste piles.
The most prevalent contaminants identified in ground water and the
septic system at the Site are VOCs such as 1,1,1 Trichloroetha~0
(TCA) and degradation products of TCA such as 1,1 DichloroethJ-~
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9
DCE); and 1,2 Dichloroethylene (1,2 DCE). Also identified in the
ground water are Trichloroethylene (TCE), Acetone, and chloroform.
contaminants found in the waste piles include acids, caustics,
chromium, nickel, and minor amounts of VOCs.
In the analysis of each contaminated media, analytical values
obtained from the CDM RI will be used. Data supplied in the GEI
Draft RI will be used to supplement CDM data. The significant
findings of the Remedial Investigation are summarized below.
A.
soil
In this context soils are defined as materials occurring above the
low water table which, because the water table fluctuates between
two to six feet below the surface, is assumed to be six feet below
the ground surface. The soils consist of fill (silty sand) which
has pockets of sawdust and silt. In some areas, notably the
wetlands, there is a thin layer of organic material. These soils
can best be described as mineral soils. This definition of soil
excludes the materials within the waste piles and the leaching
field soils since neither consists of natural materials. The soil
has been investigated by soil-gas techniques, test pitting, soil
borings, and split spoon samples during well installation.
In 1989 CDM found that VOC contaminant levels in soil were very low
with no detection of any VOCs. Only toluene, acetone, and ethyl
benzene were detected in minor amounts. Metal levels (EP-Toxicity
Extract) were below detection limits or very low. Therefore, no
contaminants of concern were selected for the Site soils. The lack
of contamination of site soils is believed to be due to a number
of factors:
sawdust is an integral material in the upper one to two
feet of the fill, this layer may have trapped any VOCs
holding them near the surface where they were volatized
into the atmosphere;
the lower mineral soils lack organic carbon which'will
retain VOC and metal contamination; and
the fluctuating levels in Pequawket Pond have both a
physical and chemical flushing action that mobilizes and
removes any contaminants.
The ultimate destination of any contaminants that may have been
present in the soil is the ground water. Further characterization
of the soil surrounding and beneath the septic tank will be
necessary when the tank is removed. One soil sample was taken
adjacent to the septic tank and found to have TCA (53 ppb) and 1,1
DCA (31 ppb). The location of soil samples obtained by CDM are in
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B.
Leaching Field soils and Septic Tank
The leaching field consists of two levels, an older lower level and
a newer upper level. It is believed that the lower level either
stopped functioning or became limited in its performance and that
the upper level was installed to empty the septic tank. The lower
level is attached to the septic tank by an outlet pipe that extends
twenty feet from the septic tank to the distribution box. The
plastic leach field pipes radiate from the distribution box and are
bedded on two to four inches of medium to coarse black foundry
sands. These foundry sands are underlain by hay and one foot of
gravel. The leach field pipes are buried 3 feet below the surface
and are at, or just above, the water table for portions of the year
and many of them were clogged with silt, organic matter, and lime-
like material. This lime-like material is believed to be caustic
that was either disposed of into the system, or was added to
restore the performance of the septic system. This lower leach
field is situated chiefly on lot 8 between the building and the
larger waste pile. The upper leach field consists of a single PVC
drainage pipe that rests above the lower leaching field, and is
buried one foot below the surface. This PVC pipe extended eastward
from the septic tank to discharge into the wetland on Lot 7 at a
point fifty feet from the boundary of KMC (lot 8) and Carroll Reed
(lot 7). Much of the area over the leach field has been disturbed
by test pitting operations.
The leach field soils occupy an area of approximately 20 feet by
55 feet principally on lot 8 and includes a small area where the
PVC drainage pipe discharged on lot 7. The areas considered to be
leaching field soils are depicted in Appendix A as Figure 10. No
samples were obtained in the subsurface leachfield; however, it is
believed that the organic material present in and around the
leaching pipes may have retained some of the contaminants. Samples
taken near the PVC drainage pipe in 1985 had levels of TCA (140
ppb) and small quantities of other volatiles. Samples taken near
that same pipe in 1989 had minor amounts of acetone and no
detectable VOCs. Also, ground water near the area of th~ PVC
drainage pipe (well MWS-10l, Appendix A Figure 2) has historically
been the most contaminated of all the wells until the 1989 sampling
rounds conducted by CDM. The septic tank and leach field received
wastes from pipes extending from the penetrant room and the
degreasers which contained TCA (see Appendix A, Figure 8).
The material in the septic tank is an indication of the
contamination of the leach field soils. The septic tank is locatej
on the eastern side of building #1. It was constructed prior to
1975, and used as an industrial disposal system. An aqueous sample
obtained from the septic tank in July, 1989 contained greater than
3,300 ppb of TCA and 1,200 ppb of 1,1 DCA. Sediments within t~0
septic tank also contained values of TCA and 1,1 DCA, 3,300 ppb a~:
3,800 ppb respectively. Metal content within the sediments of t~~
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septic tank yielded values of total chromium (2.6 ppm). Based on
the "investigation results it appears that wastes were discharged
to the septic system and that the migration of VOCs from the septic
tank to the leach field has contributed to the presence of
contaminants in ground water at the Site. "
c.
Waste piles
Two waste piles are located on the site. The larger pile,
containing approximately 4,250 cubic yards of material, is located
on the eastern side of Building # 1. The smaller pile, which
contains approximately 400 cubic yards of material, is located on
the eastern side of Building #2. The locations of the waste piles
are depicted in Appendix A Figure 2.
During waste pile excavation an airborne hazard was identified.
Materials within the piles were sieved and found to contain 40% by
volume of particles that could be entrained by the wind. The
primary concern is that the fine, particulate materials in the
waste piles may be entrained by the wind during waste pile
excavation or during some episode in which the piles were stripped
of their vegetation. This particulate matter is composed of fine
silica sands, chromium, and nickel. Particulate nickel and
chromium have been identified as carcinogenic when inhaled. Total
metals identified to be above background include chromium (400 ppb)
and nickel (200 ppb). These metals pose no threat to ground water
as EP-Toxicity extracts of the waste pile material yielded results
below the detection limits. Fine silica particles entrained by the
wind also pose a human health threat via inhalation (silicosis).
Toluene, acetone, chloroform, ethylbenzene, and methylene chloride
were detected at low levels in the waste pile material in sampling
rounds in 1989. No other VOCs were detected within the waste pile
samples during the 1989 sampling round. It may be noted however,
that detection limits for the 1989 sampling of the waste pile by
COM were up to 1700 ppb (1.7 ppm) for TCA. Therefore it is
possible that relatively high values of TCA, which exceed cleanup
levels, still remain in the waste piles. Cleanup levels will be
discussed further in this document.
Test pit exploration determined that the waste piles contain an
unspecified amount of drummed wastes that may include caustics,
isopropyl alcohol, and organic solvents. During the test pit
program conducted by GEl many drums were discovered within the
waste pile. The location and number of discovered drums is shown
in Appendix A as Figure 11.
D.
Ground water
Ground water at the Site has been sampled periodically since 1982.
contamination during that time has consisted of TCA: 1,1 DCA: 1,2
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primary contaminant at the Site. DCA and DCE (1,1 and 1,2) are the
decay products of TCA. Values of TCA ranged between 0.95 and
18,500.0 ppb in the ground water for the February 1990 sampling
round. These levels have varied greatly over the sampling history
of the site. The most contaminated wells have been MW-7 (3,500 to
135,000 ppb of TCA) and MWS-101 (1,008 to 19,000 ppb of TCA) during
sampling rounds from 1982 to the present. The following analytical
results were obtained for TCA, DCA and DCE at the Site during the
conduct of the RI by CDM:
TABLE I
CONTAMINANT MAY 1989 FRED. FEB 1990 FRED.
ppb ppb
1,1,1 Trichloroethane 5,680.00 12/24 18,500.00 7/10
1,1 Dichloroethane 1560.00 9/24 794.00 4/10
1,2 Dichloroethane 2.00 1/24 14.60 1/10
1,1 Dichloroethylene 2.78 1/24 615.00 4/10
1,2 Dichloroethylene 38.40 1/24 14.50 1/10
Trichloroethylene 3.48 1/24 118.41 2/10
Acetone 374.00 1/24 0.00 0/10
Chloroform 171.00 3/24 0.00 0/10
ppm
Chromium 0.01 1/21 not analyzed
Nickel 4.70 3/21 not analyzed
This table lists only the maximum value of contamination found in
the monitoring wells. The frequency is the number of times that
the contaminant was found to exist over the detection limits for
wells at the site. The February 1990 sampling round concentrated
on seven wells that are the most heavily contaminated and includes
three new wells that were installed earlier in February 1990.
The contaminated ground water plume containing TCA, along with the
other contaminants, has been migrating away from the Site in a
radial pattern from the septic area and waste pile. The sources
of this plume are the leach field on the property of KMC (lot 8)
and the PVC drainage pipe that discharged to the property of
Carroll Reed (lot 7). The portion of the plume that has levels
that exceeds the Maximum Contaminant Levels (MCLs) under the Safe
Drinking Water Act (SDWA) occupies the area to the east of Building
#1. The size of this area is approximately 400 feet in length by
400 feet in width and 20 feet in depth. This plume underlies lot
7. The location of the contaminant plume is depicted in Appendix
A Figure 12. The estimated volume of ground water within this
plume is roughly five million gallons. The volume of contaminants
adsorbed to the soil and sediments of the fine silty sand layer is
minimal because there is little organic carbon below the ground
surface. A TCA partition coefficient experiment was conducted
during the RI that found that very low levels of the TCA were
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""
The contaminated ground water is concentrated in the upper twenty
feet of the alluvium (the fine silty sand layer). Migration is
restricted by slow travel times and an underlying low permeability
layer in the alluvium (the stratified silty sand layer).o The flow
of contaminants has not appeared east of the drainage culvert on
lot 7. The failure of contaminants to migrate further east of the
culvert has been interpreted as being due to ground water
discharging to the culvert where the VOCs either evaporate or are
diluted by inflow from the Pond. The possibility exists, with the
passage of time, for the downward spread of contamination from the
upper twenty feet through the stratified silty layer and ultimately
to the till and bedrock units.
TCE is present in significant quantities in only one well and has
been confined to that well (MW-11) with minor exceptions. TCE
appears to exist as a separate plume with a separate source and has
not migrated since it was detected in 1983.
Significant attenuation of contamination has not been observed in
groundwater at the site. Although TCA does degrade, it does so
slowly and in conjunction with specific mechanisms which appear to
be insufficient in the aquifer underlying the site. The primary
degradation and attenuation pathways are dilution/dispersion,
volatilization to the atmosphere, and biodegradation. Dilution and
dispersion have a minimal impact on the contaminants as ground
water flow is very slow. The rate of contaminant flow is less than'
the ground water flow (50 feet per year): however, it is difficult
to quantify. Volatilization has not impacted contaminant levels
at the site due to cold ground water temperatures. Biodegradation
has also not functioned to reduce contaminant levels as the
nutrients and environment required for microbial growth do not
extend into the fine silty sand aquifer from the surface. Some
biodegradation does occur at the Site albeit at low quantities and
slow rates. TCA is degrading slowly to less desired, and more
toxic contaminants such as 1,1 DCE: 1,2 DCA: and vinyl chloride.
An examination of TCA levels over the period 1982 through the
present show no distinct or significant trend of biodegradation or
attenuation. An examination of Appendix B, Table 1 demonstrates
that contaminant levels are not only increasing, but are also
appearing in wells that were previously uncontaminated. A further
discussion of contaminant fate is contained in section 5 of the RI.
E.
surface Water
Surface water at the site encompasses those waters in Pequawket
Pond and the catch basins for the drainage culvert to the east of
the Site (lot 7). All surface water samples were analyzed for VOCs
and the following metals: copper, chromium, mercury, nickel, and
zinc. In all surface water samples taken in 1989, no VOCs were
detected. However, some elevated levels have been detected in the
catch basins on lot 7 in 1983 and 1984. These levels are mcs~
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Two metal species, chromium and Nickel were detected at low
quantities (0.05 and 0.15 ppm respectively) in Pequawket Pond. It
may be further noted that these are the maximum levels optained and
that the majority of samples were below detection limits. Based
on the available data, it appears that any impacts of the KMC Site
on the surface water of Pequawket Pond are not significant.
F.
Sediments
Sediments sampled include those of Pequawket Pond and the catch
basins of the drainage culvert on the eastern side of lot 7.
Sediments associated with the septic tank will not be addressed in
this section. All sediment samples were analyzed for acid/base
neutral extractables (ABNs); VOCs; and the following metals;
copper, chromium, mercury, nickel, and zinc. Elevated levels of
mercury were detected in Pond sediments; however, no mercury has
been detected in the septic system or the casting sands. Therefore
the mercury does not appear to be associated with the Site.
While the volume of contaminated sediments underlying Pequawket
Pond remains large, those sediments associated with the catch
basins occupy a very small volume perhaps no greater than a cubic
yard. The mobility of these sediments, both in the pond and the
catch basins, is extremely limited. In these environments the
sediments will likely be buried under newer sediments as time
progresses.
G.
Air
Air monitoring at the Site has included ambient air sampling with
a photoionization detector, Draeger tubes specific to vinyl
chloride, charcoal collection tubes for laboratory analysis, and
air monitoring badges worn by on-site personnel and in stationary
deployment around the Site. Ambient air analysis consistently
showed no contamination above background levels. Vinyl chloride
was detected on personal air monitoring badges on two separate days
(7 & 8.4 ppm) when test pit operations on the Waste Pile were being
conducted. Passive air monitoring badges were positioned in
several locations across the site. These badges showed no
detection of any VOCs. Similarly, charcoal tubes were deployed
near several of the source areas and later analyzed at a
laboratory. These also showed no detection. It is believed that
the vinyl chloride that was detected during test pit operations
was a limited occurrence and was most likely a degradation product
of TCA.
H.
Structures
Structures on the site consist of two buildings, a larger building
to the south in which manufacturing operations took place
(designated as Building #1), and a smaller building to the north
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empty of equipment and no wastes are apparent in either building.
Several depressions in the floor are periodically filled with water
that is contaminated: however, this water is invading ground water
and not an additional source of contamination. The flo'or plan of
building #1 is shown in Appendix A Figure 8. .
A complete discussion of site characteristics can be found in the
RI at section 4, pages 4-1 through 4-23 and Section 5, pages 5-1
through 5-14.
VI.
SUMMARY OF SITE RISKS
The State's contractor, CDM, performed an Endangerment Assessment
(EA) to estimate the probability and magnitude of potential adverse
human health effects from exposure to contaminants associated with
the site. The EA is in chapter six (6) of the Remedial
Investigation Report. The human health risk assessment followed
a four step process: 1) contaminant identification, which
identified those hazardous substances which, given the specifics
of the site were of significant concern: 2) exposure assessment,
which identified actual or potential exposure pathways,
characterized the potentially exposed populations, and determined
the extent of possible exposure: 3 ) toxicity assessment, which
considered the types and magnitude of adverse health effects
associated with exposure to hazardous substances: and 4) risk
characterization, which integrated the three earlier steps to
summarize the potential and actual risks posed by hazardous
substances at the Site, including carcinogenic, and noncarcinogenic
risks at the site. The results of the human health endangerment
assessment for KMC are discussed below.
An ecological assessment, found in chapter seven (7) of the
Remedial Investigation Report, provides a qualitative assessment
of potential adverse environmental effects from exposure to
contaminants at the site. A summary of the conclusions from the
ecological assessments follows the human health risk assessment.
Thirteen (13) contaminants of concern, listed in Tables 2 through
5 found in Appendix B of this Record of Decision, were selected
for evaluation of potential human health effects from exposure to
ground water, waste piles, surface water and sediments in the EA.
These contaminants constitute a representative subset of all the
contaminants identified at the site during the Remedial
Investigation. contaminants of concern were selected to represent
potential site related hazards based on toxicity, concentration,
frequency of detection, and mobility and persistence in the
environment. A summary of the health effects of each of the
contaminants of concern can be found in section 6.1.3 of the
Endangerment Assessment.
An assessment of potential adverse effects to the ground water frc~
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The septic system includes the septic tank and the leachfield
soils. Four volatile organic compounds were found in the
leachfield soils during the 1985 investigation. The. chemicals
identified include; Tetrachloroethylene, 1,1,1~Trichloroethane,
Methylene Chloride, and 1,1-Dichloroethane. For this scenario
1,1,1-Trichloroethane was used as an indicator chemical to
establish an allowable concentration of VOCs in soil to protect the
ground water. Cleanup levels are explained in more detail in
Section X of this document.
Potential human health effects associated wi th e~posure to the
contaminants of concern were estimated quantitatively through the
development of several. hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future
uses, and location of the Site. The scenarios developed are
considered to be a reasonable worst case estimate. The following
is a brief summary of the exposure pathways evaluated. A more
thorough description of exposure pathways can be found in section
6.3 of the EA which is in Chapter 6 of the RI.
Ground Water
The ground water is not currently being used. Therefore no
current exposure scenario was considered. Future use of
ground water by residents, as a drinking water supply, was
evaluated as a potential exposure pathway. The ground water
underlying the Site has a classification of lIB, a potential
drinking water source. For this scenario a lifetime of
consuming two (2) liters of water per day was assumed.
Waste Piles
Ingestion of waste pile contaminants was evaluated for
potential current and future exposures. The current scenario
assumed trespassing by older children, seven (7) to eighteen
(18) years old, 32 days per year for twelve (12) years. For
the future scenario, residential use of the site was assumed.
The exposure scenario evaluated a more sensitive population,
children aged one (1) to six (6). It was assumed they might
be exposed to the contaminants in the waste piles 100 days per
year for six (6) years. No current exposure scenario was
considered for the inhalation of particulate matter from the
waste pile. Future exposure is contingent upon either man-
made or natural disturbance of the waste piles natural cover.
It is not possible to quantify risks associated with the
inhalation of particulate matter in the future scenario:
therefore, this risk will be discussed from a quali tati ve
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17
Surface Water
"
Incidental ingestion of one tenth of a liter of surface water
while swimming was evaluated as a potential current-and future
exposure pathway. The current scenario assumed swimming in
Pequawket Pond 16 days per summer for 70 years. The future
scenario assumed residential use of the site and increased use
of the pond to 64 days per summer.
Sediments
Ingestion of sediments was evaluated for potential current and
future use. The current scenario assumed ingestion of
sediments by older children seven (7) to eighteen (18) years
old, 16 days per year for twelve (12) years. Residential use
for the site was assumed for the future scenario and a more
sensitive population, children aged one (1) to six (6), was
evaluated. It was assumed young children might ingest 200
milligrams of sediment 64 days per year for six years.
Cancer risks are calculated by multiplying the toxicity and the
exposure: Risk = Toxicity x Exposure. The toxicity of carcinogenic
compounds is expressed as a chemical specific cancer potency factor
(CPF). The cancer potency factor is the potency per milligram of
contaminant per kilogram of body weight per day. Cancer potency
factors have been developed by EPA from epidemiological or animal
studies to reflect a conservative "upper bound" of the risk posed
by potentially carcinogenic compounds. That is, the true risk is
very unlikely to be greater than the risk predicted.
Exposure level refers to an individual uptake of contaminant based
on site specific information and assumptions. The exposure level
is expressed as milligrams of contaminant per kilogram of body
weight per day. Risk for an individual contaminant is then
calculated as follows: Risk = cancer potency factor x Exposure.
The resulting risk estimates are expressed in scientific notation
as a probability (e.g. 1.0E-06 or 10-6 for one in a million) and
indicate (using this example) that an individual is unlikely to
have greater than a one in a million chance of developing cancer
over 70 years as a result of site-related exposure to the compound
at the stated concentration.
The hazard index (HI) was also calculated for each pathway as EPA's
measure of the potential for noncarcinogenic health effects. The
hazard index is calculated by dividing the exposure level by the
reference dose (RfD) or other suitable benchmark for
noncarcinogenic health effects. Thus, exposure levels which are
below the reference dose will yield a hazard index less than one.
A hazard index less than one indicates that lifetime exposure to
the contaminant is unlikely to produce an adverse health effect.
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individuals over the course of a lifetime. They reflect a daily
exposure level that is likely to be without an appreciable risk of
an adverse health effect. Reference doses are derived from
epidemiological or animal studies and incorporate uncertainty
factors to help ensure that adverse health effects will not occur.
Tables 6 through 13, found in Appendix B of this Record of
Decision, summarize the adverse human health effects for the
exposure pathways identified above. Each table identifies the
average and reasonable maximum exposure based on the average and
maximum concentration of contaminants. Contaminants which produce
carcinogenic effects were found only in ground water, therefore a
risk estimate was calculated for drinking ground water.
Contaminants that produce noncarcinogenic effects were evaluated
for drinking ground water, and ingestion of waste piles, surface
water, and sediments. Adverse effects from dermal contact were not
quantified since the contaminants identified in these media are not
known to be absorbed through the skin.
The current potential risks from the ground water at this site
exceed EPA's established risk range of one in ten thousand (10"4)
to one in a million (10-6) for carcinogenic contaminants and a
hazard index greater than one (1) for contaminants with
noncarcinogenic effects. For ground water the potential future
risk estimates of excess lifetime cancer risk range from seven (7)
cancer cases in 10,000 to 1.5 cancer cases in 100. The chemical
1,1-Dichloroethylene contributes approximately 70 percent of the
risk. For the chemicals with noncarcinogenic effects the total
hazard indices for ground water are equal to or greater than one
(1) which indicates that the concentrations of contaminants could
result in adverse effects.
Many contaminants of concern in ground water exceed drinking water
regulations Maximum Contaminant Level (MCL) or Maximum Contaminant
Level Goal (MCLG). The following is a list of contaminants of
concern, their MCL or MCLG and the maximum value of ,that
contaminant found to exist in the ground water at the Site in 1989:
TABLE II
Contaminant
MCL\MCLG
1,1,1 Trichloroethane
1,1 Dichloroethylene
1,2 Dichloroethane
Trichloroethylene
200 ppb
7 ppb
5 ppb
5 ppb
MAXIMUM CONCENTRATION
(1989)
5,680.0 ppb
615.0 ppb
14.6 ppb
120.0 ppb
The contaminants in the waste piles, based on the potential future
exposure scenario, results in a hazard index greater than one. T~0
main contaminant found in the waste pile is chromium. Due to t~0
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assessment assumed all the chromium detected is in the hexavalent
ionic state. This assumption produces a result that is protective
of human health. The hazard indices were less than one for
ingestion of sediments and surface water for the future and current
scenarios. Therefore, these two pathways are not considered as a
threat to human health.
The inhalatioh of fine particulate material from the waste pile
may present an imminent and substantial endangerment to the public
health in the future scenario. If the waste pile is exposed by
either natural or man-made events, the possibility exists that a
significant amount of the waste pile material could be entrained
by the wind (up to 40%). This material contains fine silica, and
particulate chromium and nickel. Chromium (hexavalent ionic state)
and nickel are carcinogenic by the inhalation route. Fine-grained
silica, when inhaled, leads to silicosis.
A qualitative study of the ecological effects of the site was
conducted. It found that ingestion of contaminants at the site by
the biological community (as described in section 7.1 of the RI)
does not appear to pose a major risk. The major risk posed is from
potential destruction of the waste piles since they are within the
100 year flood plain and encroach on the wetlands. Erosion of this
waste pile during major flooding events could pose a potentially
significant risk to the Pequawket Pond system and the wetlands.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, and the environment. Specifically an imminent
and substantial threat to public health and the ecosystem could
result from the waste pile and potential threat to human health
could occur from drinking ground water.
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. statutory Requirements/Response objectives
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 all federal and
more stringent state environmental standards, requirements,
criteria or limitations, unless a 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 preference for remedies in which treatment which
permanently and significantly reduces the volume, toxicity or
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20
remedies not involving such treatment. Response alternatives were
developed to be consistent with these congressional mandates.
Based on preliminary information relating to types of contaminants,
environmental media of concern, and potential exposure pathways,
remedial action objectives were developed to aid in the development
and screening of alternatives. . These remedial action objectives
were developed to mitigate existing and future potential threats
to public health and the environment. These response objectives
were:
1.
To minimize further horizontal and vertical migration of
contaminated ground water from the KMC site;
2 .
To minimize any negative impact to Pequawket Pond
resulting from discharge of contaminated ground water;
3.
To prevent the inhalation of wind blown fine, particulate
materials from the Waste Piles;
4 .
To reduce the risks associated with ingestion of or
physical contact with metals in the Waste Piles;
5.
To prevent the possibility of a release of other
contaminants that may be present in the Waste Piles:
6.
To prevent the migration of contaminants from the septic
system and surrounding soils that could further degrade
ground water quality, and;
7.
To reduce the risk associated with inhalation of VOCs and
physical contact with the contents of the septic system
or the surrounding soils.
B.
Technology and Alternative Development and screening
CERCLA and the NCP set forth the process by which remedial actions
are evaluated and selected. In accordance with these requirements,
a'range of alternatives was developed for the site.
with respect to source control, the Feasibility study (FS)
developed a range of alternatives in which treatment that reduces
the toxicity, mobility, or volume of the hazardous substances is
a principal element. This range included an alternative that
removes or destroys hazardous substances to the maximum extent
practicable, eliminating or minimizing the need for long ter:::
management. This range also included alternatives that treat the
principal threats posed by the site but vary in the degree 0 f
treatment employed and the quantities and characteristics of tr.c
treatment residuals and untreated waste that must be manage:::
alternatives that involve little or no treatment but provi.:.'
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21
action alternative.
with respect to ground water response action, the FS developed a
limited number of remedial alternatives that attain site specific
remediation levels within different time frames using different
technologies: and a no action alternative.
v
Chapter 3 of the FS identified, assessed, and screened technologies
based on implementability, effectiveness, and cost. These
technologies were combined into source control (SC) and management
of migration (MM) alternatives. Chapter 3 of the FS presented
remedial alternatives that were developed by combining the
technologies identified in the previous screening process, into the
categories identified in Section 300.430(e) (3) of the NCP. The
purpose of the initial screening was to narrow the number of
potential remedial actions for further detailed analysis while
preserving a range of options. Each alternative was then evaluated
and screened in Chapter 4 of the FS.
In summary, of the 13 source control and 8 management of migration
remedial alternatives screened in Chapter 3 of the FS, five source
control and six management of migration alternatives were retained
for detailed analysis. Tables 3-5 and 3-6 of the FS identify the
alternatives that were retained through the screening process, as
well as those that were eliminated from further consideration.
VIII.
DESCRIPTION OF ALTERNATIVES
This. Section provides
evaluated. A detailed
be found in Tables 3-3
FS.
a narrative summary of each alternative
tabular assessment of each alternative can
of Section 3 and 4-10 of Section 4 of the
A.
Source Control (SC) Alternatives Analyzed
Source control alternatives are concerned with the elimination of
those areas in which large concentrations of contaminants exist
that were formerly disposal areas. These areas may still
contribute to the spread of, or intensification of, contamination
to the sediments, ground water, or surface water at and off the
Site. The principle source area, and prime threat, that has been
identified is the septic tank with its leach field. The waste
piles are c::.onsidered to be potential source areas since their
contents are not fully characterized and disposal practices in the
past may have resulted in hazardous substances being placed there.
Also, the waste piles are considered to be a potential inhalation
hazard. If a drum within the waste pile containing a hazardous
substance were to discharge its contents, or if the waste piles
were to be disturbed such that they became subject to wind erosion,
the waste piles would be considered a prime threat.
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following alternatives:
SC-l:
No-action Alternative;
SC-3:
Off-site Solid Waste Landfili and On-Site Low
Temperature Thermal Stripping;
SC-5:
Off-Site Solid Waste Landfill
Incineration;
and Off-Site
SC-6:
Off-Site Solid Waste Landfill
Hazardous Waste Landfill; and
and Off-Site
SC-13:
Off-Site Hazardous Waste Landfill.
SC-l
No-Action
This alternative is included in the Feasibility Study (FS), as
required by CERCLA, to serve as a basis for comparison with the
other source control alternatives being considered.
This source control alternative would involve no remedial action
on the contaminated soil associated with the leaching field, the
septic tank, or the waste piles. Further, the hazard of a drum
containing a hazardous substance within the waste pile discharging
its contents will remain unmitigated.
This alternative does not meet any identified ARARs, particularly
since MCLs are already exceeded at the site. Leaving the waste
pile intact may lead to violations of the Clean Water Act (CWA) if
a buried drum were to rupture, and violations of EO 11990
(Protection of Wetlands) if the waste pile were to erode and fill
portions of the wetlands. Disturbing the waste pile in a search
for drums, and then placing the nonhazardous components of the
waste piles on-site may lead to violations of the Clean Air Act
(CAA) , EO 11988 (Floodplain Protection), EOl1990, and will lead to
violations of New Hampshire Solid Waste Rules.
SC-3
Off-site Solid Waste Landfill and On-site Low Temperature Thermal
striPPing
This alternative involves excavation of the waste piles and on-
site treatment of the leach field soils. EPA estimates that the
portion of the waste piles contaminated with hazardous substances
above cleanup levels will make up approximately five percent of the
waste piles. This estimate is based on test pitting, data
collected by GEI, and soil borings conducted within the waste pile.
The larger waste pile, which is behind building #1, contains an
estimated volume of 4,250 cubic yards (including two feet of
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23
of the larger waste pile and behind building #2, contains an
estimated 400 cubic yards (including two feet of underlying soil) .
The remaining 4,400 cubic yards of fine particulate materials in
the waste piles will be taken off-site to a RCRA subtitle D solid
waste facility or will be disposed of in an appropriate manner that
will comply with all federal, state, and local laws. Removal of
the waste piles will be conducted so as to minimize dust
production. This action will reduce the potential hazard of the
inhalation of carcinogenic and toxic, noncarcinogenic particulate
matter. Removing the waste piles will also ensure compliance with
wetland and floodplain ARARs, and the New Hampshire Solid Waste
regulations.
The materials in the waste piles containing hazardous substances
above cleanup levels, which are estimated at 250 cubic yards, will
be excavated, transported, and treated prior to landfilling in a
RCRA subtitle C hazardous waste landfill. Treatment methods in all
of the alternatives cited in which there is off-site landfilling
at a RCRA Subtitle C hazardous waste landfill (SC-3, SC-5, SC-6,
and SC-13) will be dependent on which RCRA Subtitle C hazardous
waste landfill is in compliance and accepting wastes when the
remedy begins.
contaminated leach field soils will be treated on-site with low
temperature thermal aeration for this alternative. The
contaminated leaching field soils are believed to occupy a volume
of 250 cubic yards. It is assumed that it will be necessary to
excavate the area of the leach field (125 square yards) down to the
water table or a depth of 6 feet. The leaching field excavation
will be preceeded by an exploratory boring program to fully
characterize the volume and nature of contaminants to be removed.
Excavation and removal of contaminated leach field soils will be
based on the cleanup levels contained in section X of this
document. The results of several pilot studies have demonstrated
that VOC removal efficiencies of 99.99% are possible with low
temperature thermal aeration. The treated soil will be di~posed
of on-site in the same area from which it was excavated.
The septic tank and its contents (a total of 5 cubic yards) will
be excavated and transported off-site for incineration. The
residue will be disposed of at a RCRA Subtitle C Hazardous Waste
Facility.
Applicable or Relevant and Appropriate Requirements (ARARs) for the
removal, transport, and incineration of the septic tank include
the CWA, the CAA, portions of the Resource Conservation ar.:
Recovery Act (RCM), the Safe Drinking Water Act (SDWA), OSH:'"
requirements, DOT rules for Hazardous Materials Transport.
Executive Orders (EO) 11988 Floodplain Management, EO 119G'
Protection of Wetlands, N.H. Hazardous Wastes Rules, N.H. Sol;:
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24
statutes. Land Disposal Restrictions (LDRs) under 40 CFR 268 will
apply to any containerized wastes that are discovered during the
waste pile excavation if those wastes are either labeled as RCRA
listed hazardous wastes, or if they have. properties of
characteristic wastes. Any materials found during the excavation
of the waste piles that are subject to the LDRs, will be
. containerized or overpacked and transported to the appropriate
treatment and disposal facility.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 1 month
TIME FOR OPERATION: 6 months
CAPITAL COST: $3,301,000
o & M: (Included with Capital Costs)
TOTAL COST (Present worth): $3,301,000
sc-s
Off-site Solid Waste Landfill and Off-Site Incineration
This alternative provides the same method of treatment and disposal
for the waste pile materials as SC-3.
Leaching field soils will be excavated as in SC-3, and transported
to a facility to be incinerated. Destruction efficiencies for VOCs
contained in soil and debris through incineration are very high
(99.9999%). Residue from the incineration process may be treated
and disposed of at a RCRA subtitle C Hazardous Waste facility.
The ARARs of concern are the same as in SC-3.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 1 month
TIME FOR OPERATION: 6 months
CAPITAL COST: $4,060,000
o & M: (Included with Capital Costs)
TOTAL COST (Present worth): $4,060,000
SC-6
Off-site Solid Waste Landfill and Off-site Hazardous Waste Landfill
,
Waste pile material will be treated and disposed of in a fashion
identical to SC-3 and SC-5.
Leaching field soils in this alternative will be excavated as in
SC-3, transported off-site, treated, and disposed of in a RCRA
subtitle C hazardous waste landfill.
The ARARs of concern are the same as in SC-3 and SC-5.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 1 month
TIME FOR OPERATION: 6 months
CAPITAL COST: $3,256,000
o & M: (Included with Capital Costs)
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25
SC-13
Off-site Hazardous Waste Landfill
This alternative would result in the removal of both waste piles
in their entirety and the leach field soils for disposal at a RCRA
subtitle C hazardous waste landfill. This alternative was
formulated on the presumption that aIr of the waste pile material
is unsuitable for disposal at a solid waste landfill.
The ARARs of concern are the same as in SC-3, SC-5, and SC-6.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 1 month
TIME FOR OPERATION: 6months
CAPITAL COST: $4,566,000
o & M: (Included with capital Costs)
TOTAL COST (Present worth): $4,566,000
B.
Management of Migration (MM) Alternatives Analyzed
Management of migration al ternati ves address contaminants that have
migrated from the original source of contamination. At the
Kearsarge Metallurgical Site, contaminants have migrated from the
area of the leaching field and larger waste pile. Ground water
flows to the east from the source area. Surface water flows to the
south into adj ,'\cent Pequawket Pond and east into the adj oining
wetlands. The prime threat is the contaminated ground water plume-
which is flowing to the east.
The Management of Migration alternatives evaluated for the site
include:
MM-l:
MM-2:
MM-3:
MM-4:
MM-5:
MM-6:
MM-l
No-Action
No M:tion;
Ground Water Monitoring Program;
Ground Water Extraction, On-Site Treatment, and
On-Site Recharge;
,
Ground Water Extraction, On-Site Treatment, and
Discharge to Surface Water;
Ground Water Extraction, On-Site Treatment, and
Discharge to Publicly Owned Treatment Works
(POTW); and
Ground Water Extraction, On-Site Treatment, and
Discharge to POTW or On-Site Recharge;
Under this al ternati ve, no active measures would be taken t
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26
Further, no monitoring of the contaminant plume would occur.
Contaminant levels in the ground water at the site exceed MCLs,
and show no tendency to attenuate with time. Therefore, this
alternative is neither practicable, nor protective of human health
and the environment. .
This alternative does not meet any identified ARARs, particularly
since MCLs are already exceeded at the site.
MM-2
Ground Water Monitorinq Proqram
This alternative consists of long-term ground water sampling and
analysis to monitor contaminant concentration and migration, and
imposition of institutional controls such as deed restrictions to
prevent the development of contaminated ground water for use as
drinking water. Sampling would be performed twice a year for the
first five years and annually for an additional 25 years. Under
this alternative additional sampling beyond 30 years may be
possible if contaminant levels persist.
This alternative does not meet any identified ARARs, particularly
since MCLs are already exceeded at the Site.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 1 to 2 years
TIME FOR OPERATION: 30 years
CAPITAL COST: $85,000
o & M (Present Worth): None
TOTAL COST (Present worth): $85,000
MM-3
Ground Water Extraction. On-site Treatment. and On-Site Recharqe
Alternatives MM-3, MM-4, MM-5, and MM-6 are identical in that they
propose to extract the contaminated ground water and treat it. The
primary difference is where the water is discharged. The ground
water would be extracted from the shallow aquifer with either
groups of wells or an extraction trench. The coliected
contaminated ground water would then be treated to remove metals
by chemical precipitation. The precipitation process tentatively
selected, the sulfide process, would remove iron and manganese
which would reduce the efficiency of further treatment processes.
Prior to full implementation of the management of migration remedy
a pilot plant or treatablility study would be performed to
determine the proper metal precipitation process and the ability
of the complete system to remove all contaminants of concern to the
required levels. The sulfide process was selected because it
removes chromium and nickel, which were the metals selected as
contaminants of concern in the ground water. The solids that would
be precipitated out of the ground water would be dewatered an:!
shipped to a hazardous waste treatment and disposal facility ~:
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if determined to be non-hazardous. Ground water would then be
treated to remove VOCs, utilizing an air stripping treatment. In
air stripping, the contaminated groundwater is pumped ~o the top
of a tower where, as the water cascades down,air is forced up
through the tower removing VOCs from the ground water and placing
them into the air stream. The resulting air stream is then passed
through an activated carbon filter to remove contaminants before
being released to the atmosphere. Prior to discharge to the sewer,
the ground water contaminants will be reduced to a level at or
below cleanup levels as outlined in Section X of this document.
In this alternative (MM-3) ground water would be extracted and
treated to cleanup levels. Once treatment is complete, ground
water would be re-introduced to the watertable through an
underground recharge bed. The on-site recharge would assist in
flushing the contaminated ground water through to the extraction
system. The increased time frame for cleanup, 10 to 15 years: as
opposed to 10 years for alternatives MM-4, MM-5, and MM-6i is due
to climate conditions at the site. Freezing temperatures or
seasonally high ground water levels may restrict the use of aquifer
recharge as proposed in this alternative.
ARARs for this alternative, and each of the following alternatives,
are the CWA, the SDWA, the CAA (for emissions from the stripper),
Executive Orders 11988 (floodplains), 11990 (wetlands), .and New
Hampshire Wetland regulations. Ground water recharged to the
aquifer must meet the cleanup levels established in this Record of
Deci~ion (ROD). Also, any discharge of treated ground water to
ground water at the Site must meet the requirements of the New
Hampshire ground water discharge limits in accordance with N.H.
Code Ws 410, Protection of Ground Water.
Alternatives MM-3, MM-4, MM-5, and MM-6 are affected by EO 11990
and N.H. Wetland regulations because of the negative impact the
construction of a ground water extraction system and ground water
pumping may have on the wetlands. Compliance with these
regulations will involve maintaining erosion and siltation controls
during construction, and restoring those areas to their formerly
beneficial role as wetlands once construction is completed. These
al ternati ves will have minimal impact on the wetlands during
operation in that the dewatered area will be minimal as low
permeability will reduce the size of the cone of depression. The
greatest impact on wetlands will be the construction of the
extraction system which will alter an area of 350 feet by 40 feet.
This alteration will be temporary as the grades within the
construction area will be returned to the present undisturbed
topography once the extraction system is installed. Additionally,
the cone of depression from the pumping of a trench or a series of
wells will dewater a very narrow area (10 feet). The type of
wetland will be altered from a forested wetland to a shrub-scrub
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EO 11988 has the goal of maintaining the character of floodplains
and minimizing the impact of floods on human health and safety.
This goal is accomplished by minimizing construction within
floodplains. The management of migration alternatives that utilize
groundwater treatment (MM-3, MM-4, MM-5, and MM-6) would affect the
area to a minimal extent. These alternatives would either add only
a small building (less than 1,000 square feet) to an area that
already is moderately developed, or would feature no above ground
structures at all if the existing building is deemed suitable to
house the treatment plant.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 2 years
TIME FOR OPERATION: 10 to 15 years
CAPITAL COST: $3,158,000
o & M (Present Worth): $1,032,000
TOTAL COST (Present worth): $4,275,000
~
Ground Water
Surface Water
Extraction,
On-site
Treatment,
and
Discharge
to
This alternative features the same extraction and treatment system
as MM-3; however, in this case the discharge water is discharged
to the surface water by a diffuser constructed on the bottom of
Pequawket Pond.
ARARs will be the same as for MM-3; however, treatment must also
comply with substantive National Pollutant Discharge Elimination
System (NPDES) requirements. NPDES requirements, due to Ambient
Water Quality Criteria may be more stringent and require more
compliance monitoring than would be associated with other
al ternati ves. NPDES discharge restrictions for certain metals that
are found in the ground water at the site are very stringent. The
NPDES limits set for mercury (0.012 ppb) are lower than the
analysis detection limits that were used to quantify mercury at
the Site (0.3 ppb). Therefore, it is uncertain whether NPDES
limits for mercury could be met.
ESTIMATED TIME FOR CONSTRUCTION: 2 years
ESTIMATED TIME FOR OPERATION: 10 years
ESTIMATED CAPITAL COST: $2,891,000
ESTIMATED 0 & M (Present Worth): $1,032,000
ESTIMATED TOTAL COST (Present worth): $4,008,000
MM-S
Ground Water Extraction, On-site Treatment,
PUbliclY Owned Treatment Works (POTW)
and
Discharqe
to
The discharge of treated ground water would be through a new se~e:.
connection from the on-site treatment building to the public se~.~:
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29
ARARs will be the same as for the previous alternatives, excepting
NPDES requirements. The treated water, prior to introduction to
the sewer system, would be of drinking water quality. The Conway
Village Fire District (CVFD) does not presently have industrial
pretreatment standards. CVFD and its engineer will develop
discharge standards prior to the implementation of this
alternative. .Final treatment and disposal would occur at the POTW.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 2 years
TIME FOR OPERATION: 10 years
CAPITAL COST: $2,891,000
o & M (Present Worth): $1,044,000
TOTAL COST (Present worth): $4,020,000
MM-6
Ground Water Extraction. On-site Treatment. and Discharqe to POTW
or On-site Recharqe
This alternative features discharge to the POTW, and the use of an
on-site ground water recharge system when discharge to the POTW is
not possible. This is a combination of alternatives MM-3 and MM-
5, and was devised to address the possibility of exclusion from the
POTW if demand dictates, or the possibility of seasonal limitations
for recharge.
ARARs for this alternative are the same as MM-3, and the treatment
of ground water would also be to the levels specified by the POTW
as outlined in MM-5.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR CONSTRUCTION: 2 years
TIME FOR OPERATION: 10 years
CAPITAL COST: $3,162,000
o & M (Present Worth): $1,044,000
TOTAL COST (Present worth): $4,291,000
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121 (b) (1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
al ternati ves. Building upon these specific statutory mandates,
the NCP articulates nine evaluation criteria to be used in
assessing the individual remedial alternatives.
A detailed analysis was performed on the five source control and
six management of migration alternatives using the nine evaluation
criteria in order to select a site remedy. The following is a
summary of the comparison of each alternative I s strengths and
weakness I with respect to the nine evaluation criteria. These
criteria and their definitions are as follows:
Threshold criteria
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in order to be eligible for selection in accordance with the NCP.
1. Overall protection of human health and the e~vironment
addresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced or. controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy meets
all ARARs or other Federal and state environmental laws and/or
provides grounds for invoking a waiver.
Primary Balancinq criteria
The following five criteria are used to
elements of alternatives which have met the
each other.
compare and evaluate
threshold criteria to
3. Long-term effectiveness and permanence refers to the
ability of a remedy to maintain reliable protection of human
health and the environment over time, once clean-up goals have
been met.
4. Reduction of toxicity, mobility, or volume through
treatment addresses the degree to which alternatives employ
recycling or treatment that reduces toxicity, mobility, or
volume including how treatment is used to address the
principal threats posed by the site.
5. Short term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on human
heal th and the environment that may be posed during the
construction and implementation period, until clean-up goals
are achieved.
6. Implementability addresses the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to implement a
particular option.
7. Cost includes estimated capital and operation
maintenance (O&M) costs, as well as present-worth costs.
&
MOdifvinq criteria
The modifying criteria are factored into the final balancing
remedial alternatives. This generally occurs after EPA
received public comment on the RI/FS and Proposed Plan.
of
has
8. State acceptance addresses the state's position and ~e~.
concerns related to the preferred alternative and Otr,0:
al ternatives; and the state's comments on ARARs or t:-..
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31
9. community acceptance addresses publics general response
to the alternatives described in the Proposed Plan and RIFS
report.
A detailed tabular assessment of the nine criteria applied to each
alternative can be found in Section 4 in Table 4-10 of the
Feasibility Study. .
Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of each
al ternati ve against the nine criteria, was conducted. This
comparative analysis can be found in section 4 of the Feasibility
Study. .
The following section balances the strengths and weaknesses of the
five source control and six management of migration alternatives
under each of the nine criteria set out above.
1.
Overall protection of human health and the environment
Source control alternatives SC-5, SC-6, and SC-13 will be equally
protective of human health and the environment since they utilize
technologies that will reduce contamination to acceptable levels
and prevent direct contact, ingestion, and inhalation of site
contaminants. These technologies include soil treatment,
incineration, and disposal at regulated facilities. Alternative.
SC-l is not protective since it anticipates no action on-site and
leaves the site hazards intact. Alternative SC-3 is not as
protective as SC-5, SC-6, and SC-13 since SC-3 will be treating the
material on-site, creating the potential for VOC emissions to
impact nearby residences.
The combined soil removal and treatment of SC-3, SC-5, SC-6, and
SC-13 would cease the further contamination of ground water beneath
the site. The groundwater treatment components of MM-3, MM-4, MM-
5 and MM-6 would treat already contaminated groundwater to Federal
and state drinking water standards at the site. Further, downward
and off-site migration of contaminants in the groundwater caused
by precipitation and soil leaching would be controlled. Dust
erosion, surface runoff and direct contact with contaminated soils,
wastes and sediments would also be minimized by the proper remov~l
and treatment of those areas designated as source areas.
Management of Migration alternatives MM-3, MM-4, MM-5, and MM-6 use
technologies that will be equally protective of human health and
the environment by reducing contamination and by preventing the
ingestion of site contaminants. The technologies employed include
metals removal via precipitation, and VOC removal via air
stripping. Alternatives MM-l and MM-2 are not protective since
those alternatives anticipate no action on-site which will leave
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32
Monitoring alone, without a groundwater treatment system as in MM-
3, MM-4, MM-S, and MM-6 would allow contaminants to continue to
migrate downward into the groundwater and off-site. Monitoring
alone may be used as a remedy at sites which have naturally
occurring impermeable layers under the groundwater flow zone which
act to restrict this downward migration. The Kearsarge
Metallurgical site has no impermeable layer under the groundwater
flow zone; rather the site is situated on a thick cover of alluvial
deposits over bedrock. Without groundwater treatment, MM-1 and MM-
2 will not meet MCLs at the Site, and will not be protective of
human health and the environment.
2.
Compliance with ARARS
Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific and location specific ARARs.
These alternative-specific ARARs are presented in Appendix B,
Tables 14 through 16.
Alternatives SC-3, SC-S, SC-6, and SC-13 would be subject to
essentially the same ARARs with varying degrees of compliance
required for each. SC-3, on-site treatment of leach field soils,
would have to comply with the more stringent portions of the CAA.
SC-3 would have a greater impact on interests protected by EO 11990
(wetlands) and EO 11988 (flood plains) than SC-S, SC-6, and SC-13
since the excavation of the waste pile would be prolonged. SC-S,
off-si te incineration of leach field soils, would also have to
comply with stricter requirements under the CAA. SC-6 and SC-13
would have fewer ARARs to satisfy than the other alternatives, and
those standards can be more easily achieved than with the other
alternatives.
MM-1 and MM-2 do not attain the following federal and state ARARs
for groundwater: Safe Drinking Water Act (SDWA), WS 410 NH
Groundwater Quality Criteria, WS 300 NH Drinking Water Standards,
and Federal Ambient Water Quality criteria (AWQC). SC-1 does not
comply with RCRA 40 CFR Part 264 and the State of New Hampshire
regulations for the disposal of hazardous waste. SC-l also would
violate Executive Order 11990 (wetlands) and Section 404 of the
Clean Water Act as future erosion and surface transport would fill
portions of the wetlands.
Alternatives MM-3, MM-S, and MM-6 would equally comply with the
SDWA as well as NH Ground Water Quality Criteria and Drinking Water
Standards. Additional requirements would be necessary for each of
the following ground water treatment options. Alternative MM-3
would have to comply with the N.H. Ground Water discharge limits
and other applicable New Hampshire ground water anti-degradation
regulations. Alternative MM-4 would have to comply with the
stringent treatment standards for metal constituents as directed
by the Ambient Water Quality Criteria (AWQC) under NPDES.
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33
and MM-4 meet. Alternative MM-5 would have to meet discharge
limits as set by the POTW.
3 .
Lonq term effectiveness and permanence
Alternative SC-5. offers the greatest degree of long-term
effectiveness and permanence when one compares the five source
control alternatives. This alternative provides for off-site
incineration of contaminated leach field soil. Incineration and
treatment destroys the source of contamination and meets cleanup
goals for VOCs and metals. Alternative SC-6 and SC-13 also provide
for long-term effectiveness and permanence for the site in that the
contaminated materials are removed. These alternatives include
treatment of contaminated soils and disposal at a RCRA subtitle C
hazardous waste landfill. These alternatives do not provide for
the same long-term effectiveness and permanence as SC-S, since the
residual contaminant levels will be higher for SC-3, SC-6, and SC-
13. SC-1, the no action alternative, provides for neither long-
term effectiveness nor permanence as all contaminants will remain
at the Site.
Alternatives MM-3, MM-4, MM-5, and MM-6 offer an equal degree of
long-term effectiveness and permanence of the six management of
migration alternatives. These alternatives use. on-site extraction
and treatment of contaminated groundwater. The precipit?tion of
metal species and air stripping of VOCs will remove contaminants
from the ground water and meet the cleanup goals for VOCs and
metals. MM-1 and MM-2 provide little or no long-term effectiveness
and .permanence as neither alternative proposes any action to
remediate the contaminated ground water. Natural attenuation is
not currently reducing the risk from ground water. The ablilty and
time required for the ground water beneath the site to become
clean, with no active measures being taken, cannot be determined.
Removing the source areas from the site as required by SC-3, SC-
5, SC-6 and SC-13 are most effective in minimizing the potential
for further contamination of groundwater. Unless the efforts
proposed by MM-3, MM-4, MM-S, and MM-6 are undertaken contaminated
groundwater would continue to migrate offsite for a significant
period of time.
4 .
Reduction of toxicity. mobility. or volume throuqh treatment
Alternative Sc-s provides for the greatest reduction of toxicity,
mobility and volume in soil through incineration of contaminated
soil. Alternatives SC-6, and SC-13, although they do not include
incineration, will also reduce toxicity, mObility, and volume of
contaminants, although to a lesser degree than SC-S through
treatment and disposal of contaminated soils at a hazardous wast~
landfill. Alternative SC-3 , on-site treatment and disposal c!
leach field soils, will also reduce the toxicity and volume c..:
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34
those contaminants will be only slightly diminished compared to
alternatives SC-6 and SC-13. Alternative SC-l provides no
reduction in toxicity, mobility or volume through treatment since
no treatment is included. .
Alternatives MM-3, MM-4, MM-5, and MM-6 provide for similar
reduction of toxicity, mobility and volume in ground water through
the extraction and treatment of contaminated ground water.
Alternatives MM-l and MM-2 provide no reduction in toxicity,
mobility or vol~me through treatment since no treatment is
included.
5.
Short-term effectiveness
Because of the potential for release of contaminants during the
excavation and transport off-site, special engineering measures
would be taken to minimize the potential for contaminant emissions
to ensure short-term protection of workers and area residents
during cleanup related construction activities. These measures
include wetting excavated soil and air monitoring to insure that
negative impacts do not qccur. Alternative SC-3 could prolong and
increase the potential for community exposure to air emissions as
contaminated soil would be treated in an on-site Low Temperature
Thermal Aeration unit; therefore, SC-3 does not satisfy the short-
term effectiveness criteria as well as SC-5, SC-6, and SC-13.
Alternatives SC-5, SC-6, and SC-13 provide an equal level of short-
term protectiveness amoungst themselves, and the best level of
short-term protectiveness of all of the source control
alternatives. Excavation and treatment of soils for SC-3 will last
approximately 4 to 6 months. Excavation and transport for SC-5,
SC-6, and SC-13 will last only one to two months. Several of the
source control alternatives will involve truck traffic in
connection with the transport of contaminated soil: an estimated
246 truckloads in the case of SC-3, and 260 loads for SC-5, SC-6,
and SC-13. Alternative SC-3 (246 loads) has a difference of 14
truck loads over alternatives SC-5, SC-6, and SC-13 (260 loads).
The reduction of truck traffic in al ternati ve SC-3 is
insignificant. Dust control will be necessary during the
excavation, loading, and transport to prevent particles from
becoming airborne. Conventional construction dust control
techniques will accomplish this. The potential for spills and
accidents exists with loading and trucking operations.
Cleanup time for SC-3 is 4 to
construction. Cleanup time for
months. SC-l is not addressed,
under this alternative.
6 months from the beginning of
SC-5, SC-6, and SC-13 is 1 to 2
as no cleanup would be conducted
with respect to long-term environmental impacts all source control
alternatives have an equal potential to release contaminants to the
wetlands during excavation. Engineering controls would be in place
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35
controls include measures to minimize erosion and runoff into the
wetlands, dust and particulate abatement, and the containment of
hazardous solids and containerized liquids within the w~ste piles.
Additional environmental sampling (air, sediment, and surface
water) would be conducted to ensure protectiveness to human health
and the environment during the conduct of the remedy.
Management of migration alternatives MM-3, MM-5, and MM-6 would
provide an equal degree of short term effectiveness. Because of
possible on-site treatment plant disruptions, MM-4, which includes
discharge to surface water, would pose a greater risk of impact on
human health and the environment during the conduct of the remedy.
The time of construction for all of the management of migration
al ternatives would be one to two years. However, the cleanup
period of the remedy is ten years. The construction of the
extraction system would provide the potential for emission of
contaminants to the atmosphere and the introduction of contaminated
ground water to the surface water and wetland. During
construction, excavation or drilling into and below the watertable
would require the stockpiling of soil or the disposal of
drilling/development water and soil washings. Engineering controls
to sample the air emissions, discharged waters, or stockpiled soils
would be implemented during this construction phase. Additional
controls would be used to control sedimentation of the wetlands,
and minimize other impacts to the wetland.
The cleanup period is 10 years for MM-4, MM-5, and MM-6 and 10 to
15 years for MM-3. Impacts to the wetlands will be minimized by
recharge to the aquifer by Pequawket Pond and the low permeability
of the soils. MM-l and MM-2 are not addressed as no cleanup would
be conducted under either alternative.
6.
Implementabilitv
While all of the alternatives can be implemented, some alternatives
are technically easier to implement than others, based on their
design and complexity.
A limitation for all source control alternatives is the physical
area in which to operate. That portion of the site which is not
wetland or a part of the building is very small. stoCkpiling of
materials to be transported would be limited. SC-3 is more
difficult to implement than SC-5, SC-6, and SC-l3 in that a
treatment unit would occupy an additional amount of space. The
area limitation of SC-3 would only slow down the remedy and not
preclude it. SC-6 and SC-13 would be more easy to implement than
SC-5 from an administrative and operational perspective. In SC-
6 and SC-13 leach field and waste pile materials go to a hazardous
waste facility. In SC-5 the leach field soils go to an incinerato~
while the waste pile material goes to a hazardous waste landfill.
Alternative SC-13 may be more difficult to implement due to the
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36
hazardous waste disposal facility. The technologies for all of the
source control measures are used on other Superfund sites and are
not difficult to design and construct.
The construction of recharge or discharge structures as in MM-3 and
MM-6 (recharge bed), and MM-4(underwater diffuser for surface
water discharge) would be difficult to site. Little room exists
on the site for a recharge bed, additionally such a recharge bed
faces operational constraints such as a locally high ground water
table and seasonal temperature extremes. An underwater diffuser
in alternative MM-4 would be difficult to maintain and subject to
damage. Discharge into Pequawket Pond would require a NPDES permit
which would require additional treatment of the ground water to
remove chromium. Also, it is yet uncertain if ground water exceeds
the Ambient Water Quality Criteria (AWQC) set for mercury. Past
sampling rounds had detection limits above AWQC levels set for
mercury. Therefore, NPDES requirements may include additional
treatment for metals. Al ternati ve MM-5 is the most easily
implemented of all of the management of migration alternatives.
MM-5 requires tying into an existing sewer system for disposal of
treated ground water.
Alternatives MM-3, MM-4, MM-5, and MM-6 are all implementable, but
will be somewhat difficult to implement as construction will be
conducted in a forested wetland, and the watertable is near the
ground surface. Alternative MM-5 and alternative MM-6 may not be
implementable if the POTW is unable to accept the treated water
from the site due to flow restrictions or other restrictions that
may be imposed through its NPDES permit. If the POTW is able to
accept the treated ground water MM-5 is the most implementable.
If the POTW is unable to accept the treated ground water MM-3 is
the next most implementable remedy.
The no-action alternatives SC-l and MM-l, and the ground water
monitoring alternative MM-2, would be difficult to implement
effectively since there is no guarantee of the future use of the
Site or surrounding properties that are affected by the Site~
7.
Cost
The estimated present worth value of each alternative and the
-------
SC-l
SC-3
SC-5
SC-6
SC-13
COST COMPARISON OF SOURCE CONTROL ALTERNATIVES
37
No Action
$
Capital
Costs
Present
Worth
Off-site Solid Waste
Landfill and On-Site
Low Temperature Thermal
Stripping
Off-Site Solid Waste
Landfill and Off-site
Incineration
Off-Site Solid Waste
Landfill and Off-Site
Hazardous Waste Landfill
Off-Site Hazardous Waste
Landfill
o
o
3,301,000
3,301,000
4,060,000
4,060,000
3,256,000
3,256,000
4,566,000
4,566,000
*
Operation and Maintenance (0 & M) Costs are included
in Capital Costs for all source control alternatives
presented.
MM-l
MM-2
MM-3
MM-4
MM-5
COST COMPARISON OF MANAGEMENT OF MIGRATION ALTERNATIVES
No Action
Ground Water
Monitoring
Ground Water Extraction
On-Site Treatment, and
On-site Recharge
Ground Water Extraction
On-site Treatment, and
Discharge to Surface Water
Ground Water Extraction
On-site Treatment, and
Discharge to POTW
capital
Costs
*
Present
Worth
O&M Costs
( $/vr)
$
o
o
o
85,000
85',000
o
3,158,000 1,032,000
4,275,000
2,891,000 1,032,000
4,008,000
2,891,000 1,044,000
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38
COST COMPARISON OF
MANAGEMENT OF MIGRATION
(continued)
capital
Costs
ALTERNATIVES
O&M Costs
( $/vr)
*
Present
Worth
MM-6
Ground Water Extraction
On-Site Treatment, and
Partial Discharge to POTW
and Partial Recharge
3,162,000 1,044,000
4,291,000
*
Present worth costs for MM-3, MM-4, MM-5, and MM-6 also
include an additional $85,000 for ground water monitoring
that is not accounted for in columns headed "Capitol
Costs" and "0 & M Costs".
8.
State acceptance
The New Hampshire Department of Environmental Services (DES) has
been involved with the site from the beginning as summarized in
Section II of this document titled "Site History and Enforcement
Activities". The Remedial Investigation and Feasibility Study was
performed as a state lead through a cooperative agreement between
the State and the EPA. The New Hampshire DES has reviewed this
document and concurs with the alternative selected for a source
control remedy and a management of migration remedy as documented
in the attached Declaration of Concurrence.
9.
Community acceptance
The comments received during the public comment period and the
discussions during the Proposed Plan and FS public meeting are
summarized in the attached document entitled "The Responsiveness
Summary" (Appendix C). Comments were received from one resident
living near the Site, local officials, and from a potentially
responsible party. The citizen commented on concerns for public
safety and community needs, and wanted more remedial alternatives
to be examined. Local officials expressed concerns over liability.
The potentially responsible party commented on the source cohtrol
portion of the remedy suggesting that EPA choose the minimal source
control remedy, SC-1. The potentially responsible party did net
comment on the management of migration remedy.
x.
THE SELECTED REMEDY
The remedies proposed for the Kearsarge Metallurgical Corporation
Site, source control SC-6 and management of migration.MM-5, address
all contamination at the Site. A detailed description of the
selected remedies along with cleanup levels is presented below.
A. Cleanup Levels
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39
identified in the baseline risk assessment found to pose an
unacceptable risk to either public health or the environment.
Cleanup levels have been set based on the appropriate ARARs (e.g.
Drinking Water MCLGs and MCLs) if available. In.the ab~ence of a
chemical specific ARAR or other suitable criterion to be
considered, a one in one million (10.6) excess cancer risk level for
carcinogenic effects or a concentration corresponding to a hazard
index of one for noncarcinogenic effects were used as the point of
departure to set cleanup levels. In instances in which the values
described above were not feasible to quantify, the limit that can
be reliably measured by analytical methods was used as the cleanup
level. Periodic assessments of the protection afforded by remedial
actions will be made as the remedy is being implemented and at the
completion of the remedial action. If the remedial action is not
found to be protective or fails to meet the cleanup levels
established in this Record of Decision, further action shall be
required.
1.
Ground Water
TheEPA has classified the ground water below the site as class
lIB. Ground water in this classification is deemed to be suitable
for drinking water, therefore MCLs and non-zero MCLGs established
under the Safe Drinking Water Act are ARARs. 'Cleanup levels for
known and probable carcinogenic compounds (Classes A & B) have been
set at the appropriate MCL since the MCLG equals zero. . Cleanup
levels for the Class C compounds (possible carcinogens) have been
set at the MCLG. In the absence of either a MCLG or MCL, a
proposed Drinking Water Standard or other suitable criterion to be
considered (i.e., National Interim Primary Drinking Water
Regulations, Health Advisory, or promulgated state standard) was
used as a cleanup level. If standards were not available, cleanup
levels were derived for carcinogenic effects using a one in a
million (10.6) excess cancer risk level as the point of departure
assuming drinking two (2) liters of ground water per day for a
lifetime. If the values described above were not capable of being
detected or were below regional background values, the~ the
practical quantitation limit or a background level was substituted.
Cleanup levels for compounds in ground water exhibiting
noncarcinogenic effects have been set at the MCLG. In the absence
of a MCLG, a proposed Drinking Water Standard, or other suitable
criterion, cleanup levels for noncarcinogenic effects have been set
at. a level thought to be without appreciable risk of an adverse
effect when exposure occurs over lifetime (hazard index = 1).
Tables III and IV summarize the cleanup levels for carcinogenic
and noncarcinogenic contaminants of concern identified in ground
-------
Car c i n 0 g e n i c
contaminants of
Concern
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
Trichloroethylene
Noncarcinogenic
Contaminants of
Concern
Chloroform
Chromium
1,1-Dichloroethylene
Nickel
1,1,1-
Trichloroethane
Hazard Index Sums:
40
TABLE III
Cleanup
Levels
(DDb)
100
4
5
7
5
TABLE IV
Cleanup
Levels
(DDb)
Basis
Risk
*
100 NIPDWR
*
50 NIPDWR
7 MCLG
700 HI+
200
MCLG
Liver Effects 0.48
Reduced Body and Organ weight
*
Basis
of Risk
Level of
Risk
*
NIPDWR
3.5E-05
Risk
1. OE-05
MCL
1.3E-05
MCLG
1.2E-04
MCL
1.6E-06
Hazard
Index
Toxicity
EndDoint
0.2
Liver
lesions
0.2
Hepatotox
icity
0.02
Liver
lesions
1.0
reduced
body and
organ wt
0.06
Hepato
toxicity
1. 00
National Interim Primary Drinking Water Regulation
Hazard Index
+
These cleanup levels must be met at the completion of the remedi~;
action at the points of compliance, which is the entire plume c:
ground water contamination. EPA has estimated that these leve:--
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41
These cleanup levels are consistent with ARARs for ground water and
attain EPA's goal for remedial actions. The target cleanup level
for 1,1 Dichloroethylene has been set at the MCLG, which is based
upqn the lowest level that can be analytically quantified, the
practical quantification limit. Therefore, EPA believes the target
clean up level is the lowest that can practically be set. Further
given the physical properties of 1,1 Dichloroethylene we expect
that it will be removed during treatment more readily than other
contaminants. Thus, if cleanup levels are achieved for other
contaminants, we expect that levels of 1,1 Dichloroethylene will
be below the target cleanup level.
2.
Waste Pile Cleanup Levels
Cleanup levels for chromium have been established for its
noncarcinogenic effects based on incidental ingestion of hexavalent
chromium. An evaluation of potential excess lifetime cancer risks
from the waste piles was not conducted since no carcinogenic
contaminants were included as contaminants of concern for ingestion
or dermal contact. Only incidental ingestion of the soils in the
waste pile was considered as a viable pathway, since chromium is
not readily absorbed through the skin. The inhalation route of
exposure was not considered in deriving cleanup levels since it is
not possible to quantify the health based risk of exposure.
Cleanup levels for the waste pile corresponds to a level thought
to be without appreciable risk of an adverse effect when exposure
occurs over a lifetime (hazard index = 1).
Exposure parameters for the ingestion of contaminated waste pile
materials are described in the RI on pages 6-22 through 6-21 and
summarized in the FS on pages 1-9 through 1-12. Table V summarizes
the cleanup levels for' the noncarcinogenic contaminant of concern
in the waste piles.
Table V: WASTE PILE CLEANUP LEVELS
Noncarcinogenic
contaminants of
Concern
Cleanup
Levels
(ppb)
Basis
Risk
Hazard
Index
Toxicity
EndDoint
Total Chromium
1,400
HI
1
Liver
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42
The cleanup level for chromium must be met at the completion of the
remedial action throughout the entire extent of the waste piles.
These cleanup levels attain EPA's goal for remedial actions for
noncarcinogenic effects of a Hazard Index less than one" (1).
3.
Septic System
Cleanup levels in soils surrounding the septic system were
established in order to protect human health and the aquifer below
the Site from potential soil leachate. The Summers's Leaching
Model was used to estimate residual soil levels that are not
expected to impair future groundwater quality. ARARs in
groundwater (MCLGs and MCLs) were used as input into the leaching
model. If the value described are not capable of being detected
or are below regional background values, then either the practical
quantitation limit or a background value was substituted.
For this site; 1,1,1 Trichloroethane; a contaminant with
noncarcinogenic effects, was used as the contaminant of concern.
Table VI summarizes the soil cleanup levels for 1,1,1
Trichloroethane devel~ped to protect public health and the aquifer.
TABLE VI: SOIL CLEANUP LEVELS
FOR THE PROTECTION OF HUMAN HEALTH AND THE AQUIFER
BASED ON THE SUMMER'S LEACHING MODEL
Noncarcinogenic
Contaminants of
Concern
S 0 i 1
Cleanup
Levels
(ppb)
Basis for
Model
Input
Residual
Groundwater
H a z a r d
Index
1,1,1
Trichloroethane
300
MCLG
200 ppb
0.06
The cleanup level in the soils are consistent with ARARs for
groundwater and attain EPA' s risk management goal for remedial
actions. EPA believes that if the cleanup level for, this
contaminant is achieved the other volatile organic compounds
detected at this site will also attain levels that are protective
of human health and the aquifer. These cleanup levels must be met
at the completion of the remedial action for the entire area of
the septic system.
B.
Description of Remedial Components
Alternative SC-6 involves the elimination of source areas at the
site. This alternative includes the following actions:
1.
Excavation of the waste piles;
2.
Transport of waste pile materials containing hazardous
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43
disposal at a RCRA subtitle C hazardous waste landfill;
3.
Transport of remaining fine, particulate materials within
the waste piles to a RCRA subtitle D sol~d waste landfill
or otherwise disposed of in a manner that will comply
with all applicable fedaral, state, and local laws;
4.
Excavation, transport, treatment, and disposal at a RCRA
subtitle C hazardous waste landfill of the contaminated
leaching field soils; and
5.
Removal of the septic tank and the contents of the septic
tank from the two on-site buildings for destruction at
an off-site incinerator.
Approximately 4,650 cubic yards of waste pile material at the site
will be excavated, and segregated on the basis of visual
inspection, screening to detect VOCs with portable instruments,
and the testing of every two hundred cubic yards of material
removed, a total of twenty samples. The twenty samples that will
be taken will be analyzed for Toxicity Characteristic Leaching
Procedure (TCLP), percent solids, and a paint filter test.
Excavation will entail the implementation of dust control measures
and excavating to two feet below grade. The resulting hole left
will be backfilled with clean fill. An estimated 4,400 cubic yards-
of waste pile material will be transported from the site to a RCRA
subtitle D solid waste facility or otherwise disposed of in a
manner that will comply with all applicable federal, state, and
local laws. The underlying soils will be tested for chromium to
ensure that contaminant levels are below the cleanup levels set for
mineral soils at the site. The waste pile materials containing
hazardous substances above cleanup levels are estimated to consist
of a total of 250 cubic yards of material. This material will be
excavated, placed into containers, and transported to a RCRA
subtitle C hazardous waste facility where it will be disposed.
The contaminated leaching field soils will be removed in a manner
similar to the waste pile soils. It is estimated that it may be
necessary to excavate a 125 square yard area to the water table (a
depth of six feet) to obtain the cleanup levels. The contaminated
portions of the leaching field soils will be transported by truck
to a RCRA subtitle C hazardous waste facility for disposal.
It may be necessary to treat the hazardous substances from the
waste piles or leaching field off-site prior to disposal as
required by the RCRA subtitle C disposal facility. Treatment wil:
be contingent on the level of contamination of the material and th0
standards that the disposal facility require.
The septic tank will first have its contents removed. The sept. -
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44
septic tank with its contents will be transported off-site for
incineration. Incineration is chosen because the septic tank as
its somewhat porous nature may have caused the absorption of
hazardous materials and high concentrations of VOCs have been found
to occur in the septic tank. The soils underlying the septic tank
are included as leaching field soils.
Alternative MM-5 involves the extraction and treatment of
contaminated ground water at the Site. This alternative includes
the following actions:
1.
Extraction of ground water at the Site through a series
of trenches or wells;
2.
Pretreatment of the ground water to remove metals;
3.
Air stripping of the ground water to remove VOCs;
4 .
Discharge of treated
Treatment Works (POTW).
water
to
the
Publicly
Owned
The groundwater extraction system will consist of either a large
number of shallow well points or a trench that is 350 feet long,
2 feet wide, and approximately 10 to 15 feet deep (Appendix A,
Figure 12). The low permeability of the aquifer underlying the
Site dictates that perhaps a pilot scale plant first be built to
gauge the extraction rates that may be obtained from the aquifer
and the degree of treatment possible. Current data suggest that
an extraction trench 10 feet deep and 350 feet long will only be
able to produce 10 to 15 gallons per minute. A pilot scale plant
using a scaled down version of the extraction system will be used
to gather data both on aquifer performance and the suitability of
differnt treatment techniques. Once data are obtained from such
a pilot plant, it will be possible to determine the more efficient
extraction system and design the most effective treatment system.
Groundwater will be treated onsite to remove metals and organics
(VOCs) through a series of technologies involving chemical and
physical processes. The treated groundwater will theh be
discharged to the sewer. A conceptual treatment process diagram
is shown in Appendix A, Figure 13.
No practicable and effective management of migration alternative
exists which would not include construction in the wetlands.
Short-term wetlands alterations are restricted to the construction
of an extraction trench, an area that is 350 feet long and 30 to
40 feet wide. The extraction trench is located in the forested
wetland shown in Appendix A Figure 12. Once the extraction system
is installed (two years) the affected area will be restored to its
original topography. Measures will be taken during construction
to minimize impacts to the wetlands. Erosion and siltation control
devices will be employed along the construction corridor which will
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45
inside these erosion and siltation control devices and any waste
material will be removed from the wetlands. The wetlands
restoration will consist of revegetating the affected,area. The
total area that will be impacted over the long term is an area that
is 350 feet long and approximately 10 feet wide. The ten foot wide
area is the result of the dewatering action of the collection pipe.
Removing groundwater from the site, as required by MM-3, MM-4, MM-
5, and MM-6 would de-water only a very narrow portion (ten foot
wide, 350 feet long) of the wetlands. This impact would be present
during the entire cleanup period; however, it would not affect
those wetlands outside of the altered area. Once the extraction
system is installed and the cleanup is underway, it will be
possible to replant the altered area with a mix of shrub-scrub
wetland plants. No forested wetland plants will be allowed to grow
wi thin the area of the extraction system while the remedy is
proceeding, as deep traveling root structures may clog or disrupt
the collection pipe.
Extracted groundwater will first undergo removal of metals through
precipitation, flocculation, and sedimentation. Precipitation
reduces the solubility of iron, nickel, chromium, and other metals
so that tiny particles of the metals are produced. Once a
precipitate forms, the contaminated water is directed to a
flocculation t~nk where the particles collide and adhere due to
flocculating agents. Lastly, these enlargened precipitates are
introduced to a settling chamber where these heavier particles are
allo~ed to settle into a sludge at the bottom of the tank. The
resulting sludge will be periodically tested and properly disposed
of at an appropriate offsite treatment or disposal facility. The
exact type of precipitation (hydroxide or sulfide) and the
flocculating agents will be determined during the pilot plant phase
of the remediation effort. A schematic of the metals removal
process is provided in Appendix A Figure 14.
After removal of the metal constituents the groundwater is then
passed through an air stripping chamber to remove VOCs by forcing
air up through the water. The air stripping chamber will be the
packed column type with a counter current air flow. In this type
of stripper a regulated amount of water is allowed to enter the top
of the column and then fall through a porous chamber. As the water
falls from the top of the column a stream of air is blown up froM
the bottom of the chamber. The porous chamber creates a greater
surface area over which VOCs can evaporate into the air-stream.
Since air leaving the stripper will contain small quantities of
VOCs, the air will then be treated by activated carbon filtration
prior to release to the atmosphere. A simplified diagram of an air
stripper is shown in Appendix A Figure 15.
The VOC groundwater contaminants that can be easily strippe::
include TCA; 1,1 and 1,2 DCA and DCE; and TCE. Treatibility test:',
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46
strip the previously mentioned contaminants,
chloroform which are not as easy to strip.
and
acetone
and
After treatment the water will be discharged to the PubLicly Owned
Treatment Works (POTW) operated by the Conway Vill~ge Fire District
(CVFD). The treated ground water will be directed into the sewer
main on Mill street which borders KMC. The limiting criteria for
discharge to the sewer is the volume of water and the water
quality. Since the POTW is expanding and will have excess
capacity, the CVFD has indicated that the POTW could handle the
volume of waste water generated at the site which is estimated at
10 to 15 gallons per minute. No discharge limits have been set
with regard to water quality; however, the CVFD is discussing these
issues with its engineer. If the CVFD cannot accept the treated
ground water, then it will be necessary to use the discharge option
outlined in alternative MM-3. In MM-3 treated ground water is
recharged into the aquifer beneath the Site. The recharge field
would be 300 feet by 150 feet, consisting of a level area
containing sand, gravel, and a network of PVC pipes to distribute
the treated water. This recharge field would be on the west side
of building #1 as depicted in Appendix A Figure 12.
Periodic review and modification of the design, construction,
maintenance and operation of the groundwater extraction and
treatment system will be necessary. Performance of the system will
be evaluated annually, or more frequently, to determine if the
goals and standards of the design criteria are being met. If not,
adjustment or modification may be necessary. These adjustments or
modifications may include relocating or adding extraction wells,
trenches, or altering pumping rates. Switching from continuous
pumping to pulsed pumping may improve the efficiency of contaminant
recovery and should be evaluated should modification be necessary.
Should new information regarding the extraction and treatment
technology exist, it will be evaluated and applied as appropriate.
After the cleanup levels have been met and the remedy is determined
to be protective, the groundwater system will be shut down. The
cleanup levels for the ground water should be attained in ten
years. After the cleanup levels have been met a groundwater
monitoring system will then be utilized to collect information
quarterly for three years to ensure that the cleanup levels have
been met and the remedy is protective. Once these levels are
maintained and the remedy is determined to be protective, a long-
term monitoring program for the site will be established in
accordance with ground water monitoring programs in the New
Hampshire Hazardous Waste regulations. If after 5 years there is
no progress or, if after 10 years cleanup levels are not attained,
the groundwater remedy shall be reconsidered. 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
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47
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. .
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Kearsarge
Metallurgical corporation Site is consistent with CERCLA and, to
the extent practicable, the NCP. The selected remedy is protective
of human health and the environment, attains ARARs and is cost
effective. The selected remedy also satisfies the statutory
preference for treatment which permanently and significantly
reduces the mobility, toxicity or volume of hazardous substances
as a principal element. Additionally, the selected remedy utilizes
alternate treatment technologies or resource recovery technologies
to the maximum extent practicable.
A.
The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this site will permanently reduce the risks posed to
human health and the environment by eliminating, reducing or
controlling exposures to human and environmental receptors through
removal, treatment, and engineering controls; more specifically the
removal, treatment if necessary, and disposal at a hazardous waste
landfill of hazardous components of the waste piles, and the
contaminated soils in the leaching field. Also the septic system
and its contents will be removed and incinerated. No wastes will
remain on the surface of the site. Ground water at the Site will
be extracted, treated, and disposed of at the POTW.
The remedial actions, as proposed, will be protective of human
heal th and the environment. Removal of the source areas will
eliminate further ground water contamination from soil leaching.
Ground water treatment will reduce toxicity and will retard the
migration of the contaminated plume and halt further contamination
of the aquifer. Extracting and treating ground water reduces
cancer and chemical hazard risks. A long-term monitoring program
will ensure the remedy remains protective of human health and the
environment. Finally, implementation of the selected remedy will
not pose unacceptable short-term risks or cross-media impacts since
both remedies are proven technologies and will be field tested as
a small pilot scale plant to reduce operational risks.
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.
Wetlands on the Site evoke the most stringent requirements.
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48
plains) is EPA's statement on procedures on wetlands protection 40
CFR Part 6 Appendix A. The purpose of 40 CFR Part 6 Appendix A is
to set forth procedures regarding proposed work in wetlands and
flood plains and to minimize the impact that any activity may have
on the interests described in Executive Orders 11990 and 11988.
The substantive portions of environmental laws identified as ARARs
for the selected remedial action include:
Chemical Specific
Safe Drinking Water Act - Maximum Contaminant Levels (SDWA)
Federal Ambient Water Quality Criteria
National Ambient Air Quality Standards
Ground Water Protection - RCRA Subtitle C, 40 CFR Part 264 (F)
New Hampshire Surface Water Quality Standards (Ws 430)
New Hampshire Air Quality Rules (RSA Chapter 125-C)
New Hampshire Drinking Water Standards
Location Specific
Clean Water Act (CWA)
Fish and Wildlife Coordination Act
Executive Order 11990 (Protection of Wetlands)
Executive Order 11888 (Floodplains Restrictions)
40 CFR Part 6 Appendix A
New Hampshire Solid Waste Regulations (He-P 1901)
New Hampshire Wetlands Regulations (Ws 300 and 400)
New Hampshire Hazardous Waste Regulations (He-P 1905)
New Hampshire Hazardous Waste Regulations
Action Specific
Resource Conservation and Recovery Act (RCRA)'
OSHA General Industry Standards
OSHA Safety and Health Standards
OSHA Recordkeeping, Reporting and Related Regulations
DOT Rules for Transportation of Hazardous Materials
To Be Considered
New Hampshire Protection of Groundwater (Ws 410)
New Hampshire Ground Water Quality Criteria (Ws 410.05)
New Hampshire Ground Water Discharge Criteria (Ws 410.09)
New Hampshire Boundary Criteria (Ws 410.13)
New Hampshire Regulations for VOC's (ENVA 1200)
EPA Risk Reference Doses
EPA Carcinogen Assessment Group Potency Factors
Threshold Limit Values
US EPA Offsite Policy
Land Disposal Requirements (LDRs) (40 CFR 268)
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49
Tables 2-1, 2-3 and 2-4 in Section 2.0 of the FS, lists all ARARs
identified for the Site and whether they are applicable, relevant
and appropriate or to be considered. Within each table is also
presented a brief synopsis of the requirements... Any changes to
applicability or appropriateness or relevance are discussed below.
The remedial. actions involve installing groundwater collection
wells or trenches, constructing a groundwater treatment facility,
and excavation and removal of the source areas. During all
construction and operation activities, OSHA requirements are
applicable.
1.
Chemical Specific
a.
Federal and State Drinkinq Water Standards
It has been determined by the EPA that the groundwater in the
aquifer at the Site would be a possible drinking water source were
it not contaminated by contaminants originating from the Site. The
State of New Hampshire has not yet classified ground water in the
State. However, using the Federal guidelines and classification
system the ground water underlying the Site would be classified as
IIB potential drinking water. Maximum contaminant Levels (MCLs)
and Maximum contaminant Level Goals (MCLGs) promulgated under the
Safe Drinking Water Act which regulate public drinking water.
supplies, are applicable to drinking water at the tap and are not
applicable to groundwater. However, because the groundwater may
be used as a potential drinking water source, MCLs are relevant and
appropriate.
New Hampshire's Protection of Groundwater regulations (Ws 410)
do not establish groundwater quality standards, but do establish
groundwater criteria. Included in this criteria is the requirement
that no person shall cause the groundwater to contain a substance
at a level that the state determines may be potentially harmful to
human health or to the environment. Because New Hampshire's
regulations do not contain a standard or level of control as
required by 9 121(d} (2) (A) (ii) of CERCLA, they will not be an ARAR.
They are, however, to be considered (TBCs) and will be met.
This remedy will attain these ARARs and will comply with those
regulations which have been identified as TBCs by meeting the
groundwater cleanup goals at the Site through the groundwater
treatment system and by the excavation and removal of the source
of. contamination. Excavation and removal will control further
leaching of contaminants into the groundwater. Treating the
groundwater will reduce levels of contamination at the Site to the
cleanup levels identified in this ROD. Treated groundwater will
also meet federal standards, state criteria for drinking water, and
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50
2.
Location Specific
a.
Federal and State Surface Water Standards
Title III, along with Executive Order 11990 (Protection of
Wetlands) and state wetland standards are applicable to that
portion of the action involving the construction of the ground
water extraction system. These rules prohibit activity adversely
affecting a wetland if a practicable alternative which has less
effect is available. Constructing the ground water extraction
system in the wetland is necessary because the contaminant plume
directly underlies the wetland. Leaving the wetlands in their
present condition fails to restore wetlands to their original
beneficial use and fails to maintain the wetlands' water quality.
Construction will be conducted to avoid or minimize the damage to
flora and fauna within the wetland, and to avoid damage to a
current drinking water supply. Additionally, restoration of the
wetlands will occur in two phases as noted previously. The first
phase occurs once construction of the extraction system is complete
and will consist of restoring the original topography and
establishing shallow rooting shrubs. The second phase occurs once
the remedy is complete in ten years and consists of allowing the
original wetland species (red maple and red oak) to reestablish
themselves naturally.
After reviewing the Federal Emergency Management Agency, Floodplain
Insurance Rate Maps for Town of Conway, EPA has determined that the
site is located in a 100-year floodplain. Executive Order 11988
(Floodplain Management) is therefore an ARAR for the site. These
regulations govern construction within a floodplain. Construction
on a floodplain by Federal Agencies is to be avoided unless there
is no practicable alternative. The entire Site lies within the 100
year flood plain. In this instance, construction within the flood
plain will eliminate structures (the waste piles) and any other
structures will either not be exposed to flood action (the ground
water extraction system), or be located in an existing structure
(the air stripper inside building #1). Construction within the
flood plain is necessary if the remedial objectives are to be'met.
Further, the elimination of site risks reduces the possibility of
spreading Site contaminants during flood events.
Supplementing Executive Orders 11990 (wetlands) and 11988 (flood
plains) is EPA's statement on procedures on wetlands protection 40
CFR Part 6 Appendix A. The purpose of 40 CFR Part 6 Appendix A is
to set forth procedures regarding proposed work in wetlands and
flood plains and to minimize the impact that any activity may have
on the interests described in Executive Orders 11990 and 11988.
b.
Federal Clean Air Act
Pollution Requlations
and
New
Hampshire
l<. :. :-
Federal
Primary
and
Secondary
National
Ambient
Air
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51
Standards (NAAQS) exist for emissions of sulfur oxide, carbon
monoxide, ozone, nitrogen oxides and lead and particulate matter
whereas the National Emission Standards for Hazardous Air
Pollutants (NESHAPs) address volatile organic emissions. Threshold
Limit Values (TLVs) provide an extensive list of control levels for
workplace environments and, although they are based on the exposure
of a select population and not generally transferable to the
general public, they are used to assess site inhalation risks for
soil removal operations.
New Hampshire regulates air quality and pollution control under
N.H. Admin. Code Chapter Air 100-1200, which is relevant and
appropriate to the evaluation of air emissions associated with
remedial actions at the site and ambient air quality.
The National Ambient Air Quality Standards promulgated under the
Clean Air Act are relevant and appropriate to the control of
particulate matter during excavation and groundwater treatment.
The New Hampshire air quality standards are slightly more stringent
than federal regulations and are therefore applicable to the
remedy. Although initial air sampling offsite indicated airborne
VOCs were below background values, controls may be necessary to
prevent fugitive dust and chemical emissions during remedial
action. The use of Best Available Control Technology will meet
these ARARs during the excavation and transport of soil, and during
ground water cleanup.
In addition, N.H. guidance on air emissions (ENVA 1200, Regulations
for VOCs) is to be considered for the site. For such an area, the
regulation indicates the need for control of VOC emissions from
various Industrial processes. CERCLA ground water air strippers,
while not covered under such regulations, may emit amounts of VOCs.
As outlined in OSWER Directive 9355.0-28 EPA is unwilling simply
to transfer contaminants from one media (ground water) to another
(air), and emphasizes the use of minimum technology treatments to
reduce the volume and mobility of site contaminants. Therefore,
gases generated by air stripping during the groundwater treatment
phase will be treated by a carbon adsorption unit.
3.
Action specific
No RCRA hazardous wastes will be treated, transported, disposed of,
or stored; therefore, RCRA regulations have been found not to be
applicable to either the source control or the management of
migration remedies. However, RCRA regulations may be appropriate
and relevant to some portions of both the source control and
management of migration remedies.
The State of New Hampshire has been authorized by EPA to administer
and enforce RCRA programs in lieu of the federal authority. The
authorized state hazardous waste regulations are equivalent to or
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52
regulations consist of New Hampshire's Hazardous Waste Management
Act at N.H. Admin. Code He-P Ch. 1905 and of the Solid Waste
Management Act, RSA Ch. 149-M and the Solid Waste Management Rules,
N.H. Admin. Rules He-P Ch. 1901. .
Sludge generated by the groundwater treatment unit will be disposed
of at an offsite RCRA facility in accordance with federal and state
requirements.
One potential requirement for any remedy conducted at the Site is
the Land Disposal Restrictions (LDRs), 40 CFR 268. To determine
whether LDRs are applicable to this CERCLA response action, one
must answer three questions. For LDRs to be applicable, the answer
to all three questions must be "yes".
1-
2.
Does the response action constitute placement?
Is the CERCLA substance being placed also a RCRA
hazardous waste?
Is the RCRA hazardous waste restricted under the LDRs?
3.
Based upon EPA guidance, the response to the first question is yes
since placement does occur. The response to the second question
is no, since the waste is not a RCRA hazardous waste. RCRA
hazardous wastes are defined in 40 CFR 261. Within 40 CFR 261
there are two groups of RCRA hazardous wastes, listed RCRA
Hazardous wastes and Characteristic RCRA Hazardous Wastes. Listed
hazardous wastes are defined by composition and use. The only
listed RCRA wastes used on the Site were acids and caustics (EPA
# D002). Although TCA was used on the site, the use and nature of
its composition is unknown. Acid, caustic, and solvent wastes were
drummed and stored in and near building # 2 at the Site during the
period 1979 until 1982. Although these wastes were generated or
used at the Site, no information exists to indicate that these
wastes were improperly disposed of at the site. Also, no
information exists to indicate that listed wastes were discharged
into the septic tank during the period prior to 1979. Al though the
degreasing tank, which was attached directly to the septic tank,
contained TCA, it cannot be shown that the waste in the degreaser
was a listed waste. Further, it cannot be shown that the listed
waste was disposed of onto the ground at any time. Therefore,
LDRs are not applicable at the site.
Furthermore, LDRs are not relavant and appropriate for the leaching
field soils, the septic tank and its contents, and the waste piles.
All these wastes are considered soil and debris wastes. At this
time, the EPA has determined the LDRs are not relevant and
appropriate for soil and debris wastes.
The waste piles contained no significant levels of leachable metals
as indicated by the EP-toxicity testing and it does not appear that
leachable metal levels will be exceeded using the new TCLP method.
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53
or characteristic hazardous waste is found, LDRs will apply to that
particular substance in the container.
Similar to the source control alternatives, LDRs have been found
to not be applicable or relevant and appropria~e to the ground
water remedy since no contaminants in the ground water are listed
wastes. LDRs are not relevant and appropriate for the ground water
at the site as the cleanup of ground water for LDRs is identical
to compliance with the Safe Drinking Water Act in that MCLs must
be attained. Treatment of the ground water at the site will reduce
contaminants to levels similar to, or below those values set forth
under LDRs. RCRA regulations are not applicable with respect to
the management of migration alternatives as none of the wastes
being treated are RCRA hazardous wastes. However, portions of RCRA
regulations may be appropriate and relevant to the conduct of the
remedy.
C.
The Selected Remedial Action is cost-Effective
In the Agency's judgment, the selected remedies, SC-6 and MM-5,
are cost effective, i.e., the remedies afford overall effectiveness
proportional to their costs. Once EPA identified alternatives that
were protective of human health and the environment and that either
attain or waive ARARs, EPA evaluated the overall effectiveness of
each alternative by assessing the relevant three criteria - long
term effectiveness and permanence; reduction in toxicity, mobility,
and volume through treatment; and short term effectiveness. The
relationship of the overall effectiveness of these remedial
alternatives were determined to be proportional to their costs.
A summary of the costs associated with each of the source control
remedies are presented below. All costs are presented in net
present costs.
COST COMPARISON OF SOURCE CONTROL ALTERNATIVES
capital
Costs
*Present
Worth
SC-1
No Action
$
o
o
SC-5
Off-site Solid Waste
Landfill and On-site
Low Temperature Thermal
Stripping
Off-site Solid Waste
Landfill and Off-site
Incineration
3,301,000
3,301,000
SC-3
4,060,000
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54
COST COMPARISON
OF SOURCE CONTROL
(continued)
capital
Costs
ALTERNATIVES
.*present
Worth
SC-6
Off-site Solid Waste
Landfill and Off-Site
Hazardous Waste Landfill
3,256,000
3,256,000
SC-13 Off-site Hazardous Waste
Landfill
4,566,000
4,566,000
Four alternatives are protective and attain ARARs, SC-3, SC-5, SC-
6,and SC-l3. Comparing these alternatives, EPA's selected remedy,
SC-6, combines the most cost-effective remedial alternative
components that were evaluated. The remedy provides a degree of
protectiveness proportionate to its costs. Excavation, off-site
transport, treatment, and disposal at hazardous waste landfill of
all hazardous components were estimated to be significantly less
costly than off-site incineration of the hazardous components which
would cost approximately 25 percent more. Alternative SC-13 is
essentially identical to the selected source control remedy SC-6.
In SC-13 however, cost has been calculated with the presumption
that all of the material in the waste piles is hazardous. This
condition has not been shown to be a valid assumption. Low
Temperature Thermal Aeration of the hazardous components is within
five percent of the total cost, and would be valid but for
implementability problems which have been cited previously. The
less expensive alternative, SC-l (no-action), did not meet ARARs
since contamination above drinking water standards would have been
allowed to migrate offsite.
A summary of the costs for each of the elements of the selected
source control remedy is presented below. All costs are net
present costs.
TOTAL COSTS OF SELECTED SOURCE CONTROL REMEDY
contaminated Media/Remedv
CaDita1
Waste Pile
$
801,500
Leaching Field Soils
Septic Tank
117,000
17,800
Miscellaneous*
2.319.900
TOTAL
3,256,000
*Miscellaneous includes the
mObilization/demobilization,
following:
temporary
Heal th & Safety I
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55
facilities, site work including grading and
loaming and seeding, contractor allowances,
allowances, and general administration.
A summary of the costs associated with each of the management of
migration remedies are presented below. All costs are presented
in net present costs.
"
MM-1
MM-2
MM-3
MM-4
MM-5
MM-.6
backfilling,
contingency
COST COMPARISON OF MANAGEMENT OF MIGRATION ALTERNATIVES
capital
Costs
*
Present
Worth
O&M Costs
($/vr)
No Action
$
o
o
o
Ground Water
Monitoring
85,000
85,000
o
Ground Water Extraction
On-Site Treatment, and
On-Site Recharge
3,158,000 1,032,000
4,275,000
Ground Water Extraction
On-site Treatment, and
Discharge to Surface Water
2,891,000 1,032,000
4,008,000
Ground Water Extraction
On-Site Treatment, and
Discharge to POTW
2,891,000 1,044,000
4,020,000
Ground Water Extraction
On-Site Treatment, and
Partial Discharge to POTW
and Partial Recharge
3,162,000 1,044,000
4,291,000
*
Present worth costs for MM-3, MM-4, MM-5, and MM-6 also
include an additional $85,000 for ground water monitoring
that is not accounted for in columns headed "Capitol
Costs" and "0 & M Costs".
Four of the management of migration alternatives are protective
and attain ARARs, MM-3, MM-4, MM-5, and MM-6. Comparing these
alt:ernatives, EPA's selected remedy, MM-5, combines the most cost-
effective remedial alternative components that were evaluated. The
remedy provides a degree of protectiveness proportionate to its
costs. Alternatives MM-3, MM-4, and MM-6 are identical to th.?
selected management of migration remedy MM-5 with regard to the
extraction of ground water and its treatment. The only difference
is the discharge point of the water. Alternatives MM-3 and Mr'~-'-
would be difficult to implement due to the construction of aver;
large recharge area and would also be approximately 7% morC'
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56
5, NPDES discharge limits, New Hampshire wetlands regulations, and
implementation make this alternative less desirable. NPDES
discharge limitations would require additional ~ompliance
monitoring. The least expensive alternatives, MM-1 (no-action) and
MM-2, did not meet ARARs since contamination above drinking water
standards would have been allowed to migrate offsite.
A summary of the costs for each of the elements of the selected
management of migration remedy are presented below. All costs are
net present costs.
TOTAL COSTS OF SELECTED MANAGEMENT OF MIGRATION REMEDY
Portion of Remedv
Present Worth Cost
I.
capital Costs
a. Ground Water Collection System
b. Ground Water Treatment System
c. Miscellaneous*
$
58,000
740,000
2.093.000
2,891,000
II.
Annual operation and Maintenance
(@ $170,000 per year)
1,044,000
III. Ground Water Monitoring
85,000
TOTAL
4,020,000
*Miscellaneous includes the following: Health & Safety,
mObilization/demobilization, temporary utilities and
facilities, contractor allowances, engineering, contingency
allowances, and general administration.
A complete accounting of costs for each source control and
management of migration alternative is contained in Section 4 of
the FS.
The two remedies, SC-6 and MM-S, may be performed exclusive of one
anothe. It may be noted that it would be more efficient to remove
the source either before, or during the construction of the ground
water extraction system. The total cost of remediating the Site
is:
TOTAL ESTIMATED COST:
$ 7,276,000
D.
The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies
to the Maximum Extent Practicable
Once the Agency identified those al ternati ves that attain ARARs a r..:
that are protective of human health and the environment, Er.:..
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57
al1:ernative treatment technologies or resource recovery
technologies to the maximum extent practicable. This determination
was made by deciding which one of the identified al.ternatives
provides the best balance of trade-offs among alternatives in terms
of:: 1) long-term effectiveness and permanence:. 2) reduction of
toxicity, mobility or volume through treatment: 3) short-term
effectiveness: 4) implementabili ty: and 5) cost. The balancing
test emphasized long-term effectiveness and permanence and the
reduction of toxicity, mobility and volume through treatment: and
considered the preference for treatment as a principal element, the
bias against offsite land disposal of untreated waste, and
community and state acceptance. The selected remedy provides the
best balance of trade-offs among the alternatives.
Source control alternative SC-6 was selected as the remedy because
its long-term effectiveness and permanence and its abil i ty to
reduce toxicity, mobility and volume of contaminants through
treatment was the most efficient of all alternatives in light of
implementability and cost concerns. The principal elements of the
remedy consist of physically removing the source areas from the
site, and treating those materials prior to disposal in a hazardous
waste landfill.
Alterative sc-s is similar to SC-6 in its long-term effectiveness
and reduction of toxicity , mobility and volume of contaminants.
Alternative SC-5 is slightly superior in both of these categories.
HOIf/eVer, when implementability and cost are factored in, SC-6
becomes the selected remedy. "When the alternatives provide
similar long-term effectiveness and permanence and reduction of
toxicity, mobility or volume, the other balancing criteria arise
to distinguish the alternatives and playa more significant role
in selecting the remedy." NCP Preamble, 55 Fed. Reg. 8725 (1990).
Alternative SC-5 was not selected because it cost 25% more than SC-
6, without providing a corresponding increase in protection.
Alternatives SC-3, SC-6, and SC-l3 are equally effective in the
long-term. SC-3 will reduce the toxicity, while SC-6 and SC-13
will reduce the mobility of the contaminants. Volume of
contaminants will remain the same with SC-3, SC-6, and SC-13.
Alternative SC-6 is superior to both SC-3 and SC-l3 when comparing
each to implementability and cost. SC-3 costs slightly more than
SC-6; however, suffers from the small area available to work at the
site. SC-13 uses technologies, processes, and activities identical
to SC-6; however, SC-13 considers the option of treating and
disposing the entire 4,650 cubic yards of waste pile material at
a RCRA subtitle C hazardous waste facility.
Management of migration alternative MM-5 was selected as the remedy
because its long-term effectiveness and permanence and its ability
to reduce toxicity, mobility and volume of contaminants through
capture and treatment was the most efficient of all alternatives
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58
elements of the remedy consist of extracting groundwater under and
around the site and treating the groundwater through air stripping
prior to discharging it to the Publicly Owned Treatment Works. The
air stripping process is a proven technique which provides a
permanent solution for contaminated groundwater and has been used
successfully at other hazardous waste cleanup sites.
Alternatives MM-3, MM-4, and MM-6 are similar to MM-5 in that they
are effective in the long-term and will reduce toxicity, mobility
and volume of contaminants. All alternatives are equally effective
in both of these categories. However, when implementabil~ty and
cost are factored in, MM-S becomes the selected remedy.
Alternative MM-6 was not selected because of higher costs.
Al ternati ve MM-S is superior to MM-3 when comparing each to
implementability and cost. MM-3 costs slightly more than MM-5 and
suffers from the small area available to work at the site in
constructing a recharge bed. Alternatives MM-3 and MM-6 also will
be affected by seasonal changes which adds recharge restrictions
which will affect the cleanup time. MM-4 which is least costly,
was not selected due to the problems associated with constructing
and operating a large underwater diffuser, which is a definite
hinderance in implementation.
E.
The Selected Remedy satisfies the Preference for
Treatment Which Permanently and significantly Reduces
the Toxicity, Mobility or Volume of the Hazardous
Substances as a principal Element
The principal element of the selected source control remedy is
removal and treatment. The principal element of the selected
management of migration remedy is ground water extraction and
treatment. These elements address the primary threats at the Site,
further contamination of the groundwater with VOCs and metals. The
selected remedy satisfies the statutory preference for treatment
as a principal element by treating the extracted groundwater in
treatment processes which result in the removal of VOCs and metals.
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
No significant changes from the ~roposed Plan have been made to
the selected remedies as detailed in the Record of Decision.
XIII. STATE ROLE
The New Hampshire Department of Environmental Services has reviev,'ed
the various alternatives and has indicated its support for the
selected remedies. The State has also reviewed the Remedia 1
Investigation, Endangerment Assessment, Ecological Assessment, anJ
Feasibili ty Study to determine if the selected remedies are:;;
compliance with applicable or relevant and appropriate Sta ~..
Environmental laws and regulations. The New Hampshire Departme: .
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59
Kearsarge Metallurgical Corporation Site. A copy
declaration of concurrence is attached as Appendix E.
of
-------
APPEHD:IX A
-------
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. .
. .
. -
.'
o
2000
.000
SCALE IN FEET
site
FIGURE 1
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\
~\
~b
~ \
~
~ \
~~ Gt 1IW.7
SOLID ~..... 8\
WASTE ~
PILES \
b
\
\
\
~
~
~
~
~
~
~
.....
~
l
1AW.11 8
Lot?
\
OUTFALL
N
\
PEQUAWKET POND
.
o
.
100
.
200
.
JOO
Approximate
Scale, feet
Schematic
FIGURE 2
-------
"
CAFRli. FeD SKI!HPS. IN:.
""-11IIt.
)
FIGURE 3
Wet18"1ds
.J
~
"
LEGEND
.6':d
G::I
~ fOR£!rTED
~ WETLNID
£M£IICI£NT
W£T\.AND
-ue/SCRUI
W£n.AND
" .'
)
-------
480
480
440
i
~ 4.0
..
..
ri 400
o
0:
..
:>
..
...
.. -
110
140
410
480
440
410
400
180
"
f
110
:;:
ri
0 140
0:
..
:>
..
...
.. 110
"'"
.80
,...
A'
480
480
440
0
:>
.
410 ~
:;:
ri
400 0
0:
..
:>
..
...
180 ..
110
140
8'
480
480
440
420
400
180 0
:>
.
!
180 ,.;
..
-,-
SECT ION
A-A'
A
~
~
...
..'.......... ..
. . '.
'fI.r . ,..,.",. .u.
cur... "., ..... -
8
"" , . ,.., ...
"U "..r,'IIO .,"
Ct., MIlD "". .....
SECTION 8-8'
SOUf1CE GEl Remedial Investigation KMC Site. 1986
NOTES:
HORIZONTAL SCAlE: I In. . 80f..
VERTICA l SCALE: II.. . 4Of..
.. SEE Fn 2-'2 FOR lOCATIONS OF CROSS SECTIONS
L nc 8TUTIIII Utili _CATaD . 'III CIIOI. KcnOlll
- lAID OIII.'UPOU'- KIWIIII 101'--
IIA' IIDf ""'III.' M:'N&L _IUIf'ACI C-'IOIII
.'WlII 10111.8.
lE8£ND
i PlIUOMIlIlC AlII ""'U. Llvnl IUIU.tO
011 .".11, "'"
~.1I1OII11I _'01 _111 - MAL
III1I.VAL _II WLL 18 _nlllD .. IOL 01
0"1 II _I.
100
280
FIGURE 4a .
Cross sections
A' and B B'
280
-------
, '
FIGURE 4b
Cross section Transects
A - A' and B - B'
(
(-
"
""-11Gt.
~
(
-------
.,
-------
i'
l \.'. ..C',''''.
. ',!' /1 ,;ir::;J';(" r:..
i.
., '1.
CJ
. ,.r.,
;,1rft
. i. ~ .
, "
'. i :A.
"" : I,
:f;" Ot',
'~! 'J""'"
. . '~'J-'
:-,"H
,-.-.- "
CA""OlL
INDUIY"III
MILL
UIIUT
[~~ .. "'N"'''
N
J
"\8'''+
(455.881
\
PRONI
prOUA.UT
POND
MWS-II+
I
(456.441
LEGENDI'
Groundwater .onitoring weill
NHWSPCC, Dec..ber 1982
Elevationl ..a.ured
January 17, 1985, NHWSPCC
"11.-' :roundvater el.vation
contour
Schematic
Croundwater eiavation ..a.ur..o"L.'
. collected January 17, 1985 by N"W5PCC
Il.vatlon of tope of c..lng. ."d
depth. to groundwater .u..arll.d I"
Table 5-1.
I
o
I
100
I
200
I
300
Approximate
Scale, feet
FIGURE 6
Ground Water Contour
January 17, 1985
-------
-
N
PVC D,alnaVI Pipi
f,a.. SlptiC Tank"
LEGEND'
r
~ - Te.t Pit/Sampling
" Locotlon.
. - Center PoInt
I
o
I
100
I
200
Schematic
'00
-
Approximate
Scale, feet-
FIGURE 7
GEl" Test pit/sampling Locations
-------
... -
e
~:k"': ;I~E
. . .
a-SAII08LASTWG \lllJlT
SAND HANDLING
POURING
r---
FURNACES
X_X-
x_X-
X-
)(
I
X
I
X
I
X
I
X
I
X
I
X
I
)
COMPRESSOR
ROOM
X
I
h
X
I ~
X ...
I :
1 ~
z
:c
J:
u
FIGURE 8
Location of Leach Field
I~ )
~ ,.
(',
, .
.. l'
. ,>
OFFICE
AND
ADMIN.
NO SCALE
-------
)
" '.
'J .' , )
~
I
_1- - - - - - - --~
I
I BUilDING NQ I
,----------1
I
I I
L___-I-
r-----l--"'------
I I I
I I I
I I I
I
--------
. . .
I
I
I
I
I
I
./t a-IAHDIlASTING \WA.T J
I(IIC-U'~1'2}J~r .
I(MC.SS-II.05I I
I(IIC. sss-a-oa . I r - - -
.' IfPnCT- L-_-
.:~;: :;<: J. . .r;" :~~-~:\ I
" . I
X-X - x
I
x
I
x
I
x
I
x
I
x
I
I
h
x
I ~
x ...
I :
1 ~
IE
c
z
u
LEGEND
...
SOIL SAWl£ LOCATION
. NO 8CAlE
CDM
Soil
FIGURE 9
Sampling
-------
(
~
IIMC. ".eM. 031
{;.IIIIC..,.eMOOS4
I
I I
- - - - - - - -'---
: BUILDING NO.1
----------1
I I
I
'-----
r - - - - - 1 - - "T - --- --
I I I
I I . I
I I I
I
. . .
. . .
x _x _X-
x_x -
x- .
I
x
I
x
I
x
I
x
I
x
I
x
I
FIGURE 10
Location of Leach Field Soils
l'
--------
I
I
I
I
I
I
I
Location 0' 'Leach Field
LEGEND
... SOIL SAMl'U LOCAnOll
NO ICAI.I
,. \
(
> '.
-------
/
r
I
o
I
100
I
200
300
Approximate
Scale, feet
FIGURE 11
Location and Number of Barrels Observed
During GEI Test pitting operation
-
N
LEGEND'
TP-07A~ - Tes' Pit ~ocotlon'
t:::\ Approllmote Number 0'
~ - Drums Observed In
. Tu' Pit
r.. - Approximate Area 0'
. ~ Was'e Pile Where Drums
~~.: Were Observed
-------
~NEW ENGLAND
l={1--I EMBROIDERY
L
N
\
.
o
CARROLL REE
SKI SHOPS
INC
MILL
. 't~
. .
.
o
CARROLL
INDUSTRIES.
o~
\
\
\
1. ."
.,,"'" 1.
c?o
~
~
~
.",.
~
-------
ON-SITE TREATMENT BY EXTRACfIONI
CHEMICAL PRECIPITATIONI
AIR STRIPPING
CLEAN Ala
.
.
SETTLING CARlON
AGENTS FILTEa5
.
;ROUNO- ( ~ GROUND- t CROUI'fD-
W A TEll CHEMICAL W A TEl Ala. 1 WATtI
l PRECIPITATION , STMIPPING 1
I METALS I Ala I
DiWATIIIHG
OFF-SITE
LA I'fDFI LL
DISCHARGE
TO POTW
FIGURE 13
-------
PAEC'~fTATION
PRECIPITATING CHEMICALSl
FLOCCULATING AGENTS.~
INLfT LIQUID STllEAM-t
RAPID MIX TANK
AnER THE ADDITION OF PRECIPITATING
CHEMICAU THE PRECIPITATION REACTION
COMMENCES TO FORM VERY SMALL PAR.
TICLES CAllED PRECIPfTATION NUCLEI.
THE FLOCCULATING AGENTS AllOW THESE
PARTICLES TO AGGLOMERATE
FLOCCULATION
FLOCCULATION CHAMBER
IV SLOW AND GENTLE MIXING THE
PRECIPITATED PARTICLES. AIDED IV
THE FLOCCULATING AGENTS. COLLIDE.
AGGLOMERATE. AND GROW INTO LARGER
SETTLEABlE PARTICLES
SEDIMENTATION
OUTLET LIQUID
STREAM
SEDIMENTATION BASIN
THE SmlEAILf PARTICLES PRODUCED
IV THE FLOCCULATION STEP ARE SmLED.
COLLECTED AND PERIODICAll V REMOVED
REPRESENTATIVE CONFIGURATION EMPLOYING PRECIPITATION,
FLOCCULATION, AND SEDIMENTATION
FIGURE 14
-------
PACKED COLUMN
DIFFUSED AIR BASIN
EXIT AIR
~ACKI"O
MATERIAL
AIR SUPPLY
CAID ".
., t
T
-EFFlueNT
: .'if
DISTRI8UTOR
SUPPORT
""'-PlATE
~...;=-;,.c 01111"0
--;-~ AI"
EFFlUE"Ti
COKE TRAY AERATOR
~il~18UTI"Q
JOO~~SPLA'H
RAW WAnll ~- - ""0".
IfIJLZ1' .
r~un~n - ~
A TSJr'IIASIN - oun.!T
CROSS-FLOW TOWER
AlA
l"lET
oUR
INLET
WATER
OUTLET
. COlLECTtO"
8ASI"
Source: Canter and Knox. 1985
FIGURE 15
Air stripping Equipment configurations
Air stripping is a mass transfer process in which volatile
contaminants in water or soil are transferred to gas, There are
-------
APPENDIX B
-------
29-Dee-82 25-Jan-83 - 20-Jul-83
MW-1
MW-4
MW-7
MW:8
MW-9
MW.IO
MW.11
MW-I2
MWS- 101
MWD- 102
MWS- 103
MWS- 104
MWS.I05
MWD- 106
MWD-I07
MWD-108
MWD.I09
MWA.I10
MWA.I I 1
MWS.II2
MWS.113
MWS- 114
MWS.II5
MWS- 116
MWD.117
CDM.I
CDM.2
CDM-3
CONWAY 1
CaN/AV2
ND (d)
ND (d)
10900
278
3500
<5.0
<5.0
<5.0
66
<10
>2600
<.0
N>
N>
46
N>
ND . no. detected
(d) . average value 01 duplicate samples
< . less than detection limit specilied
t
Hi5iORiCAL GROUt~CWATER 1.1.1 ..TR:CHlOROETHANE (1.1,1 ~TCA) DATA (ppb)
N~
3.Feb-84
144
243
6000
N>
N>
N>
77
N>
. \
7-Au .84
GB
17-Jan-85 '9.Jul.8S '8.Dee-8S 20.Mar.86 19-Jun.86
150 75.4 8 c5.0 N> 1.4
496.5 2'9 149 62.4 220 13
50000 135000 49000 33460 5052 5300 5680
5 6.5 (d) <5.0 <5 <5 5.55
N> to N> N> N> N> N>
N> 5.6 N> N> N> N> 7.2
53.5 to 116.3 83 38.7 28.5 (d) N>
4'.7 to N> N> N> <5.0 N>
18000 10000 13500 1470
N> 13.9 d.5 (d) 0.97
3G <15.0 <5.0 N>
N> N> 12.4 N>
N> N> ND (d) N>
N> N> N> 2.78
N> N> N> N>
N> N> N> 11.1
N> N> N> 0.95
N> N) N> N)
N> N) N) N>
N> N> ND (d) 18
N) cS.O N)
328.8 580 64.6
119.4 113.8
N> N> N)
c5.0 154 (d) N)
N>
N>
TABLE 1
18600 (d)
<4.0
20.19
1008
34.8
cO.4
1.02
28.96
cO.4
-------
TABLE 2: SUMMARY OF CONTAMINANTS
OF CONCERN IN GROUND WATER
Average Maximum
Contaminants of Concentration Detection Frequency of
Concern (DDb) (DDb) Detection
Acetone 44 374 1/27
Chloroform 8 171 2/27
Chromium 13 50 6/19
1,1-Dichloroethane 98 1,560 9/27
1,2-Dichloroethane 1 15 2/27
1,1-Dichloroethylene 26 615 4/27
1,2-Dichloroethylene 3 38 2/27
Nickel 351 6,000 4/19
1, 1, I-Trichloroethane 996 18,550 14/27
Trichloroethylene 7 118 2/27
TABLE 3: SUMMARY OF CONTAMINANTS
OF CONCERN IN WASTE PILE
Average Maximum
.Contaminants of Concentration Detection Frequency of
Concern (DDm) (DDm) Detection
Chromium 1035 1790 12/12
Copper 57 120 12/12
-------
TABLE 4: SUMMARY OF CONTAMINANTS
OF CONCERN IN SURFACE WATER
COJ1taminants of
Concern
Average
Concentration
(DDm)
Chromium
0.02
<-'
Nickel
0.06
Maximum
Detection.
(DDm)
0.05
0.15
TABLE 5: SUMMARY OF CONTAMINANTS
OF CONCERN IN SEDIMENTS
Corltaminants of
Corlcern
Average
Concentration
(DPm)
Maximum
Detection
(DPm
Chromium 240 580
Mercury 0.25 0.4
Nickel 148 320
Frequency of
Detection
2/4
3/4
Frequency of
Detection
4/4
4/4
-------
TABLE 6:
CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTIO~
OF GROUND WATER
Cancer
Concentration Potency Exposure Risk Risk
Contaminant of (uq/l) Factor Factor Estimate Estimate
Concern avq Max mq/kq/d-1 l/kq/d avq Max
Chloroform 8 171 6.1E-03 2.9E-02 1.3E-06 3.0E-05
l,l-Oichloroet- 98 1,560 9.1E-02 2.9E-02 2.5E-04 4.1E-03
hane
1,2-0ichloroet- 1 15 9.1E-02 -2. 9E-02 3.1E-06 3.8E-05
hane
1,1-0ichloroe
thylene 26 615 6.0E-01 2.9E-02 4.4E-04 1.1E-02
Trichloroe-
thylene 7 118 1.1E-02 2.9E-02 2.0E-06 3.7E-05
------- --------
SUM 7.0E-04 1.5E-02
Exposure Factor:
2 liter of ground water per day
70 kg person for 70 years
(differences in table due to rounding)
-------
(
TABLE 7
NONCARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF GROUND WATER
Concentration Reference Exposure Hazard Hazard
contaminants of (uq/l) Dose Factor Index Index
Concern avq max mq/kq/d I/kq/d avq max
Acetone 44 374 1.IE-Ol 2.9E-02 1.3E-02 1.IE-OI
Chloroform 8 171 1.0E-02 2. 9E-02 2.2E-02 4.9E-OI
Chromium 13 50 5.0E-03 2. 9E-02 7. 7E-02 2.9E-Ol
1, 1, Dichloroethane 98 1,560 1.0E-01 2. 9E-02 2.8E-02 4.5E-01
1, 1, Dichloroethylene 26 615 9.0E-03 2. 9E-02 8. 2E-02 2.0E+00
1,2,Dichloroethylene 3 38 2.0E-02 2. 9E-02 4.6E-03 5.5E-02
Nickel
2.0E-02
2.9E-02
5.0E-01
8.6E+00
351
6,000
1, 1, 1Trichloroethane
9.0E-02
2.9E-02
3.2E-01
5.9E+00
996
18,550
Potential Future Ingestion of Ground Water
Hazard Index Sums:
Average
Reasonable
Maximum Exposure
Liver Effects
0.5
8.8
Kidney Effects
0.013
0.1
Reduced body & organ weight
8.6
0.5
Fxrc):".11 rl' F.lctor:
2 liter of ground water per day, 70 kg person, for 70 years
Toxicity
Endpoint
increased liver &
kidney weight
liver lesions
hepatotoxicity
ND
liver lesions
increased serum
alkaline phosphat-
ase (liver)
reduced body and
organ weight.
-------
TABLE 8
NONCARCINOGENIC RISKS FOR THE POSSIBLE CURRENT n:GESTION
OF WASTE PILES
Contaminants of
Concern
Concentration Reference Exposure Hazard Ha:~ard
(mg/kg) Dose Factor Index Index
avq Max mq/kq/d (mq/kq/dl avq Max
1035 1790 5.0E-03 0.2 4.1E-02 7.2E-02
57 120 3.7E-02 0.2 3.2E-04 6.6E-04
590 930 2.OE-02 0.2 6.0E-03 9.5E-03
Chromium
Copper
Nickel
Potential Current
Ingestion of Waste Piles
Hazard Index Sums:
Average
Reasonable
Maximum
Exposure
Liver Effects
5.3E-02
7.3E-02
GI Tract Effects
3.2E-04
6.6E-04
Reduced body & organ weight
6.0E-03
9.5E-03
Exposure Factor
43 kg older child/teenager ingests 100 mg of soil per day
32 days per year for 12 years
(differences in table due to rounding)
.,
Toxicity
Endpoint
liver lesions
GI irritation
reduced body and
-------
"'~ nT_I:' 0
"'~&.I~~ J
C:
NONCARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF WASTE PILES
Concentration Reference
contaminants of (mg/kg) Dose
Concern avq Max mq/kq/d
Chromium 1035 1790 5.0E-03
Copper 57 120 3.7E-02
Nickel 590 930 2.0E-02
Potential Future
Ingestion of Waste Piles
Hazard Index Sums: Average
Liver Effects 8.0E-Ol
GI Tract Effects 6.0E-03
Reduced body & organ weight 1. 2E-Ol
Exposure Factor
14 kg child ingests 200 mg of soil per day,
100 days per year for 6 years
(differences in table due to rounding)
Exposure
Factor
mq/kq/d
3.9
3.9
3.9
Reasonable
Max imum
Exposure
1.4E+00
1.3E-02
1.8E-Ol
Hazard Hazard
Index Index
avq Max
8.0E-Ol 1.4E+OO
6.1E-03 1.3E-02
1.2E-Ol 1.8E-Ol
Toxicity
Endpoint
liver lesions
GI irritation
reduced body and
-------
TABLE 10
NONCARCINOGENIC RISKS FOR THE POSSIBLE CURRENT INCIDENTAL
INGESTION OF SURFACE WATER
Concentration Reference Exposure Hazard Hazard
Contaminants of (mg/l) Dose Factor Index Index Toxicity
Concern avq max mq/kq/dav l/kq/dv avq Max Endpoint
Chromium 0.02 0.05 5.0E-03 8.1E-05 3.3E-04 8.1E-04 liver lesions
Nickel 0.06 0.15 2.0E-02 8.1E-05 2.3E-04 6.1E-04 reduced body and
organ weight
Potential Current Incidental
Ingestion of Surface water
Hazard Index Sums:
Average
Reasonable
Maximum
Exposure
Liver Effects
3.0E-04
8.1E-04
Reduced body & organ weight
2.3E-04
6.1E-04
Exposure Factor
70 kg person ingests 0.13 liters of water per event,
and swims 16 times per year for 70 years.
-------
TABLE 11
NONCARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INCIDENTAL
INGESTION OF SURFACE WATER
Concentration Reference Exposure Hazard Hazard
Contaminants of (mq/l) Dose Factor Index Index Toxicity
Concern avq Max mq/kq/d l/kq/d avq Max Endpoint
Chromium 0.02 0.05 5.0E-03 3. 3E-04 1.3E-03 3.3E-03 liver lesions
Nickel 0.06 0.15 2.0E-02 3.3E-04 9.1E-04 2.4E-03 reduced body and
organ weight
Potential Current Incidental
Ingestion of Surface Water
Hazard Index Sums:
Average
Reasonable
Maximum
Exposure
Liver Effects
1.3E-03
3.3E-03
Reduced body & organ weight
9.1E-04
2.4E-03
Exposure Factor
70 kg person ingests 0.13 liters of water per event
and swims 64 times per year for 70 years.
-------
TABLE 12
NONCARCINOGENIC RISKS FOR THE POSSIBLE CURRENT IHADVERTENT
INGESTION OF SEDIMENTS
Concentration Reference
Contaminants of (mq/kg) Dose
Concern avq Max mq/kq/d
Chromium 240 580 5.0E-03
Mercury 0.25 0.4 3.0E-04
Nickel 150 320 2.0E-02
Exposure Hazard Ha~ard
Factor Index Index
mq/kq/d avq Max
0.1 4.9E-03 1. 2E-02
0.1 8.3E-05 1.4E-04
0.1 7.5E-04 1.6E-03
Potential Current Incidental
Ingestion of Sediments
Hazard Index Sums:
Average
Reasonable
Maximum
Exposure
Liver Effects
4.9E-03
1.2E-02
Kidney Effects
8.0E-05
1.4E-04
Reduced body & organ weight
7.5E-04
1.6E-03
Sxposure Factor
43 kg older child/teenager ingests 100 mg of sediments
per day 16 days a year for 12 years.
(differences in table due to rounding)
o
Toxicity
Endpoint
liver lesions
kidney effects
reduced body and
-------
TABLE 13
NONCARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INADVERTENT
INGESTION OF SEDIMENTS
Concentration Reference
Contaminants of (mg/l) Dose
Concern avq Max mq/kq/d
Chromium 240 580 5.0E-03
Mercury 0.025 0.4 3.0E-04
Nickel 150 320 2.0E-02
Potential Current Incidental
Ingestion of Sediments
Hazard Index Sums:
Average
Liver Effects
1. 2E-01
Reduced body & organ weight
1. 9E-02
Kidney Effects
2.0E-03
Exposure Factor
14 kg child ingests 200 mg of sediments,
per day 64 days a year for 6 years.
(differences in table due to rounding)
Exposure Hazard Hazard
Factor Index Index
mq/kq/d avq Max
2.5 1.2E-01 2.9E-01
2.5 2.0E-03 3.3E-03
2.5 1. 9E-02 4.0E-02
Reasonable
Maximum
Exposure
2.9E-01
4.0E-02
3.0E-03
Toxicity
Endpoint
liver lesions
kidney effects
reduced body and
-------
J8Im8VNJIWOUft
SoUa
....
Or~tu
'ederal
It8fulatory
l18quir..nta
ltat. 88fUlatory
~
lOIa - ...&1- COfttuinant
Lavala (1ICLa t (40 en
141.11 - 141.16t
801a - ....188 eaac.atration
U.ita 0081a (1IC:ID8»
(40 era 141.50 - 141.51t
8CP 40 era JOO~4JO
OrOl8lllll8t.r trot8C'tlon
IteM lIMitl. C, 40 era
'art 2&4 - 8ubp8rt ,
~ .'~:IJ 1.1. AdaiD.
C'od8 'art .. 410
'rotecUon of orOUDClllatu
-'
TABLE 14
c
aIIIIII~C ..... All) ~, MIII'I88IIS, All) ~
... ~ DMSA88 81ft, ~, - 1D..J.:.--4
STMUS
..l.vant Uld
Appropriate
..levUlt and
Appropriate
..l..Ult and
Appropriat.
AwUc8bl.
IllQUIIIDtENI' mmpsts
MCL8 have boon prGaUl,at.d for a nu8bor
of co_n or,.nic and inor,anic con-
tuinUlta. Th..e lev.la r8CJUbt. the
concentr.tion of contuiD&ftta in public
drink in, ..t.r auppU.a, but MY abo be
conaidored for ,roundvat.r 8CJUif.ra
potentially u.ed for drinkin, wat.r.
IICID8 ar. atUldard in tho IICP ..copt
whor. they are ..ro. Althouth.n
.pplicable MCL08 .r. pr..entl, aon-..ro
and IICLa ar. tbo pr..ent .tUldlrd, it
Ihould be noted tbat IICLa CUI be
auporcododl.
"'.a. raqul r_ta 1nc:ludo botb
concentraUon atandlrdl and aonitorin9
raqulr_ta and conactho action
raqulr.8Iftta for r.,ulated unita.
"'-a. pro.laiOll8 r89Ulat. di.c:bar... to
9r..-dwatu and proYido for 9roundvat.r
protaction.
IXlRSIDDAnOil IW 'nIB rs
MCL8 win be conaidored for UI. a. pohntial
cl.an-up crit.ria.
Ian-S.ro'~ will be conaidor.d for us. ..
potential ol..n-up crit.ria.
IUndar. will be cOll8idered for UI. a.
potential cl.an-up cri t.ria..
stat. ,roundvater quality criteria viii be
c:onIIiduod for UI. a. potential cl.an-up
cdt.da. ..Mdtal action win be taken
to 811a1aat. tbo uncontrolled di.c:bar91 of
of ba.ardaua ...t. caaatitUonta, .ulatil.
or9U1ic ~ (9OC'.t, and Inor,anlc
-------
IDI1IVMI'ftDITf
TABLE 14
lCoat'd)
~caIrG8C:IPIC ..... JI8D CIIDaIA. ~. JI8D 8JIDI8:8
... '1118 DaIIID88 81ft. ~. - "'8--
UQUIIIItaft
IIA .,5-&: U l8etion
.. 410.05 G~0UDdM8tlr
Qualitr Crltlrla
IIA 485-&: U S8c:tion
.. 410.0' G~OUDdv8tlr
Di.ehar98 C~it.ria,
incoqlOraUDf br r.ference
IIA 141-8:1 .. Pert JOJ
....at- C8tudnant Le-Ia
111:1.'.1 and SU998lted
80 Adftr.. ".pona.
..".18 IIIIMtS 1 )
IIA .'5-&:1) .. 411.10
Additional Crit.ril
au. 485-&:1) l8etion
.. no. n Bowtdary
Cr !tub
STA1US
AppUcabl.
Appltcab1.
Appltcabl.
IIIQUtItD8Irr SYlmPSIS
.. nO.OSII) prohibita IItldlarp of
IYiludoua .It. to trOllll6lat.r. ~dor
.. nO.OSI.), no lubatane. doatC)ft8ted
in.. no, or tlhic:h h baraful to
...... Ia.alth or tho ...vir_nt ..y
be dtac:har,ed to ,roundwatlr 10 II to
IIClod pri..ry NC:L8. Allo, under ..
410.051,), ,r0undw8t.r not to be
do,rlclad in luch a vay to caul. violation
of lurf.c. vat.r Itandarda vitbtn or
Idjlcent to property.
.. 410.0' ..tablil".1 troundwat.r dilc:har,.
crit.ria indudiD, NC:L8 and SI'IMLS, codi-
fied iD .. .art J02, DrinUftt -tlr
J89ulltiona. Stanclarda Ipplicabl. to thl
lit. 1De1uda SI'IMLS for lif.ti.. I.polur.
to Todc Contudnant Lo..l, .. JOJ. 01 I al :
SIIAJILS for eontwnanta allodated vith
cancer ailll Contwnant LovllI,
WIt JOJ.Ollbl: and 1Cta, WIt J02.02,
.. J02.04, and .. J02.ll.
.. 410.10 Itat.. that ,roundwat.r ....11
DOt be alt.red iD luch a wa, al to rOlldor
it unau1tab1. for drinkiD, vat.r lupp1,.
.. nO.n providel CClllpUane. boundary
critlria and defin.. 8ft lat.rvention Ion..
CIOIISIIZItATIOII III ftII rs
ar~t.~ alt.raati..1 tlhich iDVOlvl .ffluent
dileta.r98 bacll to tho ,roundwat.r vill cOllply
vith WI r8CJlllation.
stat. MOL and SRAaL 1...11 tlhic:h Ir. 80rl
'.
Itrin9lDt than 'odaral l.v.ll viii be
eonatdored for ual al potential cllan-up
critlria.
state MOL 8Dd SRUL 11..18 tlhicla erl 80rl
ItriDflDt than fodaral llVlll viii be
c:aaaidored for ua. .1 pot_tial cl.an-up
crit.ria.
l888dial actiona for tho ,roundwatlr
tr.at8lDt viii conaider thlll definod
boundarill tlhen dotlr8inin9 a point of
-------
TABLJ:i 15
"
IDCATIOI SPECIFIC AJII\It8 AIm canDIA. ~. AIm GU'IDNICB
p(8 ~ UNISAJIGE Sl'I'B. COIIIIPoY. IIEW IINU'SIIIJII1
ta:DI~AI1IftORITf
CORSIDERATIOIf 1ft 'THE 'S
W8tlande/Floodplain.
rederal
aequlatory
Require_nta
State Re9Ulatory
Requi re...nts
rederal criteria,
Advhories and
Guidance
RElQUIJtEMEIft
Clean water Act (OIA) -
Section 404: 40 era Part
230, ]) era Part. 320-330
ri.h and ~ld1ife
Coordination Act
(40 erR 6.)02)
Nev Ha~.hire W8tlanda Act
(RSA 48)-1. under Tenhn
Alterations RSA 485-1.:17'
. R.H. Ad8in. code
Cb. Nt 100-800
Hi.toric pra.ervation
IRSA 227-C, RSA 31:89Ia)
.. 89lk)
W8tl.nda I.ecutive order
IEO 11990)
rloodplain. Ixecutive
Order IEO 11888)
STATUS
~lic.ble
Applic.ble
~licable
Relevant.
~roprhte
Applicable
Applicabla
REQUIREMDft' SYNOPSIS
under this require_nt, the discharge of
dred98d or fill ..terial into a vetland
is prohibited without a perait. lW8tlands
as defined in u.s. IUn8y corps of Engineers
re9Ulations)
This re9Ulation requires that any rederal
Agency that propose. to IIOdify a body
of water 8Ust consult with the u.s. rish
and wildlife services. !bis requirement
is addressed under ~ S.ction 404
require..nts.
These re9Ulate dredging, filling and
other activities in or adjacent to
veUands .
The.e re9Ulate the altering or
destruction of historic place. and
area..
under this regulation, federal agencies
are required to .ini.i.a the destruction,
loss or degradation of wetlands, and
beneficial values of wetlands.
rederal Agencies ar. required to reduce
the risk of flood loss, to 81ni.i..
iapact of floods, and to restore and
preserve the natural and beneficial
value of floodplains.
DUring the identification, .creening, and
evaluation of alternatives, the effects on
identified !Me vetlands are evaluated. Remedial
activities Which discharge ..terials into the
wetlande, will co~ly with these criteria.
Diversion, channeling or other activity that may
aodify !Me'. dovnstrea. creek and affects fish or
wildlife requires that the 'ish and Wildlife
Service be consulted.
All alt.rn.tives considered will addre.s
po..ible i"acts to identified IMC vetlands.
Re_dial activities will .inifti.e har. to
the vetlandl to the extent possible.
All alternative. considered ..y address
possible i~ct. to any identified historic
places and area..
All alternativas considered wiil address
possible iapact. to identified KMC wetlands.
Re..dial activities will .ini.i.e hars to
the vetlandl to tha extant possible.
The potential effects of re..dial action on
identified IMC floodplain will be avaluated
to ensure that the pl.nning and deci.ion-
asking reflect consideration of flood
hazards and floodplain aanage..nt, including
restoration and preservation of natural
-------
TABLE 16
~C8-8ftc:Jnc 8UPLlaau8 08 8UL8YU1t UD U..nlAft8 nD88AL.. nAB
88QUIaaID"n roa SOO8a COIn'IIOL AIID llAUGam8'I' or IllGUftO. ~
I.
lequi re..at
rlDlaAL lIQUII&KI8rS
Bot
Applicabl.
1.
Solid .a.to DI.,o.al racllit, crlt.ria
IICIA .ubtitl. D. .0 cr. 'art 257:
'ropo..d .art 25.)
2.
.a..~doua .a.to lafalation. IleRA
Subtitl. C, 40 cr. 'a~t 26.)
a.
Ground .at.~ 'rotoctioa 121..10
- 2U.IOt) ISubpart r)
b.
Grouad .at.~ "oaito~ia9 121..10
- 2U.ft)
c.
Cloauro and 'oat-Clo.ur. 12'4.110
- 2'4.120, 2'5.120 - 265.112)
Isubpart 0)
d.
Coatalnor. 12'..110 - 21..17.:
265.170 - 215.177) ISubpart I)
..
~aak. 1214.110 - 264.1":
215.110 - 215.111) (Subpart oJ)
f.
lurfaeo 18pOUadMnt8 12'..220 -
26..2)0, 2'5.220 - 265.210)
I
9. .aato 'II.. 121..250 - 2'..251:
2'5.250 - 215.25') I Subpart L)
h. Laad ~roat..nt 1265.)00 - I
214.111: 215.270 - 265.212)
I. Laadfill. 121..'00 - 215."':
215.)00 - 2'5.'11) (Subpart It.
:I. laeia.rator. 12'4.340 -
214."', 215.,.0 - 215.'")
II. .a.ardou. aad Solid ...t.
AI.nda.nt. ("SWA) Lond D18po881
..atrictiona lul. 1261-270)
Applieablo
I
1.1..ant
Appropriah
J[
J[
J[
J[
J[
I
11
J[
J[
.aUoaal.
R8.0ba..rdoua .a.t.a .., b. di.po..d In
'ubtitl. D Solid ..at. laadflil.
....dI81 alt.raati..a iaelud. ,roundvat.r
tr.at..nt,aad r.eb.r,..
.a...lal 8It.rnatl... laclud. ,roundv8t.r
..aborta, .
Clo.ur. .nd poat-elo.ur. r.quire..nts
.a, b. r.quir.d lor .at.rial. in
".st. pllo.
'...dial alt.raatl... Inelud.
contain.ri.in, and off-.it. transport of
cont..in.ted soil. .
....dlal alt.rnatl..s Includ. on-sit.
.at.r tr.at..nt ID.ol.ln, surlac. tsnks.
I...dlal alt.rnatl... do aot includ.
aurf.e. i.pounda.nt 01 ba.ardous vsst..
....dial alt.rnati... includ.
..ea.ation of .oil and stora,. in vsst.
pil.. prior to tr.at..nt/disposal.
....dlal alt.rnati... do not includ.
hnd tr.at..nt.
....dial alt.rnati..s inelud.
elppin, and elosin, sit. ss lsndfill.
I...dlal Ilt.rnltl..s inelud. lov
t..,.rltur. th.r..l strlppin,.
....dlal alt.rnlti..a inelud. land
-------
TABLE 16
(Cont'd)
~
~--.nClnc 8anuCA8l.88 08 8aa.8ftft AIID u.mn.IAft8 r....u. UD ~
~~ !'O~ ~~ ~L AJID 1IAIIAOaaJn' or IUGU!'I08 ~
).
aequho..nt
SOMA C42 UIC )000 If II Raai8U.
conta.inant Le.ol. IMCLaI
140 cr. 141.11 - 14S.1'1
4.
SOMA 142 USC )000 Cfll Raai8U.
conco.tratioD Li.it. OOal. I"CLOal
(40 cr. 141.50 - 141.511
5.
.011th Iffoct. "'O'I...t. 11&A'I)
(ICAOCI8, USI.A, Ra.ch 1''')
..
'ollth Ad.i.oriol, '.A Offico 0'
Drinkin, .It.r, Rarch )1, 1'17
7.
IOMA C42 ule 1000 Cfll UDd.r,rownd
Injoction CODtrol ..,Ulltio.,
(40 cra 144, 145, 14' Ind 1471
Cl.l. .Itor act C'L'2-S001
UJ uIe 1251) I
I.
I.
'04.rll .It.r Qullit~ critoril
C l.cUon IOU
b.
'Itio.ll 'ollutlat Di.chlr,.
Ili.ialtio. I~.to. C8.DII)
Cloctio. 402, 40 cra 'Irt. 122-1251
Itlto .ator Qu.lit~ Ita.dardl
CI.ctiona )01, )02 Ind )0)1
e.
d.
'od.rll .rotrolt..nt .equira-
"Dtl for Di.ch.r,. to Publicl,
OwDod 7rolt...t WOrk. II.ctio..
JO' Ind 1071
o.
OC.an ou.,in, aequir...nt. .
(Soction 401, 40 cra 125.120-
125.124, 220-2)11
loctioe 404 Ihl CSt Gaid.li... for
',.cification of Di.,..al .it..
for Dr.d,.d or rill Ratorill
140 cr. 'Irt 2)0, )J cr. 'Irt.
HO-HOI
f.
lIot
Applicabl.
Applicabl.
][
x
][
][
a.1.vlnt
A'ppropdat.
][
x
][
1[
J[
1[
1[
aationalo
.._dhl Ilt..rllativ.. includ. ,roundvlt.r
nchl r,. .
....dill Ilt8rnltiv.. includo ,roundvlt.r
nchl r,o.
....4ial .It.rnativ.. includ. ,roundvlt.r
nchlr,..
....-dial alt.rnativ.. illclud. ,roundvlter
r.ct Ir,..
....dial Ilt.rn.tiv.. do not includ.
und.r,round inj.ction.
..quirod for aquif.r r...diation.
'o..ibl. di.ch.r,o of tro.tod
,roundvator to ..quvk.tt Pond.
....dill Iltornltiv.. includ. di.ch.r,.
to .ur'lcl vltor.
....di.l .ltornativ.. includ. di.chlr,.
to POft.
110 Ilt.rnltiv.. includ. oC.ln du.pin,.
10 4r.d,o ..tori.l viii b. ,.norat.d
-------
TABLE 16
(Cont'd)
~~nc 8UftdCA8l.88 08 8881.11'nft AD UI'8OftIU88 n188AL AIID ftM8
88QU18DI88TS PO. souaa COIft'IIOL AIID 1IAIDOamn' 0' IIIOUI08 ~
lot ..l.vant
.equln..nt Applicabl. Applicable Approprlat. aaUond.
,. Dr.d,.d Rat.rlal DI.po.al lit.. . I. dr.d,. ..t.rlal will b. ,.n.rat.d a.
Denial or ...trlctlon. .roc.dur.. a r.ault of r...dlal alt.rnativ...
C404 Cc), JJ use lJ44 Cc) 40 cra
.art 2111
b. Public 8.altb .a.l. for Decl.lon to . ....dl.l alt.rnativ.. Inc:1ud. at r
Li.t .ollutant. a. .a.ardou. ..i..ion. control..
CI.ctio. 112 of tb. Cl.a. Air Actl
.. I.cl..ratio. at I.a .~Ir...nt. . 80 oc.a. I.cin.ratlo. alt.rnaUv..
CJJ ule 1412, 1414, 1411, 1411) includ.d..
C40 cr. .art. 220 - 225, 221, 221'
10. Rarl.. .rot.ctlo. .....rcb a.d . ....dlal Alt.r.ativ.. do not i.pact
lanctuarl.. Act CJJ use 1401) .arin. .nvlron..nt..
11. ..qulatlo. of Actl.ltl.. Aff.ctln, . Actl.ltl.a In w.tland. would b.
Wat.r of tb. U.I. CJJ c,. ..rt. J20 cov.r.d und.r th... r.,ul.tion..
- u.»
u. Ura.lue Rill 7allln, aul.. C42 use . Ro uranla..ill tailin,. on.it..
2022, 40 cr. .art 1'2)
u. Cl.an Air Act C.2 UIC 1401)1
a. .attonal --tent Air QIIaUtr . ....dlal .It.rnativ.. Inc:1ud. .ir
Itandard. CRAAQI) for I...n ..i,.lon. control..
Crit.ria 'ollutant. C to er.
.art SO)
b. Itandard. for li,h- and Lov- . Ro ~adloactiv. ..at. on-.it..
Lav.l .adioacti.. .a.t. CI0
cn .art 20'
c. lational I.i..lo.. Itan4ard. . ...,dlal alt.rnativ.. includ. .ir
for la.ardou. Air .01Iutant., ..i..ion. control.. Chlorofor. i8 in
C40 cr. .art 11) ,round.at.r.
u. OIRA ..qulr...nt. C2. use 151) . .a..dial .It.rnativ.. inc:1ud. on-ait.
C2' cr. .art. 1'10, 1.21 a.d 1'0.1 work.r activiti...
u. I..cutl.. Ord.r. II'" C '_loodphin . ....di.1 alt.rnativ.. includ.
Rana,....t) .nd 11"0 C .rotacUon activiti.. in a ..tland and a floodplain.
-------
TABLE 16
(Cont'd)
K'nCl8-8I'8C1nC 8APfto1c:a81.88 OIl 88D.8Qft &lID unonIAft8 r...-aL .. I'I'Aft
UQU18811D1'S POI souaa COIIr8OL UD IWUGUID"f O' IlICDA!'108 ALTDD7IYU
11.
lequir...nt
act. I.latod to 'roteetioa aad 'ro-
.or..tioa of .atioa.l, Arcb.olo-
,ical or CUltural ao.oarc..
Cl' V'C .,0, J2 cra .art. 22' aad
22'.., a.d .J era .art. 1 and 1.4'
lot
Applic.bl.
Jt
AppUcablo
11.
DOt aul0' for .a.ardoa. Ratorial.
~ran.port ct. cra 'arta 101, 111.1
- 111.500'
u.
lada.t.rod .peci.. act of 1.,J
111 usc un.
Jt
u.
.i.h a.d .J'dlif. Coordi.atio. act
111 usc "it
20.
'I..b a.d .I.ldlifa l8pro.....t act of
1.,. 11' cra .art 142a,
u.
ri.b a.d .ildlif. Co..or.atio. act of
1..0 CI' VSC 2'01, 50 cr. .art 'J'
22.
Coa.tal 10.0 Ra..,o...t Act II' use
Inu
Jt
u.
...t1cido ..,i.tr.tioD, ~olor..co.
aDd ActioD Lo..l.
.
21.
...t. Load AllocatioD 'roc.duro.
I'A Offico of .at.r C.O cr. .art 125,
150'
25.
rodoral '010 .oarco Aquifor
a.qulr...nt. 152 ,. "'3, M.rch 5, 1"'1
Jt
2'.
I.A'. oroundwator 'rotoctioa Strat."
ouldoll... for oroundwat.r Cla..lfleation
21.
... I..reo "rfor...eo Ita.dar40 for
..troloun Liquid Itora,o va...l.
~odc 'ub.ta.e.. Co.trol Act C~ICAI
Data, 'olicy aad Cho.lcal ...I.orl..
C15 use 2'01, I.ctlon ,.
Jt
28.
Jt
..
TOlic lub.t.nc. control Act
II' ole 2'011 .CI a.quir...at.
(40 era ..rt "II
Jt
a.l..ant
. ~proprht.
Jt
Jt
Jt
Jt
Jt
Jt
aaUoaal.
10 .a\ura1 alcb.olo,ical or cultur.1
r..ourc.. OQ .it..
a...4i.1 tlt.rnati... includ.
tr.D.port of ba.ardou. .a.t. off.it..
loft. on.l.t..
'...dial actloa .ay .ff.ct fi.h or
wildlifo.
....dlal action .ay .ff.ct fi.h or
.11dlif..
....dial action ..y .ff.ct fi.h or
wildlU..
.
sito i. not .ithin Coa.t.l Son.
Mana,...nt ar.a.
10 p..ticid.. pr...nt on .it..
'o..ibl. '.O.T... di.ehar,..
lit. i. not und.rlain by .01.
.ourc. aquif.r.
....dlal action. .ill conaid.r
,round.at.r cia.....
10 p.troloun .tora,. to b. provid.d
a. part of r...dial action..
10 TSCA r.9Ol.t.d ch..ic.l. on.it..
-------
TABLE 16
(Cont'd)
ACYI--8ncrnc 8Uft.lCA8l.88 08 8UJ.1WM11' &lID U.-onIAft8 r....u. UD ft&ft
8.8QOJ8D1D!'8 .va sooaa: COIITIIOL AIID DIIIIODDn' or IIICDUI08 AL~
2t.
lequlr...nt
Int.rl. 'ollcy for ,18aaln, .nd
I.pl...ntlnt ccaCLA a..pon.. Action.
C50 r. .5'33-11/5/'5.
30.
'ropo..d .t.nd.rd. for Conte.ln.nt
'.I..lon. of Vol.tll. or,.nlc.
C50 r. 3'.1-2/5/'71
II.
Int.ri. I~CLA raid.nc.
contiruou, .it.. .nd oa-.lt.
of ...t. .nd tr..t.d r..idu.
st.t...nt 3/27/...
IYA'lI or ... ......1111. ..QUlaIJIIIlft'.
31.
of .0-
..n.,...nt
IIU 'olicy
1.
... ..ap.hir. 8011d ...t. ",ne,...nt
aul.., ..-. Cb. 1'01
2.
... ...p.hiro ....rdoa. ...t. lul.e,
11.-' Ch. 1905
..
",nlf..tin, ..quir...nt.
111-' 1'05.04
b.
..ck.,in, .nd Lab.lin, ..quir...nt.,
..-. 1905.05
c.
'.r.lt lequlr...nt. for .e..rdou.
...t. r.cllltl.., ..-. 1'05.0'
Rot
Appllcabl.
I
Applic.bl.
'.l...nt
Appropriate
I
I
I
I
I
I
I
..Uonll.
....dl.l alt.rn.tl.o. Includo
I.ploaontin, r..pon.o .ctlon. undor
CIICLA.
,o.odl.l .It.rnatl... Includ. .Ir
..1..10.. control..
'..odl.l 8It.ra.tl... Includo on-.lto
..na,o..nt of ...t. .nd tr.et.d ro.lduo.
.on-~...rdoul .alt. ..y r..aln on .It.
.ftor tr..taont r.qulrln, lolld .a.t.
facility ..na,..ont .nd clo.ur..
St.ndardl .ppllc.bl. to tr.at..nt,
.tor.,. ..d dl.po.al of be.erdou. wa.t.
end clolgr. of ba.ardou. w..t.
fecilltl... !!! .0-' 1'05.02(el.
....dl.l .It.rnatlv.1 .., Includ. the
r..o..l .nd tren.port off-.lt. of
cont..ln.t.d .011 end/or ,roundwat.r
for off-lit. tro.t.ont or dl.po.el.
....dl.l .It.rnetl... .a, includo the
r.....l .nd tran.port off-.It. of
conte.ln.t.d .011 and/or ,roundwator
for off-.lt. tr..t.ont or .dl.po.al.
Pur.u.nt to .octlon 121101111 of tho
Suporfund a..nd8ont and ..authorlaatian
Act of 19" I.SARA.', no fodoral, .tat.
or 10c.1 par.lt I. r.qulr.d for tho
portion of .ny r..o.el or ro..dlal
ectlon conductod ontlrolf on .It.,
whor. lacb ro.odlal action I. .ol.ct.d
.nd carrl.d out in co.pllanc. with th8
-------
TABLE 16
(Cont'd)
AC'I'I--...anc: 8UP1dca8U8 CJ8 8aanurr AlII) UI'8OftIAft8 r8DK8AL A8D ftAft
8&vu:aauu-ri "'. Svu8'-8 cc--,.:c:. :--D ~~ 0" :a(!u-A~!O!! ".~!..U!..,-...!..~
..qul re..nt
lIot
Appliceble
II.
.t.nll.rll. for o...r.tor.
...-. 1'05.01
..
.t..II.rd8 for ova.r. ..11 Oper.tor.
of ....rllou. ...t. r.cil1ti..
...-. Un.08
Cit
CU,
CUi'
Ch'
Cw,
CwU
..curlty .equlr...nt., ..-.
1'05.0ICII' lacorpor.tia, by
r.f.r.nc. .0 cr. IZI..l.
o.n.r.l I..p.ctio. .equlr.-
..at. 1.-' 1'05.011Il'I.)ld),
incorpor.ti., .0 cr. IZ14.15
'.'.088.1 Yr.l.i." ..-.
1'05.01 III'C4'1.' i.cor-
par.tint cr. IZ15.11
.aqulr....t. for IfDlt.bl.,
...ctiw. or I.co.,.tlbl.
W..t.., ..-. 1'05.011Il'14'lf)
lacorpor.tiat .0 cr. IZI..l?
I
Loc.tl0. .t.all.rll., ..-.
1'05.081I1'C.'C"
.r.p.r."." .~II 'r...ntlon
.equlr...nt., ..-. 1'05.01Id'
14'Ih' incorpar.tlat .0 cr.
Zit, subpart C
Applic.ble
I
..I...at
Appropriat.
I
I
][
][
x
][
..tlonal.
....di.l .It.r..ti... .., laclud. the
,.n.r.tion of tr..t..at r.alduala vhich
conatitut. h...rllou. v.at., .nd the
tr.naport off-ait. of cont..inat.d aoil
.ad/or ,roundvat.r for off-.it. tr.at..nt
or di.po..l.
Applic.bl. to .11 contlfUoua 1.nd
and atructur.a g..d for tr.atin,.
or diapoaint of ha..rdoua v.at.a.
1'05.0IC.': R.-' 1'05.011'),
atoring
H.-,
.a..dl.1 .1t.ra.tl..a ..y lnclud.
a.c...tioa of cont..ia.t.1I aoil: .cc..a
control woulll b. nac.aaary to prot.ct
public fro. ..poaur. to haa.rdoua
vaat.a.
....lIlal .It.raltlv.. lnclud. .tora,.
and tr..t..nt of cont..inat.d aoil
or troundw.t.r .nll .ay r.qulr.
inap.ctiona thlt ar. fr.qu.nt .nou,h to
ld.ntify probl..' which .'Y I.ad to
conta.inant r.I..a..
....lIi.l .It.r..tl... Includ. ator.,..
tr.at..at, or dlapo..l of h.a.rdoua
..at. on-.lt.: facility op.r.tlon
r.qulr.. p.rao88.1 tr.lnln, to .naur.
c08pli..c. vlth .pplic.bl. at.nd.rda
.nd .ff.cti.. ...r,.ncy r.apona..
10 lfDlt.bl., r..ctl.. or Inco.p.tibl.
..at.a ld.atlfi.lI.
Loc.tlon atanllarda r.atrlct the aitin,
of tr..t..nt f.clliti.. oa ,.olo,ical
f.ult. .ad floodplaina.
....111.1 .1t.r..tl..a Includ. ator.,.
.all tr..t..nt of conta.ln.t.d aoll
or ,rouadv.t.r: .nll .,y r.quir. .ppro-
prl.t. ..aaur.a to pr...nt .nll r.apond
to .n, unpl.nn.d r.I.... of ha.ardou.
-------
TABLE 16
(Cont'd)
~~nc 8&P1'L1~8 CI8 8UL8YU1'1' AD UP80ft1Aft8 n....u. AD IDft
IIKQUIUIIDrI'S ... souaa co.noL AIID IIA8IIoGDIKft or 1UG8A7J08 AL7DIIA7nU
.equlr...nt
lot
Applicablo
hUI
Contin,oner 'lan, 10-' ltOS.OI
CdlCJICil incorporatia, 40 cr.
264, 'ubpa~t D
CdUI
Oroundwat.~ 'rotoctio., .0-'
1'05.0ICdIC4ICjl incorporatin,
40 cr. 2'4, 'ubpart r
ChI Cloaur. aD. 'oatooCloauro, .0-'
1.05.0ICd)C4)Ckl incor,oratia, 40
cr. 'ubpart O.
Cal rinancial lequiro.onta, .0-' I
l'OS.0ICd)C4)Cl1 incorporatia,
40 cr. 'ubpart .
CaU ~ranafor .f ovaorabi" '0-'
1I05.0ICd)(5)
CaUl 1. lIoaito~iD', '0-' I
nos.o. (4)(l)a
2. .a-' 1105.0ICdIC'lb
CaUU ..apona., I
.0-' l'OS.OICdIC'ICcl
Cahl .ocordkoo,in, aad .oportia" I
.0-' 1'05.0ICdIC71
Cnl Ranifoat lequiro..ata - I
.oportln, 0' Dlacropaacio.,
Re-' 1905.08(d'CI'
Applicabla
I
.olo.ant
Approprlato
I
I
I
I
laUonalo
.0..dia1 altorDati.o. iDC1udo atora,o
aad troat"Dt or coata.laatod aoi1 or
,rouDd.ator; aDd .a, roqulro
a"ropriato ..aauroa to pro.oDt and
roa,oDd to aar un,lannod roloaa. of
ba.ardoaa .aato conatituaDta.
.0..dia1 altornati.oa ..y includo
troat..at aDd rocirculation of
,roundwator. .a.ardoua cODatituonta In
troatod ,rouadwator .a, not o.coed
atato or rodara1 atandarda for
,roundwator protoctlon.
Doai98 aDd porror.anco atandarda
ror r..odiatioD and cloauro.
CODa.Dt docro. ,ro.id.a financial
aaauranc. for c1oauro of alto.
. .
lot a"licab1. ir all oD-aito
ba.ardoua .a.to to bo ro.ovod ,rlor to
clo.uro.
.0..dia1 alt.rDativoa do not includo
an on-ait. aurfaco I.poundaont
laadfi11, or land troat.ant.
7ho Di.iaion .ay roquiro any racllity
to inatal1 appro,riato aonltorln,
a,ato.a, iacludln, air ..I..lona and
,rouad.ator conta.lnatioD; d.a.od
appropriata aftor conaultation .Ith
otbor atat. a,oncioa.
Idontificatlon or appropriate aito
ro..diatioD a1roady undar.ay.
raci1ity .il1 Dot rocoi.a or proca..
oU-dto ...toa.
racilit, .111 not racoi.a or proco.a
-------
TABLE 16
(Cont'd)
M:'I'I""~IfIC .APl'LICA8ta. 08 -.a.nan MID &n'8OftIAft. raau. MID ftU'8
~ roa SCJUaa C08"I'8OL &lID IIUUIODIIDft or 1UCDA7108 ~
aequiu_nt
Bot
Applicabl.
Applicabl.
Z
a.l.vant
Appropriat.
a.Uonale
Cni)
Jublic lotification 'lla,
..-. 1.05,0'Cd,C"
Di.i.(o. .., roquir. tho d...lop..nt
of pu~lic notific.tion plan to iDfor.
tho pQhlic of facility acti.iti...
a...dial .It.r..ti... includ.
contai..ti.in, aDd off-lit.
traDlport of cODta.inat.d loil
,roUlld"at.r.
and/or
CaYiit ~.ch.ical ata.dard. f.r Z
contain.r Rana,._nt, ..-.
1'05.0'Cf'Cl'Ca' iDcotporatin,
to cn aubpart I
CnUit ~.chnical atandard. fot Tankl Z
..-. 1905.0'Cf'Cl'Cb, to cr.
Iullpart J
Cahl ~.ch.ical ata..ar.. fOf X
lurfac. lapounde.nt., 'a-'
1'05.0ICf'Cl,(c, incor,or.tin,
to cpa 2't, .ub,.rt a
Cn' ~.chnical Ita.dard. for Z
.a.t. .il.., ..-,
1'05.0'Cf'Cl,(d, iacorper.tin,
to cpa Subpart L
Cnit ~.chnical Itandard. for Laad X
~r.at..nt, '0-'
1.05.0ICf'Cl,C" iacorpor.tin,
to cpa lubpart R
Cadit ~.chnical ata.dard. for Z
Landfill., ..-,
1'05.01'lf'll,(f, iacor-
poratin, to cpa 2't, Subpart I
Cad1f, Incin.rator Ita.derd., .a-' Z
1905.01(flll,(,1 and ..-,
1'05.01IfIC21(bl
Cnhl Additional ~.cb.ical StaDdard.
a. Tr.at_nt, ..-,
1'05.0.(f'12'la'
b. Incin.rato~ Standard., ..-,
1905.0'lf'12,(b,
c. Dilpolal standard. for
Landfill., R.-, 1'05.01
Cfll2llblClI
....dl'l alt.r..tiv.. iacluda on-lit.
.at.r tr.at..nt iDvolvin, lurfac.
ta.ka.
....dial al'or.ati... do Dot includ.
lurflc. i..ouade..t. of ha.ardoul
.alt..
....di81 alt.rnath'l. includ.
..cavatio. 0' .oil and Itorl,.
in ..It. ~l.. prior to tr.at.ant.
....dial alt.rnlti... do not iaclud.
land tr.at..nt.
....dial alt.rnativ.a do includ.
c.ppi., aDd cl0.in, .it. a. landfill.
....dial Ilt.rnativ.a' includ. on-.it.
10" t...oratura th.r.al .trippin,.
z
....di.l alt.rn.tiv.. includ. on-.it.
tr..t...t.
z
s.. I..iii, abo...
z
....di.l alt.rnativ.. includ.
-------
TABLE 16
(Cont'd)
~CJ8-8NClnc 8U.LlCA8L88 - 88D.89aft A8D UP80ftIAft8 n...u..\88 ftAft
88IQOI1DIIDI'S ~ SOCDC8 C08nIOL A8D IUIIAODD'I' or 1llGaM'108 ALTDIIU'nU
lequiro.ont
.ot
Applicablo
Applicable
4.
Dilpol.l Itandardl for
Land Troatoant, Ra-'
UOS.08 If' CZ lib' CZ'
I
c...,
'itin, la9Qlationl, Ra-'
UOS.OICt'
I
J.
C...i, Rana,o_.t of Spocifie
.a.lrdoul ..Itl., B.-.
l'OS.OI(b' (1'1"
ISA t.s..AIIJ .. tl0.01.
racilitioa .oquirint Gl'oundwator
Dilchar,o 'or.it
I
I
t.
RIA tIS-A.IJ .. tl0.05(.), 'rohibitl
Diachar,o of .a.lrdoa. Con.tituont.
to Groundwator
5.
critoria for 'Ir.itt04 Dilehar,o.
to Groundwator I .. .art: tOO, ISA
US-AI U
I.
.. .art tOO. 'actioa WI tl0.0'.
Groundwatar .tand.l'dl, incor-
perltin, br rofaroaco .. 'Irt J02.
Ka.iau. cont..inlat: Lo.ol. CReL'"
and 'ut,oltad 80 Ad.orao la.pon'l
Lo..l. (.8A8L"'1
b.
.oaltb-bllod Gro.ndwatar .rotaction
.tandardl, .. 410.05(b,..
c.
.. 410.10, Groundwatar not to be
altorld in lueb a .a, a. to randar it
unluitablo for dr1..int wator lup,ly.
6.
ISA US-A.U WI 410.05(", Grounchatar
not to ba dotrad.d in aucb a wa, to eau.a
yiolatioD of .urtaea .ator .tandard.
within or adjae'Dt to proparty.
.olo.ant
Approprhto
laUonalo
Lanel traat..nt Dot boing conaldarad.
racility will Dot rocoi.o wa.to fro.
off-.ito .oarcil.
'o..dial altaraati.al do not includa
racycling, rocla.ation or ra.ourca
roco.ary.
I
Pura.a.t to aaction 121(0'(1' of tha
luporf.ad anoadaant and 'oauthorilation
Act of 1'" C.SAtA.', no fadaral, .tata
or local por.it ia raquirod for tha
portio. of an, ra.oval or ra.adial
action conduct.d antiroly onait., wh.r.
aucb r...dial action ia .olact.d and
carriod out in co.plianc. with the
provi.ionl of aaction 121 of SARA.
....dial'a1t.rnati.o. ineludo di.ehar,.
of tr.at.d groundwat.r to groundwatar.
I
....dial alt.raati... includ. diaehar,.
of tr.at.d groundwatar to ,roundwat.r.
I
I...dial alt.rnati... includ. di.eh.r,a
of tr.at.d ,roundwat.r to groundwat.r.
I
....dial alt.raati... includa di.ehar"
of tr.atod groundwat.r to ,roundwatar.
I
Incorporatol .tat. and fadaral
.ini... Itandard. for drinking wat.r
.."Uo. .
Conta.inant .igrating fro. ait. to
.aqua.lt.tt 'ond.
-------
TABLE 16
(Cant'd)
~""""CJnc Wun.JC&8UW OJI 8aD.89aft &lID U..,nXAft8 P8IIDAL UD ftAft
~ IP'08 sooaa COIft1IOL MD lIADOaDI' or 1dGaM'108 ALTDIIATIVU
..QUi re"Dt
Rot
Applicable
Applicable
'.l.vant
Appropdate
.aUonale
a.
8urlac. .at.r .teaderd. lor Cia.. A
.at.r., asA .'S-A
z
s.. lib).
b.
8arlac. .at.r .taDderd. lor Cia.. I
.at.r., 8SA .'S-A
I
rur.aaDt to tt. .. wat.r 'ollution
Control Act, asA cb. .'S-A. ..quavk.tt
.ond and all 01 it. tributari.. in
Con "a, ar. cla..iU.d al Ch.. I
.ur.ac. "at.r..
c. 8arlac. ..t.r .taD.ar.. for Cla.. C Z
"at.r., asA US-A
.. 8arf.c. ..t.r .tander.. for cl... D Z
"at.r., asA US-A
.. ~i.al "at.r. a... for ."i..in" or X
for ,ro"inl and takinl of Ih.llfi.h,
asA .U-A
s.. 'Ib).
s.. lib).
80 tidal "at.r. adjac.nt to lit..
7.
Wat.r Qualit, .taDder.. .i.b Lif.,
aSA .'S-A W. .art .'7
I
Conta.inIDt. fro. .it. .i9ratin9 to
.udac. "at.r..
. .
..
WaUr QuaUt, .tander" AnU-Do9redaUon
'olicy, .SA .'S-A W. 'art .'9
I
conta.inanta fro. .it. .i9ratin, to
lurfac. "at.n.
9.
8taDder.. for 'ro-~r..t..nt 01 ...t..
di.cbarl.. to tublicl, Own.. ~r.at..nt
Work. C~), asA .'S-A W. .art 90.
z
.....ial alt.rnativ.. includ. tr.at..nt
and di.cbar9. of conta.inlt.d ,round-
"ater to rot'W.
10. ... Adai.. Code, asA .n-All
Wt Cha,tar SOD. ..r.it .roc.dura lor
W.tlanda ,roj.ctl
z
Work "ithin tho v.tland ar.a on .it.
.1' r..ult and.r r...dial Ilt.rnltiv.l.
rur.uant to s.ction 1211.)111 of the
lup.rfued ...n".nt and ..authori.ation
Act of 19" 18SAaA81. no f.d.rll, atat.
or local ,.r.it il r.quir.d for the
portion of Iny r.80val or r...di.l
action conduct.d .ntir.ly on-ait.,
vh.ro auch r...dial let ion i. ..I.ct.d
and carri.d out in co.,lilnc. vith the
provi.ion. of s.ction 121 of SARA.
11. ... Adai.. coda, as. ."-All Wt. Ch.,tor '00,
Crit.ria and Condition. fot ,ro,...ll to
dr..,. or fill ".tl.nd.
I
.ro,.... r...dill Ilt.rnati... .ay
-------
TABLE 16
(Cant'd)
~--.nuPlc -UPLICA8L8- (8 -........ AD Ul'8DftIAft- nI88&Io AD IBft
88QOJaaDTS ro. souaC8 C08"I'IIOL AIm IlUlAGDIDft or III08A7I08 ~
..qUir._nt
Bot
Applicabl.
12. cra 'a~t. 1910, 1921 and 1,0t: iDcorporat.d
by .. Adai.. Coda 88-' 1'05.0ICd)Cl)Cc),
wbicb pro.Id.. tbat b..a~dou. .a.t. facility
vork.~. .ball .ot be ..po..d to cb..Ical.
I. .Iolatio. of OSBA .tandardl
U. Ca)
UA US-CII,ZIY - AdDi.. Cod.
aJ~ 101.11, a8fUi~in, air ..I..IoD
p.r.it. fO~ Iny d..Ic. wblcb
proc..I.. to.Ic ..t.rial. o~ ..y
contrlbut. to pollution of air:
Z
Cb)
UA US-CII,ZIY - AclDi.. Cod.
Air lOI.02(f), p.~.lt. requirlD,
air ..il.loD. fo~ .p.clfi.d
incin.~ator..
Z
U. n Adalin. Cod. aJ~ 101.01 (UA U!-C:I,
ZI'I) IDd Ah 101.09 (U. U5-C:U
inco~ratin, by ~.f.~..c. tb. DO.t
.trln,..t of tb. fol10.i.,:
(1)
... 'oa~c' ..~foraa.c. .ta.dard.
(to cn 10),
(2)
.atio.al ..i..i.. .ta.dard. for
...ardo.. aJ~ 'ollut.nt.
(to cpa 'a~t Ill',
... 8a8P.bi~. .tat. lepl....tatio.
'la. ..i..lon li.it.
(I)
15. UA U!-Clt n Adai.. Cod. CIIapter Air
100, aJr 101, 'd..~ aDd '.coadary
ADbi.nt Ai~ QUality .tandard.
11. UA 12!-CII,ZI n Adai.. Cod. CIIlpt.r
Ai~ '00, ~..tin, aad Ro.i~orin, .roc.dur..
Applicable
Z
a.l..aat
Appropriat.
Z
Z
z
aational.
a...dial alt.raati... includ. ba.ardou.
wa.t. tr.at..nt faciliti.. on-.it..
..r.ua.t to s.ctio. 121(.)(1) of the
Sup.rfund A88DcID..t and ..authori.ation
Act of 1'" C.SAaA8), ao f.d.ral,
.tat. o~ local per.it i. raquirad for
tb. porti.a of .ay r.DOy.l or r..adial
actioa coaduct.d oa-.it., wb.r. .uch
r...dial action i. ..l.ct.d and c.rri.d
out la coaplianc. with the proYl.iona
of S.ctlon 121 of SARA.
S.. Uta) abo...
a....dbl 'aharnati".. includ. on-alt.
low t....ratur. tb.r.al .trippin,
proc.dur.. .ubj.ct to .tat. air
..it alo. li.I ta.
....di.l alt.rnati".. Includ. on-lit.
10. t..,.ratur. tbar.al .trippin,
proc.dur.. .ubj.ct to .tat. air
..I..loa U.it..
a...di.l .It.rn.ti... includ. on-lita
low t..,.r.tur. tb.r.al .trippin,
proc.dur.. ,ubj.ct to .t.t. .ir
-------
TABLE 16
(Cont'd)
~-.....a:Inc 8un.1CA8L88 - 8~ .. UI'8OftXAft8 ra88U. MID ftAft
~~ ~ J!OO!!C!! ~'= ~ ~~ Q~ IUGaAYI08 AL7U8&7JftS
lequha"Dt
17. UA US-Ca',1E1 .. Adai.. Coda Chapter
Air tOO, owear or Operator Obli,ation.
lot
AppUc.ble
Applicable
'alavant
Appropriah
..Uonala
IE
'a88dill altarDati.a. includ. OD-.ita
lov ta.,.ratura tbar.al .trippin,
procalura. .ubjact to .tata air
a.tado. U.it..
18. UA US-Ca., UA US-Ca',n .. ..iD.
Coda Chaptar Air 1200, .art 1201,
IDciaaratora
IE
....dial 8ltarnativa. includa on-.it.
lov t..,.ratara th.r.al .trippin,
procadur.. .ubjact to .tat. air
a.talioa Uait..
U. UA US-Ca., UA US-Ca',n .. ..ia.
Coda Chaptar Air 1200, .art 120.,
Volatila or,aaic Coapouad.
IE
....dial altaraati.a. iDcluda on-.ita
lov ta.,.ratara tb.r.al .trippin,
procodura. .ubjact to .t.t. .ir
..i..ioa U.itl.
20. .. Dapt. .f 18f.t, aul.. for Yraa.port of
la.ardoa. Ratarial., .. "ia. Coda,
lat. Chap. COO
21. ... Cb. It'-A, .. Oil Ipilla,. Itatata,
..tabliabIDI .taad8rd. for tba oparatlon
of patrolaua facillti.., aad probibitin,
dlacbar,a of patrolaua iato .arfaca or
,roaadvat.r or aD, land araa "ara
patrolaa. .., ~atar public vatar.
IE
....dial altornati.a. includ. off-.ito
tran.port aad dlapo.al of ha.ardou.
"..ta.
IE
10 patrolaua product. oa .it..
-------
APPENDIX C
-------
KEARSARGE METALLURGICAL CORPORATION SITE
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
Preface. . . . . . . . . . . . . . . . .
. . . ..
. . . . . .
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN . . . . . . . . . .
~
I!.
S!TE ~!STORY AND BACKGROUND
. . . .
. . .
. . . .
. . .
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS. . . . . . .
A.
Summary of Resident Comments. . . . . . . . . . .
1. Concerns Regarding EPA and State Response to
site Cleanup. . . . . . . . . . . . . . . . .
Concerns Regarding Remedial Alternative. . .
Concerns Regarding Health Risks. . . . . . .
2.
3.
B.
Summary of Potentially Responsible Parties Comments
1. Evaluation of the ~o-Action Alternative
. 2. Evaluation of Soil Recycling as a Source
Control Action. . . . . . . . . . . . . . .
AT'I'ACHMENT A -
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE KEARSARGE METALLURGICAL CORPORATION SITE
AT'I'ACHMENT B -
POTENTIALLY RESPONSIBLE PARTY COMMENTS
AT'I'ACHMENT C -
TRANSCRIPT OF THE JULY 24, 1990 INFORMAL
PUBLIC HEARING
1
2
3
5
6
6
7
8
12
12
-------
KEARSARGE METALLURGICAL CORPORATION SITE
Preface
On June 29, 1990, the u.s. Environmental Protection Agency (EPA)
opened a 30 day public comment period to provide an opportunity
for interested parties to comment on the Remedial Investigation
(RI), Endangerment Assessment, Feasibility study (FS), and the
Proposed Plan prepared for the Kearsarge Metallurgical
Corporation (KMC) Superfund site (the Site) in Conway, New
Hampshire. On July 19, 1990, EPA announced a 30 day extension of
the public comment period in response to a request from an
interested party, bringing the closing date to August 27, 1990.
EPA made a preliminary recommendation of its preferred
alternative for site remediation in the Proposed Plan issued on
,June 21, 1990.
~
The purpose of this Responsiveness Summary is to document EPA's
responses to comments and questions raised during the public
comment period. EPA considered all of the comments received
during the public comment period and has summarized them in this
document before selecting a final remedial alternative to address
contamination at the site.
This Responsiveness Summary is organized into the following
sections:
I.
Overview of Remedial Alternatives Considered in the
Feasibility Study and Proposed Plan This section lists
the remedial alternatives evaluated in the FS and Proposed
Plan, including EPA's preliminary recommendation of a
preferred alternative.
II.
site History and Backqround - This section provides a brief
Site history.
III. Summary of Comments Received Durinq the Public Comment
Period and EPA Responses to These Comments - This section
summarizes and provides EPA's responses to comments received
from residents and other interested parties during the
public comment period. Additionally, comments receiyed from
the potentially responsible parties (PRPs) are summarized
and EPA's responses to the comments are provided.
Attachment A - List of community relations activities that
EPA and New Hampshire Department of Environmental Services
(DES) has conducted to date on the site.
-------
2
Attachment C - Transcript of the July 24, 1990 informal
public hearing on the Site, held at the Kennett High School
in Conway, New Hampshire.
Z.
OVERVZEW OF REMEDZAL ALTERNATZVES CONSZDERED ZN THE
FEASZBZLZTY STUDY AND PROPOSED PLAN
()
Using the information gathered during the Remedial Investigation
(RI) (an investigation of the nature and extent of both on-site
am,i uii-s.i.L~ l;ontamination) and the Endangerment Assessment (an
assessment of the potential risks to human health and the
environment associated with site contamination), EPA identified
several cleanup objectives for the site.
The, primary cleanup objective is to reduce the risks to public
hea.lth and the environment posed by exposure to the sources of
contamination on-site or to contamination that may potentially
mig'rate off-site. Cleanup goals for ground water and soils are
set. at levels that EPA considers to be protective of public
hea.lth and the environment.
Aft:er identifying the cleanup objectives, EPA developed and
evalluated potential cleanup alternatives, called remedial
alternatives. The Feasibility study (FS) describes the remedial
alt:ernatives co~sidered to address contamination at the site,
inc:luding the septic system, the waste piles, and the
contaminated ground water. The FS also describes the criteria
EP~. used to narrow the range of alternatives to five potential
Source Control (SC) remedial alternatives and six potential
Management of Migration (MM) remedial alternatives.
EPJ~'s preliminary recommendation of a preferred alternative to
address site contamination involves excavation and disposal of
two waste piles and the leaching field soils, the extraction and
trE~atment of contaminated ground water, and the removal and
incineration of the septic tank and contents.
RE!!EDZAL ALTERNATZVES CONSZDERED ZN THE FEASZBZLZTY STUDY
ThE~ remedial alternatives considered for Source Control and
Management of Migration by EPA are listed below. The June 1990
Proposed Plan should be consulted for a detailed explanation of
thE~se remedial alternatives as well as EPA I S preferred
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3
ALTERNATIVES TO ADDRESS SOURCE CONTROL
Alternative SC-l:
Alternative SC-3:
Alternative SC-5:
Alternative SC-6:
Alternative SC-13:
No Action
Off-Site Solid Waste Landfill and On-site Low
Temperature Thermal Stripping
Off-Site Solid Waste Landfill and Off-site
Incineration
Off-Site Solid~aste Landfill and Off-Site
Hazardous Waste Landfill
ALTERNATIVES TO ADDRESS GROUND WATER CONTAMINATION
Off-site Hazardous Waste Landfill
Alternative MM-l: No Action
Alternative MM-2: Ground Water Monitoring Program
Alternative MM-3: Ground Water Extraction, On-Site Treatment,
and On-site Recharge
Alternative MM-4: Ground Water Extraction, On-site Treatment,
and Discharge to Surface Water
Alternative MM-5: Ground Water Extraction, On-Site Treatment,
and Discharge to POTW
Alternative MM-6: Ground Water Extraction, On-Site Treatment,
Partial On-Site Recharge and Partial
Discharge to POTW
II.
SITE HISTORY AND BACKGROUND
The Site is comprised of two lots, lots 7 and 8, as depicted on
Map 27 at the Conway Tax Assessor's Office in Conway, New
Hampshire. Lot 7 covers five acres and consists of forested
wetland. The current owner of lot 7 is Carroll Reed, Inc.
through a land trust. The only structures on lot 7 are a north-
south oriented drainage pipe with four open-bottomed catch basins
and the larger of two separate waste piles. Lot 8 consists of
approximately four acres and contains the two buildings which
belong to KMC, the septic tank and leaching field, the smaller of
the two waste piles, and a small portion of the larger waste
pile. The Site is bounded by Pequawket Pond to the south, by
lots owned by New England Embroidery on the west, Conway Supply
Company on the east, Mill Street and Carroll Industries on the
northwest, and by another lot owned by Carroll Reed, Inc. on the
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New England ~
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- . Solid Waste Pile
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. . Forested Wetland
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Metallurgical
Kearsarge
-------
.
5
During the period 1964 through 1982 the area of the present day
Site was operated as a foundry by KMC. This foundry produced
precision stainless steel castings. The castings were produced
by the injection of molten steel into ceramic molds, otherwise
known as the investment, or lost wax method. KMC used 1,1,1
Trichloroethane (TCA) as a solvent in the wax pattern process.
The application of an unknown amount of caustic soda,
hydrofluoric acid, chlorinated solvents, and flammable liquids to
both the ground surface and the septic system occurred in the
late 1970's. The waste piles, which are located on both the
Carroll Reed and KMC properties, originated prior to 1970, based
on aerial photographs of the Site.
The New Hampshire Bureau of Hazardous Waste Management (NHBHWM)
issued a Notice of Violation and Order of Abatement to KMC and
its former executives to conduct a hydrologic study of the Site
in October 1982. KMC took no action to conduct such a study, and
the State began a hydrologic investigation to characterize the
Site. In December of 1982 monitoring wells, installed by NHBHWM
and the New Hampshire Highway Department, showed significant
levels of chlorinated solvents also known as Volatile Organic
Compounds (VOCs) in the ground water. In May 1983 NHBSWM ordered
KMC and its officers to remove the waste piles at the Site;
however, no action was carried out by KMC to remove the piles.
Further investigations resulted in the Site being added, in
September 1984, to the National Priorities List (NPL) of sites to
be cleaned up. No remedial measures have been conducted at the
Site. The Site has remained unoccupied since its abandonment by
KMC in 1982.
A Remedial Investigation (RI) was performed to define the nature
and extent of contamination at the site. Field activities for
the RI included the collection and analysis of samples of ground
water, soil, sediment, surface water, and waste pile material.
The results of these analyses identified contaminants such as
volatile organic compounds (VOCs) and metals in ground water, the
waste piles, the septic tank, and the leach field.
Using data collected during the RI, EPA developed a FS that
included the initial screening of the source control (SC)
remedial alternatives and the management of migration (MM)
remedial alternatives.
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS
This Responsiveness Summary summarizes the comments received
during the public comment period held from June 28, 1990 to
August 27, 1990. One set of written comments was received from a
PRP. In addition, two concerned citizens made oral comments at
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6
cOD~ents are summarized below. The complete text of PRP comments
is included as Attachment B. A copy of the transcript from the
in1:ormal public hearing is included as Attachment C of this
doc:ument. The Administrative Record containing the documents and
reports upon which EPA bases its remedial action decisions is
avalilable at the Conway Public Library, Main Street, Conway, New
Hampshire and at the EPA Records Center, 90 Canal street, 1st
F1c1or, Boston, Massachusetts.
A.
g~~~! o~ Resident and citizen
Group Comments
Con~ents from residents and concerned citizens' groups are
sun~arized below. The comments are organized into the following
cat.egories:
1. Concerns Regarding EPA and state Response to site
Cleanup
2. Concerns Regarding Remedial Alternative
3. Concerns Regarding Health Risks
1.
Concerns Regarding EPA and state Response to site Cleanup
Comment a: Mr. Curt Lunt, Conway Town Manager, expressed
the concern that implementation of the cleanup plan was
being stalled by the search for potentially responsible
parties.
EPA Response:
EPA recognizes public frustration with the lengthy Superfund
process; however, EPA and the State are required to conduct
the investigation of the Kearsarge Metallurgical Corporation
site in accordance with the Superfund law (CERCLA) and with
the regulations and guidance documents promulgated under
that law. The investigation and cleanup process is complex
and lengthy. This ensures thoroughness in addressing site
contamination. EPA evaluates all Superfund sites during
various investigatory stages to ensure that no releases
occur which could exacerbate any potential public health or
environmental problems. Should such a release occur, or if
one is likely to occur, EPA can take immediate action under
its Emergency Removal Program. It may be further noted that
the investigation has not been impeded by the search for
Potentially Responsible Parties (PRPs) and that such a
search is conducted independently of and concurrently with
the actual site investigation.
Comment b: Mr. Lunt also was concerned about the
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7
property at the Site. Mr. Lunt stated that Carroll Reed is
a good employer whose property may be adversely affected by
operations at the Site.
EPA Response:
Under the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, 42 U.S.C. Section
9601, et~. (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986, Congress defined
the categories of persons who 'may be liable for cleanup
costs, and it also established certain defenses. See
Section 107 of CERCLA. These laws apply to all persons.
Concerns Regarding Remedial Alternative
2.
Comment a: Mr. Joseph Sullivan, a Town resident,
commented that EPA had not examined all possible remedial
alternatives. Mr. Sullivan stated that the threat to the
ground water could be cut by relocating Town wells farther
from the Site, capping the Site, and possibly paving the
entire lot. Mr. Sullivan also suggested driving pilings
around the entire property to restrict ground water
migration from beneath the Site.
EPA Response:
The proposed management of migration alternative is
consistent with the preference expressed in the CERCLA
statute for remedies which employ treatment as their
principal element to reduce the volume, toxicity, or
mobility of hazardous substances at the Site. Containment
of contaminated ground water would not only fail this
criteria but presents additional implementation problems
which are presented below.
Municipal water supply wells are located in an area of water
bearing strata. The Conway wells are located in the Saco
River Valley in an area of highly permeable deposits. This
location is ideal for water production, therefore finding
another site that provides the quality and quantity of water
would be costly if not technically unfeasible. If another
source could be found, the piping costs to connect back to
the system would be substantial. The threat to current
water supplies is best addressed by removal of contaminants
from the system by implementing EPA's selected remedy. This
is the most cost effective solution. There are three source
areas on the site that could release contaminants to the
ground water: the septic tank, the septic system leach
field, and possible buried drums containing hazardous
materials. Paving the site would not prevent the
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8
I>
the ground water. Sheet piles do not restrict ground water
movement due to leakage. EPA evaluated the use of vertical
barriers as part of the FS. vertical barriers to restrict
ground water migration must be keyed into an impermeable
layer at their base. The depth of the bedrock at the site
would make the use of vertical barriers very difficult to
implement and of limited effectiveness. Therefore, vertical
barriers were eliminated from further consideration.
=c:m~nt b: Mr. Sullivan stated that he would like to see
other alternatives developed ~o address the potential
threats of the site.
EPA Response:
EPA conducted a full evaluation of possible alternatives to
mitigate the contamination problem at the KMC site. This
process consists of identifying and evaluating available
technologies, establishing alternatives with appropriate
technologies and evaluating and screening of these
alternatives. Then a full detailed evaluation is conducted
on those remaining alternatives. EPA and DES developed 13
Source Control alternatives and 8 Management of Migration
alternatives for detailed evaluation. Of these, five Source
Control and six Management of Migration alternatives were
retained for further evaluation. The Feasibility Study for
KMC, June 1990, is available in the Conway Public Library
and EPA records center for those interested in reviewing the
full Feasibility Study process.
Concerns Regarding Health Risks
3.
Comment a: Mr. Sullivan stated that the nature of the
threat to residents' health and the associated hazards are
not known, and that he would like EPA to better define the
problem.
EPA Response:
The Endangerment Assessment conducted in the Remedial
Investigation quantifies the potential threat to human
health based on the combination of two factors: exposure and
toxicity of the contaminants at the site. EPA examined the
possible health threats from contaminated ground water,
surface water and sediments of Pequawket Pond, the soils
around the leach field, and the waste piles. Under current
conditions, the health threat to residents from the Site is
minimal.
However, the Endangerment Assessment also evaluates the
potential future threat to human health. This evaluation
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9
individuals could come into contact with the contaminants.
Based on this evaluation, drinking the ground water
underneath the site and ingesting the soil in the waste
piles could pose a risk that EPA considers unacceptable.
EPA also identified a significant risk associated with the
waste piles. If the waste pile is stripped of its
vegetative cover by either natural or man-made events, the
possibility exists that a significant amount of the waste
pile material could be entrained by the wind. This material
contains particulate material that has both carcinogenic and
toxic, non-carcinogenic effeces when inhaled. The potential
threats from the level of contaminants found in the
sediments and surface water of Pequawket Pond were minimal.
The risks associated with the Site are quantified in section
6 of the RI.
G
Comment b: Mr. Sullivan stated that he would like to
know the nature of l,l,l-Trichloroethane, i.e., where it
comes from, the type of compound it is, if it breaks down
into other constituents, if it has other names, and if there
are any other health hazards associated with it.
EPA Response:
l,l,l-Trichloroethane (TCA), also known as methyl
chloroform, is a colorless, man-made liquid solvent that has
a sweet, sharp odor. It is a common industrial chemical
that is widely used for cleaning of electrical equipment,
motors, electronic components, photographic film, circuit
boards, and various metal and plastic parts during
manufacturing. It is found in home-use products such as
spot removers, glues, and aerosol sprays. In the
environment, it does not adhere well to soils with low
organic content and can be carried by water through the soil
into ground water. Exposure to TCA can cause dizziness,
drowsiness, lack of coordination, and irregular heartbeat.
Extremely high concentrations can cause a blood pressure
drop, unconsciousness and death due to heart failure.
Animal studies have shown that mild liver damage results
from long-term exposure. The scientific data is
inconclusive regarding the carcinogenic potential of TCA in
humans. The natural degradation products of TCA include
. vinyl chloride, which is considered by the EPA to be a
potent liver and lung carcinogen. Concentrations of TCA in
ground water may be naturally reduced by dilution,
attenuation, and volatilization. More detailed
toxicological information on TCA can be found in Appendix C
of the Remedial Investigation.
Chlorinated organic solvents such as TCA have been shown to
be subject to microbial degradation. Under naturally
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10
o
water systems can transform environmental contaminants. In
cases of simple straight chain hydrocarbons, the compounds
may be mineralized to carbon dioxide and water under aerobic
conditions. In the case of chlorinated compounds, more
complex degradation mechanisms are required. Degradation of
chlorinated hydrocarbons results primarily from reductive
dehalogenation. Figure 2 on Page 11 illustrates the
degradation products for the chlorinated ethane and ethenes.
Although natural degradation may be occurring to a limited
extent at the KMC site, the conditions are not optimal for
degradation. The presence of wood chips and a saw dust
layer under the waste pile in an anoxic environment may
serve to provide a source of methane for methantrophs to act
on TCA, however, much of the contaminant plume extends into
the wetland area where soils at that depth have lower levels
of organic matter as is necessary for methane generation.
The environmental conditions in these areas may not support
significant rates of TCA degradation. Furthermore, the
natural degradation products include more toxic and mobile
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. .
. .
I~ i. 1 - TCA I
C 11.1 - DCA I
~ I I , I - DeE I
t
TC~
I PCE I
.~
c 8< t 1,2;... DeE
~I CHLOROMETHANQ
SOURCE:
Leverett & Dragun, 1984.
Oragun, 1989.
KMC SITE
RIfFS
- --~-
fIGURE 2
DEGRADATION PATHWAYS FOR
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12
B.
Summary of Potentially Responsible Party's Comments
This section presents EPA's response to comments received from
EnviroBusiness Inc. (EBI) on behalf of Carroll Reed Inc., a
pot.entially responsible party. The responses address each of the
con~ents in turn from the narrative. Some of the comments are
verbatim, while others are paraphrased from a number of arguments
presented.
1.
~~alu~~i~~ of the No-Action Alternative
Comment a: Based upon a review and analysis of the RI
and FS and an earlier Draft Remedial Investigation, EBI
concludes that the SC-l Alternative (No-Action) is the most
appropriate response action for the waste piles at the Site.
EPA Response:
EPA evaluates the no-action alternative based on the
assumption that there will be no remedial action at the
site. It does not mean that the site will remain in its
current state. EPA assumes that the land use in the future
will be different. Therefore, the possible exposure routes
and the potential future risks differ. In the case of KMC,
EPA assumes a residential scenario in the future. This
suggests that it is possible for a home to be built on or
next to the waste piles and for the contaminated ground
water to the primary source of drinking water. Although the
current human health risks at the site are minimal, there
are potential risks from the site due to plausible changes
in land use.
EPA determined that the no-action source control alternative
(SC-1) for the waste pile is not appropriate since it would
not be protective of public health and the environment and
would not comply with applicable or relevant and appropriate
requirements (ARARs). The current potential risks from the
ground water at this site exceed EPA's established risk
ran~e of one in ten thousand (10.') to one in a million
(10.) for carcinogenic contaminants and a hazard index
greater than one (1) for contaminants with noncarcinogenic
effects. For ground water the potential future risk
estimates of excess lifetime cancer risk range from seven
(7) cancer cases in 10,000 to 1.5 cancer cases in 100. For
the chemicals with noncarcinogenic effects the total hazard
indices for ground water are equal to or greater than one
(1) which indicates that the concentrations of contaminants
could result in adverse effects. Substantial health risks
are also associated with the inhalation of waste pile
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13
With regard to non-compliance with ARARs, see response to
comment "Compliance with ARARs" on Page 16.
Comment b: EBI finds CDM's contention that the waste
pile under current conditions is an uncontrolled potential
source of contamination inconsistent with the information
presented in the RI.
EPA Response:
EPA contends that the waste pile under current conditions is
an uncontrolled potential source of contamination.
The erosion of fine particulates from the waste pile was
identified in the remedial investigation to be of minor
concern under current conditions. However, under the future
no-action scenario the potential for erosion of the waste
pile under a severe storm or flooding event is a cause for
concern. Section 7.0 of the Remedial Investigation
(pg. 7-9) states, "The major risk posed is that of the solid
waste pile within the lOa-year flood plain and encroaching
on the wetlands. Erosion of this waste pile during major
flooding events could pose a potentially significant risk to
the Pequawket Pond system."
The EP toxicity test is used to determine if a waste
exhibits toxic characteristics for the purpose of
classification. The EPA uses Endangerment Assessment
techniques to evaluate potential risks posed by
contaminants. Passing the EP toxicity test does not signify
that no risk exists.
Under the current situation the waste pile is not a major
source of ground water contamination. However future
conditions could lead to the release of contaminants from
buried drums containing hazardous materials, such as spent
TCA.
Sbort-Term Effectiveness:
Comment: Section 4.2.2 (page 4-2) of the FS addresses
short-term effectiveness of the SC-l Alternative. Regarding
the waste pile, the FS states:
"Therefore, the no-action alternative would provide only
temporary mitigation of inhalation of silica sands from the
waste pile."
This statement appears to be inconsistent with the
information presented in Section 5.3.1 (page 5-6) of the RI
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14
Additional information demonstrating the negligible short-
term risks posed by the waste pile is presented in Section
6.3.2 (page 6-25) of the RI.
section 4.2.2 (page 4-2) of the FS states:
"the no-action alternative would not be effective in
preventing the potential release of contaminants which may
be present in and under the waste pile (e.g., buried
~!"1..!!!Ig) - "
However, in the RI, the findings discount this pathway of
contaminant migration.
EPA Response:
The conclusion reached by EBI does not anticipate the
presence of intact barrels of hazardous wastes or other such
source materials. However, EPA believes that given the
history of waste handling practices by KMC, the presence of
such wastes is a very real possibility and the RI does not
discount that theory. Should only a few barrels or
containers of hazardous wastes exist within the pile, they
could corrode and present a potential for a release to the
environment. The existence of the organic layer beneath
the waste pile could somewhat mitigate the release of
hazardous materials assuming it is a continuous layer;
however, the RI does not demonstrate that this is the case.
The site contains other source areas which threaten to
contribute to ground water contamination, such as the septic
tank and leach fields. The implementation of SC-l will not
address the contaminants in these areas.
LOl1lg-Term Effectiveness
Comment: The no-action, long-term effectiveness conclusions
(with respect to the waste pile) are contradictory to the
information presented in the RI.
section 5.3.1 (page 5-6) of the RI, states:
"In this setting little wind erosion would be expected to
occur and transport via blowing sands is not considered a
pathway of concern under the current situation."
In Section 6.3.2 (page 6-25) of the RI, further states:
"exposure to silica and metals from fugitive dust
originating from the waste pile are considered negligible
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15
Section 5.3.1 of the RI, states that only 25 percent of the
surface area of the waste pile is exposed. Given a no-
action alternative, EBI maintains that this percentage will
decrease as overgrowth continues to spread over the waste
pile. .
Section 6.4.2 (page 6-33) of the RI states:
"Potential risks associated with inadvertent waste pile soil
ingestion are shown in Table 6-24 for the average and
maximum cases. Since no contaminants of concern in the soil
are carcinogenic by the oral route of exposure, there is no
excess lifetime cancer risk. The HI for the average case is
0.06 and the maximum case it is 0.08. Since both HI's are
less than one, no chronic adverse health effects are
expected due to exposure to waste pile soils under the
current scenario." .
Given the conclusions demonstrating no cancer and non-
cancer health risks, and demonstrating negligible risks
associated with inhalation of fugitive dusts emissions, the
statement in the FS that no-action alternative "would not
provide long-term effectiveness" is unsubstantiated.
EPA Resporse:
The excerpts from Section 5.3.1 and Section 6.3.2 of the RI
provide discussion of current conditions and not future
conditions. It is not expected that overgrowth will
continue on the waste pile as the only portions of the waste
pile not overgrown are those where the silica sands are at
the surface. Therefore these areas are continuously exposed
and subject to erosion due to wind which could result in
more respirable particles subject to entrainment by wind.
The excerpt from Section 6.4.2 of the RI provides a
discussion of the current scenario. Under the current
scenario a fence exists surrounding the waste pile. Over
the long-term this fence may deteriorate or become damaged
by trespassers and would not effectively prevent exposure to
the silica sands in the waste pile. This increase in
exposure to the waste pile by trespassers would increase the
Hazard Index (HI) for inadvertent waste pile soil ingestion.
The HI form exposure to the waste pile under the future
scenario for the maximum case for chromium is 1.4. The
future scenario assumes unrestricted access to the waste
pile. Under the no-action alternative when evaluating long-
term effectiveness, it is assumed that remaining risks from
the waste pile would consist of a HI of up to 1.4.
Therefore, the no-action alternative would not provide long-
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16
RecSuction of Toxicity, Mobility, and Volume Through Treatment
Comment:
The RI states:
"Under the no-action alternative, there would be no
treatment of source materials and no reduction of
contaminant toxicity, mobility, or volume from that
currently exists."
which
However, based upon the RI, it cannot be determined what the
baseline toxicity, mobility and volume criteria are. EP
toxicity tests revealed that all leachate analytes were
below regulatory limits. section 5.6 (page 5-14) of the RI,
states: "source materials may be present in discrete
pockets", however no quantitative data was presented to
substantiate this claim.
EPA Response:
The EP toxicity tests at the site do not include VOCs. The
EP toxicity test is used to determine if a waste exhibits
toxic characteristics for the purpose of classification.
The EPA uses Endangerment Assessment techniques to evaluate
potential risks posed by contaminants. Passing EP toxicity
does not signify that no risk exists to human health and the
environment.
Data exists to suggest that source materials may be present
in the waste pile. Considering the disposal practices of
the KMC facility and the fact that there are believed to be
several hundred drums still remaining in the pile, there is
a strong and reasonable probability that buried drums
containing hazardous materials remain buried in the waste
pile.
COJllpliance with ARARs
Comment: It is unclear which ARARs the no-action
alternative does not comply with.
The RI discounts erosion as a pathway or contamination (see
section 5.3.2 on page 5-7 of the RI). Therefore, the
assertion that the "no-action alternative would not comply
with Executive Order 11990 (wetlands)", is inconsistent with
the RI findings.
EPA Response:
The implementation of the SC-l will result in the violation
of several applicable or relevant and appropriate Federal
and State requirements. EBI's comment ignores the source
-------
17
threat associated with the waste piles are the buried drums.
These drums have the potential to eventually corrode and
discharge their contents to the environment, This discharge
could violate several state of New Hampshire. regulations
regarding the protection of ground water of .the state,
specifically N.H. Admin. Code Parts 410.05, 410.09, and
410.10. This discharge would also violate 33 USC 1251, the
Clean Water Act. Although the waste piles have been stable,
a single event such as a flood could alter that situation.
Erosion would violate the state Wetlands Act, Section 404 of
the Clean Water Act and Executive Order 11990 (the
Protection of Wetlands). The existence of this pile
violates State Solid Waste Management rules He-P Ch. 1901.
Contaminants in the septic tank could further contaminate
the ground water, resulting in violation of the previously
mentioned Federal and State ground water statutes.
.0
Overall Protection of Human Health and the Environment
Comment: In the case of the waste pile, the RI does not
present any evidence suggesting the waste pile poses a risk
to human health. Although the RI demonstrates potential
adverse chronic health effects under the future scenario
(i.e., residential use), EBI concludes that the RI's
findings are invalid because the future risk calculations
were based upon the assumption that chromium in the waste
piles is present in the hexavalent form. EBI maintains that
chromium would be present in the less toxic trivalent form.
EPA Response:
Although EPA is in general agreement with EBI that it is
unlikely that all of the chromium in the waste pile is in
the Cr(VI) state, this conservation assumption was made in
accordance with EPA risk assessment policy that chromium
should be considered to be in the hexavalent form unless
data are available for both Cr(III) and Cr(VI). There is
evidence that Cr(VI) compounds are reduced to CReIII) by
organic matter present in soils. However, the waste pile
contains little or no natural soil matter that might aid
such reduction.
Trivalent chromium Cr(III) may occur in soil as Cr+3 and
Cr203 or Cr(OH)3' w~ereas hexavalent chromium (CrVI) occurs
as cr?07.2 and Cro, -. At a soil pH between 5.5 and 7.0 under
aerob1C conditions (Eh c 0 to +0.05), chromium should be
present in soil as t~e Cr(III) cation (Bartlett & Kimble,
1976a) . Only when Eh levels exceed +0.05 would cr207-z or
CrO-2 be encountered. Oxidation of Cr(III) to Cr(VI) in
soils was not observed by Bartlett & Kimble (1976a) in their
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19
2.
Evaluation of 80il Recycling as a Source Control Action
In the following section EBI presents an alternative to disposal
of non-hazardous portions of the waste pile and leach field
soils. Each section will be evaluated and responded to in kind.
Comment: Although EBI concludes that SC-l (No Action) is
the appropriate response action for the waste piles, it
further observes that the FS discussion of Source Control
response options is incomplete. Section 3.2 of the FS
discusses Source Control response actions. Based upon waste
pile information presented in sections 4.2 and 5.3 of the
RI, EBI believes that soil recycling is a Source Control
response action that warrants further consideration. Soil
recycling into asphalt paving material appears to be the
process option most compatible with the soil types present
in the waste pile.
Further analysis on the leach field soils, including
physical analyses, may reveal that the soil recycling
process is amenable to these soils as well.
Based upon our review of the RI/FS Reports and our research
of soil recycling technologies, EBI believes that for each
Source Control (SC) alternative proposed in the FS,
excluding the no-action alternative, a corresponding Band C
alternative should be developed. The B option for each SC
alternative would include soil recycling of the non-
hazardous soils of the waste pile instead of disposal of
these soils at a solid waste disposal facility. The C
option of each alternative would involve recycling of both
the non-hazardous waste pile soils and the leach field
soils. All other phases of the SC alternatives would remain
unchanged in the Band C options.
EPA Response:
EPA does not consider this to be a viable alternative. Oil
contaminated soils free of other contamination may be used
to produce both hot and cold asphalt mixes in lieu of
disposal to a hazardous waste land fill. KMC leach field
soils will not be suitable for recycle option due to the
presence of TCA. Asphalt production would tend to volatize
the TCA causing a release to the atmosphere unless special
precautions were employed. In fact, some low temperature
thermal aeration systems for treatment of VOC contaminated
soil employ asphalt batch plant equipment to promote
volatilization prior to carbon adsorption from the vapor
phase. Additionally, it is questionable whether asphalt
production using leach field soils would encapsulate TCA to
soil particles. A bench-scale study would have to be
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18
of the soil, aeration status or time of reaction. Bartlett
and James (1979) concluded that oxidation of Cr(III) in
soils was associated with the reduction of manganese (Mn)
and in the absence of Mn or other highly oxidized species,
oxidation of Cr(III) to Cr(VI) would not occur in soils.
Bartlett & Kimble (1976b) found that the presence of organic
matter in soils resulted in the spontaneous reduction of
Cr(VI) to Cr(III) with a corresponding oxidation of organic
matter.
Once absorbed, Cr(VI) may be reduced to Cr(III) by
juices in the human body. Cr(III) is not oxidized
higher state in biological systems (ATSDR, 1989).
is considered to be an essential nutrient and is
considerably less toxic than Cr(VI). Nonetheless, when
analytical data which distinguish between the two valence
states of chromium area are not available, EPA guidance for
conducting risk assessment for Superfund sites recommends
that chromium is assumed to be in the hexavalent form as a
conservative estimate of risk.
gastric
to a
Cr(III)
No data currently exists for the waste pile material to
distinguish between chromium (III) and chromium (VI).
Therefore, chromium was assumed to be in the hexavalent
form.
state Acceptance
Comment: EBI believes that the SC-1 alternative, with
respect to the waste piles, will comply with ARARs.
EPA Response:
Concerning only the waste piles, the implementation of SC-1
will result in the violation of several applicable or
relevant and appropriate Federal and State requirements.
The most potent threat associated with the waste piles are
the buried drums. These drums have the potential to
eventually corrode and discharge their contents to the
environment, This discharge could violate several State of
New Hampshire regulations regarding the protection of ground
water of the State, specifically N.H. Admin. Code Parts
410.05, 410.09, and 410.10. This discharge would also
violate 33 USC 1251, the Clean Water Act. Although the
waste piles have been stable, a single event such as a flood
could alter that situation. Erosion would violate the State
Wetlands Act, Section 404 of the Clean Water Act and
Executive Order 11990 (the Protection of Wetlands). The
existence of this pile violates State Solid Waste Management
-------
20
permanence. Finally, the organic matter contained within
leach field soils will not adhere to the asphalt emulsion,
therefore leach field soils will not be suitaple for this
reuse option. .
Asphalt itself is a bituminous substance occurring naturally
or as a residue in petroleum refining and consists chiefly
of hydrocarbons. When added to an aggregate, the asphalt
encapsulates the individual particles, rendering the
~~ntaminating petroleum hydro~arbons stable. The use of
asphalt production as a remedial action for soils from
hazardous waste sites is generally for soils containing
Total Petroleum Hydrocarbons (TPH). The production of both
hot and cold mixes are closely regulated by the NHDES to
ensure that the material is properly handled and utilized,
and that the products produced are non-hazardous. The
material and methods for producing hot and cold mixes are
quite distinct and different. Hot asphalt mixes necessarily
require rigid materials specifications in order to produce
high quality products suitable for heavy duty road
construction. The material from the KMC waste pile would
not be suitable for hot asphalt mixes due to the excess fine
particles. Cold mixes are not rigidly controlled and the
product obtained has very limited capabilities.
Cold Mix Asphalt - There are no standards applicable to the
production of cold mixes. In general, cold mixes are more
tolerant of excessive fines, such as clay, and moisture
content. Producers will usually accept fines in the 50
percent range, compensating for the fines by adding more
asphalt emulsion. Moisture content is also loosely
controlled because the emulsion itself contains water.
Limited variations in moisture content impact curing time,
but have little effect on strength.
Unlike hot mix asphalt, production of cold mixes can proceed
year round in enclosed spaces with no air quality control.
Cold asphalt mixes are produced by first preparing the soil
to be used by fine screening and removal of metal fragments,
roots and other debris. The stones removed by fine
screening are generally crushed to smaller size and
reintroduced. If excessive fines are present, rubble can be
crushed and added or coarser soils can be blended in. If
the moisture content is high, dry soils may be blended in.
The prepared soils are blended with an asphaltic emulsion
and often "proprietary" or "secret" ingredients to increase
particle adhesion and the strength of the finished product.
Once prepared, the mix may be stored open to the weather for
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21
According to the grain size distribution performed by in the
RI, the waste pile materials are suitable for cold mix
asphalt; but because of the fine texture of the material, it
must be combined with an approximately equal volume of
coarse sandy material. The waste pile is composed of a
fine powder-like sand (98% passing the No. 4 si~ve) and must
therefore be combined with coarser sand (retained on 1/2",
3/8", No.4 and No.8 sieves) to be suitable for reuse as
asphalt according to Standard Specifications for AASHTO
materials. If coarser materials are not used the resulting
asphalt would be viscous and syrup-like which would not be
suitable for reuse.
The approximate volume of asphalt produced would be about
8800 cubic yards (cy or yd3) (i.e. double the estimated
volume of the waste pile materials) assuming asphalt
fixatives and coarse sands will be added. Paving all
available areas excluding heavily wooded areas and wetlands,
would result in a pavement thickness of 36 inches.
The use of the waste pile material for asphalt production is
not a stand alone alternative since the hazardous material
would have to be addressed separately. It would therefore
be considered an additional technology within a Source
Control alternative. The use of the waste pile material in
asphalt batch production would be subject to State and local
approvals. The approval of the use of this material would
be unlikely due to the magnitude of asphalt that would be
produced.
The fine nature of the material could result in an asphalt
mix that would have low level strength and therefore have
very limited use.
Alternative Screening Process
Comment: EBI has reviewed the soil recycling process and
determined that such a process would meet the alternative
screening criteria as set forth in 40 eFR 300.68(9). These
criteria are presented on page 3-19 of the FS Report. Soil
recycling will provide a more permanent reduction in
toxicity and mobility than off-site disposal (with or
without treatment and stabilization).
EPA Response:
Encapsulation of material by asphalt batch production
not provide treatment to reduce contaminant toxicity,
however it does reduce its mObility. Asphalt batch
production would also increase the material volume.
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22
Shc)rt-Term Effectiveness
Comment: The short-term effectiveness of the Band C
options would provide medium short-term effectiveness,
similar to the SC alternatives developed in the FS.
EPA Response:
The proposed reuse alternative provides less short-term
effectiveness than other SC alternatives evaluated in the FS
because it requires greater handling of the materials during
blending and mixing operations to produce the asphalt
thereby creating increased potential for exposure.
LOlLg-Term Effectiveness
Comment: The Band C options provide improved long-term
effectiveness over the SC alternatives presented in the FS
because the recycling process will bind virtually all of the
volatile organic compounds or metals in the soils. The
recycled product (asphalt pavement) would no longer pose a
public threat. In addition, it can be argued that long term
effectiveness and permanence of off-site disposal will
always reMain somewhat undefined (e.g., leaking landfills).
EPA Response:
Asphalt production has been used with soils contaminated
with total petroleum hydrocarbons, (TPH), however TCA is not
a component of oils. The heat and mixing process of asphalt
production is similar to low temperature thermal aeration as
it drives volatiles off the soil particles into the
airstream where a vapor treatment system would be needed.
Asphalt production has not been proven, unlike low
temperature thermal aeration, to be an effective treatment
for volatile organic compounds other than TPH components.
Therefore, this reuse option would not be effective for
leach field soils. However, it may be effective for
reducing the mobility of chromium in the waste pile soils.
with regard to the waste pile, asphalt production may
provide good long-term effectiveness and permanence.
Implementability
Comment: Excavation of soils to be recycled on-site would
be performed with standard construction equipment. However,
recycling can only be performed when the ambient air
temperature is greater than 32 degrees Fahrenheit. Dust
control, using conventional dust control techniques, may be
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23
emulsion is introduced to the soil, wind erosion of the sand
would no longer occur.
Soil recycling will require applicable State. of New
Hampshire recycling permit approvals.
EPA Response:
Truck traffic will be substantially increased.
Approximately 245 truckloads will be required to provide
coarse sand and asphalt for production (based on doubling
waste pile volume). Additionally, if the asphalt mix
produced is to be used off-site, the number of trucks
required to transport the increased volume off-site will be
490 truckloads, double the original estimate. Dust control
will also be required during loading trucking operations.
It is also expected that asphalt production will increase
completion time as production and transport or stockpiling
of asphalt cannot occur until mobilization, excavation of
the waste pile, and transport for disposal of hazardous
materials has occurred as required.
Final disposition of the asphalt mix is unresolved. There
does not appear to be adequate available space on-site for
asphalt plant operations or on-site paving with the
materials or temporary storage for future off-site use.
Off-site use may also be subject to approval by the state of
New Hampshire.
Costs
Comment: Soil recycling can be accomplished at a unit cost
as low as $97.00/yd3 compared to $l45.00/yd3 to dispose of
non-hazardous soil in a solid waste landfill (see estimated
costs in the FS).
Due to the overgrowth and debris on and surrounding the
waste pile, the mobilization cost estimate appears to be
reasonable.
Because of the sandy nature of the waste pile soils, the
soil recycling of the waste pile and the leach field soils
can be completed in less than 4 weeks. On page 4-10 of the
FS, the FS estimates a processing rate of 26 yd3 for low
temperature thermal aeration of the leach field soils.
Based on the estimate of 250 yd3 of leach field soils,
processing of these soils should require no more than two
weeks if the thermal aeration technology is used.
Therefore, providing for a four week mobilization period and
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24
recycling and thermal aeration are conducted concurrently),
EBI estimates Source Control measures can be accomplished in
an eight week period. The eight week estimate represents a
worst-case scenario for time required to complete an SC
alternative with soil recycling. .
If both the Band C options were substituted in one of the
SC-3,5, 6 or 13 Alternatives, the estimated costs of such
an SC Alternative are presented in Table 1. In the
~~ep~~~tion of these costs, EBI has used the FS estimates
for all phases of the alternative, with the exception of the
soil recycling phases (i.e., recycling of non-hazardous
waste pile soils/sands and recycling of leach field soils).
Applying the health and safety costs of $15,000 per week,
health and safety costs for an eight week period should not
exceed $120,000. Furthermore, the recycling process would
not require temporary utilities/facilities or engineering
development costs estimated at $260,000 and $367,000,
respectively, and therefore do not appear in Table 1. The
use of the unit cost and quantity estimates for the other
phases of the SC Alternative does not represent EBI's
approval or adoption of these estimates which are presented
herein for comparative purposes only.
EPA Response:
The costs outlined by EBI are incomplete and underestimate
certain cost items associated with asphalt batch as a
treatment technology. The cost associated with the
additional coarse sand that must be added to the waste pile
material in order to provide adequate strength has not been
included. This cost is estimated to be approximately
$44,000.
Item 6, Recycling of Leach Field Soils should be changed to
Loading, Hauling and Disposal of Contaminated Leach Field
Soils at Off-site Hazardous Waste Landfill with
Treatment/Stabilization. This cost is $465/cy or a total of
$116,250.
The quantity listed for Item 9, Health and Safety, should be
16 weeks in order to take into account the time required to
mobilize equipment on-site, excavate the waste pile, and
transport hazardous substances off-site for disposal. This
added time will increase the Health and Safety costs to
$240,000.
Temporary utilities and facilities would be required for
this alternative for an additional cost of $260,000.
The EBI proposed remedy is likely to be more costly than the
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25
Compliance with ARARS
Comment: The Band C recycling options implemented in any
of the SC alternatives would comply with CERCLA and SARA as
recycling would provide a permanent solution for the
remediation of the waste pile and leach field soils.
Air monitoring may still be required as in the case in all
SC alternatives.
EPA Response:
Soil recycling would not provide a permanent solution for
remediation of leach field soils. Although soil recycling
to asphalt has not been an alternative typical for use at a
Superfund site, it should comply with ARARs for the fine,
particulate material of the waste piles which are below
cleanup levels.
The production of asphalt is a permitted activity in the
State of New Hampshire. Permit approval is based on
material suitability and air emissions from the production
process. Additional testing and evaluation would have to be
conducted in order to determine whether the waste pile
material would meet the approval of the State for asphalt
production.
Overall Protection of Human Health and the Environment
Comment:
improved
compared
proposed
EBI believes that soil recycling would provide
protection of human health and the environment
to the soil disposal and treatment remedies
in the SC alternatives.
EPA Response:
Soil recycling should provide equal protection of human
health and the environment compared to other proposed source
control alternatives for the fine, particulate materials of
the waste pile if adequate controls can be implemented
during the increased material handling efforts required.
However, EBI has not addressed the contaminated soils which
will be encountered in the septic tank leach field. Use of
these soils in asphalt production would not provide equal
protection of human health and the environment as compared
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26
state Acceptance
Comment: Soil recycling is intended to meet applicable
state of New Hampshire ARARs.
EPA Response:
~
Due to the fact that it is unknown whether the waste pile
material and the resulting air emissions would meet permit
~~gui~~~~nts for asphalt batch production without further
testing and evaluation, the S~ate does not accept nor reject
this alternative.
REFERENCES
ATSDR, 1989-90 Toxicological Profile for Chromium. Agency
for Toxic Substances and Disease Registry. u.S. Public.
Health Service.
Bartlett, R.J. and B. James, 1979. Behavior of Chromium in
Soils: III. Oxidation. Journal of Environmental Quality
(JEQ) 8(1): 31-35.
Bartlett, R.J. and J.M. Kimble, 1976a. 'Behavior of Chromium
in Soils: I. Trivalent Forms. JEQ 8(4): 379-382.
Ibid, 1976b. Behavior of Chromium in Soils II.
Forms. JEQ 5(4): 383-386.
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ATTACHMENT A
-------
ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE KEARSARGE"
METALLURGICAL CORPORATION SITE IN CONWAY, NEW HAMPSHIRE
The U.S. Environmental Protection Agency (EPA) and the New
Hampshire Department of Environmental Services (DES) have
conducted the following community relations activities at the
Kearsarge Metallurgical Corporation Superfund Site:
o 8/83
o 8/13/85
o 8/26/85
o 11/1/85
o 2/28/86
o 3/31/86
o 5/5/86
o 6/3/86
o 8/5/86
o 8/29/86
o 9/15/86
o 10/22/86
o 4/15/87
o 12/4/87
EPA issues press release detailing site status at
time of its proposal for inclusion on the National
Priorities List.
DES issues press release announcing 8/26/85 public
information meeting.
DES holds public informational meeting to present
Remedial Investigation overview.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Board
of Selectmen.
DES sends site status update letter to Conway Town
Manager.
DES issues press release announcing 12/18/87 public
-------
o 12/18/87
o 2/1/89
o 2/9/89
o 5/8/89
o 1/90
o 6/90
o 6/19/90
o 6/22/90
o 6/28/90
o 6/29/90
o 7/19/90
o 7/24/90
o 8/27/90
DES and EPA hold public informational meeting to . .
discuss Remedial Investigation/Feasibility Study
progress.
DES sends site status update letter to Town of Conway
and state Representative Nanci Allard..
DES sends site status update letter to Town of Conway
and State Representative Nanci Allard.
DES, town selectmen, and town manager have a meeting
to discuss Remedial Investigation/Feasibility Study
progress.
DES issues Community Relations Plan.
EPA and DES issue Proposed Plan to address
contamination at the site.
EPA issues press release announcing the availability
of the Proposed Plan, the dates of the Public
Informational Meeting and Informal Public Hearing and
the beginning of the Public Comment Period.
EPA publishes notice in the Conway Daily Sun
announcing the availability of the Site
Administrative Record.
EPA and DES hold public informational meeting on the
Proposed Plan.
30-day public comment period for the Proposed Plan
begins.
EPA issues press release announcing 30-day extension
of public comment period for Proposed Plan.
EPA/DES hold an Informal Public Hearing to receive
comments on the Proposed Plan.
-------
ATTACHMENT B
PRP COMMENTS
()
-------
."
LAW OFFICES OF
JOSEPH S RANSMEIER
LAWRENCE E SPELLMAN
JOHN C RANSMEIER
DOM. 0 AM8RUOSO
LAWRENCE S SMITH
MICHAEL LENEHAN
E TUPPER KINDER
STEVEN E HENGEN
GARRY R LANE
JEFFREY J ZELLERS
TIMOTHY E 8RITAIN
DIANE L PERIN
R. STEVENSON UPTON
R MATTHEW CAIRNS
LISA L BIKLEN
CAROL J HOLAHAN
JOHN T ALEXANDER
RANSMEIER 8: SPELLMAN
ONE CAPITOL STREET
P.O. BOX 1378
CONCORD. NEW HAMPSHIRE 03302.1378
TELEPHONE 16031 228.0477
FAX Nos. 16031 224.2780
16031 228.2131
JAMES B GODFREY
Oft COUNSEL
August 27, 1990
Mr. Richard A. Goehlert
United States Environmental Protection
Waste Management Division (HSN/CAN 5)
JFK Federal Building
Boston, MA 02203
Agency
Re:
Carroll Reed, Inc.
Kearsarge Metallurgical Corporation
Site: Conway, New Hampshire
Dear Mr. Goehlert:
Please find enclosed the comments of Carroll Reed, Inc.
("Carroll Reed") on the proposed clean-up plan for the Kearsarge
Metallurgical Corporation Superfund site, which proposed plan
was noticed in June, 1990. Please be advised that Carroll Reed
continues to believe that it has no statutory or common law
liability to the United States, to the State of New Hampshire,
to any other governmental or private entity, or to any person
for conditions that allegedly exist at the Kearsarge
Metallurgical Corporation site as defined by EPA. (Please see
letter of John J. Regan to Richard A. Goehlert dated July 20,
1990.) The enclosed comments are submitted solely for the
purpose of pointing out errors, inaccuracies, inconsistencies
and misinterpretations which Carroll Reed, Inc. and its
consultant, Enviro Business, Inc. ("EBI") believe exist in the
documents presented by EPA and its consultant, CDM. Please be
advised that the submission of these comments should not be
inferred by you to indicate a commitment or a willingness on the
part of Carroll Reed to undertake any remedial action at the KMC
site. As you know, the problems at the KMC site were created
solely by the acts of KMC for which Carroll Reed has no
-------
Mr. Richard A. Goehlert
August 27, 1990
Page 2
Notwithstanding the above, Carroll Reed, as has been its
practice throughout this matter, stands ready to cooperate with
~~A :u review the enclosed comments which are directed to
establishing a remedial alternative which is appropriate for the
KMC site. We believe that these comments demonstrate that thers
are approaches to the problems at the KMC site which are
superior to EPA's proposed plan. The EBI comments present
alternatives which accomplish appropriate' clean-up goals at a
lower cost and in less time than EPA's plan. Also, EBI's
comments avoid the problems associated with offsite disposal of
a substantial quantity of the waste material at issue.
As I mentioned to you in my letter of August 21, 1990, I
believe that a meeting in early September would be helpful for
all parties. Please feel free to contact me if you have any
questions concerning the enclosed.
Very truly yours,
~~~LL-
E. Tupper Kinder
ETK/jcvf
cc: John A. Bewick
Elizabeth Foote
John J. Regan
Gregory H. Smith
Thomas Walsh
djmm272
P.s.
Please note that the enclosures to this letter were
hand-delivered with the FAXed copy of this letter
-------
.
.
.
nviroB usiness
20 l\4all Road
Burlington. MA 01803
(6171 229-9922
August 27, 1990
Mr. Thomas M. Walsh, Executive Vice President
Carroll Reed, Inc.
Mill Street
Conway, NH 03866
Re:
Kearsarge Metallurgical Corporation (KMC) Hazardous Waste Site
Remediallnvestie:ationJFeasibilitY Study (RIfFS) Comments
Dear Mr. Walsh:
EnviroBusiness, Inc. (EBI) has completed its review of the RIlFS Repons for the
Kearsarge Metallurgical Corporation Hazardous Waste Site, located in Conway, New
Hampshire. Per your request, we are providing you with our comments on the EPA
proposed clean-up plan for the Kearsarge Metallurgical COIporation Superfund site.
The attached comments address source control (SC) alternatives proposed in the
Feasibility Study Repon prepared by Camp Dresser & Mckee, Inc. (CDM). Based upon
the information contained in the RI Report, J;:BI believes that the SC-l Alternative is the
most appropriate remedial action alternative for the waste piles. This conclusion is also
supponed by the information presented in GEl's Draft Remedial Investigation Repon,
dated December 5, 1986.
Comments on SC alternatives are divided into two sections. The information
presented in the two sections is mutually exclusive: that is, Section One demonstrates that
the risks associated with the site are insignificant or unsubstantiated and Section Two
presents recycling as an option that mitigates risk at the site more effectively than other SC
alternatives. Section One addresses the quantitative and qualitative infonnation in the Rl
Repon that characterizes the waste pile and compares it to information presented in the FS
Report. EBI concludes that CDM's evaluation of the No-Action Alternative (SC-l), based
upon the criteria set fonh on page 3-19 of the FS Report, is inconsistent with the
information presented in the RI Repon, and is therefore inaccurate.
EBI also provides comments challenging CDM's use of hexavalent chromium
versus trivalent chromium in the waste pile non-carcinogenic risk calculations. There are
no data in the RI Repon supporting CDM's use of hexavalent chromium in their non-
carcinogenic risk calculations. In the attached comments, EBI provides information
-------
.'
.
,
Toxicological supporting data on chromium is attached for your review. This information
was generated from the EPA and National Library of Medicine Infonnation Databases.
"-...
While EBI concludes that the No-Action Alternative is the most appropriate
response action with respect to the waste pile, EBI also reviewed the other source control
alternatives proposed by CDM. Based upon this review, EBI concludes that CDM has
failed to consider soil recycling as a remedial response method capable of addressing both
non-hazardous waste pile soils and contaminated leach field soils. Section Two presents
recycling as an additional SC action for these soils. An SC option utilizing soil recycling
can be accomplished in a shoner period of time than other SC alternatives (8 weeks versus
26 weeks), provides for a permanent on-site solution for contaminated soils and non-
hazardous soils, and can be accomplished at roughly half the cost of the other SC
alternatives. More importantly, soil recycling will provide greater protection to public
health and the environment because the recycling alternative would encapsulate the
chemicals present in the soils and require no off-site transpon. Accordingly, EBI believes
an SC alternative using soil recyling wamutts funher analysis and study.
If you have any questions regarding our comments or other aspects of the RIlFS
Repons, please contact me or John Stamatov at (617) 924-7455.
Sincerely,
I1AA_~~
(/'.i' John A. Bewick '
Principal
Enclosures
cc:
E. Tupper Kinder, Esq.
-------
.
,
EnviroBusiness
20 Mall Road.
Burlington. MA 01803
f 6171 229-9922
L
"
EVALUATION OF THE NO-ACTION ALTERNATIVE
(Section One)
Based upon a review and analysis of the RI and FS Reports prepared by CDM and GErs
Draft Remedial Investigation Repon, EBI concludes that the SC-l Alternative (No-Action)
is the most appropriate response action for the waste piles at the KMC site. CDM has not
presented any evidence in the RI Report confinning the presence of hazardous wastes in the
waste pile. Presumably, if any hazardous wastes were dumped on the waste pile in the
past, such wastes would have either volatilized or neutralized through the passage of time
To review and evaluate the SC Alternatives, EBI evaluated CDM's conclusions based on
the infonnation presented in the RI Repon. An examination of these documents reveal
inconsistencies in the infonnation CDM uses to disqualify the SC-l Alternative.
In Section 4.2.1 of the FS (page 4-2), CDM states:
"Under the no-action alternative, conditions would remain at the site, and
both waste piles and the septic tank/leach field area would remain as
uncontrolled potential sources of contamination."
EBI fmds CDM's contention that the waste pile under current conditions is an uncontrolled
potential source of contamination inconsistent with the infonnation presented in the RI.
For example, the RI Repon addresses the waste pile in Section 5.3.2 (page 5-7):
"During site investigation activities undenaken at the KMC site during
1989, observations were made during rainstonns to evaluate the potential
for surface erosion. During these rainfall events it was apparent that the soil
has a significant infiltration capacity and no erosion of material was
observed. In fact, erosion features such as gullies are absent even from the
steepest ponions of the waste pile. The vegetated areas present along the
Pequawket Pond shoreline and the wetland area east of the waste pile serve
as buffer areas to surface runoff and therefore runoff of particulates is not
considered a significant route for contaminant migration from the site to
nearby surface waters under current conditions.
"Erosion and runoff of additional waste pile sands to the pond is not
considered to be a significant pathway for migration of wastes under
average conditions."
Moreover, even if it is argued that materials in the waste pile are "uncontrolled" and
may enter the environment, Section 4.2 (page 4-6) of the RI Repon states:
"GEl perfonned EP toxicity characteristic test on three waste pile samples
and found that all leachate analytes (Ag, As, Ba, Cd, Cr, Hg, Pb, Se) were
below detection limits and regulatory limits."
CDM confumed GErs fmdings in 1989 (see page 4-7 of the RI Repon). Furthennore
-------
KMC RI/FS Comments
CML Group
Page 2 of 11
,,-
"Although source materials may be present in discrete pockets within the
pile, this material is not considered to be a major source of groundwater
contamination. The organic layer formed from past disposal of woodchips
may serve as a zone in which microbial activity is enhanced contributing to
degradation of solvents and retarding contaminant flow." .
The following subsections evaluate the SC-l Alternative using the same criteria used to
evaluate the SC alternatives presented in the FS Repon.
"
Short- Term Effectiveness
Section 4.2.2 (page 4-2) of the FS addresses short-term effectiveness of the SC-l
Alternative. Regarding the waste pile, COM states:
"Therefore, the no-action alternative would provide only temporary
mitigation of inhalation of silica sands from the waste pile."
This statement appears to be inconsistent with the information presented in Section
5.3.1 (page 5-6) of the RI Repon which addresses wind dispersal. In Section 5.3.1,
COM states:
" Approximately 40 percent of the waste pile sands fall between 0.1 and 0.5
mm particle size and could be subject to entrainment. However, only about
25 percent of the total surface areas of the waste pile is comprised of this
material. The remainder of the area is either vegetated or covered with scrap
materials not susceptible to erosion. Funhermore, the waste pile is buffered
by the forested area to the east and south and by KMC Building No.1 to the
west. In this setting little wind erosion would be expected to occur and
transpon via blowing sands is not considered a pathway of concern under
the cUITent situation."
Additional infonnation demonsttating the negligible shon-term risks posed by the waste
pile is presented in Section 6.3.2 (page 6-25) of the RI Repon where COM states:
"Exposures and potential risks from volatile organics in the waste pile are
assumed to be negligible and will not be considered further. As previously
noted, exposures to silica and metals from fugitive dust originating from the
waste pile are considered negligible under current conditions. "
Section 4.2.2 (page 4-2) states:
"the no-action alternative would not be effective in preventing the potential
release of contaminants which may be present in and under the waste pile
(e.g., buried drums)."
However, in the RI Report, CDM's fmdings discount this pathway of contaminant
migration:
"Although source materials may be present in discrete pockets within the
pile, this material is not considered to be a major source of groundwater
contamination. The organic layer formed from past disposal of woodchips
may serve as a zone in which microbial activity is enhanced contributing to
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KMC RIlFS Comments
CML Group
Page 3 of 11
.'
Long- Term Effectiveness
CDM's No-Action. long-term effectiveness conclusions (with respect to the waste pile)
are contradictory to the infonnation presented by CDM in the RI Repon.
t
In Section 5.3.1 (page 5-6) of the RI Repon. CDM states:
"In this setting little wind erosion would be expected to occur and transpon
via blowing sands is not considered a pathway of concern under the current
situation. "
In Section 6.3.2 (page 6-25). CDM further states:
"exposures to silica and metals from fugitive dust originating from the
waste pile are considered negligible under CmTent conditions."
In Section 5.3.1 of the RI Repon. CDM states that only 25 percent of the surface area
of the waste pile is exposed. Given a no-action alternative. EBI maintains that this
percentage will decrease as overgrowth continues to spread over the waste pile.
Section 6.4.2 (page 6-33) of the RI Repon states:
"Potential risks associated with inadvenent waste pile soil ingestion are
shown in Table 6-24 for the average and maximum cases. Since no
contaminants of concern in the soil are carcinogenic by the oral route of
exposure. there is no excess lifetime cancer risk. The HI for the average
case is 0.06 and for the maximum case it is 0.08. Since both Hfs are less
than one. no chronic adverse health effects are expected due to exposure to
waste pile soils under the current scenario."
Given CDM's conclusion demonstrating no cancer and non-cancer health risks. and
demonstrating negligible risks associated with inhalation of fugitive dusts emissions.
CDM's statement that no-action alternative "would not provide long-term effectiveness"
is unsubstantiated.
Reduction of Toxicity, Mobility, and Volume Through Treatment
CDM states:
"Under the no-action alternative. there would be no treatment of source
materials and no reduction of contaminant toxicity. mobility. or volume
from that which currently exists."
However. based upon the RI Repon. it cannot be determined what the baseline toxicity,
mobility and volume criteria are. EP toxicity tests performed by GEl and CDM
revealed all leachate analytes below regulatory limits. In Section 5.6 (page 5-14) of the
RI Repon. CDM states "source materials may be present in discrete pockets". however
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KMC RIlFS Comments
CML Group
Page 4 of 11
Compliance with ARARs
It is unclear which ARARs the no-action alternative does not comply with. The
following are excerpts from the RI Repon. . .
In Section 4.2 (page 4-6), CDM writes: . .
"GEl perfonned EP toxicity characteristic test on three waste pile samples
and found that all leachate analytes (Ag, As, Ba, Cd, Cr, Hg, Pb, Se) were
below detection limits and regulatory limits."
...
In addition, CDM has not quantitatively or qualitatively defined the extent of hazardous
waste contamination in the waste pile. Without the establishment of baseline toxicity
infonnation, is unclear how CDM maintains that the no-action alternative "is
inconsistent with SARA 121(d) which prefers tteatment and detoxification of hazardous
wastes." Similarly, inconclusive evidence in the RI Report does not support CDM's
claim that the no-action alternative "does not comply with RCRA 40 CFR Part 264 and
the State of New Hampshire regulations for disposal of hazardous waste."
CDM discounts erosion as a pathway of contamination (see Section 5.3.2 (page 5-7) of
the RI Report). Therefore, CDM's assertion that "the no-action alternative would not
comply with Executive Order 11990 (wetlands)", is inconsistent with the RI Report
findings.
Overall Protection of Human Health and the Environment
In the case of the waste pile, the RI Report does not present any evidence suggesting
the waste pile poses a risk to human health. Although CDM demonstrates potential
adverse chronic health effects under the future scenario (Le., residential use), EBI
concludes that CDM's findings are invalid because CDM's future risk calculations were
based upon CDM's assumption that chromium in the waste piles is present in the
hexavalent fonn. EBI maintains that chromium would be present in the less toxic
trivalent fonn.
In Section 6.4.2 (page 6-33) of the RI Report, CDM concludes the waste pile poses no
risk under the current scenario:
"Potential risks associated with inadvertent waste pile soil ingestion are
shown in Table 6-24 for the average and maximum cases. Since no
contaminants of concern in the soil are carcinogenic by the oral route of
exposure, there is no excess lifetime cancer risk. The HI for the average
case is 0.06 and for the maximum case it is 0.08. Since both Hfs are less
than one, no chronic adverse health effects are expected due to exposure to
waste pile soils under the current scenario."
Non-carcinogenic risks are measured in terms of the Hazard Index (Ill). The
ill is defined by the equation:
In = ADDIRFD
where
ADD = Average Daily Dose in mg/kg/day
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KMC RIlFS Comments
CML Group
Page 5 of 11
The ID is a unitless ratio of potential exposure dose to a threshold dose. below
which no chronic health effects are expected. By definition. IDs less than one
indicate thai no adverse non-carcinogenic health effects are expected.
Conversely. IDs greater than one suggest a potential for adverse chronic non-
carcinogenic health effects. . .
I
'"
Although CDM concludes no risk in the current scenario. under the future scenario.
CDM has detennined that (see Section 6.4.5 (page 6-34) of the RI Repon):
"potential adverse chronic health effects may exist for residential use of the
waste pile area."
To arrive at this conclusion. CDM states:
" All chromium is assumed to be in the hexavalent fonn" .
This assumption is contrary to standard industry data for environmental chemistry of
chromium. Below are excerpts from Chromium Hazards to Fish. Wildlife. and
Invertebrates: A SvnoDtic Review. Eisler. R. 1986. U.S. Fish and Wildlife Service
BioI. Rep. 85( 1.6). 6Opp.
"All stable Cr+6 anionic compounds strongly oxidize organic matter on
contact and yield oxidized organic matter and Cr+3."
"
"Interaction of +6 chromic oxide. dichromate. or chromate compounds
with organic compounds can result in reduction to the comparatively
less toxic trivalent fonn."
"Chromium in biological materials is usually in the +3 fonn. and is the
fonn that functions as an essential element in mammals by maintaining
efficient glucose. lipid. and protein metabolism. In general. the toxicity
of trivalent chromium to mammals is low because its membrane
penneability is poor and it is noncorrosive; further. there is little
tendency for Cr+3 to biomagnify in food chains in the inorganic fonn."
Using hexavalent chromium to detennine future risk. CDM detennined an average case
ID of 1.0. The ID for the maximum case was calculated to be 1.4. If these same
detenninations are made using trivalent chromium (representative of site conditions) the
average case HI is 0.005 and the maximum case HI is 0.007. The RFD is 1.0 X 10°
for hexavalent chrome and 5.0 X 10-3 for trivalent chrome. Based upon these
calculations. the waste pile presents no potential risks under the future scenario.
Similarly, CDM provides no quantitative evidence demonstrating a threat to the
environment posed by the waste pile. To the contrary, CDM states:
"Ingestion of contaminants at the site by the biological community would not
appear to pose a major risk to the biological community as the total area of waste
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KMC RIJFS Comments
CML Group
Page 6 of 11
State Acceptance
EBI believes the SC-! Alternative with respect to the waste piles will comply with
-------
KMC RIlFS Comments
. CML Group
Page 7 of 11
EVALUATION OF SOIL RECYCLING AS A SOURCE
CONTROL ACTION
(Section Two)
cj
Although EBI concludes that SC-l (No-Action) is the most appropriate response action for
the waste piles, it further observes that the FS discussion of source control response
options is incomplete. Section 3.2 of the FS discusses source control response actions.
Based upon waste pile infonnation presented in Sections 4.2 and 5.3 of the RI Repon, EBI
believes that soil recycling is a source control response action that warrants further
consideranon. Soil recycling into asphalt paving material appears to be the process option
most compatible with the soil types present in the waste pile.
Further analysis on the leach field soils, including physical analyses, may reveal that the
soil recycling process is amenable to these soils as well.
Description of Technology
The technology of recycling contaminated soil into useable asphalt paving material is
gaining wide acceptance as a proven remedial alternative. During the recycling process,
contaminated soils are completely coated with an asphalt emulsion. This coating
process physically and chemically binds contaminants into a cohesive asphaltic cold
mix material. The recycled material can be used on-site for a variety of paving needs,
thereby eliminating the need for off-site disposal of the contaminated soil. If paving
alternatives are not available, the recycled material can be stockpiled on-site indefmitely
without any deleterious effects to public health, the environment or the recycled
material. The recycling system is completely mobile.
Representatives of Carroll Reed, Inc. have identified several locations on their propeny
where asphalt pavement produced from the recycling process could be applied.
Alternative Source Control Measures
Based upon our review of the RIlFS Reports and our research of soil recycling
technologies, EBI believes that for each source control (SC) alternative proposed by
CDM, excluding the No-Action Alternative, a corresponding B and C alternative should
be developed. The B option for each SC alternative would include soil recycling of the
non-hazardous soils of the waste pile instead of disposal of these soils at at solid waste
disposal facility. The C option of each alternative would involve recycling of both the
non-hazardous waste pile soils and the leach field soils. All other phases of the SC
alternatives would remain unchanged in the B and C options.
Alternative Screening Process
EBI has reviewed the soil recycling process and determined that such a process would
meet the alternative screening criteria as set forth in 40 CFR 3OO.68(g). These criteria
are presented on page 3-19 of the FS Report. Soil recycling will provide a more
-------
KMC RIlFS Comments
, CML Group
Page 8 of 11
treatment and stabilization). Soil recycling also may pose less of a risk to the public,
workers, or the environment during implementation as on-site recycling eliminates any
risks which may be associated with off-site transportation. In the overall protection of
human health and the environment analyses of each SC alternative (Sections 4.3.8,
4.4.8, 4.5.8, and 4.6.8), CDM states: '
"Potential exposure of all populations from accidental spills or releases
during off-site transpon exists" .
On-site recycling would eliminate off-site transport requirements for certain soils,
thereby reducing the risk defined by CDM. .
Short- Term Effectiveness
The shon-term effectiveness of the B and C options would provide medium shon term
effectiveness, similar to the SC alternatives developed by CDM.
Long- Term Effectiveness and Permanence
The B and C options provide improved long-term effectiveness over the SC alternatives
presented by CDM because the recycling process will bind vinually all of the volatile
organic compounds or metals in the soils. The recycled product (asphalt pavement)
would no longer pose a public health threat. In addition, it can be argued that long term
effectiveness and permanence of off-site disposal will always remain somewhat
undefined (e.g., leaking landfills).
Implementability
Excavation of soils to be recycled on-site would be performed with standard
construction equipment. However, recycling can only be performed when the ambient
air temperature is greater than 32 degrees Fahrenheit. Dust control, using conventional
dust control techniques, may be required during the excavation process. Once the
asphalt emulsion is introduced to the soil, wind erosion of the sand would no longer
occur.
Soil recycling will require applicable State of New Hampshire recycling pennit
approvals.
Costs
Soil recycling can be accomplished at a unit cost as low as $97.00/yd3 compared to
$145.00/yd3 to dispose or non-hazardous soil in a solid waste landf1l1 (see CDM
estimated costs).
Due to the overgrowth and debris on and surrounding the waste pile, the mobilization
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KMC RIlFS Comments
CML Group
Page 9 of 11
t.\
Because of the sandy natw'e of the waste pile soils, the soil recycling of the waste pile
and the leach field soils can be completed in less than 4 weeks. On page 4-10 of the FS
Repon, COM estimates a processing rate of 26 yd3 for low temperature thennal
aeration of the leach field soils. Based on COM's estimate of 250 yd3 ofleach field
soils, processing of these soils should require no more than two weeks if the thennal
aeration teChnology is used.
Therefore, providing for a four week mobilization period and four weeks of source
conttol measures (assuming soil recycling and thennal aeration are conducted
concmrently), EBI estimates source conttol measures can be accomplished in an eight
week period. The eight week estimate represents a worst-case scenario for time
required to complete an SC alternative with soil recycling.
If both the Band C options were substituted in one of the SC-3, 5, 6 or 13
Alternatives, the estimated costs of such an SC Alternative are presented in Table 1.
In the preparation of these costs, EBI has used CDM's estimates for all phases of the
alternative, with the exception of the soil recycling phases (i.e., recycling of non-
hazardous waste pile soils/sands and recycling of leach field soils). Applying CDM's
health and safety cost estimate of $15,000 per week, health and safety costs for an eight
week period should not exceed $120,000. Furthermore, the recycling process would
not require teiliporary utilities/facilities or engineering development costs estimated at
$260,000 and $367,000, respectively, and therefore do not appear in Table 1. The use
of CDM's unit cost and quantity estimates for the other phases of the SC Alternative
does not represent EBI's approval or adoption of these estimates which are presented
-------
SOIL RECYCLING COSTS
Table 1
JnM
1. Testing of waste pile material
to classify hazardous material
and non-hazardous material
2. Separating and stockpiling
hazardous and non-hazardous
waste pile components
3. Recycling of non-hazardous
waste pile soils/sands.
4. Loading, hauling and disposal of
hazardous waste pile components
at a hazardous waste landfill with
trea tme nUstabii iza tion.
5. Demolition of septic system
components
6. Recycling of leach field soils
7. Loading, hauling and disposal of
drums from KMC building and septic
tank and sludge at off-site incinerator
8. Mobilization & demobilization
9. Health & safety
10.
Site work
11.
Loarning and seeding
SUBTOTAL
INDIRECT COSTS
SUBTOTAL, EST. CAPITAL COSTS
TOTAL ESTIMATED CAPITAL COSTS
$1,000 $1,000
$97/cy $24,250
$560/drum $16,800
QUANTITY
UNIT COST
20 samples
$1200/sample
4650 cy
$5.00/cy
4400 cy
$97/cy
250 cy
$465/cy
LS.
250 cy
30 drums
loS. $200,000
8 wks $15,000/wk
20,000 sq. ft. $3.00/sq. ft.
2225 sq. yds. $4.00/sq. yd
Overhead & Profit (15%)
Contingency (15%)
Administration (15%)
KMC RIlFS Comments
CML Group
Page 10 of 11
COST
$24,000
$23,250
$429,000
$116,250
$200,000
$120,000
$60,000
$8.900
$1,023,450
$153,518
$1,176,968
$176,545
$176 545
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KMC RIlFS Comments
. CML Group
Page 11 of 11
Compliance with ARARs
The B and C recycling options implemented in any of the SC alternatives would comply
with CERCLA and SARA as recycling would provide a permanent solution for the
remediation of the waste pile and leach field soils. .
Air monitoring may still be required as is the case in all SC alternatives.
Overall Protection of Human Health and the Environment
EBI believes that soil recycling would provide improved protection of human health
and the environment compared to the soil disposal and treatment remedies proposed in
the SC alternatives.
State Acceptance
-------
EnviroBusiness
IRIS NUMBER
LAST REVISION DATE
IRIS STATUS
IRIS STATUS
IRIS STATUS
IRIS STATUS
IRIS STATUS
IRIS STATUS
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
RECORD LENGTH
NAME OF SUBSTANCE
CAS REGISTRY NUMBER
SYNONYMS
SYNONYMS
SYNONYMS
SYNONYMS
SYNONYMS
20 Mall Road
Bur!ington. MA 01803
16171229-9922
Chromium III
mIS File
27
900802
Oral RfD Assessment (RDO) on-line 03/01/88
Inhalation RfC Assessment (RDI) no data
Carcinogenicity Assessment (CAR) no data
Drinking Water Health Advisories (DWHA) on-line
03/01/88
U.S. EPA Regulatory Actions (EXSR) on-line
08/01/90
Supplementary Data no data
03/01/88 RDO Critical effect added
03/01/88 HADV Health Advisory added
08/01/89 REFS Bibliography on-line
08/01/90 RCRA EPA contact changed
10412
Chromi um (III)
16065-83-1
CHROMIC ION
CHROMIUM
Chromium (III)
CHROMIUM (III) ION
CHROMIUM, ION
------------------------------------------------------------------------------
REFERENCE DOSE FOR ORAL EXPOSURE
o ORAL RFD SUMMARY:
Critical Effect
--------------------
No effects observed
Rat Chronic Feeding
Study
Ivankovi c and
Preussmann, 1975
Experimental Doses*
UF
MF
RfD
-----------------------
---------
NOEL: 5% Cr203 in
diet 5 days/week for
600 feedings (1800
g/kg bw average total
dose) .
100
10
1E+O
mg/kg/day
(as an
insoluble
sal t)
----------------------------------------------------------------------------
LOAEL: none
*Dose Conversion Factors & Assumptions: 1800 g Cr203/kg bw x 1000 mg/g x
0.6849 Cr/g Cr203 / 600 feeding days x 5 feeding days/7 days = 1468
mg/kg/day
-------
Chromium ill
IRIS File
August 21. 1990
Page.2 of 6
o ORAL RFD STUDIES:
Ivankovic, S. and R. Preussrnann. 1975. Absence of toxic and carcinogenic
effects after administration of high doses of chromic oxide pigment in sub-
acute and long-term feeding experiments in rats. Food Cosmet. Toxicol. 13:
347-351. .
(,
Groups of 60 male and female rats were fed chromic oxide (Cr203) baked in
bread at dietary levels of 0, 1, 2, or 5%, 5 days/week for 600 feedings (840
total days). The primary purpose of this ,study was to assess the carcino-
genic potential of Cr203. Body weight and food consumption were monitored.
The average total amounts of ingested Cr203 were given as 360, 720, and 1800
g/kg bw for the 1, 2, and 5% treatment groups, respectively. The animals were
maintained on control diets following termination of exposure until they
became moribund or died. All major organs were examined histologically.
Other toxicologic parameters were not mentioned explicitly, but may have
included some or all of those described for the accompanying subchronic study
(see below). No effects due to Cr203 treatment were observed at any dose
level.
Ivankovic and Preussmann (1975) also treated rats (both sexes, 12-19
rats/group) at dietary levels of 0, 2, or 5% Cr203 in bread, 5 days/week for
90 days. Food consumption and body weight were monitored. Toxicologic
parameters included serum protein, bilirubin, hematology, urinalysis, organ
weights, and histopathology. The only effects observed were reductions (12-
37%) in the absolute weights of the livers and spleens of animals in the high-
dose group. Organ weights relative to body weight were not reported. The
high dose is equivalent to 1400 mg/kg/day (dose converted using reported
data) .
Other subchronic oral studies show no indication of adverse effects
attributable to trivalent chromium compounds, but dose levels were consider-
ably lower.
------------------------------------------------------------------------------
o ORAL RFD UNCERTAINTY :
UF = 100. The factor of 100 represents two 10-fo1d decreases in mg/kg bw/day
dose that account for both the expected interhuman and interspecies
variability to the toxicity of the chemical in lieu of specific data.
------------------------------------------------------------------------------
o ORAL RFD MODIFYING FACTOR:
MF = 10. The additional modifying factor of 10 is adopted to reflect
uncertainty in the NOEL because: 1) the effects observed in the 90-day study
were not explicitly addressed in the 2-year study and, thus, the highest NOAEL
in the 2-year study may be a LOAEL; 2) the absorption of chromium is low
«1%) and is influenced by a number of factors; thus, a considerable potential
variation in absorption exists; and 3) animals were allowed to die naturally
after feeding stopped (2 years) and only then was histology performed.
------------------------------------------------------------------------------
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Chromium ill
IRIS File
August 21, 1990
Page 3 of 6
This RfD is limited to metallic chromium (III) of insoluble salts.
Examples of insoluble salts include chromic III oxide (Cr203) and chromium III
sulfate [Cr2(S04)3].
Very limited data suggest that Cr III may have respiratory effects on
humans. No data on chronic or subchronic .effects.of inhaled Cr III in ani-
mals can be found. Adequate teratoloqydata do not exist, but reproductive
effects are not seen at dietary levels of 5% Cr203.
------------------------------------------------------------------------------
o ORAL RFD CONFIDENCE:
Study: Low
Data Base:
RfD: Low
Low
The principal study is rated low because of the lack of explicit detail on
study protocol and results. Low confidence in the data base reflects the lack
of high-dose supporting data. The low confidence in the RfD reflects the
foregoing, but also reflects the lack of an observed effect level. Thus, the
RfD, as given, should be considered conservative, since the MF addresses only
those factors which might lower the RfD.
------------------------------------------------------------------------------
o ORAL RFD SOURCE DOCUMENT :
U.S. EPA. 1984. Health Effects Assessment for Trivalent Chromium. Prepared
by the Office of Health and Environmental Assessment, Environmental Criteria
and Assessment Office, Cincinnati, OH, OHEA for the Office of Solid Waste and
Emergency Response.
The ADI in the 1984 Health Effects Assessment document received an Agency
review with the help of two external scientists.
------------------------------------------------------------------------------
o REVIEW DATES
o VERIFICATION DATE
o EPA CONTACTS:
: 11/21/85, 02/05/86
: 11/21/85
Michael L. Dourson / ORD -- (513)569-7544 / FTS 684-7544
Christopher T. DeRosa / ORe -- (513)569-7534 / FTS 684-7534
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
ONE-DAY HEALTH ADVISORY
An HA has been developed for total chromium and applies to chromium (III) .
Please refer to Section III in the file on chromium(VI) for the total chromiU7..
-------
Chromium ill
IRIS File
August 21. 1990
Page 4 of 6
------------------------------------------------------------------------------
------------------------------------------------------------------------------
-----------------------------------------------------------~------------------
AMBIENT WATER QUALITY CRITERIA FOR HUMANS .
J
Water and Fish Consumption:
1.7E+5 ug/L
Fish Consumption Only:
3.433E+6 ug/L
Considers technological or economic feasibility? -- NO
Discussion -- The Woe of 1.7E+5 ug/L is based on consumption of contaminated
aquatic organisms and water. A WQC of 3.433E+6 ug/L has also been established
based on consumption of contaminated aquatic organisms alone.
Reference --
45 FR 79318 (11/28/80)
EPA Contact -- Criteria and Standards Division, OWRS
(202)475-7315 / FTS 475-7315
------------------------------------------------------------------------------
------------------------------------------------------------------------------
AMBIENT WATER QUALITY CRITERIA FOR AQUATIC ORGANISMS
Freshwater:
Acute -- 9.8E+2 ug/L (hardness dependent)
Chronic -- 1.2E+2 ug/L (hardness dependent)
Marine:
None
Considers technological or economic feasibility? -- NO
Discussion -- For freshwater aquatic life the concentration (in ug/L) of
total recoverable trivalent chromium should not exceed the numerical value
given by the equations "e**(0.8190 [In (hardness)]+3.688)" for acute exposure
and "e**(O.8190 [In (hardness)]+1.561)" for chronic exposure (** indicates
exponentiation; hardness is in mg/L). For example, at a hardness of 50 mg/L,
the acute and chronic Woe would be 980 and 120 ug/L, respectively.
Reference --
50 FR 30784 (07/29/85)
EPA Contact -- Criteria and Standards Division, OWRS
(202)475-7315 I FTS 475-7315
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
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Chromium ill
IRIS File
August 21. 1990
Page. 5 of 6
Value (status) --
0.12 mg/L [total chromium]
(Proposed, 1985)
Considers technological or economic feasibility? -- NO
Discussion -- An MCLG of 0.12 mg/L for total chromium (CrIII and Cr VI) is
proposed based on a provisional DWEL of 0.17 mg/L with data on human exposure
factored in (0.10 mg/day in the diet and 0 mg/day by air). A DWEL of 0.17
mg/L was calculated from a NOAEL of 2.41 mg/kg/day in rats [1-year drinking
water study (Cr VI)], with an uncertainty factor of 500 applied and
consumption of 2 L of water/day assumed.
Reference --
50 FR 46936 Part IV (11/13/85)
EPA Contact -- Kenneth Bailey 1 Criteria and Standards Division, ODW 1
(202)382-7571 1 FTS 382-7571; or Drinking Water Hotline 1 (800)426-4791
------------------------------------------------------------------------------
------------------------------------------------------------------------------
MAXIMUM CONTAMINANT LEVEL
Value (status) --
0.05 mg/L [total chromium]
(Interim, 1980)
Considers technological or economic feasibility? -- NO
Discussion --
Reference --
45 FR 57332
EPA Contact -- Kenneth Bailey 1 Criteria and Standards Division, ODW 1
(202)382-7571 1 FTS 382-7571; or Drinking Water Hotline 1 (800)426-4791
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
REPORTABLE QUANTITIES
Value (status) -- See discussion
(Final, 1985)
Considers technological or economic feasibility? -- NO
Discussion -- Though "Chromium (III), insoluble salts" is not specifically
designated as a CERCLA hazardous substance, insoluble chromium (III) salts
would be considered hazardous substances under the CERCLA broad generic
listing for "Chromium and Compounds." There is no corresponding reportable
quantity (RQ) for this generic class of compounds. However, the releaser is
still liable for cleanup costs if the designated Federal On-Scene Coordinator
(OSC) decides to take response action with respect to the release of an
insoluble chromium (III) salt that is not otherwise specifically listed as a
CERCLA hazardous substance. There are two chromium (III) salts which are
specifically listed as CERCLA hazardous substances, chromic acetate and
chromic sulfate. Both have been assigned final RQs of 1000 pounds based on
-------
Chromium ill
IRIS File
August 21. 1990
Pag~ 6 of 6
Act) .
Reference --
51 FR 34534 (09/29/86)
EPA Contact -- RCRA/Superfund Hotline
(800)424-9346 / (202)382-3000 / FTS 382-3000
------------------------------------------------------------------------------
------------------------------------------------------------------------------
RCRA REQUIREMENTS
Status -- Listed
Reference -- 52 FR 25942 (07/09/87)
EPA Contact -- RCRA/Superfund Hotline
(800)424-9346 / (202)382-3000 / FTS 382-3000
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
TOXIC SUBSTANCES CONTROL ACT REQUIREMENTS
No data available
------------------------------------------------------------------------------
------------------------------------------------------------------------------
ORAL REFERENCE DOSE
REFERENCES
Ivankovic, S. and R. Preussmann. 1975. Absence of
toxic and carcinogenic effects after
administration of high doses of chromic oxide
pigment in subacute and long-term feeding
experiments in rats. Food Cosmet. Toxicol. 13:
347-351.
U.S. EPA. 1984. Health Effects Assessment for
Trivalent Chromium. Prepared by the Environmental
Criteria and Assessment Office, Cincinnati, OH.
OREA for the Office of Solid Waste and Emergency
Response, Washington, DC.
None
ORAL REFERENCE DOSE
REFERENCES
INHALATION REFERENCE DOSE
REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
HEALTH ADVISORY'
REFERENCES
None
An HA has been developed for total chromium and
applies to chromium(III). Please refer to Section
VI in the file on chromium(VI) for the total
-------
EnviroBusiness
IRIS NUMBER
LAST REVISION DATE
UPDATE HISTORY
IRIS STATUS
IRIS STATUS
IRIS STATUS
IRIS STATUS
IRIS STATUS
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
IRIS REVISION HISTORY
RECORD LENGTH
NAME OF SUBSTANCE
CAS REGISTRY NUMBER
SYNONYMS
SYNONYMS
SYNONYMS
SYNONYMS
SYNONYMS
Chromium VI
mIS File
20 Mall Road
Burlington. M:\ 01803
16171 229-9922
141
900604
Complete Update on 06/04/90, 30 fields
added/edited/deleted.
Oral RfD Assessment (RFO) on-line 03/01/88
Inhalation RfD Assessment (RFI) pending
Carcinogenicity Assessment (CAR) on-line 06/01/90
Drinking Water Health Advisories (DWHA) on-line
03/01/88
U.S. EPA Regulatory Actions (EXSR) on-line
06/01/90
09/30/87
03/01/88
03/01/88
12/01/89
06/01/90
06/01/90
06/01/90
06/01/90
06/01/90
20222
Chromium (VI)
7440-47-3
CHROMIC ION
CHROMIUM
CHROMIUM, ION
Chromium (VI)
CHROMIUM (VI) ION
CAREV Citation corrected
CARr Confidence statement revised
HADV Health Advisory added
RDI Inhalation RfD now under review
CAREV Basis - Text revised
CARO Text revised
CAA Area code for EPA contact corrected
? EPA contact changed
REFS Bibliography on-line
------------------------------------------------------------------------------
REFERENCE DOSE FOR ORAL EXPOSURE
o ORAL RFD SUMMARY:
Critical Effect
--------------------
No effects reported
Rat, I-Year Drinking
Study
MacKenzie et al.,
1958
Experimental Doses*
-----------------------
NOAEL: 25 mg/L of
chromium as K2Cr04
(converted to 2.4 mg
of chromium (VI) /kg/day)
LOAEL: none
UF
MF
RfD
---------
500
1
5E-3
mg/kg/day
----------------------------------------------------------------------------
*Dose Conversion Factors & Assumptions:
-------
Chromium VI
IRIS File
August 21, 1990
Page ~ of 17
0.097 L/kg/day (reported)
------------------------------------------------------------------------------
o ORAL RFD STUDIES:
b
MacKenzie, R.D., R.U. Bye rrum , C.F. Decker, C.A. Hoppert and R.F. Langham.
1958. Chronic toxicity studies. II. Hexavalent and trivalent chromium
administered in drinking water to rats. Am. Med. Assoc. Arch. Ind. Health.
18: 232-234.
Groups of eight male and eight female.Sprague-Dawley rats were supplied
with drinking water containing 0-11 ppm (0-11 mg/L) hexavalent chromium (as
K2Cr04) for 1 year. The control group (10/sex) received distilled water. A
second experiment involved three groups of 12 males and 9 female rats. One
group was given 25 ppm (25 mg/L) chromium (as K2Cr04); a second received 25
ppm chromium in the form of chromic chloride; and the controls again received
distilled water. No significant adverse effects were seen on appearance,
weight gain, or food consumption, and there were no pathologic changes in the
blood or other tissues in any treatment group. The rats receiving 25 ppm of
chromium (as K2Cr04) showed an approximate 20% reduction in water consumption.
This dose corresponds to 2.4 mg chromium(VI)/kg/day based on actual body
weight and water consumption data.
For rats treated with 0-11 ppm (in the diet), blood was examined monthly,
and tissues (livers, kidneys and femurs) were examined at 6 months and 1 year.
Spleens were also examined at 1 year. The 25 ppm groups (and corresponding
controls) were examined similarly, except that no animals were killed at 6
months. An abrupt rise in tissue chromium concentrations was noted in rats
treated with greater than 5 ppm. The authors stated that "apparently, tissues
can accumulate considerable quantities of chromium before pathological changes
result." In the 25 ppm treatment groups, tissue concentrations of chromium
were approximately 9 times higher for those treated with hexavalent chromium
than for the trivalent group.
Similar no-effect levels have been observed in dogs and humans. Anwar et
al. (1961) observed no significant effects in female dogs (2/dose group) given
up to 11.2 ppm chromium(VI) (as K2Cr04) in drinking water for 4 years. The
calculated doses were 0.012-0.30 mg/kg of chromium(VI). In humans, no adverse
health effects were detected (by physical examination) in a family of four
persons who drank for 3 years from a private well containing chromium(VI) at
approximately 1 mg/L (0.03 mg/kg/day for a 70-kg human).
------------------------------------------------------------------------------
o ORAL RFD UNCERTAINTY :
UF = 500. The uncertainty factor of 500 represents two 10-fold decreases in
dose to account for both the expected interhuman and interspecies variability
in the toxicity of the chemical in lieu of specific data, and an additional
factor of 5 to compensate for the less-than-lifetime exposure duration of the
principal study.
----------------------------------
------------------
o ORAL RFD MODIFYING FACTOR:
-------
Chromium VI
IRIS File
August 21. 1990
Page 3.of 17
------------------------------------------------------------------------------
o ORAL RFD COMMENTS:
This RfD is limited to metallic chromium(VI) of soluble salts. Examples
of soluble salts include potassium dichromate (K2CR207), sodium dichromate
(Na2Cr207), potassium chromate (K2Cr04) and sodium chromate (Na2Cr04).
Trivalent chromium is an essential nutrient. There is some evidence to
indicate that hexavalent chromium is reduced in part to trivalent chromium in
vivo (Petrilli and DeFlora, 1977, 1978; Gruber and Jennette, 1978).
The literature available on possible fetal damage caused by chromium
compounds is limited. No studies were located on teratogenic effects
resulting from ingestion of chromium.
------------------------------------------------------------------------------
o ORAL RFD CONFIDENCE:
Study: Low
Data Base: Low
RfD: Low
Confidence in the chosen study is low because of the small number of
animals tested, the small number of parameters measured and the lack of toxic
effect at the highest dose tested. Confidence in the data base is low because
the supporting studies are of equally low quality, and teratogenic and
reproductive endpoints are not well studied. Low confidence in the RfD
follows.
------------------------------------------------------------------------------
o ORAL RFD SOURCE DOCUMENT :
U.S. EPA. 1984. Health Effects Assessment for Hexavalent Chromium. Pre-
pared by the Office of Health and Environmental Assessment, Environmental
Criteria and Assessment Office, Cincinnati, OH for the Office of Solid Waste
and Emergency Response, Washington, DC.
U.S. EPA. 1985. Drinking Water Health Advisory for Chromium. Prepared by
the Office of Health and Environmental Assessment, Environmental Criteria and
Assessment Office, Cincinnati, OH for the Office of Drinking Water,
Washington, DC. (Draft)
------------------------------------------------------------------------------
o REVIEW DATES
o VERIFICATION DATE
o EPA CONTACTS:
Kenneth L. Bailey / ODW -- (202)382-5535 / FTS 382-5535
: 11/21/85, 02/05/86
: 02/05/86
Christopher T. DeRosa / ORD -- (513)569-7534 / FTS 684-7534
------------------------------------------------------------------------------
-------
Chromium VI
IRIS File
August 21. 1990
Page 4 of 17
------------------------------------------------------------------------------
REFERENCE DOSE FOR INHALATION EXPOSURE
o INHALATION RFD SUMMARY:
A risk assessment for this chemical is und~r review by an EPA work group.
I
------------------------------------------------------------------------------
EVIDENCE FOR HUMAN CARCINOGENICITY
o CLASSIFICATION : A: human carcinogen
o BASIS FOR CLASSIFICATION: Results.of occupational epidemiologic
studies
VI
of chromium-exposed workers are consistent
across investigators and study populations.
Dose- response relationships have been
established for chromium exposure and lung
cancer. Chromium-exposed workers are exposed
to both chromium III and chromium VI
compounds. In animal studies only chromium
o HUMAN CARCINOGENICITY DATA:
has been found to be carcinogenic: it was
concluded that only chromium VI can be
classified as a human carcinogen.
Sufficient. Epidemiologic studies of chromate production facilities in
the United States (Machle and Gregorius, 1948: Brinton et al., 1952: Mancuso
and Hueper, 1951, Mancuso, 1975: Baetjer, 1950a,b: Taylor, 1966: Enterline,
1974: Hayes et al., 1979: Hill and Ferguson, 1979), Great Britain (Bidstrup,
1951; Bidstrup and Case, 1956: Alderson et al., 1981), Japan (Watanabe and
Fukuchi, 1975; Ohsaki et al., 1978: Sano and Mitohara, 1978: Satoh et al.,
1981) and West Germany (Korallus et al., 1982: Bittersohl, 1971) have
established an association between chromium (Cr) exposure and lung cancer.
Most of these studies did not attempt to determine whether Cr III or Cr VI
compounds were the etiologic agents.
Three studies of the chrome pigment industry, one in Norway (Langard and
Norseth, 1975), one in England (Davies, 1978, 1979), and the third in the
Netherlands and Germany (Frentzel-Beyme, 1983) also found an association
between occupational chromium exposure (predominantly to Cr VI) and lung
cancer.
Results of two studies of the chromium plating industry (Royle, 1975;
Silverstein et al., 1981) were inconclusive, while the findings of a Japanese
study of chrome platers were negative (Okubo and Tsuchiya, 1979). The results
of studies of ferrochromium workers (Pokrovskaya and Shabynina, 1973: Langard
et al., 1980; Axe1sson et al., 1980) were inconclusive as to lung cancer risk.
------------------------------------------------------------------------------
o ANIMAL CARCINOGENICITY DATA:
Sufficient. Hexavalent chromium compounds were carcinogenic in animal
assays producing the following tumor types: intramuscular injection site
tumors in Fischer 344 and Bethesda Black rats and in C57BL mice (Furst et al.,
1976: Maltoni, 1974, 1976: Payne, 1960a,b: Heuper and Payne, 1959): intra-
-------
Chromium VI
IRIS File
August 21, 1990
Page ~ of 17
Dawley and Bethesda Black rats (Payne, 1960a,b: Heuper 1961: Heuper and Payne,
1962): intrabronchial implantation site tumors for various Cr VI compounds in
Wistar rats (Levy and Martin, 1983: Laskin et al., 1970: Levy as quoted in
NIOSH, 1975): and subcutaneous injection site sarcomas in Sprague-Dawley rats
(Maltoni, 1974, 1976). . .
------------------------------------------------------------------------------
o SUPPORTING DATA:
A larqe number of chromium compounds have been assayed in in vitro
genetic toxicology assays. In general, hexavalent chromium is mutagenic in
bacterial assays whereas trivalent chromium is not (Lofroth, 1978: petrillie
and Flora, 1977, 1978). Likewise Cr VI but not Cr III was mutagenic in yeasts
(Bonatti et al., 1976) and in V79 cells (Newbold et al., 1979). Chromium III
and VI compounds decrease the fidelity of DNA synthesis in vitro (Loeb et al.,
1977), while Cr VI compounds inhibit replicative DNA synthesis in mammalian
cells (Levis et al., 1978) and produce unscheduled DNA synthesis, presumably
repair synthesis, as a consequence of DNA damage (Raffetto, 1977). Chromate
has been shown to transform both primary cells and cell lines (Fradkin et al.,
1975: Tsuda and Kato, 1977: Casto et al., 1979). Chromosomal effects produced
by treatment with chromium compounds have been reported by a number of
authors: for example, both Cr VI and Cr III salts were clastogenic for
cultured human leukocytes (Nakamuro et al., 1978).
------------------------------------------------------------------------------
------------------------------------------------------------------------------
INHALATION EXPOSURE CARCINOGENICITY ASSESSMENT
o CLASSIFICATION : A: human carcinogen
o BASIS FOR CLASSIFICATION : Results of occupational
studies
epidemiologic
VI
of chromium-exposed workers are consistent
across investigators and study populations.
Dose- response relationships have been
established for chromium exposure and lung
cancer. Chromium-exposed workers are exposed
to both chromium III and chromium VI
compounds. In animal studies only chromium
has been found to be carcinogenic; it was
concluded that only chromium VI can be
classified as a human carcinogen.
: 1.2E-2/ug/cu.m
: Multistage, extra risk
o INHALATION UNIT RISK
o DOSE EXTRAPOLATION METHOD
o RISK/AIR CONCENTRATIONS:
Air Concentrations at Specified Risk Levels:
Risk Level
Concentration
--------------------
--------------
E-4 (1 in 10,000)
E-5 (1 in 100,000)
E-6 (1 in 1,000,000)
8E-3 ug/cu.m
8E-4 ug/cu.m
8E-5 ug/cu.m
-------
Chromium VI
IRIS File
August 21. 1990
Page ~ of 17
o INHALATION DOSE-RESPONSE DATA:
Species/Strain
Tumor Type
Dose
Tumor
Incidence
Reference
-----------------------------------------------------------------------------
human Route: Occupational exposure
(inhalation)
Age Midrange . Deaths from Person
(years) (ug/cu.m) Lung Cancer Years
50 5.66 3 1345 Mancuso,
25.27 6 931 1975
46.83 6 299
60 4.68 4 1063
20.79 5 712
39.08 5 211
70 4.41 2 401
21. 29 4 345
------------------------------------------------------------------------------
o ADDITIONAL COMMENTS:
The cancer mortality in Mancuso (1975) was assumed to be due to Cr VI,
which was further assumed to be no less than one-seventh of total chromium.
It was also assumed that the smoking habits of chromate workers were similar
to those of the U.S. white male population. Slope factors based on Langard et
ale (1980), Axelsson et ale (1980), and Pokrovskaya and Shabynina (1973)
result in air unit risk estimates of 1.3E-1, 3.5E-2 and 9.2E-2 ug/cu.m,
respectively.
Hexavalent chromium compounds have not produced lung tumors in animals
by inhalation. Trivalent chromium compounds have not been reported as car-
cinogenic by any route of administration.
The unit risk should not be used if the air concentration exceeds 8E-1
ug/cu.m, since above this concentration the slope factor may differ from
that stated.
------------------------------------------------------------------------------
o DISCUSSION OF CONFIDENCE:
Results of studies of chromium exposure are consistent across investi-
gators and countries. A dose-relationship for lung tumors has been estab-
lished. The assumption that the ratio of Cr III to Cr VI is 6:1 may lead to
a 7-fold underestimation of risk. The use of 1949 hygiene data, which may
underestimate worker exposure, may result in an overestimation of risk.
Further overestimation of risk may be due to the implicit assumption that
the smoking habits of chromate workers were similar to those of the general
white male population, since it is generally accepted that the proportion of
smokers is higher for industrial workers than for the general population.
-------
Chromium VI
IRIS File
August 21. 1990
Page 7 of 17
----------------------
--------------------------------------------
CARCINOGENICITY ASSESSMENT DOCUMENTATION AND REVIEW
o CARCINOGENICITY SOURCE:
Mancuso, T.F. 1975. International Conference on Heavy Metals in the Envi-
ronment. Toronto, Ontario, Canada.
u.S. EPA. 1984. Health Assessment Document for Chromium. Prepared by
the Office of Health and Environmental Assessment, Environmental Criteria
and Assessment Office, Cincinnati, OH. EEA 600/8-83-014F.
The quantification of cancer risk in the 1984 Health Assessment Document
has received peer review in public sessions of the Environmental Health Com-
mittee of the U.S. EPA's Science Advisory Board.
DOCUMENT
------------------------------------------------------------------------------
o REVIEW DATES
o VERIFICATION DATE
o EPA CONTACTS:
: 06/26/86
: 06/26/86
Herman J. Gibb 1 ORe -- (202)382-5898 1 FTS 382-5898
Chao W. Chen / ORe -- (202)382-5719 1 FTS 382-5719
------------------------------------------------------------------------------
------------------------------------------------------------------------------
ONE-DAY HEALTH ADVISORY
NOTE:
All chromium HAs are based on total chromium (III and VI) .
------
Appropriate data for calculating a One-day HA are not available. It is
recommended that the Ten-day HA of 1.4 mg/L be used as the One-day HA.
------------------------------------------------------------------------------
------------------------------------------------------------------------------
TEN-DAY HEALTH ADVISORY
NOTE:
All chromium HAs are based on total chromium (III and VI) .
------
Ten-day HA -- 1.4E+0 mg/L
NOAEL -- 14.4 mq/kg/day
UF -- 100 (allows for interspecies and intrahuman variability
a NOAEL from an animal study)
Assumptions -- 1 L/day water consumption for a 10-kg child
Principal Study -- Gross and Heller, 1946
-------
Chromium VI
IRIS File
August 21. 1990
Page ~ of 17
Rats were exposed to drinking water containing Cr(VI) (K2Cr04) at levels
of 80 or 134 mg Cr(VI)/L for 60 days (8.3 or 14.4 mg Cr(VI)/kg/day,
respectively) without adverse effects. Therefore, a NOAEL Qf 14.4 mg/kg/day
is identified. .
------------------------------------------------------------------------------
b,
------------------------------------------------------------------------------
LONGER-TERM CHILD HEALTH ADVISORY
NOTE:
All chromium HAs are based on total chromium (III and VI) .
-----
Longer-term (Child) HA -- 2.4E-1 mg/L
NOAEL -- 2.4 mg/kg/day
OF -- 100 (allows for interspecies and intrahuman variability with the
a NOAEL from an animal study)
Assumptions -- 1 L/day water consumption for a 10-kg child
.use of
Principal study -- MacKenzie et al., 1958
In a 1-year drinking water study, consumption of water containing either
Cr(III) (CrCl3) or Cr(VI) (K2Cr04) (0 to 1.87 mg/kg/day for male rats and 0 to
2.41 mg/kg/day for female rats) produced no significant differences in weight
gain, appearance, or pathological changes in the blood or other tissue.
Therefore, a NOAEL of 2.41 mg/kg/day is identified.
------------------------------------------------------------------------------
------------------------------------------------------------------------------
LONGER-TERM ADULT HEALTH ADVISORY
NOTE:
All chromium HAs are based on total chromium (III and VI).
------
Longer-term (Adult) HA -- 8.4E-l mg/L
NOAEL -- 2.4 mg/kg/day
OF -- 100 (allows for interspecies and intrahuman variability
a NOAEL from an animal study)
Assumptions -- 2 L/day water consumption for a 70-kg adult
with the use of
Principal study -- MacKenzie et al., 1958
(study described in HALTC)
------------------------------------------------------------------------------
------------------------------------------------------------------------------
LIFETIME HEALTH ADVISORY
NOTE:
All chromium HAs are based on total chromium (III and VI) .
-----
Drinking Water Equivalent Level (DWEL) -- 1.7E-l mg/L
-------
Chromium VI
IRIS File
August 21. 1990
Page 9.of 17
RiD Verification Date = 02/05/86
(see RDO)
Lifetime HA -- 1.2E-1 mg/L
Assumptions -- 71% exposure by drinking water
Principal study -- MacKenzie et al., 1958 (This study was used in the
derivation of the chronic oral RiD: see RDO)
------------------------------------------------------------------------------
--------.......
--------------------------------------------------------------
ORGANOLEPTIC PROPERTIES
No data available
------------------------------------------------------------------------------
------------------------------------------------------------------------------
DRINKING WATER ANALYTICAL PROCEDURES
Determination of chromium is by an atomic absorption technique using
either direct aspiration into a flame or a furnace.
------------------------------------------------------------------------------
------------------------------------------------------------------------------
DRINKING WATER TREATMENT
The treatment technologies that are available to remove chromium from
water include coagulation/filtration, lime softening, ion exchange, and
reverse osmosis.
------------------------------------------------------------------------------
------------------------------------------------------------------------------
HEALTH ADVISORY DOCUMENTATION AND REVIEW
o HEALTH ADVISORY SOURCE:
u.S. EPA. 1985. Drinking Water Criteria Document on Chromium.
Drinking Water, Washington, DC. (Draft)
DOCUMENT
Office of
------------------------------------------------------------------------------
o HEALTH ADVISORY REVIEW :
EPA review of HAs in 1985.
Public review of HAs following notification of availability in October, 1985.
Scientific Advisory Panel review of HAs in January, 1986.
------------------------------------------------------------------------------
-------
Chromium VI
IRIS File
August 21. 1990
Page 10 of 17
Kenneth Bailey / ODW -- (202)382-5535 / FTS 382-5535
Edward V. Ohanian / ODW -- (202)382-7571 / FTS 382-7571
------------------------------------------------------------------------------
------------------------------------------------------------------------------
l
------------------------------------------------------------------------------
CLEAN AIR ACT REQUIREMENTS
Action --
Intent to list under Section 112
Considers technological or economic feasibility? -- NO
Discussion -- Chromium VI is considered a human carcinogen (IARC Group I),
and according to EPA's preliminary risk assessment from ambient air exposures,
public health risks are significant. There is considerable uncertainty as to
the carcinogenicity of other valence states of chromium and the proportion of
chromium VI in emission or ambient air samples. The EPA indicated that it
intends to add total chromium or chromium VI to the list of hazardous air
pollutants for which it intends to establish emission standards under section
l12(b) (1) (A) of the Clean Air Act. The EPA will decide whether to add total
chromium or chromium VI to the list only after studying possible techniques
that might be used to control emissions and further assessing the public
health risks. The EPA will add total chromium or chromium VI to the list if
emission standards are warranted.
Reference --
50 FR 24317 (06/10/85)
EPA Contact -- Emissions Standards Division, OAQPS
(919)541-5571 / FTS 629-5571
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
AMBIENT WATER QUALITY CRITERIA FOR HUMANS
Water and Fish Consumption --
Fish Consumption Only -- None
5.0E+l ug/L
Considers technological or economic feasibility? -- NO
Discussion --
Reference --
45 FR 79318 (11/28/80)
EPA Contact -- Criteria and Standards Division, OWRS
(202)475-7315 / FTS 475-7315
-------
Chromium VI
IRIS File
August 21. 1990
Page 11. of 17
------------------------------------------------------------------------------
AMBIENT WATER QUALITY CRITERIA FOR AQUATIC ORGANISMS
"
Freshwater:
Acute -- 1.6E+1 ug/L (1-hour average)
Chronic -- 1.1E+1 ug/L (4-day average)
Marine:
Acute -- 1.1E+3 ug/L (1-hour average)
Chronic -- 5.0E+1 ug/L (4-day average)
Considers technological or economic feasibility? -- NO
Discussion --
Reference --
50 FR 30784 (07/28/85)
EPA Contact -- Criteria and Standards Division, OWRS
(202)475-7315 / FTS 475-7315
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
MAXIMUM CONTAMINANT LEVEL GOAL
Value (status) --
0.12 mg/L [total chromium]
(Proposed, 1985)
Considers technological or economic feasibility? -- NO
Discussion -- An MCLG of 0.12 mg/L for total chromium (Cr III and Cr VI) is
proposed based on a provisional DWEL of 0.17 mg/L with data on human exposure
factored in (0.10 mg/day in the diet and 0 mg/day by air). A DWEL of 0.17
mg/L was calculated from a NOAEL of 2.41 mg/kg/day in rats [l-year drinking
water study (Cr VI)], with an uncertainty factor of 500 applied and
consumption of 2 L of water/day assumed.
Reference --
50 FR 46936 Part IV (11/13/85)
EPA Contact -- Kenneth Bailey / Criteria and Standards Division, ODW /
(202)382-7571 / FTS 382-7571; or Drinking Water Hotline / (800)426-4791
------------------------------------------------------------------------------
------------------------------------------------------------------------------
MAXIMUM CONTAMINANT LEVEL
Value (status) --
0.05 mg/L [total chromium]
(Interim, 1980)
-------
Chromiwn VI
IRIS File
August 21. 1990
Page 12 of 17
Discussion --
Reference --
45 FR 57332
'-'
EPA Contact -- Kenneth Bailey / Criteria and Standards Division, ODW /
(202)382-7571 / FTS 382-7571; or Drinking Water Hotline / (800)426-4791
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
REPORTABLE QUANTITIES
Val ue (status) --
1 pound (Proposed, 1987)
Considers technological or economic feasibility? -- NO
Discussion -- The proposed RQ for chromium is based on potential
carcinogenicity. Available epidemiological data on inhalation of hexavalent
chromium indicate a hazard ranking of high based on a potency factor of
388. 99/mg/kg/day and assignment to weight-of-evidence group A. This
corresponds to an RQ of 1 pound.
Reference -- 52 FR 8140 (03/16/87)
EPA Contact -- RCRA/Superfund Hotline
(800)424-9346 / (202)382-3000 / FTS 382-3000
------------------------------------------------------------------------------
------------------------------------------------------------------------------
RCRA REQUIREMENTS
Status -- Listed
Reference -- 52 FR 25942 (07/09/87)
EPA Contact -- RCRA/Superfund Hotline
(800)424-9346 / (202)382-3000 / FTS 382-3000
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
TOXIC SUBSTANCES CONTROL ACT REQUIREMENTS
No data available
------------------------------------------------------------------------------
-------
O~ REFERENCE DOSE
REFERENCES
ORAL REFERENCE DOSE
REFERENCES
ORAL REFERENCE DOSE
REFERENCES
ORAL REFERENCE DOSE
REFERENCES
ORAL REFERENCE DOSE
REFERENCES
ORAL REFERENCE DOSE
REFERENCES
ORAL REFERENCE DOSE
REFERENCES
INHAIATION REFERENCE DOSE
REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
CARCINOGENICITY
ASSESSMENT REFERENCES
Chromium VI
IRIS File
August 21. 1990
Page 1~ of 17
Anwar, R.A., F.F. Langham, C.A. Hoppert, B.V.
Alfredson and R.U. Byerrum. 1961. Chronic toxicity
studies. III. Chronic toxicity of cadmium and
chromium in dogs. Arch. Environ~ 3: 456-460.
Gruber, J.E. and K.W. Jennette. 1978. Metabolism
of the carcinogen chromate by rat liver
micro somes. Biochern. Biophys. Res. Commun. 82(2):
700-706.
MacKenzie, R.D., R.U. Byerrum, C.F. Decker, C.A.
Hoppert and R.F Langham. 1958. Chronic toxicity
studies. II. Hexavalent and trivalent chromium
administered in drinking water to rats. Am. Med.
Assoc. Arch. Ind. Health. 18: 232-234.
Petrilli, F.L. and S. DeFlora. 1977. Toxicity and
mutagencity of hexavalent chromium on Salmonella
typhimurium. Appl. Environ. Microbiol. 33(4):
805-809.
Petrilli, F.L. and S. DeFlora. 1978. Oxidation of
inactive trivalent chromium to the mutagenic
hexavalent form. Mutat. Res. 58(2-3): 167-178.
U.S. EPA. 1984. Health Effects Assessment for
Hexavalent Chromium. Prepared by the Office of
Health and Environmental Assessment, Environmental
Criteria and Assessment Office, Cincinnati, OH for
the Office of Solid Waste and Emergency Response,
Washington, DC.
U.S. EPA. 1985. Drinking Water Health Advisory for
Chromium. Prepared by th~ Office of Health and
Environmental Assessment, Environmental Criteria
and Assessment Office, Cincinnati, OH for the
Office of Drinking Water, Washington, DC.
None
Alderson, M.R., N.S. Rattan and L. Bidstrup. 1981.
Health of workmen in the chromate-producing
industry in Britain. Br. J. Ind. Med. 38: 117-124.
Axelsson, G., R. Rylander and A. Schmidt. 1980.
Mortality and incidence of tumours among
ferrochromium workers. Br. J. Ind. Med. 37:
121-127.
Baetjer, A.M. 1950a.
chromate workers. I.
and report of cases.
2(5): 487-504.
Baetjer, A.M. 1950b. Pulmonary carcinoma in
chromate workers. II. Incidence on basis of
hospital records. Arch. Ind. Hyg. Occup. Med.
2(5): 505-516.
Bidstrup, P.L. 1951. Carcinoma of the lung in
chromate workers. Br. J. Med. 8: 302-305.
Bidstrup, P.L. and R.A.M. Case. 1956. Carcinoma of
the lung in workmen in the biChromates-producing
industry in Great Britain. Br. J. Ind. Med. 13:
260-264.
Bittersohl, G. 1971. Epidemiological research of
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Pulmonary carcinoma in
A review of the literature
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Chromium VI
IRIS File
August 21. 1990
Page 1~ of 17
Geschwulstforschl. 38 (3-4): 198-209.
Bonatti, S., M. Meini and A. Abbondandolo. 1976.
Genetic effects of potassium dichromate in
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Brinton, H.P., E.S. Frasier and A.L. Koven. 1952.
Morbidity and mortality experience among chromate
workers. Public Health Rep. 67(9): 835-847.
Casto, B.C., J. Meyers and J.A. DiPaolo. 1979.
Enhancement of viral transformation for evaluation
of the carcinqgenic or mutagenic potential of
inorganic metal salts. Cancer Res. 39: 193-198.
Davies, J.M. 1978. Lung-cancer mortality in
workers making chrome pigments. Lancet. 1: 384.
Davies, J.M. 1979. Lung cancer mortality of
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Enterline, P.E. 1974. Respiratory cancer among
chromate workers. J. Occup. Med. 16: 523-526.
Fradkin, A., A. Janoff, B.P. Lane and M. Kuschner.
1975. In vitro transformation of BHK21 cells grown
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Frentzel-Beyme, R. 1983. Lung cancer mortality of
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Furst, A., M. Schlauder and D.P. Sasmore. 1976.
Tumorigenic activity of lead chromate. Cancer Res.
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Hayes, R.B., A.M. Lilienfeld and L.M. Snell. 1979.
Mortality in chromium chemical production workers:
A prospective study. Int. J. Epidemiol. 8(4):
365-374.
Hueper, W.C. 1961. Environmental carcinogenesis
and cancers. Cancer Res. 21: 842-857.
Hueper, W.C. and W.W. Payne. 1959. Experimental
cancers in rats produced by chromium compounds and
their significance to industry and public health.
Ind. Hyg. J. 20: 274-280.
Heuper, W.C. and W.W. Payne. 1962. Experimental
studies in metal carcinogenesis: Chromium, nickel,
iron, and arsenic. Arch. Environ. Health. 5:
445-462.
Hill, W.J. and W.S. Ferguson. 1979. Statistical
analysis of epidemiological data from a chromium
chemical manufacturing plant. J. Occup. Med.
21(2): 103-106.
Korallus, U., H. Lange, A. Ness, E. Wustefeld and
T. Zwingers. 1982. Relationships between
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Chromium VI
IRIS File
August 21. 1990
Page 15 of 17
of bronchial carinomas in workers producing
chromate pigments. Br. J. Ind. Med. 32: 62-65.
Langard, S., A. Anderson and B. Gylseth. 1980.
Incidence of cancer among ferrochromium and
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Laskin, S., M. Kuschner and R.T. Drew. 1970.
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Levis, A.G., M. Buttignol, V. Bianchi and G.
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Levy, L.S. and P.A. Martin. 1983. The effects of a
range of chromium- containing materials on rat
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Loeb, L.A., M.A. Sirover and S.S. Agarwal. 1977.
Infidelity of DNA synthesis as related to
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Mancuso, T.F. and W.C. Hueper. 1951. Occupational
cancer and other health hazards in a chromate
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Kurata. 1978. Comparative studies of chromosomal
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Chromium VI
IRIS File
August 21. 1990
Page 1.6 of 17
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HEALTH ADVISORY
REFERENCES
HEALTH ADVISORY
REFERENCES
Chromium VI
IRIS File
August 21. 1990
Page 1~ of 17
--
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NAME OF SUBSTANCE
CAS REGISTRY NUMBER
SYNONYMS
SYNONYMS
SYNONYMS
MOLECULAR FORMULA
WISWESSER LINE NOTATION
RTECS NUMBER
OHM-TADS NUMBER
EPA HAZARDOUS WASTE
NUMBER
20 Mall Road
Bur.lington. MA 01803
(6171229-9922
Chromium
Toxicological ProOle
891219
Reviewed by SRP on 3/17/89
Field update on 05/18/90, 1 field
added/edited/deleted.
Field update on 12/29/89, 1 field
added/edited/deleted.
Complete Update on 12/19/89, 1 field
added/edited/deleted.
Complete Update on 11/28/89, 86 fields
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Field Update on 10/03/89, 1 field
added/edited/deleted.
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added/edited/deleted.
Complete Update on 05/02/85
115077
CHROMIUM
7440-47-3
CHROM (GERMAN) **PEER REVIEWED**
CHROME **PEER REVIEWED**
CHROME (FRENCH) **PEER REVIEWED**
Cr **PEER REVIEWED**
CR **QC REVIEWED**
NIOSH/GB4200000
7216647
D007; A waste containing chromium may (or may not)
be characterized a hazardous waste following
testing by the Toxicant Extraction Procedure as
prescribed by the Resource Conservation and
Recovery Act (RCRA) regulations.
METHODS OF MANUFACTUIUNG
OBTAINED FROM CHROME ORE, CHROMITE (FECR204), BY A SILICOTHERMIC OR
ALUMINOTHERMIC PROCESS. ... CHROMIUM, MJ UDY, ED, ACS MONOGRAPH SERIES,
NO 132 (REINHOLD, NEW YORK, 1956) VOL 1, 433 PP; VOL 2, 402 PP;
ROLLINSON... COMPREHENSIVE INORG CHEMISTRY VOL 3, JC BAILAR, JR ...
(PERGAMON PRESS, OXFORD, 1973) PP 623-700. [The Merck Index. 10th ed.
Rahway, New Jersey: Merck Co., Inc., 1983. , p. 317] **QC REVIEWED**
METHODS OF MANUFACTUIUNG
REDUCTION OF CHROMIC OXIDE BY ALUMINUM, SILICON OR CARBON & SUBSEQUENT
PURIFICATION; ELECTROLYSIS OF CHROMIC ACID OR AMMONIUM CHROME ALUMI~;
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Toxicological Profile
Chromium
August 21. 1990
Page:1. of 41
FERROCHRafiUM ALLOYS [SRI] **PEER REVIEWED**
FORMULATIONS/PREPARATIONS
PRODUCTION & DISTRIBUTION: CHROMIUM METAL IS AVAIL IN USA AS
ELECTROLYTIC CHROMIUM (99.5% CR), ALUMINOTHERMIC CHROMIUM (98. 5% CR) &
DUCTILE CHROMIUM (99.99% CR). [IARC. Monographs on the Evaluation of
the Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-1985.
(Multivolume work). V2103 (1973)] **PEER REVIEWED**
FORMULATIONS/PREPARATIONS
F0'RMS ~.v~.!LABLE: (1) CHROMIUM METAL AS LUMPS, GRANULES, OR POWDER; (2)
HIGH OR LOW CARBON FERRO-CHROMIUM; . (3) SINGLE CRYSTALS, HIGH PURITY
CRYSTALS, OR POWDER RUN 99.97% PURE. [Sax, N.I. and R.J. Lewis, Sr.
(eds.). Hawley's Condensed Chemical Dictionary. 11th ed. New York: Van
Nostrand Reinhold Co., 1987. , p. 280] **PEER REVIEWED**
MANUFACTURERS
ALFA Products, Morton Thiokol Inc, 152 Andover St, Danvers, MA 01923,
(617) 777-1970, (800)343-0660 [McCurdy, P.P. (ed.). Chemical Week
Buyer's Guide '88. New York, NY: McGraw-Hill Inc., 1988. , p. 205]
**PEER REVIEWED**
MANUFACTURERS
Anderson Physics Labs, Inc, 406 N Busey Ave, Urbana, IL 61801-2598,
(217) 356-1347 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide '88.
New York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
Aran Isles Chemicals Inc, 1 Marbee Rd, Rockport, MA 01966, (617)
546-3439 [Van, H. and C.A. Deyrup (eds.). OPD Chemical Buyer's
Directory 1988. 75th ed. New York, NY: Schnell Publishing Co., Inc.
1988. , p. 184] **PEER REVIEWED**
MANUFACTURERS
Atlantic Equip Engineers Div of Micron Metals, Inc, 297 S Washington
Ave, PO Box 181, Bergenfie1d, NJ 07621, (201) 384-5606, [Kuney, J.H.
and J.N. Nullican (eds.) Chemcyclopedia. Washington, DC: American
Chemical Society, 1988. , p. 180] **PEER REVIEWED**
MANUFACTURERS
Atomergic Chemetals Corp, 91 Carolyn Blvd, Farrningdale NY 11735-1527,
(516) 694-9000 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide '88.
New York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
Belmont Metals Inc, 322 Belmont Ave, Brooklyn, NY 11207, (718) 342-4900
[McCurdy, P.P. (ed.). Chemical Week Buyer's Guide '88. New York, NY:
McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
Cerac, Inc, PO Box 1178, 407 N 13th St, Milwaukee, WI 53201, (414)
289-9800 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide '88. New
York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
Chernal10y Co, Inc, County Line & Railroad Ave, Bryn Mawr, PA 19010,
(215) 527-3700 [Van, H. and C.A. Deyrup (eds.). OPD Chemical Buyer's
Directory 1988. 75th ed. New York, NY: Schnell Publishing Co., Inc.
1988. , p. 184] **PEER REVIEWED**
MANUFACTURERS
Elkem Metals Co, Park West Office Center, PO Box 266, Pittsburgh, pa
15230 (412) 778-3600 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide
'88. New York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED*-
MANUFACTURERS .
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Toxicological Profile
Chromiwn
August 21. 1990
Page 3 of 41
~
[Kuney, J.H. and J.N. Nullican (eds.) Chemcyclopedia. washington, DC:
American Chemical Society, 1988. , p. 180] **PEER REVIEWED**
MANUFACTURERS
Metalsmart, PO Box 1267, Great Neck, NY 11023, (516)"482-1624 [McCurdy,
P.P. (ed.). Chemical Week Buyer's Guide '88. New York, NY: McGraw-Hill
Inc., 1988. , p. 205J **PEER REVIEWED**
MANUFACTURERS
Noah Chemical Div, Noah Technologies Corp, 7001 Fairgrounds Parkway,
San Antonio, TX 78238, (512) 521-3323 [McCurdy, P.P. (ed.). Chemical
Week Buyer's Guide '88. New York, NY: McGraw-Hill Inc., 1988. , p. 205]
**PEER REVIEWED**
MANUFACTURERS
Reade Metals & Minerals Corp, 45 West River Rd, Suite 203, Rumson, NJ
07760, (201) 842-2294 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide
'88. New York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
Sharpe Chemicals Co, 1116 S Varney St, Burbank, CA 91502, (818)
841-7605 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide '88. New
York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
United Mineral & Chem Corp, 129 Hudson St, New York NY 10013, (212)
966-4330 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide '88. New
York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
Var-Lac-oid Chem Co, Inc, 13 Foster St, PO Box 181, Bergenfield, NJ
07621 (201) 387-0038 [McCurdy, P.P. (ed.). Chemical Week Buyer's Guide
'88. New York, NY: McGraw-Hill Inc., 1988. , p. 205] **PEER REVIEWED**
MANUFACTURERS
Weinstein Chemicals Inc, 666 Baker St, Suite 353, Costa Mesa, CA 92626,
(714) 754-0901 [Van, H. and C.A. Deyrup (eds.). OPD Chemical Buyer's
Directory 1988. 75th ed. New York, NY: Schnell Publishing Co., Inc.
1988. , p. 184] **PEER REVIEWED**
OTHER MANUFACTURING INFORMATION
THE SILVER SOLDERED STAINLESS STEEL WIRE CORRODED MORE THAN THE
COBALT-CHROMIUM TYPE, & RELEASED MORE NICKEL & CHROMIUM THAN DID THE
COBALT-CHROMIUM WIRES. [BERGE M ET AL; ACTA ODONTOL SCAND 40 (2): 75
(1982)] **PEER REVIEWED**
OTHER MANUFACTURING INFORMATION
Eleven plants manufacture chrome pigments, individually producing 9-79
metric tons/day. Industry wide production= 64,500 metric tons, 60% from
two plants in NE United States. /Chrome pigments/ [USEPA; Background
Document, Resource Conservation and Recovery Act Subtitle C:
Identification and Listing of Hazardous Waste p.189 (1980)J **PEER
REVIEWED**
MAJOR USES
INCR RESISTANCE & DURABILITY OF METALS; CHROMEPLATING OTHER METALS [The
Merck Index. 10th ed. Rahway, New Jersey: Merck Co., Inc., 1983. , p.
317] **PEER REVIEWED**
MAJOR USES
NUCLEAR & HIGH TEMPERATURE RESEARCH [Sax, N.I. and R.J. Lewis, Sr.
(eds.). Hawley's Condensed Chemical Dictionary. 11th ed. New York: Van
Nostrand Reinhold Co., 1987. , p. 280J **PEER REVIEWED**
MAJOR USES
Pigments for floor covering products, paper, cement, and asphalt
roofing. /Total chromium/ [USEPA; Background Document, Resource
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Toxicological Profile
Chromium
August 21. 1990
Page 4 of 41
Hazardous Waste p.189 (1980)] **PEER REVIEWED**
MAJOR USES
Used in coloring glass an emerald color. [Weast, R.C. (ed.) Handbook of
Chemistry and Physics, 68th ed. Boca Raton, Florida: .CRC Press Inc.,
1987-1988. B-13] "PEER REVIEWED** ..
MAJOR USES .
COMPONENT OF STAINLESS & HEAT RESISTING STEELS COMPONENT OF STAINLESS &
HEAT RESISTING STEELS [SRI] **PEER REVIEWED**
MAJOR USES
COMPONENT OF FULL ALLOY' STEEL [SRI] "PEER REVIEWED**
MAJOR USES
COMPONENT OF HIGH STRENGTH, LOW AJ.:LoY', & ELECTRIC STEELS [SRI] "PEER
REVIEWED**
MAJOR USES
COMPONENT OF SUPERALLOY'S, CAST IRONS, & CARBON STEEL [SRI] **PEER
REVIEWED * *
MAJOR USES
COMPONENT OF OTHER ALLOY'S-EG, NONFERROUS & MAGNETIC [SRI] **PEER
REVI EWED * *
MAJOR USES
COMPONENT OF TOOL STEEL & WELDING MATERIALS [SRI] "PEER REVIEWED**
MAJOR USES
1) Use in fabrication of alloys; 2) use in preparation of alloy steels
to enhance corrosion and heat resistance; 3) use in fabrication of
plated products for decoration or increased wear resistance; 4) use in
production of non-ferrous alloys to impart special qualities to the
alloys; S) use in production and processing of insoluble salts; 6) use
as chemicai intermediates; use in textile industry in dyeing, silk
treating, printing, and moth proofing wool; 7) use in leather industry
in tanning; use in photographic fixing baths; 8) use as catalysts for
halogenation, alkylation, and catalytic cracking of hydrocarbons; and
9) use as fuel additives and propellant additives; in ceramics.'
IChromium metal and insoluble chromium saltsl [Mackison, F. W., R. S.
Stricoff, and L. J. Partridge, Jr. (eds.). NIOSH/OSHA - Occupational
Health Guidelines for Chemical Hazards. DHHS (NIOSH) Publication, p. 3]
**PEER REVIEWED**
MAJOR USES
Chromium and its compounds are used in metal alloys such as stainless
steel; protective coatings on metal; magnetic tapes; and pigments for
paints, cement, paper, rubber, composition floor covering and other
materials. Other uses include organic chemical synthesis, photochemical
processing and industrial water treatment. In medicine, chromium
compounds are used in astringents and antiseptics. IChromium and its
compoundsl [DHHS/NTP; Fourth Annual Report On Carcinogens p.S8 (1985)
NTP 85-002] **PEER REVIEWED**
MAJOR USES
Chromium encounters many industrial applications, including its uses in
steel and nonferrous alloys, metal-plating, refractory materials,
chromate pigments and chromate preservatives. IChromiuml [Baselt RC;
Biological Monitoring Methods for Industrial Chemicals p.81 (1980)]
**PEER REVIEWED** .
MAJOR USES
CONSTITUENT OF INORG PIGMENTS. ITOTAL CHROMIUMI [Sax, N. I. and R. J.
Lewis, Sr. (eds.). Hawley's Condensed Chemical Dictionary. 11th ed. Ne~
York: Van Nostrand Reinhold Co., 1987. , p. 280] **PEER REVIEWED**
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Toxicological Profile
Chromium
August 21. 1990
Page ~ of 41
t
SENSITIZER IN PHOTOGRAPHIC INDUSTRY; PREPARATION OF CHROMATES. /TOTAL
CHROMIUM/ [Browning, E. Toxicity of Industrial Metals. 2nd ed. New
York: Appleton-Century-Crofts, 1969. , p. 120] **PEER REVIEWED**
MAJOR USES . .
(51)Chromium is used as a radioisotopic tracer. /(51)Chromium isotope/
[NAS; Medical and Biological Effects of Environmental Pollutants:
Chromium p.3 (1974)] **PEER REVIEWED**
CONSUMPTION PATTERNS
A recent study has projected a 3.4% growth in USA chromium (Cr)
consumption leading to a total USA chromium (Cr) demand in the yr 2000
of 10X10+6 metric tons. [Kirk-othmer Encyclopedia of Chemical
Technology. 3rd ed., Volumes 1-26. New York, NY: John Wiley and Sons,
1978-1984. 4(78) 58] **PEER REVIEWED**
CONSUMPTION PATTERNS
(1976) Total consumption in USA= 3.27X10+5 metric tons. [Kirk-othmer
Encyclopedia of Chemical Technology. 3rd ed., Volumes 1-26. New York,
NY: John Wiley and Sons, 1978-1984. 4(78) 58] **PEER REVIEWED**
CONSUMPTION PATTERNS
STAINLESS & HEAT RESISTING STEELS, 71.4%; FULL ALLOY STEEL, 15.2%; HIGH
STRENGTH, LOW ALLOY & ELECTRIC STEELS, 3.1%; SUPERALLOYS, 2.8%; CAST
IRONS, 2.6%; CARBON STEEL, 2.4%; OTHER, 2.5% (1982, CHROMIUM & CHROMIUM
ALLOY USE) [SRI] **PEER REVIEWED**
CONSUMPTION PATTERNS
Stainless and heat resisting steel, 76%; full alloy steel, 11%; super
alloys, 4% and other alloys, 9% (1986) /Consumption of chromium
ferroalloys, metal, and other chromium containing materials by end use/
[BUREAU OF MINES. MINERAL COMMODITY SUMMARIES 1987 p.34) *-PEER
REVIEWED**
U.S. PRODUCTION
(1986) No mine production [BUREAU OF MINES. MINERAL COMMODITY SUMMARIES
1987 p.34] **PEER REVIEWED**
U.S. PRODUCTION
(1986) 7.89x10+10 g /secondary production/ [BUREAU OF MINES. MINERAL
COMMODITY SUMMARIES 1987 p.34] **PEER REVIEWED**
U.S. IMPORTS
(1977) 2.22X10+9 G [SRI] **PEER REVIEWED**
U.S. IMPORTS
(1982) 1.68X10+9 G [SRI) **PEER REVIEWED**
U.S. IMPORTS
(1986) 3.96x10+11 9 [BUREAU OF MINES. MINERAL COMMODITY SUMMARIES 1987
p.34] **PEER REVIEWED**
U. S. EXPORTS
(1977) 4.96XlO+8 G [SRI] **PEER REVIEWED**
U. S. EXPORTS
(1982) 2.16X10+8 G [SRI] **PEER REVIEWED**
U. S. EXPORTS
(1986) 2.72x10+10 9 [BUREAU OF MINES. MINERAL COMMODITY SUMMARIES 1987
p.34] **PEER REVIEWED**
COLOR/FORM STEEL-GRAY, LUSTROUS METAL; BODY-cENTERED CUBIC
STRUCTURE [The Merck Index. 10th ed. Rahway, New
Jersey: Merck Co., Inc., 1983. , p. 317] **PEER
REVIEWED**
GRAY CRYSTALS [Sax, N. I. Dangerous Properties of
Industrial Materials. 6th ed. New York, NY: Van
Nostrand Reinhold, 1984. , p. 790) **PEER
REVIEWED**
-------
COLOR/FORM
ODOR
BOILING POINT
MELTING POINT
MOLECULAR WEIGHT
DENSITY/SPECIFIC GRAVITY
HEAT OF VAPORIZATION
SOLUBILITIES
SURFACE TENSION
VAPOR PRESSURE
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
Toxicological Profile
Chromium
August 21. 1990
Page ~ of 41
BLUE-WHITE HARD METAL [Clayton, G. D. and F. E.
Clayton (eds.). Patty's Industrial Hygiene and
Toxicology: Volume 2A, 2B, 2C: Toxicology. 3rd ed.
New York: John Wiley Sons, 1981.-1982. , p. 1593]
**PEER REVIEWED** .
Odorless [Mackison, F. W., R. S. Stricoff, and L.
J. Partridge, Jr. (eds.). NIOSH/OSHA -
Occupational Health Guidelines for Chemical
Hazards. DHHS (NIOSH) Publication, p. 1] **PEER
REVIEWED * *
2642 DEG C [TQe Merck Index. 10th ed. Rahway, New
Jersey: Merck Co., Inc., 1983. , p. 317] **QC
REVIEWED * *
1900 DEG C [The Merck Index. 10th ed. Rahway, New
Jersey: Merck Co., Inc., 1983. , p. 317] **QC
REVIEWED**
51.996 [Weast, R.C. (ed.) Handbook of Chemistry
and Physics, 68th ed. Boca Raton, Florida: CRC
Press Inc., 1987-1988. B-85] **PEER REVIEWED**
7.14 [The Merck Index. 10th ed. Rahway, New
Jersey: Merck Co., Inc., 1983. , p. 317] **QC
REVIEWED * *
APPROX 81.7 KCAL/G-ATOM [The Merck Index. 10th ed.
Rahway, New Jersey: Merck Co., Inc., 1983. , p.
317] **PEER REVIEWED**
Insol in water [Sax, N.I. and R.J. Lewis, Sr.
. (eds.). Hawley's Condensed Chemical Dictionary.
11th ed. New York: Van Nostrand Reinhold Co.,
1987. , p. 280] **PEER REVIEWED**
1590 + or - 50 mN/m in vacuum at 1950 deg C
(Sessile drop method); 1700 + or - 50 mN/m in air
at melting point (Dynam drop wt method): 1520 mN/m
in air or Helium at 1800 deg C (Sessile drop
method) [Weast, R.C. (ed.) Handbook of Chemistry
and Physics, 68th ed. Boca Raton, Florida: CRC
Press Inc., 1987-1988. F-21] **PEER REVIEWED**
1 MM HG @ 1616 DEG C [Sax, N.I. Dangerous
Properties of Industrial Materials. 6th ed. New
York, NY: Van Nostrand Reinhold, 1984. , p. 790]
**QC REVIEWED**
HEAT OF FUSION: 3660 CAL/G MOLE: 62.1 CAL/G
[Weast, R.C. (ed.) Handbook of Chemistry and
Physics, 68th ed. Boca Raton, Florida: CRC Press
Inc., 1987-1988. B-218] **PEER REVIEWED**
LATENT HEAT OF FUSION: APPROX 3.5 KCAL/G-ATCI1;
HEAT CAPACITY (25 DEG C): 5.58 CAL/G-ATOM DEG [The
Merck Index. 10th ed. Rahway, New Jersey: Merck
Co., Inc., 1983. , p. 317] **PEER REVIEWED**
TAKES A HIGH POLISH; HARD AS CORUNDUM & LESS
FUSIBLE THAN PLATINUM [The Merck Index. 10th ed.
Rahway, New Jersey: Merck Co., Inc., 1983. , p.
317] **PEER REVIEWED**
ATOMIC NUMBER 24: VALENCES 1-6 [The Merck Index.
10th ed. Rahway, New Jersey: Merck Co., Inc.,
1983. , p. 317] **PEER REVIEWED**
-------
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
, Toxicological Profile
Chromium
August 21. 1990
Page 7 .of 41
IN SEVERAL DIFFERENT STATES [National Research
Council. Drinking Water & Health Volume 1.
Washington, DC: National Academy Press, 1977. , p.
241] **PEER REVIEWED** '.
UNDER STRONGLY OXIDIZING CONDITIONS, MAY BE
CONVERTED TO HEXAVALENT STATE & OCCUR AS CHROMATE
ANIONS [National Research Council. Drinking Water
& Health Volume 1. Washington, DC: National
Academy Press, 1977. , p. 242] **PEER REVIEWED**
IONIC (CRYSTAL) RADII (FOR COORDINATION NUMBER 6) :
0.69(+3) ANGSTROM, 0.52(+6) ANGSTROM rOsol, A.
(ed.). Remington's Pharmaceutical Sciences. 16th
ed. Easton, pennsylvania: Mack Publishing Co.,
1980. , p. 360] **PEER REVIEWED**
ELECTRONEGATIVITY (PAULING SCALE): 1. 6: ORBITAL
ELECTRONS: (AR)3D5-4S1; ABUNDANCE (% OF EARTH'S
CRUST): 2X10-2 rOsol, A. (ed.). Remington's
Pharmaceutical Sciences. 16th ed. Easton, .
Pennsylvania: Mack Publishing Co., 1980. , p. 360]
**PEER REVIEWED**
Chromium is a mixture of four stable isotopes with
mass numbers 50 (4.31%), 52 (83.76%), 53 (9.55%)
and 54 (2.38%). Thermal neutron capture cross
sections are 17, 0.8, 18 and 0.38, respectively.
[Lederer CM et al; Table of Isotopes 6th ed p.18
(1967) as cited in NAS; Medical and Biological
Effects of Environmental Pollutants: Chromium p.3
(1974)] **PEER REVIEWED**
Five radioistopes are known, two others (mass
numbers 46 & 47) have been reported. [NAS: Medical
and Biological Effects of Environmental
Pollutants: Chromium p.3 (1974)] **PEER REVIEWED**
Magnetic moments are slightly below the spin-only
value of 3.88 boro magneton. [NAS: Medcal and
Biological Effects of Environmental Pollutants:
Chromium p.4 (1974)] **PEER REVIEWED**
Linear coefficient of thermal expansion at 20 deg
C= 6.2XlO-6 [Kirk-othmer Encyclopedia of Chemical
Technology. 3rd ed., Volumes 1-26. New York, NY:
John Wiley and Sons, 1978-1984. 4(78) 56] **PEER
REVIEWED**
Thermal conductivity at 20 deg C, W(rnK)= 91
(Kirk-othmer Encyclopedia of Chemical Technology.
3rd ed., Volumes 1-26. New York, NY: John Wiley
and Sons, 1978-1984. 4(78) 56] **PEER REVIEWED**
Total emissivity at 100 deg C, nonoxidizing atrn=
0.08 (Kirk-othmer Encyclopedia of Chemical
Technology. 3rd ed., Volumes 1-26. New York, NY:
John Wiley and Sons, 1978-1984. 4(78) 56] **PEER
REVIEWED. *
Elastic modulus, GPa= 250. (Kirk-othmer
Encyclopedia of Chemical Technology. 3rd ed.,
Volumes 1-26. New York, NY: John Wiley and Sons,
1978-1984. 4(78) 56] **PEER REVIEWED**
Compressibility at 10-60 TPa= 70X10-3.
-------
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
OTHER CHEMICAL/PHYSICAL
PROPERTIES
ToxiCQlogical Profile
Chromium
August 21. 1990
Page 8 of 41
3rd ed., Volumes 1-26. New York, NY: John Wiley
and Sons, 1978-1984. 4(78) 56J **PEER REVIEWED**
BRITTLE METAL [The Merck Index. 10th ed. Rahway,
New Jersey: Merck Co., Inc., 1ge3. , p. 468J
**PEER REVIEWED** . .
Chromium forms a number of cmpd in various
oxidation states. Those of 2+ (chromous), 3+
(chromic) and 6+ (chranates) are the most
important /Chromium, alloys and cmpd/
[International Labour Office. Encyclopedia of
Occupational Health and Safety. Vols. 1&11.
Geneva, Switzerland: International Labour Office,
1983. , p. 468J **PEER REVIEWED**
Soluble in acids (except nitric) and strong
alkalies. [Sax, N.I. and R.J. Lewis, Sr. (eds.).
Hawley's Condensed Chemical Dictionary. 11th ed.
New York: Van Nostrand Reinhold Co., 1987. , p.
280J **PEER REVIEWED**
FIRE POTENTIAL
FIRE HAZARD: MODERATE, IN FORM OF DUST. [Sax, N.I. Dangerous Properties
of Industrial Materials. 6th ed. New York, NY: Van Nostrand Reinhold,
1984. , p. 790] **QC REVIEWED**
FIRE POTENTIAL
... WHEN FINELY DIVIDED BURNS RAPIDLY IF HEATED IN FLAME. [Browning, E.
Toxicity of Industrial Metals. 2nd ed. New York:
Appleton-Century-Crofts, 1969. , p. 119J **QC REVIEWED**
FIRE FIGHTING PROCEDURES
Respiratory protection from chromium metal and insoluble chromium salts
while fighting fires: self-contained breathing apparatus with a full
facepiece operated in pressure-demand or other positive pressure mode.
/Chromium metal and insoluble chromium salts/ [Mackison, F. W., R. S.
Stricoff, and L. J. Partridge, Jr. (eds.). NIOSH/OSHA - Occupational
Health Guidelines for Chemical Hazards. DHHS(NIOSH) Publication, p. 6]
**PEER REVIEWED**
EXPLOSIVE LIMITS AND POTENTIAL
FUSED AMMONIUM NITRATE WITH POWDERED METALS IS OFTEN A VIOLENT &
SOMETIMES AN EXPLOSIVE REACTION. ... CHROMIUM... REACTED IN THIS WAY.
[National Fire Protection Association. Fire Protection Guide on
Hazardous Materials. 9th ed. Boston, MA: National Fire Protection
Association, 1986. 49IM-22J **QC REVIEWED**
EXPLOSIVE LIMITS AND POTENTIAL
When Idustl is suspended in carbon dioxide atmospheres... lit isl
ignitable and explosive ... [Bretherick, L. Handbook of Reactive
Chemical Hazards. 3rd ed. Boston, MA: Butterworths, 1985. , p. 192J
**QC REVIEWED**
REACTIVITIES & INCOMPATIBILITIES
MOLTEN LITHIUM AT 180 DEG C ATTACKS VANADIUM, BERYLLIUM, OR CHROMIUM
SEVERELY. [National Fire Protection Association. Fire Protection Guide
on Hazardous Materials. 9th ed. Boston, MA: National Fire Protection
Association, 1986. 49IM-118] **QC REVIEWED**
REACTIVITIES & INCOMPATIBILITIES
VIOLENT DECOMP OF HYDROGEN PEROXIDE (52% BY WT OR GREATER) MAY BE
CAUSED BY CONTACT WITH... CHRaaUM ... & SALTS. [National Fire
Protection Association. Fire Protection Guide on Hazardous Materials.
9th ed. Boston, MA: National Fire Protection Association, 1986.
-------
Toxicological Profile
Chromium
August 21, 1990
Page 9 of 41
, .
REACTIVITIES & INCOMPATIBILITIES
REACTS WITH DIL HYDROCHLORIC ACID, SULFURIC ACID; NOT WITH NITRIC ACID:
ATTACKED BY CAUSTIC ALKALIES & ALKALI CARBONATES. [The Merck Index.
10th ed. Rahway, New Jersey: Merck Co., Inc., 1983. " p. 317] **PEER
REVIEWED** '
REACTIVITIES & INCOMPATIBILITIES
CHROMIUM IS ATTACKED VIGOROUSLY BY FUSED POTASSIUM CHLORATE, PRODUCING
VIVID INCANDESCENCE. PYROPHORIC CHROMIUM UNITES WITH SULFUR DIOXIDE
WITH INCANDESCENCE, PYROPHORIC CHROMIUM UNITES WITH NITRIC OXIDE WITH
INCANDESCENCE. [National Fire Protection Association. Fire Protection
Guide on Hazardous Materials. 9th ed. Boston, MA: National Fire
Protection Association, 1986. 49lM-66] **PEER REVIEWED**
REACTIVITIES & INCOMPATIBILITIES
/Chromium/ contact with /bromine pentaflouride (BrF5) / at ambient or
slightly elevated temp is violent, /with/ ignition often occuring.
[Bretherick, L. Handbook of Reactive Chemical Hazards. 3rd ed. Boston,
MA: Butterworths, 1985. , p. 93] **PEER REVIEWED**
REACTIVITIES & INCOMPATIBILITIES
Potentially hazardous incompatibility with strong oxidizers. /Chromium
metal and insoluble salts (as Cr)/ [NIOSH. Pocket Guide to Chemical
Hazards. 5th Printing/Revision. DHHS (NIOSH) Publ. No. 85-114.
Washington, D.C.: U.S. Dept. of Health and Human Services, , p. 82]
**PEER REVIEWED**
SKIN, EYE AND RESPIRATORY IRRITATIONS
Chromium aerosols ... caused ... irritation to the upper respiratory
tract. [Waldbott GL: Health Effects of Envir Poll p.201 (1973)] **PEER
REVIEWED**
SKIN, EYE AND RESPIRATORY IRRITATIONS
Chromium causes severe nasal irritation ... . [Arena, J.M. and Drew,
R.H. (eds.) Poisoning-Toxicology, Symptoms, Treatments. 5th ed.
Springfield, IL: Charles C. Thomas Publisher, 1986. , p. 873] **PEER
REVIEWED**
PROTECTIVE EQUIPMENT & CLOTHING
Gloves or rubber coats protect against chrome ulceration of the skin.
[Nat'l Research Council Canada: Effects of Chromium in the Canadian
Envir p.ll5 (1976) NRCC No.lS0l7] **PEER REVIEWED**
PROTECTIVE EQUIPMENT & CLOTHING
Employees should be provided with and required to use impervious
clothing, gloves, face shields (eight-inch m!n), and other appropriate
protective clothing necessary to prevent repeated or prolonged skin
contact with solids or liquids containing insol chromium salts. ...
Employees should be provided with and required to use dust and
splashproof safety goggles where solids or liquids containing insol
chromium salts may contact the eyes. /Chromium metal and insol chromium
salts/ [Mackison, F. W., R. S. Stricoff, and L. J. Partridge, Jr.
(eds. ). NIOSH/OSHA - Occupational Health Guidelines for Chemical
Hazards. DHHS (NIOSH) Publication, p. 3] **PEER REVIEWED**
PROTECTIVE EQUIPMENT' CLOTHING
Respirator selection: Upper limit respirator devices permitted by
NIOSH: Any detectable concn: any self-contained breathing apparatus
with a full facepiece and operated in a pressure-demand or other
positive pressure mode or any supplied-air respirator with a full
facepiece and operated in a pressure-demand or other positive pressure
mode in combination with an auxiliary self-contained breathing
apparatus operated in pressure-demand or other positive pressure mode;
-------
Toxicological Prome
Chromium
August 21. 1990
Page H> of 41
high-efficiency particulate filter or any appropriate escape-type
self-contained breathing apparatus. /Chromium metal and insoluble salts
(as Cr), carcinogenic Cr (VI) / [NIOSH. Pocket Guide to Chemical
Hazards. 5th Printing/Revision. DHHS (NIOSH) Publ. NO. 85-114.
Washington, D.C.: U.S. Dept. of Health and Human Services, , p. 83]
**PEER REVIEWED** .
PROTECTIVE EQUIPMENT & CLOTHING
Respirator selection: Upper limit respirator devices permitted: 0.25
mg/cu m: any supplied air respirator or any self-contained breathing
apparatus or any dust and mist respirator except single-use and
quarter4mask respirators: 0.625 mgJcu m: any powered air-purifying
respirator with a high-efficiency particulate filter or any
supplied-air respirator operated in a continuous flow mode: 1.25 mg/cu
m: any air-purifying full facepiece respirator with a high-efficiency
particulate filter or any powered air-purifying respirator with a
tight-fitting facepiece and a high-efficiency particulate filter or any
self-contained breathing apparatus with a full facepiece or any
supplied-air respirator with a full facepiece: 25 mg/cu m: any
supplied-air respirator with a half4mask and operated in a
pressure-demand or other positive pressure mode: 50 mg/cu m: any
supplied-air respirator with a full facepiece and operated in a
pressure-demand or other positive pressure mode: Emergency or planned
entry in unknown concn or IDLH conditions: any self-contained breathing
apparatus with a full facepiece and operated in a pressure-demand or
other positive pressure mode or any supplied-air respirator with a full
facepiece and operated in a pressure-demand or other positive pressure
mode in combination with an auxiliary self-contained breathing
apparatus operated in pressure-demand or other positive pressure mode:
escape: any air-purifying full facepiece respirator with a
high-efficiency particulate filter or any self-contained breathing
apparatus with a full facepiece. /Chromium metal and insoluble salts
(as Cr), noncarcinogenic Cr (VI)/ [NIOSH. Pocket Guide to Chemical
Hazards. 5th Printing/Revision. DHHS (NIOSH) Publ. No. 85-114.
Washington, D.C.: U.S. Dept. of Health and Human Services, , p. 83]
**PEER REVIEWED**
OTHER PREVENTIVE MEASURES
Daily washing of the inside of the nose combined with covering the
nasal septum with zinc or barium ointment should be sufficient to avoid
ulcerations and perforation of the septum. [Friberg, L., Nordberg,
G.F., Kessler, E. and Vouk, V.B. (eds). Handbook of the Toxicology of
Metals. 2nd ed. Vols I, II.: Amsterdam: Elsevier Science Publishers
B. V., 1986. V2 205] **PEER REVIEWED**
OTHER PREVENTIVE MEASURES
Contact lenses should not be worn when working with this chemical.
[NIOSH. Pocket Guide to Chemical Hazards. 2nd Printing. DHHS (NIOSH)
Publ. No. 85-114. Washington, D.C.: U.S. Dept. .of Health and Human
Services, NIOSH/Supt. , p. 83] **PEER REVIEWED**
OTHER PREVENTIVE MEASURES
Contact lens use in industry is controversial. A survey of 100
corporations resulted in the recommendation that each company establish
their own contact lens use policy. One presumed hazard of contact lens
use is possible chemical entrapment. /It was/ found that contact lens
minimized injury or protected the eye. The eye was afforded more
protection fram liquid irritants. Soft contact lenses do not worsen
corneal damage from strong chemicals and in some cases could actually
-------
Toxicological Profile
Chromiwn
August 21. 1990
Page 11 of 41
"
contact lenses in industrial environments as part of the standard eye
protection, eg, face shields; however, more data are needed to
establish the value of contact lenses. [Randolph SA, Zavon MR; J Occup
Med 29: 237-42 (1987)] **PEER REVIEWED** .
OTHER PREVENTIVE MEASURES .
Good industrial hygiene practices recommend that engineering controls
be used to reduce environmental. concentrations to the permissible
exposure level. ... In addition to respirator selection, a complete
respiratory protection program should be instituted which includes
regular training /sessions/, maintenance, inspection, cleaning, and
evaluation /of the equipment/. /Cluomium metal and insoluble chromium
salts/ [Mackison, F. W., R. S. Stricoff, and L. J. Partridge, Jr.
(eds.). NIOSH/OSHA - Occupational Health Guidelines for Chemical
Hazards. DHHS (NIOSH) Publication, p. 3] **PEER REVIEWED**
OTHER PREVENTIVE MEASURES
Control methods which may be effective include local exhaust
ventilation, general dilution ventilation, & personal protective
equipment. /Chromium metal and insol chromium salts/ [Mackison, F. W.,
R. S. Stricoff, and L. J. Partridge, Jr. (eds.). NIOSH/OSHA-
Occupational Health Guidelines for Chemical Hazards. DHHS(NIOSH)
Publication, p. 3] **PEER REVIEWED**
OTHER PREVENTIVE MEASURES
Persons not wearing protective equipment and clothing should be
restricted from areas of spills until cleanup has been completed.
/Chromiummetal and insoluble chromium salts/ [Mackison, F. W., R. S.
Stricoff, and L. J. Partridge, Jr. (eds.). NIOSH/OSHA - Occupational
Health Guidelines for Chemical Hazards. DHHS(NIOSH) Publication, p. 4]
**PEER REVIEWED**
OTHER PREVENTIVE MEASURES
Promptly remove non-impervious clothing that becomes contaminated.
/Chromium metal and insoluble salts (as Cr)/ [NIOSH. Pocket Guide to
Chemical Hazards. 5th Printing/Revision. DHHS (NIOSH) Publ. No. 85-114.
Washington, D.C.: U.S. Dept. of Health and Human Services, , p. 83]
**PEER REVIEWED**
OTHER PREVENTIVE MEASURES
SRP: Local exhaust ventilation should be applied wherever there is an
incidence of point source emissions or dispersion of regulated
contaminants in the work area. Ventilation control of the contaminant
as close to its point of generation is both the most economical and
safest method to minimize personnel exposure to airborne contaminants.
[CITATION] **PEER REVIEWED**
OTHER PREVENTIVE MEASURES
Eating and smoking should not be permitted in areas where solids or
liquids containing insoluble chromium salts are handled, processed, or
stored. /Chromium metal and insoluble chromium salts/ [Mackison, F. w.,
R. S. Stricoff, and L. J. Partridge, Jr. (eds.). NIOSH/OSHA -
Occupational Health Guidelines for Chemical Hazards. DHHS(NIOSH)
Publication, p. 3] **PEER REVIEWED**
CLEANUP METHODS
COLLECT SPILLED MATERIAL IN THE MOST CONVENIENT & SAFE MANNER & DEPOSIT
IN SEALED CONTAINERS FOR RECLAMATION OR FOR DISPOSAL IN A SECURED
SANITARY LANDFILL. LIQ CONTAINING CHRafiUM METAL OR INSOL CHRafiUM
SALTS SHOULD BE ABSORBED IN VERMICULITE, DRY SAND, EARTH, OR SIMILAR
MATERIAL. [Mackison, F. W., R. S. Stricoff, and L. J. Partridge, Jr.
(eds.). NIOSH/OSHA - Occupational Health Guidelines for Chemical
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Toxicological Profile
Chromium
August 21. 1990
Page 12 of 41
CLEANUP METHODS
WHERE POSSIBLE, WET METHODS OF CLEANING SHOULD BE USED; AT OTHER SITES,
THE ONLY ACCEPTABLE ALTERNATIVE IS BY VACUUM CLEANING. SPILLS OF LIQ OR
SOLID MUST BE REMJVED IMMEDIATELY TO PREVENT DISPERSION AS AIRBORNE
DUST. [International Labour Office. Encyclopedia of 'Occupational Health
and Safety. Vols. 1&11. Geneva, 'Switzerland: International Labour
Office, 1983. , p. 472] **PEER REVIEWED**
CLEANUP METHODS
If chromium metal or insoluble chromium salts are spilled, the
following steps should be taken: 1. Remove all ignition sources where
metallic chromium has been spilled. 2. Ventilate area of spill. 3)
Collect spilled material in the most convenient and safe manner and
deposit in sealed containers for reclamation or for disposal in a
secured sanitary landfill. Liquid containing chromium metal or
'insoluble chromium salts should be absorbed in vermiculite, dry sand,
earth, or a similar material. /Chromium metal and insoluble chromium
salts/ [Mackison, F. W., R. S. Stricoff, and L. J. Partridge, Jr.
(eds. ). NIOSH/OSHA - Occupational Health Guidelines for Chemical
Hazards. DHHS(NIOSH) Publication, p. 4] **PEER REVIEWED**
DISPOSAL METHODS
SRP: At the time of review, criteria for land treatment or burial
(sanitary landfil~) disposal practices are subject to significant
revision. Prior to implementing land disposal of waste residue
(including waste sludge), consult with environmental regulatory
agencies for guidance on acceptable disposal practices. [CITATION]
**PEER REVIEWED**
DISPOSAL METHODS
Precipitation is the preferred treatment process for removing toxic
heavy metals from electroplating waters. Precipitation processes
include hydroxide, lime and/or sulfide treatment. Chemical reduction is
used to treat complex metals such as nickel, copper, hexavalent
chromium waste, soluble lead, silver, metal containing cyanide, and
mercury. Adsorption has shown potential for treating and polishing
aqueous metal bearing wastes. Activated carbon, activated alumina, and
iron filings are all applicable adsorbents. Alkaline chlorination and
incineration are effective cyanide destruction treatments. Evaporation,
ion-exchange, reverse osmosis, electrodialysis, and electrolytic
recovery are waste reduction and recovery techniques applicable to
metal bearing hazardous streams. [Grosse DW; 12th Annual Research
Symposium on Land Disposal, Remedial Action, Incineration, and
Treatment of Hazardous Wastes (1986)] **PEER REVIEWED**
STABILITY/SHELF LIFE
NOT OXIDIZED BY AIR, EVEN IN PRESENCE OF MUCH M:)ISTURE [The Merck
Index. 10th ed. Rahway, New Jersey: Merck Co., Inc., 1983. , p. 317]
**QC REVIEWED**
TOXIC HAZARD RATING
Classification of carcinogenicity: 1) evidence in humans: inadequate:
2) evidence in animals: inadequate. Overall summary evaluation of
carcinogenic risk to humans is group 3: The chemical is not
classifiable as to its carcinogenicity to humans. /From table,
trivalent chromium cmpd/ [IARC. Monographs on the Evaluation of the
Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-1985.
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Toxicological Profile
Chromium
August 21. 1990
Page 1~ of 41
L
THE FOI.LCMING OVERVIEW IS A SUMMARY.
DATABASE FOR TREATMENT PURPOSES.
EMERGENCY MEDICAL TREATMENT
o LIFE SUPPORT:
CONSULT THE Ca1PLETE POISINDEX (R)
This overview assumes that basic life support measures have
been instituted.
o CLINICAL EFFECTS:
SUMMARY
o Oral ingestion produces gastrointestinal corrosion and
acute multisystem shock, followed by renal failure,
hemorrhagic diathesis, and hepatic injury within several
days.
HEENT
o Oral burns and severe corneal injury may result from
acute exposure. Chronic inhalation produces deep
perforating nasal ulcers (chrome holes).
CARDIOVASCULAR
o Circulatory collapse and shock are frequently reported
following overdose.
RESPIRATORY
o Pulmonary edema, pneumonoconiosis, metal fume fever, and
bronchial asthma may occur.
NEUROLOGIC
o Hepatic encephalopathy may occur.
GASTROINTESTINAL
o Gastroenteritis and hemorrhage frequently occur
immediately following oral ingestion.
HEPATIC .
o Acute hepatitis may be a late manifestation.
GENITOURINARY
o Renal failure is commonly observed during the first few
days after ingestion. .
HEMATOLOGIC
o Thrombocytopenia, and anemia usually occur after 3 to 7
dayS. Methemoglobinemia has been reported.
DERMATOLOGIC
o Deep perforating ulcers and hypersensitivity dermatitis
may be noted. Systemic toxicity has resulted from
minimal dermal exposure.
CARCINOGENICITY
o An increased incidence of lung cancer has been
associated with chronic exposure to hexavalent chromium.
IMruNOLOGIC
o Exposure to chromium vapors may result in an
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, Toxicological Profile
Chromium
August 21. 1990
Page 14. of 41
o TREATMENT OVERVIEW :
ORAL EXPOSURE
o Administer ascorbic acid (1 gram per 0.135 gram of
elemental chromium).
o DO NOT induce vomiting.
o DILUTION: Immediately dilute with 4 to 8 ounces (120 to
240 mL) of milk or water (not to exceed 15 mL/kg in a
child) .
o Gastric lavage with magnesium hy~oxide or other
antacid, using a soft nasogastric or orogastric tube.
o Exchange transfusion is recommended in all substantial
ingestions.
o FORCED DIURESIS: After initial hydration administer
furosemide 1 mg/kg up to 40 mg/dose.
o ALKALINE DIURESIS: Assure adequate hydration and renal
function. Administer 88 to 132 rnEq/L sodium bicarbonate
and 20 to 40 rnEq KCL (as needed) in D5w or other fluid
to produce adequate urine flow and urine pH of at least
7.5. Addi tional doses may be needed to maintain
alkaline urine, with furosemide or mannitol to maintain
diuresis. Monitor fluid balance and serum potassium.
Obtain hourly intake/output and hourly urine pH.
o HYPOTENSION: Administer IV fluids and place in
Trendelenburg position. If unresponsive to these
measures, administer dopamine (2 to 5 mcg/kg/min) or
norepinephrine (0.1 to 0.2 mcg/kg/min) and titrate as
needed to desired response.
o MONITOR VOLUME STATUS, HEMATOCRIT, AND PLATELET COUNT.
INHALATION EXPOSURE
o DECONTAMINATION: Move patient to fresh air. Monitor
for respiratory distress. If cough or difficulty in
breathing develops, evaluate for respiratory tract
irritation, bronchitis, or pneumonitis. Administer 100%
humidified supplemental oxygen with assisted ventilation
as required.
Monitor for respiratory distress for 72 hours.
Obtain baseline chest x-ray and vital signs.
Pulmonary edema may be managed with PEEP and short-term
steroid therapy.
EYE EXPOSURE
o DECONTAMINATION: Exposed eyes should be irrigated with
copious amounts of tepid water for at least 15 minutes.
If irritation, pain, swelling, lacrimation, or
photophobia persist, the patient should probably be seen
in a health care facility.
DERMAL EXPOSURE
o Wash the exposed area with water or 10 to 20% ascorbic
acid solution for 15 minutes. A physician may need to
examine the exposed area if irritation or pain persists.
o Excision of affected skin is recommended in severe
exposures.
o
o
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, Toxicological Profile
Chromium
August 21. 1990
Page 15. of 41
o RANGE OF TOXICITY :
o
Serious toxicity has resulted from ingestion of 0.5 gm'of
hexavalent chromium. Death has resulted from 1 to 8gm
and survival with 15 gIn. Dermal. involvement of 10% of
body surface has been fatal. Trivalent chromium has not
been associated with toxicity.
1"
o REFERENCE
: [Rumack BH & Spoerke DG: POISINDEX(R)
Informa~ion System. Micromedex Inc., Denver,
CO, 1990: CCIS CD-ReM Volume 66, edition exp
November, 1990. ] **PEER REVIEWED**
ANTIDOTE AND EMERGENCY TREATMENT
TREATMENT: B. CHRONIC POISONING: 1. TREAT WEEPING DERMATITIS WITH 1 %
ALUMINUM ACETATE WET DRESSINGS. AVOID FURTHER EXPOSURE TO CHROMATE. 2.
TREAT LIVER DAMAGE BY GIVING HIGH-CARBOHYDRATE, HIGH-PROTEIN, HIGH
VITAMIN DIET ... . [Dreisbach, R. H. Handbook of Poisoning. 9th ed. Los
Altos, Ca1.1fornia: Lange Medical Publications, 1977. , p. 219] **PEER
REVIEWED'*'tr
ANTIDOTE AND EMERGENCY TREATMENT
. .. MILK OR OTHER EMULGATIONS HAVE BEEN ADVISED IN ... CHROMIC ACID
INGESTION. ACUTE ASTHMATIC ATTACKS CAUSED BY CHROMATES SHOULD BE
TREATED LIKE OTHER ASTHMATIC ATTACKS. ... WOUNDS ON HANDS & ARMS ...
CLEANED & COVERED... /CHROMIUM CMPD/ [Friberg, L., G.R. Nordberg, and
V.B. Vouk. Handbook on the Toxicoloqy of Metals. New York: Elsevier
North Holland, 1979. , p. 394] **PEER REVIEWED**
MEDICAL SURVEILLANCE
Residual scars in individuals afflicted with ulcers on the hands, arms,
and feet serve as a criterion to physicians in the diaqnosis of
chromium sensitivity. [Waldbott GL: Health Effects of Envir Poll p.202
(1973)] **PEER REVIEWED**
MEDICAL SURVEILLANCE
Reporting Siqns and Symptoms: A physician should be contacted if anyone
develops any siqns or symptoms and suspects that they are caused by
exposure to chromium metal or insoluble chromium salts. /Chromium metal
or insoluble chromium salts/ [Mackison, F. W., R. S. Stricoff, and L.
J. Partridge, Jr. (eds.). NIOSH/OSHA - Occupational Health Guidelines
for Chemical Hazards. DHHS (NIOSH) Publication, p. 1] "PEER REVIEWED**
MEDICAL SURVEILLANCE
1) Initial Medical Examination: a) A complete history and physical
examination: The purpose is to detect existing conditions that might
place the exposed employee at increased risk, and to establish a
baseline for future health monitoring. Examination of the respiratory
system should be stressed. b) 14" x 17" chest roentgenogram: Chromium
and its insoluble salts may cause human lung damage. Surveillance of
the lung is indicated. c) FVC and FEV (1 sec): Insoluble chromium salts
are reported to cause decreased pulmonary function. Periodic
surveillance is indicated. 2) Periodic Medical Examination: The
aforementioned medical examinations should be repeated on an annual
basis. /Chromium metal or insoluble chromium salts/ [Mackison, F. W.,
R. S. Stricoff, and L. J. Partridge, Jr. (eds.). NIOSH/OSHA-
-------
Toxicological Profile
Chromium
August 21. 1990
Page 16 of 41
Publication, p. 2] **PEER REVIEWED**
MEDICAL SURVEILIANCE
Preemployment physical exam should incl: a work history to determine
past exposure to chromic acid and hexavalent Cr cmpd, exposure to other
carcinogens, smoking history, history of skin or pu~onary
sensitization to Cr, history or presence of dermatitis, skin ulcers, or
lesions of the nasal mucosa and/or perforation of the septum, and a
chest x-ray. On periodic exam an evaluation should be made of skin and
respiratory complaints, esp in workers who demonstrate allergic
reactions. Chest x-ray should be taken yearly for workers over 40, and
every five years for younger worke~s. Blood, liver, and kidney function
should be evaluated periodically. /Chromium & cmpd/ [Sittig, M.
Handbook of Toxic and Hazardous Chemicals and Carcinogens, 1985. 2nd
ed. Park Ridge, NJ: Noyes Data Corporation, 1985. , p. 246] **PEER
REVIEWED**
HUMAN TOXICITY EXCERPTS
CHRaaUM METAL ... APPEARS TO BE INNOCUOUS. ... NO VISUAL DISTURBANCES
IN P'T PURPORTEDLY POISONED BY CHROMIUM (CR) BUT ... NARROWING OF
RETINAL ARTERIES & PALLOR & INDISTINCTNESS OF PAPILLA IN THREE CASES, &
RETINAL HEMORRHAGE IN A FOURTH CASE ... /REPORTED/. [Grant, W. M.
Toxicology of the Eye. 2nd ed. Springfield, Illinois: Charles C.
Thomas, 1974. , p. 290] **PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
250 volunteers were exposed to 12 different chromium aerOsols in concn
of 1.5 ug/cu m to 40 ug cu m. Levels from 10 to 24 ug/cu m, even for
brief periods, caused shock and irritation of the upper respiratory
tract. [Waldbott GL; Health Effects of Environ Poll p.201 (1973)]
**PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
Li ver tissue was contaminated with 0.02 and 11 ppm chromium (Cr) from
stainless steel scalpels and needles, while a blood sample drawn with a
stainless steel needle was contaminated with 85 ppb chromium (Cr).
[Versieck JMJ, Speecke ABH; In Nuclear Activation Techniques in the
Life Sciences by Int'l Atomic Energy Agency p.39-49 (1972) as cited in
Nat'l Research Council Canada; Effects of Chromium in the Canadian
Envir p.118 (1976) NRCC No.15017] **PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
Symptoms /of exposure/: histologic fibrosis of lung /Chromium metal and
insoluble salts (as Cr)/ [NIOSH. Pocket Guide to Chemical Hazards. 5th
Printing/Revision. DHHS (NIOSH) Publ. No. 85-114. Washington, D.C.:
U.S. Dept. of Health and Human Services, , p. 83] **PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
The organ which is affected by exposure to chromium metal & insol salts
(as Cr) is resp system. /Chromium metal and insoluble salts (as Cr) I
[NIOSH. Pocket Guide to Chemical Hazards. 5th Printing/Revision. DHBS
(NIOSH) Publ. No. 85-114. Washington, D.C.: U.S. Dept. of Health and
Human Services, , p. 83] **PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
Potential symptans as a result of exposure /to chromium, chromic,
Chranous salts (as Cr) I: sensitive dermatitis. IChromium, chromic,
chranous salts (as Cr) / [NIOSH. Pocket Guide to Chemical Hazards. 5th
Printing/Revision. DHHS (NIOSH) Publ. No. 85-114. Washington, D.C.:
U.S. Dept. of Health and Human Services, , p. 85] **PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
THERE IS EXCESSIVE RISK OF LUNG CANCER ~NG WORKERS IN
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. Toxicological Prome
Chromiwn
August 21. 1990
Page 17.of 41
I 0
CHROMIUM CMPD IS RESPONSIBLE, BUT IDENTITY OF THIS OR THESE IS NOT
KNOWN. THERE IS NO EVIDENCE THAT NON-OCCUPATIONAL EXPOSURE TO CHROMIUM
CONSTITUTES CANCER HAZARD. /CHROMIUM & CHROMIUM CMPD/ [IARC. Monographs
on the Evaluation of the carcinogenic Risk of Chemica~s to Man. Geneva:
World Health Organization, International Agency for Research on Cancer,
1972-1985. (Multivolume work). V2120 (1973)] **PEER REVIEWED**
HUMAN TOXICITY EXCERPTS '.
Chromium (III), the naturally occurring form, has low toxicity due to
poor membrane permeability and noncorrosivity, while Cr(VI), from
industrial emissions, is highly toxic due to strong oxidation
characteristics and ready membrane.permeabi1ity. ICr(III) and Cr(VI)/
[Nat '1 Research Council Canada; Effects of Chromium in the Canadian
Envir p.15 (1976) NRCC No.15017] **PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
Studies of patients who received surgical implantations of chromi\.ml
alloy prostheses have given conflicting results regarding mobilization
of chromium from these devices. The discrepancies in results may have
been due not only to differences among alloys and coating of the
prostheses, but also to analytical "inaccuracies," including metal
contamination during specimen collection. In their own study of serum
and urine from 44 patients from day 1 through 2.5 yr after implantation
of cobalt chromium and/or titanium aluminum vanadium alloy prostheses,
elevated levels of chromium were detected only in the .urine of three
patients at day 1-2 after surgery. These increased urinary chromium
concentrations were thought to be due to the trauma of surgery rather
than to mobilization from the prosthesis. /Chromium and chromium cmpd/
[DHHS/ATSDR; Toxicological Profile for Chromium (Draft) p.47 (10/87)]
**PEER REVIEWED**
HUMAN TOXICITY EXCERPTS
. .. PULMONARY DISEASE IN WORKERS EXPOSED TO FERROCHROME ALLOYS WITH
CHROMIUM LEVELS IN AIR OF 0.27 MG/CU M REPORTED. OTHER DUSTS & FUMES
WERE PRESENT, HCMEVER, IN THIS PLANT. /TOTAL CHROMIUM/ [American
Conference of Governmental Industrial Hygienists. Documentation of the
Threshold Limit Values and Biological Exposure Indices. 5th ed.
Cincinnati, OH: , p. 139] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
A GROUP OF 25 C57BL MICE (SEX UNSPECIFIED) RECEIVED 6 WEEKLY IIVI
INJECTIONS OF 0.05 ML OF 0.005% SUSPENSION OF CHROMIUM (CR) POWDER IN
GELATIN-SALINE SOLN. 6 ANIMALS LIVED UP TO 12 MO, BUT NONE TO 18 MO. NO
TUMORS WERE OBSERVED. [IARC. Monographs on the Evaluation of the
Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-1985.
(Multivolume work). V23 260 (1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
OF 25 MALE WISTAR RATS GIVEN 6 WEEKLY IIV / INJECTIONS OF 0.18 ML OF A
0.05% SUSPENSION OF CHROMIUM (CR) POWDER IN GELATIN-SALINE SOLN, 15
LIVED TO 1 YR. ROUND CELL SARCa-sAS ... IN 4 RATS; 1 ... HAD HEMANGIOMA:
2 ... HAD PAPILLARY ADENa-sAS OF THE LUNG, ONE ... SHOWED EXTENSIVE
SQUAMOUS CELL CARCINa1ATOUS CHANGES. NO VEHICLE TREATED CONTROLS...
(HUEPER, 1955) [!ARC. Monographs on the Evaluation of the Carcinogenic
Risk of Chemicals to Man. Geneva: World Health Organization,
International Agency for Research on Cancer, 1972-1985. (Multivolume
work). V23 260 (1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
8 RABBITS RECEIVED 6 WEEKLY IV INJECTIONS OF. O. 5 ML/KG BODY WT OF 5%
-------
, Toxicological Profile
, Chromium
August 21. 1990
Page 18 .of 41
COURSE. .. 4 MO LATER; & 3 YR AFTER FIRST... A 3im SERIES OF
INJECTIONS. .. GIVEN TO 3 SURVIVING. ... 1 OF 3 ... LIVED 6 MO AFTER
. .. DEVELOPED TtJM:)R ... INVOLVING LYMPH NODE. ... NO TUMORS ... IN
CONTROLS. (HUEPER, 1955) [!ARC. Monographs on the Evaluation of the
Carcinoqenic Risk of Chemicals to Man. Geneva: World' Health
Organization, International Agency for Research on Cancer, 1972-1985.
(Multivolume work). V23 261 (1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
. .. 25 ... WISTAR RATS RECEIVED INJECTION I INTRAMEDULLARY I INTO FEMUR
OF 0.2 ML OF 50% (BY WT) SUSPENSION OF CHROMIUM POWDER (45 MG) IN
GELATIN-SALINE... 19 SURVIVED OVER 1 YR. NO TUMORS ... OF 25 ...
OSBORNE-MENDEL RATS INJECTED IN FEMUR WITH SAME DOSE... IN LANOLIN. . .
14 SURVIVED FOR 1 YR; 1 ... DEVELOPED FIBROMA @ INJECTION SITE.
(HUEPER, 1955) [IARe. Monoqraphs on the Evaluation of the Carcinogenic
Risk of Chemicals to Man. Geneva: World Health Organization,
International Agency for Research on Cancer, 1972-1985. (Multivolume
work). V23 263 (1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
. .. OSBORNE-MENDEL RATS WERE GIVEN 6 MONTHLY INTRAPLEURAL INJECTIONS OF
0.05 ML OF 33.6% (BY WT) SUSPENSION OF CHROMIUM POWDER IN LANOLIN... 6
... SURVIVED UP TO 19-24 MO ... 3 HEMANGIOMAS (IN FEMALE OSBORNE-MENDEL
RAT) & 1 ANGIOSARCOMA WERE OBSERVED @ DIFFERENT SITES... ROUND CELL
SARCOMAS WERE OBSERVED... INO CONTROLS REPORTED I (HUEPER, 1955) [IARC.
Monoqraphs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: World Health Organization, International Agency for
Research on Cancer, 1972-1985. (Multivolume work). V23 261 (1980)]
**PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
NO TUMORS WERE OBSERVED AFTER 14 MO IN 50 C57BL MALE MICE THAT RECEIVED
6 INTRAPLEURAL INJECTIONS OF 0.2 ML OF 0.005% SUSPENSION OF CHROMIUM
POWDER IN GELATIN-SALINE SOLN EVERY OTHER WI<; 32 MICE LIVED FOR 7-14
MO. (HUEPER, 1955) [lARC. Monoqraphs on the Evaluation of the
Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-1985.
(Multivolume work). V23 261 (1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
FIFTY MALE C57BL MICE, APPROX 6 WI< OLD, WERE GIVEN WEEKLY IP INJECTIONS
FOR 4 CONSECUTIVE WI< OF 0.2 ML OF 0.005% SUSPENSION OF CHROMIUM POWDER
IN A 2.5% GELATIN-SALINE SOLN; 40 MICE SURVIVED FROM 6-21 MO. 1 MOUSE
DEVELOPED MYELOID LEUKEMIA; NO OTHER TUMORS WERE NOTED. INO CONTROLS
REPORTED! (HUEPER, 1955) [IARC. Monographs on the Evaluation of the
Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-1985.
(Multivolume work). V23 260 (1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
. .. WISTAR RATS, 3-4 N:> OLD ... GIVEN WEEKLY IP INJECTIONS FOR 6 ... WI<
OF 0.1 ML OF 0.05% SUSPENSION OF CHROMIUM POWDER IN 2. 5% GELATIN-SALINE
SOLN. 1 RAT DEVELOPED SCIRRHOUS CARCI~ ... 1 ... HAD ... INSULINOMA
OF THE PANCREAS. ... NO VEHICLE TREATED CONTROLS REPORTED. ...
INSULINOMAS WERE FOUND ONLY IN TREATED RATS !NOT IN CONTROLS!. (HUEPER,
1955) [LARC. Monographs on the Evaluation of the Carcinogenic Risk of
Chemicals to Man. Genevc' World Health Organization, International
Agency for Research on C~ncer, 1972-1985. (Multivolume work). V23 260
(1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
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, Toxicological Profile
Chromium
August 21. 1990
Pqe 19.of 41
ML OF A 0.5% SUSPENSION OF CHROMIUM POWDER IN GELATIN-SALINE SOLN. ...
12 ... 1 SURVIVED 1 UP TO 25-30 MO. ... 1 ANGIOSARCOMA... OBSERVED @
DIFFERENT SITES IN TREATED ANIMALS. ROUND CELL SARCOMAS WERE OBSERVED
... & IN 3/12 ... VEHICLE-TREATED CONTROLS... LIVED. FOR 18 MO.
(HUEPER, 1955) [IARC. Monographs on the Evaluation of the Carcinogenic
Risk of Chemicals to Man. Geneva: World Health Organization,
International Agency for Research on Cancer, 1972-1985. (Multivolume
work). V23 261 (1980)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
The greatest chromium (Cr) toxicity risk to plants is posed in acidic
sandy soil with low organic content. [Nat'l Research Council Canada;
Effects of Chromium in the canadian Envir p.16 (1976) NRCC No.15017]
**PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
SINGLE 1M INJECTIONS OF 2 MG POWDERED CHRafiUM METAL IN 0.5 ML OILY
PENICILLIN G-PROCAINE SUSPENSION GIVEN TO 24 MALE FISCHER RATS RESULTED
IN NO LOCAL TUMORS IN 22 SURVIVORS @ 24 MO. INO CONTROLS GIVENI [!ARC.
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: World Health Organization, International Agency for
Research on Cancer, 1972-1985. (Multivolume work). V23 259 (1980)]
**PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
EXPERIMENTS IN MICE, RATS, HAMSTERS, GUINEA PIGS AND RABBITS TO
INVESTIGATE THE CARCINOGENICITY OF CHROMIC (III) ACETATE, CHROMIC (III)
OXIDE. .. CHROMIUM (VI) TRIOXIDE, CHROMIUM METAL... SODIUM CHROMATE (VI)
. .. SODIUM DICHROMATE (VI) ... CHROMIUM (III) SULFATE... WERE INADEQUATE
TO EVALUATE THE CARCINOGENICITY OF THESE CHROMIUM COMPOUNDS. [IARe.
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: World Health Organization, International Agency for
Research on Cancer, 1972-1985. (Multivolume work). V23 302 (1980)]
**PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
Although the uptake, storage, and elimination of contaminants by naiad
mollusks has been studied, relatively little information is available
on toxicity. Contaminants appear to have destroyed some population
directly by exerting toxic effects, or indirectly by causing or
contributing to the elimination of essential food organisms or host
fish. Various common contaminants have been reported to be toxic at the
following concentrations (pprn): cadmium, 2: copper sulfate, 2 to 18.7;
ammonia,S: potassium, 11: chromium, 12.4: arsenic trioxide, 16;
copper, 19: and zinc, 66. [Haulik ME, marking LL: Gov Rep Announcements
Index (15): 1-27 (1987)] **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
The data on the effects of cations such as copper, cadmium, and
chromium on the biochem parameters in a freshwater fish, Clarias
batrachus, showed an incr of the protein content in the liver, kidney,
stomach, intestine, testis, and ovary, and a decr in the muscle after
copper and cadmium treatment but chromium did not cause any changes of
protein concn in the kidney and testis. The administration of copper
and cadmium incr the concn of free amino acids in all the fish organs,
whereas chromium did not change this concn in the muscle. A decr in dry
wt, and an incr in tissue permeability after these treatments were
recorded in all the organs studied. In general, the above biochem
parameters of the organs were affected by treatments of the above
cations in the followinq order: cadmium> copper> chromium over
-------
.
Toxicological Profile
Chromium
August 21. 1990
Page 2Q of 41
pronounced in the liver and kidney, followed by the intestine, stomach,
muscle, testis, and ovary in this species. [Jana S, Sahana SS; Physiol
Bohemoslov 37 (1): 79-82 (1988)J **PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS . .
Low doses of chromium produce a relatively specific necrosis of the
proximal convoluted tubule. Functionally, this leads to pronounced
glucosuria. After low doses of chromium the surface of the kidney shows
marked signs of ischemia and tissue damage. ... when the dose of the
chromium is incr, toxicity is seen throughout the proximal tubule.
[Doull, J., C.D.Klassen, and M.D. Amdur (eds.). Casarett and Doull's
Toxicology. 3rd ed., New York: Ma~llan Co., Inc., 1986. , p. 319J
**PEER REVIEWED**
NON-HUMAN TOXICITY EXCERPTS
The presence of > 100 ppm Chromium may adversely affect the
biodegradation of sewage sludge. /Total chromium/ [Nat'l Research
Council Canada; Effects of Chromium in the Canadian Envir p.91 (1976)
NRCC No.1S017J **PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
Chromium (Cr) containing aerosol particles with a diam of 2 urn are
deposited in the upper respiratory tract (nose, pharynx) while smaller
particles penetrated to the trachea, bronchial tubes, and alveoli.
[Natusch DFS, Wallace JR; Science 186: 695-9 (1974) as cited in Nat'l
Research Council Canada; Effects of Chromium in the Canadian Envir p.94
(1976) NRCC No.1S017J **PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
In the rat, chromium (Cr) absorbed by the intestines is almost entirely
bound to transferrin, the iron-carrying protein. [Hopkins LL, Schwarz
K; Biochem Biophys Acta 90: 484-91 (1964) as cited in NAS; Medical and
Biological Effects of Environmental POllutants: Chromium p.37 (1974»)
**PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
Chromium (Cr) rapidly accumulates in the testes and then in the
epididymes after injection of a tracer dose, thus suggests a possible
incorporation of chromium (Cr) into sperm. [Hopkins LL; Amer J Physiol
209: 731-35 (1965) as cited in NAS; Medical and Biological Effects of
Environmental Pollutants: Chromium p.39 (1974)J **PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
Chromium is distributed approx equally among human tissues with the
exception of lung, which may contain 2-3 times the concn of other
tissues. [Seiler, H.G., H. Sigel and A. Sigel (eds.). Handbook on the
Toxici ty of Inorganic Compounds. New York, NY: Marcel Dekker, Inc.
1988. , p. 243] **PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
Chromium is normally excreted through the kidneys and urine, with some
excretion through the bile and feces; minor routes of excretion incl
milk, sweat, hair, and nails. [Seiler, H.G., H. Sigel and A. Sigel
(eds.). Handbook on the Toxicity of Inorganic Compounds. New York, NY:
Marcel Dekker, Inc. 1988. , p. 244J **PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
The daily urinary excretion of chromium in 15 female subjects was 0.20
+ or - 0.03 ug/l and in 27 male subjects was virtually the same, 0.17 +
or - 0.03 ug/l. When chranium intake was supplemented fivefold with
chromium chloride, urinary excretion also increased about fivefold.
[Anderson RA et al; J Nutr 113 (2): 276-81 (1983) as cited in
DHHS/ATSDR; Toxicological Profile for Chranium (Draft) p.48 (10/87»)
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Toxicological Profile
Chromium
August 21. 1990
Page 21 of 41
l
ABSORPTION, DISTRIBUTION AND EXCRETION
In rats, chromium (Cr) (salts) show highest uptake in ovaries, spleen,
kidneys, and liver; and chromium (Cr) as glucose tolerance factor shows
highest uptake in the liver, uterus, kidneys, and bone. In man, the
highest uptake is in the lung and and the chromium (Cr) which
accumulates in the liver is concentrated in the nuclei. [NAS; Medical
and Biological Effects of Environmental Pollutants: Chromium p.37-39
(1974») **PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
Nonradioactive and radioactive metal salts were administered
intravenously to Sprague Dawley rats. The highest amount of each metal
approached the maximum tolerated dose. Cobalt (Co), silver (Ag), and
manganese (Mn) were eliminated rapidly. The elimination of 20 to SO
percent of the dosage was observed for copper (Cu), thallium (Tl),
bismuth (Bi), lead (Pb), cesium (Cs), gold (Au), zinc (Zn), mercury
(Hg), selenium (Se), and chromium (Cr). No substantial elimination rate
decline was observed for methyl-mercury, and iron and the decline was
small for thalium, cesium, mercury, tin, cobalt, silver, zinc, .
chromium, and arsenic. Copper, thallium, lead, and zinc were excreted
at a slower rate, with 30.6 to 38.3 percent excreted on the first day.
The rest of the metals were eliminated slowly by the intestinal route.
Cobalt was removed rapidly via urine, while lead, tin, zinc, methyl
mercury, silver, iron, manganese, and cadmium were eliminated slowly.
Silver, arsenic, manganese, copper, selenium, cadmium, lead, bismuth,
and methyl mercury were highly concentrated in bile relative to plasma.
Liver and kidney contained the highest concentrations of most metals.
Cobalt, cesium, gold, selenium, and chromium were removed predominantly
by urine. [Gregus Z, Klaassen CO; Toxicol Appl Pharm 85 (1): 24-38
(1986») **PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
HEPATIC CONCN OF CHROMIUM IS HIGH IN CHILDHOOD & DECLINES TO VERY LOW
LEVELS AFTER AGE OF 20 YR. /CHROMIUM & INORGANIC CR CMPD/ [IARC.
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: World Health Organization, International Agency for
. Research on Cancer, 1972-1985. (Multivolume work). V2ll8 (1973»)
**PEER REVIEWED**
ABSORPTION, DISTRIBUTION AND EXCRETION
CHROMIUM IS EXCRETED IN URINE & FECES WITH THE URINARY PATHWAY
ACCOUNTING FOR 80%. NEARLY ALL CR IN URINE IS PRESENT IN FORM OF LOW
MOLECULAR WEIGHT COMPLEXES: VERY LITTLE PROTEIN BOUND CR IS EXCRETED.
. .. MEAN 24 HR URINARY CR EXCRETION OF 20 YOUNG ADULTS WAS 8. 4 UG WITH
AN AVG RANGE OF 1.6-21 UG ... [National Research Council. Drinking
Water & Health Volume 1. Washington, DC: National Academy Press, 1977.
, p. 243) **PEER REVIEWED**
METABOLISM/METABOLITES
In plants, chromium (Cr) interferes with uptake translocation, and
accumulation by plant tops of calcium, potassium, magnesium,
phosphorus, boron, copper and aggravates iron deficiency chlorosis by
interfering with iron metabolism. [Turner MA, Rush RH; Soil Soc Am Proe
35: 755 (1971) as cited in Nat'l Research Council Canada; Effects of
Chromium in the Canadian Envir p.88 (176) NRCC No.15017) **PEER
REVIEWED** .
METABOLISM/METABOLITES
Aquatic Fate: Little is known about the relation between concentrations
of total Chromium in a given environment and biological effects on the
-------
Toxicological Profile
Chromium
August 21. 1990
Page ~ of 41
the Cr, the sarne elemental concentration has a wide variety of of
mobilities and reactivities and thus has different effects. Chromium
toxicity to aquatic biota is significantly influenced by abiotic
variables such as hardness, temperature, pH, and salinity of water; and
bioloqical factors such as species, life staqe, and,potential
differences in sensitivities of ,local populations. ITotal chromiuml [US
Dept of the Interior: Chromium Hazards to Fish, Wildlife, and
Invertebrates: A Synoptic Review; p.3 Rptf 85(1.6) (1985)] **PEER
REVIEWED * *
BIOLOGICAL HALF-LIFE
The elimination curve for chromium.as measured by whole-body countinq
has an exponential form. In rats, 3 different components of the curve
have been identified with the half-times of 0.5, 5.9, and 83.4 days,
respectively. [Friberq, L., Nordberq, G.F., Kessler, E. and Vouk, V.B.
(eds). Handbook of the Toxicoloqy of Metals. 2nd ed. Vols I, II.:
Amsterdam: Elsevier Science Publishers B.V., 1986. V2 193] **PEER
REVIEWED**
MECHANISM OF ACTION
Synthetically prepared chromium-ATP competes with magnesium-ATP as an
enzyme substrate and inhibits bioloqical catalysis. [Janson CA, Cleland
WW; J BioI Chem 249: 2572-4 (1974) as cited in Nat'l Research Council
Canada; Effects of Chromium in the Canadian Envir p.66 (1976) NRCC
No.lS01?] **PEER REVIEWED**
MECHANISM OF ACTION
Excess Chromium (Cr) inhibits the action of hormones and enzymes
throuqh non-specific bindinqs, chanqinq three dimensional confiquration
of the active site. [Nat'l Research Council Canada; Effects of Chromium
in the Canadian Envir p.67 (1976) NRCC No.15017] **PEER REVIEWED**
MECHANISM OF ACTION
Excessive chromium (Cr) inhibits bacterial urease activity (1-10
uqlml), thromboplastin activity (1.25 mql200 uq protein) and
beta-qlucuronidase activity. [NA5; Medical and Bioloqical Effects of
Environmental POllutants: Chromium p.25 (1974)] **PEER REVIEWED**
INTERACTIONS
... RATS... GIVEN 1 INTRATRACHEAL INTUBATION OF 10 MG POWDER CHROMIUM
ALONE OR ... WITH... METHYLCHOLANTHRENE & KILLED @ ... INTERVALS UP TO
12 WK. SQUAMOUS-CELL CARCINOMAS OF LUNG DEVELOPED... IN 7/12 RATS
GIVEN 5 MG METHYLCHOLANTHRENE+CHROMIUM 3/12 GIVEN 1 MG
METHYLCHOLANTHRENE+CHROMIUM ... 3/7 GIVEN 5 MG METHYLCHOLANTHRENE ...
1/8 GIVEN 1 MG METHYLCHOLANTHRENE & IN 0/12 GIVEN CHROMIUM ALONE. /00
CONTROLS REPORTED/ [IARC. Monoqraphs on the Evaluation of the
Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Orqanization, International Aqency for Research on Cancer, 1972-1985.
(Multivolume work). V23 256 (1980)] **PEER REVIEWED**
POPULATIONS AT SPECIAL RISK
The effects of chromium compounds on the skin are caused primarily by
direct contact. Most of the effects have occurred in occupational
settinqs, and as expected, with more men than women reportinq these
effects. IChromium compoundsl [USEPA; Health Assessment Document:
Chromium p.2-8 (1984) EPA 600/8-83-014F] **PEER REVIEWED**
POPULATIONS AT SPECIAL RISK
There is sufficient evidence for increased incidence of lunq cancer
amonq workers in the chromate producinq industry and possibly also
amonq chromium platers and chromium alloy workers. /Chromatel
[DHHS/NTP: Fourth Annual Report On Carcinoqens p.58 (1985) NTP 85-002]
-------
Toxicological Profile
Chromium
August 21, 1990
Page 23 of 41
BIONECESSITY
Chromium (Cr) is an essential element for fungi and vertebrates.
ITrivalent chromiuml [Altman PL, Dittmer DS, eds; Biology Data Book 2nd
ed (1974) as cited in Nat'l Research Council Canada;. .Effects of
Chromium in the Canadian Envir p.20 (1976) NRCC No.ls017] "PEER
REVIEWED** .
BIONECESSITY .
Trivalent chromium is considered essential for the maintenance of
normal glucose tolerance in animals and man, and the factor or the
group of factors containing trivalent chromium, called GTF (glucose
tolerance factor) has been suggested to be responsible for this
favorable action of chromium. The chromium status in diabetic subjects
appears to be abnormal, and chromium is capable of potentiating
insulin, but so far the exact structure(s) of the biologically active
chromium complex(es) has (have) not been identified. /Trivalent
chromiuml [Friberg, L., Nordberg, G.F., Kessler, E. and Vouk, V.B.
(eds). Handbook of the Toxicology of Metals. 2nd ed. Vols I, II.:
Amsterdam: Elsevier Science Publishers B.V., 1986. V2 194) **PEER
REVIEWED * *
BIONECESSITY
Chromium appears to play an important role in the maintenance of
vascular integrity. A deficiency of this metal in animals results in
elevated serum choesterol levels and incr atherosclerotic aortic
plaques. Autopsies of humans have revealed virtually no chromium in the
aortas of individuals dying of atherosclerotic heart disease, in
comparison with normal individuals dying of other causes. [Doull, J.,
C.D.Klassen, and M.D. Amdur (eds.). Casarett and Doull's Toxicology.
3rd ed., New York: Macmillan Co., Inc., 1986. , p. 404) **PEER
REVIEWED * *
BIONECESSITY
Chromium (III) may stabilize biological proteins in their proper
configurations. ICr(III)1 [Mertz W; Physiol Rev 49: 165-239 (1969) as
cited in Nat'l Research Council Canada; Effects of Chromium in the
Canadian Envir p.67 (1976) NRCC No.1s017] **PEER REVIEWED**
BIONECESSITY
Trivalent chromium is essential in mammals. Adequate trivalent chromium
nutrition improves growth and longevity and, along with insulin, helps
to maintain correct glucose, lipid, and protein metabolism. ITrivalent
chromiuml [Nat'l Research Council Canada; Effects of Chromium in the
Canadian Environment p.94 (1976) NRCC No 15017] **PEER REVIEWED**
BIONECESSITY
Chromium is an essential nutrient for man, being required for the
maintenance of normal glucose tolerance. The human diet supplies from
5-115 ug/day of the element, of which only 1-25% is absorbed from the
gastrointestinal tract. [Baselt RC; Biological Monitoring Methods for
Industrial Chemicals p. 81 (1980)] **PEER REVIEWED**
BIONECESSITY
Chromium, usually supplied by glucose tolerance factor (Cr(III)
comp1exed with amino acids and nicotinic acid) assists in binding
insulin to fat cell membranes stimulating them to absorb glucose.
IChromium ionl [Mertz W et al: Fed Proc 33: 2275-80 (1974) as cited in
Nat'l Research Council Canada: Effects of Chromium in the Canadian
Envir p.66 (1976) NRCC No.ls017] **PEER REVIEWED**
BIONECESSITY
Trypsin contains chromium as an integral part. Cr removal, by dialysis,
-------
Toxicological Profile
Chromium
August 21. 1990
Page 2~ of 41
activity. /Chromium ion/ [Langenbeck W: Hoppe Seyler Z Physiol Chem
324: 54-7 (1961) as cited in NAB: Medical and Biological Effects of
Environmenal Pollutants: Chromium p.25 (1974)] **PEER REVIEWED**
BIONECESSITY . .
Deficiency of chromium in the diet of animals causes a syndrome
simulating diabetes. /Chromium ion/ [Waldbott GL: Health Effects of
Envir Poll p.201 (1973)] **PEER REVIEWED**
BIONECESSITY
A lack of chromium has been associated with atherosclerotic heart
disease, elevated cholesterol levels in the blood, and high fat content
of the aorta. /Chramium ion/ [Waldbott GL: Health Effects of Envir Poll
p.201 (1973)] **PEER REVIEWED**
BIONECESSITY
Chromium is essential for sugar and fat metabolism. /Chromium ion/
[Britt DL & Hushon JM: Bio Effects Criteria & Stds for Hazardous
Pollutants p.6-21 (1976)] **PEER REVIEWED**
BIONECESSITY
... Defect in chromium deficiency... in young animal, growth rate may
be reduced. Corneal lesions have been observed in rats deficient in
both chromium and protein: no lesions have been seen with either single
deficiency. /Chromium ion/ rOsol, A. (ed.). Remington's Pharmaceutical
Sciences. 16th ed. Easton, Pennsylvania: Mack Publishing Co., 1980. ,
p. 975] **PEER REVIEWED**
BIONECESSITY
Deficiency has been reported in a few pt receiving total parenteral
nutrition for 5 mo to three yr. These pt had peripheral neuropathy
and/or encephalopathy that was alleviated by admin of chromium 150 ug
daily. Symptoms incl a diabetes like condition with impaired
utilization of glucose. Other pt with similar symptoms of glucose
intolerance also had protein calorie malnutrition. /Chromium ion/
[American Medical Association, Department of Drugs. Drug Evaluations.
6th ed. Chicago, Ill: American Medical Association, 1986. , p. 856J
**PEER REVIEWED**
BIONECESSITY
Impairment of glucose tolerance is the first response of animals to a
mild chromium deficiency. A more severe deficiency can be produced by
raising animals in an environment that allows strict control of
airborne contamination or by subjecting them to additional stress, such
as low-protein diets, hemorrhage or strenuous exercise. Chromium
deficiency in rats resulted in significantly increased concentrations
of circulating cholesterol and incidences of aortic plaques. Fasting
hyperglycemia and glycosuria were observed in rats raised under maximal
exclusion of chromium contamination. More than half of the 185 chromium
deficient rats showed a positive test for urine sugar. The combination
of chromium deficiency and protein deficiency produced by feeding rats
a diet containing 10% isolated soy protein, resulted in the
degeneration of the cornea, manifested by vascular infiltration and
opacities. The mortality of male mice raised in an environment allowing
maximal exclusion of trace contamination was decreased if chromium was
added to their drinking water at 5 mg/l. In rats, early mortality was
not significantly affected, but chromium supplementation increased the
lifespan of survivors. The mean age of last surviving 10% was increased
from 1,141 to 1,249 days. Most mice and rats grew significantly better
with chromium supplementation than their deficient controls. Chromium
supplemented rats had a significantly lower incidence of aortic plaques
-------
Toxicological Profile
Chromium
August 21. 1990
Page 2S of 41
I
c
controls had positive tests for urine sugar. IChromium ionl [NAS;
Medical and Biological Effects of Environmental Pollutants: Chromium
p.31 (1974)] **PEER REVIEWED**
THERAPEUTIC USES
Some disorders caused by lack of manganese
(Cr). [Popov VV: Vop Pitan 28: 24-7 (1969)
Council Canada; Effects of Chromium in the
NRCC No.15017] **PEER REVIEWED**
THERAPEUTIC USES
Chromium (Cr) supplemented animal diets reduced incidence of
atherosclerosis. [Schroeder HA et ~l; J Chron Dis 23: 123 (1970) as
cited in Nat' 1 Research Council Canada: Effects of Chromium in the
Canadian Envir p.94 (1976) NRCC No.15017] **PEER REVIEWED**
THERAPEUTIC USES
Protein-calorie malnutrition and the syndrome of kwashiorkor and
marasmus improve when children are fed one dose of 250 ug Cr. [Hopkins
LL et al; J Clin Nutr 21: 203-11 (1968) as cited in NAS: Medical and
Biological Effects of Environmental Pollutants: Chromium p.33 (1974)]
**PEER REVIEWED**
THERAPEUTIC USES
... A chromium supplements such as Brewer's yeast extract can have
beneficial effects in some cases, particularly with the elderly,
malnourished children, and diabetics. [Seiler, H.G., H. Sigel and A.
Sigel (eds.). Handbook on the Toxicity of Inorganic Compounds. New
York, NY: Marcel Dekker, Inc. 1988. , p. 245] **PEER REVIEWED**
NATURAL OCCURRING SOURCES
CHROMIUM IS FOUND IN NATURE ONLY IN THE COMBINED STATE & NOT AS THE
ELEMENT. ... [!ARC. Monographs on the Evaluation of the Carcinogenic
Risk of Chemicals to Man. Geneva: World Health Organization,
International Agency for Research on Cancer, 1972-1985. (Multivolume
work). V2108 (1973)] **PEER REVIEWED**
NATURAL OCCURRING SOURCES
Chromium is widely distributed: avg concn 125 mg/kg in the continental
crust, but rare in natural waters. IChromium and chromium cmpdl [USEPA;
Ambient Water Quality Criteria Doc: Chromium p.C-4 (1980) EPA
440/5-80-035] **PEER REVIEWED**
NATURAL OCCURRING SOURCES
PRESENT IN SMALL QUANTITIES IN ALL SOILS & PLANTS & ... CONSIDERED
AGRICULTURALLY AS A DELETERIOUS ELEMENT. CERTAIN SOILS WITH A
RELATIVELY HIGH CONTENT (0.2-0.4%) ARE SAID TO BE INFERTILE; CITRUS
TREES GROWN ON THEM SHOW YELLOWING OF FOLIAGE... . [Browning, E.
Toxicity of Industrial Metals. 2nd ed. New York:
Appleton-Century-Crofts, 1969. , p. 119] **PEER REVIEWED**
NATURAL OCCURRING SOURCES
IIRON CHROMITE (FEO.CR203), WHICH IS FOUND 1 IN NATURE ONLY IN THE
COMBlNEP STATE & NOT AS THE ELEMENT. ... DERIVED MAINLY FROM CHROMITE
(FEO.CR203) ... FOUND IN CONSIDERABLE QUANTITIES IN RHODESIA, RUSSIA,
SOUTH AFRICA, NEW CALEDONIA & THE PHILIPPINES & CONTAINS 40-50%
CHROMIUM... . [IARC. Monographs on the Evaluation of the Carcinogenic
Risk of Chemicals to Man. Geneva: World Health Organization,
International Agency for Research on Cancer, 1972-1985. (Multivolume
work). V2108 (1973)] **PEER REVIEWED**
NATURAL OCCURRING SOURCES
CHROMIUM OCCURS IN NATURE MOSTLY AS CHROME IRON ORE (FEO. CR203) .
CHROMIUM IS PRESENT IN SMALL QUANTITIES IN ALL SOILS & PLANTS, @ 1-2.5
PPB IN SEA WATER, & @ ABOUT 200 PPM IN THE EARTH'S CRUST. THE NORMAL
can be treated with chromium
as cited in Nat'l Research
-------
Toxicological Profile
Chromium
August 21, 1990
Page 26 of 41
HUMAN ADULT BODY CONTAINS ABOUT 6 MG CR, WITH TISSUE CONCN OF 0.02-0. 04
PPM CR ON DRY WI' BASIS. [Venugopal, B. and T.D. Luckey. Metal Toxicity
in Mammals, 2. New York: Plenum Press, 1978. , p. 248] **PEER
REVIEWED** .
NATURAL OCCURRING SOURCES
IT IS PRESENT IN MINOR AMI' IN IGNEOUS ROCRS , IS MUCH MORE ABUNDANT IN
BASIC' ULTRABASIC TYPES THAN IN THE K>RE SILICIC TYPES OF ROCKS.
[National Research Council. Drinking Water' Health Volume 1.
Washington, DC: National Academy Press, 1977. , p. 241] **PEER
REVIEWED * *
NATURAL OCCURRING SOURCES
The most common meteorites, ie chondrites, contain 3,000 ug/g (ppm)
chromium. /Total chromium/ [NAS; Medical and Biological Effects of
Environmental Pollutants: Chromium p.2 (1974)] **PEER REVIEWED**
NATURAL OCCURRING SOURCES
Chromium in air associated with large particles (> 5 um diam)
originates from wind blown soil and soil forming processes. /Total
chromium/ [Nat' 1 Research Council Canada; Effects of Chromium in the
Canadian Envir p.26 (1976) NRCC No.15017] **PEER REVIEWED**
NATURAL OCCURRING SOURCES
The abundance of chromium in various materials is as follows: 80-200
ppm in the continental crust, 125 ppm avg; 1,000-3,400 ppm in
ultramafic igneous rocks, 1,800 ppm avg; 40-600 ppm in basaltic igneous
rocks, 220 ppm avg; 2-90 ppm in granitic igneous rocks, 20 ppm avg;
30-590 ppm in shales and clays, 120 ppm avg; and 10-1,000 ppm in coals,
20 ppm avg. /Total chromium/ [Bowen HJM ed; Trace Elements in Biochem
(1966) as cited in NAS; Medical and Biological Effects of Environmental
Pollutants: Chromium p.9 (1974)] **PEER REVIEWED**
ARTIFICIAL SOURCES
Drinking water generally contains the same chromium levels as the
surface and groundwaters, which serve as its source. Although some
piping materials contain significant levels of chromium (corrosion
resistant steel, 8-14%; cement, 5-120 ppm chromium), little is leached
into the water. However, it should be noted that Cr(III) may be
oxidized to Cr(VI) during the chlorination process. ITotal chromiuml
[Nat'l Research Council Canada; Effects of Chromium in the Canadian
Environment p.36 (1976) NRCC No 15017] **PEER REVIEWED**
ARTIFICIAL SOURCES
. .. IT COULD OCCUR AS WATER POLLUTANT FRCM C~ CHEMICAL PLANTS OR IN
LOSSES DURING PIGMENT PRODN OR LEATHER TANNING OPERATIONS. ITOTAL
CHROMIUMI [lARC. Monographs on the Evaluation of the Carcinogenic Risk
of Chemicals to Man. Geneva: World Health Orqanization, International
Agency for Research on Cancer, 1972-1985. (Multivolume work). v2106
(1980)] **PEER REVIEWED**
ARTIFICIAL SOURCES
The two largest sources of chromium emission in the atmosphere are from
the chemical manufacturing industry and combustion of natural gas, oil,
and coal. Other sources include wind transport from road dust, cement
producing plants because cement contains chromium, the wearing down of
asbestos brake linings from automobiles or similar sources of wind
carried asbestos since asbestos contains chromium, incineration of
municipal refuse and sewage sludge, exhaust emission from automotive
catalytic converters, emissions from cooling towers that use chromium
compounds as rust inhibitors, waste waters from electroplating, leather
tanning, and textile industries when discharge into surface waters, and
-------
Toxicological Profile
Chromium
August 21. 1990
Page 27 of 41
l
municipal incineration when disposed of improperly in landfill sites.
/Total chromium/ [DHHS/ATSDR: Toxicological Profile for Chromium
(Draft) p.1 (10/87») ..PEER REVIEWED..
ARTIFICIAL SOURCES '.
Particles emitted from coal fired power plants contained 2.3-31 ppm,
chromium emitted gases contained 0~22-2.2 mg/cu m. Concn were reduced
by fly ash collection to 0.19-6.6 ppm and 0.018-0.5 mg/cu m,
respectively. /Total chromium/ [Sullivan RJ: Preliminary Air Poll
Survey of Chromium and its Canpounds p.1-75 (1969) NAPCA Pub. APTD
69-34 as cited in NAS: Medical and Biological Effects of Environmental
Pollutants: Chromium p.15 (1974») ~.PEER REVIEWED..
ARTIFICIAL SOURCES
The burning of wood in fireplaces, campfires, leaf burning, and rubbish
incineration contribute chromium to the air. /Total chromium/
[Schroeder HA: API Air Quality Monograph '70-15: Chromium p.1-28 (1970)
as cited in NAS: Medical and Biological Effects of Environmental
Pollutants: Chromium p.15 (1974)] ..PEER REVIEWED..
ARTIFICIAL SOURCES
Air emissions containing chromium result from the following major
industries: paper mills, organic & inorganic petro-chemicals,
fertilizers, steel and metal foundries, motor vehicles, glass, cement,
asbestos manufacture, textile mills and seam generation power plants.
[Dean JG et al: Envir Sci Technol 6: 518-22 (1972) as cited in Nat'l
Research Council Canada: Effects of Chromium in the Canadian Envir p.52
(1976) NRCC No.15017] ..PEER REVIEWED..
ARTIFICIAL SOURCES
Wastewater treatment sludge from the production of chrome yellow,
orange, and green pigments, chrome oxide green pigments, molybdate
orange, zinc yellow, and iron blue pigments, and oven residue from
chrome oxide green pigments contain toxic metals including hexavalent
chromium. An est 4300 metric tons of sludge are generated per yr
(50-60% of this in 1980 or 2100-2600 lb). These wastes are frequently
disposed of in unlined lagoons and landfills or dumped in the open
creating a potential for toxic environmental contamination. /Total
chromium/ [USEPA: Background Document, Resource Conservation and
Recovery Act Subtittle C: Identification and Listing of Hazardous Waste
p.188, 202 (1980)] ..PEER REVIEWED..
ARTIFICIAL SOURCES
New York City emits 4.4xlO+8 g/yr Cr. 43% of the daily Cr in New York
City sewer burden and 24% of chromium emmission from New York City to
vapor are from electroplating wastes, while residential waste and rain
water runoff contribute .28% and 9%, respectively. /Total chromium/
[Klein LA et al: J Water Poll Control Fed 46: 2653-62 (1974) as cited
in Nat' 1 Research Council Canada: Effects of Chromium in the Canadian
Envir p.58 (1976) NRCC No.15017] ..PEER REVIEWED..
ARTIFICIAL SOURCES
The sources of chromium in waste streams are from its use as a
corrosion inhibitor and from dyeing and tanning industries. /Total
chromium/ [Brown, R.W., G. B. Evans, Jr., B.D. Frentrup (eds.).
Hazardous Waste Land Treatment. Boston, MA: Butterworth Publishers,
1983. , p. 252] ..PEER REVIEWED..
ENVIRONMENTAL FATE
TERRESTRIAL FATE: In order to decide on a suitable sampling depth for
grassland soil treated with sewage sludge and to assess implications
for grazing animals, a field trial on two soils was designed to
-------
Toxicological Profile
Chromium
August 21. 1990
Page 2!! of 41
following surface applications of sludge. Soil cores were taken using
specialized equipment to 30 em depth and divided into seven sections.
Movement from the soil surface to a depth of 10 em was observed for all
of the seven metals: cadmium, chromium, copper, molybdenum, nickel,
lead and zinc, but most of the metal (60%-100%, mean 87%) remained in
the upper 5 em of solI. Sampling to a depth of 5 or 7.5 em would be
most suitable for monitoring long-term grassland treated with surface
applications of sludge. [Davis RD et al: Environ Pollut 49 (2): 99-116
(1988)] ..PEER REVIEWED..
ENVIRONMENTAL FATE
Aquatic Fate: ... Most of the chrauium ln surface waters may be present
in particulate form as sediment. Some of the particulate chromium would
remain as suspended matter and ultimately be deposited in sediments.
. .. The exact chemical forms of chromium in surface waters are not well
defined. Although most of the soluble chromium in surface waters may be
present as Cr(VI), a small amount may be present as Cr(III) organic
complexes. Hexavalent chromium is the major stable form of chromium in
seawater; however, Cr(VI) may be reduced to Cr(III) by organic matter
present in water, and may eventually deposit in sediments. /Chromium/
[USEPA; Health Assessment Document: Chromium p.3-l8 (1984) EPA
600/8-83-0l4F) ..PEER REVIEWED..
ENVIRONMENTAL FATE
Atmospheric Fate: Under normal conditions, chromium (III) and Cr(O) are
relatively unreactive in the atmosphere. Cr(VI) in air may react with
particulate matter or gaseous pollutants to form Cr(III). However,
these atmospheric reactions have not been extensively studied. ...
Chromium is removed from air through wet and dry depositions. The total
yearly deposition of chromium in urban areas may vary from 0.12 ug/sq m
to 3 ug/sq m. In general, urban areas have higher total deposition than
rural areas. Chromium concentration in a wet deposition may vary fran
0.004 to 0.060 ug/ml and 0.0006 to 0.034 ug/l for urban and rural
areas, respectively. The precipitated chromium from the air enters
surface water or soil. /Chromium/ [USEPA; Health Assessment Document:
Chromium p.3-17 (1984) EPA 600/8-83-014F] ..PEER REVIEWED..
ENVIRONMENTAL FATE
TERRESTRIAL FATE: Uptake is greater from ultrabasic soils by a factor
of 5-40 than on calcarious or silica-based soils. /Total chromium/
[Schroeder HA et al; J Chron Dis 15: 941-4 (1962) as cited in NAS;
Medical and Biological Effects of Environmental Pollutants: Chromium
p.12 (1974)] ..PEER REVIEWED..
ENVIRONMENTAL FATE
ATMOSPHERIC FATE: Chromium is associated with particulate matter in the
air, and is not expected to exist in gaseous form. /Total chromium/
[Nat'l Research Council Canada; Effects of Chromium in the Canadian
Envir p.22 (1976) NRCC No.15017] ..PEER REVIEWED..
ENVIRONMENTAL FATE
Atmospheric Fate: Chromium (Cr) is most highly concn in the smallest
particles collected from ambient air. Bulk analysis does not allow
adequate characterization of these particles. /Total chromium/ [Natusch
DFS et al; Science 183: 202-4 (1974)] *.PEER REVIEWED**
BIOCONCENTRATION
Snails showed an accumulation factor of 1x10+6. /Total chromium/
[Levine EP; Science 133: 1352-3 (1961) as cited in Nat'l Research
Council Canada; Effects of Chromium in the Canadian Envir p. SO (1976)
NRCC No.1S017] **PEER REVIEWED..
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Toxicological Profile
Chromiwn
August 21. 1990
Page 29 of 41
l
o
Leptospermum scoparum, a shrub, showed an accumulation factor of 1x10+3
compared to normal plants. /Total chromium/ [Lyon GL et al: Planta 88:
282-7 (1969) as cited in Nat'l Research Council Canada: Effects of
Chromium in the Canadian Envir p.50 (1976) NRCC No.15017] **PEER
REVIEWED * * . .
BIOCONCENTRATION
Seaweed showed an accumulation factor of 1x10+2. /Total chromium/
[Boothe PN, Knauer GA: L1mnol Oceanoqr17: 270-4 (1974) as cited in
Nat'l Research Council Canada: Effects of Chromium in the Canadian
Envir p.50 (1976) NRCC No.15017] **PEER REVIEWED**
PROBABLE ROUTES OF HUMAN EXPOSURE
The toxicologically important routes of entry are inhalation and
ingestion. /Chromium metal and insoluble salts (as Cr)/ [NIOSH. Pocket
Guide to Chemical Hazards. 5th Printing/Revision. DHHS (NIOSH) Publ.
No. 85-114. Washington, D.C.: U.S. Dept. of Health and Human Services,
, p. 83] **PEER REVIEWED**
PROBABLE ROUTES OF HUMAN EXPOSURE
Exposure to the metal and its insoluble and soluble salts is generally
via inhalation OI dusts OL fumes: the current threshold limit values
for these compounds range from 0.05-0.5 mg/cu m /Chromium metal and its
salts/ [Baselt Re: Biological Monitoring Methods for Industrial
Chemicals p. 81 (1980)] **PEER REVIEWED**
AVERAGE DAILY INTAKE
The mean daily dietary intake of chromium from air, water, and food has
been estimated to be 0.3, 4.0, and 280 ug, respectively. A recent study
estimated a median value of 240 ug as the daily dietary intake of
chromium from foods in Belgium: however, inhalation intake in
occupationally exposed people and cigarette smokers may far exceed the
inhalation intake in the general population. /Chromium ad Chromium
cmpd/ [DHHS/ATSDR: Toxicological Profile for Chromium (Draft) p.83
(10/87)] **PEER REVIEWED**
AVERAGE DAILY INTAKE
The US Food and Nutrition Board has recommended a safe and adequate
dietary intake of 50-200 ug chromium/day... . /Total chromium/
[Seiler, H.G., H. Sigel and A. Sigel (eds.). Handbook on the Toxicity
of Inorganic Compounds. New York, NY: Marcel Dekker, Inc. 1988. , p.
245] **PEER REVIEWED**
AVERAGE DAILY INTAKE
Estimated safe and adequate daily dietary intakes of chromium: infants:
0-0.5 yr: 0.01-0.04 mg: 0.5-1 yr: 0.02-0.06 mg: children and
adolescents: 1-3 yr: 0.02-0.08 mg: 4-6 yr: 0.03-0.12 mg: 7-10 yr:
0.05-0.2 mg: 11+ yr: 0.05-0.2 mg: adults: 0.05-0.2 mg /From table/
/Total chromium/ [Gilman, A.G., L.S.Goodman, and A. Gilman. (eds.).
Goodman and Gilman's The Pharmacological Basis of Therapeutics. 7th ed.
New York: Macmillan Publishing Co., Inc., 1985. , p. 1548] **PEER
REVIEWED**
AVERAGE DAILY INl'AKE
... In the range of 0.03-0.1 mg. ... 280, 4, and 0.28 ug from food,
water, and air. /Total chromium/ [Friberg, L., Nordberg, G.F., Kessler,
E. and Vouk, V.B. (eds). Handbook of the Toxicology of Metals. 2nd ed.
Vols I, II.: Amsterdam: Elsevier Science Publishers B.V., 1986. V2l89]
**PEER REVIEWED**
AVERAGE DAILY INl'AKE
IN USA VARIES WIDELY DUE TO DIET AND GEOGRAPHY. EST RANGE F~ 5 TO 115
UG/DAY WITH AN AVG OF 60-65 UG/DAY ... TO 5-500 UG/DAY, WITH AN AVG OF
-------
Toxicological Profile
Chromiwn
August 21. 1990
Page 30 of 41
,
\
Council. Drinking Water & Health Volume 1. Washington, DC: National
Academy Press, 1977. , p. 242J **PEER REVIEWED**
PROBABLE EXPOSURES
EXPOSURE TO CHRafiUM METAL DOES NOT GIVE RISE TO PULMONARY FIBROSIS OR
PNEUMOCONIOSIS. [American Conference of Governmental Industrial
Hygienists. Documentation of the Threshold Limit Values and Biological
Exposure Indices. 5th ed. Cincinnati, OH: , p. 139J **PEER REVIEWED**
PROBABLE EXPOSURES
Stainless steel use in mixing containers in the baking industries may
be the source of extraneous chromium in food. [Nat'l Research Council
Canada: Effects of Chromium in the .Canadian Envir p.43 (976) NRCC
No.ls017J **PEER REVIEWED*.
PROBABLE EXPOSURES
Common operations in which exposure to chromium metal or insoluble
chromium salts may occur includes the following: 1) use in fabrication
of alloys: 2) use in preparation of alloy steels to enhance corrosion
and heat resistance: 3) use in fabrication of plated products for
decoration or increased wear resistance: 4) use in production of non
ferrous alloys to impart special qualities to the alloys: 5) use in
production and processing of insoluble salts: 6) use as chemical
intermediates: use in textile industry in dyeing, silk treating,
printing, and moth proofing wool; 7) use in leather industry in
tanning: use in photographic fixing baths: 8) use as catalysts for
halogenation, alkylation, and catalytic cracking of hydrocarbons: and
9) use as fuel additives and propellant additives: in photographic
fixing baths and in ceramics. /Chromium metal and insoluble chromium
salts/ [Mackison, F. W., R. S. Stricoff, and L. J. Partridge, Jr.
(eds.). NIOSH/OSHA - Occupational Health Guidelines for Chemical
Hazards. DHHS (NIOSH) Publication, p. 3 J "PEER REVIEWED"
PROBABLE EXPOSURES
Common operations in which exposure to soluble chromic and chromous
salts may occur include the following: 1) use in textile treatment in
dyeing, printing, moth proofing, and water proofing: use in tanning of
leather in gloves, garments, and shoe uppers: 2) use in manufacture of
pigments of green varnishes, inks, paints, and glazes: 3) use in metal
treatment and polishing: 4) use in photographic fixing baths for
hardening of emulsions: use as catalysts and in manufacture of
catalysts: and 5) use in chemical synthesis: use as corrosion
inhibitors. /Sol chromic & chromous salts (as Cr)/ [Mackison, F. W., R.
S. Stricoff, and L. J. Partridge, Jr. (eds.). NIOSH/OSHA - Occupational
Health Guidelines for Chemical Hazards. DHHS(NIOSH) Publication, p. 3]
..PEER REVIEWED..
PROBABLE EXPOSURES
OCCUPATIONAL EXPOSURE: CHRCMIUM & ITS CMPD ARE FOUND IN 3 MAIN TYPES OF
INDUST ACTIVITY: (I) M:>ST CR DERIV ARE USED IN METALLURGICAL INDUST ...
(II) CHRafiUM CMPD ARE ... C~ONENT OF REFRACTORY MATERIALS... &
(III) MANY OF HIGHLY COLORED CHROMATE SALTS... ARE USED IN PIGMENT,
PAINT, TANNING' DYEING INDUSTRIES. [IARC. Monographs on the Evaluation
of the Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-1985.
(Multivolume work). V23 243 (1980)] **PEER REVIEWED**
PROBABLE EXPOSURES
In decreasing order, the est levels of exposure are: 1) occupational:
2) food: 3) water: and 4) air. /Total chromium/ [USEPA: Drinking Water
Criteria Document: Chromium (Draft) p.1 (7/27/81) EPA 68-02-3651]
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Toxicological Profile
Chromiwn
August 21. 1990
Page 31 of 41
10
PROBABLE EXPOSURES .
... Inhalation of the dust and fumes released during the manufacture of
dichromate from chromite ore; inhalation of chromic acid mist during
the electroplating and surface treatment of metals; .cind skin contact in
various manufacturing processes. /Total chromium/ [Sittig, M. Handbook
of Toxic and Hazardous Chemicals and Carcinogens, 1985. 2nd ed. Park
Ridge, NJ: Noyes Data Corporation, 1985. , p. 245] **PEER REVIEWED**
IMMEDIATELY DANGEROUS TO LIFE OR HEALTH
500 mg/cu m [NIOSH. Pocket Guide to Chemical Hazards. 2nd Printing.
DHHS (NIOSH) Pub1. No. 85-114. Washington, D.C.: U.S. Dept. of Health
and Human Services, NIOSH/Supt. , p. 82] **QC REVIEWED**
ACCEPTABLE DAILY INl'AKES
Estimated Adequate and Safe Intake (EASI) levels for chromium: Infants:
1) age 0.0 to 0.5 yr: 0.01 to 0.04 mg/day, 2) age 0.5 to 1.0 yr: 0.02
to 0.06 mg/day; Children: 1) age 1 to 3 yr: 0.02 to 0.08 mg/day, 2) age
4 to 6 yr: 0.03 to 0.12 mg/day, 3) age 7 to 10 yr: 0.05 to 0.20 mg/day,
and 4) age> or = to 11 yr: 0.05 to 0.20 mg/day; and Adults: 0.05 to
0.20 mg/day. /Chromium, from table/ [NAS; Recommended Dietary
Allowances (1980) as cited in USEPA; Health Assessment Document:
Chromium p.6-2 (1984) EPA 600/8-83-014F] **PEER REVIEWED**
OSHA STANDARDS
Meets criteria for OSHA medical records rule. /Total chromium/ [29 CFR
1910.20 (7/1/88)] **PEER REVIEWED**
OSHA STANDARDS
8 hr Time-Weighted avg: 1 mg/cu m /Chromium, metal & insol salts (as
Cr)/ [29 CFR 1910.1000 (7/1/88)] **PEER REVIEWED**
THRESHOLD LIMIT VALUES
Time Weighted Avg (TWA) 0.5 mg/cu m (1981) [American Conference of
Governmental Industrial Hygienists. Threshold Limit Values and
Biological Exposure Indices for 1989-1990. Cincinnati, OH: American,
p. 17] **QC REVIEWED**
THRESHOLD LIMIT VALUES
Excursion Limit Recommendation: Excursions in worker exposure levels
may exceed three times the TLV-TWA for no more than a total of 30 min
during a work day and under no circumstances should they exceed five
times the TLV-TWA, provided that the TLV-TWA is not exceeded. [American
Conference of Governmental Industrial Hygienists. Threshold Limit
Values and Biological Exposure Indices for 1989-1990. Cincinnati, OH:
American, p. 6] **QC REVIEWED**
RCRA REQUIREMENl'S
A solid waste containing chromium mayor may not become characterized
as a hazardous waste when subjected to the Toxicant Extraction
Procedure listed in 40 CFR 261.24, and if so characterized, must be
managed as a hazardous waste. [40 CFR 261.24 (7/1/88)] **PEER
REVIEWED**
SAMPLING PROCEDURES
Ana1yte: Trace metals; Matrix: Air; Procedure: Filter collection, acid
digestion /Chromium and chromium cmpd/ [U.S. Department of Health,
Education Welfare, Public Health Service. Center for Disease Control,
National Institute for OCcupational Safety Health. NIOSH Manual of V5
173-1] **PEER REVIEWED**
SAMPLING PROCEDURES
Measurements to determine employee exposure are best taken so that the
average eight hour exposure is based on a single eight hour sample or
on two four hour samples. Several short-time interval samples (up to 3:
-------
Toxicological Profile
Chromium
August 21. 1990
Page 32 of 41
samples should be taken in the employee's breathing zone (air that
would most nearly represent that inhaled by the employee). /Chromium
metal, insoluble chromium salts, sol chromic and chromous salts (as
Cr)/ [Mackison, F. W., R. S. Stricoff, and L. J. Partridge, Jr. (eds.).
NIOSH/OSHA - Occupational Health Guidelines for Chemical Hazards.
DHHS (NIOSH) Pu,blication , p. 2] **PEER REVIEWED**
SAMPLING PROCEDURES
Measurements to determine employee ceiling exposure are best taken
during periods of maximum expected airborne concentrations of chromium
metal or insoluble chromium salts. Each measurement should consist of a
fifteen minute sample or series of.consecutive samples totalling
fifteen minutes in the employee's breathing zone (air that would most
nearly represent that inhaled by the employee). A minimum of three
measurements should be taken on one work shift with the highest level
of all measurements taken as an estimate of the employee's exposure.
/Chromium metal, insoluble chromium salts, chromic acid and chromates/
[Mackison, F. W., R. S. Stricoff, and L. J. Partridge, Jr. (eds.).
NIOSH/OSHA - Occupational Health Guidelines for Chemical Hazards.
DHHS(NIOSH) Publication, p. 2] **PEER REVIEWED**
SAMPLING PROCEDURES
Analyte: Chromium: Matrix: air: Sampler: filter (0.8 um celulose ester
membrane): Flow rate: 1-3 l/min: Vol: min: 10 I @ 0.5 mg/cu m, max:
1000 1: Stability: stable /Chromium and chromium cmpd/ [U.S. Department
of Health and Human Services, Public Health Service. Centers for
Disease Control, National Institute for Occupational Safety and Health.
NIOSH V1 7024-1] **PEER REVIEWED**
SAMPLING PROCEDURES
Analyte: Chromium: Matrix: air: Sampler: filter (0.8 um cellulose ester
membrane): Flow rate: 1 l/min: Vol: min: 10 1, max: 400 1: Stability:
At least 1 yr at 25 deg C /Chromium and chromium cmpd/ [U.S. Department
of Health and Human Services, Public Health Service. Centers for
Disease Control, National Institute for Occupational Safety and Health.
NIOSH V2 7200-1] **PEER REVIEWED**
SAMPLING PROCEDURES
Analyte: Chromium: Matrix: air: Sampler: filter (0.8 um cellulose
membrane): Flow rate: 1-4 l/min: Vol: min: 5 1, max: 1000 1: Stability:
stable /Chromium and chromium cmpd/ [U.S. Department of Health and
Human Services, Public Health Service. Centers for Disease Control,
National Institute for Occupational Safety and Health. NIOSH V1 7300-1]
**PEER REVIEWED** .
SAMPLING PROCEDURES
Analyte: Chranium; Specimen: Blood or tissue; Vol: 10 ml blood, or 1 9
tissue: Preservative: Heparin for blood, none for tissue: Controls:
collect 3 blood specimens from unexposed workers: Stability: not
established /Chromium and chromium cmpd/ [U.S. Department of Health and
Human Services, Public Health Service. Centers for Disease Control,
National Institute for Occupational Safety and Health. NIOSH V1 8005-1]
**PEER REVIEWED**
SAMPLING PROCEDURES
Analyte: Chromium: Specimen: urine: Vol: 50-200 ml in polyethylene
bottle: Preservative: 5 ml concn nitric acid added after collection:
Controls: collect at least 3 urine specimens from unexposed workers:
Stability: not established /Chromium and chromium cmpd/ [U.S.
Department of Health and Human Services, Public Health Service. Centers
for Disease Control, National Institute for Occupational Safety and
-------
Toxicological Profile
Chromium
August 21. 1990
Page ~3 of 41
"
SAMPLING PROCEDURES
ANALYTE: CHROMIUM, MATRIX: AIR, PROCEDURE: FILTER COLLECTION, ACID
DIGESTION, INDUCTIVELY COUPLED PLASMA-ATOMIC EMISSION SPECTROSCOPY
ANALYSIS, RANGE: 5-2000 UG/CU M, DETECTION LIMIT: 1.-.3 NG/ML. /CHRCIoITUM
AND CHRCIoITUM SALTS/ [U.S. Department of Health, Education Welfare,
Public Health Service. Center for Disease Control, National Institute
for Occupational Safety Health. NIOSH Manual of V7 351-1] **PEER
, REVIEWED**
SAMPLING PROCEDURES
ANALYTE: CHRCIoITUM, SOL CHROMIC AND CHROMOUS SALTS AS CHROMIUM. MATRIX:
AIR. PROCEDURE: FILTER COLLECTION, .NITRIC ACID DIGESTION /CHROMIUM AND
CHROMIUM CHPD/ [U.S. Department of Health, Education Welfare, Public
Health Service. Center for Disease Control, National Institute for
Occupational Safety Health. NIOSH Manual of V3 S323-1] **PEER
REVIEWED * *
SAMPLING PROCEDURES
Direct preconcentration of chromium in natural waters using a cationic
ion exchange resin is likely to occlude much of the Cr. /Chromium and
chromium crnpd/ [National Research Council Canada: Effects of Chromium
in the Canadian Envir p. 118 (1976) NRCC No.15017] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
It can be shown that polarography is most effectually suitable to the
determination of chromium(VI) compounds. Chromium (VI) is
electrochemically active over the entire pH range, so that medium pH
can be selected for measuring, thus protecting samples most effectively
from undergoing redox reactions during the analytical procedure. In
some cases sample pre-treatment can be employed to eliminate reductants
prior to final measurement. very few methods are available to
selectively measure chromium(III). [Harzdorf AC: Int J Environ Anal
Chem 29 (4): 249-61 (1987)] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Sample matrix: plasma: Sample preparation: wet washing with nitric
acid/hydrochlorous aCid/sulfuric acid: residue complexed with APDC and
extracted with MIBK: evaporated residue dissolved in nitric
acid/hydrochloric acid, and soln deposited on a poly carbonate foil.
/Tota1 chromium/ [DHHS/ATSDR: Toxicological Profile for Chromium
(Draft) p.90 (10/87)] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Sample matrix: air: Sample preparation: air particulate matter
collected on filter and irradiated with x-ray photons. /Total chromium/
[Wiersem JM et al: APCA AnnU Meet Proc 77th 84 p.15 (1984) as cited 1n
DHHS/ATSDR: Toxicological Profile for Chromium (Draft) p.90 (10/87)]
**PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Sample matrix: wet atmospheric deposition (snow), determination in
soluble ... part: Sample preparation: melted snow filtered through
Nucleophore filter, the filtrate acidified with nitric acid and dried
by freeze drier, residue dissolved in nitric acid, this pre concentrated
soln placed in plastic tubes, both plastic tube and Nucleophore filter
irradiated with protons. /Total chromium/ [Jarvis RE et al; Int J
Environ Anal Chem 15: 89-106 (1983) as cited in DHHS/ATSDR:
Toxicological Profile for Chromium (Draft) p.90 (10/87)] **PEER
REVIEWED**
ANALYTIC LABORATORY METHODS
Sample matrix: wastewater; Sample preparation: sample mixed with a
-------
Toxicological Profile
Chromiwn
August 21. 1990
Page 34 of 41
heated in water bath at 50 deg C for 10 minutes. /Total chromium/ [Oi
WB, Zhu LZ; Talenta 33 (8): 694-6 (1986) as cited in DHHS/ATSDR;
Toxicological Profile for Chromium (Draft) p.91 (10/87)J **PEER
REVIEWED * * .
ANALYTIC LABORATORY METHODS
Sample matrix: body fluids (milk, urine, etc); Sample preparation:
dried sample ashed by oxygen plasma, hydrogen peroxide addition,
drying, and dilution in normal hydrochloric acid. /Total chromium/
[DHHS/ATSDR; Toxicological Profile for Chromium (Draft) p.92 (10/87)J
**PEER REVIEWED**
ANALYTIC LABORATORY METHODS
MATRIX: WASTE WATER; PROCEDURE: PULSE POLAROGRAPHY; SESITIVITY: 0.01
MG/L (HEXAVALENT); HEIGL, A; POLAROGRAPHIC DETERMINATION OF CHROMIUM IN
WASTE WATER (GER); CHIMIA, 32: 339 (1978). /TOTAL CHROMIUM/ [IARC.
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: World Health Organization, International Agency for
Research on Cancer, 1972-1985. (Multivolume work). V23 251 (1980)J
**PEER REVIEWED..
ANALYTIC LABORATORY METHODS
MATRIX: SEAWATER; PROCEDURE: ISOTOPE DILUTION MASS SPECTROMETRY;
SENSITIVITY: 0.001 UG/L; OSAKI S ET AL; DETERMINATION OF HEXAVALENT AND
TOTAL CHROMIUM IN SEA WATER BY ISOTOPE DILUTION MASS SPECTROMETRY
(JPN); BUNSEKI KAGAKU, 25: 358 (1976). /TOTAL CHROMIUM/ [lARC.
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: World Health Organization, International Agency for
Research on Cancer, 1972-1985. (Multivolume work). V23 252 (1980)J
*.PEER REVIEWED..
ANALYTIC LABORATORY METHODS
MATRIX: RIVER WATER; PROCEDURE: X-RAY EMISSION ANALYSIS; LI MC ET AL;
DETERMINATION OF TRACE ELEMENTS IN ENVIRONMENTAL SAMPLES BY
PROTON-INDUCED X-RAY EMISSION ANALYSIS (CHIN); KIO HSUEH TUNG PAO, 24:
19 (1979). /TOTAL CHROMIUM/ [IARC. Monographs on the Evaluation of the
Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-1985.
(Multivolume work). V23 252 (1980)J .*PEER REVIEWED..
ANALYTIC LABORATORY METHODS
METALS IN SOLN ARE DETERMINED DIRECTLY BY ATafiC ABSORPTION
SPECTROPHOTOMETRY; SUSPENDED METALS ARE SEPARATED BY MEMBRANE
FILTRATION, OR SUSPENSION IS DISSOLVED & ANALYZED... APPLICABLE TO
SURFACE AND SALINE WATER, & ~STIC , INDUSTRIAL WATERS. /TOTAL
CHROMIUM/ [Association of Official Analytical Chemists. Official
Methods of Analysis. 10th ed. and supplements. Washington, DC:
Association of Official Analytical Chemists, 1965. New editions through
13/557 33.089J *.PEER REVIEWED..
ANALYTIC LABORATORY METHODS
ANALYTE: TOTAL PARTICUIATE CHROMIUM; MATRIX: AIR; RANGE: 0.01 TO LESS
THAN 0.4 MG/CU M AIR; PROCEDURE: ATOMIC ABSORPTION /TOTAL PARTICUIATE
CHROMIUM! [U.S. Department of Health, Education Welfare, Public Health
Service. Center for Disease Control, National Institute for
Occupational Safety Health. NIOSH Manual of V1 152-1] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Analyte: Chromium: Matrix: air; Technique: Atomic absorption, flame;
Wavelength: 357.9 nm; Range: 5-250 ug/sample; Est LOD: 0.06 ug/sample:
Precision: 0.04-0.06 (%Sr); Interferences: iron and nickel, minimized
by high temp flame /Total chromium/ [U.S. Department of Health and
-------
Toxicological Profile
Chromium
August 21. 1990
Page 3~ of 41
t.
National Institute for Occupational Safety and Health. NIOSH V1 7024-1)
**PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Analyte: Chromium: Matrix: air: Procedure: X-ray fluorescence: Range:
0.04 to 0.42 mg/cu m: Est LOD: 2 ug each metal/sample: Precision: 0.068
(%Sr): Interferences: Controlled with wavelength dispersive
fluorescence, more severe with energy dispersive systems, cobalt in
fumes requires different ratio standard element /Total chromium/ [U.S.
Department of Health and Human Services, Public Health Service. Centers
for Disease Control, National Institute for OCcupational Safety and
Health. NIOSH V2 7200-1) **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Analyte: Chromium: Matrix: air: Procedure: inductively coupled argon
plasma, atomic emission spectroscopy: Wavelength: 205.6 nm: Range:
2.5-1000 ug/sample: Precision: 0.053 @ 2.5 ug/filter, 0.016 @ 1000
ug/filter: Interferences: spectral, minimized by wavelength selection,
interelement and background correction /Total chromium/ [U.S.
Department of Health and Human Services, Public Health Service. .Centers
for Disease Control, National Institute for Occupational Safety and
Health. NIOSH V1 7300-1) **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Analyte: Chromium. Matrix: Air. Procedure: Filter collection, acid
digestion, Inductively-coupled plasma-atomic emission spectroscopy
(ICP-AES) analysis. Instrumental detection limit: 1.3 ng/ml.
Sensitivity intensity: 0.50 ug/ml. /Total chromium/ [U.S. Department of
Health, Education Welfare, Public Health Service. Center for Disease
Control, National Institute for Occupational Safety Health. NIOSH
Manual of V7 351-1] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
SPARK SOURCE MASS SPECTROSCOPY. EVANS JR CA & MORRISON GH, TRACE
ELEMENT SURVEY ANALYSIS OF BIOLOGICAL MATERIALS BY SPARK SOURCE MASS
SPECTROMETRY, ANALYT CHEM 40: 869 (1968). /TOTAL CHROMIUM/ [IARe.
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: World Health Organization, International Agency for
Research on Cancer, 1972-1985. (Multivolume work). V2 107] **PEER
REVIEWED**
ANALYTIC LABORATORY METHODS
GAS CHROMATOGRAPHY. TAYLOR MI.: GAS LIQUID CHROMATOGRAPHY OF TRACE
METALS. IN: MERTZ W & COMATZER WE, EDS, NEWER TRACE ELEMENTS, NEW YORK,
MARCEL DEKKER, P 363 (1971). /TOTAL CHROMIUM/ [!ARC. Monographs on the
Evaluation of the Carcinogenic Risk of Chemicals to Man. Geneva: World
Health Organization, International Agency for Research on Cancer,
1972-1985. (Multivolume work). V2 107) **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
EPA Method 7190: Chromium (Atomic Absorption, Direct Aspiration) Method
7190 is applicable for the determination of metals in solution by
atomic absorption spectrometry. Preliminary treatment of waste water,
ground water, Extraction Procedure (EP) extracts, and industrial waste
is always necessary because of the complexity and variability of sample
matrix. After aspiration and atomization of the sample in a flame, a
light beam from a hollow cathode lamp or an electrodeless discharge
lamp is directed through the flame into a monochromator and onto a
detector that measures the amount of light absorbed. ... The light
energy absorbed by the flame is a measure of the concentration of that
metal in the sample. The performance characteristics for an aqueous
-------
, Toxicological Profile
Chromium
August 21. 1990
Page 36. of 41
detection limit of 0.05 mg/l. /Total chromium/ [USEPA: Test Methods for
Evaluating Solid Waste SW-846 (1986)] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
EPA Method 7191: Chranium (Atanic Absorption, Furnace, Technique) Method
7191 is applicable for the determination of metals in solution by
atomic absorption spectrometry. For certain samples, lower
concentrations may be determined using this technique. To ensure valid
data, each matrix must be examined for interference effects and, if
detected, treat them accordingly, using either successive dilution,
matrix modification, or method of standard additions. If poor
recoveries are obtained, a matrix ~odifier may be necessary. A
representative aliquot of a sample is placed in the graphite tube in
the furnace, evaporated to dryness, charred, and atomized. ...
Radiation from a given excited element is passed through the vapor
contain1ng ground-state atoms of that element. ... The metal atoms to
be measured are placed in the beam of radiation by increasing the
temperature of the furnace, thereby causing the injected specimen to be
volatilized. A monochromator isolates the characteristic radiation from
the hollow cathode lamp or electrodeless discharge lamp, and a
photosensitive device measures the attenuated transmitted radiation.
The optimum concentration range is 5-100 ug/l with a detection limit of
1 ug/l. /Total chromium/ [USEPA: Test Methods for Evaluating Solid
Waste SW-846 (1986)] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Direct Aspiration Atomic Absorption Spectrometry is used for the
determination of Chromium. Using air-acetylene as the flame gas at a
wavelength of 357.9 nm, the detection limit is 0.02 mg/l, with a
sensitivity of 0.1 mg/l, at an optimum concentration range of 0.2-10
mg/l. /Total chranium/ [Franson MA (Ed); Standard Methods for the
Examination of Water and Wastewater p.154 (1985)] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
EPA Method 200.7: An Inductively Coupled Plasma - Atomic Emission
Spectrophotmetric method for the determination of dissolved, suspended,
or total elements in drinking water, surface water, and domestic and
industrial wastewaters, is described. Chromium is analyzed at a
wavelength of 267.716 nm and has an estimated detection limit of 7
ug/l. /Total chromium/ [40 CFR 136 (7/1/88)] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Analyte: Chromium; Matrix: air; Wavelength: 357.9 nm; Range: 5-250
ug/samp: Est LOD: 0.06 ug/sample; Precision: 0.04-0.06: Interferences:
iron and nickel, minimized by high temp fl~~e. ITotal chromiuml [U.S.
Department of Health and Human Services, Public Health Service. Centers
for Disease Control, National Institute for Occupational Safety and
Health. NIOSH V1 7024-1] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Filtering materials contain chromium which can.be transferred to the
sample, ie, Delbag= 0.19 ppm Cr, Millipore- 17.6 ppm Cr, Millipore=
17.6 ppm Cr, Nucleopore- 0.57 ppm Cr. /Total chranium/ [Filby RH:
p.59-79 in Heavy Metals in the Environment (1973) as cited in National
Research Council Canada; Effects of Chranium in the Canadian Envir
p.118 (1986) NRCC No.1S017] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Low temp, oxygen plasma ashing should be used over high temp drying
ashing to minimize Cr loss by volatilization. ITotal chromiuml [Wolf
WR; Fed Proc 34: 927 (1975) as cited in National Research Council
-------
, Toxicological Profile
, Chromium
August 21. 1990
Page 37. of 41
No.1S017] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Gravimetric determination of chromium involves dissolution of the
sample, isolation by separation, precipitation of hydrous Cr oxide and
ignition to chromic oxide: detection limit= S ppm. /Total chromium/
[National Research Council Canada: Effects of Chromim in the Canadian
Envir p. 126 (1976) NRCC No.1S017] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Electron microprobe analysis, where a sample is bombarded with high
energy electrons causing emission of characteristic x-rays has a
detection limit of 100-2,000 ppm. ~roton bombardment and proton
microprobe analysis has a detection limit of 0.1 ppm chromium in a
sample area 1 um in diam. Laser (high energy pulse of coherent light)
and ion (inert gas or oxygen ions accelerated to high energies)
microprobe methods have a detection limit of 1 ppm. /Total chromium/
[Nat'l Research Council Canada: Effects of Chromium in the Canadian
Envir p.134 (1976) NRCC No.15017] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Electron spectroscopy for chemical analysis (ESCA) uses bombardment of
sample with photons (x-rays) causing elements to project electrons.
Elemental analysis and determination of oxidation states is possible,
with a detection limit of 1,000 ppm. /Total chromium/ [Nat'l Research
Council Canada: Effects of Chromium in the Canadian Envir p.136 (1976)
NRCC No.15017) **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
Analysis of soil samples for metals content is normally done using an
air dried sample ground with a porcelain mortar and pestle to pass a 2
rom sieve and digested using concentrated nitric acid or hydrofluoric
acid in an acid digestion bomb. Extracts can be analyzed for ...
chromium ... . /Total chromium/ [Brown, K.W., G. B. Evans, Jr., B.D.
Frentrup (eds.). Hazardous Waste Land Treatment. Boston, MA:
Butterworth Publishers, 1983. , p. 105] **PEER REVIEWED**
ANALYTIC LABORATORY METHODS
CHROMIUM WAS DETERMINED IN ENVIRONMENTAL MATERIALS BY NEUTRON
ACTIVATION ANALYSIS, ATOMIC ABSORPTION & GAS CHROMATOGRAPHY IN 3
LABORATORIES. /TOTAL CHROMIUM/ [PIERCE JO ET AL: MEAS, DETECT CONTROL
ENVIRON POLLUT, PROC INT SYMP: 357-68 (1976)] **PEER REVIEWED**
CLINICAL LABORATORY METHODS
It can be shown that polarography is most effectually suitable to the
determination of chromium (VI) compounds. Chromium (VI) is
electrochemically active over the entire pH range, so that medium pH
can be selected for measuring, thus protecting samples most effectively
from undergoing redox reactions during the analytical procedure. In
some cases sample pre-treatment can be employed to eliminate reductants
prior to final measurement. Very few methods are available to
selectively measure chromium(III). [Harzdorf AC: Int J Environ Anal
Chem 29 (4): 249-61 (1987)] **PEER REVIEWED**
CLINICAL LABORATORY METHODS
SPARK SOURCE MASS SPECTROSCOPY OF BIOLOGICAL MATERIALS: EVANS JR CA &
MORRISON GH, TRACE ELEMENT SURVEY ANALYSIS OF BIOLOGICAL MATERIALS BY
SPARK SOURCE MASS SPECTRCMETRY, ANALYT CHEM 40: 869 (1968). /TOTAL
CHROMIUM/ [LARC. Monographs on the Evaluation of the Carcinogenic Risk
of Chemicals to Man. Geneva: World Health Organization, International
Agency for Research on Cancer, 1972-1985. (Multivolume work). V2107
(1973)] **PEER REVIEWED**
-------
Toxicological Profile
Chromium
August 21. 1990
Page 38. of 41
Whole human blood; X-ray fluorescence with sensitivity of 0.15 mg/l:
Paradellis T; Eur J Nucl Med 2: 277-279 (1977); Blood serum; Atomic
Absorption Spectroscopy with sensitivity of 0.02 mg/l: Arpadzhyan S,
Kachov I; Zentralbl Pharm 117: 237-240 (1978) , Long~path photometry;
Yarbro S, Flaschka HA; Microchem J 21: 415-423 (1976); Urine; Gas
Chromatography with sensitivity of 0.1 pq: Ryan TR, Vogt CRH; J
Chromatogr 130: 346-350 (1977). ITota1 chromium/ [!ARC. Monographs on
the Evaluation of the Carcinogenic Risk of Chemicals to Man. Geneva:
World Health Organization, International Agency for Research on Cancer,
1972-1985. (Multivolume work). V23 253 (1980)] **PEER REVIEWED**
CLINICAL LABORATORY METHODS .
The traditional colorimetric method employing the violet complex of
1,5-diphenylcarbazide is still a valuable method for analyzing chromium
in urine. The detection limit is 3.5 ng but method is subject to
interference by... ions. Flame photometry, X-ray emission
spectrography' polarography are less sensitive than diphenylcarbazide
method. Polarographic methods with detection limit as low as 1 ng have
been described, but ... are subject to interference by... ions:
Beyermann K; Z Anal Chem 190: 4-33 & 346-369 (1962). Neutron activation
... has been used for determination of chromium in urine: Cornelis R et
al; Anal Chim Acta 78: 317-327 (1975). /Total chromium/ [Friberg, L.,
Nordberg, G.F., Kessler, E. and Vouk, V.B. (eds). Handbook of the
Toxicology of Metals. 2nd ed. Vols I, II.: Amsterdam: Elsevier Science
Publishers B.V., 1986. V2 187] **PEER REVIEWED**
CLINICAL LABORATORY METHODS
Analyte: Chromium; Matrix: blood or tissue; Procedure:
Inductively-coupled argon plasma-atomic emission spectroscopy;
Wavelength: 205.6 nm; Range: 10 to 10,000 ug/100 g blood, 2 to 2000
ug/g tissue; Est LCD: 1 ug/100 g blood, 0.2 ug/g tissue; Precision: 4.7
(%Sr); Interferences: spectral, minimized by wavelength selection.
/Total chromium/ [U.S. Department of Health and Human Services, Public
Health Service. Centers for Disease Control, National Institute for
Occupational Safety and Health. NIOSH V1 8005-1] **PEER REVIEWED**
CLINICAL LABORATORY METHODS
Analyte: Chromium; Matrix: urine; Procedure: Inductively-coupled
argon-plasma, atomic emission spectroscopy; Extraction media:
polydithiocarbamate resin; Wavelength: 205.6 nm; Range: 0.25-200
ug/sample; Est LCD: 0.1 ug/sample; Precision: 0.078 (%Sr)
Interferences: spectral, minimized by wavelength selection. /Total
chromium/ [U.S. Department of Health and Human Services, Public Health
Service. Centers for Disease Control, National Institute for
Occupational Safety and Health. NIOSH V1 8310-1] **PEER REVIEWED**
CLINICAL LABORATORY METHODS
ANALYTE: CHRCIfiUM, MATRIX: WHOLE HUMAN BLOOD, PROCEDURE: X-RAY
FLUORESCENCE, SENSITIVITY: 0.15 MG/L. /TOTAL CHROMIUM/ [IARC.
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to
Man. Geneva: world Health Organization, International Agency for
Research on Cancer, 1972-1985. (Multivolume work). V23 251] **PEER
REVIEWED**
CLINICAL LABORATORY METHODS
Urine is diluted with water and analyzed directly by graphite-furnace
atomic absorption spectrometry, using tungsten-halogen background
correction. Reaqents: stock soln; 1 mq/ml chromium ion (Fisher
reference std); Aqueous standards: 5, 10, 20, 40, and 80 uq/l (All soln
should be stored in Polyethylene containers which have been washed in
-------
, Toxicological Profile
Chromium
August 21. 1990
Page 39 .of 41
spectrometer with graphite furnace, optical temperature sensor, and
tungsten-halogen background corrector, Chromium hollow cathode lamp,
Argon purge gas in interrupt mode. (40 ml/min); Procedure: dilute 0.5
ml of the urine specimen or Aqueous standards to 2.5~ with deionized
water, inject 20 ul ... into graphite furnace, measure absorption at
357.9 nm; Evaluation: sensitivity, 0.1 ug/l; linearity, 5-40 ug/l with
dilution: CV, not established; Relative recovery, not established;
Interferences: none are known. ITotal chromiuml [Baselt RC; Biological
Monitoring Methods for Industrial Chemicals p. 82-83 (1980») **PEER
REVIEWED * *
CLINICAL LABORATORY METHODS
CELLULAR ANALYSIS FOR CHROMIUM ACCa-tPLISHED BY ION MICROSCOPE OR LASER
MICROPROBE TECHNIQUES. lTOTAL CHROMIUMI [IARC. Monographs on the
Evaluation of the Carcinogenic Risk of Chemicals to Man. Geneva: World
Health Organization, International Agency for Research on Cancer,
1972-1985. (Multivolume work). V2107 (1973») **PEER REVIEWED**
CLINICAL LABORATORY METHODS
Analysis by emission spectroscopy of unashed, dried biological samples
using a DCARC excitation source with photoplate detection has a
detection limit of 0.5 ppm and> or = to 15% precision. ITotal
chromiuml [Nat'l Research Council Canada; Effects of Chromium in the
Canadian Envir p.129 (1976) NRCC No.15017) **PEER REVIEWED**
CLINICAL LABORATORY METHODS
50% of chromium detected in blood samples originated from distilled
water reagent or glass surfaces of equipment. ITotal chromiuml [Wolf WR
et al: Anal Chern 44: 616-18 (1972) as cited in Nat'l Research Council
Canada; Effects of Chromium in the Canadian Envir p.127 (1976) NRCC
No.15017] **PEER REVIEWED**
CLINICAL LABORATORY METHODS
Analyte: chromium; matrix: hair; Procedure: AAS; conventional reference
range: 0.21 + or - 0.14 ug/g (mean + or - 1 SD); international
recommended reference range: 4.0 + or - 2.7 nmol/g (mean + or - 1 SD).
ITotal chromiuml [Tietz, N.W. (ed.). Clinical Guide to Laboratory
Tests. Philadelphia, PA: W.B. Saunders Co., 1983. , p. 120) **PEER
REVIEWED**
CLINICAL LABORATORY METHODS
Several methods are available for measuring elemental chromium in ...
biological samples. These include atomic absorption spectroscopy,
instrumental neutron activation analysis, X-ray fluorescence, and
particle-induced X-ray emissions (PIXE). While these methods are
sensitive to the ppb level, problems in sample collection, preparation
and interferences are shared by all. In biological samples, neutron
activation analysis data tend to be lower than atomic absorption and
X-ray fluorescence data. ... Generally, a comparison of the results
indicates that modified atomic absorption spectroscopy provides
relatively reliable analyses. Another problem in chromium determination
is the lack of adequate reference materials. Ideally, reference
materials should match the samples to be analyzed with respect to
chromium levels and each reference composition. Because the materials
are not yet standardized, inter-laboratory comparisons are difficult.
ITotal chromiuml [USEPA; Health Assessment Document: Chromium p.2-4
(1984) EPA 600/8-83-014F) **PEER REVIEWED**
CLINICAL LABORATORY METHODS
Sample matrix: blood, serum, orchard leaves; Sample preparation: sample
after wet digestion converted to a volatile chelate usually with
-------
Toxicological Profile
Chromium
August 21. 1990
Page 4Q of 41
Anal Chem 17 (2): 113-70 (1984) as cited in DHHS/ATSDR; Toxicological
Profile for Chromium (Draft) p.92 (10/87)] **PEER REVIEWED**
SPECIAL REPORTS
Riggin RM et al; Gov Rep Announcements Index (12): 1~56 (1984). A
critical literature review of the state of the art for speciation of
arsenic, chromium, manganese, and nickel in atmospheric samples was
performed. Techniques for distinguishing the compound forms and valence
states of these metals were critically assessed.
SPECIAL REPORTS
Eisler R; Gov Rep Announcements Index (8): 1-70 (1986). Ecological and
toxicological aspects of chromium in the environment are reviewed, with
special reference to North American natural resources. Subtopics
include chemical properties and background concentrations in biological
and abiotic samples, persistence, beneficial and protective properties,
toxic and sublethal effects, results of field investigations, and
current recommendations for the protection of sensitive species of fish
and wildlife.
SPECIAL REPORTS
Nat'l Research Council Canada; Effects of Chromium in the Canadian
Environment (1976) NRCC No 15017
SPECIAL REPORTS
Nat'l Research Council Canada; Executive Reports: Effects of Chromium,
Alkali Halides, Arsenic, Asbestos, Mercury, Cadmium in the Canadian
Environment (1980) NRCC No 17585
SPECIAL REPORTS
USEPA; Ambient Water Quality Criteria Doc: Chromium (1984) EPA
440/5-84-029
SPECIAL REPORTS
USEPA; Health Assessment Document: Chromium (1984) EPA 600/8-83-014F
SPECIAL REPORTS
USEPA; Ambient Water Quality Criteria Doc: Chromium (1980) EPA
440/5-80-035
SPECIAL REPORTS
CPSC; Chemical Hazard Assessment Profile: Chromium (1980)
SPECIAL REPORTS
USEPA; Air Quality Data for Metals 1968 and 1969 APDT
SPECIAL REPORTS
Schroeder HA; Air Quality Monograph '70-15: Chromium (1970)
SPECIAL REPORTS
USEPA; Drinking Water Criteria Document: Chromium (Draft) (1981) EPA
Contract No 68-02-3651
SPECIAL REPORTS
DHHS/ATSDR; Toxicological Profile for Chromium (6/89)
SPECIAL REPORTS
NORSETH T; THE CARCINOGENICITY OF CHRCIfiUM; ENVIRON HEALTH PERSPECT 40:
121 (1981). THE CARCINOGENICITY OF CHRafiUM COMPOUNDS IS REVIEWED WITH
SPECIFIC ATTENTION TO THE GAPS IN KNOWLEDGE FOR RISK ESTIMATION'
RESEARCH NEEDS.
SPECIAL REPORTS
NAS; Medical and Biological Effects of Environmental Pollutants:
Chromium (1974)
SPECIAL REPORTS
USEPA; Background Document, Resource Conservation and Recovery Act
Subtitle C: Identification and Listing of Hazardous Waste (1980)
SPECIAL REPORTS
-------
Toxicological Profile
Chromium
August 21, 1990
Page 41 of 41
Invertebrates: A Synoptic Review: Rpt' 85(1.6) (1986).
SPECIAL REPORTS
GOITRE M ET AL, CHRafiUM DERMATITIS & ORAL ADMIN OF METAL. CONTACT
DERMATITIS 8(3): 208 (1982).
SPECIAL REPORTS .
DAHL R, MIKKELSEN HB; BRONCHIAL ASTHMA AND CHROMIUM ALLERGY
PRECIPITATED BY STEEL WELDING. UGESKR LAEGER 144 (11): 801 (1982).
-------
ATTACHMENT C
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~ ~
1
BNVZROHHBNTAL PROTBC'l'ION. AGENCY
2
IlBGION I
3
4
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6
7 SUPERFUND PROGRAM
8
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SITE
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2)
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HR. COUGHLIN:
tonight.
I want to thank you all for coming
My name is Dan Coughlln. I'm the Chief of.'
the
New
Hampshire .' Superfund Section at E.P.A.
I
have
with
me
here tonight, Dick Goehlert, who is
the
Remedial
Project
Manager
for
the Kearsarge
Metallurgical
Corporation
Site.
On
my right is
Dick
Pease,
from
the New Hampshire Department of
Environmental Services.
(Asked to repeat what was said by people who couldn't hear)
HR. COUGHLIN:
Oh,
I'm sorry. My name is Dan Coughlin,
Chief
of
the
New
Hampshire Superfund Section at
E.P.A.
I
have with me tonight, Dick Goehlert, the
Remedial
Project
Manager
for
the
Kearsarge
Metallurgical
Corporation
Superfund
Site.
Paul
Lincoln
is
from
the
New Hampshire Department of
Environmental
Services
and,
on
my
right,
Dick
Pease,
from
the
Department
of
Environmental
Services.
Tonight's
meeting
is a public hearing
for
the
Kearsarge Metallurgical Corporation Site.
We're here to hear your comments on the proposed
plan and facilities plan that we put on to the
public on June 28th. Actually, when did we put
that out? Somewhere in the middle of June. The
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feasibility
study
the
RFS
and the proposed plan
was
sent
to
the
public.
We
conducted a public..
information
meeting
on
June
28th, where we went
over
the
proposed plan and the FS and conducted a
question
and
I\I1swer
session with those that were
at
that
particular
meeting.
A full copy of the
proposed
plan,
if
you
don't
have
one with you
tonight,
is
available
up
back, if you'd like to
get
it.
A
thirty-day
public
comment
period,
started
the
day
after
we
had
that
public
information
meeting,
which
was
June 29th, 1990.
Supplement
to that, upon receipt of a request from
an
interested
public,
the
comment
period
was
extended
by
thirty days, so we now have a revised
public
comment
period, which will run for a total
of sixty days. In other words, the comment period
runs from June 29th, 1990, to August 27th, 1990.
What we are going to do tonight, is provide you a
very
quick
description
of the proposed plan, the
alternatives
we
looked
at
and
the
preferred
alternative
the
agency
has selected, or at least
tentatively
selected
the
proposed
plan. Then we
will
accept
formal
comments
from
anybody
who
wishes
to
make
comments.
If you do wish to make
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comments,
there
are
some
index
cards
up back.
Please
put
your name on them.~nd we will call you
in
order
of when you have signed up. The purpose
of
tonight's
meeting,
as
I
say,
is
to accept
comments
that: will
be
transcribed
and
our
responses
will
be
part of the record of decision
which
we issue when we've made a final decision on
the
remedy.
Does
everybody have a proposed plan
or
does anybody else want to make comments? I have
two
cards,
at
this
point.
Okay,
once we have
completed
the
formal
comment
portion
of
the
program
tonight, we will close the hearing and, if
anybody
has
any questions that they would like to
bring
up,
then you can come up and talk to any of
us up front here and we'll be happy to talk to you
as long as you want to talk. I think that pretty
much covers what I want to do. Dick, why don't you
go ahead and do the review of the proposed plan?
MR. GOEHLERT:
For those of you who were here a month
ago,
you
will
remember...I
didn't
do this last
month.
There
we
go.
This is a basic map of the
site,
located
on Mill Street, just about a half a
mile
from
here. There are two buildings, building
one,
building two.
The site boundary right now is
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(
basically
this
dark
line.
There
are some waste
piles
here and here. There are. some barrels in the.
building
here,
here
and
there is a ground water
plume
that
measures
about 315 by 350 feet there.
And
that
is
a; basic description of the site and
the
hazards
or contamination as were found on the
site
to
date.
There
are
two
parts
of
the
preferred
alternative.
The
first
part that I am
gOing
to
describe,
is
known
as
source control
alternative
and
that is described here and taking
the solid waste piles that I've described and
separating them into two components, a non-
hazardous component and a hazardous component. The
non-hazardous
components will be placed in a solid
waste
land
fill. The hazardous component would be
sent
off to a hazardous waste landfill. There is a
septic
tank
and its contents...let me put the map
here.
The
septic tank is located right there and
there
is 80il surrounding the leaching field. This
will
be
excavated,
removed
from
the
site, for
incineration.
The
drum
waste, the drums, if they
are
hazardous,
they
will
be
sent
off
for
incineration.
If the drums are not hazardous, they
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will
be
disposed
of
as
solid
waste
also-
There
is
soil from the leachj;ng field, which will
be
excavated" and
that soil will be sent off to a
hazardous
waste
disposal
facility.
That is the
preferred
alternative.
.
Schematically,
this
basically
The
piles
shows you
are going
the drum
where
things
are
going.
one
of
two
places. The
soils
and
waste
are
going
to
another place. The
were studied, and the
SC 6. There was a
other
alternatives
which
preferred
alternative is
no
action
alternative, in
which no action would be taken, obviously. The
SC 3 is off-site solid waste landfill and you
would have on-site low temperature thermal
stripping
of
the leaching field soils. That would
be the only difference from SC - 3, to SC - 6. SC -
5,
you
would
have off site incineration of the
leaching field soils and off site solid waste
landfill. Sc 6, as I said, is the preferred
alternative. SC - 13 would be the off site method
of waste landfill of all the materials. The other
aspect of the preferred plan is what's called the
management of migration and this is for the ground
water
contamination.
The
preferred
plan
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is
the
on
site
treatment
of
the ground water,
that's
discharged
to the pUblicly owned treatment..
sources.
The
extraction of the ground water would
be
by wells and/or a collection trench.
Treatment
would
be
to re~ove volatile organic compounds and
the
metals.
There
would be some solids resulting
from
the
metals
being taken out of the water. If
those
were
deemed
to be hazardous, they would be
shipped
to
a
hazardous
waste disposal facility.
If,
after
testing,
they
were not deemed to be a
hazardous
material, they would go to a solid waste
plant.
The
treated
water would be discharged to
the
publicly owned treatment works.
The schematic
looks
somewhat like that. Ground water is going to
be
taken
out
of
the ground and it's gOing to be
extracted.
You
go through a treatment process of
for
the
volitiles,
which are the contaminants in
the
ground. I should mention that the ground water
contamination,
consists
mostly
of
1,1
Trichloroethane
or
commonly,
DCA.
The
other
management
of migration alternatives differ mainly
in
the aspect of where the discharge of the ground
water
would be, with the exception of first one is
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no
action.
The second one would be just a ground
water
monitoring
plan
with no
treatment.
That.
would be a "long-term option, over twenty-five
years! . The other alternatives which would
constitute an .action, HH 3 is an on site
treatment
with an on site discharge. That would be
a
discharge
4 is the
back
the ground.
to
HH-
same
treatment
to the
only
with
the
discharge
surface
water
of
Pequawket Pond.
HM-
5 is the
preferred
alternative.
HH-
6 would be a partial
discharge
to publicly owned treatment works, and a
partial
site recharge to the aquifer.
on
I would
like
just
to
summarize
one thing. The preferred
alternative
has
a
cost
of the source control of
3.26
million
and the management migration of 4.02
million
for
total
of
7.28. That cost, on the
a
management
migration
is a net present worth cost.
There
is
of
cost
a
operation
and maintenance,
which
is
brought back to the time frame of today,
to
get a total cost. That concludes my description
of
the
preferred
alternative, the preferred plan
and alternative.
MR. COUGHLIN:
Okay, thanks, Dick.
Anybody else want
LEGAL DEPOSITION SERVICE
.HEILA .ANTAS CASSAVAUGH
an CHUIICH IIOAD
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It
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to
make
comment tonight, other than the two cards
that
I
have? I would remind you that, if you wish..
to
make
written comment, you may do so. Certainly
"
would
you
do to so. Just make sure you
encourage
get
it
into us; and post marked before the 27th of
August.
And,
I
the
as
comments
we take
say,
tonight
and
the
written
that
comments
we get,
during
the
written
comment...during
the comment
period,
will
be
answered
in
a response to this
which
becomes
summary,
decision. Anybody else out there, Susan,
that....okay. All right, first comment, Joseph
of
part
the
record
of
Sullivan.
If
you'd come down and speak into this
microphone, we'd appreciate it.
HR. SULLIVAN:
I think I'm speaking for almost
everybody
here.
I' d like to qualify that. I hope
I
don't
We
know
what
am.
is the nature of the
threat to our health and the hazard. I'd like to
have you quantity it and qualify it. Two, you've
left out other alternatives in this. The threat
to
our
ground water. It could be cut quite a bit,
by
relocating
wells
in town, well away from
our
here,
capping
over the piece of land and possibly
paving
the
entire
lot.
With
the
rain
drains
LEGAL DE~OSITION SERVICE
.HEILA .ANTAS CASSAVAUGH
all CHURCH ROAD
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carried
off
of the sites, it doesn't get into the
ground.
If you needed to, you~ould drive pilings, .
3
around
the
entire
piece
of property, to quite a
4
depth.
For the amount of money that you're talking
5
6
about,
which
is
just about equivalent to what we
are
spending
to
build
a
new
school
and
two
7
additions
onto
other schools.
As a taxpayer, I'm
8
9
stunned.
If
this
is indicative of the E.P.A., I
think
everybody
ought to have a good look at this
10
and
examine it very carefully, because I think the
11
S and L's a$
with the s.P.A.
personally, have
a
crisis, is going to be parallel
12
unless we get a handle on it. I,
r
13
the
feeling it's a snow job and
14
15
I'd
like to see other al~ernatives to contain this
alleged
hazard
and
I'd also like to know what is
16
17
II
Trichloroethane.
I'd
like
to
know
what the
other
terms
of
it
is,
where it comes from, the
18
type
of a compound it is. How you break it on down
19
and
what are the other health hazards to it. Thank
~
20
21
you.
MR. COUGHLIN:
Excuse me, sir, could I ask you a
22
23
question?
I
missed
one
of your points, when you
talked
about
au - did
you
say a pilot around the
24
whole site?
I
- I
1.r
LEGAL DEPOSITION SERVICE
SHEILA SANTAS CASSAVAUGH
an CHURCH ROAD
PEM.ROKE. NEW HAMPSHIRE 03275
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MR. SULLIVAN:
I'd drive a steel piling around the
entire site, to contain it.
MR. COUGHLIN:
Oh, a piling.
MR. SULLIVAN :
And contain it.
MR. COUGHLIN:
Okay,:
I just didn't understand what you
said.
MR. SULLIVAN:
And
you cap it off with asphalt and put
a
hockey
the women around here want a
rink.
All
hockey
rink and an indoor swimming pool. You could
put
that
on
the
site
too,
for less money than
you're talking.
MR. COUGHLIN:
Okay, thank you, sir.
Mr. Curtis Lunt.
MR. LUNT:
Yes,
I'm Curt Lunt, the Town Manager in
Conway. I've been following this thing since 1982.
It's, for those of us who live nearby and drink
the water, it's kind of hard to argue with any
plan that would keep us from drinking the water,
50 you'd have to be an engineer to really
understand
the
plan.
Our engineers are reviewing
this
with
by
comment
the
Board
of
Selectmen,
which they will make in writing, at this point. I
guess I want to comment on behalf of the
selectmen. '!'hey talked to us briefly today. I
guess
what
as a result of the meetinQ a
happened
LEGAL DEPOSITION SERVICE
SHEILA SANTAS CASSAVAUGH
211 CHURCH IIOAD
"1I...ItOICI:. NEW HA"".HIIIII 03275
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2
couple
weeks
ago
and
the comments to the press,
was
that
there's something here besides the plan.
3
The
plan
maybe
was stalled by the so-called hunt
4
for
the
potential
responsible
parties.
I guess
5
6
it's
hard
not. to
be concerned by the indefinite
time
table
that's
attached.
I don't mean to the
7
construction
cost
or the construction time table,
8
9
that's
pretty
clear,
but
the,
when
will
this
construction
start?
Obviousl.Y
after the money is
10
raised.
Obviously some of the money will come from
11
the
hunt for the
potentially responsible parties.
12
That's
something we're not used to. It's something
r
13
that
concerns
us
because
one
of
the
parties
14
mentioned
in
the
local
press
was Carroll Reed,
15
who's
an
adjacent
property
to
this
lCearsarge
16
17
Metallurgical.
Now, as you probably know, Carroll
Reed
is
one
of
the
last
industries we have in
18
19
town.
They're
a
good employer. They, apparently
their
land
has
been
despoiled
by
some of this
20
21
material
on
the
ground.
It's
hard
for
us
to
imagine
the
financial
.cons equenc e s
to
Carroll
22
23
Reed,
in trying to sell the property, the company,
for
example,
if
you've
got
this
potentially
24
L
LEGAL DEPOSITION SERVICE
SHEILA 8ANTAS CASSAVAUGH
2n CHURCH ROAD
~E".1t01CE. NEW HAMPSHIRE 03275
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1
2
3
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5
6
7
8
9
10
J1
12
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15
16
17
18
19
20
21
22
23
~I"
(. ..
l~
responsible
party, hanging over your head, unknown
consequences.
We
can't
imagine
how
they could.
have
dumped
it
themselves
on
purpose. So we're
concerned
that
this
whole
plan
could
be
forestalled
or . turned into a hunt for the, you
know, people with money, potential money and it
should be, if it's going to be done, done as
qUickly as possible and we all know who dumped it.
MR. COUGHLIN:
Thank you. Is there anybody else that
would
like
to
make
formal
a
comment,
at this
point?
If
not, then we will close off the formal
part
of
the evening and the public hearing is now
closed.
As
I
said,
if anybody would like to ask
any
questions,
feel free to come on up front here
and
we'll
just
talk
to
you,
individually. The
meeting is, the hearing is now ended.
(Off the record)
LEGAL DEPOSITION SERVICE
SHEILA SANTAS CASSAVAUGH
211 CHURCH ROAD
PE".ItOICE. NEW HA"~HIRE 03275
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THE STATE OF NEW HAMPSHIRE
MERRIMACK, SSe
I, Sheila Santas-C~ssavaugh, a Notary Public, in the
State of New Hampshire, do hereby certify that I transcribed
from a tape recording, the foregoing twelve (12) pages and
that the same 18 a true, full and correct transcript of all
of the testimony of the witnesses, to the best of my
knowledge and belief.
I further certify that I am neither attorney nor
counsel for, nor related to or employed by any of the
parties to the action in which this hearing was taken, and
further that I am not a relative or employee. of any
attorney or counsel employed in this case, nor am I
financially interested in this action.
IN WITNESS 1fBEREOF,
26th d3Y of July, 1990.
I have hereunto set my hand this
~
Sheila Santas-Cassava
Notary Public
Justice of the Peace
Certified Audio Transcriber
LEGAL DEPOSITION SERVICE
SHEILA SANTAS CASSAVAUGH
ZII CHURCH ItOAD
~1:".ltOKI:. Haw HA"~"lltE 0327'
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APPBlfD:IX D
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Kearsarge Metallurgical Corporation
NPL Site Administrative Record
"
Index
Compiled: June 20, 1990
ROD Signed: September 28, 1990
. Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
-------
. Introduction
This document is the Index to the Administrative Record for the Kearsarge Metallurgical
National Priorities List (NPL) site. Section I of the Index cites site-specific documents and Section
II cites guidance documents used by EP A staff in selecting a response action at the site.
The Administrative Record is available for public review at EPA Region I, Boston,
Massachusetts, and at the Conway Public Library, Main Street, Conway, New Hampshire 03813.
Questions concerning the Administrative Record should be addressed to the EPA Region I site
manager.
The Administrative Record is required by th~ Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
-------
o
Section I
-------
1.0
3.0
3.4
3.5
ADMINISTRATIVE RECORD INDEX
for the
Kearsarge Metallurgical Corporation NPL Site
Pre-Remedial
1.2
Preliminary Assessment
1.
Memorandum from Donald Smith, EPA Region I to File (December 18, 1987).
Concerning the Preliminary Assessment
1.6
Hazard Ranking System (HRS)
1.
Hazard Ranking Package, EPA Region I (August 17, 1983).
Remedial Investigation (RI)
3.1
Correspondence
1.
Memorandum from Wayne Johnston, State of New Hampshire Bureau of
Environmental Health to Muriel Robinette, State of New Hampshire Water
Supply & Pollution Control Commission (September 9,1985). Concerning
gamma spectral analysis of waste casting sand
Memorandum from Diane E. Tefft, State of New Hampshire Division of Public
Health Services to Brook Dupee, State of New Hampshire Office of Risk
Assessment (March 7, 1989). Concerning the State of New Hampshire's
position on standards for radioactivity.
2.
3.2
Sampling and Analysis Data
The Sampling and Analysis Datafor the Remedial Investigation (RI) may be reviewed,
by appointment only, at State of New Hampshire Department of Environmental
Services, Concord, New Hampshire or EPA Region I, Boston, Massachusetts.
3.3
In addition, Sampling and Analysis Datafor the Remedial Investigation (RI) may be
found in summary form within the reports listed in 3.4 Interim Deliverables and
3.6 Remedial Investigation (RI) Reports.
Scopes of Work
"Draft - Revised Scope of Work For Phase n Site Characterization,"
Geotechnical Engineers Inc. for Kearsarge Metallurgical Corporation
(May 31, 1985).
Interim Deliverables
1.
"Draft - Phase I Site Characterization," Geotechnical Engineers Inc. for
Kearsarge Metallurgical Corporation (February 8, 1985).
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
1.
"Atomic Energy Commission - Agreement Between Atomic Energy Commission
and State of New Hampshire - Discontinuance of Certain Commission
Regulatory Authority and Responsibility Within the State," U.S. Atomic Energy
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3.6
()
2.
a
3.
4.
5.
6.
3.7
3.9
Page 2
Remedial Investigation (RI) Reports
'Draft - Remedial Investigation Repon - Volume 1 of 3," Geotechnical
Engineers Inc. for Kearsarge Metallurgical Corporation (December 5, 1986).
The record cited in entry number 2, consisting of oversized maps and drawings, may
be reviewed, by appointment only, at State of New Hampshire Department of
Environmental Services, Concord, New Hampshire. .
1.
'Draft - Remedial Investigation Repon - Volume 2 of 3," Geotechnical
Engineers Inc. for Kearsarge Metallurgical Corporation (December 5, 1986).
'Draft - Remedial Investigation Repon - Volume 3 of 3," Geotechnical
Engineers Inc. for Kearsarge Metallurgical Corporation (December 5, 1986).
"Remedial Investigation Repon:" Camp Dresser & McKee Inc. (June 1990).
"RIlFS Appendices A & B," Camp Dresser & McKee Inc. (June 1990).
"RIlFS Appendices C - G," Camp Dresser & McKee Inc. (June 1990).
Work Plans and Progress Repons
1.
"Project Operations Plan," Camp Dresser & McKee Inc. (April 1990).
Health Assessments
"Health Assessment," U.S. Department of Health and Human Services Agency
for Toxic Substances and Disease Registry (A TSDR) (July 28, 1989).
Feasibility Study (FS)
4.0
4.1
4.6
1.
Correspondence
1.
Memorandum from Richard Christian, Camp Dresser & McKee Inc. to Richard
Goehlen, EPA Region I (June I, 1990). Concerning the discharge of treated
groundwater from the site to the surface water of Pequawket Pond.
Feasibility Study (FS) Repons
Repons
1.
2.
"Feasibility StUdy Repon," Camp Dresser & McKee Inc. (June 1990).
Cross-Reference: "RIlFS Appendices A & B," Camp Dresser & McKee Inc.
(June 1990) [Filed and cited as entry number 5 in 3.6 Remedial Investigation
(RI) Reports].
Cross-Reference: "RIlFS Appendices C - H," Camp Dresser & McKee Inc.
(June 1990) [Filed and cited as entry number 6 in 3.6 Remedial Investigation
(RI) Reports].
3.
Comments
Comments on the Feasibility Study received by EP A Region J during the formal public
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4.9
Page 3
Proposed Plans for Selected Remedial Action
Repons
1.
"EPA Proposed Cleanup Plan for the Kearsarge Superfund Site," EPA Region I
(June 1990).
Comments
Comments on the Proposed Plan received by EP A Region I during the formal public
comment period are filed and cited in 5.3 Responsiveness Swnmaries.
Record of Decision (ROD)
5.0
5.1
5.3
5.4
10.0 Enforcement
G
Comspondence
1.
Memorandum from Don R. Clay, EPA Headquaners to EPA Regions I-X
Regional Administrators (January 29, 1990). Concerning the twenty-fIrst
remedy delegation repon authorizing EP A Region I to proceed with a 1990
Record of Decision for Kearsarge Metallurgical Corporation NPL site.
Responsiveness Summaries
Cross-Reference: Responsiveness Summary, EPA Region I
(September 28, 1990) [Filed and included as Appendix C in entry number 1 in
5.4 Record of Decision (ROD)].
Thefollowing citations indicate documents received by EPA Region I during the
formal public comment period.
1.
Cross-Reference: Transcript, EPA Region I and State of New Hampshire
Department of Environmental Services Proposed Plan Public Meeting for the
Kearsarge Metallurgical Corporation Site (July 24, 1990) [Filed and included as
an attachment to Appendix C in entry number 1 in 5.4 Record of Decision
(ROD)].
Comments Dated August 27,1990 from John A. Bewick, EnviroBusiness, Inc.
for Carroll Reed, Inc. on the June 1990 "EPA Proposed Cleanup Plan for the
Kearsarge Superfund Site," EPA Region I.
Record of Decision (ROD)
2.
3.
1.
Record of Decision, EPA Region I (September 28, 1990).
10.3 State and Local Enforcement Records
1.
Letter from Thomas L. Sweeney, State of New Hampshire Department of Health
and Welfare to E. Brooks Moore Jr., Kearsarge Metallurgical Corporation
(December 9, 1981). Concerning Letter of Deficiency under the New Hampsh ire
Hazardous Waste Management Act
Letter from Kenneth W. Marschner, State of New Hampshire Department of
Health and Welfare to Don Bennett, Indian Head Bank NOM
(February 2, 1982). Concerning the disposition of drums.
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Page 4
10.3 State and Local Enforcement Records (cont'd.)
G
u
3.
Letter from Thomas L. Sweeney, State of New Hampshire Department of Health
and Welfare to Don Bennett, Indian Head Bank North (March 18, 1982).
Concerning Notice of Violation and Order of Abatement under the New
Hampshire Hazardous Waste Management Act No. 82-3.
Notice of Violation and Order of Abatement under the. New Hampshire
Hazardous Waste Management Act, Kearsarge Metallurgical Corporation, James
F. Eldredge, and E. Brooks Moore Jr., Order #82-20, (October 4, 1982).
Petition for Permanent Injunction and Civil Penalty, State of New Hampshire v.
Kearsarge Metallurgical Corporation, James F. Eldredge, and E. Brooks Moore
Jr., State of New Hampshire Superior Court (April 13, 1983).
Letter from Thomas L. Sweeney, State of New Hampshire Department of Health
and Welfare to CaITOll Reed, Inc. (May 16, 1983). Concerning an order to
remove the waste pile located largely on propeny owned by Carroll Reed, Inc.
Letter from Thomas L. Sweeney, State of New Hampshire Department of Health
and Welfare to Kearsarge Metallurgical Corporation, James F. Eldredge, and
E. Brooks Moore Jr., (May 17, 1983). Concerning Notice of Violation and
Order of Abatement
Consent Order, State of New Hampshire v. Kearsarge Metallurgical Corporation,
et al., State of New Hampshire Superior Court, #83-E-031 (July 26, 1985).
4.
5.
£
V.
7.
8.
13.0 Community Relations
13.1 Correspondence
1.
Lener from Merrill S. Hohman, EPA Region I to John Cloutier, New Hampshire
People's Alliance (February 16, 1984) with attached statement from New
Hampshire People's Alliance. Concerning EPA interim response to issues raised
at the February 5, 1984 conference.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to Roben Bumstead, Town of Conway
(November I, 1985). Concerning site progress.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to Patty D'Andria, EPA Region I
(November 22, 1985). Concerning an update on community relations activities.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to Roben Bumstead, Town of Conway
(February 28, 1986). Concerning site progress.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to Roben Bumstead, Town of Conway
(March 31,1986). Concerning site progress.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to Roben Bumstead, Town of Conway
(May 5, 1986). Concerning site progress.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to Roben Bumstead, Town of Conway
(June 3, 1986). Concerning site progress.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to Roben Bumstead. Town of Conway
(August 5, 1986). Concerning site progress.
Letter from Michael A. Sills. State of New Hampshire Water Supply and
Pollution Conttol Commission to Roben Bumstead, Town of Conway
(August 29, 1986). Concerning site progress.
2.
3.
4.
5.
6.
7.
8.
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Page 5
13.1 Correspondence (cont'd.)
10. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Roben Bumstead, Town of Conway
(September 15, 1986). Concerning site progress.
11. Letter from Gary Abel to Muriel S. Robinette, State of New Hampshire Water
Supply and Pollution Control Commission (September 26, 1986). Concerning a
request for information.. .
12. Letter from Muriel S. Robinette, State of New Hampshire Water Supply and
Pollution Control Commission to Gary Abel (October 8, 1986). Concerning a
survey of environmental and health risks.
13. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Robert Bumstead, Town of Conway
(October 22, 1986). Concerning site progress.
14. Letter from Michael A. Sills, State of New Hampshire Department of
Environmental Services to Curtis H. Lunt, Town of Conway (April 15, 1987).
Concerning site progress and attached sampling and analysis data.
15. Letter from Paul C. Lincoln, State of New Hampshire Department of
Environmental Services to Curtis H. Lunt, Town of Conway (February I, 1990).
Concerning site progress.
,)
13.2 Community Relations Plans
"Community Relations Plan," State of New Hampshire Department of
Environmental Services (January 1990).
13.3 News Clippings/Press Releases
1.
1.
2.
Press Release, EP A Region I (August 1983). Concerning site status at the time
of its NPL listing.
Press Release, State of New Hampshire Department of Environmental Services
(August 13, 1985). Concerning a hydrogeological investigation public meeting to
be held August 26, 1985.
Press Release, State of New Hampshire Department of Environmental Services
(December 4, 1987). Concerning a Hydrogeological (Remedial) Investigation
public meeting to be held December 18, 1987.
"Environmental News," State of New Hampshire Department of Environmental
Services (December 7, 1987). Concerning a Hydrogeological (Remedial)
Investigation public meeting to be held December 18, 1987.
"EP A Environmental News - EP A Announces Public Meeting to Explain
Proposed Oeanup Plan for the Kearsarge Metallurgical Corporation Superfund
Site," EPA Region I (June 19, 1990). Concerning the announcement of a public
meeting on June 28,1990 and availability of the Proposed Plan, the Feasibility
Study, and other documentS.
''EPA Environmental News - EPA Announces Extension of Public Comment
Period on Cleanup Plan for the Kearsarge Metallurgical Corporation Superfund
Site," EPA Region I (July 19, 1990). Concerning the announcement of a public
hearing on July 24,1990.
3.
4.
s.
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.
Page 6
"
13.4 Public Meetings
1.
State of New Hampshire Meeting Agenda, Public Meeting for the Kearsarge
Metallurgical Corporation Site (August 26, 1985). Concerning the recently
released Hydrogeological Investigation (RIlFS).
State of New Hampshire Meeting Notes, Public Meeting for the Kearsarge
Metallurgical Corporation Site (August 29, 1985). Coricerning the
August 26, 1985 public meeting on the recently released Hydrogeological
Investigation (RIlFS). .
"Private Party Remedial Investigation Results and Superfund Program Studies,"
State Remedial Investigation Public Meeting Agenda and Handout for the
Kearsarge Metallurgical Corporation Site, State of New Hampshire
(December 18,1987).
"Minutes of Selectmen's MeerlDg," Town of Conway (May 8, 1989).
Meeting Notes, Camp Dresser & McKee Inc. (May 1989). Concerning the
May 8, 1989 Selectmen meeting at the Town of Conway Town Hall.
EP A Region I Meeting Agenda, Public Meeting for the Kearsarge Metallurgical
Corporation Site (June 28,1990) with attached meeting handouts. Concerning
the recently released Proposed Plan. .
EP A Region I Meeting Notes, Public Meeting for the Kearsarge Metallurgical
Corporation Site (June 28, 1990). Concerning the recently released Proposed
Plan.
Cross-Reference: Transcript, EP A Region I and State of New Hampshire
Depanmen\ of Environmental Services Proposed Plan Public Meeting for the
Kearsarge Metallurgical Corporation Site (July 24, 1990) [Filed and included as
an attachment to Appendix C in entty number 1 in 5.4 Record of Decision
(ROD)]. .
()
G
2.
3.
4.
5.
6.
7.
8.
14.0 Congressional Relations
14.1 Conespondence
1.
Letter from Michael A. Sills, State of New Hampshire Waste Management
Division to Nancy A. Allard, Member of the State of New Hampshire House of
Representatives (January 21, 1988). Concerning the status of the site.
Letter from Michael A. Sills, State of New Hampshire Waste Management
Division to Raymond S. Burton, Member of the State of New Hampshire
Executive Council (January 21,1988). Concerning the status of the site.
Letter from Michael A. Sills, State of New Hampshire Waste Management
Division to Howard C. Dickinson Jr., Member of the State of New Hampshire
House of Representatives (January 21, 1988). Concerning the status of the site.
Letter from Michael A. Sills, State of New Hampshire Waste Management
Division to Roger C. Heath, Member of the State of New Hampshire Senate
(J anuary 21, 1988). Concerning the status of the site.
Letter from Michael A. Sills, State of New Hampshire Waste Management
Division to William J. Hounsell, Member of the State of New Hampshire House
of Representatives (January 21, 1988). Concerning the status of the site.
Letter from Paul C. Lincoln, State of New Hampshire Depanment of
Environmental Services to Nancy A. Allard, Member of the State of New
Hampshire House of Representatives (February 9, 1990). Concerning the status
of the site.
2.
3.
4.
5.
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Page 7
16.0 Natural Resource Trustee
16.4 Trustee Notification Form and Selection Guide
1.
Letter from Menill S. Hohman, EPA Region I to Sharon Christopherson, U.S.
Department of Commerce National Oceanic and Atmospheric Administration
(NOAA) (July 2, 1987). Concerning attached "Trustee Notification Form" and
"Guide To Trustee Selection."
Letter from Menill S. Hohman, EPA Region I to William Patterson, U.S.
Department of the Interior (July 2, 1987). Concerning attached "Trustee
Notification Form" and "Guide To Trustee Selection."
2.
17.0 Site Management Records
17.2 Access Records
Letter from Kevin C. Devine, Devine, Millimet, Stahl & Branch (Attorney for
Kearsarge Metallurgical Corporation) to KeMeth W. Marschner, State of New
Hampshire Department of Health and Welfare (December 7, 1982). Concerning
access to the premises of Kearsarge Metallurgical Corporation for well digging
and monitoring.
Letter from Sherilyn Burnen Young, Orr and Reno (Attorney for Kearsarge
Metallurgical Corporation) to Roben Murphy and Tom Walsh, Carroll Reed,
Inc. (August 15,1985). Concerning access to a waste pile located largely on the
property owned by Carroll Reed, Inc.
Letter from Elizabeth A. Ryan, Devine, Millimet, Stahl & Branch (Attorney for
Kearsarge Metallurgical Corporation) to KeMeth W. Marschner, State of New
Hampshire Department of Health and Welfare (October 8, 1985). Concerning
access to the premises of Kearsarge Metallurgical Corporation for erection of a
fence.
Letter from John J. Regan, Hale and Dorr (Attorney for Carroll Reed, Inc.) to
Kenneth W. Marschner, State of New Hampshire Department of Health and
Welfare (October 10, 1985). Concerning access across Carroll Reed, Inc.
property for installation of a fence.
Letter from James E. Bradstreet, Carroll Industries, Inc. to Sherilyn Burnett
Young, Orr and Reno (Attorney for Kearsarge Metallurgical Corporation)
(October 21,1985). Concerning access to lot 50.
19.0 Resource Conservation and Recovery Act (RCRA) Records
1.
2.
3.
4.
5.
19.4 RCRA Facility Inspection Repons
"RCRA Inspection Checklist" Form, State of New Hampshire Department of
Environmental Services (September 29, 1981).
''Trip Summary" Form, State of New Hampshire Depanment of Environmental
Services (September 29, 1981).
19.6 Notifications of Ha7Mdous Waste Activity
1.
2.
1.
2.
"Notification of Ha7Mdous Waste Activity" Form, EPA Region I
(September 21, 1981).
"Notification Form", State of New Hampshire Bureau of Solid Waste
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Section II
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13.
14.
Page 8
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.
General EPA Guidance Documents
1.
"Protection of Wetlands (Executive Order 11990), Appendix D," Federal Re~ster
(Vol. 42), 1977. .
2.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Biodeeradation and Treatability of Specific Pollutants (EPN6ffJI9-79/034), October 1979.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Carbon AdsOJ:ption Isothenns for Toxic Orianics (EPN6ffJ/8-80!023), April 1, 1980.
3.
4.
U.S. Environmental Protection Agency. Office of Water and Waste Management
Evaluatini Cover Systems for Solid and H~7~Tdous Waste, 1980.
''Final and Proposed Amendments to the National Oil and Hazardous Substances Pollution
Contingency Plan," Code of Federal ReiUlations (Title 40, Part 300), 1983.
5.
6.
U.S. Environmental Protection Agency. Office of Ground-Water Protection.
Ground-Water Protection Strate~ (EPN440/6-84!OO2), August 1984.
U.S. Environmental Protection Agency. Office of Research and Development and Office of
Emergency and Remedial Response. Review of In-Place Treatment Techniques for
Contaminated Surface Soils - Volume 1: Technical Evaluation (EPN54012-84/003a),
September 1984.
7.
8.
"Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean
Water Act; Final Rule and Interim Final Rule and Proposed Rule," Federal Reeister
(Vol. 49, No. 209), October 26, 1984.
9.
U.S. Environmental Protection Agency. Hazardous Response Suppon Division. Standard
Qperatini Safety Guides, November 1984.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance Document for Cleanup of Surface Tank and Drum Sites (OSWER Directive
9380.0-3), May 28, 1985.
10.
11.
~~:;=~~:nn:~~~~~~~~~~~fhU~:a~~ ~ard~~~~
Waste Sites (EPN600/8-85/oo8), June 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investi~ations under CERCLA (Comprehensive Environmental
Response. Compensation. and Liability Act) (EPN540/G-85/oo2), June 1985.
12.
U.S. Environmental Protection Agency. Office of Solid 'Waste and Emergency Response.
Guidance on Feasibility Studies under CERCLA (Comprehensive Environmental Response.
Compensation. and Liability Act) (EPN540/G-85/003), June 1985.
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement.
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,~
16.
r,
,.,
~ I.
18.
20.
21.
22.
23.
24.
25.
26.
27.
Page 9
15.
Memorandum from Gene Lucero, U.S. Environmental Protection Agency Office of Waste
Programs Enforcement to Addressees ("Director, Waste Management Division, Regions I,
IV, V, vn, and VTII; Director, Emergency and Remedial Response Division, Region n;
Director, Hazardous Waste Management Division, Region llI; Director, Air and Waste
Management Division, Region VI; Director, Toxics and Waste Management Division,
Region IX; Director, Hazardous and Waste Division, Region X"), August 28, 1985
(discussing community relations activities at Superfund Enforcement sites).
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory and Office of Emergency and Remedial Response. Covers for Uncontrolled
Hazardous Waste Sites (EPA 54012-85/002), September 1985.
U.S. Department of Health and Human Services. National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration. Occupational Safe~ and
Health Guidance Manual for Hazardous Waste Site Activities, October 1985.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Handbook of Remedial Action at Waste Di~osal Sites (EPN625/6-85JU06), October 1985.
19.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Handbook: Remedial Action at Waste Di~osal Sites (Revised)
(EPN625/6-85/006), October 1985.
"National Oil and Hazardous Substances Pollption Contingency Plan," Code of Federal
Re~ulations (Title 40, Part 300), 1985.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Handbook for Stabilization/Solidification of Hazardous Waste
(EPN540/2-86/00I), June 1986.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Treatment Techno]o~ Briefs: Alternatives to Hazardous Waste Landfills
(EPN600/8-86/017), July 1986.
Memorandum from Henry L. Longest n, Rebecca Hanmer, Gene A. Lucero, EP A
Headquarters to Waste Management Division Directors, Regions I-X and Water
Management Division Directors, Regions I-X, April 15, 1986 (discussing discharge of
wastewater from CERCLA sites into publicly owned treatment works (POTWs).
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2), September 20, 1986.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Mobile Treatment TechnolQ~es for Superfund Wastes (EPA 54012-861003 (£),
September 1986.
U.S. Environmental Protection Agency. Conwrehensive Environmental Response.
Compensation. and Liabi1i~ Act of 1980, as amended October 17. 1986. .
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (EPN540/1-86,{)60, OSWER Directive
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35.
36.
37.
38.
Page 10
28.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2), October 1986. .
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on SQperfund Selection of Remedy (OSWER Directive 9355.0-19),
December 24,1986. .
29.
30.
U.S. Environmental Protection Agency. . Office of Emergency and Remedial Response.
SQperfund State-Lead Remedial ~ect Manaeement Handbook, (EPA/540/G-871OO2),
December 1986.
31.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Technolo~ Briefs: Data ReqUirements for Selectini Remedial Action
Technolo~ (EPA/60012-87/001), January 1987.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Data Quality Obiectives for Remedial Re~nse Activities: Develo,pment Process
(EPA/540/G-87/003, OSWER Directive 9355.0-7B), March 1987.
32.
33.
Letter from Lee M. Thomas, U.S. Environmental Protection Agency to James J. Florio,
Chairman, Subcommittee on Consumer Protection and Competitiveness, Committee on
Energy and Commerce, U.S. House of Representatives, May 21, 1987 (discussing EPA's
implementation of the Superfund Amendments and Reauthorization Act of 1986).
Memorandum from J. Winston Poner, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Addressees ("Regional Administrators, Regions
I-X; Regional Counsel, Regions I-X; Director, Waste Management Division, Regions I, N,
V, VII, and VIII; Director, Emergency and Remedial Response Division, Region II;
Director, Hazardous Waste Management Division, Regions m 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") (OSWER Directive
9234.0-05), July 9, 1987 (discussing interim guidance on compliance with applicable or
relevant and appropriate requirements).
34.
Memorandum from David P. Ryan, EPA Headquarters to Addressees (Assistant Regional
Administrators; Management Division Directors; Senior Budget Officers; Regional
Comptrollers; Waste Management Division Directors; ESD Directors of Regions I, VI, and
VII; Director, Office of Emergency and Remedial Response; Director, Office of Waste
Programs Enforcement; Financial Management Officers), July 15, 1987 (Discussing
detennination of indirect costs in Superfund Removal project ceilings (Comptrollers Policy
Announcement No. 87-15».
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Additional Interim Guidance for Fiscal Year 1987 Record of Decisions, July 24, 1987.
Memorandum from Francis S. Blake, General Counsel, to J. Winston Porter, Assistant
Administrator for Solid Waste and Emergency Response, July 31, 1987 (discussing the
scope of the CERCLA pettoleum exclusion under sections 101 (14) and 104 (a) (2».
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Alternate Concentration Limits Guidance (OSWER Directive 9481.00-6C,
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39.
\
"
40.
('
41.
()
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
Page 11
U.S. Environmental Protection Agency. Center for Environmental Research Information.
A Compendium ofTechnolo~es Used in the Treatment of Hazardous Waste'
(EPN625/8-871014), September 1987.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Draft Guidance on CERn.A Conwliance with Other Laws Manual (OSWER Directive
9234.1-01), November 25,1987. .
U.S. Environmental Protection Agency~ Office of Emergency and Remedial Response.
A Compendium of Superfund Field Qperations Methods (OSWER Directive 9355.0-14),
December 1987.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Removal Procedures - Revision Number Three (OSWER Directive
9360.0-03B), February 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Conductin~ Remedial Investi~ations and FeasibilitY Studies under
CERCLA (Comprehensive Environmental Response. Compensation. and Liability Act),
March 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated GroundWater at Superfund Sites
(OSWER Directive 9283.1-2), Apri11988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
CommunitY Rdations in Superfund: A Handbook (Interim Version) (EPN540/G-881OO2,
OSWER Directive 9230.0-3A), June 1988.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Draft Guidance on CERCLA Compliance with Other Laws Manual (OSWER Directive
9234.1-01), August 8, 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Removal Prowam Policy Notebook - Volume 1, October 12, 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Removal Prowam Policy Notebook - Volume 2, October 12, 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on Conductin~ Remedial Investi~ations and FeasibilitY Studies
under CERCLA (Conwrehensive Environmental Re$pOnse. Compensation. and Liabili(y
AW, October 1988.
Memorandum from Michael Callahan, U.S. Environmental Protection Agency Office of
Health and Environmental Assessment to Henry L. Longest, U.S. Environmental Protection
Agency Office of Emergency and Remedial Response, December 6, 1988 (discussing
update of PCB cleanup-levels).
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2), December 1988.
Memorandum from Henry L. Longest II, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors, Waste Management Division, Regions I.
IV, V, VII, VIII et al. (OSWER Directive 9347.2-01), June 5, 1989 (discussing land
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56.
57.
58.
59.
Page 12
53.
Memorandum from Henry L. Longest II and Gerald Emison, EPA Headquarters to
Addresses, (OSWER Directive 9355.0-28), June 15, 1989 (discussing control of air"
emissions from Superfund air strippers at Superfund Groundwater sites).
U.S. Environmental Protection Agency. Risk Assessment Work Group, Region I.
SUPJ)lemental Risk Assessment Guidance for the Superfund Pmwam (Draft EinaU
(EPAJ901/5-89/001), June 1989. . .
54.
55.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Risk Assessment Guidance for Superfund. Human Health Evaluation Manual Part A,
July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA (CoI1lPrehensive Environmental Re!ij)Onse. Compensation. and LWWi~ Act)
CoI1lPliance with Other Laws Manual - Part II: Clean Air Act and Other Environmental
Statutes and State RCQuirements (EPA/540/G-89/009, OSWER Directive 9234.1-02),
August 1989.
Memorandum from Jonathan Z. Cannon, EPA Headquarters to Waste Management Division
Directors, Regions I, IV, V, VI, VII, VIII; Emergency and Remedial response Division
Director, Region II; Hazardous Waste Management Division Directors, Regions III, IX;
Hazardous Waste Division Director, Region X, (OSWER Directive 9355.4-03),
October 18, 1989 (discussing considerations in groundwater remediation at Superfund
sites).
"National Oil and Hazardous Substances Pollution Contingency Plan," Federal Re~ster
(Vol. 55, No. 46), March 8, 1990.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
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C>
'"
APPENDIX B
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HOBERT W. VARNEY
CONML.~O~K
TTYfTDlJ 14IUO"W~..3312
!lOBERT I5UltR(M
VIlt\itN~ "'WIN
WlUJAM lE."~~
10llN 1..fM1.1,£f,
JUHN LU:IIAW
ratnllRfCK M\,.\iAKJ(Y
IOIIN USlinU!!
WillA"""!! SANDHII
T. TAVlJlR r"CIiMY. ''''.11.
S~tc of New Humpl:lhire
DEPARTMENT OF E1\TVIRONMENTAL eERVICES
WASTE MANAGEMENT DIVISION
6 Hazen Dr.'t~1 Concord. NH 033C:l-6509
603.271.2900
I'HlUP J. O'BRIEN. PI1.1J.
DIII~,,:roK
MICHAEL A. SILLS. Ph.D., r.E.
CHI!" I!NGlNEBR
September 25, 1990
Ms. Julie Belaga
Regiona' Administrator
USEPA, Region I
JFK Federal Bldg.
Boston, MA 02203
Re:
Record of Decision
KeGrsarge Metallurgical Corporation Site
Conway. NH
Dear Ms. Belaga:
The New Hampshire Depar't~nt of Environnental Services has reviewed the
above referenced Rec~rd of Decision (ROD) and concur's with the recommendations
ther'eln and that the recommeMed alternative is consistent with the rules and
regulations of AppHcabl e or' Rel evant and Appropr1 ate State Requi rements
(ARARs). Furthermore, if the project utilizes the trust fund, the state will
provide a 10 percent match and operational support for the project if sta.te
funds are available.
51 ncerp.ly ,
r;;?t'~ 0((
Phil ip J. O' 8,.1 P.~h. D
D1 rector
Rn~~a~e~.J~
Conm1ss1oner
RWV/jd/WPP?96
cc: Michael A. 5111s, Ph.D, P.E., NHDES-WMD
Carl W. Baxter, P.E., NHDES-WMEB
Richard H. Pease, p.r., NHDES-WMEB
Paul C. L1nco'n, P.E., NHDES-WMEB
Char1es Holtman. Esq., NHAGO
Daryl luce, USEPA, Region I
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