United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01 -91/053
December 1990
EPA Superfund
Record of Decision
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50272.101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/ROl-91/053
1 ~
3. Reclplent'8 Acceaaion No.
4. TI1Ie and Subtitle
SUPERFUND RECORD OF DECISION
Union Chemical, ME
First Remedial Action - Final
7. Author(a)
5. Report Date
12/27/90
6.
8. Perfonnlng Organlzlltlon Repl No.
II. 1Wf0nning Orgalnlzlltlon ...... 8nd Add....
10. ProjedlTa8lllWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. SponeorIng OrgarV8tlon Nama 8nd Addreaa
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
Agency
800/000
14.
15. Supplementary No"'a
16. Abatrac1 (Umlt: 200 _rda)
The 12.5-acre Union Chemical (UCC) site is an inactive paint stripping solvent
manufacturing and recycling facility in Hope, Knox County, Maine. Land use in the
area is residential, and a pond is located approximately 300 feet northeast of the
site. The site is bounded on the east and southeast by Quiggle Brook, which flows
southward for 5 miles before discharging into Crawford Pond, a drinking water source.
A floodplain and a wetland area exist along Quiggle Brook at the eastern end of the
site, and another wetland has been identified to the south. Site operations, which
began in 1967, included formulating patented solvents for paint stripping and
coating. These products were manufactured and utilized on the premises in several
onsite buildings. Later operations also included recycling of used stripping
compounds and solvents from other businesses on a small scale until 1982, when a
fluid-bed incinerator was acquired. In 1979, State investigations identified the
presence of onsite ground water contamination. Subsequent private studies in 1981
confirmed the presence of two contaminated ground water plumes in the area between
the facilities and Quiggle Brook, and that the northern plume had resulted from
migration of chemical constituents from the onsite Old Leach Field. The southern
(See Attached Page)
17. Document Analyala .. Deacrlptora
Record of Decision - Union Chemical, ME
First Remedial Action - Final
Contaminated Media: soil, gw, debris
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes), other organics
(arsenic, lead), other inorganics (asbestos)
(dioxin), metals
b. Identifler8lOpen-Ended Tenna
c. COSA T1 AeIdiGroup
<8. AvlllabiHty Statament
111. Security Cl88a (TIlla Report)
None
20. Security Cl88a (TIlia Page)
Nonp-
21. No. of Pagea
291
I
~ Price
(See ANSl-l39.18)
See In"truction" on Reverse
272 (4-77)
(Formerly NTlS-35)
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EPA/ROD/ROl-91/053
Union Chemical, ME
First Remedial Action - Final
_~stract (Continued)
plume is believed to be contaminated as a result of a leaking storage tank in a former
drum disposal area south of the plant buildings. The State issued several violations
to the owner between 1979 and 1984, and eventually closed the plant in late 1984. At
that time approximately 2,000 to 2,500 55-gallon drums and 30 liquid storage tanks were
identified onsite. In 1984, the State removed all the material from within the
55-gallon drums and all but two of the liquid storage tanks. This Record of Decision
(ROD) addresses remediation of contaminated onsite soil, debris, sludge, ground water,
and facilities, and provides for further evaluation of contaminated offsite soil. . The
primary contaminants of concern affecting the soil, groundwater, and debris are VOCs
including PCE, TCE, toluene, and xylenes: other organics including dioxin; metals
including arsenic and lead; and other inorganics including asbestos.
The selected remedial action for this site includes decontaminating all onsite
facilities including the still building, production facilities, welding shop,
incinerator complex, concrete pads, the church, all associated equipment, tanks,
above-ground drums, and buried pipes using high pressure steam cleaning or another
decontamination technique; collecting and testing all wastewater resulting from
decontamination operations, draining all contaminated water from sumps, and treating
onsite, if necessary, using UV light/oxidation or another treatment technology;
crushing and treating all concrete from the warehouse pad, structures, floor, and sumps
by low temperature thermal aeration or an equivalent desorption technique; backfilling
the treated concrete onsite, if it meets LDR standards, or removing it offsite for
disposal at a RCRA facility; removing and containing asbestos from the still building,
'ollowed by offsite disposal; treating any other RCRA hazardous wastes onsite including
.ioxin/lead scrubber ash, liquids, and sludge from the onsite equipment prior to
offsite disposal by sOlidification/stabilization; demolishing the onsite facilities and
associated components; sampling the debris and removing it offsite to either a RCRA
facility or permitted landfill depending on testing results: excavating 10,500 cubic
yards of soil from the unsaturated and saturated zones; treating the contaminated
saturated soil from the Old Leach Field area onsite using low temperature soil aeration
or equivalent (thermal desorption); conducting treatability studies prior to full-scale
treatment of contaminated soil; excavating and treating saturated soil and soil gases
outside the above areas that exceed clean-up levels using vacuum extraction;
controlling air emissions of organics using vapor phase carbon adsorption; incinerating
or thermally regenerating the residual carbon offsite: treating fumes and other
particulate matter collected by the thermal aeration; treating soil which does not
achieve site-specific clean-up levels using another approved technology, or obtaining a
RCRA Treatability Variance; redepositing the treated material onsite with the other
treated soil; filling excavated areas with clean fill: mixing nutrients with soil prior
to redepositing, and grading and revegetating the area; constructing additional vacuum
enhanced extraction and monitoring wells; pumping and treating ground water onsite
using UV light/oxidation or an equivalent destruction technology, followed by liquid
phase carbon adsorption or an equivalent treatment technology prior to onsite discharge
to Quiggle Brook; pretreating ground water, if necessary, to remove inorganics or
solids; monitoring air and ground water; sampling offsite soil, and collecting
meteorological site information to define whether offsite soil contamination was the
result of UCC operations; and implementing institutional controls including deed and
ground water use restrictions, and site access restrictions such as fencing. The
oresent worth cost for this remedial action ranges from $9,724,000 to $10,654,000,
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EPA/ROD/ROl-91/053
Union Chemical, ME
First Remedial Action - Final
Abstract (Continued)
PERFORMANCE STANDARDS OR GOALS: Soil clean-up levels are based on an excess lifetime
cancer risk level of less than 10-6 and an HI
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/
DBCLARATION POR '1'HB
RECORD OF DBCISION
SITB DMB UD LOCATIOIt
o
union Chemical Company, Inc.
South Hope, Maine
STATBKBNT OF PURPOSB
This decision document presents the selected remedial action for
the Union Chemical Company, Inc. site (the "Site"), located in
South Hope, Maine. This document was developed in accordance
with the comprehensive Environmental Response, compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the
extent practiCable, the National contingency Plan (NCP): 40CFR
Part 300 et sea. (1990). The Regional Administrator for Region I
of the United states Environmental Protection Agency (EPA) has
been delegated the authority to approve this Record of Decision.
The state of Maine has concurred on the selected remedy and
determined, through a detailed evaluation, that the selected
remedy is consistent with Maine laws and regulations.
STATEXENT OF BASIS
'This decision is based on the Administrative Record compiled for
the site which was developed in accordance with section 113(k) of
CERCLA. The Administrative Record is available for public review
at the Hope Town Hall in Hope, Maine, and at the EPA Region I
Waste Management Division Records Center in Boston, Massachusetts.
The Administrative Record index (attached as Appendix C to the
ROD) identifies each of the items which comprise the
Administrative Record upon which the selection of the remedial
action is based.
ASSBSSMENT OF '1'HB SITB
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, welfare, or the environment.
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DESCRIPTION OP THE 8ELlCTED aBMEDY
The selected remedial action for the Union Chemical Company, Inc.
site is a comprehensive, mUlti-component approach for overall
remediation of the contaminated on-site soils, groundwater, and
facilities, and a further evaluation of off-site soils
surrounding the Site. The selected remedy addresses the
significant threats to human health and the environment posed by
the Site. Furthermore, the principal threat to human health and
the environment posed by the Site -- the highly contaminated
groundwater found on the Site -- is addressed through treatment,
to the maximum extent practicable, of the source of this.
contamination and of the contaminated groundwater itself.
The remedy selected in the ROD incorporates the following
components:
"
.
Soil Excavation and On-Site Low-Temperature Soil Aeration
Treatlnent;
.
Vacuum-Enhanced Groundwater Extraction, On-Site Groundwater
Treatment, and On-site Discharge of Treated Groundwater into
Quiggle Brook;
Facilities Decontamination and Demolition, and Off-Site
Disposal of Debris; and
.
.
Limited Action for Off-Site Soils;
These four components are summarized below:
Soil Excavation and On-Site Low-TemDerature Soil Aeration
Treatment
Once the existing facilities have been removed from the Site,
contaminated soils within the unsaturated zone exceeding soil
cleanup levels will be excavated. Contaminated soils will also
be excavated from the saturated zone between the old leach field
and interceptor trench which exceed soil clean-up levels. After
a screening process has been performed to remove cobbles and/or
boulders (which will be crushed prior to treatment), excavated
soils will be treated on-site using a low-temperature soil
aeration or equivalent thermal desorption treatment process.
Potential airborne releases of volatile organic and particulate
emissions during excavation and treatment will be minimized by
the use of several air pollution control techniques. The organic
contaminants that are volatilized from the contaminated soils as
vapors from the treatment process will be further collected (for
eventual treatment off-site) using vapor-phase carbon adsorption
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. - . -' -
o
materials or an equivalent method. Fugitive dust from the
treatment process will be collected by air pollution control
equipment. Frequent and representative sampling of soil from
excavated areas and treated soil, as well as continuous air
monitoring, will take place during the entire
excavation/treatment process. Treated soils will be backfilled
on the site, and the site will be regraded and revegetated.
Prior to full-scale treatment of the contaminated soils, pilot-
scale tests will be conducted using site-specific soils. The
primary objectives of these tests will be to confirm that the
site-specific soil cleanup levels and treatment standards will be
met and to provide additional design data for the soil treatment
system including the air pollution controls required.
v~cuu:-~~a~~d ~r~~~~w~ier ~~;act~~~i On-site GrO~dwater
Teat e t d 0 - 1 sch r of ated Groundwater into
ouiaale Brook
On-site contaminated groundwater will be extracted and treated
using ultraviolet (UV)/oxidation or an equivalent destruction
technology. The need for pre- or post-treatment of the
groundwater will be further evaluated during design-phase
treatability studies, and will be implemented as required. The
treated groundwater will be discharged to Quiggle Brook via a
pipe. The vacuum-extracted contaminated soil gasses will be
collected (for eventual treatment off-site) using a vapor phase
carbon adsorption process or equivalent treatment technology
prior to discharge to the atmosphere. Institutional controls
will be required both on- and off-site during the remedial action
to reduce the potential for exposures by humans to the
contaminants on the site, and the potential further migration of
contaminants off the site.
pilot-scale treatability studies, additional aquifer tests, and
a fate and transport model will be conducted to provide
additional design data for the groundwater treatment system.
Several vacuum-enhanced extraction wells will be installed on the
site to extract contaminated groundwater from the till and
weathered bedrock. The extraction well configuration will be
refined, as necessary, during the course of the remedial action.
Facilities Decontam1nAtJon and Demolition. and Off-Site Disposal
of Debris
Facilities currently on the site will be decontaminated by high-
pressure steam cleaning or another effective decontamination
technique. Water remaining in sumps on the site and from
decontamination activities will be collected and treated in the
groundwater treatment system, if technically practicable.
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'.J - -
Concrete structures will be crushed and treated in the on-site
soil treatment facility. The asbestos in the still building will
be appropriately containerized and removed for off-site disposal.
Any other RCRA hazardous waste associated with the existing
facilities (including the dioxin-containing ash in the secondary
scrubber equipment of the incinerator) will be treated by best
available and appropriate techniques prior to off-site disposal.
Following decontamination procedures, existing facilities will be
demolished, sampled, and the debris disposed of off-site in an
appropriate facility. Various techniques will be used to mitigate
the release of airborne emissions during all decontamination and
demolition activities.
Limited Action for Off-Site Soils
Further monitoring and analysis of off-site soils will be
conducted to define whether or not off-site soil contamination is
present as a result of past Union Chemical Company, Inc.
operations and, if so, whether this contamination warrants
further remedial action. Following one year of continuous, site-
specific collection of meteorological data, additional air
modeling simulations will be performed to determine the potential
off-site locations where airborne materials from the Site may
have been deposited. Subsequent to a review of this data from
air modeling simulations (or sooner, if required), as well as a
review of existing data, soil samples will be collected and
analyzed from selected locations. After five years of
meteorological data collection from the Site, additional air
modeling simulations will be performed and the need for
additional soil sampling evaluated. Throughout all phases of
this data collection and analysis effort, EPA will determine if
additional remedial actions are required for off-site soils.
PIVB-YEAR OVID
As required by law, EPA will review the site at least once every
five years after the initiation of remedial action if any
hazardous substances, pollutants or contaminants remain at the
Site to assure that the remedial action continues to protect
human health and the environment. EPA will also evaluate the
risks posed by the site at the completion of the remedial action
(i.e., before the Site is proposed for deletion from the NPL).
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DECLaRATION
- -'-
The selected remedy for the Union Chemical Co., Inc. site is
protective of human health and the environment, attains all
Federal and state requirements that are applicable or relevant
and appropriate (ARAR) to this remedial action, and is cost-
effective. This remedy utilizes permanent solutions to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment ~at reduces
toxicity, mobility, or volume as a principal element.
J)~ .~71
.
Date
/1fo
5
Julie Belaga
Regional Administra
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t
"
u.s. BNVIROHKBNTAL PROTECTIOB AGENCY
REGION I
RECORD OF DECISION
UNION CHEMICAL CO., rRC. SUPERFUND SITE
SOUTH HOPE, KAINE
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contents
I.
II.
III.
IV.
VI.
VII.
VIII.
UNION CHEMICAL co., INC. SUPERPUND SITE
UCORD OF DECISION
TABLE OF CONTENTS
~
Number
SITE NAME, LOCATION AND DESCRIPTION.
. . . . . . . . .
1
SITE HISTORY' BNFORCEMENT ACTIVITIES
. . . . . . . . .
2
A.
B.
Land Use' Response History. . .
Enforcement History. . . . . . .
. . . . .
2
4
. . . .
. . . .
. . . . .
COKMUNITY PARTICIPATION. . .
. . . . .
. . .
. . . . .
6
SCOPE' ROLE OF OPERABLE UNIT OR RESPONSE ACTION
. . .
8
V.
SUMMARY OF SITE CHARACTERISTICS.
. . . . . . . .
. . .
9
A.
B.
C.
D.
Soil (on-site and off-site) . . . . . . . . . . ., 9
Groundwater. . . . . . . . . . . . . . . . . . . . 11
Surface waters and Sediments. . . . . . . . . . . 12
Facilities. . . . . . . . . . . . . . . . . . . . 14
SUKMARY OF SITE RISKS. . . . . .
. . . .
. . . . 15
. . .
A.
B.
C.
Public Health Risk Assessment. . . . . . . . . . . 15
Environmental Assessment. . . . . . . . . . . . . 19
Conclusions. . . . . . . . . . . . . . . . . . . . 19
DEVELOPMENT AND SCREENING OF ALTERNATIVES
. . . 20
. . . .
A.
B.
statutory Requirements/Response Objectives. . . . 20
'1'echnoloqy and Alternative Development
and screening. . . . . . . . . . . . . . . . . . . 21
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . .
. . 24
A.
B.
Source control (SC) Alternatives Analyzed. . . . . 24
Management of Migration (KM)
Alternatives Analyzed. . . . . . . . . . . . . . . 28
Facilities (F) Management
Alternatives Analyzed. . . . . . . . . . . . . . . 31
Off-site (OS) soils Alternatives Analyzed. . . . . 33
C.
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Contents
IX.
XI.
XII.
XIII.
X.
UNION CHEMICAL CO., INC. SUPERFUND SITE
RECORD 01' DBCISION
TABLB 01' CONTENTS Ccontinue~)
"
~
Number
StJMKARy 01' DE COMPARATIVE ANALYSIS 01' ALTERNATIVES. . 35
A.
B.
C.
D.
Source Control (SC) Alternatives. . . . . . . . . 37
Management of Migration (MM) Alternatives. . . . . 41
Pacilities (I') Management Alternatives. . . . . . 45
Off-Site Soils (OS) Alternatives. . . . . . . . . 48
THE SELECTED REMEDY.
. . .
. . 51
. . . .
. . . . . . . .
A. Cleanup Levels
. . . . . . .
. . 51
. . . . .
. . . .
B.
Description of Remedial Components
. . . . . .
. . 58
STATUTORY DETERMINATIONS
. . . . .
. . . . 72
. . . . . .
A.
The Selecte~ Reme~y is Protective of Human
Health an~ the Environment. . . . . . . . . . . . 72
The Selecte~ Reme~y Attains ABARs . . . . . . . . . 74
The Selecte~ Reme~ial Action is Cost Effective. . 83
The Selecte~ Reme~y Utilizes Permanent Solutions
an~ Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable. . 85
The Selecte~ Reme~y Satisfies the Preference
for Treatment Which Permanently an~ significantly
Re~uces the Toxicity, Mobility or Volume of the
Hazar~ous Substances as a principal Element. . . . 87
B.
C.
D.
E.
DOCUMENTATION OF SIGNIFICANT CHANGES
. . . . . . .
. . 88
STATB ROLE
. . . . . . . . . . . . . .
. . 90
. . . . . .
APPENDIX A -- RESPONSIVENESS SUMMARY
APPENDIX B -- STATE 01' MAINE CONCURRENCE LETTER
APPENDIX C -- ADMINISTRATIVE RECORD INDEX
TABLES
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UNION CHEMICAL COMPANY, %NC. RECORD OF DECISION SUMMARY
SOUTH HOPE, MAINE December 27, 1990
*..........**.********.*****.***.****.****.*.*.***....................
I.
BITB RAME, LOCATION AND DBSCRIPTION
The Union Chemical Company, Inc. site (the Rsitetl) is located within
the Town of Hope, Maine (see attached Figure 1), which is .
approximately seven miles west of Rockland and Camden, Maine. The
Union Chemical Company, Inc. (RUCC") site occupies approximately 12.5
acres along the south side of Route 17, in the village of South Hope,
Knox county, Maine (see attached Figure 2). A majority of UCC's past
site activities took place within a 2.25-acre fenced area. This
fenced-in area currently encloses most of the plant's former waste
handling facilities, including the still Building, the former
Warehouse concrete pad, the old Leach Field, and the incinerator and
associated equipment (see attached Figure 3). Apart from the 2.25-
acre fenced in area, the UCC site is readily accessible.
The site is adjacent to numerous residential dwellings, some of which
are within 150 feet of the site along the north side of Route 17 and
400 feet west of the site along the south side of Route 17. The site
is bounded on the east and southeast by Quiggle Brook, which is a
southerly flowing outlet stream of Fish pond. Quiggle Brook flows
southward for approximately 5 miles before discharging into Crawford
Pond, a drinking water source. Fish Pond is located approximatelY 300
feet northeast of the site, along the north side of Route 17. A
floodplain and wetland area exist along Quiggle Brook at the eastern
edge of the Site, and intermittent wet areas in the northwest corner
and immediately south of the fenced-in portion of the site have been
identified as wetlands.
A more complete description of the site can be found in Section 2.0,
at pages 8 through 14, of the Final Draft Remedial Investigation (RI)
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UNION CHEMICAL COMPANY, ZNC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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II.
SITE HISTORY AND BNFORCEMENT ACTrvITIES
A.
Land Ua. and Response History
The Union Chemical Company was incorporated as a paint stripping
and solvent manufacturing business, and began operations in South
Hope, Maine in 1967. Prior to commencing these operations, the
property along Route 17 was wooded, rural land that was the site
of a small meeting house or church, which was surrounded by the
many residential dwellings which are in existence today.
Initially, plant operations consisted of formulating patented
solvents for stripping paint and coatings from furniture and
other items. These chemical products were originally
manufactured and utilized on the premises for stripping
furniture, and later for distribution throughout the United
States and Canada.
The company eventually expanded operations to include recycling
of used stripping compounds and solvents from other businesses.
Recycling initially occurred using a small solvent recovery or
distillation unit, but was later expanded to include the use of
the on-site boiler for the treatment of these compounds. In
1982, operations were further expanded to include a full-scale,
fluidized-bed incinerator which acquired interim status under
the Resource Conservation and Recovery Act (RCRA) to treat
hazardous wastes.
Groundwater contamination on the Site and contamination of
Quiggle Brook was first discovered by the State of Maine,
Department of Environmental Protection (MDEP) in late 1979. .The
Union Chemical Company contracted with Wright Pierce
Architects/Engineers (Wright-Pierce), on June 4, 1981, to conduct
the first organized, technically-oriented evaluation of the
hydrogeology of the Site. The primary objective of this study
was to gather chemical and hydrogeologic data to support the
development of a cleanup plan for the contaminated soils and
groundwater discovered along the east side of the Site. The
analysis of samples and subsequent evaluation of data collected
by Wright-Pierce indicated that two contaminated groundwater
plumes were present in the area between the facilities and
Quiggle Brook. The Wright-Pierce data further indicated that the
more northerly groundwater plume resulted from the migration of
chemical constituents from an Old Leach Field on the Site (see
attached Figure 3), while the source of the more southerly plu~e
was believed to be a former drum storage area south of the plan~
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UNION CHEMICAL COMPANY, INC. RECORD 01' DECISION SUMMARY
SOUTH BOPE, KAINE December 27, 1990
**.*****************************************************************..
buildings, where a storage tank had reportedly leaked.
In November 1981, Wright-Pierce was again commissioned by the
Union Chemical Company to install piezometers (monitoring wells)
to observe the groundwater contamination and flow beneath the
site. Two groundwater flow patterns, or aquifer systems, were
identified using groundwater elevation measurements from the
numerous piezometers installed on the site. One of these aquifer
systems was found to flow in the till underneath the site
(referred to as the shallow aquifer), and a second system was
identified in the bedrock (referred to as the bedrock aquifer) .
Wright-Pierce concluded that the shallow groundwater beneath the
site flows easterly and discharges into Quiggle Brook under both
pumping and non-pumping conditions. It was also concluded that
Quiggle Brook was a likely discharge point for the majority of
the groundwater flowing through the bedrock beneath the site
under non-pumping conditions at the site.
Between 1979 and 1984, the MDEP cited the plant for deficiencies
in and/or violations of several operating licenses.
Additionally, the MDEP conducted numerous investigations into
potential impacts of chemical contamination at and from the site.
MDEP closed the hazardous waste treatment operations at the Site
in June 1984, at which time approximately 2,000 - 2,500 55-gallon
drums and 30 liquid storage tanks were found on the site. All of
the materials contained within the 55-gallon drums and all but
two of the liquid storage tanks located on the site in June 1984
were removed by EPA and the MDEP by the end of November 1984.
In 1986, the state court ordered that UCC be evicted from the
site, and appointed Maine DEP as the receiver of the property.
All ucc operations ceased at that time. MDEP installed
additional groundwater monitoring wells during the winter of
1986. Groundwater samples were taken from these monitoring wells
to provide a clearer understanding of the contamination existing
at the site. Groundwater monitoring data from these wells
indicated that chemicals had not migrated across Quiggle Brook,
confirming the wright-pierce conclusion that the brook acts as a
divide (barrier) to the flow of till and shallow bedrock
groundwater underneath the brook. Further data collected by the
MDEP indicated that the contamination found in Quiggle Brook was
limited to the marshy (wetland) areas along Quiggle Brook neares:
the site, and a portion of the brook approximately 200 feet in
length downstream from these marshy areas. Volatile organic
compounds (VOCs), similar to those processed by the UCC on the
site, were the principal contaminants observed in Quiggle Brook.
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UNION CHEMICAL COMPANY, ZNC. RECORD OP DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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B.
Bnforcement History
As noted above, separate and joint response actions by EPA and
MDEP were undertaken in late 1984 after hazardous waste treatment
operations ceased on the Site in June 1984. These cleanup
activities resulted in the removal of the barrels, liquids, and
all but two large storage tanks from the Site. Historical
environmental sampling has shown that the groundwater, surface
water (i.e., Quiggle Brook), and soils on the site have been
contaminated by past UCC operations.
The UCC site was first proposed in April 1985 for inclusion on
EPA's Superfund National Priorities List (NPL), the roster of
sites eligible for long-term cleanup funds. The Site was later
re-proposed in June 1988 and formally included on the NPL in
October 1989.
On March 23, 1987, EPA notified UCC and its president, Raymond
Esposito, and approximately 375 additional parties who either
generated wastes that were shipped to the Site, arranged for the
disposal of wastes at the Site, or transported wastes to the Site
of their potential liability with respect to the Site.
Negotiations commenced with these potentially responsible parties
(PRPs) on May 5, 1987 for recovery of past costs expended by EPA
and DEP and for the performance of a Remedial Investigation
(RI)/Feasibility Study (FS) at the Site.
The PRPs formed a steering committee during the summer of 1987.
This committee was involved in substantial negotiations with the
EPA and MDEP throughout the summer and fall of 1987.
Later in the fall of 1987, EPA and MDEP reached agreements in the
form of two Administrative Orders by Consent (AOC) which required
the PRPs to begin investigations aimed at identifying remedial
alternatives for the Site. Approximately two hundred and ninety
(290) PRPs were involved in these two administrative orders. The
first administrative order became effective in November 1987 and
the second order in January 1988. In these two consent orders,
the settling parties agreed to reimburse EPA and the State of
Maine for a majority of the response costs incurred prior to May
22, 1987 for cleanup activities at the Site, and to finance the
performance and oversight of an RI/FS on the Site. The settling
parties established a trust fund to pay for these RI/FS
activities and selected a group of Trustees from these settling
parties to manage the trust fund.
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In August 1989, several additional potentially responsible
parties (who were sued by EPA in November 1987) signed a Consent
Decree by which EPA was reimbursed for all remaining past
response costs incurred at the site through May 22, 1987, plus
interest and enforcement costs. At the present time, EPA is
continuing litigation actions against the Union Chemical Co.,
Inc. (now known as the Union Research Co. or Seneca Research,
Inc.), UCC's president, Raymond Esposito, and four other PRPs.
Finally, in January 1990, EPA notified approximately 25
additional parties who either generated wastes that were shipped
to the site or arranged for the disposal of wastes at the site of
their potential liability with respect to the UCC site.
Identification of these additional parties was based upon
information provided through an extensive auditing effort
performed by EPA, and requested through the steering committee,
on the volumetric contribution of selected PRPs identified at the
site.
The PRPs have been very active in the remedy selection process
for this site. As previously noted, a group of approximately 265
PRPs formed a Trust to manage and coordinate the conduct of the
RI/FS. In addition, technical comments by the PRPs during the
public comment period were submitted in writing and are included
in the Administrative Record.
A more detailed description of the site history can be found in
section 2.0, pages 8 through 31, and Appendix A of the Final Draft RI
report.
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III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement has
been very high. EPA has kept the community and other interested
parties apprised of site activities through numerous informational
meetings, fact sheets, press releases, public hearings, and the
establishment of a telephone Hot-Line.
Community interests and discussions with EPA and the State of Maine
DEP have been primarily through the two citizens' groups that have
been established at the UCC site. These two groups are the Concerned
Citizens of Hope and Hope's Committee for a Clean Environment. In
March 1990, Hope's Committee for a Clean Environment was awarded the
Technical Assistance Grant (TAG) available for the Site and, in turn,
contracted with three technical advisors during June-July 1990.
During March 1988, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about and involved in all activities during the
remedial activities being undertaken at the UCC site. On May 18, 1988
and May 3, 1989, EPA held public informational meetings at the Hope
Elementary School in Hope, Maine to describe plans for the Remedial
Investigation and Feasibility study.
On May 2 and July 12, 1990, EPA made the administrative record and an
addendum to the administrative record available for public review at
EPA's offices in Boston and at the Hope Town Hall in Hope, Maine. EPA
published a notice and brief analysis of the Proposed Plan in two
local newspapers, the Courier Gazette and the Camden Herald, on July
5, 1990. The Proposed Plan was also made available to the public
through mailings to approximately 850 interested parties and by
inclusion of the Proposed Plan in the administrative record located ir.
Boston and at the Hope Town Hall.
Also on May 2, 1990, EPA held an informational public meeting to
discuss the results of the Draft Remedial Investigation/Baseline Risy.
Assessment report. On July 12, 1990, EPA held another informational
public meeting to discuss the results of the Final Draft Remedial
Investigation and Baseline Risk Assessment, to discuss the cleanup
alternatives presented in the Final Draft Feasibility study, and to
present the Agency's Proposed Plan. During this meeting, the Agency
also answered questions from the public.
From July 13, 1990 to October 5, 1990, the Agency held a lengthy,
85-day public comment period to accept public comments on the rernedia:
alternatives presented in the Final Draft Feasibility Study and the
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Proposed Plan, and on any other documents previously released to the
public as contained in the Administrative Record. On August 1, August
23, and september 17, 1990, the Agency held public hearings to discuss
the Proposed Plan and to accept any oral comments. A transcript of
these hearings, and the Agency's response to comments made during the
public comment period are included in the Responsiveness summary that
is attached as Appendix A hereto.
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IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by combining different source
control, management of migration, facilities and off-site soils
remedial alternatives to obtain a comprehensive approach for overall
site remediation. In summary, the selected remedy, which includes:
(1) extraction and treatment of contaminated groundwater: (2)
excavation and treatment of contaminated soils: (3) decontamination
(with prior treatment, as appropriate) and demolition of the
facilities; and (4) further monitoring and analysis of off-site soils,
addresses the significant threats to human health and the environment
posed by the Site. Furthermore, the principal threat to human health
and the environment posed by the Site -- the highly contaminated
groundwater found on the site -- is addressed through treatment, to
the maximum extent practicable, of the source of this contamination
and of the contaminated groundwater itself.
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v.
SUMMARY 01' SITB CHARACTERISTICS
Section 1.0 of the Final Draft Feasibility Study (FS) contains an
overview of the Remedial Investigation (RI) performed at the site.
The significant findings of the RI are summarized below.
A.
soil (on-site and off-site)
The investigations performed during the RI of on-site soil
contamination and potential off-site 50il contamination,
consisted mainly of:
1)
. 2)
borings through the
located on the site to
chemicals had
underlying soils (see
Drilling and sampling 25 soil
concrete pads or containments
determine the extent to which
contaminated the concrete and
attached Figure 4).
Drilling and sampling approximately 80 additional soil
borings on the site (to depths ranging from 10 to 15
feet below the ground surface) to determine the extent
of chemical contamination in these soils (see attached
Figure 4).
3)
Drilling and sampling approximately 20 additional soil
borings on and in areas surrounding the site during the
installation of additional monitoring wells and
piezometers.
4)
sampling off-site surface and subsurface soils at
various locations, including selected wooded and
residential areas surrounding the site, to identify
potential airborne contamination which may have
occurred as a result of UCC's past operation of the
site's hazardous waste incinerator (see attached Figure
5) .
These various soil investigations indicated that the stratigraphy
of the site consists of two geologic sequences (see attached
Figure 6). The first sequence consists of unconsolidated drift,
also referred to as ground moraine deposits, which mainly
consists of glacial till. These glacial deposits are
predominantly composed of a dense, gray, silty till of
Wisconsonian Age. However, some sandy till occurs
discontinuously within the silty till at the ground surface east
of the facilities and adjacent to Quiggle Brook. These
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UNION CHEMICAL COMPANY, %NC. RECORD OP DBCISION SUMMARY
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unconsolidated soils extend from the ground surface (with
thicknesses varying from 70 feet near Quiggle Brook to less than
25 feet at the western portion of the Site) to the underlying
geologic sequence which consists of lower Paleozoic rusty schist
and qneiss bedrock with small granitic intrusions. The bedrock
is severely weathered and fractured within the upper five feet,
immediately below the bedrock/till interface.
Generally, on-site soils affected by the organic chemical
contaminants handled on the UCC Site can be grouped into two (2)
categories:
1)
unsaturated soils (soils located above the groundwater
table) that were directly contaminated by the disposal
or spilling of contaminants on the ground surface: and
saturated soils (soils located below the groundwater
table) that were contaminated by the chemicals in the
groundwater moving through these soils. .
2)
The chemical contamination of the unsaturated soils appears to
have occurred as a result of spills or leaks from drums, tanks,
or pipes previously located on the Site. The chemical
contamination of these unsaturated soils is relatively small in
lateral extent in comparison to the extent of contamination of
the saturated soils on the Site. However, the concentrations of
organic chemical contaminants in the unsaturated soils is
significantly higher than those concentrations in the underlying
saturated soils.
The principal source areas of the organic chemical contaminants
on the UCC Site are the Old Leach Field, the area surrounding
monitoring well B-9 and MW-13, and the perimeter soils
surrounding the south side of the former warehouse pad. The most
frequently detected organic contaminants in these three principal
source areas are: toluene: 1,1,1-trichloroethane (l,l,l-TCA):
trichloroethene (TCE); xylene; and tetrachloroethene (PCE). (See
attached Figures 7-22 and Table 1).
Additionally, field investigations were also performed during the
RI in areas off the site to determine background conditions and
to assess the potential impact of past incinerator operations at
the UCC site. Twenty-four (24) sampling locations were selected
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related to the elevated VOC concentrations found
primarily in the soils near the still Building located
on the site.
The VOCs most frequently detected in the groundwater
included (in decreasing order of frequency) 1,1-
dichloroethane (l,l-DCA), trichloroethene (TCE), 1,1-
dichloroethene (l,l-DCE), and 1,1,1-trichloroethane
(l,l,l-TCA) (see attached Table 2).
The existing data are insufficient to confirm or deny
the presence or absence of non-aqueous phase liquids
(NAPLs) within the subsurface at the site.
Additionally, sampling was conducted during the RI at numerous
residential wells in the area of the UCC site. The results from
these data indicate that the volatile organic chemical impacts
identified in one deep bedrock residential well, located
immediately north of the site, can be associated with the site
contamination. These data confirm the presence of contamination
identified during several historical sampling rounds from this
same residential well. However, chemical data from this bedrock
well indicates that no Federal or state of Maine drinking water
standards were exceeded at the time of sampling.
C.
surface Waters and Sediments
Analysis of the possible extent of site-related contamination of
. surface waters on the site and off the UCC property was also
performed during the RI. These investigations focused on the
surface waters and sediments within several bodies of water,
including:
Quiggle Brook:
Fish pond:
Crawford Pond:
The wetland area located in the northwest corner of the
property: and
The wetland area and associated drainage ways located
behind the southern-most portion of the fence
surrounding the facilities on the Site.
Additionally, analytical results
samples obtained prior to the RI
were also reviewed. These areas
hereto.
of surface water and sediment
from Fish pond and Grassy Pond
are shown on Figure 1 attached
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two ways: (i) randomly, and (ii) based upon best-engineering
judgement which incorporated computer modelling of the
incinerator stack emissions to simulate where fallout of these
emissions may have been deposited onto the ground. Significant
variability in sample results for polycyclic aromatic
hydrocarbons (PAHs), lead and dioxin made it very difficult to
determine precisely whether the source of these contaminants was
from past operations at the UCC Site or not. Generally, metals
were detected at concentrations which were within the typical
State of Maine background levels, and total PAHs were detected at
low parts per million (ppm) levels in several off-site locations,
primarily residential yards. However, at one location, lead
levels exceeded the typical background levels for lead. At
another off-site location (the woodland area north of the Site),
two surface soil samples were taken. In one of these samples,
one dioxin-isomer (out of the eighteen such isomers analyzed for
in each of these samples) was tentatively identified at a low
parts per billion (ppb) level.
B.
Groundwater
Field investigations were conducted during the RI to characterize
the quality and movement of groundwater beneath the Site and in
surrounding areas. The following is a summary of the results of
these groundwater investigations.
Groundwater in the shallow (till zone) aquifer flows
beneath the site in an easterly direction (under
normal, non-pumping conditions at the Site) towards
Quiggle Brook (see attached Figure 23).
Quiggle Brook acts as a groundwater discharge point for
the contaminated groundwater flowing beneath the site
(under non-pumping conditions at the site).
Concentrations of several volatile organic chemical
(VOC) contaminants were detected in the till and
shallow bedrock monitoring wells located on-site;
specifically, between the eastern fence and Quiggle
Brook (see attached Figures 24-29).
Past operations of two on-site, deep bedrock water
supply wells has drawn VOCs from the shallow bedrock
into the deeper bedrock.
Elevated concentrations of VOCs in groundwater are
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Surface water samples were collected from five locations within
Quiggle Brook (along the eastern property boundary, between Route
17 and the old mill dam) in 1987 and 1988. These samples
indicated that the detected concentrations of VOCs (primarily
1,2-dichloroethene, 1,1,1-trichloroethane and 1,1-dichloroethane)
were less than those found in similar surface water samples
obtained from the same area in 1981 (when the UCC was
operational). In addition, these VOCs were not detected
consistently in surface water samples obtained from Quiggle Brook
during the RI; most likely due to the influence of seasonal
variations in the volume of water flowing within the brook.
Sediment samples obtained from this same area of Quiggle Brook
during the RI showed variable concentrations of heavy metals.
Lead was the predominant contaminant detected within Quiggle
Brook sediment samples, but at concentrations within the typical
range for state of Maine background levels of lead. However, one
sediment sample taken during the summer of 1988 contained lead at
156 parts per million (ppm), which is approximately three to five
times background levels. A second sediment sample from this same
location during the fall of 1988 indicated lead concentrations
within typical background concentrations at 14.1 ppm. PARs were
detected at low concentrations in the sediment samples taken frOD
Quiggle Brook, but were not considered to be at concentrations
which would be harmful to public health or the environment and
were not detected with any significant degree of frequency in
soils on the site. . At a similar, "control" brook (an unnamed
tributary to Seven Tree Pond) located approximately four (4)
miles west of the site along state Route 17, sediment samples
were taken and analyzed for PARs (see attached Figure 30). No
PARs were detected in these samples, which suggests that the
influence of Route 17 as a potential source of PAHs in Quiggle
Brook is unlikely.
Two surface water and sediment samples taken during the RI from
Fish Pond (i.e. just downstream from the Hobbs Pond and Fish Pond
interconnected waterway/dam, and just upstream of the Fish Pond
dam near state Route 17), revealed no detectable concentrations
of organic chemical constituents. Inorganic chemicals, including
heavy metals, were detected in both of these sediment samples but
the concentrations were well within typical state of Maine
background levels found for these heavy metals in soils.
Analysis of a surface water sample collected from Crawford Pond
indicated the presence of a very low concentration of methylene
chloride in the wetland area surrounding the inlet to the pond,
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which is also the outlet of Quiggle Brook as it flows into
Crawford Pond. This low concentration of methylene chloride is
thought to have resulted from laboratory contamination during
sample preparation. No other chemicals were detected in the
surface waters of Crawford Pond.
Sediment samples taken in the wetland area along State Route 17
in the northwest corner of the site showed highly variable
concentrations of heavy metals such as lead, chromium and zinc.
Analysis of surface water samples obtained from the wetland area
south of the southern-most portion of the on-site fence did show
the presence of VOCs (specifically, l,l,l-trichloroethane, 1,1-
dichloroethane, trichloroethene, 1,2-dichloroethene, and
tetrachloroethene), but only in the sample taken closest to the
southern-most portion of the fence.
Finally, surface water and sediment samples vere taken in Grassy
Pond and Fish Pond in July 1987 by the Camden and Rockland Water
Company for analyses of PCBs, semi-volatile organics, VOCs, and
dioxins. None of these chemicals were detected in any of the
samples obtained from either pond.
D.
Facilities
Samples were obtained from within the buildings and other
facilities/equipment remaining at the UCC site during the RI.
Samples consisted of liquid, sludge, ash, dust, fiberglass, floor
sweepings, wood shavings, and floor scrapings from the
incinerator, floor drainage sumps, tanks, and other structures
and equipment remaining from past UCC operations. Analytical
results of these samples indicated that concentrations of organic
and/or inorganic chemicals exist in practically all of these
facilities and equipment. Most notably, dioxin and furan
contamination was confirmed twice in the ash samples obtained
from the secondary scrubber at 2,3,7,8-TCDD toxicity equivalent
values of 4.5 to 12.96 ppb and, to a lesser extent, within
several other components of the incinerator equipment (2,3,7,8-
TCDD toxicity equivalent values of 0.0 to 0.8 ppb). Asbestos was
found within the Still Building, and significant heavy metals
contamination (exceeding certain characteristic hazardous waste
limits) was identified within the various sump and incinerator
ash/sludge samples collected.
A more complete discussion of the Site characteristics can be found in
the Final Draft Remedial Investigation report within Section 3.0,
pages 32 through 58.
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VI.
SUMMARY 01' SITE RISKS
A Baseline Risk Assessment (Baseline RA) was performed to estimate the
probability and magnitude of potential adverse human health and
environmental effects from exposure to contaminants associated with
the site. The public 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 non-
carcinogenic risks. Several EPA guidance documents were used in the
preparation of the Baseline RA including, but not limited to : (i)
Risk Assessment Guidance for Superfund, Volume I, Human Health
~valuation Manual (Part A), Interim Final, EPA/540/1-89/002, December
1989: and (ii) supplemental Risk Assessment Guidance for the superfund
Program, EPA Region I, Draft Final, EPA 901/5-89-001, June 1989.
The results of the public health risk assessment performed for the Dee
site are discussed below followed by the conclusions of the
environmental assessment.
A.
PUblic Health Risk Assessment
Of the more than seventy (70) organic and inorganic chemical
constituents detected in the groundwater, soils, surface waters,
sediments, and facilities on and off the UCC site, as shown in Tables
1 through 5 attached to this Record of Decision (ROD), twenty-three
(23) contaminants of concern were selected for evaluation in the
Baseline RA. Table 6, also attached, lists these 23 contaminants of
concern. These contaminants of concern are considered to constitute a
representative subset of the more than 70 contaminants identified at
the site during the Remedial Investigation. These 23 contaminants of
concern were selected to represent potential site-related hazards
based on toxicity, concentration, frequency of detection, mobility and
persistence in the environment. A summary of the health effects of
each of these 23 contaminants of concern can be found in section
12.2.3, pages 182 through 192, of the Final Draft Remedial
Investigation (RI) report, while detailed toxicity profiles of each
contaminant of concern is provided in Appendix S of the Final Draft RI
report.
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Potential human health effects associated with exposure to these 23
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 (current) uses, potential future uses
(specifically, residential use), and location of the Site. Table 7 of
this ROD identifies the exposure pathways considered. Table 8
provides the exposure assumptions used in the Baseline RA. A more
thorough description of the exposure pathways can be found in Section
12.4, pages 201 through 221, of the Final Draft RI report.
For each exposure pathway developed and evaluated for each impacted
medium at the UCC Site, carcinogenic and non-carcinogenic health risks
were estimated for an average and a reasonable maximum exposure
scenario which corresponded to exposures to the average (i.e.,
geometric mean) and the maximum concentration detected in that
particular medium at the UCC Site. .
Excess lifetime carcinogenic (cancer) risks were determined for each
exposure pathway by mUltiplying the exposure level with the chemical-
specific cancer potency factor. Cancer potency factors have been
developed by EPA from epidemiological or animal studies to reflect a
conservative "upper bound" estimate of the risk posed by potentially
carcinogenic compounds. That is, the true risk is very unlikely to be
greater than the risk predicted. The resulting risk estimates are
expressed in scientific notation as a probability (e.g., 1 x 10'6 for
1/1,000,000), and indicate (using this example) that an individual is
not likely to have greater than a one in a million chance of
developing cancer over 70 years as a result of Site-related exposure
as defined for the given compound at the stated concentration.
Current EPA practice considers carcinogenic risks to be additive when
assessing exposure to a mixture of hazardous substances.
The hazard index was also calculated for each exposure pathway as
EPA's measure of the potential for non-carcinogenic health effects.
The hazard index is calculated by dividing the exposure level by the
reference dose (RfD) or other suitable benchmark for non-carcinogenic
health effects. Reference doses have been developed by EPA to protec~
sensitive individuals over the course of a lifetime and they reflect a
daily exposure level that is likely to be without an appreciable ris~:
of an adverse health effect. RfDs are derived from epidemiological or
animal studies and incorporate uncertainty factors to help ensure tha~
adverse health effects will not occur. The hazard index is often
expressed as a single value (e.g., 0.3) which indicates the ratio of
the stated exposure as compared to the reference dose value (in this
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example, the exposure as characterized is approximately one third of
an acceptable exposure level for the given compound). The hazard index
is only considered additive for compounds that have the same or
similar toxic endpoints (for example: the hazard index for a compound
known to produce liver damage should not be added to that of a second
compound whose toxic endpoint is kidney damage).
The attached Tables 9 and 10 depict the present (current) risks and
the potential future (residential use) risk estimates, respectively,
for each of the exposure pathways presented in Table 7. These tables
also present both the carcinogenic and non-carcinogenic risks
estimated for each exposure pathway and corresponding average and
reasonable maximum exposure scenarios, as well as an indication of the
contaminant(s) which contribute the most to the estimated risk for
that particular exposure pathway. The reader should refer to tables
25 through 62 of Appendix X of the Final Draft RI report, for
additional specifics on the individual risk estimates for the
contaminants of concern and exposure pathways evaluated for the uee
site.
Based upon the detailed information provided in the section 12.0, The
Baseline Risk Assessment (RA) and corresponding appendices, of the
Final Draft RI report, the following conclusions were developed:
o
The 23 contaminants of concern selected for evaluation in
the Baseline RA represent the majority of the carcinogenic
and non-carcinogenic hazards (risks) posed by the uee site.
Current Risks:
o
potential incremental carcinogenic risks, over a lifetime
(70 years) of exposure, are limited under current site
conditions pri~arily because of the existing fence which
surrounds the major source areas of contamination on the
site.' The estimated risks under current site conditions
range from 1 x 10.5 (from absorPtion of incinerator residues
containing dioxin) to 2 x 10'" (from ingestion of other
facilities residues). These current, potential incremental
, If the fence did not prevent access to the site, current
risks from exposure to on-site soils would likely be equivalent to
or less than the risk quantified under future site conditions,
which are calculated with the assumption that the site will be used
for residences.
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cancer risks do not exceed the lower limit of EPA's
acceptable risk range of 10.4 to 10.6, but, when compared to
the state of Ma\ne's policy guidance for cancer risks
greater than 10. , may indicate a basis for health concern.
See attached Table 9.
o
Non-carcinogenic or other adverse health risks (hazards) are
not expected to result from exposures assumed under current
Site conditions because the hazard indices calculated did
not exceed 1.0. See attached Table 9.2
Future Risks:
o
Under future Site conditions, an increased risk of cancer
over a lifetime of exposure may be associated with the Site,
if the UCC Site is not cleaned up. This estimated excess
lifetime cancer risk is principally from the ingestion
(drinking) of the contaminated Site groundwater. The
estimated carcinogenic risk from the ingestion of on-site
groundwater ranges from 1 x 10.' (worst case scenario) to
6 x 10.4 (average case scenario). These estimates exceeds
EPA's lower risk range limit of 10.4 and the State of
Maine's risk policy guidance of 10.5. The major
contaminants of concern which are contributing most to this
carcinogenic risk are 1,1-dichloroethene, 1,1-dichloroethane
and trichloroethene (see attached Table 10). The future
risk associated with exposures to on-site soils ranges from
6 x 10.5 to 4 X 10'7, and does not exceed the lower limit of
EPA's acceptable risk range of 10.4 to 10.6.
o
If ingestion of the contaminated Site groundwater were to
occur in the future over a lifetime, non-carcinogenic
effects could be observed in individuals ingesting this
groundwater. The hazard index is estimated at 26 (worst
case scenario). The major contaminants of concern which are
contributing most to this potential hazard are methylene
chloride and 1,1-dich1oroethene (see attached Table 10).
2 As indicated above for carcinogenic risks, if the fence did
not prevent access to the Site, current non-carcinogenic risks fro~
exposure to on-site soils would likely be equivalent to or less
than the risk quantified under future site conditions.
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B.
Bnviroum8ntal Assessment
An environmental assessment was also conducted for the ucc site, which
incorporated the results of the wetlands assessment and RI field
sampling activities performed. The results of the wetlands assessment
can be found in Appendix I of the Final Draft RI report, while section
12.7 of the Final Draft RI report provides a narrative discussion of
the environmental assessment.
Overall, this environmental assessment concluded that, while
significant hazards do not exist, potential impacts could occur to the
wildlife population at the site if they came in direct contact with
the contaminated soils, sludges, and facilities. Additionally, the
environmental assessment concluded that biota present in the
intermittently wet area (wetland) in the northwest corner of the site
(see attached Figure 31) may be adversely affected by the presence of
metals in the sediments of this area. However, based on the
conclusions provided in the wetlands assessment, this isolated wetland
area primarily serves as a detention area for stormwater runoff from
~oute 17 and its functional value is considered low in comparison to
the wetlands associated with Quiggle Brook. Finally, this assessment
concluded that the organic and inorganic contaminants observed in
Quiggle Brook would not adversely affect the benthic organisms in this
brook.
C.
Conclusions
In summary, the public health and environmental assessments showed
that 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, welfare, or the environment.
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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 the Comprehensive Environmental Response,
Compensation, and Liability Act (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 mobility of the
hazardous substances is a principal element over remedies not
involving such treatment. Response alternatives were developed
for the UCC Site 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 for
the UCC site 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 are:
1.
On-Site Soil Remedial Action Objective
Prevent further leaching and migration into the
groundwater of contaminants in the soils on the
Site, by removal and treatment of contaminants
above specific concentrations throughout the Site.
2.
Groundwater Remedial Action Objectives
Provide rapid restoration of the
groundwater throughout the Site,
concentrations that will protect
future users, as well as natural
wildlife) that come into contact
contaminated
to
current and
resources (i. e. ,
with the
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ONION CJlEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
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contaminants contained within the qroundwater.
Protect off-site groundwater and surface waters
(particularly Quiggle Brook) by preventing further
miqration of the contaminated on-site groundwater.
Facilities Remedial Action Objectives
3.
Prevent ingestion or absorption of contaminants
(particularly dioxins) contained within the
incinerator equipment remaining on the site.
Prevent inhalation of friable asbestos from the
still Building.
Remove all existing structures located on the site
to allow for the cleanup of contaminated soils
found throughout the site.
Remove all other contaminated materials from the
facilities so that the site will be suitable for
all potential future uses.
Off-Site soil Remedial Action Objective
4.
Further evaluate and, if necessary, minimize
and/or mitigate any potential risks to public
health and the environment from potential soil
impacts due to contaminants which were previously
emitted from the UCC site incinerator.
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 remedial alternatives were developed and
evaluated for the UCC site.
with respect to source control remedial actions which focus on
the contaminated on-site soils, the RI/FS developed a range of
remedial alternatives in which treatment that reduces the
toxicity, mobility, or volume of the hazardous substances was a
principal element. This range included alternatives that remove
or destroy hazardous substances to the maximum extent feasible,
eliminating or minimizing to the degree possible the need for
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alternatives that treat the principal threats posed by the Site
but vary in the degree of treatment emp~oyed and the quantities
and characteristics of the treatment residuals and untreated
waste that must be managed: a1ternative(s) that involve little or
no treatment but provide protection through engineering or
institutional controls: and a no action alternative.
With respect to groundwater remedial actions, the RI/FS developed
a limited number of remedial alternatives that attain site-
specific remediation levels within different timeframes using
different technologies: and a no action alternative. .
With respect to the on-site facilities and off-site soils
remedial actions, the RI/FS developed only a limited number of
remedial alternatives which were consistent with the source
control and management of migration response objectives; as well
as no action alternatives.
As discussed in Section 4.0 of the Final Draft Feasibility Study
(FS) report, remedial technologies were identified, assessed and
screened based on the following factors: implementability,
effectiveness, and cost. These remedial technologies were
combined into their appropriate source control (SC), management
of migration (MM), facilities management (F), and off-site soils
(OS) remedial alternatives. section 5.0 of the Final Draft
Feasibility Study report presents the remedial alternatives
developed by combining the remaining technologies identified in
the previous screening process into, at a minimum, 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 alternatives for further detailed analysis while
preserving a range of options. Each remedial alternative was
then evaluated and screened later in Section 5.0 of the Final
Draft Feasibility Study report.
In summary, of the seven (7) source control, six (6) management
of migration, five (5) facilities management and two (2) off-
site soils remedial alternatives screened in section 5.0, all but
one (1) source control remedial alternative was retained for
detailed analysis. Table 11, attached to this ROD, identifies
the source control, management of migration, facilities
management, and off-site soils remedial alternatives that were
retained through these various screening processes. This table
also identifies a source control remedial alternative (SC-4)
which was eliminated from further consideration, because of its
disproportionate cost in relation to its effectiveness and
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implementability, as compared to other source control
alternatives involving treatment of the contaminated on-site
soils.
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VIII.
DESCRIPTION OF ALTERNATIVES
This Section of the ROD provides a narrative summary of each remedial
alternative evaluated in detail in the Final Draft FS report. A
detailed tabular assessment of each alternative can be found in tables
31, 34, 37, 40, 43, 46, 49, 52, 55, 58, 61, 64, 67, 70, 74, 77, 80,
82, and 84 of the Final Draft FS report.
A.
Source Control (SC) Alternatives Analyzed
The source control alternatives analyzed in detail for the uee
Site included the No-Action (Se-l); Limited Action (Se-2); Site
Capping (SC-3); Soil Excavation and Low-Temperature Thermal
Aeration Treatment (SC-5); In-Situ Soil Aeration (SC-6); and Soil
Excavation and High-Temperature Thermal Treatment (SC-7) remedial
alternatives.
SC-1:
NO-Action
This source control (SC) alternative would involve no
remedial action on any of the contaminated soils found at
the Site. This alternative is included in the Feasibility
Study's detailed analysis to serve as a basis for comparison
with the other SC remedial alternatives considered. A
no-action alternative would be selected only if the Site
posed little or no risk to public health and the
environment.
This alternative includes the monitoring of groundwater and
Quiggle Brook. The no-action alternative would entail a
review of the Site conditions every five years. For
purposes of estimating costs of this alternative in the
Final Draft FS, it was assumed that this alternative would
be implemented for 30 years.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 0 years
ESTIMATED TIME OF OPERATION: approximately 30 years
ESTIMATED CAPITAL COST: $0
ESTIMATED TOTAL COST (NET PRESENT WORTH): $78,000
SC-2:
Limited Action
The limited action alternative consists of institutional
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specifically, this alternative includes annual maintenance
of the existing chain link fence and warning signs around
the site; deed restrictions to prevent development and use
of the site and adjacent off-site areas; and five-year.
reviews of the site conditions to evaluate the necessity of
additional remedial actions.
BSTIMATED TIME FOR DESIGN AND CONSTRUCTION: 0 years
ESTIMATED TIME OF OPERATION: approximately 30 years
ESTIMATED CAPITAL COST: $5,000
ESTIMATED TOTAL COST (NET PRESENT WORTH): $101,000
SC-3:
site capping
This source control alternative consists of constructing a
multimedia, RCRA-compliant cap over the contaminated on-
site soils to limit additional exposures to the soil
contaminants which pose a relatively low long-term threat
alone but, more importantly, to reduce or eliminate the
migration of chemical contaminants from the unsaturated
soils into the underlying groundwater system which poses
the principal threat at the site. This alternative was
evaluated in detail considering three soil cleanup levels as
presented in the Final Draft FS report. More specifically,
Case A.1 included capping those contaminated soils greater
than 0.1 ppm (covering approximately 39,200 square feet),
Case A.2 included capping those contaminated soils exceeding
1.0 ppm (covering approximately 21,200 square feet), and
Case A.3 included capping those contaminated soils exceeding
10 ppm (covering approximately 11,800 square feet). To
implement this alternative, the facilities covering these
contaminated soils would need to be demolished and removed.
This alternative would also include the institution of deed
restrictions prohibiting site development.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 1-2
ESTIMATED PERIOD OF OPERATION: approximately 30
ESTIMATED CAPITAL COST:
$260,000 for Case A.3
$458,000 for Case A.2
$812,000 for Case A.1
ESTIMATED TOTAL COST (NET PRESENT WORTH):
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SC-s:
soil Excavation and Low-Temperature Thermal Aeration
Treatment
This source control remedial alternative involves the
excavation of contaminated on-site soils and low-temperature.
thermal treatment of these soils. The Final Draft FS report
considered three soil cleanup levels for implementation of
this alternative: Case A.1 (approximately 8,500 cubic yards
of in-place soil), Case A.2 (approximately 5,100 cubic yards
of in-place soil), and Case A.3 (approximately 2,600 cubic
yards of in-place soil). An additional version of the 0.1
ppm soil cleanup level was evaluated in the Final Draft FS
report for this remedial alternative, and is referred to as
Case B.
[Note that Case B of this SC remedial alternative has been
selected as a component of the overall remedy which
addresses the contaminated soils on the Site. The Case B
option, which involves the excavation and treatment of both
unsaturated and saturated contaminated soils (approximately
10,500 cubic yards of in-place soil), is discussed in detail
in Section X, "The Selected Remedy" portion of this ROD).
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 1-1.5 years
ESTIMATED PERIOD OF OPERATION: approximately 6 months
ESTIMATED CAPITAL COST:
$1,579,000 for Case A.3
$2,210,000 for Case A.2
$3,059,000 for Case A.1
ESTIMATED TOTAL COST (NET PRESENT WORTH):
$1,579,000 for Case A.3.
$2,210,000 for Case A.2.
$3,059,000 for Case A.l.
In-situ 80il Aeration
SC-6:
This alternative involves the extraction of contaminants
from the unsaturated on-site soils (contaminated soils above
the groundwater table) using an in-situ vacuum extraction
method. The contaminants in the soils are removed without
excavation. The contaminated soils remain "in-situ" or in
place while undergoing treatment. Piping is attached to
extraction wells and also to a vacuum pump. The vacuum pu;r
draws air from the surrounding contaminated soils into the
wells without disturbing the soils. As the air passes over
the contaminated soils, VOc contaminants are transferred
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from the soil to the air. The air is then sent through
carbon adsorption columns that remove the contaminants from
the air, and the treated air is discharged to the
atmosphere. The carbon is then regenerated to remove the
contaminants, and then reused in the process for further
treatment of the contaminated air. The contaminants removed
from the carbon are permanently destroyed. other components
of this option include the conduct of an pilot study on the
site to guide system design, construction, and operation of
the in-situ soil aeration/vacuum system: treatment and
disposal of condensed moisture extracted by the in-situ
aeration system: soil sampling and analysis to evaluate the
cleanup of the contaminated soils to the chosen target
cleanup levels: annual inspection and maintenance of the
existing fence during the time of remediation: and mulching
and planting of grass on the site following remediation.
Removal of the facilities would not be necessary under this
option. This alternative was also considered for the three
contaminated soil cleanup levels (i.e., Case A.l, A.2, and
Case A.3) to be included in the cleanup. These cleanup
levels are described as part of Alternative SC-3: more
complete descriptions are included in the Final Draft FS
report.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED PERIOD OF OPERATION: approximately
ESTIMATED CAPITAL COST:
$514,000 for Case A.3
$909,000 for Case A.2
$1,123,000 for Case A.1
ESTIMATED TOTAL COST (NET PRESENT WORTH):
$1,980,000 for Case A.3.
$3,009,000 for Case A.2.
$3,946,000 for Case A.1.
Soil Excavation and High-Temperature Thermal
Treatment
1-2 years
5-15 years
SC-7:
This alternative involves soil excavation with treatment of
the excavated soils using a high-temperature (typically
1,300 to 1,400 degrees Fahrenheit) thermal treatment process
on the site, such as a mobile rotary-kiln incinerator. This
alternative was evaluated for the three Case A IIsuboptions"
noted above in SC-3, as well as the Case B option. This
alternative would require the removal of the existing
facilities on the site in order to access all the
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contaminated soils requiring excavation. The contaminated
soils that would undergo the high-temperature treatment
process would be backfilled on the Site into the original
excavation area, and/or used for regrading and vegetating
the site. This alternative would also include air
monitoring at the perimeter of the Site during all
excavation and treatment operations on the site. An on-
site "trial burn" and sampling effort to evaluate and
optimize the destruction and removal efficiency of the
mobile incineration system would occur under this
alternative.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 1-1.5
BSTIMATED PERIOD OF OPERATION: 6 months-1 year
ESTIMATED CAPITAL COST:
$2,542,000-$5,201,000 for Case A.3
$4,108,000-$7,025,000 for Case A.2
$6,256,000-$9,569,000 for Case A.1
$7,531,000-$11,076,000 for Case B
ESTIMATED TOTAL COST (NET PRESENT WORTH):
$2,542,000-$5,201,000 for Case A.3
$4,108,000-$7,025,000 for Case A.2
$6,256,000-$9,569,000 for Case A.l
$7,531,000-$11,076,000 for Case B
years
B.
Management of Migration (MK) Alternatives Analyzed
Management of migration alternatives address contaminants that
have migrated from the original source of contamination. At the
ucc Site, contaminants have migrated from the contaminated soils
(source) which are primarily located within the 2.25-acre fenced
area of the site into the shallow and deeper aquifers underlying
the Site.
The Management of Migration alternatives evaluated in detail for
the UCC Site included: No-Action (MM-l), Limited Action (MM-2),
Groundwater Extraction with On-site Treatment and Discharge to
Quiggle Brook (MM-3), Vacuum-Enhanced Groundwater Extraction with
On-site Treatment and Discharge to Quiggle Brook (MM-4),
Groundwater Extraction with On-site Treatment and Reinjection
(MM-5), and Vacuum-Enhanced Groundwater Extraction with On-Site
Treatment and Reinjection (MM-6).
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lIX-ll
.o-Ac~ion
This alternative would consist of implementing a groundwater
monitoring program to assess the continuing condition of the
site. During the program, quarterly water samples would be
taken and analyzed and the site would be reviewed every five.
years to assess the need for additional remedial action.
The no-action (monitoring only) groundwater alternative is
included for evaluation, as required by CERCLA, as a basis
for comparison with the other MM alternatives. For purposes
of estimating costs of this alternative in the Final Draft
FS, it was assumed that this MM alternative would be
implemented for 30 years.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 0 years
ESTIMATED PERIOD 01' OPERATION: approximately 30 years
ESTIMATED CAPITAL COST: $0
ESTIMATED TOTAL COST (NET PRESENT WORTH): $890,000
HK-2:
Limi~ed Action
This limited action alternative, like Alternative MM-l,
would involve continued monitoring of the site groundwater.
The monitoring program for this alternative would be the
same as that for MM-l. In addition, this alternative would
include the implementation of deed restrictions to limit
future development and use of the site groundwater: for
example, prevention of the installation of an on-site water
supply or reactivation of an existing well. The deed
restrictions would reduce the risk posed by exposure to
groundwater.
BSTIMATED TIME FOR DESIGN AND CONSTRUCTION: 0 years
BSTIMATED PERIOD 01' OPERATION: approximatelY 30 years
BSTIMATED CAPITAL COST: $0
BSTIMATED TOTAL COST (NET PRESENT WORTH): $895,000
HK-3:
Groundwa~er Extraction, on-site Treatment, and
Discharge to Quiggle Brook
This alternative would involve the extraction and treatment
of groundwater on-site by pumping the water containing
chemical contaminants with concentrations greater than
drinking water standards. Several groundwater extraction
wells would be used to extract the contaminated groundwater.
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The wells would be installed in the till zone and bedrock
aquifers, where groundwater contamination was detected
during the RI. Extracted groundwater would be treated with
a process called ultraviolet (UV) light/oxidation. This
alternative might require pretreatment of the groundwater to
remove solids or other matter which could affect the
UV/oxidation treatment process. The treated groundwater
would be discharged to Quiggle Brook and sampled
periodically to determine the effectiveness of treatment.
Institutional controls such as deed or zoning restrictions
would be required to prevent ingestion of groundwater prior
to completion of the cleanup.
ESTIMATED TIME FOR DBSIGN AND CONSTRUCTION:
ESTIMATED PERIOD OF OPERATION:approximately
BSTLMATBD CAPITAL COST: $1,114,000
ESTIMATED TOTAL COST (NET PRESENT WORTH):
$4,192,000-$5,014,000
1-2 years
15-30 years
MH-4:
Vacuum-Enhanced Groundwater Extraction, On-site
Treatment, and Discharge to Quiggle Brook
This management of migration (MM) remedial alternative has
been selected as the remedial alternative component of the
overall selected remedy for addressing the contaminated
groundwater on the Site. This MM alternative is described
in detail in Section X, "The Selected Remedy," of this ROD.
MH-5:
Groundwater Extraction, On-site Treatment, and
Reinjection
Alternative MM-5 includes extraction of the contaminated
groundwater with concentrations exceeding drinking water
standards on the Site by pumping, followed by treatment and
reinjection of the treated water back into the till zone
aquifer on the Site. Similar to the processes described in
alternative MM-3, this alternative would involve
installation of extraction wells, extraction of contaminated
groundwater to ground surface treatment units, and treatment
of extracted water by UV/oxidation. Monitoring and
evaluation activities would include sampling of monitoring
and extraction wells, monitoring water levels, and
periodically performing maintenance and redevelopment of the
reinjection wells. Institutional controls such as deed or
zoning restrictions would be required to prevent ingestion
of groundwater prior to completion of the cleanup.
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ESTIMATED ~IKE FOR DESIGN AND CONSTRUCTION:
ESTIMATED PERIOD OF OPERATION:approximately
ESTIMATED CAPITAL COST: $1,573,000
ESTIMATED ~OTAL COST (NET PRESENT WORTH):
$4,806,000-$5,689,000
1-2 years
15-30 years
101-6:
vacuum-Enbanced Groundwa~er Ex~rac~ion, on-Si~e
~reatment, and Reinjection
This alternative involves extraction of contaminated
groundwater with concentrations exceeding drinking water
standards, by using vacuum-enhanced extraction wells as
described in detail in alternative MM-4 (EPA'S Selected
Remedy).. The only difference between this alternative and
MM-4 is that under this alternative treated groundwater
would be reinjected into the till aquifer located on the
site (as described in MM-5 above) instead of being
discharged into Quiggle Brook. Because of this difference,
alternative MM-6 requires the installation of several
reinjection wells as described in alternative MM-5, and the
monitoring and maintenance inherent with these reinjection
wells. Institutional controls such as deed or zoning
restrictions would be required to prevent ingestion of
groundwater prior to completion of the cleanup.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED PERIOD OF OPERATION:approximately
ESTIMATED CAPITAL COST: $1,648,000
ESTIMATED TOTAL COST (NET PRESENT WORTH):
$5,633,000-$7,615,000
1-2 years
15-30 years
C.
Facili~ies (F) KanaqemeD~ Al~erna~ives Analyzed
The Facilities (F) management alternatives evaluated in detail in
the Final Draft FS report are described below.
F-1:
110 Ac~ion
This "no action" alternative was evaluated as a baseline for
the comparison of other facilities management remedial
alternatives. As with other no action alternatives
presented previously for source control and management of
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the condition of the site. Because the cost for these
monitoring programs is included in the management of
migration (groundwater) alternatives, the only cost incurred
for this facilities management alternative would be that for
an evaluation of the Site every five years to determine the
need for additional remedial action. For purposes of
estimating costs of this alternative in the Final Draft FS,
it was assumed that this facilities alternative would be
implemented for 30 years.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 0 years
ESTIMATED PERIOD OF OPERATION: approximately 30 years
ESTIMATED CAPITAL COST: $0
ESTIMATED ~T.L COST (HET PRESENT WORTH): $78,000
Limited Action
F-2:
This alternative consists of institutional actions designed
to eliminate or reduce the potential for exposure to the
contaminated site facilities. The activities involved in
the implementation of this alternative includes the
installation of additional access barriers (fences) and
lighting, annual maintenance of the existing fences and
signs around the Site area, implementation of deed
restrictions, and conducting a review of the site conditions
every five years to evaluate the necessity of additional
remedial action.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 6 months
ESTIMATED PERIOD OF OPERATION: approximately 30 years
ESTIMATED CAPITAL COST: $13,000
ESTIMATED TOTAL COST (NET PRESENT WORTH): $128,000
F-3:
Facilities Decontamination Only
This facilities management alternative includes all of the
features of Alternative F-2, with the following additional
activities:
Removal of materials from, decontamination of, and
encapsulation of sumps in-place; and
Decontamination of facilities' concrete pads,
walls, and incineration components in-place using
high-pressure steam cleaning.
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ESTIMATED TIME ~OR DESIGN AND CONSTRUCTION: 1 year
ESTIMATED PERIOD OF OPERATION: approximately 30 years
BSTIMATED CAPITAL COST: $102,000
ESTIMATED TOTAL COST (NET PRESENT WORTH): $217,000
Facilities Decontamination and Demolition
~-4:
This facilities (F) management remedial alternative has been
selected as the remedial alternative component of the
overall selected remedy for addressing the facilities
contamination on the site. This facilities alternative is
discussed in detail in Section X of this ROD, as part of
EPA's Selected Remedy for the UCC site.
F-S:
~acilities Demolition and Disposal without
Decontamination
This alternative consists of demolition (without prior
decontamination) of all site facilities, including the
following:
. still building and associated
. Church
. Welding shop
. Incinerator complex
. Concrete pads
Activities involved in the demolition of these facilities
would include removal of water from the existing sumps for
treatment and disposal, removal of the asbestos from the
still building, and demolition, excavation, and backfilling
of the sumps.. After demolition, the debris would be
disposed of off-site in a permitted landfill. Unlike
Alternative F-4, no decontamination of facilities is
included in this alternative prior to the demolition of the
facilities.
production facilities
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 1 year
ESTIMATED PERIOD OF OPERATION: approximately 6 months
ESTIMATED CAPITAL COST: $1,813,000
ESTIMATED TOTAL COST (NET PRESENT WORTH): $1,813,000
D.
Off-site (OS) Soils Alternatives Analyzed
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The fOllowinq alternatives where evaluated in detail in the
Draft FS report to address the remedial action objectives
established for the potential off-site soils contamination
potentially resultinq from past operations at the UCC Site.
Final
OS-l:
110 Action
This remedial alternative is a "strict" no action
alternative where no additional samplinq, analysis or
evaluation of the potential off-site soils contamination
would occur. This alternative is included in the evaluation
of alternatives to address the off-site (OS) soils
contamination to provide a baseline for comparison with the
other OS alternative considered in the Final Draft FS
report.
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR DESIGN AND CONSTRUCTION: 0
PERIOD OF OPERATION: 0 years
CAPITAL COST: $0
TOTAL COST (NET PRESENT WORTH): $0
years
OS-2:
Limited Action
This off-site (OS) soil remedial alternative has been
selected as the remedial alternative component of the
overall selected remedy for addressinq the off-site soils
contamination which may potentially be associated with the
site. This OS alternative is discussed in Section X, "The
Selected Remedy," of this ROD.
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IX.
SUHKARY OF THE COMPARATZVE ANALYSIS OF ALTERNATIVES
section l2l(b) (1) of CERCLA presents several factors that, at a
minimum, EPA is required to c9nsider in its assessment of
alternatives. Building upon these specific statutory mandates,
the National contingency Plan articulates nine evaluation
criteria to be used in assessing the individual remedial
alternatives.
A detailed analysis was performed on the alternatives using the
nine evaluation criteria in order to select a site remedy. The
following is a summary of the comparison of each alternative's
strength and weakness with respect to the nine evaluation
criteria. These criteria and their definitions are as follows:
Threshold criteria
The two threshold criteria described below must be met in order
for the alternatives to be eligible for selection in accordance
with the NCP.
1.
2.
Overall protection of human health and the environment
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.
compliance with Applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy
will meet all of the ARARs of other Federal and state
environmental laws and/or provide grounds for invoking
a waiver.
primarY Balancina Criteria
The following five criteria are utilized to compare and evaluate
the elements of one alternative to another that meet the .
threshold criteria.
3.
Long-term effectiveness and permanence addresses the
criteria that are utilized to assess alternatives for
the long-term effectiveness and permanence they afford,
along with the degree of certainty that they will prove
successful.
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7.
4.
R.duc~ion of ~ozici~y, .obili~y, or volume ~hrough
~r.atment addresses the degree ~o 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.
Short ~.rm effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed
during the construction and implementation period,
until cleanup goals are achieved.
5.
6.
Implementability addresses the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to
implement a particular option.
Cost includes estimated capital and Operation
Maintenance (O&M) costs, as well as present-worth
costs.
Modifvina criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received public
comment on the RIfFS and Proposed Plan.
8.
9.
state acceptance addresses the State's position and key
concerns related to the preferred alternative and other
alternatives, and the State's comments on ARARs or the
proposed use of waivers.
Community acceptance addresses the publics general
response to the alternatives described in the Proposed
Plan and RIfFS report.
A detailed tabular assessment of each alternative according to
the nine criteria (excluding criteria #2 above regarding
Compliance with ARARs) can be found in tables 31, 34, 37, 40, 43.
46, 49, 52, 55, 58, 61, 64, 67, 70, 74, 77, 80, 82, and 84 of the
Final Draft FS report. The detailed tabular assessment of each
alternative specifically with regards to criteria #2 (Compliance
with ARARs) can be found in tables 30, 33, 36, 39, 42, 45, 48,
51, 54, 57, 60, 63, 66, 69, 72, 76, 79, and 83 of the Final Draf~
FS report.
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Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of
each alternative against the nine criteria, was conducted.
The discussions below present the nine criteria and a brief
narrative summary of the alternatives, and the strengths and
weaknesses according to the detailed and comparative analysis.
A.
. Source control (SC) Alternatives
1. Overall Protection of Human Health and the Environment
Source control alternatives se-l and se-2 (no action and
limited action, respectively) do not provide adequate
protection of human health and the environment, since no
remedial action or only institutional controls are
incorporated into these two alternatives. These
alternatives would not prevent further migration of
contaminants from the source area into the groundwater.
Institutional controls alone are not sufficient to protect
human health and the environment. The se-l alternative was
included in the Final Draft FS and in this assessment
principally to serve as a basis for comparison with the
other se alternatives considered.
Alternatives Se-3, Se-5, Se-6, and Se-7 provide adequate
protection of human health and the environment by different
mechanisms. More specifically, se-3 (capping) achieves
overall protectiveness by isolating the soil contaminants
from potential human and environmental exposures and
reducing the continuing migration of soil contaminants into
the groundwater. On the other hand, alternatives se-5 (soil
excavation and low-temperature treatment), se-6 (soil
excavation and high-temperature treatment) and Se-7 (in-
situ soil treatment) provide overall protection by
permanently eliminating, through treatment, the soil
contaminants on the Site and, thereby, the principal threats
posed by the contaminated groundwater.
2. ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements lARARs)
"
Source control alternatives Se-l and se-2 will not comply
with the ARARs established for the site primarily because
these alternatives will continue to allow soil contaminants
to leach into the groundwater, thereby, perpetuating the
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exceedance of MCLGs and MCLs.
The implementation of 5C-5, 5C-6 and 5C-7 will comply
the chemical-, location-, and action-specific ARARs
determined for the Site and these particular remedial
alternatives.
with
3. Lena-Term Effectiveness and Permanence
Alternatives SC-1 and SC-2 would not provide any degree of
long-term effectiveness or permanence since the soil
contaminants, which are the QrinciQal sources of qroundwater
contamination on the Site, would remain in-place without an}'
form of treatment or containment.
Each of the remaining four source control remedial
alternatives would afford both long-term effectiveness and
permanence, but with varying degrees of certainty and
successful long-term results. 5C-3 (capping) would rely on
the adequacy and reliability of the cap and the
institutional controls in order to provide the continued
maintenance needed for long-term protection. 5C-5, SC-6 and
SC-7 provide a greater degree of certainty regarding
ultimate success than 5C-3, since these three remedial
alternatives employ treatment rather than containment of the
soil contamination at the site. Among the three treatment
alternatives, attainment of low part per million cleanup
levels is more certain with 5C-5 and SC-7 than SC-6. As
such, the risk to groundwater from residual contamination is
probably greater for 5C-6 than for 5C-5 and SC-7.
4. Reduction of Toxicitv. Mobilitv or Volume Throuah
~
Source control alternatives 5C-1, 5C-2 and 5C-3 do not
provide any reduction of the toxicity, mobility or volume of
the soil contaminants at the site since treatment is not
employed as a part of these alternatives.
In contrast, SC-5, SC-6 and SC-7 employ treatment which will
permanently and significantly reduce the toxicity, mobility
and volume of the hazardous substances in the soil at the
UCC Site. However, based upon available information, it is
less certain that SC-6, in-situ soil aeration, can achieve
cleanup levels in the low parts per million range. In
addition, the time frame for cleanup using SC-6 is more
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uncertain. Finally, without extensive excavation or
drilling, it is difficult to verify attainment of cleanup
levels throughout the soils which have been treated in-
situ. Even then, pocket of chemical residues could exist in
areas or depths which are not sampled.
5. Short-Term Effectiveness
While alternatives SC-1 and SC-2 would pose the least short-
term impacts to the surrounding community and the limited
number of workers required to implement them, these
alternatives do not provide overall protection or comply
with ARARs.
In comparison, alternatives SC-3, SC-S, SC-6 and SC-7 will
each result in some degree of short-term impacts to the
community, workers and the environment on and surrounding
the site during implementation. The magnitude of such
impacts varies primarily among those alternatives requiring
excavation (i.e. Sc-s and SC-7), which results in a greater
potential for airborne emissions from the Site, and those
alternatives which cap (SC-3) or treat in-situ (SC-6) the
soil contaminants at the site. However, the anticipated
effectiveness and reliability of mitigative measures to
reduce such impacts would offset these potential impacts.
Additionally, these short-term impacts, when assessed
together with the time period required until overall
protection of human health and the environment is achieved,
warrants further consideration of Sc-s and SC-7.
6. ImDlementabilitv
All source control alternatives are considered to be readily
implementable. It should be noted that most of these
alternatives (excluding SC-l and SC-2) require that certain
facilities (F) alternatives are implemented in concert with
these SC alternatives. More specifically, SC-3, SC-S and
SC-7 require that the existing facilities on the site be
demolished to cap or to excavate the soil contaminants which
are migrating and contaminating the groundwater at the site.
On the other hand, while demolition is not a prerequisite
for implementation of SC-6, the facilities could hinder
placement of strategic wells necessary for in-situ aeration.
Additionally, as stated above, with respect to in-situ
. treatment (SC-6) of the contaminated soils, it is difficult
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to verify attainment of cleanup levels throughout the soils
which have been treated in-situ. SC-6 would thus likely
require a more extensive effort to verify the attainment of
the low cleanup levels required.
7. Cost
As provided in the attached Table 12 and in Appendix D of
the Final Draft FS, the capital, annual operation and
maintenance and net present worth costs for all source
control alternatives vary depending on the degree of
complexity, treatment and effectiveness afforded by a
particular alternative. In particular, alternatives se-5,
SC-6 and Se-7, which all incorporate treatment but differ in
the mechanics of such treatment, have a range of present
worth costs of from approximately $1.5 to $11.1 million
(depending on the soil cleanup levels).
8. state AcceDtance
Overall, the state of Maine, Department of Environmental
Protection (MDEP) is in favor of SC-5. While recognizing
that se-6 is less expensive and would result in less short-
term impacts over Se-5, the trade-offs are that source
remediation will take longer. Additionally, attainment of
the low soil clean-up levels is less likely and verification
of attainment in the heterogeneous site soils would be more
difficult with SC-6. Therefore, the State of Maine believes
that SC-5 will make attainment of groundwater clean-up
levels more likely and reduce the time, and thus cost, of
the management of migration portion of the remedy.
9. Commun~cceDtance
In general, the comments received during the public comment
period (both orally and in writing) and the discussions held
at the public informational/hearings suggested that the
community favored (with reservations) the source control
remedy identified in the Proposed Plan, but did not offer
any other recommendations with regards to the other source
control alternatives. Comments received during the public
comment period are attached in document entitled
"Responsiveness Summary" (Appendix A).
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B.
Kanaq..ent of Kiqration (KH) Alternatives
1. Overall Protection of Human Health and the Environment
Management of Migration alternatives MM-1 and MM-2 (no
action and limited action, respectively) do not provide
adequate protection of human health and the environment
since no remedial action or only institutional controls are
incorporated into these two alternatives. These
alternatives do not provide for cleanup of contaminated
groundwater to protect public health and wildlife, and does
not protect off-site groundwater and surface waters.
Institutional controls alone are not sufficient to protect
human health and the environment. The MM-1 alternative was
included in the Final Draft FS and in this assessment
principally to serve as a basis for comparison with the
other MM alternatives considered.
Since the remaining MM alternatives incorporate similar, yet
different variations of a groundwater extraction and
treatment system, all of these alternatives would eventually
provide for the overall protection of human health and the
environment. At a minimum, these remaining four MM
alternatives (MM-3 through MM-6) would provide for the
isolation (control) of the groundwater contamination at the
Site.
2. ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements (ARARs)
Management of Migration alternatives MM-1 and MM-2 will not
comply with the ARARs established for the Site, since
concentrations of contaminants in groundwater will continue
to exceed MCLs and non-zero MCLGs if no remedial action is
undertaken.
Based on the information provided in the Final Draft RI and
FS, alternatives MM-3 through MM-6 would comply with MCLs
and non-zero MCLGs, which are ARARs for the groundwater
cleanup. Compliance with ARARs is made more certain
through: (i) the use of vacuum-enhanced extraction in
conjunction with traditional groundwater pumping methods
(MM-4 and MM-6) , supplemented by (ii) implementation of a SC
alternative which employs treatment to reduce the toxicity,
mobility and volume of contaminants (SC-S, SC-6 and SC-7).
Vacuum-enhanced extraction also allows for the removal of
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soil contaminants that exist in areas which may not
otherwise undergo excavation, and thus ARARs would likely be
achieved more rapidly.
Alternatives MM-3 and MM-4 involve discharge of treated
groundwater to Quiggle Brook. Both alternatives employ the
UV/oxidation treatment method, which will attain water
quality standards, including Federal Ambient Water Quality
Criteria. Alternatives MM-S and MM-6, which involve
reinjection of treated groundwater into the aquifer, comply
with federal and state ARARs, which require attainment of
drinking water standards in the reinjected groundwater.
3. Lonq-Term Effectiveness and Permanence
Alternatives MM-l and MM-2 would not provide any degree of
long-term effectiveness or permanence since the groundwater
contamination on the Site would continue without any form of
treatment or containment. The potential for institutional
controls to reliably restrict the exposure to the principal
threat (risk) at and surrounding the Site (i.e. the
groundwater contamination) over the long-term would require
careful coordination with the community, local and state
officials, and EPA.
Since alternatives MM-3 through MM-6 utilize an identical
method for treating the extracted groundwater, the long-
term effectiveness and permanence afforded by these
alternatives are relatively similar with respect to such
treatment. However, alternatives MM-4 and MM-6, which
incorporate vacuum-enhanced extraction and conventional
groundwater pumping, would provide a greater degree of long-
term certainty relative to overall protectiveness and
compliance with ARARs. This is principally due to the
additional removal of contaminants from soils through the
use of vacuum-enhanced extraction, which would not be
achieved through the use of conventional groundwater pumping
alone as provided in alternatives MM-J and MM-S.
4. Reduction of Toxicitv. Mobilitv or Volume Throuqh
Treatment
Management of migration alternatives MM-l and MM-2 do not
provide any reduction of the toxicity, mobility or volume of
the groundwater contamination which exists at the site since.
treatment is not employed as a part of these alternatives.
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In contrast, MM-4 and MM-6, which employ treatment "of the
principal threat posed by the site (i.e the groundwater
contamination), will permanently and significantly reduce
the toxicity, mobility and volume of the hazardous
substances at the UCC site. MM-3 and MM-S also employ
treatment that will reduce toxicity and volume, but
reinjection could cause groundwater mounding in the till
zone, which may force contaminants deeper into the bedrock
or into previously un~ontaminated areas.
5. Short-Term Effectiveness
While MM-l and MM-2 pose the least impacts to the
surrounding community and those limited workers required to
implement these alternatives over the short-term, these
alternatives do not provide overall protection or comply
with ARARs, as discussed herein, and they are thus
eliminated from further consideration.
Alternatives MM-3 through MM-6 would each involve similar
degrees of short-term risks and potential community and
worker impacts during implementation of the groundwater
extraction wells and treatment system. In addition,
mitigative measures (such as continuous monitoring of them
systems) would assure that these impacts would be minimal.
However, based on the information provided in the Final
Draft FS, EPA believes that the time to achieve overall
protection and compliance with ARARs is more certain with
the implementation of alternatives MM-4 and MM-6, which
incorporate vacuum extraction of previously saturated soils
within the area of the groundwater extraction well proper.
EPA is also aware that the fractured bedrock conditions at
the site may pose inherent difficulties that may affect
achieving the groundwater cleanup levels within the time
frames estimated in the Final Draft FS. Therefore, these
estimated time frames may change upon completion of a
thorough review of the performance of the groundwater
extraction and treatment system throughout design,
construction, and operation and maintenance.
For all the MM alternatives involving groundwater
extraction, the public has raised concerns that the capaciti"
of nearby drinking water wells will be reduced. However,
these potential impacts are overshadowed by the risk that
reinjection of treated groundwater (under MM-S and MM-6)
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could result in mounding of groundwater and possible
contamination of previously unaffected areas surrounding the
Site.
6. Ymolementabilitv
All MM alternatives are considered to be administratively
and technically feasible, with respect to all construction,
operation, and availability of services required. However,
technical concerns with alternatives MM-5 and MM-6 which
incorporate reinjection of treated water versus direct
discharge into Quiggle Brook have been raised. These
technical difficulties involve the spacial limitations for
installing these reinjection wells and the long-term
maintenance problems which will likely occur due to clogging
of the wells themselves.
7. Cost
As provided in the attached Table 12 and in Appendix D of
the Final Draft FS, the capital, annual operation and
maintenance and net present worth costs for all management
of migration alternatives (excluding MM-1 and MM-2) vary
slightly, primarily due to the time frame estimated for
achieving remediation of the groundwater contamination. In
particular, alternatives MM-3 through MM-6, which all
incorporate groundwater extraction but differ in the
mechanics of such extraction and reinjection/discharge of
the treated water, have a range of present worth costs of
from approximately $4.2 to $6.8 million (depending on the
estimated remediation time frame, i.e. 12 years to 100
years, respectively).
8. state Acceotance
The state of Maine, Department of Environmental Protection
(MDEP) is in favor of MM-4 for the management of migration
alternative. This alternative, the state believes, is the
alternative that is most likely to restore the aquifer to
drinking water quality.
9. Community Acceotance
In general, the comments received during the public comment
period (both orally and in writing) and the discussions held
at the public informational/hearings suggested that the
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community favored (with reservations) the management of
migration remedy identified in the Proposed Plan, but did
not offer any other comments/recommendations or otherwise
with regards to the other MM alternatives. Comments
received during the public comment period are attached in
document entitled "Responsiveness summary" (Appendix A) .
Facilities (F) Management Alternatives
C.
1. Overall Protection of Human Health and the Environment
Facilities management alternatives, F-l and F-2 (no action
and limited action, respectively) do not provide adequate
protection of human health and the environment since no
remedial action or only institutional controls are
incorporated into these two alternatives. specifically,
F-l and F-2 would not reduce ingestion or absorption of the
dioxin and other contaminants in the incinerator equipment,
or prevent inhalation of asbestos within the still Building.
In addition, F-l and F-2, which do not include removal of
the facilities, would prevent the effective treatment of
contaminated soils through implementation of SC-S or SC-7.
The F-l alternative was included in the Final Draft FS and
in this assessment principally to serve as a basis for
comparison with the other facilities alternatives
considered, and are thus eliminated from further
consideration.
since the remaining facilities alternatives incorporate some
degree of either decontamination, and/or demolition and
disposal, all of these alternatives would eventually provide
for the overall protection of human health and the
environment by eliminating, reducing, or controlling (over
the long-term) potential exposures to the hazardous
materials on and/or within these facilities.
e evant and
Facilities alternatives F-l and F-2 would not allow for
compliance with the ARARs established for the site,
particularly, RCRA closure and post closure requirements and
federal and state asbestos requirements. Furthermore, these
two alternatives would significantly prohibit the effective
implementation of a source control and/or management of
migration remedy which would be required to eliminate the
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continuing source of and the ~oundwater exceedances of
ARARs established for the Site.
The facilities alternatives F-3 and F-4 would comply with
ARARs through careful planning and control of the
decontamination component of these alternatives. In
addition, the requirements for disposal of RCRA hazardous
wastes found in these facilities would comply with the RCRA
ARARs established for the site. Alternative F-S would not
result in ARARs compliance since the RCRA hazardous waste
would not be treated prior to off-site disposal. (For this
reason, this alternative should have been eliminated from
the detailed analysis.)
3. Lena-Term Effectiveness and Permanence
Alternative F-l would not provide any degree of long-term
effectiveness or permanence since the hazardous materials
within the facilities would remain, and the risks estimated
from exposures too these materials would not be reduced.
Alternative F-2 would provide a slightly greater degree of
long-term effectiveness, but the potential for institutional
controls to restrict reliably the exposure to these
facilities would require careful coordination with the
community, local and state officials, and EPA.
Alternatives F-3 through F-S would provide a similar degree
of long-term effectiveness and permanence since no residual
waste which would pose a risk to the public health, welfare
or the environment would remain within the facilities.
However, alternative F-3 would have a direct influence on
the available source control remedy which could be
undertaken at the Site, since the facilities would remain
following decontamination. on the other hand, alternatives
F-4 and F-S would remove all facilities following
decontamination and removal of the hazardous wastes
contained within these facilities, thereby facilitating the
excavation of contaminated soils, which will result in a
overall remedy that is more effective in the long term.
4. Reduction of Toxicitv. Mobilitv or Volume Throuah
Treatment
Alternatives F-l and F-2 do not provide any reduction of the
toxicity, mobility or volume of the contamination which
exists within the facilities since no treatment would be
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employed.
Alternatives F-3 through.F-4, which employ treatment of the
hazardous materials within the facilities prior to disposal
and decontamination of these facilities, would permanently
and significantly reduce the toxicity, mobility and volume
of the hazardous substances at the UCC site. Alternative F- -
5 will not reduce the toxicity, mobility or volume through
treatment of the contamination contained in the facilities.
5. Short-Term Effectiveness
Alternatives F-1 and F-2 pose the least short-term impacts
to the surrounding community and those limited workers
required to implement these alternatives.
The short-term impacts of the remaining facilities
alternatives principally result from the additional truck
traffic which would be required to remove the hazardous
wastes within the facilities off the site. Additionally,
alternatives F-4 and F-5 would result in further impacts to
workers, the community and the environment due to the
demolition activities that would occur. However, the
protective measures employed with these alternatives and the
air monitoring that would occur should ensure that these
impacts are minimized and/or mitigated. Furthermore, the
impacts from the demolition activities described in F-5
would likely be greater than those resulting from F-4 since
no decontamination would occur on the facilities prior to
demolition.
6. ImDlementabilitv
All facilities alternatives are considered to be
administratively and technically feasible, with respect to
all construction, operation, and availability of services
required. However, as previously noted herein, the
implementation of those facilities alternatives which do not
involve demolition of the facilities (i.e. F-1 through F-)}
prevent the selection of an effective source control remedy
involving excavation.
7. Cost
As provided in the attached Table 12 and in Appendix D of
the Final Draft FS, the capital, annual operation and
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maintenance and net present worth costs for all the
Facilities management alternatives (excluding F-1 and F-2)
vary by less than one-order of magnitude. Specifically,
these present worth costs range from approximately $0.2
million for alternative F-3 to $1.8 million for alternative
F-S.
8. state AcceDtance
The State of Maine, Department of Environmental Protection
(MDEP) concurs with the selection of F-4, as part of a
comprehensive multi-phased approach to contamination at the
Site.
9. Community Acceptance
In general, the comments received during the public comment
period (both orally and in writing) and the discussions held
at the public informational/hearings suggested that the
community favored (with reservations) the facilities
management remedy identified in the Proposed Plan, but did
not offer any other recommendations or otherwise with
regards to the other facilities alternatives. Comments
received during the .public comment period are attached in
document entitled "Responsiveness Summary" (Appendix A).
Off-Si~e Soils (OS) Al~erDa~ives
D.
1. Overall Protection of Human Health and the Environment
Neither of the two 05 alternatives, 05-1 and 05-2 (no action
and limited action, respectively) involve active remedial
measures such as capping or excavation and treatment.
However, 05-2 provides a greater degree of overall
protection, because it will be used to further evaluate and
verify the previous results which indicate that there is not
a significant threat associated with airborne contamination
from past operations of the UCC incinerator.
2. ComDliance with ADDlicable or Relevant and Ap~roDriate
Reauirements CARARs)
Since these two alternatives do not result in significant
remedial actions, few ARARs exist from which to determine
compliance. However, under 05-2, compliance with ARARs will
occur for the protection of workers performing the
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additional sampling and analysis required by this
alternative.
3. Lana-Term Effectiveness and Permanence
OS-2 would provide additional long-term permanence in
comparison to OS-l, if potential remedial actions were
required based on the results obtained through
implementation of this alternative.
4. Reduction of Toxicitv. Mobilitv or Volume Throuah
Treatment
Alternatives OS-l and OS-2 do not provide any reduction of
the toxicity, mobility or volume of hazardous substances
since no treatment would be employed.
5. Short-Term Effectiveness
Alternatives F-1 and F-2 pose no short-term impacts to the
surrounding community and environment, and those limited
workers required to implement these alternatives.
6. Imclementabilitv
All OS alternatives are considered to be administratively
and technically feasible, with respect to the availability
of services required.
7. Cost
As provided in the attached Table 12 and in Appendix D of
the Final Draft FS, the capital, annual operation and
maintenance and net present worth costs for these two OS
alternatives range from approximately $0 to $0.3 million.
8. state AcceDtance
The State of Maine, Department of Environmental Protection
(MDEP) believes strongly that OS-2 is necessary to protect
public health or the environment and that it is an important
component of a comprehensive remedy for this site.
9. Community Accectance
In general, the comments received during the public comment
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ONION CHEMICAL COMPANY, ZNC. RECORD OP DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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period (both orally and in writing) and the discussions held
at the public informational/hearings suggested that the
community favored (with reservations) the off-site soils
remedy identified in the Proposed Plan in comparison to the
No-Action alternative. Comments received during the public
comment period are attached in document entitled
"Responsiveness Summary" (Appendix A).
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ONION CHEMICAL COMPANY, XNC. RECORD OF DECISION sUKHARY
SOUTH HOPE, MAINE December 27, 1990
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x.
'1'HE 8BLBC'1'BD REDDY
The selected remedial action for the UCC site is a comprehensive,
multi-component approach for overall remediation of the contaminated
on-site soils, groundwater and facilities, and a further evaluation of
off-site soils surrounding the site area. This comprehensive remedial
approach is described in detail herein, following the discussions
immediately below regarding cleanup levels. The cleanup levels
discussed herein have been established to guide the remedial design
and for use in measuring the success of the selected remedial action
for the UCC site.
A.
CleanU'D Levels
Cleanup levels have been established for those contaminants of
concern identified in the Baseline Risk Assessment, and those
additional contaminants that were found to exceed site-specific
ARARs or other criteria which were to-be-considered (IITBC")3 at
the site.
Periodic assessments of the protection to human health and the
environment afforded by remedial actions selected for the UCC
site will be made as the remedy is being implemented and at the
completion of the remedial action. If it is determined that the
completed remedial action is not or will not be protective of
human health and the environment, further action shall be
required. The determination of the protectiveness afforded by
the remedial action will consider, at a minimum, the cancer risk
range of 10.' to 10.6, as provided in the National contingency
Plan (NCP).
1.
Groundwater CleanuD Levels
The aquifers underlying and surrounding the UCC site are
current sources of drinking water to the local community and
have been classified according to EPA's Ground-Water
protection strategy as Class IIA and the state's groundwater
classification scheme as GW-A.
3 Under the NCP, standards which, although not ARARs, are to-
be-cons idered ("TBC") may be used in determining what is protect i ve
at a site.
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UNION CHEMICAL COMPANY, %NC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
[[[
Accordingly, cleanup levels have been set based on Maximum
contaminant Levels [MCLs] and non-zero Maximum Contaminant
Level Goals [MCLGs], if available. More specifically,
cleanup levels for known and probable carcinogenic compounds
(Classes A & B) have been set at the appropriate MCL, if
available.' Cleanup levels for Class C compounds (possible
carcinogens), Class D compounds (not classified), and Class
E compounds (no evidence of carcinogenicity) have been set
at the MCLG, which is typically set at levels greater than
zero and equal to the MCL.
In the absence of an established MCLG or MCL, other suitable
criteria (TBCs) were considered for the UCC site. In these
instances, EPA used proposed rules under the Safe Drinking
Water Act -- proposed MCLGs and proposed MCLs -- or State of
Maine Maximum Exposure Guidelines (MEGs) to establish the
cleanup level for both carcinogenic and non-carcinogenic
compounds.
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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Table A.l below summarizes the groundwater cleanup levels
established for those carcinogenic contaminants identified
at the UCC Site, with the exception of Arsenic. The cleanup
level for Arsenic, which was identified as a contaminant of
concern, will be set at the MCL of 50 ppb. Arsenic was not
included in Table A.l since the maximum concentration
detected during the RI did not exceed the MCL. However,
since Arsenic was a contaminant of concern, limited
monitoring for arsenic will be included in the groundwater
monitoring program to be undertaken during the remedial
action. This will be conducted to verify that the arsenic
MCL is not being exceeded.
'.rABLE A.1
GROUNDWATER CLEANUP LEVELS FOR '.rHE CARCINOGENIC
COMPOUNDS IDENTIFIED IN THE GROUNDWATER AT THE UCC SITE
---------------------------------------------------------------------
carcinogenic
contaminants
Cleanup
Level
(ppb)
Basis for
Cleanup
Level
Level of
Risk
---------------------------------------------------------------------
Bis(2-etbylbexyl)phthalate
Carbon Tetrachloride
Chloroform (as Total T~)
1,1-dichloroethane
1,2-dichloroethan8
1,1~dicbloro8thene
Methylene Cbloride
Tetrachloroethene
Trichloroethene
vinyl Chloride
4
5
100
5
5
7
5
5
5
2
PMCL'
MCL2
HCL4
KEG
HCL2/KEG
HCLG-MCL2/KEG
PMCL'
PMCL5
HCL~KEG
MCL
2X10 -6
2xlO -5
2xlO-5
1xlO -5
lX10.5
1X10.I,
1X10.6
7xlO.6
2xlO.6
lxl 0 .1,
--------------------------------------------------------------------
,
2
3
I,
5
- 55 Fed. Reg. 30370, 371.
- 52 Fed. Reg. 25690, 691.
- THM, represents the word
- 40 CFR 141, S 141.12.
- 54 Fed. Reg. 22062, 064.
SUK 3xlO-I,
(with Vinyl Chloride and
'. '-dichloroethene included in 5\.11\)
SUK 9X10-5
(without Vinyl Chloride and '.'-
dichloroethene included in SI.IT\)
Trihalomethanes.
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUHKARY
SOUTH HOPE, KAINE December 27, 1990
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Table A.2 below summarizes the qroundwater cleanup levels
established for those non-carcinogenic contaminants (as well
as those carcinogenic contaminants which also exhibit non-
carcinogenic effects) identified at the UCC Site, with the
exception of Arsenic and Lead. The cleanup levels for
Arsenic and lead, which were both identified as contaminants
of concern, will be set at their respective MCLs of 50 ppb.
Arsenic and lead were not included in Table A.2 since their
maximum concentrations detected during the RI did not exceed
their respective MCLs. However, limited monitoring for
arsenic and lead will be included in the groundwater
monitoring program to be undertaken during the remedial
action. This will be conducted to verify that the arsenic
and lead MCLs are not being exceeded.
TABLE A.2
GROUNDWATER CLEANUP LEVELS FOR THE NON-CARCINOGENIC
COMPOUNDS IDENTIFIED IN THE GROUNDWATER AT THE UCC SITE
---------------------------------------------------------------------
Non-Carcinogenic
contaminants
Cleanup
Level
(ppb)
Basis for
Cleanup
Level
Target
Endpoint
of Toxicity
Hazard
Quotient
---------------------------------------------------------------------
Bis(2-ethylhexyl)phthalate
Carbon Tetrachloride
Chloroform
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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4 - 54 Fed. Reg. 22062, 064.
The Hazard Index (HI) for those compounds included in Table
A.2, which have been identified as having similar toxicity
endpoints, is as follows:
EndDoint
HI
Liver
Blood
Liver & Kidney
eNS
Fetotoxicity
Hyperactivity
& Decreased Body
weight
.10
.36
.20
.20
.10
.15
The groundwater cleanup levels discussed herein and as
presented in Tables A.1 and A.2 must be met at the
completion of the remedial action at the compliance points.
These compliance points will be: (i) throughout the
underlying shallow and bedrock aquifers on the uee site, and
(ii) in areas of contaminated groundwater immediately off
the site. Based on the currently available information
obtained during the Remedial Investigation, EPA and the
state of Maine DEP believe that these cleanup levels will be
achieved within 15 to 30 years of full-scale implementation
of the management of migration component of the selected
remedy, as estimated in the Final Draft FS. However, if it
becomes apparent, during full-scale implementation and/or
operation of the groundwater extraction system, that the
groundwater contaminant levels at the site have ceased to
decline and are remaining constant at concentrations higher
than the cleanup levels specified above, the groundwater
extraction and treatment system, its performance standards,
and/or the management of migration component of the selected
remedy may require reevaluation.
These cleanup levels are consistent with the ARARs
determined for the groundwater at the uee site and will, at
the completion of remedial action, attain EPA's risk
management goal for remedial actions (e.g. carcinogenic risk
range of between 10.4 and 10.6).
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, MAINE December 27, 1990
.********..**..*.*.******.***.*...*..***.....***..*.*.***.************
2.
80i1 C1e.DUD Levels
Cleanup levels in
human health from
The establishment
critical in order
contaminants into
Site.
soils were established in order to protect
ingestion of contaminated groundwater.
of specific soil cleanup levels is
to prevent further leaching of these soil
the groundwater aquifers below the UCC
The "Decision Tree Process," a percolation-transport model
(as described in detail in Appendix B of the Final Draft FS)
was used to estimate the residual levels of contaminants in
soil (following excavation and treatment) that are not
expected to impair future groundwater quality. Federal MCLs
and non-zero MCLGs, the ARARs used to establish groundwater
cleanup levels for the UCC Site, were used as the levels
from which to extrapolate back to establish the specific
soil cleanup levels required, based on this specific model.
Where no MCL or MCLG existed for a particular contaminant,
proposed MCLGs and proposed MCLs were also considered in
this process.
Table B.l summarizes the cleanup levels established for the
four most prevalent soil contaminants identified at the uce
Site. These soil cleanup levels were selected for only
these four soil contaminants based upon: (i) their wide
lateral distribution throughout the site; (ii) their high
concentrations relative to their respective MCLs and non-
zero MCLGs: (iii) the fact that these four contaminants are
co-located with other soil contaminants within the principal
source area on the Site; and (iv) their range of organic
carbon partitioning coefficients (K~).
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
**********************************************************************
,.ABLE B. 1
SOIL CLEANUP LEVELS ESTABLISHED FOR 'rIlE
PROTECTION OF HUMAN HEALTH AND THE UNDERLYING AQUIFERS
OCC SITE BASED ON THE DECISION .TREE PROCESS
PERCOLATION-TRANSPORT KODEL
---------------------------------------------------------------------
Soil
contaminants
soil
Cleanup
Level
(ppm)
AT THE
Basis for
Kodel
Input
Target
Bndpoint
of Toxicity
Residual
Groundwater
Risk and/or
Hazard Quotient
carcinoaenic contaminants
---------------------------------------------------------------------
1,1-dicbloroetbene
Trichloroetbene
Tetrachloroethene
0.1
0.1
0.1
Non-carcinogenic contaminants
1,1-dichloroetbene
Tetrachloroethene
Total xylenes
0.1
0.1
100.0
MCLG-MCL
MCL
PMCL
1X10.4
2xl0 -6
7xl0 -6
----
MCLG-MCL
PMCL
PMCLG-PMCL
Liver
Liver
Hyperactivity,
Decreased Body
weigbt
.02
.01
.15
---------------------------------------------------------------------
and
SUM
1X10.4
(for carcinogenic contaminants)
Total HI
Liver
.03
Hyperactivity,
Decreased
Body
weight
.15
(for non-carcinogenic contaminants)
These soil cleanup levels are consistent with the ARARs
established for the groundwater at the ucc site. These soil
cleanup levels will also allow for the attainment of EPA's
risk management goal for remedial actions (i.e. the
groundwater carcinogenic risk level will be between 10" and
10.6 and the Hazard Index will be less than 1 at the
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UNION CHEMICAL COXPANY, INC. RECORD OP DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
.*....***..**..**.*****.***********.*.......**.....**.....*......*...*
completion of the remedial action). ~hese soil cleanup
levels will be achieved throughout the Site, and will be
confirmed at the completion of the remedial action to be
undertaken at the UCC site.
B.
DescriDtion of Remedial ComDonents
The selected remedy for the UCC Site includes a combination of
remedial alternatives SC-5, MM-4, F-4 and OS-2, as noted
previously in section VIII. The major components of this
comprehensive, multi-component remedy include:
1.
Soil Excavation and On-site Low-Temperature Soil
Aeration Treatment (SC-5);
2.
Vacuum-Enhanced Groundwater Extraction, On-Site
Groundwater Treatment, and On-site D"ischarge of Treated
Groundwater into Quiggle Brook (MM-4); .
3.
Facilities Decontamination and Demolition, and Off-
Site Disposal of Debris (F-4); and
Limited Action for Off-site Soils (OS-2).
4.
The following discussions present in further detail the events
which will likely occur during the implementation of each of the
above-described major remedial components of the selected remedy.
SC-5:
Soil Excavation and On-Site Low-Temperature Soil Aeration
Treatment
The selected remedy for the contaminated on-site soils at
the UCC site involves excavation and on-site treatment to
achieve the soil cleanup levels stated above.
Excavation and Materials Handlina of contaminated On-Site
Soils
This source control remedial alternative will require
removing the existing facilities at the Site (as discussed
in detail later under the selected Facilities remedial
alternativej in order to excavate the on-site contaminated
soils identified for cleanup.
Once these facilities are removed from the Site,
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UNION CHEMICAL COMPANY, %NC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
.**************..*............*...*.......*.*..***.***..**.**********.
contaminated soils within the unsaturated zone, as well as
those within the saturated zone in selected locations, which
exceed the soil cleanup levels will be excavated for
subsequent treatment on the site. The contaminated,
unsaturated5 s011s requiring excavation and treatment are
primarily located within the enclosed-fenced portion of the
Site. The vertical, lower excavation limit for these
contaminated, unsaturated soils will be determined by EPA
based on either: (a) 0.5 feet below the groundwater table
encountered at the time of excavation: (b) 11.5 feet below
the ground surface (which was based upon the assumptions
used to establish the site-specific soil cleanup levels
previously detailed herein): or (c) deeper than described in
(a) and (b) above in localized areas if appropriate and if
technically practicable.
The contaminated, saturated soils that exceed the soil
cleanup levels and that require excavation and treatment are
primarily located in the area between the old leach field
and the interceptor trench (as depicted in Figure 38 of the
Final Draft FS). The vertical, lower excavation limit for
these contaminated, saturated soils will be, at a minimum,
6.0 feet below the groundwater table encountered at the time
of excavation.
contaminated, saturated soils that are outside the areas
primarily described above and that exceed the soil cleanup
levels will not be excavated, but will be removed for
treatment using the vacuum-enhanced extraction wells
discussed under the management of migration selected
remedial alternative below. Supplemental soil sampling and
analysis will be conducted during the remedial design and
remedial action to further confirm the lateral and vertical
limits of excavation in both the unsaturated and saturated
soils.
Initially, the excavation will likely proceed in those areas
of the Site where the on-site low-temperature thermal
treatment unit will be setup for full-scale operation.
5 Excavation of unsaturated soils will likely involve the
excavation of some saturated soils below the water table within the
areas of this excavation. The extent of excavation of contaminated
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UNION CHEMICAL COMPANY, INC. RECORD OP DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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Clean fill will be brought onto the Site, if necessary, to
backfill this excavated area and to provide an adequate base
for the thermal treatment unit. Prior to setting up the
thermal treatment unit on the Site, the entire area where
this unit will be located will also be covered with a low
permeability, synthetic liner to eliminate the possibility
of contaminating the underlying uncontaminated soil or clean
fill which may have been brought onto the Site.
To ascertain that those areas which undergo excavation
achieve the soil cleanup levels specified in this ROD,
confirmatory sampling will occur within and along the
perimeters of all excavated areas. This sampling will be
conducted to determine, statistically whether a particular
excavated area has achieved the soil cleanup levels or
requires further excavation. An on-site, mobile and/or an
off-site, certified laboratory will provide confirmatory
analyses on soil samples obtained from throughout these
excavated areas.
Throughout all phases of the excavation, materials handling
(including screening, crushing, and transfer operations)
and/or any stockpiling activities conducted on site soils
(or concrete), every effort will be made to minimize or
mitigate any airborne release of volatile organic and
particulate emissions (and excessive noise) from the site in
order to protect the public health, welfare and the
environment. These efforts will include the use of one or
more of the following techniques in order to minimize or
mitigate the release of such emissions: controlled
excavation techniques, dust suppressants (e.g. water or
foaming agents), stock and/or waste pile coverings, partial
or full enclosures on each or all of the on-site work areas,
and air pollution control devices to treat air emissions
collected by an enclosure. These efforts are critical since
significant on-site contamination includes compounds which
could threaten public health, and volatile aromatic
compounds such as toluene, xylene, and ethylbenzene which
may result in odors. All of these potential air emission
releases must be adequately monitored and controlled on the
site in order to protect public health, welfare and the
environment located off the site.
Treatment of contaminated. Excavated Soils
All specified, excavated soils exceeding the soil cleanup
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UNION CHEMICAL COMPANY, %NC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAlltE Decem})er 27, 1990
********...*..*........*.....*...**.....*..*.......**..*...*.....*****
levels will be treated using a low-temperature soil aeration
or equivalent thermal desorption (aeration) treatment
process located on the site. This process will treat the
excavated, contaminated soils by processing them through a
low-temperature (estimated at 300 to 850 degrees Fahrenheit)
thermal treatment unit in order to meet the soil cleanup
levels and treatment standards described herein.
Prior to full-scale treatment of the contaminated soils,
pilot-scale tests will be conducted on the site using site-
specific soils. The primary objectives of these tests will
be, at a minimum, to (i) confirm that the full-range of
contaminants and their respective concentrations in soils
will routinely attain the soil cleanup levels and treatment
standards specified for this site, (ii) determine the
optimum operational settings for or modifications required
to the treatment unit prior to full-scale treatment on the
Site, (iii) establish the most feasible location for
placement of the thermal treatment unit on the site while
minimizing the need to clear excessive trees and brush on
the property, (iv) provide a comprehensive materials balance
estimate for all waste streams resulting from this process
and the media-specific criteria to used for determining the
ultimate disposition for all waste streams from the process,
(v) assess the effectiveness of the air pollution control
equipment (to be used with the thermal treatment process) on
the volatilized contaminants generated by this process, and
(vi) collect various air monitoring data in order to provide
information regarding the appropriate techniques and extent
of air pollution controls and monitoring required during
full-scale operations. Additionally, prior to full-scale
treatment and during the excavation activities stated
previously, the contaminated, excavated soils will be
screened to remove all cobbles and/or boulders encountered
during excavation which cannot be successfully treated
without prior crushing. Those cobbles/boulders which are
too large for treatment will be crushed and then fed into
the low-temperature soil aeration or equivalent thermal
desorption (aeration) treatment unit.
The full-scale thermal treatment process will occur within a
closed system, capturing any fugitive dust and/or volatile
organics that are generated by the thermal treatment
process. The organic contaminants that are driven-off
(volatilized) from the contaminated soils as vapors will be
further treated using vapor-phase carbon adsorption
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UNION CHEMICAL COXPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
*.*..*****.****...******..*****************************.*.*******.*...
materials or an equivalent treatment method in order to: (i)
satisfy the site-specific discharge and air emission
requirements or other criteria to-be-considered, and (ii)
protect public health, welfare and the environment at the
property boundary. If carbon adsorption materials are
utilized, these materials will undergo thermal regeneration
or incineration at an approved off-site facility.
Furthermore, to ensure compliance with all Federal and State
air quality standards (including, but not limited to,
particulate and air toxic requirements/criteria), any
fugitive dust (particulate matter) generated by the thermal
treatment process will be collected by additional air
pollution control equipment. Particulate matter (including
fines) that are collected by these air pollution control
equipment will be sampled and analyzed and, if necessary,
treated to met the soil cleanup levels and treatment
standards established for the Site, by the thermal aeration
treatment unit prior to returning these materials onto the
site. These materials must be mixed with previously treated
soils prior to being returned to the excavation.
During and following full-scale treatment of the
contaminated soils on the Site, the treated soils will be
frequently and representatively sampled and analyzed to
ensure that both the soil cleanup levels stated in this ROD
and the treatment standards established under RCRA's Land
Disposal Restrictions (LDRs) at 40 CFR 268, Subpart D, ~
268.40, are being achieved. Treated soils that achieve
these site-specific soil cleanup levels and treatment
standards will be placed in the original, excavated area on
the site. Treated soils that do not achieve these site-
specific levels or treatment standards will be further
treated by this process, to the maximum extent practicable.
As stated in the Final Draft F5, EPA believes that the LDR
treatment standards can be attained using this source
control remedial technology. However, any soils that do not
achieve these site-specific cleanup requirements will either
undergo further treatment on-site using a different
treatment technology approved by EPA, or a Treatability
Variance under RCRA may be required to comply with the RCRA
LDRs.
Air monitoring will be continuously performed during all
excavation, materials handling and soil treatment
activities. This comprehensive air monitoring program will
include, at a minimum, the acquisition of both volatile
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ONION CHEMICAL COMPANY, INC. BOORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
**.*.....*..*.**************.**.******..**********...*******...*....**
organic and particulate samples from areas where excavation,
materials handling and treatment are occurring, as well as
along the perimeter and at specific off-site locations. The
specific contaminants, sampling methodologies, and
analytical requirements will be determined during the
remedial design by conducting, at a minimum, air modeling of
these potential emission sources. Regular monitoring for
airborne volatile organic emissions will be performed both
on a real-time and laboratory, chemical-specific
confirmatory basis. This air monitoring information will be
used, at a minimum, to determine: (1) whether operations
will continue as scheduled: (2) whether contingency actions
(such as slowing operations) are required on the site: (3)
whether operations should be shutdown partially or
completely in order to make modifications to the operations:
or (4) whether contingency actions (such as notification)
are required for the surrounding community.
site Restoration
Surface water controls will be implemented around the site
to direct surface water runoff away from the site both
during and following remedial actions performed on the Site.
Additionally, as noted above, treated soils that achieve the
site-specific cleanup levels and treatment standards will be
used as backfill within the excavated areas on the site
and/or used to recontour the entire area to promote
drainage. Prior to placement of these treated soils back on
the site, all soils will be mixed with nutrients and/or
native soils to promote the re-establishment (comparable to
the surrounding area) of these soils for future habitat
growth. Finally, all disturbed areas of the site will be
regraded and revegetated to prevent further surface water
erosion from occurring on the site, and to establish
vegetative growth which is comparable to the surrounding
wooded/grassy areas. These steps will occur after all
equipment has been decontaminated and removed from the site
as part of this source control component of the overall
remedial action for the site.
vacuum-Enhanced Groundwater Extraction, On-site Treatment,
and Discharge to Quiggle Brook
KK-4:
To address the significant groundwater contamination
existing throughout the shallow till and weathered, shallo~
bedrock aquifers underlying the site, a vacuum-enhanced
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ONION CHEKICAL COMPANY, ZNC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
[[[
qroundwater extraction and treatment system configuration
will be employed at the uee Site.
Establishment of Institutional Controls Durina Remedial
Desian/Remedial Action
Institutional controls will be required for the uee property
and surrounding properties to the Site to protect human
health and the environment, and to supplement the remedial
actions that will be designed, implemented and operated
according to this ROD.
Institutional controls required on the uee property will
include, at a minimum, restricting access and use (through
deed restrictions, the installation of additional lighting,
fences and warning signs, and/or other mechanisms) during
the remedial action, and restricting the -use (through deed
restrictions and/or other mechanisms) of the on-site
contaminated groundwater for drinking water purposes.
In addition, institutional controls will be required on
surrounding properties to the uee Site. These institutional
controls may include, at a minimum: (i) restrictions on the
use of existing bedrock drinking water wells on properties
located in close proximity to the Site whose pumping is
shown to accelerate or alter the movement of contaminated
groundwater from beneath the Site; this includes, at a
minimum, residential well # 20 in order to prevent the
further migration of groundwater contamination existing off
the Site; (ii) restrictions on the installation and use of
new bedrock drinking water wells on properties located in
close proximity to the Site which could influence the
migration of the existing groundwater contamination off the
Site; (iii) deed restrictions; (iv) advisory controls, such
as well-use advisories and deed notices; and (v) other
mechanisms which may be determined necessary to reduce the
potential for exposures by humans to the contaminants on the
Site (both in the soils and groundwater) during and until
the entire remediation effort is completed.
Installation of Groundwater Extraction and Monitorinq Wells
This management of migration alternative will require the
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ONION CHEMICAL COMPANY, %NC. RECORD OF DECISION sUMMARY
SOUTH HOPE, KAINE December 27, 1990
***.***************************************************************.*.
located in a manner which will maximize: (i) the extraction
of the contaminated groundwater on the site that exceeds the
groundwater cleanup levels specified in this ROD, with the
exception of the contaminated groundwater currently known to
exist at the deep bedrock well designated as ODW: and (ii)
the removal of those soil contaminants (which are not
undergoing excavation as described in Sc-s above) that
exceed the soil cleanup levels. These extraction wells will.
be located on-site within both the till and weathered
bedrock during the initial phases of the remedial action.
If groundwater contamination is still found to be exceeding
the groundwater cleanup levels specified in this ROD within
the deeper bedrock aquifer (including within the on-site
well ODW) during the remedial action monitoring program,
then additional extraction wells may be required in the
bedrock aquifer. The exact number, depth, size, and
location of these extraction wells (and additional
monitoring wells) will be defined during the remedial design
phase of the overall remedial action and refined, as
necessary, during the course of the remedial action. such
refinement may include modifications to the groundwater
extraction rate, alternating pumping at individual or
multiple extraction wells to eliminate stagnation points,
pulse pumping to allow aquifer equilibration and to allow
adsorbed contaminants to further partition from the soil,
and/or the construction of new extraction wells to
facilitate or accelerate cleanup of the contaminant
plume(s).
prior to full-scale implementation of this groundwater
remedial alternative, one or more pilot-scale treatability
studies will be conducted on the site. These studies will,
at a minimum, be used to provide additional site-specific
data to design a groundwater pretreatment system for
suspended solids and/or metals (if pretreatment is
necessary), to establish the optimum wavelength and exposure
period for the UV light groundwater treatment system, to
select the oxidant(s) and their optimum dosage to assure
treatment system performance in achieving the groundwater
cleanup levels and discharge standards, and to verify that
the vacuum-enhanced extraction system can achieve the soil
cleanup levels in the areas of the site between the
interceptor trench and Quiggle Brook where limited soil
contamination exists above the soil cleanup levels specified
herein. In order to conduct such a pilot-study at the site,
an additional aquifer testes) will also be conducted on the
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UNION CHEMICAL COMPANY, XNC. RECORD OF DECISION SUMMARY
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Site to extract the contaminated groundwater for the
treatability study(ies), and provide additional sampling and
analysis data in order to determine the numbers, depths,
and locations of the vacuum-enhanced extraction wells on the
Site. Furthermore, it will also be necessary to apply a
fate and transport numerical model to simulate the effects
of pumping the aquifer to select the optimal locations of
the extraction wells, and to facilitate predictions of
system performance and aquifer cleanup response. .
On-Site Groundwater Treatment Svstem/Discharae System
Installation
The extracted groundwater will be placed in holding tanks
located on the Site prior to being treated using the process
called ultraviolet (UV) light/oxidation or an equivalent
destruction technology. In this process, the extracted
groundwater will be put in contact with an oxidant (such as
ozone and/or hydrogen peroxide) and UV light. This
treatment method will destroy the organic contaminants in
the groundwater while producing carbon dioxide, residual
ozone gases, and treated water. The residual ozone gases
generated by this treatment method will subsequently be
destroyed on the Site using an appropriate treatment method.
Pre-treatment'of the extracted groundwater prior to
UV/oxidation treatment may be necessary to remove inorganics
(heavy metals) and/or solids. If pretreatment is necessary,
the collected solid (sludge-like) material will undergo
additional testing to determine whether the material is
hazardous or non-hazardous, and whether additional treatmer~
and/or disposal is required on this material either on-site
or off-site. Additional post-treatment of the UV-treated
groundwater using liquid-phase carbon adsorption, or an
equivalent treatment technology, prior to discharge into
Quiggle Brook will be required if such further treatment is
warranted to meet the site-specific discharge
requirements/standards, and to eliminate potential slugs of
contamination from passing through the UV/oxidation system.
If liquid-phase carbon adsorption is used for such post-
treatment, the carbon will be either regenerated or
incinerated off-site at a permitted facility.
The vacuum-extracted, contaminated soil gases will also be
treated on the Site using a vapor-phase carbon adsorption
process or an equivalent treatment technology prior to
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UNION CHEMICAL COMPANY, XNC. RECORD OF DECISION SUMMARY
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discharge into the atmosphere. These soil gases will be
monitored accordingly to ensure compliance with Federal and
state air quality standards and to protect public health,
welfare and the environment of the surrounding community.
The groundwater treatment system effluent will be piped to
Quiggle Brook for discharge. The piping and discharge point
will be located entirely on the site. The discharge point
will be designed so that it will preserve the wetland areas
along Quiggle Brook by keeping these areas moist despite the
extraction of groundwater from these areas. This discharge
will, however, not further impact the area{s) where the
treated water is actually discharged into the brook.
Groundwater reatment
Maintenance
The treated groundwater will be sampled periodically prior
to being directly discharged into Quiggle Brook. Periodic
sampling will also occur, at a minimum, in the brook, in
existing and new monitoring wells, residential wells, and
throughout the treatment system. The frequency of sampling
will be determined during the remedial design. samples
collected during these monitoring periods will, at a
minimum, utilize those analytical methods established under
either or both the SDWA (SOO series methods) and RCRA (8000
series/SW-846 methods) to provide the best precision and
accuracy analytically achievable at the time these samples
are obtained. In addition, periodic sampling will include
the collection and analysis of groundwater samples in on-
site monitoring and residential wells for the compound, N,N-
dimethylformamide - DMF, using the best analytical methods
available which are approved by EPA: while further, limited
monitoring for arsenic and lead will also occur on the site.
The objective of these sampling efforts will be to ensure
that the treated water achieves the discharge criteria and
that ambient water quality criteria or other standards
within Quiggle Brook are not exceeded by the discharge to
Quiggle Brook, and that the groundwater cleanup levels
established for this site are being achieved throughout all
the aquifers underlying the site, and that surrounding
residential wells are not being impacted by the
contamination and/or extraction of groundwater on the site.
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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F-4:
~aciliti.8 Decontamination and Demolition
Facilities Alternative F-4 has been selected to facilitate
the cleanup of the contaminated soil and to address the
existing contamination of and within all the facilities that
currently remain at the UCC Site. These facilities include,
at a minimum: the still building and associated production
facilities, the welding shop, the incinerator complex, all
concrete pads, and the church.
Decontamination (and Treatment. as aDDroDriate)
This component of the overall remedial action will involve
the decontamination of all on-site facilities (including, at
a minimum, any and all equipment, tanks, pipes, and drums
contained within these facilities or buried on-site) using
high-pressure steam cleaning or another effective
decontamination technique, to the maximum extent
practicable. Whether high-pressure steam cleaning or
another decontamination technique is utilized, every effort
will be made to minimize and/or mitigate the release of
airborne volatile and particulate emissions (and excessive
noise) into the surrounding environment during all phases of
such decontamination work. These efforts will include the
use of one or more of the following techniques in order to
minimize and/or mitigate a release of such emissions:
controlled steam cleaning techniques, dust suppressants
(e.g. water or foaming agents), partial or full enclosures
on each or all of the on-site work areas, and/or air
pollution control devices to treat air emissions collected
by an enclosure. Additionally, all water resulting from
these decontamination operations will be collected and
analyzed to determine the eventual disposition of this
material. If further treatment of this water is required,
this treatment will occur on-site using the UV/oxidation
groundwater treatment system as described above in MM-4, if
technically practicable, or another equally effective water
treatment technique.
Prior to facilities decontamination, any contaminated
currently remaining within the sumps on the site will
drained, collected, and analyzed prior to eventual
treatment on or off the Site. If treatment on-site is
warranted, such treatment will occur using the UV
light/oxidation system being employed for groundwater
treatment, if technically practicable, or an equally
water
be
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
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effective treatment technique.
All of the concrete on the site from the warehouse pad,
structures, floors and sumps will undergo low-temperature
thermal aeration treatment or an equivalent thermal
desorption technique (as described in the selected source
control alternative, SC-S) following crushing of this
material to enable such treatment. This crushing operation
will be carefully controlled, as discussed above under SC-
5, to prevent and/or eliminate any potential releases of
volatile or particulate emissions and excessive noise into
the surrounding environment. The treated concrete will then
be used as backfill on-site, if it meets the RCRA LDR
standards determined as ARARs for the UCC site, or disposed
of off-site at a permitted, RCRA hazardous waste facility.
The asbestos contained within the still building will be
appropriately containerized in accordance with federal and
state requirements, and subsequentlY removed from the site
for off-site disposal.
Any and all other RCRA hazardous waste (including, at a
minimum, liquids, sludges, and ash) found within the
incinerator equipment, sumps, and/or other on-site equipment
will be treated by best available and appropriate techniques
prior to off-site disposal. Based on existing sampling
results, such treatment will likely include, at a minimum,
solidification/stabilization techniques due to the
characteristics of these hazardous wastes. The dioxin/lead-
contaminated secondary scrubber ash found within the
incinerator equipment components will also be
solidified/stabilized to meet the RCRA LDR treatment
standards for FOOI-FOOS spent solvents, and the RCRA
characteristic of toxicity requirements (through TCLP
testing) prior to off-site disposal at a permitted RCRA
facility. These requirements are based upon an assessment
that these incinerator residues are classified as F001-FOOS
wastes pursuant to EPA'S "derived-from" rule at 40 CFR 261.3
(c) (2).
pemolition
Following these activities, the welding shop, still building
and associated production facilities, the former church, and
the entire incinerator complex will be demolished. These
demolished facilities (debris) will then undergo extensive,
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UNION CHEMICAL COMPANY, Z.C. RECORD OF DECISION SUMMARY
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representative sampling and analysis to determine whether
this debris is hazardous or non-hazardous.
Off-site DisDosal
Finally, demolition debris (and any other material discussed
above) which is determined to be non-hazardous will be taken
off-site for disposal at a permitted, demolition landfill
without prior treatment. Demolition debris, and all other
material described above, that is determined to be a
hazardous waste will also be taken off-site (following
additional treatment, if required) and disposed of at a
permitted, RCRA hazardous waste facility.
OS-2:
Limited Action
A Limited Action remedial alternative has been selected to
address the remedial response objectives 'stated previously
for the off-site soils surrounding the UCC Site.
Additionally, this remedial alternative has been selected to
further define whether or not off-site soil contamination is
present as a result of past UCC operations and, if so,
whether this contamination warrants further remedial action.
Data Collection and Analvsis
Under this remedial alternative, continuous, site-specific
meteorological data (i.e., wind speed, wind direction,
temperature, and barometric pressure) will be collected for
a minimum period of five years. Following the acquisition
of one fUll-year of meteorological data from the Site,
additional air modeling simulations (similar to those
performed during the RI) will be performed to determine the
potential locations where airborne materials from the
incinerator and/or the on-site boilers may have been
deposited off the Site. Based upon the results obtained
from this re-modeling effort (or sooner, if required), in
comparison to the results obtained during the RI using
Augusta, Maine meteorological data and other factors to be
considered, additional off-site soil samples will be
collected. These samples will be analyzed, at a minimum,
for dioxins and furans, heavy metals and semi-volatile
organic compounds.
Following the initial, minimum, five-years of site-specific
meteorological data collection (as stated above), the
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UNION CHEMICAL COMPANY, XNC. RECORD OF DECISION SUMMARY
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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 UCC
site if any hazardous substances, pollutants or contaminants remain at
the site to assure that the remedial action continues to protect human
health and the environment. EPA will also evaluate risk posed by the
site at the completion of the remedial action (i.e., before the site
is proposed for deletion from the NPL).
incinerator and/or on-site boiler stack(s) will be modelled
again to determine where potential, additional off-site
locations will require additional sampling to be performed.
If additional sampling is warranted in new, off-site
locations based upon this and previous modeling efforts and
any other factors that must be considered, these samples
will be analyzed, at a minimum, for the same organic and
inorganic compounds mentioned above.
Throughout all phases of this data collection and analysis
effort, EPA will determine if additional remedial actions
are required for these off-site soils. This determination
will be made following an opportunity for both state and
public involve~ent.
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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XI.
STATUTORY DETBRMINATIONS
The remedial action selected for implementation at the UCC Site is
consistent with CERCLA and 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
presently posed to human health and the environment by
eliminating, reducing or controlling exposures to human and
environmental receptors through treatment, engineering controls,
and institutional controls. Specifically:
The combination of the source control component (SC-S)
and the management of migration component (MM-4) will
reduce the most significant risks (principal threats)
identified in the Baseline Risk Assessment: the
present and future risks posed by ingestion of
contaminated groundwater. The selected remedy will
attain federal MCLs and non-zero MCLGs, which are
generally protective of human health and suitable for
public drinking water supplies. Where no MCL or MCLG
exists, other standards were considered in setting
cleanup levels which provide protection against risks
associated with ingestion of (or inhalation of or
dermal contact with) contaminated groundwater. Use of
a vacuum-enhanced groundwater extraction system
increases the certainty that groundwater cleanup
standards will be attained throughout the Site.
The selected remedy will eliminate or reduce risks to
human and environmental receptors by preventing
contaminated on-site groundwater from migrating off-
site and into nearby surface waters, particularly
Quiggle Brook. Discharge of treated groundwater will
not adversely affect Quiggle Brook, since groundwater
will be treated to water quality standards.
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UNION CHEMICAL COMPANY, XNC. aECORD OP DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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The facilities (F-4) component of the remedy will
permanentlY eliminate or reduce exposures to hazardous
substances present in the facilities. 05-2, sampling
of off-site soils to assess further the impacts of past
operations of the UCC incinerator, is necessary to .
ensure that the remedy is protective and effective in
the long-term and short-term. Because dioxins and
furans were found in the secondary scrubber on the UCC
site, it is possible that these toxic compounds were
released through the incinerator stack and deposited
off-site. Given the technical difficulties of
reconstructing the direction of the plume from the
stack and the fact that one off-site sample showed
inconclusive results, further off-site sampling is
needed to protect human health and the environment.
Use of temporary institutional controls limiting the
use of existing and new drinking water wells during the
remedial action is necessary to ensure that pumping
does not draw groundwater contamination further off-
site.
In addition, the selected remedy will result in human exposure
levels that are within the 10.4 to 10.6 incremental cancer risk
range and that are less than the hazard index of one (1) for non-
carcinogens. More, specificallY, the source control and
management of migration components will attain the groundwater
cleanup standards set at MCLs, which are generally within the
range for protection of human health. Once all the groundwater
cleanup standards specified above are attained, the residual risk
will be re-calculated. If at that point the cumulative risk
posed by remaining contaminants falls outside the 10.4 to 10.'
incremental cancer risk range, then further remedial action will
be taken to bring the cumulative risk within the acceptable
range.
Finally, implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts. As
described above, measures will be taken to reduce to acceptable
levels any short-term risks associated with excavation and
treatment of contaminated soils, and the vacuum extraction and
groundwater treatment system.
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UNION CHEMICAL COMPANY, INC. RECORD OP DECISION SUMMARY
SOUTH HOPE, MAINE December 27, 1990
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B.
~he Selected Remedy Attains ARARs
This remedy will attain all the substantive, non-procedural
portions of applicable or relevant and appropriate federal and
state requirements that apply to the UCC Site. The key
environmental laws from which ARARs for the selected remedial
action are derived, and the specific ARARs, include:
Chemical-SDecific
Safe Drinking Water Act (SDWA) - Maximum Contaminant Levels
(MCLs) and non-zero Maximum Contaminant Level Goals (MCLGs)
Clean Water Act (CWA) - Federal Ambient Water Quality Criteria
(AWQC)
Clean Air Act (CAA) - National Ambient Air Quality Standards
(NAAQS) and National Emission Standards for Hazardous Air
Pollutants (NESHAPs)
Maine Water Pollution Control Law
Maine Air Pollution Control Law
Maine Ambient Air Quality Standards
Location-Specific
Executive Order 11990, Protection of Wetlands
Executive Order 11988, Floodplain Management
Maine Water Classification Program
Maine Site Location of Development Law
Maine Protection of Natural Resources Law
Maine Water Pollution Control Law
Maine Air Pollution Control Law
Action-SDecific
Resource Conservation and Recovery Act (RCRA) - Land Disposal
Restrictions (LORs)
Clean Air Act (CAA) - NESHAP Regulations
DOT Rules for Transportation of Hazardous Materials
OSHA Health and Safety Standards
OSHA Record Keeping, Reporting and Related Regulations
Maine Hazardous Waste Management Rules
Maine Protection of Natural Resources Law
Maine Water Pollution Control Law
Maine DEP Asbestos Abatement Regulations
Maine Air Pollution Control Law
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UNION CHEMICAL COMPANY, XNC. ueaRD OF DECISION SUMMARY
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The following policies, criteria, and guidances will also be
considered (TBCS) during the implementation of the remedial
action:
~o-be-considered
proposed MCLs and proposed MCLGs greater than zero
OSWER Directive 9355.0-28, control of Air Emissions from
superfund Air strippers at superfund Groundwater sites
Reference concentrations (RfCS)
Maine Department of Human Services Rule 10-144A,CMR c. 231 --
Maximum Exposure Guidelines (MEGs)
Maine Department of Human Services Policy, "Derivation of Interim
Exposure Guidelines for the Hazardous Air pollutant program"
A table briefly summarizing the ARARs for the selected remedy at
the Union Chemical site is attached as Table 13 to this ROD. A
more complete narrative summary of significant ARARs and TBCS is
provided below.
Federal and state Drinkina water ARARs and TBCs
The groundwater in the aquifer underlying the site is classified
by the state as GW-A, a drinking water source. EPA has
determined that Maximum contaminant Levels (MCLS) promulgated
under the Safe Drinking Water Act (SDWA) are relevant and
appropriate. MCLs are enforceable standards under the SDWA which
represent the maximum level of contaminants that is acceptable
for users of public drinking water supplies. MCLs are relevant
and appropriate because the groundwater immediately off-site is
currently used as a drinking water source, and because the
groundwater underlying the site may be used as a drinking water
source in the future.
MCLs were used in establishing cleanup levels for the site,6
except that for those contaminants for which no MCLs were
6 As stated in the preamble to the NCP, 55 Fed. Reg. 8751,
MCLGs (Maximum contaminant Level Goals established under SDWA)
which are set at levels above zero, may be relevant and appropriate
based on site-specific factors. MCLGs are non-enforceable goals
set at levels at which no adverse health effects may arise, with
a margin of safety. In this case, where non-zero MCLGs existed for
the contaminants of concern at the Union Chemical site, they were
equivalent to the MCLs used.
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ONION CBEKICAL COKPANY, XNC. aBCORD OP DECISION SUMMARY
SOUTH HOPE, KAINE. December 27, 1990
[[[****
available, other standards and guidelines were considered in
establishing cleanup levels. The guidelines considered were:
proposed MCLs and proposed MCLGs, and the Maximum Exposure
Guidelines (MEGs) established by the state of Maine. Because
these standards do not meet the criteria for an ARAR, as
established by Section 121(d) of CERCLA and the NCP, EPA is not
required to meet these standards. They are, however, to be
considered (TBCs) for the following reasons:
1. Consideration of proposed MCLs and proposed non-zero
MCLGs is appropriate in setting cleanup levels because these
proposed standards have been developed in accordance with
EPA policy in establishing final MCLs and MCLGs.
2. For 1,1-dichloroethane and methyl ethyl ketone, it is
appropriate to consider MEGs in the development of cleanup
levels, since no MCL or other ARARexists. Use of these
MEGs will reduce risks to levels which are within EPA's
acceptable range of 10-4 to 10-6 for carcinogenic compounds,
and which are also below a Hazard Index of one (1) for non-
carcinogenic compounds for the relevant toxicity endpoints.
These MEGs are developed by the Maine Department Human
Services based on federal standards, health advisories and
environmental toxicology methods.
EPA believes that the ARARs and TBCs established as cleanup
levels will be attained by extracting and treating the
groundwater to attain these levels throughout the aquifers on the
Site. EPA anticipates that these cleanup levels will be attainej
first in the overburden (till) and weathered bedrock located on
the Site and, thereafter, in the deeper bedrock, if required.
Cleanup levels in the overburden/weathered bedrock must be
attained before attempting to extract and treat groundwater fro~
the deep bedrock. This will ensure that the principal source
areas of groundwater contamination on the Site (those areas near
the existing on-site facilities) will not be drawdown into the
deeper bedrock by the operation of a deep bedrock extraction well
system. This is critical since the source of residential well
water in the area of the Site is primarily from the deeper
bedrock aquifer system throughout the Site area.
Pederal and state Surface Water ARARs and TBCs
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discharge of treated groundwater to Quiggle Brook.
Quiggle Brook is classified as a tributary to a Class GPA water
(Crawford pond).7 Class GPA waters are suitable for use as
drinking water after disinfection, recreation, fishing and
habitat for fish and other aquatic life. Any discharge into a
tributary of a Class GPA water which, by itself or in combination
with other activities, causes water quality degradation or
impairs the characteristics and designated uses of downstream
waters is prohibited.
Maine's regulations relating to Water Quality criteria for Toxic
pollutants provide that: (i) levels of toxic pollutants shall not
exceed Federal Ambient Water Quality criteria~ and (ii) where
federal criteria do not exist, the Board of Environmental
protection may adopt site-specific numerical criteria for toxic
pollutants. Xn this case, because drinking water is also a
designated use of Class GPA waters, MCLs are relevant and
appropriate standards that must be met in the effluent. In
addition, AWQCs for protection of human health are relevant and
appropriate where no MCL for a particular contaminant exists.
Federal AWQCs for protection of aquatic life are also applicable
to the site, since the designated use of the stream requires
protection of aquatic life.
The selected remedy will attain these ARARs because prior to its
discharge to Quiggle Brook, contaminated groundwater will be
treated to AWQCs. Discharge of treated groundwater to Quiggle
Brook will not cause water quality degradation or impair the uses
or characteristics of Quiggle Brook or Crawford pond.
Federal and state Air pollution ARARS and TBCs
The regulations established pursuant to the Air Pollution and
protection Act, 38 MRSA S 581, have been approved by EPA under
section 110 of the Clean Air Act (CAA), and are thus enforceable
as federal requirements.
The state of Maine has established requirements for sources
7 Quiggle Brook is also a Class B water. Class B waters are
acceptable for fishing, recreation, habitat for fish and other
aquatic life, and after treatment, use as a drinking water supply.
Discharges to Class B waters cannot degrade the water below this
classification.
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
[[[**
emitting air contaminants in Chapter 115, promulgated pursuant to
38 MRSA I 590. General process sources with emissions of less
than 100 pounds per day or 10 pounds per hour of any regulated
pollutant are not covered by the licensing requirements of this
Act. Because it is expected that remedial activities at the UCC
site will not exceed these amounts, these regulations are not
applicable, but are relevant and appropriate.
Chapter 115 also includes requirements for new sources, providing
that: Best Available Control Technology (BACT) must be used; the
emissions will not violate emission standards established by DEPi
the emissions either alone or in conjunction with other emissions
will not violate AAQSes&; and that limits on impairment of
visibility must be attained. In non-attainment areas, the
technology used must be the Lowest Achievable Emissions Rate
(LAER). Since the UCC site is in an area designated as a non-
attainment area for ozone, LAER would be required for ozone
emissions.
The proposed remedy will meet the technology standards of the
Maine regulations. The low temperature thermal treatment system
will satisfy BACT, and an ozone destruction unit will be used to
limit ozone emissions from the UV/oxidation unit, satisfying the
LAER standard for ozone emissions. The vapor phase activated
carbon treatment is BACT for treatment of organic vapor streams
captured by the vacuum extraction system. In addition, ambient
air quality standards will be achieved by monitoring and
controlling emissions throughout the performance of the remedial
action. Primary and secondary Maine AAQS for particulate matter,
photochemical oxidants, and hydrocarbons will be attained during
remedial action through the use of controls described in Section
x.
Another relevant and appropriate requirement is the portion of
the federal National Emission standard for Hazardous Air
Pollutants (NESHAP) for vinyl chloride which sets emission levels
for air strippers. The vapor phase carbon component of the
8 In Chapter 110, Maine has established Maine Ambient Air
Quality Standards for particulate matter, photochemical oxidants,
and hydrocarbons. These are relevant and appropriate requirements
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groundwater extraction system is sufficiently similar to air
stripping that the vinyl chloride emission standard in the NESHAP
is relevant and appropriate. The selected remedy will attain the
federal NESHAP standard for releases of vinyl chloride at the
emission point from vapor phase carbon component of the
groundwater extraction system, or additional controls must be
included on the exit stream from the carbon component.
In addition, the NESHAP standard for asbestos is applicable to
this Site, since the selected remedy calls for demolition of
facilities containing asbestos. NESHAP standards for asbestos
will be attained during remedial action by vacuuming asbestos
from the facilities before demolition, wetting the asbestos,
placing it into leakproof bags, and proper labelling and
. disposal. Removal and disposal of asbestos will also apply with
applicable Maine Department of Environmental Protection Asbestos
Abatement Regulations.
he esource onservation and Recove
pazardous waste Manaaement Rules
and Maine
The state of Maine has been authorized by EPA to administer and
enforce the RCRA program in lieu of federal authority. The
authorized state hazardous waste regulations incorporate by
reference the federal RCRA standards for hazardous waste
facilities,9 and also impose additional requirements which are
more stringent than the federal RCRA requirements.
compliance with RCRA depends on whether the wastes are RCRA
hazardous wastes as defined under Maine's RCRA program. .
contamination at the site is the result of spills or leaks from
the operations of the Union Chemical Company. Manifests and
other documentation indicate that the substances received by the
Union Chemical Company were listed hazardous wastes (largely
solvent wastes, defined as FOOl through FOOS waste in 40 CFR
261.31), or otherwise fall within Maine's definition of hazardous
wastes. Accordingly, the Maine Hazardous Waste Management Rules
are applicable to the site.
The remedial action will be undertaken in accordance with these
applicable RCRA regulations, including general facility
standards, preparedness and contingency requirements, manifesting
9 Accordingly, citations to basic RCRA requirements in this
ROD will be to 40 CFR Part 264.
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UNION CHEMICAL COMPANY, INC. RECORD OJ' DECISION SUHKARY
SOUTH BOPE, KAINE December 27, 1990
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and record keeping requirements, ~oundwater DOnitoring
requirements, closure and post closure requirements, and use and
management of containers. In addition, the remedy will comply
with additional requirements, including the facility location
requirements and the additional standards applicable to hazardous
waste storage facilities, contained in the Maine Hazardous Waste
Management RUles, Chapter 854 of the Maine Department of
Environmental Protection Rules.
Spent carbon generated during the vapor phase carbon treatment
will be regenerated or incinerated offsite in a RCRA facility in
accordance with federal and state requirements.
Hazardous and Solid Waste Amendments to the ~esource
Conservation and Recovery Act
Land Disposal Restrictions (LDRs) promulgated under the Hazardous
and Solid Waste Amendments (HSWA) to the Resource Conservation
and Recovery Act are applicable to some components of the
selected remedy. Because contaminated soil found at the Site
contains certain restricted wastes (notably FOO~-F005 wastes),
LDRs are ARARs for disposal of this soil. Such wastes are
prohibited from land disposal unless a waste analysis using the
Toxicity Characteristic Leaching Procedure (TCLP) indicates that
the concentrations are less than the levels specified in 40 CFR
268.41. The NCP provides that, generally, a variance from the
LDR standards will be sought for CERCLA soils and debris.
However, in this case, based on the analysis performed in
preparation of the Final Draft FS, the soil treatment method
included in the selected remedy (low temperature soil aeration
treatment) is expected to attain levels lower than the
requirements of 40 CFR 268.41, and the treated soils may be
backfilled into excavation areas at the Site.10
Residuals from the facilities, including residuals from the
sumps, tanks, and floors, will be treated, if necessary, to
attain levels specified in 40 CFR 268.41 and will be disposed of
off the Site.
The selected remedy also calls for solidification of ash from the
UCC secondary scrubber, which contains.high~evels of lead and
10 If after pilot studies or implementation of the soil
treatment component of the remedy, it appears that LDR levels
cannot be attained, a treatability variance will be sought.
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UNION CHEMICAL COMPANY, INC. RECORD OF DECISION SUMMARY
SOUTH HOPE, MAINE December 27, 1990
**.*.*..**.***************.******************.*******.********..*..*.*
low levels of dioxins and furans, and disposal in a permitted
offsite RCRA ~andfill. This action is expected to attain LDR
requirements. '
rloodDlain8 and Wetlands ARARs
EPA regulations at 40 CFR Part 6, Appendix A, require EPA to
implement Executive Order 11988 (Floodplain Management) and
Executive Order 11990 (protection of Wetlands). To comply with
Executive order 11988, a remedial action must reduce the risk of
flood loss, and restore and preserve the natural and beneficial
values served by floodplains. Executive Order 11990 requires EPA
to minimize the destruction, loss or degradation of wetlands and
to preserve and enhance the beneficial values of wetlands. In
addition, new construction in wetlands is to be avoided unless
there is no practicable alternative, and steps must be taken to
minimize harm to wetlands.
As part of the RI/FS, a wetlands/floodplains assessment was
performed. The selected remedy will result in minimal impacts to
the wetlands and floodplain on the site. Extraction wells and
piping must be located within the 100-year floodplain in order to
extract contaminated groundwater. Pumping at these wells will
result in some dewatering of the wetland area adjacent to Quiggle
Brook: however, it is expected that a portion of the treated
groundwater will be discharged to Quiggle Brook and the nearby
wetlands area, thus resaturating the wetland. After the
groundwater wells are shut off, the groundwater will again
discharge to the wetlands area, resulting in resaturation.
Chapter 854
prohibiting
wetlands or
be attained
of the Maine Hazardous Waste Management Rules,
the location of a hazardous waste facility on
within the 100-year floodplain, is an ARAR and
by the selected remedy.
will
other ARARS
portions of the Maine site Location of Development LaW, 38 MRSA ~
" As stated on page 238-39 of the FS, this ash is not an F020-
F023 waste or an F026-F028 waste. Rather, the ash is a byproduct
of the incineration of F001-F005 wastes, and may be land disposed
if a TCLP test on an extract of the ash shows that the levels
specified for FOOI-F005 wastes in 40 CFR 268.41 have been attained.
These levels are expected to be attained by the selected remedy.
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UNION CHEMICAL COMPANY, X.C. RECORD OF DECISION SUMMARY
SOUTH HOPE, MAINE December 27, 1990
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481, and the regulations thereunder are relevant and appropriate
to this Site. The statute provides that a new development which
is a hazardous activity cannot have an adverse effect on the
natural environment or pose an unreasonable risk of discharge to
a significant groundwater aquifer. Portions of Chapter 375 which
set out the no adverse environmental effects standards for air
quality, natural drainage ways, runoff, erosion and sedimentation
control, groundwater quality, and buffer strips, are relevant and
appropriate and will be attained by the selected remedy. In
addition, soil excavation and facilities demolition activities
will be monitored to attain the noise abatement standards set out
in Chapter 375. .
The Maine Natural Resources Protection Act provides that removal
of soils or alteration of structures adjacent to streams must not
cause unreasonable soil erosion, cause unreasonable harm to
significant wildlife habitats, unreasonably interfere with
natural water flow, lower water quality, or unreasonably cause or
increase flooding. Chapter 305 of the MDEP regulations provides
further standards for erosion control and soil excavation. These
portions of the statute and regulations will be attained by the
selected remedy. Chapter 310, the Wetland Protection Rules,
defines wetlands to exclude the types found at the UCC Site, but
contain relevant and appropriate standards which: (i) prohibit
activities that would cause a loss in the wetland area if there
is a less damaging practicable alternative, and (ii) requires
that alteration of wetlands be kept to a minimum. Relevant and
appropriate portions of Chapter 310 will be attained.
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UNION CHEMICAL COMPAHY, :INC. DeeRD OF DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
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C.
~b. Selected ...edial Action i. cost-Effective
In the Agency's judgment, the selected remedy is cost effective,
i.e., the remedy affords overall effectiveness proportional to .
its costs. In selecting this remedy, after identifying
alternatives that are protective of human health and the
environment and that attain ARARs, EPA evaluated the overall
effectiveness of each alternative by assessing in combination the
relevant three criteria -- long term effectiveness and
permanence: reduction in toxicity, mobility, and volume through
treatment: and short-term effectiveness.
The overall effectiveness of the selected remedial alternative
was determined to be proportional to its costs. The estimated
total present worth cost of this remedial alternative is
approximately $9,724,000 to $10,654,000, (the amount in the
proposed Plan, as modified to reflect the selection of Case B for
the quantity of soil to be treated).
The components of this present worth cost are:
$3,553,000 for SC-5, Case B (the soil component of the
remedy). All of this cost is allocated to capital
costs.
$5,108,000 to $6,037,000 for MM-4 (the groundwater
component of the remedy). $1,280,000 represents
capital costs, and $3,828,000 to $4,757,000 is
allocated to operation and maintenance.
$778,000 for F-4 (facilities decontamination and
demolition). All of this cost represents capital
costs.
$282,000 for OS-2 (off-site sampling for five years)
The cost of the selected remedy is proportional to the overall
effectiveness of the remedy. This cost is higher than other
alternatives, such as capping (SC-3), pump and treat technologies
for groundwater which do not incorporate vacuum extraction (MM-J
and MM-5), and facilities decontamination (F-2). However, the
less expensive technologies do not provide the same degree of
effectiveness or permanence, and are more likely to require
longer time frames to achieve the site-specific cleanup levels.
In particular, using vacuum-enhanced groundwater extraction will
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UNION CHEMICAL COMPANY, %.C. RECORD OP DECISION SUMMARY
SOUTH HOPE, KAIHE December 27, 1990
.*.**..........*.*......*.....*.**....*.*.....*..................*..**
increase the certainty of attaining the groundwater cleanup
levels than would conventional pump and treat technologies, and
will more likely reduce the time for attaining these levels.
Additionally, although placing a cap over contaminated soils
would eliminate infiltration of surface water through the soil,
SC-5 is more effective than a cap because the toxicity, mobility
and volume of soil contaminants will be reduced through
treatment, thus shortening the time for cleanup of the
groundwater contaminated by leachate from contaminated soils.
Third, demolition of the facilities (in addition to
decontamination) is necessary to implement SC-5. While the cost
of in-situ soil treatment (SC-6) is only slightly higher than the
cost of SC-5, and in-situ treatment would not require the
demolition of the facilities or the excavation of contaminated
soils, SC-6 has not been shown to be as effective as SC-5 in
reaching cleanup levels in the low part-per-million range. It is
anticipated that the time to attain soil cleanup levels would be
much longer using in-situ treatment than if low temperature soil
aeration treatment is used. Finally, the costs of off-site
sampling are proportional to the level of protection afforded.
Such sampling is easily implementable and is not estimated to
represent a significant cost item. .
SC-s and MM-4 are less expensive than on-site incineration (SC-
7) and remedies involving reinjection of treated groundwater (MM-
5 and MM-6), but attain similar levels of long-term
effectiveness, permanence, and reductions in toxicity, mobility
and volume of contaminants through treatment.
Tables D-6, D-12, D-17 and D-19, which are contained within
Appendix D of the Final Draft FS, present itemized cost
breakdowns for each of the components of the remedy, stating the
major assumptions, activities and estimated unit costs. While
these costs are in the +50% to -30% accuracy required for
Feasibility study estimates, some changes may be made as a result
of the remedial design and construction processes involved after
the ROD is signed. It is expected that these changes, in
general, will reflect modifications resulting from the
engineering design process.
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[[[
UNION CBEXICAL COKPANY, INC. aBCORD OF DECISION SUMMARY
SOUTH HOPE, KAINB December 27, 1990
..*[[[*.
D.
~be Selected Remedy utili.es permanent solutions and
Alternative ~reatment or Resource .ecovery ~ecbDologies to
tbe Kasimum Extent Practicable
Once EPA identified the alternatives that attain ARARs and are
protective of human health and the environment, EPA identified
which alternative utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. This determination was made by
deciding which one of the identified alternatives 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) implementability; and (5) cost. The
balancing test emDhasized 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 off-site land disposal of
untreated waste, and community and state acceptance.
overall, the selected remedy provided the best balance of trade-
offs among all the alternatives evaluated in the Final Draft FS.
specifically, the management of migration component of the
selected alternative is expected to provide a long-term,
effective and permanent remedy for addressing the groundwater
contamination present at the site. Because vacuum extraction
will remove impacted air from contaminated soils which have been
dewatered by groundwater pumping, it will provide more
effectiveness in reducing concentrations of contaminants in
previously saturated soils, thereby increasing the certainty of
attaining groundwater cleanup levels and permanence of the
remedy. The air extracted from the soil will be treated, at a
minimum, by a vapor phase carbon system; potential short-term
risks to the community and workers posed by the collection of
this contaminated air will be minimized by proper design of the
vapor phase treatment system, attainment of state and federal
emission standards, and by careful monitoring. The uv/oxidation
system will permanently reduce the toxicity and volume of
contaminants, will be effective in treating groundwater to .
federal and state water quality standards, can be implemented
relatively easily, and is not excessively expensive.
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UNION CHEMICAL COMPANY, ~NC. bCORD OF DECISION SUMMARY
SOUTH BOPB, MAX" December 27, 1990
[[[
through treatment, and will increase the certainty of attaining
groundwater cleanup levels. Case B (i.e. excavation and
treatment of approximately 10,500 cubic yards, in-place volume
estimate, of saturated and unsaturated soils) provides extra
effectiveness by reducing leaching of soil contaminants from the
saturated zone near the interceptor trench, which will likely
result in decreased costs for the management of migration
component. .
The facilities component of the remedy will permanently and
reliably reduce the risks associated with the facilities, and is
necessary for implementation of the source control component (SC-
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UNION CHEKICAL COMPANY, INC. UCOIU) or DECISION stJKHARY
SOUTH HOPB, MAINE December 27, 1990
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E.
~he selected Remedy satisfies the Preference for ~reatment
Which permanently and SiqnificantlY Reduces the ~oxicity,
Mobility or volume of the Hazardous Substances as a
principal Element
The principal elements of the selected remedy combine a
groundwater treatment system together with a method for treating
the contaminated soils which are the source of the groundwater
contamination. These elements, in turn, address the principal
threat at the site, contamination of the groundwater. The
selected remedy satisfies the statutory preference for treatment
as a principal element by utilizing uv/oxidation to treat VOCs in
the groundwater, low temperature soil aeration treatment to
destroy VOCs in the soil, and vapor phase carbon to collect VOCs
in air extracted from the soils for eventual treatment.
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~ON CHEMICAL COMPANY, INC. RECORD OP DECISION SUKMARY
SOUTH BOPE, KAINE December 27, 1990
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XII. DOCUMENTATION OP SIGNIPICANT CHANGES
EPA presented a proposed plan (referred to as a preferred alternative)
£or remediation of the UCC Site on July 12, 1990 at a public
informational meeting in Hope, Maine. The source control portion of
the preferred alternative included soil excavation and on-site low-
temperature soil aeration treatment, the management of migration
portion of the preferred alternative included vacuum-enhanced
groundwater extraction, on-site groundwater treatment and on-site
discharge of treated groundwater into Quiggle Brook, the facilities
~anagement portion of the preferred alternative included facilities
decontamination, demolition and off-site disposal of debris, and the
off-site soils portion of the preferred alternative included limited
action.
Four significant changes to the proposed plan were made. First, the
soil excavation and treatment option has been changed to Case B;
thereby increasing the amount of soil to be excavated and treated.
Case B was discussed in the Proposed Plan. Case B was chosen because
the additional (roughly) 2,000 cubic yards of in-place soil
represented a significant amount of contamination. Without excavation
of this source area, the success and the time required for groundwater
cleanup could be significantly affected. Furthermore, since the
additional contaminated soils included in Case B are immediately
adjacent to those included in Case A.l, and since these contaminated
soils (though saturated) are shallow, further technical
implementability problems are not expected. Finally, comments
received from the state of Maine and the public supported excavation
of this larger volume of contaminated soils.
Second, groundwater cleanup levels were changed for ten contaminants.
Groundwater cleanup levels were eliminated for five contaminants --
chromium, copper, cyanide, nickel, and 1,3-dichlorobenzene -- because
they were not identified in the Baseline Risk Assessment as
contaminants of concern which may pose a risk at the Site, and because
their maximum observed concentrations did not exceed their federal
MCLs or proposed MCLs at any time during the Remedial Investigation.
The cleanup levels for two contaminants -- bis(2-ethylhexyl)phthalate
and methylene chloride -- were lowered, because new proposed MCLs
(PMCLs) were published on July 25, 1990 (after issuance of the
Proposed Plan), which indicated that these lower levels are necessary
to protect the human health. Groundwater cleanup levels for three
contaminants -- tetrachloroethene, 1,2-dichloroethene-trans, and
xylene were increased from the state of Maine MEGs to their proposed
MCL/MCLG levels. The cleanup levels for these contaminants were
increased because EPA believes that the scientific evidence supporting.
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UNION CHEKICAL COKPANY, XNC. RECORD OP DECISION SUMMARY
SOUTH HOPE, KAINE December 27, 1990
.***[[[*****.*
the use of proposed MCLs and proposed MCLGs is stronger than the
evidence on which the MEGs were based. EPA has placed in the
Administrative Record a memorandum which provides further support for
the selection of the proposed MCLs and proposed MCLGs for these
contaminants.
Third, because EPA determined that the groundwater cleanup level for
xylene should be set at the proposed MCL/proposed MCLG rather than the
MEG, EPA adjusted the soil percolation model results (as referred to
in section X.A.2 herein), and resulting soil cleanup level for xylene,
to reflect this change. Thus, the soil cleanup level for xylene is
now set at 100 ppm rather than 10 ppm. However, because the xylene
contamination in soils on the site is co-located with the three other
contaminants for which soil cleanup levels have also been set, the
impact of this change on the volume of soils to be excavated and
treated has been determined by EPA to be minimal.
Finally, the selected remedy includes the sampling for N,N-
dimethylformamide (DMF). This change was made in response to comments
by the public and the state of Maine which pointed out that, while DMF
may pose a risk at the site and was a component of the patented
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UNION CHEMICAL COXPANY, 1:1fC. RECORD 01' DECISION StJHHARy
SOUTH HOPE, MAIlfB December 27, 1990
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XIII. STATE ROLE
The state of Maine, Department of Environmental Protection (MDEP) has
reviewed the various remedial alternatives evaluated for the UCC Site
and has indicated that they agree with the selected remedy contained
herein. The State of Maine has also reviewed the Final Draft Remedial
Investigation, Baseline Risk Assessment and Final Draft Feasibility
Study reports to determine if the selected remedy is in compliance
with applicable or relevant and appropriate state Environmental laws
and regulations.
The State of Maine concurs with the selected remedy for the Union
Chemical Company, Inc. (UCC) Site. A copy of the declaration of
concurrence is attached as Appendix B.
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I-
f
i
t
1
t
UNION CHE1fiCAL CO., INC.
soum JI)PE, MAINE
j
ROCORD OF DOCISION
APPENDIX A
f
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RESPONSIVENESS SUJlKARY
UNION CHEMICAL CO., INC. SUPERFUND SITE
SOOTH HOPE, KAINE
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TABLE OF CONTENTS
This community relations responsiveness summary is divided into
the following sections:
I.
OVERVIEW
This section discusses EPA's preferred alternative for
remedial action at the Union Chemical Co., Inc. (UCC)
superfund site (the "site") located in South Hope, Maine.
II.
BACltGROUND
This section provides a brief discussion of the community
interests and concerns raised during the remedial planning
stages for the UCC site.
III. COMMENTS AND EPA RESPONSES
This section categorizes and summarizes comments received
from three audiences: (A) Residents, Technical Assistance
Grant (TAG) advisors and other interested parties, (B)
potentially Responsible Parties, and (C) the state of Maine
Department of Environmental Protection. This section also
provides detailed responses by EPA to each comment.
A.
summary of Residents, TAG advisors and Other
Interested Party comments are further subdivided
into the following topics:
1.
2.
3.
4.
5.
6.
7.
8.
site History:
Remedial Investigation Process:
Remedy Selection and Implementation:
Groundwater Treatment:
Soil Treatment:
Testing:
Health and Environmental: and
Miscellaneous.
B.
summary of potentially Responsible Party comments
are further subdivided into the following topics:
1.
2.
3.
Groundwater Target Cleanup Levels:
Soil Treatment: and
Off-site Limited Action Alternative.
summary of comments from the State of Maine's
Department of Environmental Protection (DEP)
regarding:
C.
1.
Groundwater Target Cleanup Levels.
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. .
Readers are referred to the Union Chemical Co., Inc. NPL Site
Administrative Record in order to review the transcripts from the
four (4) Public Hearings (see Section 13.4), and those written
comments received by EPA during the 8S-day public comment period
on EPA's Proposed Plan (see Section 5.3). The Administrative
Record is available for public review at the following locations:
(1) Hope Town Hall; Hope, Maine; (207) 763-4199, and (2) EPA
Region I Records Center; 90 Canal Street; Boston, MA: (617) S73-
5729.
~
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I.
OVERVIEW
Prior to the commencement of the public .comment period on EPA's
preferred alternative for the UCC site, EPA ~ublished their
Proposed Plan in local newspapers and distributed over 800 copies
of the plan to all interested parties included on the site
mailing list. EPA's preferred alternative involved four main
components: (1) on-site soil excavation-and low temperature soil
aeration treatment: (2) vacuum-enhanced groundwater extraction,
on-site treatment, and discharge to Quiggle Brook: (3) facilities
decontamination and demolition, and off-site disposal of debris;
and, (4) limited action for off-site soils. .
Implementation of the preferred alternative would require
removing the existing facilities at the site in order to reach
all of the contaminated soils identified for cleanup. The
facilities would undergo decontamination (and treatment of
hazardous wastes contained within the facilities) prior to
demolition and off-site disposal.
The contaminated soils which require excavation from the site
would be processed through a low temperature thermal treatment
. unit. Once the contaminants are volatilized from the soil and
the collected exhaust gases have also been treated, the treated
soils would then be used as backfill on the site or used to
recontour the area to promote drainage.
The contaminated groundwater existing throughout the shallow till
and weathered (shallow) bedrock aquifers under the site would be
removed for treatment through the installation of several vacuum-
enhanced extraction wells. The extracted groundwater would be
treated on the site utilizing a process referred to as
ultraviolet (UV)/oxidation which would destroy the contaminants
contained in the groundwater prior to discharge into Quiggle
Brook. contaminated soil gases captured by the vacuum-enhanced
wells would also be treated by vapor-phased carbon, at a minimum~
The limited action to be performed on areas surrounding the uee
site would involve the collection of site-specific meteorological
data and the acquisition of additional off-site soil samples for
chemical analysis.
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II.
BACKGROUND
Over the past six years, since EPA has taken the lead on cleanup
activities at the UCC Site, community interest and concern has
been significant. Residents have expressed particular concern
about the timing of remedial activities, the extent of
groundwater contamination, and the potential health effects of
the contamination existing on the Site. Two citizens' committees
have led communications with EPA regarding the Site: 1) The
Concerned citizens of Hope (CCH), and 2) Hope's Committee for a
Clean Environment (HCCE). These organizations have demonstrated
a strong interest in all Site activities through consistent
communication with the EPA Remedial Project Manager (RPM),
attendance at several public meetings, and ongoing meetings with
community residents to frame citizen concerns to both EPA and the
Maine DEP. In addition, local government representatives and
State environmental organizations have been active participants
in the Superfund process for this Site. Hope's Committee for a
Clean Environment was awarded a Technical Assistance Grant (TAG)
in March 1990, and has begun working with independent advisors
funded by EPA's TAG program during the public comment period on
the Proposed Plan.
EPA has had an active community relations program for the Site.
On-scene interviews for the Community Relations Plan (CRP) for
the UCC Site were held in November 1987, and the CRP itself was
developed in February 1988. Since that time, EPA has issued
numerous fact sheets to update the community on the progress of
all activities at the Site. In February 1988, EPA issued a fact
sheet describing the residential well sampling program, State and
PRP involvement, groundwater monitoring results from existing,
on-site test wells, and an explanation of the Remedial
Investigation and Feasibility Study (RIfFS) process as it relates
to the UCC Site. A public meeting was also held in February 1988
to further discuss these topics and to address citizen concerns.
A second fact sbeet was issued in May 1988. This fact sheet.
described the RIfFS work plan prepared by the PRP contractor, and
provided a summary of results from additional sampling activities
performed by EPA on local residential wells. During this same
time period, EPA established a 24-hour, local hotline
specifically to answer the public's questions about the Site. A
third fact sheet was issued in September 1988, updating the
community on the range of completed and proposed activities at
the Site.
In January 1989, EPA issued a fact sheet explaining the initial
site characterization and the progress of the RIfFS. Over the
next year, EPA conducted a series of informal availability
sessions, public meetings, and small group meetings with
community interest groups to provide continual updates on the
progress of the RIjFS. The Agency also distributed a series of
public information updates and press releases on the status of
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site activities. This stage of activity culminated in the
development of the four (4) volume Final Draft RIfFS report for
public review and comment.
The Proposed Plan fact sheet was distributed in July 1990 and
provided the community with a comprehensive summary of Site
activities and the results of tests conducted over the previous
two (2) years. EPA also placed the Administrative Record, the
Final Draft RIfFS report, and several copies of the proposed Plan
in the two (2) site information repositories in July 1990.
To obtain public input on the Final Draft RIfFS report and the
proposed Plan, EPA originally scheduled a 30-day public comment
period which began on July 13, 1990 and was scheduled to conclude
on August 12, 1990. However, based upon several requests from
local citizens and congressional interest, EPA approved two
extensions of the original, 30-day comment period. These two
extensions provided the public with an 8S-day public comment
period which ended on october 5, 1990.
EPA's community relations efforts during the 8S-day public
comment period included: public meeting notices in the Camden
Herald and courier-Gazette on July 5, 1990 to announce the
availability of the Administrative Record and invite public
comment on the proposed Plan: an informal public meeting on July
12, 1990 to present the Proposed Plan and distribute the Proposed
Plan fact sheet: several mailers to community residents to
provide an update of site activities and outline the superfund
process: and four public hearings held between August 1, 1990 and
september 17, 1990 to provide citizens with the opportunity to
comment on the Proposed Plan.
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%%1.
COMMENTS AND BPA RESPONSES
A.
Summary of Comments from Residents, TAG Advisors and
Other Interested Parties.
This section provides a detailed summary of the comments received
by EPA during the public comment period from residents, the three
(3) TAG advisors for HCCE, and other interested parties. These
comments are organized into the following subcategories: 1) Site
History; 2) Remedial Investigation Process; 3) Remedy Selection
and Implementation; 4) Groundwater Treatment; 5) Soil Treatment;
6) Testing; 7) Health and Environmental; and 8) Miscellaneous.
A summary of the comments and EPA's response to them are provided
below.
1.
Sit. History
comment a:
A representative of the Concerned citizens of Hope
requested that the fOllowing changes and/or clarifications
be made to the Proposed Plan:
- Page 4, paragraph 1: the paragraph reads that
entire Site is closed (fenced-in) when, in fact,
is access to the Site along the easterly border;
is also access on the westerly side.
the
there
there
Page 4, paragraph 2: the citizen requested that
this paragraph contain the following additional
historic~l facts: 1) from 1967 on, the stripping of
furniture, including antique furniture that was
painted with lead-based paint, was carried out on-
site; 2) the sludge was disposed of on-site in three
ways, which were in barrels within the dipping room,
through a trap in the cement floor, and into an
underground storage tank.
Page 4, paragraph 3: the Wright-Pierce report is
indicated herein as a overall, site-specific study;
the fact of the matter is that this was a leach field-
specific study intended to simply get a handle on the
contamination at that specific location on the UCC
property.
Page 4, paragraph 4: the paragraph contains an
incorrect conclusion in its reference to the
Wright-Pierce report. The conclusion states that the
groundwater in the till flows easterly and discharges
into Quiggle Brook. The citizen stated that the RIjF?
study revealed that the contamination is flowing
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/
east-southeast and southerly. She also requested that
EPA specify on pages 4 and 6 of the proposed Plan that
the groundwater flow findings of wright-Pierce were
the results of non-pumping conditions.
Page 6, paragraph 1: The paragraph incorrectly
states that contamination does not go underneath the
brook. The citizen asked EPA to review the test
results of the wells on the east side of the brook,
and correct the paragraph accordingly.
~
Page 7, at the top of the page: the sentence
states that the Union Chemical Company is now known as
union Research Company, with Dr. Raymond Esposito as
its president. The citizen also stated that the
company has further changed its name to the Seneca
Research, a New York corporation, which is owned by
Dr. Esposito's daughter (with Dr. Esposito as sole
manager and licensed operator of the New York
facility).
paqe 7, paragraph 2: the paragraph discusses the
concentrations of volatile organic compounds (VOCs)
detected. The citizen stated that she does not like
EPA's use of the terms "most notably" in this
discussion and requests that this paragraph specify
all of the contamination found.
Page 7, paragraph 3: the discussion of the
historical operation of several on-site water supply
wells requires clarification. The citizen questions
the paragraph's use of "limited extent" when
describing off-site deep bedrock and groundwater
contamination since, at this time, there is
insufficient information to state that such
contamination is in fact "limited."
Page 7, last paragraph: The paragraph states that
the contamination found in the Johnson well has not
exceeded and currently does not exceed Federal or
state of Maine drinking water standards. The citizen
does not believe that the contamination in the well
exceeds state standards, but raised concerns because
this residence is for sale.
~PA ReSDonse:
While it is inappropriate at this time to make changes to
the proposed Plan as requested by these individual
comments, EPA has attempted to correct and better clarify
these historically-related concerns in the ROD at Sections
I and II. Additionally, EPA agrees with this commenter
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. that the Site history is very important in order to base
the cleanup on. However, EPA does not feel that any of
these changes would significantly change the preferred
remedial alternative which EPA identified in the Proposed
Plan issued in July 1990, or in the Selected Remedy as
stated in the ROD at Section X.
Furthermore, with respect to the comment regarding page 4,
paragraph 1, it is true that there is access to the Site
along the easterly border and on the westerly side of the
UCC property (which is included as a part of the Site).
However, while access to these areas is unrestricted, the
Baseline Risk Assessment considered these areas of the Site
separately from the areas of the site enclosed within the
fence. The results of the Baseline Risk Assessment
indicate that the current risks to the contaminated soils
in these unrestricted areas falls between 5 x 10-6 to 7 X
10-8 for carcinogenic compounds, and well below a hazard
index of 1. The significant risks in these areas of the
Site is principally from the groundwater located underneath
the ground surface at present.
Finally, with respect to the comments regarding page 6,
paragraph 1 and page 7, paragraph 3, EPA still maintains
that no contamination from the UCC Site has migrated
underneath Quiggle Brook towards the east, and that
"limited" off-site bedrock contamination exists primar'~ly
in residential well # 20 located north from the site. In
particular, residential wells (primarily dug wells) that
are topographically upgradient and east of the Site, and
that have shown contamination below drinking water
standards, have not been linked to the groundwater
contamination on the Site. Furthermore, the existing
groundwater sampling results from both on-site and off-
site wells is extensive enough in EPA's opinion to provide
a sufficient basis from which to make such conclusions. In
addition, recent (November 13, 1990) Maine DEP test results
from selected residential wells (both dug and drilled)
located east, west and southeast of the Site did not detect
the presence of volatile organics in the drinking water
(including vinyl chloride at a detection limit of less than
1 ppb). However, EPA has stated in the ROD that the
groundwater both on- and off-site (including within
residential wells) will continue to be monitored throughout
the remedial design and remedial action.
comment b:
One individual indicated in writing that the figure located
on page 10 of EPA's handouts for the four public hearings
improperly represented the proposed volume of soil to be
excavated under the preferred source control alternative
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. .'''. - - ---.
.. '.'--" _._. ._..
(SC-5: Case A.1). The commenter suggested that a revision
to this figure to reflect the proposed excavation and
treatment of 8,500 cubic yards of soil is in order.
J:PA ReSDonse:
EPA disagrees with this comment for several reasons: (1)
the actual volume of soil to be excavated is only an
approximation at the present time and may increase or
decrease once remedial design and remedial action begin:
(2) EPA has selected the Case B version of the SC-5
remedial alternative option in the ROD, in contrast to the
Case A.1 version of the SC-5 remedial alternative presented
in the Proposed Plan, based upon public comments: (3) the
figure which was used at the public hearings does
accurately reflect the estimated 8,500 cubic yards of in-
place soil required for excavation under Case A.1, but a1so
shows an additional 2,000 cubic yards which is only
representative of the Case B option only: and (4) excluding
the Case B area identified by cross-hatch lines and dots
(2,000 cubic yards), the total volume represented by all
other areas shown on this figure totals 8,500 cubic yards.
comment c:
A citizen expressed concern that EPA is only looking at the
site as if it existed from 1978 to 1986, yet the operations
began at the UCC facility in South Hope, Maine in 1967.
EPA ReSDonse:
EPA agrees with this commenter's concern. However, much of
the historical information available regarding the UCC
facility in South Hope, Maine and the environmental
concerns posed by this facility did not materialize until
approximately 1976-1978. In fact, the state of Maine
Department of Environmental Protection (DEP) did not
discover the environmental problems at this facility until
September 1979 when groundwater and surface water
contamination was initially identified. Prior to 1976, the
Union Chemical Company conducted only limited reclaiming
and recYCling of solvents on the site. The commenter is
referred to Appendix A (Volume 2 of 4) of the Final Draft
RI/FS for a chronological fact sheet of the UCC site
prepared by the Maine DEP.
2.
Remedial IDvestigation Process
comment a:
A TAG advisor for Hope's Committee for a Clean Environment,
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commented that groundwater contamination may now or in the
future spread into the deeper bedrock, which is the source
of many people's drinking water. He suggested that
contrary to the findings in the RI report, the groundwater
does have vertical movement through the bedrock and
identified three wells, one south of the Union Chemical
plant and residential wells number 9 and 20, that have
shown contamination and suggested that the contamination
may be the result of downward movement of contaminated
groundwater. In addition, this commenter suggested that,
while groundwater flow in the shallow bedrock in the
vicinity of the site is toward the brook, there is a
larger, deeper flow to the west as part of a sub-regional
flow system. The "conceptual illustration" provided with
these comments was based on a "piezometric surface" map in
the bedrock for all of Knox County, as referenced from the
Maine Geological Survey report prepared by B. Caswell.
This TAG advisor recommended that, in order to further
define bedrock contamination, it is necessary to install
additional, deeper monitoring wells on and off the Site.
As such, the TAG advisor requested that EPAconduct
additional groundwater monitoring, placing monitoring wells
to the west and southwest of the site that are deep into
bedrock. One advisor suggested six bedrock wells be
installed in this area, at least 300 ft. deep. The advisor
stated that the wells should be constructed to allow
sampling of individual fracture zones while preventing flow
between fractures through the wellbore. This advisor also
suggested that heads in individual fractures should be
measured in these monitoring wells, in the on-site
production wells, and in some residential wells. If these
measurements do not confirm that the regional flow is to
the west, additional bedrock monitoring wells will be
needed in the indicated directions.
EPA ReSDonse:
EPA agrees that the groundwater does flow both laterally
and vertically in the bedrock beneath the UCC Site and the
surrounding areas. Both natural flow and artificial flow
induced by the effects of groundwater pumping have
contributed to the transport and distribution of
contaminants on and off the Site. Chemical and hydraulic
links have been established between the UCC site and well
ODW and residential well # 20. contamination found in
these two wells appears to be primarily due to the effects
of pumping these wells, which has caused contamination to
be conducted to them.
Water quality data from residential well # 9 indicates that
low concentrations (less than 2 ppb) of certain organic
11
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- ---.-.--
compounds are present. However, no clear hydraulic link
bas been established with the UCC site and, therefore, no
conclusive chemical link can be made at this time.
Furthermore, the concentrations of these organic compounds
have not been found to exceed their respective drinking
water standards. EPA will likely monitor this residential
well during the remedial design and remedial action due to
the presence of these organic compounds. Any deterioration
of the water quality in this well will prompt EPA (and most
likely the state DEP) to re-examine the current status and
the need for further response actions.
EPA does not dispute the possible existence of a sub-
regional flow system beneath the site. However, EPA does
disagree with the use of the reconnaissance map contained
in the Caswell report for generalized, county-wide
conditions as a basis for establishing local and sub-
regional bedrock flow configurations in the vicinity of the
UCC site. The data used to make these conclusions are
sparse (i.e. only two wells within two (2) miles of the UCC
site, both located east of Quiggle Brook, are available in
the reference report) and probably represent bedrock well
conditions from wells of varying depths, and using variable
seasonal water level data. Based on the topography alone
in the vicinity of the site, sub-regional flows appears
more likely to flow southwest rather than west. It should
be noted that the Caswell report also cautions that "...
the information and maps in this report represent
'reconnaissance investigations,' and are of necessity
generalized. Accuracy is limited to the intensity of
detail shown on the scale of the maps used (1:125,000)."
Finally, during the remedial design, additional groundwater
quality and water level data will be collected (at a
minimum) at selected, existing monitoring wells and new
monitoring wells located at the compliance points for the
site. This additional data will be used to refine (if
needed) the present understanding of the lateral and
vertical distribution of contamination and hydraulic head,
determine effective hydraulic capture zones, and monitor
progress in groundwater remediation. This additional field
work may also include (as needed) an investigation of the
vertical head and water quality variations with depth at
selected locations off the site.
comment b:
A TAG advisor expressed concern that Canonie did not
estimate groundwater risks based on worst-case scenarios
but rather, used EPA's guideline of ingesting two liters of
water per day.
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--- ....
EPA ResDonse:
As noted by this TAG advisor, EPA's risk assessment
approach for estimating groundwater risks is to use the
standardized exposure assumption for the drinking water
ingestion rate of 2 liters per day. This daily ingestion
rate represents the 90th percentile value based upon data
compiled for adults (see EPA/600//8-89/043; Final Report;
Exposure Factors Handbook). As stated in this reference,
the value of 2 liters per day reflects the reasonable
worst-case drinking water consumption rate for adults. In
order to provide consistency among individual site-specific
risk assessments throughout EPA, this standardized value is
utilized.
comment c:
The advisor also stated that a re-evaluation of the
exposure characterization for groundwater exposures is
recommended since it excluded dermal adsorption and
inhalation. The advisor stated that inclusion of these
exposure pathways could increase the estimated risks by at
least 1.5 to 2.0 collectively.
EPA ReSDonse:
EPA believes that the groundwater risk characterization
contained in the Baseline Risk Assessment is technically
sound and has been prepared following the appropriate
Regional and EPA Headquarters guidance documents.
Additionally, the risk estimations from groundwater at the
UCC Site, in accordance with these two guidances, includes
only ingestion and excludes the dermal and inhalation
pathways for the following reasons: (1) there is no
toxicity information (i.e. reference doses or cancer
potency factors) currently available for dermal routes of .
exposure and only limited toxicity information is available
for inhalation exposures; (2) the mechanisms by which
chemicals are absorbed by the skin or evaporated into the
air and subsequently absorbed by the lungs are complicated
issues which still require considerable research at this
time: currently available theories and computer models to
estimate these mechanisms have not been accepted by EPA;
(3) all currently available drinking water standards and
health advisories established by EPA are based on ingestion
only due to such scientific uncertainties; and (4) the
dermal and inhalation exposure pathways through normal
household use (including showering) are only of short
durations and contact times.
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comment d:
A TAG advisor cited that Canonie did not use a special
diagnostic procedure or take the necessary precautions
during the ~ to specificallY look for vinyl chloride in
the water. Another TAG advisor stated that the near-
absence of vinyl chloride at the site is highly anomalous
and that, in many cases, the groundwater samples were
diluted so much that the detection limits for vinyl
chloride were quite high.
~PA ReSDonse:
EPA agrees with a portion of this comment that no
specialized sampling or analYtical procedures (other than
EPA standard procedures) were incorporated into the
Remedial Investigation for the purpose of identifying vinyl
chloride specifically. However, EPA did not ignore the
fact that vinyl chloride could be present at the UCC site.
Due to the existence of several of the precursor analytes
such as 1,1-dichloroethene, and cis- and trans-1,2-
dichloroethene (which ultimately transform into vinyl
chloride under certain biodegradation conditions), the
presence of vinyl chloride mayor may not be present today.
EPA further agrees, to a point, that some groundwater
samples required dilution due the high concentrations of
several other volatile organic compounds in the same
sample. However, based upon a review of the analytical
data collected by Canonie, many of the groundwater samples
analyzed for vinyl chloride did not require any dilution.
In these instances, the detection limit achieved for vinyl
chloride was 10 ppb or less for approximately 80 percent of
these samples.
In summary, the presence or absence of vinyl chloride in
the groundwater at the site would not have and has not
changed the groundwater remedial action selected for
implementation at the site. In fact, due to the concerns
originally raised by EPA and the Maine DEP (prior to the
public comment period on the Proposed Plan) about the
presence or absence of vinyl chloride and the known
carcinogenicity to humans of this organic chemical, a
groundwater cleanup level for vinyl chloride was
established at its MCL of 2 ppb. This groundwater cleanup
level still exists in the ROD, and the groundwater
monitoring to be conducted during the remedial design and
remedial action will have to further investigate the
presence or absence of vinyl chloride to achieve this
requirement prior to completion of the remedial action at
the site.
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....
- --.--- .--
comment e:
A TAG advisor suggested that the target cleanup levels
listed for vinyl chloride, carbon tetrachloride, lead, and
chloroform are not health protective.
EPA ResDonse:
Groundwater cleanup levels for vinyl chloride, carbon
tetrachloride, lead and chloroform have been set at MCLs.
MCLs are enforceable standards under the Safe Drinking
Water Act (SDWA) which represent the maximum level of
contaminants that is acceptable for users of public
drinking water supplies. MCLs are established after
opportunity for public review and comment. The Federal
Register notices establishing these MCLs note that these
levels are considered protective. In addition to using
MCLs as cleanup levels, EPA is requiring that residual risk
be recalculated after attainment of the MCLs in the
groundwater. If at that time, the cumulative residual
carcinogenic risk of all contaminants exceeds 10-4, EPA
will reqqire further action to reduce the residual risk to
below 10"4, consistent with the NCP. Accordingly, EPA
believes that the remedy is protective of public health,
welfare and the environment.
comment f:
A TAG advisor stated that the RI prepared by Canonie did
not adequately consider the problem of volatilizing the
Site chemicals during the decontamination processes.
EPA ResDonse:
EPA strongly disagrees with this comment. First, a
Remedial Investigation (RI) is not intended to characterize
the problems suggested by this comment since the RI does
not involve an evaluation of decontamination processes,
this is conducted in the Feasibility study (FS). Second,
the RI did investigate the potential problems associated
with volatilization of Site chemicals through the
performance of air monitoring at the Site fence-line and
off-site during the conduct of the RI. No evidence of
volatilization of Site chemicals was found during the RI at
any of these perimeter locations on the Site, or at the
off-site location immediately across Route 17 from the
site. These air monitoring samples were purposely
collected during the very hot summer months of 1988, at
which time the volatilization rate of these Site chemicals
should have been extremely high in comparison to the spring.
or fall time periods. Finally, as raised during the publ ic ,"
comment period by several TAG advisors and citizens, EPA is
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concerned with the volatilization of site chemicals, not
only during the decontamination processes but also during
the excavation and treatment of contaminated soils. As
such, the ROD states that throughout all phases of the soil
excavation, treatment, and decontamination steps (at a
minimum), every effort will be made to minimize or mitigate
any airborne releases of volatile organic and particulate
emi~sions from the Site in order to protect the public
health, welfare and the environment.
comment a:
A TAG advisor recommended that a steering committee of an
adequate representation of groups within the Union Chemical
site community, including people with technical expertise
outside of EPA and DEP, be appointed to oversee the
remediation process.
EPA Res'Donse:
EPA's technical assistance grant (TAG) program is
specifically designed to provide such community input and
oversight. The TAG program may be used "... to obtain
technical assistance in interpreting information with
regard to the nature of the hazard, remedial investigation
and feasibility study, record of decision, remedial design,
selection and construction of remedial action, operation
and maintenance, or a significant removal action at a
facility..." [53 Fed. Reg. 9736, 750]. EPA and the Maine
DEP stated at one or more of the public hearings held
during the summer and fall of 1990, that they would be
willing to work with a the TAG group and other citizens
within the UCC site community to provide meaningful public
input into the remedial design and remedial action to be
performed at the site. Both EPA and DEP staff have
benefited from the valuable input that many of the citizens
and, more recently, the TAG advisors involved with the UCC
site have provided over the last three years.
comment h:
A TAG advisor expressed concern that Canonie did not
include in the RI report a discussion of the chemicals that
EPA found through split sampling methods, nor did Canonie
investigate the semi-volatile chemicals that were found in
the groundwater.
EPA ReSDonse:
EPA disagrees with this comment. More specifically,
Appendix R (Volume 3 of 4) of the Final Draft RI report
contains the results for the vast majority of EPA split-
-------
samples obtained during the conduct of the RI performed by
Canonie. Furthermore, Appendix Y of the RI report contains
the field audit reports prepared for those samples for
which EPA personnel conducted, unannounced quality
assurance/quality control investigations of the field
sampling procedures Canonie was following during the RI
sampling efforts. Based upon EPA and Maine DEP review of
these split-sample results (particularly, those obtained
during the field audits of both residential and on-site
monitoring wells), no further discussions were warranted
regarding these split-samples since these results were
essentially equivalent to those obtained by Canonie from
their own samples and laboratory analysis. Finally, the
semi-volatile chemicals identified by both EPA and Canonie
in the groundwater were assessed in the RI report (and,
more importantly, in the Baseline Risk Assessment), but
were not considered to require further evaluation since
these semi-volatile compounds were not selected to
represent contaminants of concern at the site.
comment i:
A TAG advisor recommended that the possibility of chemical
interactions which could increase toxicity should be
included in the Risk Assessment and any known interactions
should also be included in the Risk Assessment.
EPA ResDonse:
The Agency acknowledges that there may be many chemical
interactions occurring at the UCC Site (both in the s011s
and the groundwater). However, given the large number of
contaminants identified at the Site, it is extremely
difficult, if not technically impossible, to thoroughly
develop and analyze all the possible chemical interactions.
and resulting chemical mixtures that are potentially being
generated at the site. At present, there are only a .
handful of toxological studies available on such chemical
interactions. These toxicological studies are
siqnificantly limited in scope: only animals which have
been subject to acute exposures from the potential
interactions of only two chemicals at one time have been
investigated. As stated above, there are approximately 70
contaminants at this Site. Chronic exposures rather than
acute exposures were the pathways generally evaluated in
the Baseline Risk Assessment for the UCC Site, which is
consistent with the methodologies employed for other
Superfund sites. Furthermore, there are also considerable
uncertainties regarding the extrapolation of the results of
toxicological information from animal studies to humans.
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is effectively aChieving the performance goals established.
90mment c:
Residents and TAG advisors requested assurances that
adequate air, water and soil monitoring be conducted during
Remedial Action and provisions are incorporated to ensure
that all possible contaminants have been adequately
identified and previously undetected contaminants will not
appear in future investigations.
EPA ResDonse:
EPA believes that the comprehensive RI adequately
identified the contaminants at the site. One possible
contaminant, DMF, was not sampled for in the RI but
saEpling will be conducted during the remedial design and
remedial action. EPA's selected remedy also includes the
following sampling and monitoring programs: (i) monitoring
of air contamination during the soil excavation, soil
treatment, groundwater extraction, and facilities
decontamination and demolition phases of the cleanup: (ii)
groundwater monitoring to measure the success of the
groundwater portion of the remedy: (iii) surface water
monitoring to ensure that water quality standards in
Quiggle Brook will be attained: (iv) monitoring of on-site
soils to ensure that soil cleanup levels and standards are
being met: and (v) monitoring of off-site soils to further
define any off-site contamination that may be related to
past operations of the UCC incinerator. EPA believes that
these monitoring programs will be adequate to evaluate site
conditions during cleanup. In addition, pursuant to
Section 121(c) of CERCLA, EPA will conduct periodic reviews
to assure that human health and the environment are being
protected by the remedial action.
comment d:
A TAG advisor stated that steamcleaning would be, in
cases, an unnecessary cleanup step and could present
to the community. The TAG advisor also asked EPA to
detail how the steamcleaning process would work: 2)
identify how many monitors would be placed, as well as the
chemicals that would be monitored: 3) consider that, under
certain meteorological conditions where there is a
temperature inversion or no wind, remedial action
activities should be slowed down or stopped: 4) identify
the noise levels to which the site community may be exposed
during the entire cleanup operation: 5) provide
arrangements that address emergency health problems that
may arise if an unexpected problem should occur during
cleanup: and 6) provide for temporary relocation if people
some
a risK
1)
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3.
Remedy Selection and Implementation
comment a:
A number of residents expressed concern that provisions be
made to relocate residents during cleanup actions if
conditions become detrimental to public health.
EPA ResDonse:
EPA does not believe that the conditions expected during
the cleanup actions will present a risk to public health.
As stated in the ROD, EPA will take the necessary steps
throughout all phases of the soil excavation, soil
treatment, vacuum-enhanced groundwater extraction, and
demolition and decontamination of facilities to minimize or
mitigate the airborne release of volatile organic and
particulate emissions to protect public health. These
steps will include, but are not limited to, controlled
excavation techniques, dust suppressants, coverings, the
use of carbon adsorption or an equivalent treatment method
to comply with air toxics and particulate standards, and
frequent monitoring. These measures will provide
protection of public health during remediation, and EPA
does not believe that relocation will be required. If
conditions change so that the cleanup action poses
significant risks that are not present at this time, EPA
will evaluate and require (as necessary) additional
measures in order to ensure protection of public health and
the environment.
comment b:
Some residents inquired whether they would be supplied with
an alternate water supply during cleanup activities to give
added assurances that they will not consume contaminated.
residential well water during Remedial Action.
EPA ResDonse:
CUrrently, there is no evidence that drinking water wells
near the Site area are contaminated above levels which are
unsuitable for drinking. Remediation activities to be
performed at the UCC Site are designed to initially contain
and eventually cleanup the groundwater contamination that
exists. Groundwater extraction activities will be designed
to effectively prohibit new or additional deterioration of
the groundwater quality associated with the Site in
existing wells. Thus, the need for an alternative water
supply appears to be unnecessary. Water quality monitoring
on the Site, and in selected residential wells, will be
maintained to ensure that the groundwater extraction system
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are getting ill from the steamcleaning. The TAG advisor
also encouraged EPA to crush contaminated boulders and feed
them directly into the feed hopper of the soil aeration
system without prior steam cleaning.
~PA ReSDonse:
EPA proposed steamcleaning as a means of removing volatile
organics embedded in the building materials at the site.
Through steamcleaning, EPA hopes to eliminate as much
hazardous material and dust (through the wetting action of
steamcleaning) as possible from these building materials
prior to initiating the demolition operation, and also
limit the amount of hazardous material that must be
disposed of in a secured landfill.
The exact procedures to be used during thesteamcleaning
operations and the air monitoring equipment locations to be
employed throughout all phases of the remedial action will
be detailed in the comprehensive Work Plan that must be
prepared and approved by EPA prior to the commencement of
any remedial activities at the site. In addition, the
steamcleaning operations must also include means of
attaining the noise abatement levels set out in Maine's
regulations promulgated under the site Location of
Development LaW. As stated above in response to comment
3.c, EPA believes that the air monitoring and mitigative
measures included in the ROD will afford adequate
protection so that relocation is not expected to be
necessary. Finally, the remedial action must include a
contingency plan and emergency procedures that will be used
in the case of a release which could threaten public health
or the environment. These plans will also be developed and
approved by EPA during the remedial design for
implementation during the entire remedial action.
Finally, EPA has very carefully considered the TAG advisors
comment regarding the crushing of contaminated boulders
without prior steamcleaning. EPA agrees that this step is
unnecessary since the boulders will be treated in the low-
temperature soil aeration unit following this operation,
and has made the appropriate modification in the ROD.
comment e:
A representative of the National Toxic Campaign commented
that there is no evidence that an effective stabilization
method for dioxins exists that will prevent escape into the
environment during the decontamination and demolition of
facilities.
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-.- ---
-- -----
. EPA ReSDonse:
EPA plans to stabilize the dioxin present in the secondary
scrubber ash of the incinerator through a cementation
(solidification/stabilization) process. This technology will
also effectively encapsulate the heavy metals also contained
in the ash. This method of treating heavy metals is a proven
technology, and is considered the best demonstrated and
available technology (BDAT) for these types of contaminated
materials. Furthermore, the dioxins which are also present in
the contaminated ash will be stabilized as well. Although
this method has not been demonstrated for dioxins, the
chemical properties of dioxin are similar to heavy metals (and
PCBs) for which this technology has been applied at other
Superfund sites across the country. Thus, the stabilization
process that EPA is proposing for the dioxin-containing ash is
similar to the process that the Agency would use to stabilize
materials with significant concentrations of heavy metals
alone (without dioxins present).
comment f:
A representative of the National Toxic Campaign expressed
concern that sediment samples from Quiggle Brook have revealed
lead, but that EPA has not formulated plans for remediating
the contaminated sediment in the brook and other bodies of
water. Furthermore, a TAG advisor recommended that sampling
points along Quiggle Brook be resampled at times of low,
normal, and high streamflow. The advisor recommended that if
significant contamination is detected, appropriate remedial
actions should be undertaken.
EPA ReSDonse:
EPA is not requiring any remediation within Quiggle Brook due
to the significant variability and limited extent of lead
contamination (and PAH contamination) near the site; only one
sediment sample showed lead concentrations at 156 ppm, while
follow-up sampling at this same location has repeatedly shown
lead levels within typical background levels (i.e. 14.1, 8.4,
and 9.0 ppm, and total PAH concentrations were approximately
20 ppm. EPA (in consultation with the Department of Interior,
Fish & Wildlife Service) also feels that any remediation of
the lead and/or PAH contamination within the brook would
likely result in more harm than benefit to Quiggle Brook and
its associated wetland. Furthermore, EPA is indirectly
remediating the brook by selecting and implementing a
groundwater extraction and treatment remedy on the site. This
remediation effort will initially contain the contaminated
groundwater from continuing to migrate into the brook and
finally pump and treat the groundwater prior to discharge back
into the brook.
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~omment a:
A representative of the National Toxic Campaign asked whether
EPA bas a written plan that identifies and describes the
"appropriate actions" that EPA will take if an exposure risk
should occur during excavation activities at the site.
EPA ReSDonse:
The appropriate actions that will be taken if an exposure risk
should occur durinq excavation activities include but are not
limited to: 1) ceasing the cleanup operation and reevaluating
the situation, 2) adding a foam dust suppressant to the
operation, or 3) applying spray materials to the loading or
unloading hoppers to suppress dust emissions. In addition,
EPA will require that a contingency plan and emergency
procedures be developed during the remedial design which will
require an identification of the steps that will be taken in
the event of a release that threatens public health.
comment h:
One commenter suggested that data collected during the
Remedial Investigation related to the packer installed in
residential well number 20 should be considered invalid
because it does not represent groundwater flow patterns that
exist naturally or patterns that will develop as the
extraction and treatment system is installed and put into
operation.
EPA ReSDonse:
EPA considers the water-quality data gathered from residential
well # 20 during the packer tests to be valid data based upon
the purpose for which these data were collected. The test was
conducted using a packer to maximize the inflows in the upper
fracture system while keeping overall pumped water volumes at
a minimum. The results show that a hydraulic connection does
exist between the well and the UCC site, and that contaminants
reached the well, probably under the influence of pumping
within the well. Under non-pumping conditions, the well lies
upgradient of the site and it is unlikely that contaminants
flowed in a northerly direction under these conditions.
When the on-site groundwater extraction and treatment syste~
is in operation, it is even less likely that contamination
will move upgradient toward this well. However, if
residential well f 20 (or a similar well) is put into
operation and its capture zone extends into the area of
contamination on the UCC site, then its operation would cause
contamination to be transported from the site contradicting
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the intent of remedial activities at the Site.
comment i:
One commenter recommended that water levels in residential
well number 20 and several other wells be monitored during the
cleanup process, and that the installation of a transducer and
continuous monitoring equipment would facilitate the
collection of data and lead to a better understanding of the
dynamics of the groundwater table prior to and during the
groundwater extraction process.
~
EPA ResDonse:
EPA essentially agrees with this comment. Periodic monitoring
of water levels and chemical concentrations will take place at
a number of locations in and around the UCC site. Residential
well f 20 will likely be one of these locations, in addition
to residential well # 9. The use of continuous monitoring of
water levels (including the use of transducer) will most
likely take place throughout certain phases of the remedial
design which would involve field work. The exact locations
and time periods to be monitored will be determined more fully
during the remedial design.
comment i:
Several commenters urged EPA to develop a schedule that call~
for the commencement of cleanup to begin as soon as possible
in 1991, so that on-site contamination does not further impact
off-site properties.
EPA ReSDonse:
Regarding the timing of the cleanup activity, EPA operates
within a time frame set forth by the CERCLA statute. After
the Record of Decision (ROD) is signed, EPA will issue a
notice to the PRPs and allow 60 days for them to respond with
a good faith offer to perform the work as it is presented in
the ROD. If there is no offer to perform the work, EPA has
several options. These options are to: 1) use the Fund to
pay for the cleanup, 2) issue a unilateral order forcing the
PRPs to perform the cleanup, or 3) negotiate with the PRPs for
another 60 days, in order to work out any details in the PRPs'
plan for cleanup. After one of these options is initiated,
the timing depends on the time necessary to hire a qualified
contractor to perform the work as outlined, and on the public
comments received on a settlement agreement reached with the
PRPs. This time frame can also be extended due to other
variables, such as an extended public comment period, which
affects the scheduling of EPA and State staff needed to review
data and help develop the ROD.
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EPA appreciates the interest of the community in expediting
the process and moving toward cleanup activity more quickly.
EPA will be working with the state and community in addressing
the comments and proposed resolutions presented in these
public hearings so that the ROD can be signed and the process
can continue.
comment k:
One commenter inquired whether or not EPA could definitively
determine where incinerator fall-out is located based on the
proposal of the Limited Action for Off-Site soils alternative.
This commenter stated that unless EPA has information on the
weather conditions at the time the UCC incinerator was
running, it will be impossible to determine where the high
impact area is located today.
EPA ReSDonse:
Definitively determining the locations of all fall-out from an
incinerator that operated some 6 to 8 years ago is extremely
difficult, if not impossible. EPA has used its best
engineering judgement in "trying to locate contaminated areas
off the site. To date, EPA has randomly collected samples in
residential yards and has used computer simulations to select
the optimal locations for sampling soils in both residential
and wooded areas surrounding the site.
The remedy calls for the continuation of these efforts to
further identify additional, possible contaminated locations
off the site. EPA believes that, taken together, these
methods represent a comprehensive effort to identify the
possible areas, if any, where contamination from past
operations on the site may be located in the surrounding
community.
comment 1:
A TAG advisor suggested that Dimethylformamide (DMF) was a
predictable contaminant of the site given the composition of
the proprietary solvent manufactured and used at the site.
This advisor also recommended that the Risk Assessment be
corrected by re-analyzing peaks found on the samples analyzed
for VOCs and appropriate risk factors integrated into an
abatement and remediation plan.
EPA ReSDonse:
EPA agrees with the commenter that DMF was a predictacble
contaminant and that EPA should have analyzed for DMF during
the RIfFS. However, EPA does not agree with the
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recommendation that a re-evaluation of previous analytical
results is the best approach at this site, or that appropriat~
risk factors should be integrated into this ROD using this
approach. EPA has addressed these concerns in the ROD in a
more scientific manner through the collection of additional
groundwater samples for the analysis of DMF. After the
results are available, EPA will consider the next step to be
conducted, which could include a modified risk assessment and
ROD modification to incorporate DMF into the cleanup plan.
comment m:
Two of HCCE's TAG advisors recommended that the site needs to
be sufficiently well enclosed and isolated such that
contaminated dusts (e.g. during excavation and asbestos
removal), dioxin-contaminated debris (from the dismantling of
the stack and furnace), and volatilization of high
concentrations of chemicals (e.g. from beneath the concrete
pads) not be released to the environment.
EPA ResDonse:
EPA agrees with these commenters to the extent that additional
mitigative measures must be incorporated" in the remedial
design and remedial action in order to address the concerns
raised regarding the potential releases of contaminated dust
or volatile organics into the surrounding environment. These
concerns and the types of mitigative measures which EPA is
considering are included in the ROD within Section X.B of the
ROD.
comment n:
A TAG advisor recommended that air modeling be used to
determine the maximum off-site levels expected for the"
chlorinated solvents as a group and for particularly toxic
chemicals such as vinyl chloride individually using the
assumption that as much as 10-50% of volatiles in the soil
could be released during these processes.
EPA ResDonse:
While EPA generally agrees that air modeling may be one
possible methodology used to determine the amount of volatiles
in the soil that could be released during the remediation
process, EPA has not determined that this will be the method
of choice. This is stated in the ROD as part of the selected
remedy. However, the use of the assumptions as offerred
herein will be considered further during the remedial design
and implementation (if required) of such air modeling efforts.
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comment 0:
A TAG advisor recommended that in order to ensure full
disclosure of the results of investigations, the ROD should
specify that all detections of chemicals will be reported,
with estimated values provided when concentrations cannot be
reliably quantified.
EPA ResDonse:
The ROD is an overall plan for remedial action at the site.
Details of the activities, such as sampling protocols and
reporting requirements, are addressed when EPA reviews and
approves or disapproves a detailed workplan. The decision on
what level of data validation that is required will be
addressed during the remedial design and remedial action.
comment D:
A TAG advisor recommended that all soil samples containing 50
mg/kg of lead or more should be considered to have been
contaminated by fallout from Union Chemical. He suggested
that this include the sample from the Crabtree property as
well as numerous samples from Brian power's home.
EPA ResDonse:
EPA cannot agree with this recommendation. As stated in the
RI/FS, the UCC incinerator is a possible or probable source of
lead contamination in the power's yard, since prevailing winds
would have carried incinerator and/or boiler emissions toward
this property. However, other nearby yards were not
contaDinated. In addition, there are other possible sources
of lead contamination. soil samples from other areas were
generally within the state of Maine's typical background
concentration levels for lead. EPA also notes that under
current site use conditions (as evaluated in the Baseline Risk
Assessment), the lead levels present do not appear to pose a
significant risk to human health. The commenter is referred
to Table 37 of Appendix X (Volume 3 of 4) of the Final Draft
RI report.
pomment a:
A TAG advisor suggested that the additional off-site soi1
monitoring proposed by EPA is insufficient and follows an
unnecessarily leisurely schedule. The advisor recommended
that locations where UCC facility produced visible fallout,
should be sampled immediately, without waiting for the results
of any meteorological studies. The advisor suggested that
once data are available, decisions on remedies should be reaje
as quickly as possible, without a five-year delay.
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EPA ResDonse:
EPA believes that its schedule for off-site soil monitoring is
appropriate in that it takes into account both the need to
collect data over 5 years' time in order to produce a sound
modelling effort of historical air emissions, and the need to
start sampling as soon as possible. The ROD provides that
sampling may begin after collection of one year of
meteorological data (or sooner, if required).
4.
GroUD4..~.r ~r.atm.D~
comment a:
A TAG advisor recommended, considering the absence of other
contaminants in Quiggle Brook and the fact that the stream
flows into a drinking water supply (i.e. Crawford Pond), that
a stricter water treatment requirement for discharge into the
brook should be adopted.
EPA Resoonse:
The remedy provides that, since Quiggle Brook is a tributary
to a drinking water source, the groundwater remedy will attai
MCLs in the effluent prior to being released into the brook.
For those contaminants for which no MCLs exist, Federal
Ambient Water Quality Criteria (AWQC) established for the
protection of public health must be attained. These
standards, which have been developed to protect users of
drinking water, are protective.
comment b:
A TAG advisor suggested EPA consider constructing a holding
basin rather than discharging water directly from the
treatment plant into Quiggle Brook. This advisor suggested
that without some sort of holding basin, untreated water would
be discharged to Quiggle Brook in the event of a treatment-
plant failure.
EPA ResDonse:
At the present time the actual groundwater treatment syste~
design components have not been finalized, but will be at t~e
completion of the remedial design. This comment will be
further evaluated during this phase of the system design anj
is likely to become a component of the final system installej
at the Site. This is likely to be required so that any 5YS:0~
malfunction will not impact the water being discharged int8 .
the brook, and will allow for the sampling of the treated
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water prior to eventual discharge.
comment c:
A number of commenters and a TAG advisor expressed concern
about treating contaminated groundwater and surface water and
discharging it into Quiggle Brook. The TAG advisor
recommended if discharge of treated water takes place,
continuous monitoring should be in place to assure the water
quality of the effluent meets drinking water standards.
EPA ReSDonse:
EPA aqrees that Quiqqle Brook must be closely monitored as
part of the remedial action in order to assure that discharge
of contaminated groundwater does not degrade the quality of
the brook. The selected remedy calls for periodic monitoring
of Quiggle Brook itself, as well as monitoring of the effluent
to be discharged into the brook. The effluent discharge must
attain MCLs or ambient water quality criteria for protection
of human health. The frequency of the monitoring will be
established more precisely during the remedial design and,
more importantly, will be developed to protect human health
and the environment.
comment d:
A representative of the National Toxic Campaign commented that
the proposed target cleanup levels for groundwater remediation
at the site would be considered too hazardous to be accepted
at a wastewater treatment plant.
EPA ReSDonse:
EPA uses guidelines developed under the Safe Drinking Water
Act to determine the maximum contaminant levels for
groundwater drinking standards. The target cleanup levels
that EPA is proposing for groundwater remediation at the Union
Chemical site are applicable or relevant and appropriate to
safe drinking water, and are the levels that must be met by
public drinking water supplies. The Superfund program does
not address wastewater treatment plants, but perhaps the
reason that the cleanup levels proposed for the Union Chemical
site would not be acceptable for wastewater treatment plants
is that they result in levels of substances that are toxic to
the bacteria in these plants.
comment e:
A citizen commented that the proposed Plan does not provide
sufficient information to allow an expert to assess the
effectiveness of the proposed system for extraction and
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treatment of groundwater.
EPA ResDonse:
EPA has determined the basic technologies that would be
appropriate to cleanup the Site do not require, at this time,
any additional information in order to select a remedy as
detailed in the ROD. Specifically with regards to treating
the contaminated groundwater on the Site, EPA makes the
determination in the ROD whether or not to leave the
groundwater as it is, to let it flush out naturally, or to .
pump the contaminated groundwater and treat it. EPA believes
that there is presently enough information to make such a
decision, even without the exact details in-place regards the
groundwater extraction and treatment system design. These
details will be developed and approved by EPA during the
remedial design of the system. Furthermore, the ROD states
that additional field work in the form of groundwater aquifer
tests will be performed during the remedial design to assist
in designing the most effective groundwater extraction and
treatment system for the Site in order to achieve the cleanup
levels required to return the groundwater to drinking water
standards. These details are not required in the Proposed
Plan in order for EPA to select a remedy in the ROD.
comment f:
A representative of the National Toxic Campaign commented that
EPA has made up standards for the chemicals in the Hope
groundwater, since safe standards for these chemicals have not
yet been established.
EPA ReSDonse:
EPA establishes cleanup levels using the federal and state
laws that either apply to a given situation or are relevant
and appropriate to the situation. In this case, groundwater
cleanup levels were set primarily at the respective
contaminants' maximum contaminant level (Mct), which are
promulgated under the SDWA. MCLs represent the maximum
allowable concentrations of contaminants in pUblic drinking
water supplies, and represent the levels that are met by
public water supplies that serve millions of people allover
the country. MCLs are set by EPA after a thorough scientific
review process and public comment period. For those
contaminants for which no MCL existed, cleanup levels were
established at the proposed MCLs or state guidelines for
maximum exposure.
comment a:
A representative of the National Toxic Campaign commented the
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the proposed treatment of groundwater with ozone and/or
hydrogen peroxide will have a minimal effect on dioxin, if it
is present.
~PA ResDonse:
EPA has no reason to believe that dioxin is present in the
groundwater at the Site. The chemical properties of this
compound and the limited extent of on-site contamination
within the buildings, strongly suggests that dioxin-
contamination in the groundwater is highly unlikely.
Furthermore, the groundwater contamination at the UCC site has
been very well documented to be from volatile organics
transported to the site. The existing dioxin-containing ash
within the secondary scrubber at the site was the product of
incomplete combustion of these volatile organics and not from
the disposal or otherwise of dioxin-contaminated materials on
the Site.
comment h:
A TAG advisor for Hope1s committee for a Clean Environment
raised concern that the area proposed for groundwater
extraction is limited and should be broader in scope. This
advisor a1so suggested that further expansion of the area to
be pumped may be required when the groundwater has been
monitored for DMF and glycol ethers, as requested through
other comments.
EPA ReSDonse:
Groundwater extraction areas and capture zones have not been
finalized at present. These areas or zones will be delineated
during the remedial design through the implementation of
additional field work, including (but not limited to) aquife~
tests, and will be monitored for effectiveness during the
remedial action. Appropriate adjustments will be made if
alterations of the extraction or monitoring systems are
required. Furthermore, based upon the additional analytical
data to be collected during the remedial design (specific to
the occurrence or not of DMF and glycol ethers), the potential
for expansion of the groundwater extraction area may be
required in the future.
comment i:
The project manager for The Concerned citizens of Hope (CC~!
commented that her group does not accept the conclusions O~
page 7 of EPAls proposed Plan, which are: 1) groundwater
flows beneath the site in an easterly direction (under nOr7.3~,
static, non-pumping conditions on the site) towards Quiggle
Brook. Quiggle Brook acts as a groundwater discharge poi~t
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for the contaminated groundwater flowing beneath the site; 2)
concentrations of several VOCs were detected predominantly in
the till and shallow bedrock monitoring wells located on the
site, most notably between the site and Quiggle Brook; 3)
historical operation of several on-site water supply wells has
drawn VOCs from the shallow bedrock into the deeper bedrock
groundwater both on and, to a limited extent, off the site;
and 4) elevated concentrations of VOCs in the groundwater are
related to the elevated VOC concentrations found in the soils
near the still building located on the site. She stated that
the conclusions are incomplete due to lack of data on
groundwater flow patterns under pumping conditions, proper
calculations of groundwater flow patterns and sound knowledge
of placement of proposed wells, the gallons per day total
groundwater to be removed, and complete data for off-site dug
well testing prior to any groundwater treatment.
The project manager for CCH further stated that, since the
conclusions on page 7 are incomplete, the remedial alternative
described on pages 17 and 18 of the Proposed Plan is also
unacceptable. She stated that this alternative, referred to
as MM-4: Vacuum-Enhanced Groundwater Extraction, On-Site
Treatment, and Discharge to Quiggle Brook, cannot be
responsibly considered until EPA has more answers.
EPA ReSDonse:
EPA disagrees that the RIfFS did not adequately characterize
groundwater contamination. EPA conducted extensive
groundwater sampling both on- and off-site, and on the Site
under both pumping and non-pumping conditions. (See Figure 47
of the Final Draft RI for the results of the bedrock aquifer
test performed during the RI).
Past groundwater pumping practices at the UCC facility, well
ODW and in residential well' 20 did affect the transport and
distribution of contamination at the Site. However, these
wells have ceased operation and the data indicate that the
contamination is localized and moving under the influence of
natural gradients to Quiggle Brook.
During the remedial design, estimates of the area needing
groundwater remediation will be refined, and the groundwater
extraction and treatment systems will be appropriately sized.
comment ;:
The project manager for The Concerned citizens of Hope
requested that all dug wells within a half-mile radius of the
Union Chemical site be tested under pumping conditions and
that a sample be collected prior to pumping, which would be
used as a control. She asked that a minimum of six addition,
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dug wells be constructed for monitoring purposes, and stated
that she will submit a more detailed plan prior to the end of
the public comment period.
EPA ResDonse:
Dug wells that lie downgradient or, if when pumped, are likely
to capture contaminated groundwater that may be migrating from
the site will be examined and monitored as appropriate during
the remedial design and remedial action.
However, at present, no groundwater extraction is taking place
on the site and, therefore, non-pumping conditions exist.
While the UCC facility was active, groundwater was extracted.
and recharged on the site. These activities greatly effected
the distribution, direction, and rates of transport of
whatever contaminants entered the subsurface. In addition,
two wells (residential well # 20 and on-site production well
ODW) are known to have actively conducted contamination away
from the UCC facility. All of these wells have ceased
operation and the remaining contamination would appear to be
moving under natural gradient conditions. Data gathered to
date indicate that the contamination is localized to a
relatively small area surrounding the site.
comment k:
A TAG advisor stated that all end-points for the groundwater
target levels should be reduced by a factor of 10, with vinyl
chloride reduced to at least 0.1 ppb (the water quality
standard in the state of California).
EPA ResDonse:
Refer to the response to comment 4.f. EPA believes that the
cleanup levels established in the ROD are protective and need
not be reduced further, at present. with respect to vinyl
chloride, EPA has selected the MCL as the cleanup level. The
state of Maine has expressed concern that the vinyl chloride
level should be lower than the MCL. However, based on current
knowledge, it appears that vinyl chloride is one of the more
readily extracted contaminants in the groundwater using the
selected pump and treat remedial action technology, and that
vinyl chloride will be reduced below the MCL before the
cleanup levels for the other contaminants (particularly,
tetrachloroethene) have been attained. EPA has committed t8
recalculating the cumulative residual risk after the
groundwater cleanup levels have been achieved, to ensure that
the residual risk falls below the upper limit of EPA's risk
range of 10.4.
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. comment 1:
A TAG advisor recommended that a more stringent method for
testing for the presence of monobutyl ethers, glycol ethers
and DMF be incorporated in the groundwater remediation plan.
This advisor also noted that DMF and glycol monobutyl ether
were detected at levels as high or nearly as high as those
detected for xylene and TCE in the on-site groundwater.
EPA ReSDonse:
EPA will use the best, technologically-based method to test
for the presence or absence of DMF in the groundwater both on-
and off-site. At present, EPA is aware of only one analytical
method that is specialized to handle DMF but the analytical
detection limits may be questionable. EPA's own contract
laboratory program (CLP) is capable of detecting DMF down to
approximately 50 ppb using specialized equipment. The
concerns raised by this commenter regarding ethers at the Site
have not been considered by EPA, based on the available
information, to be a human health concern due to the
overriding health concerns with respect to TCE, PCE, and vinyl
chloride which are known to be present at the Site.
comment m:
A TAG advisor suggested that in order to best estimate the
timetable for groundwater cleanup, the average rather than the
geometric mean of the measured organic carbon contents should
have been used. The advisor suggested that the average was
preferable because the amount of contaminant adsorbed to soil
depends on the amount of organic carbon linearly rather than
logarithmically.
EPA ReSDonse:
The geometric mean was used as the average for the organic
carbon found in soils because it is believed to be more
representative of the data set available for the Site. These
site-specific data contained one high value which was obtained
from a near surface soil sample (0.5-1.0 feet) in the true
soil zone. The other values were from samples taken at
greater depths where proportionally more of the contamination
is found at the Site. The geometric mean value is preferred
because it produces a lower (more conservative) estimate of
the residual contaminant concentrations that will be allowed
after soil remediation is completed.
comment n:
A TAG advisor recommended that a thorough evaluation of the
pump-and-treat approach to groundwater remediation be
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conducted approximately three years after the pumping begins
to tell how well it is working. The advisor suggested that
the evaluation be based on contaminant concentrations in
monitoring wells.
EPA ResDonse:
The evaluation of the pump-and-treat system(s) will include
frequent sampling and analysis in the early stages of the
remedial action. The frequency of this monitoring may likely
decrease to some more appropriate longer-term schedule(s).
The frequency of such monitoring will be based upon the
effectiveness of the system in achieving the performance
standards established using new and existing monitoring wells
on and/or off the site.
comment 0:
A TAG advisor noted that pumping mostly from the weathered
bedrock zone would maximize the effectiveness-of the system in
preventing further migration of contamination into the
underlying fractured bedrock. Additionally, because the
weathered bedrock is more permeable than the till, more water
could be extracted. Well construction and maintenance would
also be easier.
~PA ReSDonse:
EPA agrees with this comment, as reflected in the Final Draft
FS, proposed Plan and the ROD. More specifically, the
extraction of contaminated groundwater will focus on the
plume(s) identified in the till and weathered bedrock zones
located throughout the site. This strategy, as indicated in
this comment, is expected to maximize the containment and.
eventual cleanup of the aquifers at the site. Additional
groundwater extraction may be required, based upon the
performance of the wells in the till and weathered bedrock, in
the deeper bedrock in the future.
5.
soil '.rreatment
comment a:
A TAG advisor for the Hope Committee for a Clean Environment
commented that the proposed soil treatment method is a
patented method owned by Canonie and is only effective for
removing volatile chemicals. The method only removes one-half
to two-thirds of the semi-volatile chemicals.
EPA ReSDonse:
While Canonie does have a proprietary version of the low-
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temperature soil aeration treatment technology selected for
use at the Site, several other vendors are also available to
provide the soil treatment required for in the ROD.
Therefore, EPA considered low-temperature soil aeration
treatment to be the more appropriate technology.
Additionally, the semi-volatiles that are contained in the
soil at the site have not been identified in the RI/FS as
chemicals of concern with respect to soil or groundwater
remediation at the site. Therefore, while it is not disputed
that the low-temperature soil aeration technology is not a
method of choice for semi-volatiles alone, it is a technology
to remediate the contaminants of concern at the site and it
will remove, overall approximately 60 percent of the semi-
volatiles in the soils based on currently available
information (some of which is contained in the appendicies to
the Final Draft FS).
comment b:
A TAG advisor and other residents raised doubts about the soil
removal EPA plans to conduct. They indicated that EPA should
not limit the removal to soil above the water table, nor to
the areas the Agency has proposed. They also suggested that
the volume of soil that needs to be removed and treated should
be based on an evaluation of existing data and conditions that
are found as the cleanup progresses.
EPA ReSDonse:
EPA considered this comment in preparation of the ROD and has
adjusted the proposed remedy to reflect this concern. The
exact lateral and vertical extent of the contaminated soils to
be excavated from the Site, while approximated in the Final
Draft FS and presented to the public at several public
hearings, will probably require refinement as the remedial.
design progresses. Additionally, soils will be excavated in
the saturated zone to the extent required in Case B, as.
further explained in the ROD, rather than Case A.l as stated
in the Proposed Plan. Finally, the exact lateral and vertical
extent of the excavation will be confirmed throughout the
actual remedial action process to ensure that the maximum
amount of contaminated soils will undergo excavation, to the
extent that is technically practicable.
comment c:
A TAG advisor and a representative from the Camden Rockland
Water Company questioned EPA's decision not to dig up the soil
in the marsh area along Quiggle Brook to avoid disturbing the
wetlands. Since the wetlands are contaminated, they suggested
that EPA reconsider digging up the soil in the contaminated
marsh.
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EPA ResDonse:
Under EPA's wetlands requlations, EPA must minimize the
destruction, loss or degradation of wetlands, and preserve and
enhance the beneficial values of such wetlands. In addition,
EPA must avoid new construction in wetlands unless there is no
practicable alternative. As such, EPA carefully weighed the
advantages and disadvantages of disturbing the wetlands in
order to clean up the contamination or leaving the wetlands
Has is" with the current level of contamination. In this
case, EPA decided that it would better protect the wetlands to
leave them undisturbed.
comment d:
A representative of the Camden Rockland Water Company
indicated that EPA begin the extraction of contaminated
groundwater before soil is removed to establish a normal
pumping water level. Thus, the volume of soil to be excavated
and treated can be more accurately determined.
EPA ReSDonse:
During soil excavation activities, dewatering by pumping may
be needed, particularly in the saturated soils. The extent
and sequencing of these activities will be further evaluated
during the remedial design.
comment e:
One individual recommended excavating and treating as much
soil as possible in effort to minimize cost and duration of
the groundwater extraction process.
EPA ReSDonse:
EPA used a soil-percolation model to determine how much
contaminated soil should be excavated in order to assure
attainment of the groundwater cleanup levels. EPA has
considered the public comments which support a more extensive
soil removal action at the Site, and has determined that more
extensive excavation (Case B) will result in a more rapid
cleanup that is both effective in the long-term and is cost-
effective.
comment f:
A TAG advisor recommended that mulch and/or possibly manure be
mixed with treated soil prior to replacing it on-site and
requested that trees be planted on-site to restore it to ITa~ch
the rural surroundings within the community.
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EPA ResDonse:
EPA has considered this comment in the ROD, and has indicated
in Section X.B that prior to placement of the treated soils
from the soil aeration process that nutrients and/or native
soils will be added in order to promote the re-establishment
(comparable to the surrounding area) of these soils for future
habitat growth.
comment a:
A TAG advisor suggested that the target cleanup levels
selected by EPA will allow enough contamination into the
aquifer to contaminate the entire till aquifer above the
acceptable levels for 31 years, even if the aquifer were now
entirely pure. The advisor also suggested that this
calculation is based on the assumption that leachate entering
the top of the aquifer will immediately mix throughout the
aquifer's entire thickness. The true degree of mixing will be
much less than Canonie assumes, and concentrations will be
. highest in a thin zone near the top of the aquifer. Thus the
leachate will cause groundwater concentrations much higher
than the FS predicts.
EPA ReSDonse:
soils remediation in the unsaturated zone are designed to
ameliorate the risk from contact or ingestion of the
contaminated soils and, more importantly, the leaching of the
soils contaminants into the groundwater at unacceptab~'
concentrations. Selection of residual soil concentra:
from organic compounds, that are deemed acceptable, tc
in soils are usually driven by groundwater considerati,
:1S
~ left
.s.
Instantaneous mixing of the leachate throughout the saturated
thickness of the till aquifer does not occur in the field.
However, it is a convention that is assumed here as in other
Superfund sites in Region I. There are insufficient data to
do otherwise and the overall estimate of allowable residual
soils levels is considered to be conservative. The
consequence of selecting residual soils levels that are too
high is to prolong the pump-and-treat portion of the overall
remediation. However, there is no increase in the risk to
public health or the environment.
comment h:
A TAG advisor recommended that the target cleanup levels fe,
soil should be lowered. This advisor referred EPA to thre~
(3) Superfund Records of Decision issued in FY 1987 which he
recommended EPA adopt for calculating soil cleanup levels a~
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~
the Union site.
EPA ResDonse:
EPA has reviewed these FY '87 RODs and has determined that the
site-specific methology used at the UCC site is still the most
appropriate ~ethod for establishing soil cleanup levels. This
site-specific methodology has been applied at other Superfund
sites and the results generated for the UCC site are
consistent with the results for establishing soil cleanup
levels in other RODs developed within Region I.
comment i:
A TAG advisor stated that pumping will not flush contamination
from soils above the water table.
EPA ReSDonse:
Remediation of soils above the water table will be
accomplished by: (i) excavation and treatment of these soils,
or (ii) vacuum-extraction of soils not undergoing excavation.
comment ;:
A TAG advisor suggested that rapidly leaching species, such as
DMF, methyl isobutyl ketone and methyl ethyl ketone, could
contribute excessive amounts of contamination to the
groundwater in the early phases of cleanup.
~PA ReSDonse:
While this fact is likely to be the case at the UCC site,
these contaminants will, therefore, be the contaminants which
are remediated in the initial years by the groundwater
extraction and treatment system. The concern, which will be
investigated in the remedial design, will be whether or not
this excessive amount of contamination will create any
detrimental effects to the extraction and treatment system.
comment k:
A TAG advisor, referencing a map in the FS on soil excavation,
recommended that where uncertainty exists on the extent or
characterization of soil contamination in this mapped area,
EPA should excavate the entire area. Following this
excavation, the advisor recommended additional sampling and
excavation of contaminated soils in the walls and bottom of
the pit until no further contamination is detected.
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--_.~ -- ---
EPA ResDonse:
EPA has stated that the soil excavation limits and volumes
presented in the Proposed Plan are merely estimates in order
to enable a cost estimate to be prepared in the FS. EPA has
indicated in the ROD that the exact vertical and horizontal
extent of any excavation at the Site will be made as the
remedial design and remedial action are being performed. The
final amount of soil to be excavated will not be determined
until such time that the soils within the excavated areas and
the treated soils are sUfficiently tested to EPA's
satisfaction.
Q
comment 1:
A TAG advisor suggested that the effectiveness of the vacuum
extraction system is likely to be poor because some of the
major contaminants (including DMF, isophorone, ethylene glycol
aonobutyl ether and, to a lesser extent, methyl ethyl ketone
and methyl isobutyl ketone) will remain in the soil because
they are not volatile in aqueous solution and the glacial
sediments at UCC are very heterogeneous.
EPA ReSDonse:
The heterogeneity and generally low permeabilities of the
materials at the Site will tend to inhibit both vacuum
extraction and groundwater extraction, to some extent.
However, an examination of the physical properties of
enumerated compounds indicates that they will readily
partition away from the soil matrix and toward the water
phase. Thus, groundwater extraction and treatment will be the
primary mode ameliorating unacceptable concentrations of these
compounds in the groundwater.
comment m:
A TAG advisor, who suggested that vacuum extraction for
saturated soils will be ineffective, requested that
information be made available to the public if the proposed
pilot study shows the method to be ineffective.
EPA ResDonse:
Although removal of organics through vacuum extraction may be
difficult in heterogeneous soils, EPA believes that the
combination of vacuum extraction and soil excavation
(according to Case B) presents an comprehensive approach to
removal of the source of the groundwater contamination that is
also permanent, protective and cost-effective. The results of
the completed pilot-scale studies will be made available to
the TAG group or any other member of the public, on request.
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pomment n:
A TAG advisor suggested than in order to alleviate the
increase in groundwater contamination levels when the water
table rises after rainfall, EPA should increase the depth of
soil excavation so as to treat all soil that will later be
dewatered by the pump-and-treat system. This advisor also
recommended excavation of the highly contaminated. zone around
the leach field, as identified in the FS as the Case "B"
option.
EPA ReSDonse:
Upon consideration, EPA agrees with this comment and believes
that Case B provides for a more effective remedy for
implementation at the .Site.
6.
Testing
comment a:
An attendee at a public hearing asked for a clarification as
to where soil samples have been tested in off-site areas.
EPA ReSDonse:
EPA randomly took off-site soil samples from May 1987 to
October 1988. Samples were taken all the way down to Crawfcrj
Pond and all the way up to Hobbs Pond near the dam. Samples
were also taken. in the yards of Mr. Johnston, Mr. Hastings,
Mr. powers, and Mr. Jenson.
comment b:
A commenter stated that the off-site areas
insignificance to EPA and DEP, and further
EPA's proposed limited action for off-site
inadequate.
seem to be of
commented that
testing is
EPA ReSDonse:
Based on the information known, it does not appear that there
is significant off-site soil contamination. During the RI/fS,
EPA used both random sampling and comprehensive air modelin9
simulations to try and predict areas of possible incinerator
impacts. The results of that sampling were not conclusive,
but do not appear to show a serious risk to human health and
the environment. As part of the remedy, EPA is requiring.
further samplinq and modeling using 5 years of site-specific
meteorological data. EPA believes that this part of the
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---
remedy is appropriate, given the known conditions on- and of
site.
comment c:
A citizen requested that further soil samples be taken and
that his property be among the new locations tested.
"
EPA ReSDonse:
Q
EPA appreciates the request and will consider it. EPA is
aware that additional sampling is needed and is in the process
of determining how the sampling will be conducted. There are
several options: random proximity, modeling, or grid.
comment d:
A representative of the National Toxic Campaign commented that
the Proposed Plan does not tell citizens where the additional
off-site soil samples will be taken, nor does the Proposed
Plan identify the type of samples that will be taken.
EPA ReSDonse:
Sampling points will be selected as stated above in response
to comment 6.c. Samples based on modelling must await the
results of the some meteorological data. As stated in the
ROD, samples will be analyzed at a minimum for dioxins and
furans, heavy metals and semi-volatiles (particularly, PARs).
The exact locations of these sampling points will be
determined more fully during the remedial design and remedial
action.
comment e:
Some residents requested that EPA immediately undertake
further off-site testing in locations where individuals have
reported observing "fall-out" from the incinerator and not
wait until additional data is derived through the Limited
Action alternative for off-site soils. .
EPA ReSDonse:
EPA has considered these commenters concerns and has indicated
in the ROD that sampling may occur prior to the acquistion of
one-full years worth of site-specific meteorological data.
This may include random or grid sampling near the location SS-
1 were the one dioxin isomer was approximated during the RI
field efforts. .
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-- - - -- -- -- .
._--_. -------- -
comment f:
A representative of the National Toxic Campaign commented that
the site received wastes from hospitals and inquired if any
testing for biological contamination has been conducted.
EPA ResDonse:
l)
EPA has not conducted any biological testing. EPA has
reviewed the PRPs' manifests, which identify the waste sent to
the site, and medical waste is not cited. Most of the wastes
were solvents, which EPA has found on the site.
comment a:
The project manager for The Concerned Citizens of Hope
requested that radiological testing be conducted at the site.
EPA ReSDonse:
EPA conducted initial testing for radioactive substances when
the Agency performed its first walk-through of the site, but
no radioactive materials were found.
comment h:
A few residents requested that periodic residential well
testing be conducted for semivolatile organics,
dimethylformamide (DMF) and glycols, and a TAG advisor
requested that monitoring of all residential wells in which
any contamination has been detected in the past be sampled
again for DMF either before or immediately after the ROD
signing.
EPA ReSDonse:
EPA and the state of Maine has considered this comment in the
preparation of the ROD and have indicated that DMF will be one
of the specific chemicals to be monitored during the remedial
design and remedial action, both on the site and off-site. In
fact, the Maine DEP is attempting to make arrangements at the
time of this writing to sample selected residential wells for
DMF analysis alone during the winter of 1991.
comment i:
A TAG advisor recommended further work to re-examine the
sampling methodology and testing techniques used to determine
if vinyl chloride would have been found by the procedures
used. Another TAG advisor recommended the monitoring wells be
resampled and analyzed specifically for vinyl chloride.
-------
EPA ResDonse:
EPA does not ~eel that it is appropriate at this time to re-
examine past historical groundwater data from the site to
determine whether or not vinyl chloride is present. EPA has
included vinyl chloride as one of the many chemicals which
have established groundwater cleanup levels and, therefore,
will be one of the many chemicals to be monitored throughout
the remedial design and remedial action to determine
completion of the remedy and protection of human health.
comment ;:
A TAG advisor suggested that volatile chemicals will enter the
air during the excavation of contaminated soils and could pose
a health risk to the surrounding community. The advisor
requested EPA strongly consider this when developing the air
monitoring plan for implementation during the remedial action.
EPA ReSDonse:
EPA agrees that monitoring and control of volatile organics
during the remedial action is important." The ROD requires
that monitoring must be conducted during soil excavation and
that mitigative measures, which may include the use of partial
or full-enclosures and/or air pollution control devices, will
be taken as necessary
7.
Health and Environment
comment a:
A social worker provided a broad statement regarding the
findings of the October 1988 psycho-social survey she
conducted in Hope, Maine. She stated that most of the 38
homes that she visited showed evidence of varying degrees of
stress as a result of the concerns that have arisen in the
Union Chemical Superfund site community.
EPA ReSDonse:
EPA appreciates that living near a Superfund site can cause
stress and concerns about health and safety. In selecting
this remedy, EPA has chosen the remedy which provides, in its'
opinion, the best strategy for cleaning up the Site,
consistent with CERCLA. EPA hopes that by cleaning up the
Site that one of the accomplishments of this remedial action
will be to reduce stress related to the Site.
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---. -----
90mment b:
A member of Hope's Committee for a Clean Environment stated
that the community is concerned with two general problems.
They are: 1) the integrity of safe drinking water and 2) the
long-term effects of low-level exposure to the toxins.
J:PA Resoonse:
EPA acknowledges these concerns. The remedy selected will
reduce the risk associated with future use of the groundwater
to acceptable levels, and will reduce and monitor the low-
level exposures to the contaminated soils, both on-and off- .
site, and to the facilities, 60 that they fall within the
acceptable risk range.
comment c:
Many residents and TAG advisors requested that EPA guarantee
that the drinking water supply for the community of South Hope
and any other potentially impacted region will be preserved,
and that an alternate source be provided should any exposure
to these substances develop in the drinking water of the wells
in the Hope community.
EPA Resoonse:
EPA believes that the selected remedy will restore the
groundwater under the site to drinking water standards, and
will preserve the quality of the groundwater used for drinking
water near the site. None of the drinking water wells tested
near the site have shown evidence of contamination above
drinking water standards. In fact, DEP recently collected.
residential well water samples on November 13, 1990 from
selected drilled and dug wells in close proximity to the site
(as was requested during the public comment period), and has
not detected any contamination in these wells (including vinyl
chloride at less than 1 ppb). Accordingly, EPA believes that
it is not appropriate to provide for an alternative water
supply in the absence of a risk to public health. If such a
risk occurs, EPA will consider provision of alternative water
at that time.
comment d:
A citizen whose property is closest to the site expressed
concern for his five-year old son's health because his son
plays in the dirt on his property. The citizen requested that
EPA evaluate his son's health and also test soil on his
property.
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--'-...- .-' .~
----,-_.- --- .----.-- .--
EPA ResDonse:
EPA will select soil sampling locations based either on random
proximity, grids and/or air modeling simulations. EPA does
not test the health of individuals as part of the Superfund
program, but has calculated the risk based on exposure
scenarios involving the surrounding residents to the Site.
EPA has recommended to the Agency for Toxic Substances and
Disease Registry (ATSDR) that they evaluate these concerns
further since their Agency is more suited to address the
concerns raised by this commenter.
w
comment e:
A TAG advisor for Hope's Committee for a Clean Environment
raised concern regarding the protection of human health during
the cleanup of the site.
EPA ReSDonse:
EPA has included in the ROD several provisions for monitoring
of potential releases during the remedial action and has
outlined steps to mitigate threats to public health. The
commenter is referred to Section X.B of the ROD.
comment f:
A member of HCCE requested that EPA set cleanup levels that
would restore the environment to its original condition prior
to the contamination problems posed by the Union Chemical
site.
EPA ReSDonse:
Under CERCLA, EPA's mission is generally to protect human
health and the environment. In the National Contingency Plan
(NCP), EPA has further defined what is "protective. II with
this remedy, EPA is taking appropriate steps to protect human
health and the environment. As stated in the preamble to the
NCP, EPA does not agree that cleanup should always be to
background levels. Cleaning up to background levels may not
be necessary to achieve protection of human health because the
background level for a particular contaminant may be close to
zero, as in pristine areas. See 55 Fed. Rea. 8717-18.
8.
Miscellaneous
comment a:
A citizen commented that EPA's Proposed Plan suggests that tr~.
release of certain wastes from the site would be allowable,
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~
citing that the plan states that discharge of treated water
would contain chemicals that meet EPA and DEP standards. This
raises a legal issue because the property deed prohibits the
discharge of waste of any nature. This citizen also addressed
EPA's alternative proposal of discharging or recharging into a
swamp area that is on her land. This, too, raises a legal
issue because her deed restricts any waste from being allowed
to seep, run, or in any way be allowed to get onto her land or
into Quiggle Brook.
EPA ReSDonse:
The commenter raises two issues. First, the groundwater which
will be discharged to Quiggle Brook will be treated to meet
federal drinking water standards and ambient water quality
criteria. As such, the discharge is drinkable and would not
fall into the definition of a hazardous waste, as that term is
used by EPA. In fact, the water quality of Quiggle Brook will
be improved by the remedy since contaminated groundwater will
be collected and not allowed to seep, untreated, into the
brook as currently occurs. Second, EPA is not a party to the
deed the commenter refers to, is not in the chain of title,
and is not technically bound by its terms. EPA's authority
under CERCLA to take certain response actions is not limited
by contracts between other parties. However, EFA appreciates
the fact that the commenter still owns nearby property, and
would be willing to meet and discuss these legal concerns in
the near future.
comment b:
The project manager for The Concerned citizens of Hope
presented an original petition at the public hearing and
provided a copy to EPA. The project manager asked that the
Agency sign and date both to indicate their receipt of the
petitions. The content of the petition included the follo~ing
requests:
(1) That a public water supply from a source outside of
South Hope boundaries be provided to all of the homes in
South Hope.
(2) That South Hope residents who request relocation be
moved during the entire remedial action activities at the
site.
(3) That a health fund be established to cover all
expenses for toxicological testing, evaluation,
treatment, and consults. This fund should be available
to all South Hope residents when requested.
(4)
That a mobile health unit with a toxicological tea~
-------
be established in the town to test all residents within
two-mile radius of the site who wish to be tested. The
Concerned Citizens of Hope would select one individual
expert to be part of this team.
(5) That within the next 3 months EPA retest the 46
off-site, residential wells under the same conditions and
methodology that the Agency tested the Johnson well
(Residential Well t 20), which included pumping 300 to
350 gallons of water before collecting samples, and that
dug wells have sediment testing done.
(6) That the off-site testing be expanded to acceptable
grid pattern methodology, within the next three months.
The off-site soil testing should include these locations:
the dioxin spike where many children play and Brian
Powers' yard where there is heavy lead.
EPA Res'Oonse:
EPA understands that the petition, which is signed by
approximately 160 citizens, expresses serious concerns about
public health issues related to the UCC Site. However, taking
into consideration the site conditions known at this time, the
Baseline Risk Assessment, the significant monitoring and
mitigative measures required to control air emissions under
the ROD, the limitations of EPA's authority under CERCLA, an,.
EPA's best engineering judgment, EPA believes that the demana~
presented in the petition are not necessary or appropriate as
part of the remedy for this Site. The state of Maine also
agrees that the site risks do not warrant such actions at this
time.
EPA's extensive testing of residential drinking water wells to
date has not clearly shown contamination from or related to
the UCC Site, except in Residential Well # 20. The contaminant
levels detected in Residential Well # 20 were below federal
drinking water standards. Based on these results, there is an
insufficient basis for providing alternative water supplies to
all nearby residents of the Site.
Second, EPA believes that relocation of nearby residents anj
workers during the implementation of the remedy will not be
necessary at this time. As stated in the ROD, frequent
monitoring of air quality will be performed during remedial
action, and measures will be taken to minimize or mitigate ~~e
release of potentially dangerous volatile organics and
particulates into the air. section X of the ROD contains
details regarding possible mitigative measures. Such
mitigative measures have been used at several other Superf~~j
sites to monitor and control air emissions. In EPA's
judgment, these measures will be sufficient to protect putl~~
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-..-.-.-..---
health against short-term risks posed by the remedy, and that
relocation is not warranted based on current information.
The third and fourth requests contained in the petition seek a
health fund and mobile health unit for testing residents of
South Hope. The provision of a health fund and health
services is beyond the scope of EPA's authority under CERCLA,
and, based on the results of the Baseline Risk Assessment,
does not appear to be required to protect human health.
However, EPA has contacted the Agency for Toxic Substances and
Disease Registry to evaluate these requests, which are more
appropriately dealt with by that agency.
with respect to the fifth request, EPA believes that off-site
groundwater contamination has been adequately characterized.
Several rounds of sampling have already been conducted in
residential wells, as described in the RI. Also, in November,
1990, the state of Maine conducted further tests on five
nearby residential wells, which showed no detectable levels of
volatile organics, including vinyl chloride at less than 1
ppb. The selected remedy does call for additional sampling
for some -- but not all -- nearby residential wells as a part
of evaluating the success of the groundwater component of the
remedy. Therefore, EPA believes that duplication of the
testing methods used at Residential Well # 20 is not warranted
for the 46 off-site wells referred to. If conditions change,
EPA would consider expanding the residential well monitoring
program.
with respect to the sixth request, EPA believes that the
selection of sampling points for the off-site soils must be
left until remedial design. possible methods of selecting the
best sampling locations for off-site soils include random
proximity, grid, and modelling. EPA will use the method or
methods that in its opinion are most likely to target the
locations of possible deposition of airborne contaminants from
the UCC incinerator. Following a strict grid pattern may not
be the best approach to determine the extent and possible
sources of such airborne contamination. EPA believes that it
is appropriate to determine the approach to and schedule for
off-site soil sampling during remedial design.
comment c:
The project manager for The Concerned citizens of Hope asked
EPA to identify whether the chromium found is hexavalent or
trivalent.
EPA ReSDonse:
EPA's standard protocol (and those employed at this site by
Canonie) measure chromium as a total, which represents both
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, - ..
.
-_....._.
hexavalent and trivalent as one measurement.
comment d:
A citizen commented that on page 6, paragraph 2 of the
Proposed Plan it is stated that there is potential off-site
contamination connected with the Union Chemical Company. She
suggested that there is no such thing as "potential." She
indicated that the Rockland Quarry, Union Town Dump and an
unlicensed storage site in East Union have been contaminated
and that wastes at these sites either originated from the
Union Chemical company. This citizen also suggested that the
Town of Hope School received boxes of food that was
contaminated with chemicals that were either picked-up from or
dropped off at the UCC site.
EPA ReSDonse:
EPA's investigation of the UCC Site was directed to
understanding what releases of hazardous substances have
occurred, and what the current and potential future threats
are to human health and the environment from the Site. These
investigations focused on the facilities, soil, surface
waters, sediments and groundwater under and surrounding the
UCC Site. It is beyond the scope of this particular RIfFS to
conduct an evaluation of the threats posed at other location:
to which hazardous substances may have been sent from the Dee
Site. If those other locations present an environmental or
human health risk, they will most likely be addressed as a
separate site. In fact, the Rockland Quarry has been placed
on the EPA list of sites to be investigated for inclusion on
the list of Superfund sites (i.e. the National Priorities List
- NPL), the State of Maine is conducting closure and
remediation activities at the Union Dump, and the East Union
barn was investigated in 1979 and 1984 by the State of Maine
and the EPA and no evidence of leakage or spillage of wastes
was reported at this location.
comment e:
A TAG advisor requested information on the number of air
monitoring devices to be installed on-site, the chemicals to
be measured, the "action levels" for work slow-down or
stoppage and the procedure for emergency notification of the
neighborhood.
EPA ResDonse:
EPA has not specified the actual number of air monitoring
devices or the chemicals that will be monitored for during the
remedial action since these specifics will be detailed in the
remedial design that will be prepared as the next step towar
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-- -
cleaning up the site. EPA and the Maine DEP has expressed
their willingness to work with the TAG group and the advisors
to formulate a remedial design that addresses the concerns of
a parties involved with the site. Until this time, no further
specifics can be provided to address the requests of this
commenter.
comment f:
A TAG advisor made the following specific recommendations for
monitoring: (a) 3-5 site perimeter stations with continuous
monitoring for organic vapors or chlorine with real time data,
(b) reqular collection and prompt analysis of air pollutants.
using a charcoal Tenax tube, (c) particulate monitoring with"
specific measurements of lead, and (d) use of portable flame
ionization detectors for on-site monitoring and occasional
monitoring of residences. Chemicals of most concern to
measure for should include: 1) xylene or toluene, 2) vinyl
chloride, 3) chloroform, and 4) dichlorethanes or ethylenes.
EPA ReSDonse:
As stated above, the specific details of a monitoring plan are
beyond the scope of the ROD, but will be addressed in the
detailed remedial design and remedial action workplans. EPA
appreciates the recommendations of the commenter and will take
them into account in reviewing and approving or disapproving
such workplans. EPA is also committed to working with the TAG
group throughout the remedial design and remedial action to
identify and address concerns such as this.
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B.
SUMMARY OF COMMENTS FROM THE POTENTIALLY RESPONSIBLE
PARTIES
This section provides a detailed summary of the PRP comments
received by EPA during the public comment period. These comments
are organized in the following categories: 1) Groundwater Target
Cleanup Levels; 2) Soil Treatment; and 3) Off-Site limited action
alternative.
A summary of the comments and EPA's responses to them is provided
below.
1.
GroUD4va~er ~ar9.~ C1eaDup Levels
comment a:
The Union Chemical site Trustees believe that the standards
for groundwater target cleanup levels that should apply at the
Site include, at a minimum, the federal MCLs and that the MCLs
should be selected in all cases where conflict exists between
MCLs and State of Maine MEGs.
EPA ReSDonse:
EPA has amended certain cleanup levels in the ROD as follows.
For those chemicals for which MCLs have been promulgated, MC:
were used as the target cleanup levels. If no MCL (or non-
zero MCLG) existed for a given contaminant, EPA used proposed
MCLs, proposed non-zero MCLGs, or the State of Maine MEGs in
selecting target cleanup levels.
comment b:
The Trustees have noted that the process for establishing
Maine MEGs does not appear to be related to a critical
scientific review procedure and does not include a forum in
which the public can provide the state with input into the
selection process.
EPA ResDonse:
Most of the groundwater cleanup levels in the ROd are based on
MCLs, proposed MCLs, or proposed non-zero MCLGs. Only two
cleanup levels -- for 1,1-dichloroethane and methyl ethyl
ketone -- were set using only the MEG. Because EPA has
determined that Maine MEGs are not ARARs, EPAts use of MEGs in
helping to establish cleanup levels is discretionary. In
order to be used on a discretionary basis as a standard "to-
be-considered" (TBC), MEGs need not be promulgated following
public comment procedures. The justification for the use of
MEGs in setting levels for the two contaminants mentioned
above is presented in section XI.B of the ROD.
-------
.
comment c:
The Trustees have noted that EPA has deviated from its policy
stated in the proposed plan that Maine MEGs "are to be
considered in establishing the groundwater target cleanup
levels for those contaminants for which no MCL exists."
EPA Res'Donse:
EPA considered this comment in preparing the ROD. The ROD is
now consistent with the statement in the Proposed Plan. .
comment d:
The Trustees suggested that proposed target cleanup levels
should address only those constituents which are present in
the groundwater at levels which exceed health-based standards
and which form the basis fOT remedial action. As such, the
Trustees urge EPA to delete cyanide, lead and nickel from the
target cleanup list for groundwater because these constituents
have been detected only on rare occasions at levels which do
not exceed the concentrations set forth in the Proposed Plan.
EPA ReSDonse:
In response to this comment, EPA has eliminated nickel and
cyanide cleanup levels (and also cleanup levels for chromium
and copper), because these contaminants were not identified as
contaminants of concern and their maximum observed
concentrations did not exceed the MCLs for those contaminants.
However, since lead was identified as a contaminant of concern
during the Baseline Risk Assessment, a cleanup level was
established for lead. It is expected that minimal sampling
for lead will be required as part of the remedy, unless.
sampling results show that lead levels are exceeding MCLs.
2.
80i1 Treatment
comment a:
The Trustees believe that Alternative SC-6, In-situ Soil
Aeration, is an equally acceptable soil treatment remedy and
that the Record of Decision should be written in a manner to
permit the use of either this technology or the technology
contained in the proposed Plan regarding low-temperature soil
aeration based upon. the resul~s from further field testing to
be undertaken during ~e~edial design.
EPA ReSDonse:
EPA has selected SC-5 (excavation of soils and low-
temperature soil aeration treatment) over SC-6 (in-situ soil
-------
treatment) for several reasons, as stated in Section IX.A of
the ROD. First, and most important, EPA believes that
attainment of the soil cleanup levels in the low part-per-
million range is more likely to be achieved using se-5 than
Se-6. Thus, the residual risk to groundwater as a result of
contaminants remaining in the source area is greater with se-
6. In their comments, the Trustees have not provided any
further convincing evidence that in-situ soil aeration can
achieve the low cleanup levels established. An analysis of
the FS prepared by Groundwater Technology, Inc. for the
Trustees (dated May 8, 1990) does not provide any data to
support the assertion that low part-per-million levels can be
achieved using in-situ treatment. Second, it is difficult to
verify attainment of cleanup levels throughout soils which
have be treated in situ without excavating the soils. If the
soils are to be excavated to confirm attainment of cleanup
levels, much of the advantage of in-situ treatment is lost.
Also, even if soil is excavated to confirm the results of
treatment, pockets of chemical residues could remain in
unsampled areas. Third, the time frame for achieving the
cleanup levels is significantly longer with se-6 than se-5.
WHile the Trustees state in their comments that the time for
completion could be reduced to less than 5 years, this is not
certain, especially when cleanup levels are set in the low
part-per-million range. Finally, use of se-5 allows for
treatment of contaminated concrete pads at the Site. For
these reasons, EPA has elected not to write the ROD to perrni~
use of se-6 as an alternative to se-5.
3.
Off-site Limited Action Alternative
comment a:
The Trustees request that EPA reconsider the selection of 05-
2 (Limited Action) for off-site soils and believe that the
RIfFS included off-site soil sampling sufficient to
characterize the nature and extent of chemical impacts to
areas beyond the property boundary of the site. The Trustees
argue that the selection of 05-2 is inconsistent with the NCP,
since OS-2 will not remediate any aspect of the site and
cannot produce data which will reasonably lead to a further
delineation of suspected areas of impact.
EPA ReSDonse:
EPA considered the Trustees' arguments against 05-2 in
developing the ROD, but has decided to retain OS-2 as part of
the selected remedy. EPA views 05-2 as an important part of
the remedy. Given the facts that: (1) in the past, the Maine
DEP took enforcement actions against uee for exceeding lead
levels in the feed stream to the incinerator; (2) the
incinerator .was used to burn hazardous substances; (3) PAHs
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~ .
. - ----..- ---
_.- -..----
--.-----
and dioxins are byproducts of the combustion process: and (4)
dioxins were found in the secondary scrubber component of the
incinerator, it is reasonable to require a full investigation
of possible off-site impacts of emissions from the UCC
incinerator.
EPA acknowledges that it is difficult to follow a plume of
airborne contamination that may have existed six to eight
years ago. EPA has used meterological data from the Augusta,
Maine region for modelling the locations of possible
deposition of airborne contaminants, in addition to random
sampling. These results were inconclusive, showing some low
levels of lead and PABs in predicted areas of impact
(including Mr. Powers' yard), and also the possible presence
of one dioxin isomer in one soil sample taken at a woodland
area north of the site and in the projected area of impact.
. Bas~ on these data, it is difficult to determine the exact
source of the detected contamination, although it would not be
unreasonable to conclude that the source was the UCC site
given our knowledge of site history and prevailing winds. 05-
2 is an attempt to resolve some of these uncertainties by
providing an air model using site-specific meterological data
which will better predict the areas of possible contamination
deposition, by sampling those areas, and by sampling at other
points randomly selected. It is expected that these data will
provide further information concerning both the possible
source of contamination in off-site soils and also the
potential threat to human health or the environment that may
be posed. EPA believes that further characterization of off-
site contamination is consistent with CERCLA and the NCP. 05-
2 is an appropriate step to achieve EPA's objective of further
evaluating, and if necessary, minimizing or mitigating risks
to human health and the environment from soil impacts related
to emission from the UCC incinerator. In addition, there is
significant public interest and concern on the part of Maine
DEP which was taken into account, in accordance with the NCP,
in selecting 05-2.
comment b:
The Trustees believe that since no positive values were
reported in any soil samples collected and analyzed in
accordance with EPA Region I protocols, the data clearly
indicate that dioxins and furans are not present in the soils
surrounding the site.
EPA ResDonse:
EPA believes that the data, while not clearly indicating the
presence or absence of dioxins at off-site location 55-1,
indicate that further evaluation and sampling is warranted.
The state of Maine also believes that the presence of dioxins
-------
in the incinerator warrants further off-site sampling.
comment c:
The Trustees argue that there is no way to determine if any
lead found in off-site soils is related to the site. Analysis
of the distribution of lead in the area surrounding Brian
Powers' yard indicates that the higher levels of lead are
restricted to Mr. Powers' property, which is inconsistent with
.any scientifically based analysis of emission distribution.
The Trustees also argue that the chemical analysis of soils
for PARs cannot determine the source of PARs in the
environment. There are many other factors that are attributed
to the detection of elevated levels of PARs in soils.
The Trustees stated that while the implementation of
Alternative 08-2, as suggested by EPA's Proposed Plan, will
provide a higher level of accuracy for the modeling of
emissions from the former incinerator, implementation of
Alternative 08-2 will not resolve the discrepancies in the
distribution of PARs currently observed, will not identify the
source of PARs, and cannot provide the needed information to
prove or disprove whether or not the UCC incinerator emitted
the PABs observed in the past or those yet to be detected
during future sampling studies. .
EPA ReSDonse:
EPA acknowledges that pinpointing the source of lead and PAh
contamination may be difficult, because of the presence of
possible sources other than the UCC site. A pattern of lead
and PAR deposition within the exact areas of predicted
deposition, based on a model using site specific meterological
information, would tend to indicate that the UCC site was a
source, if not the source, of such contamination. A pattern
of PARs only along Route 17 might tend to show that the
contamination was related to automobile emissions. However,
until further data on lead and PARs in off-site soils is
collected, it is not yet clear what conclusions can be
definitively drawn.
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-i
C.
SUMMARY OF COMMENTS FROM THE STATE OF MAINE
This section highlights the major concerns on the proposed remedy
for the Union Chemical superfund site received by EPA during the
public comment period from the Maine Department of Environmental
Protection (MDEP).
1.
Groun4..ter ~.rget Cleanup Levels
comment a:
The State of Maine stated in their statement for the record
that they will retain their rights to pursue separate
litigation under state authority should the state determine
that the Groundwater cleanup levels as presented by EPA in the
proposed Plan are not adequate to protect the public health
and the environment.
EPA ReSDonse:
EPA understands that the state takes the position that it can
pursue separate litigation relating to contamination at the
UCC site. EPA believes that the comprehensive groundwater
remedy as stated in the ROD is protective of human health and
the environment, and has committed to reevaluating and
recalculating the residual risk from exposure to groundwater
upon attainment of groundwater target cleanup levels.
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UNION CHEMICAL CO., INC.
soum HOPE, MAINE
t
REX::ORD OF DEX:ISION
APPENDIX B
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STATE OF MAINE
Department of Environmental Protection
t
IIAIN OFFICE: RAY BUILDING. HOSPITAL STREET. AUGUSTA
IIAIL ADDRESS: Stale House StatIon 17. AuguSIa. 04333
207.289-7688
JOHN It. 8IclU!RNAN, .lit.
GOVERNOR
DEAN C. IIARRIOTT
COMMISSIONER
December 19, 1990
Julie Belaga .
u.s. EPA, Region I
J.F. Kennedy Federal Building
Boston MA 02203-2211
Re:
Chemical Company, Inc. Superfund Site in Hope,
Th aine Department of Environmental Protection
(MEDEP) has reviewed the December 13, 1990 Draft Record of
Decision (ROD) with regard to the Remedial Action selected
for the Union Chemical Company Superfund Site in Hope,
Maine.
Based on that review the MEDEP concurs with the
selected remedial action. This action consists of a
comprehensive multi-component approach for the overall
remediation of site facilities, soils, and groundwater and
further off-site assessment as outlined in the following:
I.
C.
Facilities
A. Decontamination, demolition and off-site disposal
at a municipal landfill of non-hazardous
construction debris.
Off-site disposal of hazardous demolition debris
at an off-site RCRA facility.
Crushing and treatment of concrete in accordance
with the treatment of soils as summarized in II
below.
Monitoring of ambient air quality.
B.
D.
II.
Soil
A.
B.
C.
Pilot treatability studies.
Excavation and treatment of soils using a thermal
desorption treatment process.
Collection and treatment of off-gases using vapor
phase carbon or other appropriate technologies.
Replacing treated soils to the site.
Monitoring of ambient air quality.
D.
E.
III. Groundwater
. Portland.
REGIONAL OFFICES
. Bangor.
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._-----
Off-site characterization
A. collection of a minimum of five (5) years of
meteorological data on-site.
Modeling of historical off-site emission impacts
from the site's incinerator and boilers after one
(1) and five (5) years using site meteorological
data.
Sampling new off-site locations as warranted.
Reassessing the need for off-site remedial action
. at the completion of sampling.
This concurrence is based upon the state's under-
standing that:
.' .
A.
B.
,
IV.
A.
B.
c.
page 2
c.
Modeling of the fate and transport of contaminants
in the subsurface and pilot treatability studies.
Design and construction of a vacuum enhanced
groundwater extraction system to capture and
extract the contaminated groundwater plume and
vadose zone contaminants.
Treatment of the extracted qroundwater using an
ultraviolet light and oxidation system, along with
post and pre-treatment systems as required to meet
discharge standards.
Treatment of volatilized contaminants from the
vadose zone with vapor phase carbon or other
appropriate technology.
Discharge of treated water that meets state and
federal water quality standards to Quiggle Brook.
Monitoring of groundwater quality on and off-site.
D.
E.
F.
B.
c.
D.
The MEDEP will participate in the negotiations with the
responsible parties and in the review and approval of
operational designs and monitoring plans for the site
clean-up to the extent provided for in CERCLA.
In the event that the agencies are unsuccessful in
reaching a signed agreement with the responsible
parties to undertake the selected remedial actions, the
MEDEP will aqree to expend state Funds for ten (10)
percent of the EPA's remedial costs for the site.
Based upon the Draft ROD, the MEDEP's share of the
estimated costs will be approximately one and a half
million dollars ($1,500,000). Those funds can be
allocated by the MEDEP from the uncontrolled Hazardous
Substances sites Bond Account.
At the completion of the remedy, any residual risk at
the site will fall within the risk range specified
under the Federal National contingency plan (NCP). The
Maine DEP remains concerned that the groundwater clean-
up standard for vinyl chloride is not consistent with
the risk range specified in the NCP. In particular, if
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D.
E.
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page 3
groundwater cleanup level specified in this draft ROD,
the residual risk from this compound alone will exceed
.the worst case 10- cut off specified in the NCP.
, Further, if the MEDEP is concerned with the 10,000 ppb
clean-up standard established for xylene. The MEDEP
finds the specified groundwater clean-up goals for
1;.hese two compounds alone, may not provide sufficient
protection of public health. However, the state
anticipates that in reducing the most resistant
compounds at the site to their respective groundwater
clean-up goals, vinyl chloride and xylene will be
concurrently reduced to protective levels well below
the clean-up goals stated in the ROD. Therefore our
concurrence is based upon the statement in the draft
ROD of December 13, 1990 that the decision as to
completion of the remedy for the groundwater will be
based on the total residual groundwater risk from the
site and the understanding that further remedial action
will be required by EPA if the total site risk exceeds
the 10-4 cutoff specified in the NCP.
The MEDEP may require further remedial action to
achieve concentrations consistent with the state of
Maine's Maximum Exposure Guidelines through its own
actions.
The site conditions shall be reviewed within five (5)
years from the conclusion of the remedial action to
ensure that public health and the environment are not
significantly impacted by the residual contaminants.
Of particular concern to the MEDEP is the potential for
increased concentrations of vinyl chloride due to
anaerobic degradation of residual chlorinated compounds
in groundwater.
The MEDEP looks forward to working with the
resolve the environmental problems posed by this
you need additional information, do not hesitate
myself or members of my staff.
EPA to
site. If
to contact
Sincerely,
Dean C. Marriott
Commissioner
CC:
Al Prysunka, Director BOHMC
Scott Whittier, Director, DL&E
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UNION CHmICAL CO., INC.
saum HOPE, MAINE
ROCORD OF DEX::ISION
-------
Union Chemical Co., Inc.
Administrative Record
Index
Compiled: April 23, 1990
Updated: December 18, 1990
ROD Signed: December 27, 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 Union Chemical Co., Inc.
National Priorities List (NPL) site (the "Site").
The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthoriz,ation Act (SARA) at Section 113(k).
The Administrative Record is established to service two primary purposes. First, the basis.
for the remedial response selection is set forth in the record. and judicial review of any issue
concerning the adequacy of a response selection is limited to the record. Second, the Administrative
Record acts as a vehicle for public participation in the selection of the remedial response action.
The Administrative Record is available for public review and comment at EP A Region I
Records Center, 90 Canal Street, Boston, Massachusetts, and at the Township of Hope Town Hall,
Hope, Maine.
Section I of the Index citeS the site-speciflC documents, which are included in the .
Administrative Record volumes. Section n cites the guidance documents used by EP A staff in
selecting a remedial response action at the Site; these documents are not be included in the
Administrative Record volumes located at the Township of Hope Town Hall but are available for
review at EPA Region I Records Center.
Questions concerning the Administrative Record should be addressed to the EP A Region I
site manager at (617) 573-5780 or through the Union Chemical Co., Inc. site "Hot Line" at (207)
-------
. Section I
Site-Specific Documents
-- - -. -" - --~ --- -. - --. ~ .
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ADMINISTRATIVE RECORD INDEX
for the
Union Chemical Co., Ine. NPL Site
1.0
Pre-Remedial
Preliminary Assessment
1.2
1.3
"POtential Hazardous Waste Site Identification and Preliminary Assessment"
Form, EPA Region I (December 4. 1979).
Site Inspection
1.
1.6
"Potential Hazardous Waste Site - Site InspectionRepon" Form. EPA Region I
(November 29, 1979).
"Potential Hazardous Waste Site - Site Inspection Report" Form. EPA Region I
(September 20. 1984).
Hazard Ranking System (HRS)
1. HRS Worksheets and Documentation. EPA Region I (January 24, 1985).
2. lmtl' from Linda J. Duncan. The MITRE Corporation to Susan Svirsky, EP A
Region I (April 2.1, 1988) with the attaChed September 11,1984 (revised
October 8, 1986) HRS worksheets and documentation.
3. "Fact Sheet - Union Chemical Co., Inc. Superfund Site Added to National
Priorities List," EPA Region I (September 1989).
4. "National Priorities list for Uncontrolled Hazardous Waste Sites - Final Rule
Covering Sites Subject to the Subtitle C CoITCctive Action Authorities of the
Resource Conservation and Recovery Act," Federal Re~ster Vol. 54, No. 191
(October 4, 1989). Concerning the placement of the site on the National
Priorities List.
5. "National Priorities List Site," BFA Region L Concerning the removal action
completed on October 8, 1984. .
6. "National Priorities List Site," EPA Region 1. Concerning NPL StatUS of the site
from April 1985 through August 1989.
1.
2.
1.7
Correspondence Related to Proposal of a Site to the NPL
Thefollowing dockets may be reviewed. by appointment only, at EPA Region I,
Boston, Massachusens.
1.
National Oil and Hazardous Substances Contingency Plan; The National
Priorities list Revisions, Amendment. PmJ)Osed Rule Public Docket -
Vpdate 3. SO FR 14115 - April 10, 1985.
National Priorities List for Uncontrolled Hazardous Waste Sites - Sites Subject
to the Subtitle C Corrective Action Authorities of the Resource Conservation and
Recovery Act (RCRA). ProJx>sM Rule Public Docket - 53 FR 23977 -
June 24, 1988.
National Oil and Hazardous Substances Contingency Plan. The National
Priorities list for Uncontrolled Hazardous Waste Sites. final Rule Public
pocket - Update 7.54 FR 48184 - November 21, 1989.
2.
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2.0
2.3
Page 2
Removal Response
2.1
Cotrespondence
1. Letter from Raymond G. Esposito, Union Chemical Co., Inc. to George
Powell, State of Maine Department of Environmental Protection
(November 23, 1976). Concerning the processing of waste water.
2. Letter from Joseph N. DeCola, EPA Region I to Donald M. Bisset, State of
Maine Department of Public Safety (December 7, 1979). Concerning potential
fire hazard at the site.
3. Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Richard C.
Boynton, EPA Region I (December 4, 1981). Concerning information on the
boiler.
4. "Union Chemical Company Drum Reduction Plan," Union Chemical Co., Inc.
(May 14, 1984).
5. Letter from Henry E. Warren, State of Maine Department of Environmental
Protection to Clifford H. Goodall, Dyer, Goodall and Zeegers (Attorney for
Union O1emical Co., Inc.) (May 23,1984). Concerning drum reduction plan
and log of waste quantities.
6. Letter from Clifford H. Goodall, Dyer, Goodall and Zeegers (Attorney for
Union Chemical Co., Inc.) to Henry E. Warren, State of Maine Department of
Environmental Protection (May 25, 1984). Concerning response to
May 24, 1984 letter from Henry E. Warren, State of Maine Department of
Environmental Protection.
7. Letter from Henry E. Warren, State of Maine Department of Environmental
Protection to Michael R. Deland, EP A Region I (August 2, 1984). Concerning
confirmation of working relationship between EPA and the State.
8. Letter from David E. Boulter, State of Maine Department of Environmental
Protection to Merrill S. Hohman, EPA Region I (August 20,1984). Concerning
clarification that the State of Maine Department of Environmental Protection is
not a generator of the hazardous waste at the site, and will not assume
responsibility as a generator.
9. Memorandum from Hank Aho, State of Maine Depanment of Environmental
Protection to File (October 6, 1984). Concerning comments on cleanup.
10. Letter from Henry E. Warren, State of Maine Department of Environmental
Protection to Michael R. Deland, EPA Region I (October 24, 1984).
Concerning compliments to EPA for its effons in cleaning up the site.
11. Letter from Cynthia S. Benocci for Henry D. Aho, State of Maine Department of
Environmental Protection to Raymond G. Esposito, Union Chemical Co., Inc.
(May 30, 1985). Concerning erection of a fence.
12. Letter from Henry E. Warren, State of Maine Department of Environmental
Protection to Gifford H. Goodall, Dyer, Goodall & Zeegers (Attorney for
Union Chemical Co., Inc.). Concerning drum reduction plan and log of waste
quantities.
Sampling and Analysis Data
1.
2.
Sample Locations, State of Maine Department of Environmental Protection
(May 7, 1979) with the attached maps and analytical data.
Memorandum from Richard Siscanaw, EPA Region I to Edward L. Taylor, EPA
Region I (February 8, 1980). Concerning the attached samples from Quiggle
Brook.
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Scott L. Mason..
State of Maine Department of Environmental Protection (August 18, 1981).
Concerning the attached preliminary baseline data for the air quality moni tOTing
program.
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2.3
Page 3
Sampling and Analysis Data (cont'd.)
4. Letter from Raymond G. Esposito, Union Chemical Co., Inc. to David A. Dumas.
State of Maine Depanment of Environmental Protection (February 12, 1982).
Concerning attaChed test results on still room exhaust, boiler staCk, and
incinerator.
5. "Union Chemical Trial Burn - Sampling and Analysis - Final Report," GCA
Corporation (February 1984).
6. Memorandum from David A. Dumas, State of Maine Department of Environmental
Protection to John Chandler, State of Maine Department of Environmental
Protection (March 15, 1984). Concerning trial test burn, heavy metal analysis of
feed stock. and particulate emissions.
7. Memorandum from Frank W. Ulley, EPA Region I to Paul Groulx, EP A
Region I (December 24, 1984). Concerning the attaChed "Air Toxics Study," EPA
Region L
8. Letter from James J. Lysen, State of Maine Department of Environmental
ProteCtion to Bob Shanen, EPA Region I (January II, 1985). Concerning results
on water samples from wells, dikes, trenches, and Quiggle Brook.
9. "Draft - Air Monitoring," Roy F. Weston, Inc. (February 7, 1985).
10. Tank Sampling and Analysis Data, EPA Region 1.
The Drwn Logs tmd any remaining Sampling tmd Analysis Data/or the Removal
Response may be reviewed, by appointment only, at EPA Region I, Boston,
Massachusetts.
2,4
pollution Reports (POLREPs)
POLREPs are progress reports which are prepared as needed by the EPA Region I
On-Scene Coordinator to convey progress on the site to State, Local, and Federal
agencies during a Removal Action.
2.5
1. POLREP 1, EPA Region I(August 11, 1984).
. 2. POLREP 2, EPA Region I (August 20,1984).
3. POLREP 3, EPA Region I (August 27,1984).
4. POLREP 4, EPA Region I (September 4, 1984).
5. POLREP 5, EPA Region I (September II, 1984).
6. POLREP 6, EPA Region I (September 17, 1984).
7. POLREP 7, EPA Region I (September 19,1984).
8. POLREP 8, EPA Region I (September 24, 1984).
9. POLREP 9, EPA Region I (September 28, 1984).
10. POLREP 10, EPA Region I (October 9, 1984).
11. POLREP 11, EPA Region I (October 15, 1984).
12. POLREP 12, EPA Region I (October 16, 1984).
13. POLREP 13, EPA Region I (October 17, 1984).
14. POLREP 14, EPA Region I (October 18, 1984).
15. POLREP 15, EPA Region I (October 19,1984).
16. POLREP 16, EPA Region I (October 22, 1984).
17. POLREP 17,EPA Region I (October 27, 1984).
18. POLREP 18, EPA Region I (November 3,1984).
19. POLREP 19, EPA Region I (November 9,1984).
On-Scene Coordinator Reports
1.
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3.0
2.6
2.9
Page 4
Work Plans and Progress Repons
1.
2.
Work Plan and Field Protocols, EPA Region I (August 1984).
"Site Safety Plan," EPA Region I (August 1984).
Action Memoranda
1.
Memorandum from Donald F. B~ger, EPA Region I to Michael R Deland.
EPA Region I (August 10, 1984). Concerning a request for $400,000 to initiate
il11lTV'itiR~ removal action.
Memorandum from Donald F. Berger, EPA Region I to Michael R. Deland.
EPA Region I (September 14,1984). Concerning a ceiling increase for the
immediate removal action.
Memorandum from Edward 1. Conley, EPA Region I to Michael R Deland.
EPA Region I (October 5,1984). Concerning a ceiling increase for the
immediate removal action.
Memorandum from 1. Daniel Beny, EPA Headquarters to Lee M. Thomas. EPA
Headquarters (October 15, 1984). Concerning review of a request to increase
the authoriza1ioo far the im~Aiate removal action.
Memorandum from William N. Hedeman Jr., EPA Headquarters to Lee M.
Thomas, EPA Headquarters (October 15,1984). Concerning request to raise the
authorization for the immediate removal action to $1,2S0,OOO.
Memorandum from Michael R. Deland, EPA Region I to Lee M Thomas, EPA
Headquarters (October 19, 1984). Concerning a request to raise the
authorization for the immediate removal action to $1,500,000.
Memorandum from John J. Stanton, EPA Headquarters to William N. Hedeman
Jr., EPA Headquaners (October 23, 1984). Concerning approval of request to
raise the authorization for the im~te removal action to $1,500,000.
2.
3.
4.
5.
6.
7.
3.1
Remedial Investigation (RI)
Correspondence
1.
Letter from Steven L. Gerlcen, Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Michaellasinski, EPA Region I
(December 15, 1987). Concerning the transmittal of the worlc plans for the
Remedial Investigation and the Feasibility Study.
Letter from Steven L. Gerlcen, Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Michaellasinski, EPA Region I and Cynthia M.
Kuhns, State of Maine Department of Environmental Protection
(March 10, 1988). Concerning transmittal of the attached "Revised Text for
Laboratory Quality Assurance Manual."
Letter from Steven L. Gerken, Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Michael1asinsld, EPA Region I (April 7, 1988).
Concerning transmittal of the attached "Revision to Health and Safety Plan. to
Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Randy C. Smith, Temmce Hughes, and lames F. Green, Union
Chemical Site Trost (April 8, 1988). Concerning a request that the Union
Otemical Site Trust provide supplemental drinking water to "at risk" population
groups.
Letter from Paul R. Morin, Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Michaellasinski, EP A Region I (April 19 . 1988).
Concerning transmittal of the attached hospital route map from the Union .
Chemical Health and Safety Plan.
2.
3.
4.
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Page 5
3.1
Correspondence (cont'd.)
6. Lener from David P. Rosenblatt, Bums & Levinson (Attorney for Union
Chemical Site Trust) to Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (April 22, 1988). Concerning a request for
supplemental drinking water.
7. Letter from Steven L. Gerken, Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Michael Jasinski, EPA Region I and Cynthia M.
Kuhns, State of Maine Department of Environmental ProteCtion (May 11, 1988).
Concerning transmittal of revised ~ns of the "Project Plans - Initial Site
O1aracterization Work Plan - Project Operations Plan - Additional RIlFS Plans,"
Canonie Environmental Services Corp. for the Union Chemical Site Trust
(May 1988).
8. Letter from Steven L. Gerken, Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Michael Jasinski, EPA Region I and Cynthia M.
Kuhns, State of Maine Department of Environmental ProteCtion (May 16, 1988).
Concerning transmittal of Corrected pages of the "Project Plans - Initial Site
Characterization Work Plan - Project Operations Plan - Additional RIlFS Plans,"
Canonie Environmental Services Corp. for the Union Chemical Site Trust
(May 1988, with June 1, 1988 Revisions/Additions).
9. Letter from David P. Rosenblatt, Bums & Levinson, and Louis N. Massery,
Cooley, MaWao,..Moore & Jones, P.e. (Attorneys for the Union Chemical Site
Trust) to Cynthi~ Me 1ClIh~ S1a8C of Maine Department of Environmental
ProteCtion (June 17 ~ 1988). Concerning the Union Chemical Site Trust's
decision not to provide supplemental drinking water because nearby wells did
not show contamination.
10. Lener from Cynthia M. Kuhns, State of Maine Department of EnvironmentaJ
Protection to James F. Green, North East Solvents (June 20, 1988).
Concerning clarification of due dates for Phase 2 of the Remedial Investigation!
Feasibility StUdy.
11. Lener from Michael Jasinski, EPA Region I to Steven L. Gerken, Canonie
Environmental Services Corp. for the Union Chemical Site Trust
(August 2, 1988). Concerning the transmittal of guidance documents to be used
during the Remediallnvestigation/FeaSibility StUdy activities.
12. Letter from Mark J. Leibrock, Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Mr. and Mrs. John Jensen (September 2, 1988)
with the attached form letters to the following residents:
A. Dr. and Mrs. Kenneth Guiseley.
B. Ms. Arlene Crabtree.
C. Mr. and Mrs. Elmer Hart.
D. Mr. "and Mrs. Harold Cushman.
E. Mr. and Mrs. Dana Winchenbach.
F. Mr. and Mrs. Roben Shaw.
G. Mr. and Mrs. Donald Pushaw.
H. Mr. and Mrs. Henry Hastings.
I. Mr. Charles Lawson.
J. Mr. Scott Bissen.
K. Mr. and Mrs. Brian S. Powers.
L. Mr. and Mrs. Gordon Talbot
M. Mr. and Mrs. Charles Martz.
N. Mr. and Mrs. William Bryant
O. Ms. Hope Chase.
P. Mr. and Mrs. Harold Menifield.
Q. Ms. Sandra MacA voy.
R. Mr. and Mrs. Steven Bowman.
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Page 6
3.1
CoITespondence (cont'd.)
,T. Mr. and Mrs. Jeffrey Perkins.
U. Mr. Dennis Hall. .
V. Mr. and Mrs. Albert Hastings.
W. Mr. and Mrs. Neil Fogg.
X. Mr. George Burr.
Y. Mr. Broce Melanson.
Z . Mr. and Mrs. Dinsmore.
AA. Mr. and Mrs. Stanley.
Concerning the third quanerly residential well sampling round to be performed
on September 16, 1988.
13. Letter from Steven L. Gerken, Canonie Environmental Services Corp. for the
Union Chemical Site Trost to Michael Jasinski, EP A Region I and Cynthia M.
Kuhns, State of Maine Department of Environmental Protection
(November 18,1988). Concerning the transmittal of "Initial Site
O1aracterization," Canonie Environmental Services Corp. for the Union
Chemical Site Trost (November 1988).
14. Letter from Steven L. Gerken, Canonie Environmental Services Corp. for the
Union Chemical Site Trost to Michael Jasinski, EPA Region I and Cynthia M.
Kuhns, State of Maine Department of Environmental Protection
(January II, 1989). Concerning transmittal of the January 1989 "Draft - Work
Plan: Pbase m Remedial Investigation and Post-Screening Field Investigation,"
Canonie Environmental S~ces Corp. for the Union Chemical Site Trust.
15. Letter from Dayjd M. Webster, EPA Region I to James F. Green, Union
Otemical Sire Trust (December 12,1989). Concerning notice to proceed with
Phase 4, "Post Screening Field Investigations," as outlined in Section 7 of the
technical support document included in the signed September 16, 1987
Administrative Order.
16. Letter from David W. Wright, State of Maine Department of Environmental
Protection to James F. Green, Union Chemical Site Trust (December 12, 1989).
Concerning a notice to proceed with Phase 4, "Post Screening Field
Investigations," as outlined in Section 7 of the technical support document
included in the signed September 16, 1987 Administrative Order.
17. Letter from David M. Webster, EPA Region I to James F. Green, Union
Otemical Site Trost (December 14, 1989). Concerning notification of the
granting of an extension of time with the attached:
A. Comments Dated August 23, 1989 from David M. Webster, EPA ~egion I
on the August 1989 "Phase IB Remedial Investigation Work Plan,"
Canonie Environmental Services Corp. for the Union Chemical Site Trust
B. Letter from James F. Green, Union Clemical Site Trust to Michael
Jasinski, EP A Region I and David W. Wright, State of Maine Department
of Environmental Protection (October II, 1989). Concerning notification
of delay and request for an extension of time.
C. Letter from James F. Green, Union Clemical Site Trost to Michael
Jasinski, EPA Region I (November 22, 1989). Concerning a request for
extension of time for project deliverables.
18. Letter from Michael Jasinski, EPA Region I to Doug Anderson, Canonie
Environmental Services Corp. for the Union Chemical Site Trost
(December 14, 1989). Concerning transmittal of a groundwater elevations data
diskette.
19. Letter from Michael Jasinski, EPA Region I to Doug Anderson, Canonie
Environmental Services Corp. for the Union Chemical Site Trust
(January 3, 1990). Concerning additional guidance and data for preparation of
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3.1
Page 7
Correspondence (cont'd.)
20. Letter from David M. Webster, EPA Region I to James F. Green, Union
O1emical Site Trost (March 26, 1990). Concerning formal notice to proceed
with Phase 6, "Remedial Investigation/Fea.Sibility Study Review."
21. Lettc'r from David W. Wright, State of Maine Depanment of Environmental
Protection to James F. Green, Union Chemical Site Trust (March 26, 1990).
Concerning formal notice to proceed with Phase 6, "Remedial
Investigation/FeaSibility Study Review."
3.2
Sampling and Analysis Data
Letter Repon from Steven L. Gerken, Canonie Environmental Services Corp.
for the Union Chemical Site Trust to Michael Jas~ EPA Region I and
Cynthia Kuhns, State of Maine Deparunent of Environmental Protection
(January 5, 1989). Concerning additional information on methyl ethyl ketOne
analyses and ground water data interpretation.
Letter Repon from Steven L. Gerken, Canonie Environmental Services Corp.
for the Union O1emical Site Trust to Michael Jasinski, EPA Region I and David.
W. Wright, State of Maine Department of Environmental ProteCtion
(June 23.1989). Concerning additional information on cyanide analysis results.
The remaining Sampling and Analysis Datafor the Remedial Investigation (Rl) may be
reviewed, by appointment only, at EP A Region I, Boston, Massachusetts.
1.
2.
3.4
Interim Deliverables
Reports
Letter from Susan E. Mulholland. Canonie Environmental Services Corp. for the
Union Chemical Site Trust to Michael Jasinski, EPA Region I and Cynthia M.
Kuhns, State of Maine Department of Environmental ProteCtion
(August 17. 1988). Concerning tranSmittal of the attached August 10, 1988
"Air Monitoring Analytical LaboratOry Report," Cayton Environmental
Consultants. Inc. for Canonie Environmental Services Corp. for the Union
O1emical Site Trust
''Draft -Initial Site O1aracterization - Volume 1 of 2," Canonie Environmental
Services Corp. for the Union Chemical Site Trust (November 1988).
''Draft - Initial Site O1aracterizarlon - Volume 2 of 2," Canonie Environmental
Services Corp. for the Union Chemical Site Trust (November 1988).
The maps assodDted with the record cited in entry 1UI11Iber 4 may be reviewed, by
appointment only, at EPA Region 1. Boston. Massachusens.
1.
2.
3.
4.
S.
"Draft Wet1aMg Assessment, "1be Sman AssociateS for Canonie Environmental
Services Corp. for the Union Chemical Site Trust (October 9. 1989).
"Draft - Final Repon - Evaluation of Fractures in Four (4) Bedrock Wells,"
Technos Inc. for Canonie Environmental Services Corp. for the Union Chemical
Site Trust (November 1989).
"Draft Phase m - Initial Site Charactc:rization Addendum - Volume lof3,"
Canonie Environmental Services Corp. for Union Chemical Site Trust
(January 1990). .
"Draft Phase m - Initial Site Qlaracterization Addendum - Volume 2 of 3,"
Canonie Environmental Services Corp. for Union Chemical Site Trust
(January 1990).
6.
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Page 8
3.4
Interim Delivc:ables (cont)
Reports
"Draft Phase IB - Initial Site Charactc:rization Addendum - Volume 3 of 3,"
Canonie Environmental Services Corp. for Union Chemical Site Trust
(January 1990).
Comments
8.
3.5
9. Comments Dated January 17. 1989 from Marc A. Lappe, Ph.D. Consultant for
the Township of Hope on the November 1988 "Draft -Initial Site
O1aracterization - Volumes 1 and 2," Canonie Environmental Services Corp. for
the Union Chemical Site Trost. .
10. Meeting Notes, Carolie MAJ. Lamer, Conoemed Gtizens of Hope and Michael
Jasinski, EPA Region I (May 18,1989). Concerning Mrs. Lamer's Comments
on the November 1988 "Draft - Initial Site O1aracterization - Volumes I and 2,"
Canonie Environmental Services Corp. for the Union Chemical Site Trust
11. Comments Dated May 18, 1989 from Carolie MAJ. Lamer, Concerned Citizens
of Hope on the November 1988 "Draft -Initial Site Characterization - Volumes 1
and 2," Canonie Environmental Services Corp. for the Union Chemical Site
Tmst with the attached:
A. "Presentation to the Joint Standing Canminee on Utilities," David L. Hall
(May 17, 1989).
"Statement of Support ofLD 934" (April 26, 1989).
"LD. 934 - Statement of Marc A. Lappe, PhD." (May 17,1989).
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Edward
Logue, State of Maine Department of Environmental Protection
(May 11,1982). Concerning the attached records on April 23, 1982 fire.
12. Comments Dated Decem~ 12, 1989 from David W. Wright, State of Maine
Department of Environmental Protection on the November 1989 "Draft Final
Report - Evaluation of Fractures in Four (4) Bedrock Wells," Technos Inc.
Applicable or Relevant and Appropriate Requirements (ARARs)
1. Letter from Merrill S. Hohman, EPA Region I to Alan M. Prysunka, State of .
Maine Department of Environmental ProteCtion (Decem~ 28, 1989).
Concerning a request that the Swe of Maine identify those ARARs which were
promulgated under the States's environmental statutes.
2. Letter from Alan M. Prysunka, State of Maine Department of Environmental
Protection to Menill S. Hohman, EPA Region I (February 23,1990).
Concerning applicable or relevant and appropriate staDdards, req~ments,
criteria, or limitations with the attached:
A. "Toxic Equtvalency Factors and Land Application Criteria"
B. "Snl1't11'W)' of State and Federal Drinking Water Guidelines"
C. "Bureau of Water Quality Control- Policy Number 10: The Discharge of
Hazardous Substances to Groundwaters of the State."
B.
C.
D.
3.6
Remedial Investigation (RI) Reports
1.
2.
"Draft Report - R~i~1 Investigation - Volume 10f 2," Canonie
Environmental Services Corp. for Union Chemical Site Trost (February 1990).
"Draft Report - R~i~1 Investigation - Volume 2 of 2," Canonie
Environmental Services Corp. for Union Chemical Site Trust (February 1990).
"Final Draft Report - RemM;a1 Investigation/Fcasibility Study - Volume 1 of 4."
Canonie Environmental Services Corp. for Union Chemical Site Trust
(June 1990). .
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~- . -- -
3.6
-,--_.~- -
Page 9
Remedial Investigation (RI) ReportS (cont'd-)
3.7
"Final Draft Repon - Remediallnvestigation/Feasibility Study - Volume 2 of 4,"
Canonie Environmental Services Corp. for Union Chemical Site Trust
(June 1990).
"Final Draft Repon - Remedial Investigation/Feasibility Study - Volume 3 of 4,"
Canonie Environmental Services Corp. for Union Chemical Site Trost
(June 1990).
Qoss-Reference: "Fmal Draft Repon - RemcdiallnvestigationIFeasibility
Study - Volume 4 of 4," Canonie Environmental Services Corp. for Union
Chemical Site Trost (June 1990) [Filed and cited as entry number 4 in 4.6
Feasibility Study (FS) Reports].
Work Plans and Progress Reports
4.
5.
6.
Work. Plans
1.
"Project Plans -Initial Site O1aracterization Work Plan - Project Operations
Plan - Additional RIIFS Plans," Canonie Environmental Services Corp. for the
Union Chemical Site Trost (March 1988. with the May 1988 and the June 1,
1988 Revisions and Additions).
"Draft - Work Plan: Phase IB Remedial Investigation and Post-Screening Field
Investigation," Canome Environmental Services Corp. for the Union Chemical
Site Trost (January 19S9}.
"Proposed Change to Monitoring Well MW-13 Construction Details," Canonie
Environmental Services Corp. for the Union Chemical Site Trost
(August 21. 1989).
"Phase m Remedial Investigation Work Plan." Canonie Environmental Services
Corp. for the Union Chemical Site Trost (August 1989).
Letter Repon from Steven L. Gerken, Canonie Environmental Services Corp.
for the Union Chemical Site Trost to Michael Jasinski. EPA Region I and David
W. Wright, State of Maine Department of Environmental ProteCtion
(September 15,1989). Concerning the revised "Well MW-13 Construction
Details. ,,-
Letter Repon from Jui- Yu Hsieh, EP A Region I to Michael Jasinski. EP A
Region I (November 9, 1990). Concerning groundwater cleanup levels for the
site.
2.
3.
4.
5.
6.
Comments
7. Comments Dated June 21, 1989 from Carotie MAJ. Lamer, Concerned Qriuns
of Hope on the January 1989 "Draft - Work Plan: Phase m Remedial
Investigation and Post-Screening Field Investigation," Canonie Environmental
Services Corp. for the Union Chemical Site Trost.
8. Comments Dated July 2, 1988 from Marc A. Lappe, Ph.D. Consultant for the
Township of Hope on the May 1988 "Initial Site Characterization Work Plan,"
Canonie Environmental Services Corp. for the Union Chemical Site Trust.
9. Comments Dated August 23, 1989 from David M. Webster, EPA Region 1 on
the August 1989 "Phase IB Remedia1lnvestigation Work Plan," Canonic
Environmental Services Corp. for the Union Chemical Site Trost with anached
"Quality Assurance Acceptance" Form. EPA Region I (August 23, 1989).
10. Comments Dated September 19,1989 from David W. Wright, State of Maine
Department of Environmental ProteCtion on the September 15, 1989 Letter
Repon from Steven L. Gerken, Canonie Environmental Services Corp, for the
Union Chemical Site Trost to Michael Jasinski, EPA Region I and David W.
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Page 10
3.7
Work Plans and Progress Repons (cont'd.)
Work Plans
11. Meeting Notes, Carotie MAJ. Lamer, Concerned Citizens of Hope, EP A
Region I, State of Maine Department Of Environmental Protection, State of
Maine Board of Health, and Canonie Environmental Services Corp.
(October 26, 1989). Concerning comments on the January 1989 "Draft - Work
Plan: Phase IB Remedial Investigation and Post-Screening Field Investigation,"
Canonie Environmental Services Corp., for the Union Chemical Site Trust.
12. Comments Dated January 14, 1990 from Marc A. Lappe, Ph.D. Consultant for
the Township of Hope on the August 1989 "Phase IB Remedial Investigation
Work Plan," Canonie Environmental Services Corp. for the Union Chemical
Site Trust.
Responses to Comments
13. Response Dated September 6, 1989 from Michael Jasinski, EPA Region Ion the
June 21, 1989 Comments from Carotie MAJ. Lamer, Concerned Citizens of
Hope.
Progress Reports
14. "Monthly Status Repon No. I," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (December 30, 1987).
15. "Monthly Status Repon No.2," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (January 28, 1988).
16. "Monthly Status Repon No.3," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (February 29,1988).
17. "Monthly Status Repon No.4," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (April 1, 1988).
18. "Monthly Status Repon No.5," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (April 28, 1988).
19. "Monthly Status Repon No.6," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (June I, 1988).
20. "Monthly Status Repon No.7," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (July I, 1988). .
21. "Monthly Status Repon No.8," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (August 1, 1988).
22. "Monthly Status Repon No.9," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (September I, 1988).
23. "Monthly Status Repon No. 10," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (September 27, 1988).
24. "Monthly Status Repon No. 11," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (October 31, 1988) with attachments.
25. "Monthly Status Repon No. 12," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (December 2, 1988) with attachments.
26. "Monthly Status Repon No. 13," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (December 29, 1988).
27. "Monthly Status Repon No. 15," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (February 27, 1989).
28. "Monthly Status Repon No. 16," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (March 30, 1989).
29. "Monthly Status Repon No. 18," Canonie Environmental Services Corp. for.
Union Chemical Site Trust (May 31, 1989).
30. "Monthly Status Repon No. 19," Canonie Environmental Services Corp. for
Union Chemical Site Trust (July 3, 1989).
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Page 11
Work Plans and Progress Repons (cont'd.)
Progress Reports
3.7
.
31. "Monthly Status Repon No. 20," Canonie Environmental Services Corp. for
Union Chemical Site Trust (July 31,1989).
32. "Monthly Status Repon No. 21," Canonie Environmental Services Corp. for
Union Chemical Site Trust (September 7, 1989) with attachments.
33. "Monthly Status Repon No. 22," Canonie Environmental Services Corp. for
Union Chemical Site Trust (October 10, 1989).
34. "Monthly StatUs Repon No. 23:' Canonie Environmental Services Corp. for
Union Chemical Site Trust (November 8, 1989). .
35. "Monthly Status Repon No. 24," Canonie Environmental Services Corp. for
Union Chemical Site Trust (December 5,1989).
36. "Monthly Status Repon No. 25," Canonie Environmental Services Corp. for
Union Chemical Site Trust (December 27, 1989).
37. "Monthly Status Repon No. 26," Canoirle Environmental Services Corp. for
Union Chemical Site Trust (January 30, 1990).
38. "Monthly Status Repon No. 27," Canonie Environmental Services Corp. for
Union Chemical Site Trust (February 27,1990).
39. "Monthly Status Repon No. 28," Canonie Environmental Services Corp. for
Union Chemical Site Trust (March 29, 1990).
40. "Monthly Stams Repon No. 29:' Canonie Environmental Services Corp. for the
Union Chemical Site Trust (April 30, 1990).
41. "Monthly Status Repon No. 30," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (May 31,1990).
42. "Monthly Status Repon No. 31," Canonie Environmental Services Corp. for the
Union Chemical Site Trust (July 5, 1990). .
Health Assessments
v
3.9
1.
"The Prevalence of Selected Health Problems of Residents Living in the Vicini ty
of the Union Chemical Company," State of Maine Depanment of Hwnan
Services (December 1983).
Letter from Greg Bogdan, State of Maine Depanment of Human Services to
Board of Selectmen and Health Officer Township of Hope (October 17, 1985)
with the attaChed ''Effects of Fish Pond Drawdown on Groundwaters in
Proximity of Union Chemical in Hope, Maine." Concerning the health risk
evaluation of water drawn from Fish Pond.
''Health Assessment," U.S. Department of Health and Human Services Agency
for Toxic Substances and Disease Registry (ATSDR) (September 2,1988).
"Information to the EPA Administrative Record." U.S. Department of Health
and Human Services Agency for Toxic Substances and Disease Registry
(ATSDR) (Octobcr9. 1990).
2.
3.
4.
3.10 Endangerment Assessments
Endangerment Assessmentsfor the Union Chemical Co., Inc. NPL site (also referred
10 as the Baseline Risk Assessment) may befound in the February 1990 "Draft
Report -Remedial Investigation - Vo~ 1 of2," Canonie Environmentalfor Union
Chemical Co., Inc.
1.
Memorandum from Jui-Yu Hsieh, EPA Region I to Michael Jasinski, EPA
Region I (November 30, 1990) with attachments. Concerning health risks for
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- _... -- .,.-.--- .~-_..._. - -....L..--
4.0
4.6
Page 12
Feasibility Study (FS)
4.1
Correspondence
4.2
Letter from David W. Wright., State of Maine Depanment of Environmental
Protection to James F. Green, Union Chemical Site Trost (February 5, 1990).
Concerning notice to proceed with Phase 5, "Detailed Analysis of Alternatives."
Letter from David M Webster, EPA Region I to James F. Green, Union
Chemical Site Trost (February 5, 1990). Concerning notice to proceed with
Phase 5, "Detailed Analysis of Alternatives. "
Sampling and Analysis Data
1.
2.
4.4
Memorandum from Jui-Yu Hsieh, EPA Region I to Michael Jasinski, EPA
Region I (November 9, 1990). Concerning the use of PMCLs rather than
MEGs as groundwater cleanup levels.
Interim Deliverables
1.
4.5
"Union Chemical Company - Oean-up: Evaluation of Options," State of Maine
Department of Environmental Protection (November 6, 1985).
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
Letter from David P. Rosenblatt., Bums & Levinson (Attorney for Union
Chemical Site Trust) to Marjorie Adams, EPA Region I (June 21, 1990).
Concerning whether or not the State of Maine Bmeau of Health "Maximum
Exposure Guidelines" constitute Applicable or Relevant and Appropriate
Requirements (ARARs).
Letter from Margery L. Adams, EPA Region I to David W. Wright, State of
Maine Department of Environmental Protection (December 5, 1990).
Concerning EPA's position that maximum exposure guidelines established by
the State are not acceptable within the meaning of Section 121 of CERCLA.
Feasibility Study (FS) Reports
1.
2.
1.
Cross-Reference: "Final Draft Repon - Remedial Investigation/Feasibility
Study - Volume 1 of 4," Canonie Environmental Services Corp. for Union
Chemical Site Trust (June 1990) [Filed and cited as entry number 1 in 3.6
Remedial Investigation (RI) Repons].
Cross-Reference: "Final Draft Repon - Remedial InvestigationlFeasibility
Study - Volume 2 of 4," Canonie Environmental Services Corp. for Union
Chemical Site Trust (June 1990) [Filed and cited as entry number 2 in 3.6
Remedial Investigation (RI) Reports].
Cross-Reference: "Final Draft Repon - Remedial Investigation/Feasibility
Study - Volume 3 of 4," Canonie Environmental Services Corp. for Union
Chemical Site Trust (June 1990) [Filed and cited as entry number 3 in 3.6
Remedial Investigation (RI) Reports].
''Final Draft Repon - Remedial Investigation/Feasibility Study - Volume 4 of 4,"
Canonie Environmental Services Corp. for Union Chemical Site Trust
(June 1990).
2.
3.
-------
4.7
4.9
-- -. -...'
Page 13
Work Plans and Progress Reports
Progress Report, Canonie Environmental Services Corp. for the Union
Chemical Site Trust (July 30, 1990).
Progress Report, Canonie Environmental Services Corp. for the Union
Chemical Site Trust (Sepu::mbcr 6. 1990).
Proposed Plans for Selected R~;a1 Action
1.
2.
"EPA Proposes Oeanup Plan for the Union Chemical Co., Inc. Superfund
Site," EPA Region I (July 1990).
Record of Decision (ROD)
5.0
1.
5.1
Correspondence
1.
Memorandum from Don R Clay, EPA Headquarters to Regional
AdministratorS, EPA Regions I-X (January 29, 1990). Concerning the
delegation of selection of remedy authority for all Superfund Records of
Decision (RODs) scheduled for signature during fiscal year 1990.
Cross-Reference: "Draft - Proposed Record of Decision (ROD) Schedule," EP A
Region I (March 13, 1990) [FlIed and cited as attachment A in entry number 76
in 13.1 Correspondence].
2.
5.3
Responsiveness Summaries
Cross-Reference: Responsiveness Snmmary is ~ A of the Record of
Decision [Filed and cited as CDtI)' number 1 in 5.4 Record of Decision (ROD).
The following citations indicate written Co~1IlS received lJy EP A Region 1 during
the formal public comment period.
1.
2.
Letter from Brian S. Powers, Hope's Committee for a Clean Environment to
Julie D. Belaga, EPA Region I (July 23,1990). Concerning request for a
3O-day extension of the public comment period.
Letter from Carolie MAJ. Lamer, Conc:erncd Citizens of Hope to Michael
Jasinski, EPA Region I (July 27,1990). Concerning prior request for an
extension of the public comment period.
Letter from Brian S. Powers, Hope's Committee for a Oean Environment to
Julie D. Belaga, EP A Region I (July 27, 1990). Concerning request for an
extension of the public comment period and a postponement of the public
hearing.
CommentS Dated August 1~ 1990 from Dean C. Manion. State of Maine
DepanmentofEnvironmental Protection on the July 1990"EPA Proposes
Oeanup Plan for the Union Chemical Co., Inc. Superfund Site," EPA Region I.
Letter from Merrill S. Hohman, EPA Region I to Brian S. Powers, Hope's
Committee for a Oean Environment (August 21, 1990). Concerning the denial
of Mr. Power'uequest for.an.exte'Minn of the public .comment period. .
Letter from Marshall J. Tinkle, Thompson, McNaboe, Ashley & Bull to Michael
Jasinski, EPA Region I (August 23,1990). Concerning request for an
extension of the public comment period.
Letter from Paul L. Gibbons, Eaton, Peabody, Bradford & Veague, P.A.
(Anomey for the Selectmen and citizens of the Town of South Hope) to Julie D.
Belaga, EPA Region I (August 28, 1990). Concerning scheduling of the
additional public meeting.
3.
4.
5.
6.
7.
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-'..
5.4
Page 14
5.3
Responsiveness Summaries (cont'd.)
9. Letter from Julie D. Belaga, EPA Region I to Paul L. Gibbons, Eaton, Peabody,
Bradford & Veague, P.A. (Attorney for the Selectmen and citizens of the Town
of South Hope) (September 27, 1990). Concerning scheduling of the additional
public meeting.
10. CommentS Dated September 28, 1990 from Jeffrey L. McNelly, Camden and
Rockland Water Company on the July 1990 "EPA Proposes Oeanup Plan for
the Union Chemical Co., Inc. Superfund Site", EPA Region I.
11. CommentS Dated October I, 1990 from Beverly Paigen, PhD. for Hope's
Committee for a Oean Environment on the July 1990 ''EPA Proposes Cleanup
Plan for the Union Chemical Co., Inc. Superfund Site," EPA Region I.
12. CommentS Dated October 2, 1990 from Arlene Oabtree concerning possible
well contamination and devaluation of her property.
13. CommentS Dated October 2, 1990 from James F. Green, Roben Eastman, and
Terrance Hughes, Union Chemical Site Trust on the July 1990 "EPA Proposes
Cleanup Plan for the Union Chemical Co., Inc. Superfund Site," EPA Region I.
14. CommentS Dated October 3, 1990 from Randy C. Smith, Union Chemical Site
Trust on the July 1990 "EPA Proposes Oeanup Plan for the Union Otemical
Co., Inc. Superfund Site," EPA Region I.
15. CommentS Dated October 4, 1990 from John H. and Lois A. Jensen on the
July 1990 "BPA Proposes Oeanup Plan for the Union Chemical Co., Inc.
Superfund Site," EP A Region I.
16. CommentS Dated October 5,1990 from Benjamin Ross, Disposal Safety
Incorporated for Hope's Committee for a Oean Environment on the
June 1990 ''Final Draft Report - Remedial Investigation/Feasibility Study"
and the July 1990 "EPA Proposes Oeanup Plan for the Union Chemical Co.,
Inc. Superfund Site," EP A Region I.
17. CommentS Dated October 23, 1990 from Marc A. Lappe, Ph.D. on the
July 1990 "EPA Proposes Oeanup Plan for the Union Chemical Co., Inc.
Superfund Site,"EPA Region I.
18. CommentS Dated October 25, 1990 from Carolie MAJ. Lamer, Concerned
Citizens of Hope concerning withdrawal of testimony given at August 23, 1990
Public Hearing.
Response to CommentS
19. CommentS Dated October 16, 1990 from David W. Wright, State of Maine
Department of Environmental Protection concerning Union Chemical Site Trust
CommentS dated October 2, 1990.
Record of Decision (ROD)
1.
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Page 15
9.0
State Coordination
9.1
Conespondence
Letter from Mc:nill S. Hohman. EPA Region I to Harold Kimball, State of
Maine Planning Office (August 18, 1987). Concerning the proposed Superfund
Project.
Letter from Duane A. Scott, State of Maine Department of Transportation to
David M. Webster. EPA Region I (October 8,1987). Concerning a request to
be added to the mailing list.
10.0 Enforcement
1.
2.
u
10.1 Correspondence
Letter from Henry E. Warren, State of Maine Department of Environmental
Protection to Clifford R Goodall, Lund Wille Scott & Goodall (Attorney for
Union Chemical Co., Inc.) (November 28, 1979). Concerning the state's
enforcement of the 1979 waste discharge license.
Letter from Merrill S. Hohman, EPA Region I to James F. Green, Union
O1emical Site Trust (August 27, 1990). Concerning penalty payment for failure to
comply with deadline.
Letter from David W. Wright, State of Maine Department of Environmental
ProteCtion to Randy C. Smith, Union Chemical Site Trust (August 31, 1990).
Concerning penalty payment for failure to comply with deadHl'1e.
Letter from Robert D. Eastman. Union Chemical Site Trust to Superfund
Accounting (September 6, 1990). Concerning check for penalty payment.
10.3 State and Local Enforcement Records .
1.
2.
3.
4.
l.
2.
''Waste Discharge license Certificate," State of Maine (September 13, 1976).
Letter from George W. Lord, State of Maine Departtnent of Environmental
Protection to Raymond G. Esposito, Union Chemical Co., Inc. (August 2, 1979).
Concerning discharge of pollutants in violation of 38 M.R.S.A. 413 and 414.5.
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Henry E.
Wanen, State of Maine Department of Environmental Protection
(August 13, 1979). Concerning objection to enforcement actions. .
Letter from Robert A. Demkowicz, State of Maine Department of Environmental
ProteCtion to Clifford R Goodall, Lund, Wilk, Scott & Goodall (Attorney for
Union Chemical Co., Inc.) (September 14, 1979). Concerning coordination of
the Consent Decree for the Union Chemical facility.
Letter from Qifford H. Goodall, Lund W1lk Scott & Goodall (Anomey for Union
Chemical Co., Inc.) 10 Henry E. WmeD, State of Maine Deparunent of
Environmental Protection (October 17, 1979). Concerning the plan to upgrade the
chemical ~g plan.
Letter from Qifford R Goodall, Lund W1lk Scott & Goodall (AttOrney for Union
O1emical Co., Inc.) 10 John Bastey, State of Maine Department of Environmental
Protection (October 17,1979). Concerning the plans and progress in upgrading
the site.
"Statement of Deficiencies and Plan of Correction," State of Maine Depanmen t of
Public Safety (January 8,1980).
"Source Permit Application," Union Chemical Co., Inc. (August 4, 1980).
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to David A. Dumas,
State of Maine Department of Environmental Proteetion (August 12, 1980).
Concerning the transmittal of the attached August 11, 1980 "Application for Air
Emission License."
3.
4.
5.
6.
7.
8.
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Page 16
10.3 State and Local Enforcement Records (oont'd.)
10. "Interim License for HazArdous Waste Facility," State of Maine
(August 13, 1980).
11. "Draft - Finding of Fact & Order," State of Maine Department of Environmental
Protection (November 12,1980) with the attached November 12.1980 "Air
Emission License." State of Maine Department of Environmental Protection.
12. Letter from George W. Lord. State of Maine Department of Environmental
Protection to Raymond G. Esposito, Union Chemical Co.. Inc.
(December 8. 1980). Concerning the contaminated water and monitoring
program.
13. Letter from George Kaplan. State of Maine Department of Environmental
Protection to Raymond G. Esposito, Union Chemical Co.. Inc.
(December 31.1980). Concerning the non-c:ompliance with manifest
requirements for shipments of hazardous wastes.
14. "Hazardous Material Incident Repon Form. " State of Maine Department of
Environmental Protection (February 5.1981). .
15. Letter from John A Kroeger. State of Maine Department of Environmental
Protection to Raymond G. Esposito, Union Chemical Co., Inc. (April 1, 1981).
Concerning warning about unlicensed storage of hazardous wastes.
16. "Memorandum of Understanding," John A Kroeger, State of Maine Department
of Environmental Protection, Raymond G. Esposito, Union Chemical Co., Inc.
(June 3~ 1981). Concerning schedule of contamination appraisal reports to be
supplied to the State of Maine.
17. Lener from Raymond G. Esposito. Union Chemical Co.. Inc. to John A.
Kroeger. State of Maine Department of Environmental Protection
(November 6.1981). Concerning the program for analysis and monitoring of
potential contaminant sources.
18. 'Waste Discharge License." State of Maine Department of Environmental
Protection (October 27.1982).
19. "Findings of Fact and Order- Air Emission License, Union Chemical Co., Inc.,"
State of Maine Department of Environmental Protection (December 8, 1982).
20. Letter from Robert A. Demkowicz, State of Maine Department of Environmental
Protection to Raymond G. Esposito. Union Chemical Co.. Inc.
(October 17.1983). Concerning notice of hazardous waste facility violation due
to inadequate aisle space. leaking drums. and inadequate storage.
21. Order of Board, In the Matter 01 Union Chemical Co.,lne., Hope Zoning Board
of Appeals (October 27,1983).
22. "Application for License for Hazardous Waste Facility under the Maine Hazardous
Waste. Septage, and Solid Waste Management Act (38 M.R.SA., Section 1301
et. scq.)," Union Chemical Co., Inc. (November 29,1983).
23. Letter from David A. Dumas. State of Maine Departtnent of Environmental
Protection to Raymond G. Esposito, Union Chemical Co., Inc.
(December 8, 1983). Coocaning the attached notice of violation of air emissions
license.
24. Letter from Henry E. Warren, State of Maine Depanment of Environmental
Protection to Raymond G. Esposito, Union Chemical Co., Inc.
(December 12, 1983). Concerning acceptance of the application for air emissions
license renewal
25. Letter from Stephen A. Tibetts, Union Chemical Co., Inc. to David A. Dumas,
State of Maine Department of Environmental Protection (December 16, 1983).
Concerning attached results of the feed stock analysis for heavy metals.
26. "Addendum to Application for License for Hazardous Waste Facility," Union
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Page 17
10.3 State and Local Enforcement Records (cont'd.)
27. Letter from Cifford H. Goodall, Lund Wille Scott & Goodall (Attorney for
Union Chemical Co., Inc.) to Henry E. Warren. State of Maine Department of
Environmental ProteCtion (March 27,1984). Concerning hazardous waste
facility license.
28. Administrative Order, In the Matter of Union Chemical Company, Inc.,
Designation of Uncontrolled Hazardous Substance Site and Order, State of
Maine Department of Environmental Protection (March 30, 1984).
29. Consent Decree, Henry E. Warren, Commissioner of the State of Maine
Department of Environmental Protection v. Union Chemical Co., Inc., State of
Maine Superior Court (May 7, 1984). .
30. Complaint far Declaratory and Injunctive Relief and Civil Penalties, Henry E.
Warren, Commissioner of the State of Maine Department of Environmental
Protection v. Union ChemicaI Co., Inc., State of Maine Superior Coun
(May 7. 1984).
31. Order, Henry E. Warren, Commissioner of Environmental Protection, Plainriff,
v. UnkJn Chemical Company, Inc., Defendant, Docket No. CV-84-199
(May 25, 1984).
32. Letter from James T. Kilbreth. State of Maine Department of the Attorney
General to Donald G. Alexander. Kennebec County Superior Coun
(May 31. 1984). Concerning transmittal of an order correcting an error in a
consent decree.
33. Letter from James T. Kilbreth. State of Maine Department of the Attorney
General to Clifford H. Goodall, Dyer, Goodall and Zeegers (Attorney for Union
Chemical Co., Inc.) (June 1, 1984). Concerning incineration and drum
reduction and inflow.
34. Findings of Fact & Order, In the MarrerofUnion Chemical Company
(June 27.1984).
35. Order. Henry E. Warren, Commissioner of the Stare of Maine Deparrment of
Environmental Protection v. Union Chemical Co., Inc., State of Maine Superior
Court, Civil Action Docket No. CV-84-199 (June 29, 1984).
36. Summons to Trustee, Henry E. Warren, Commissioner of Environmenral
Protection, Plaintiffv. Union Chemical Company, Inc., Defendont, Maine
National Bank, Trustee, Stale of Maine Superior Court CV -84-199
(July 2,1984) with the attached Writ of Attachment, Henry E. Wa"en,
Commissioner of Environmental Protection, Plainriffv. Union Chemical
Company, Inc., Defendant, State of Maine Superior Court CV -84-199
(July 3, 1984).
37. "Hazardous Waste Transponer and Generator Notification re: Oosure of Union
O1emical Company." State of Maine Department of Environmental Protection
(July 9. 1984).
38. Letter from Raymond G. Esposito. Union Chemical Co.. Inc. to Samuel Zaitlin,
State of Maine Board of Environmental Proteetion (October 9.1984).
Concerning request for hearing.
39. Letter from David E. Boulter, State of Maine Department of Environmental
ProteCtion to Raymond G. Esposito. Union Chemical Co.. Inc.
(March 15. 1985). Concerning the accounting report, request for drum
disposal, and the erection of a fence.
40. Memorandum of PointS and Authorities in Support of Motion for Enforcement
and Modification of Order and for Forfeiture, Henry E. Warren, Commissioner
of the State of Maine Depa.rtment of Environmental Protection v. Union
Chemical Co., Inc., State of Maine Superior Court, Civil Action Docket No.
CV-84-199 (July 12, 1985).
41. Decision and Judgment, Katharene Larner, et aI., v. Union Chemical Co., Inc.,
Superior Coun for the State of Maine, Civil Action No. CV -80-5
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Page 18
10.3 State 'and Local Enforcement Records (cont'd)
42. Letter from James T. KiIbreth, State of Maine Department of the Attorney
General to Oifford H. Goodall, Dyer, Goodall and Zeegers (Attorney for Union
Chemical Co., Inc.) (February 24, 1986). Concerning transmittal of order.
43. Order, Kenneth C. Young, Jr., Commissioner of the State 01 Maine Department
01 Environmental Protection v. Union Chemical Co., Inc., State of Maine
Superior Court, Civil ACtion Docket No. CV-S4-199 (June 5, 1986).
44. Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Henry D. Aho,
State of Maine Department of Environmental Protection (June 6, 1986).
Concerning transmittal of the attached check to the Treasurer of State.
45. Check from Raymond G. Esposito, Union Chemical Co., Inc. to Treasurer of
State (July 23, 1986).
10.4 Interviews, Depositions, and Affidavits
1.
Deposition of Raymond G. Esposito, United States v. Union Research Co"
Inc.,formerly Union Chemical, Inc., et al, United States District Coon for the
District of Maine, Civil Action No. 87-0355B (June 6, 1989). With the attached
exhibits:
A. List of Stockholders.
B. A BriefHis1Dlical and Economic History of Union Chemical Co., Inc.
C. "Mongage Deed," Union Chemical Co., Inc. (April 23, 1976).
D. "Application for License for Hazardous Waste Facility under the Maine
Hazardous Waste, Septage, and Solid Waste Management Act
(38 M.R.S.A., Section 1301 et seq.)," Union Chemical Co., Inc.
(September 30. 1983).
E. Lener from Raymond G. Esposito, Union Chemical Co., Inc. to William
Grover, State of Maine Depanment of Environmental Protection
(February 9, 1981). Concerning sampling results.
F. Letter Repon from Raymond G. Esposito, Union Chemical Co., Inc. to
Edward Logue, State of Maine Department of Environmental Protection
(July 10, 1981). Concerning sampling results.
G. Letter Repon from Raymond G. Esposito, Union Chemical Co., Inc. to
Edward Logue, State of Maine Department of Environmental Protection
(April 13, 1981). Concerning sampling results. .
H. "Waste Discharge License Certificate," State of Maine
(September 13, 1976). .
I. Letter Repon from Raymond G. Esposito, Union Chemical Co., Inc. to
Edward Logue, State of Maine Department of Environmental Protection
(September 29, 1983). Concerning sampling results.
J. Letter Report from Raymond G. Esposito, Union Chemical Co., Inc. [0
Edward Logue, State of Maine Department of Environmental Protection
(August 12, 1981). Concerning sampling results.
K. Lener Report from Stephen A. Tibbetts, Union Chemical Co., Inc. to
Edward Logue, State of Maine Department of Environmental Protection
(March 22, 1983). Concerning sampling results.
L. "Hydrogeologic Evaluation and Development of Oean Up Plan for Area of
Contaminated Soil," Wright-Pierce for Union Chemical Co., Inc.
(July 1981).
M. "Hydrogeologic Evaluation," Wright-Pierce for Union Chemical Co., Inc.
(November 17, 1981).
N. Complaint for Declaratory and Injunctive Relief and Civil Penalties. Henry
E. Warren, Commissioner 01 the Stare 01 Maine Departrnen/ 01
Environmenlal Protection v. Union Chemical Co., Inc.. State of Maine:
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Page 19
10.4 Interviews, Depositions, and Affidavits (cont'd.)
Consent Decree, Henry E. Warren, Commissioner of the State of Maine
Department of Environmental Protection v. Union Chemical Co., Inc.,
State of Maine Superior Court (May 7, 1984).
Consent Agreement and Order, In re: Union Chemical., Inc., Proceeding
under Section 3008 of the Resource Conservation and Recovery Act, 42
U .s.C. S6928, RCRA Docket No. 83-1045
. (September 6,1984).
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Henry D.
Aho, State of Maine Depanment of Environmental Proteetion
(June 10, 1986). Concerning forthcoming disposition of ground water
plan.
10.5 General Negotiations
O.
P.
Q.
Sample Notice Letter (signed), EPA Region L Concerning notification of a
meeting on May 5, 1987 for Potentially Responsible Pmties. With the attached:
A. Registration Form.
B. Cross-Reference: "AttaChment B - Names and Addresses of Potentially
Responsible Parties," EPA Region I (March 23, 1987) [Filed and cited as
entry number 1 in 11.1 PRP Lists].
Meeting Handout Packet, EPA Region I, State of Maine Department of
Environmental Protection, and Potentially Responsible Parties
(May 5, 1987) including:
A. Union Chemical- Meeting Agenda
B. Introduction
C. Site History
D. Response Measures By Maine Department of Environmental Proteetion
E. State of Maine Department of Environmental Proteetion Presentation on the
Union Chemical Company
F. Emergency Response Measures, EPA Region I
G. Government Oversight of a Private Party Remedial Investigation and
F~ibility Swdy, EPA Region I
H. Legal Responsibilities of Parties for EPA Costs and Response Activities.
EP A Region I
I. Liability of Responsible Parties to the State of Maine, State of Maine
Department of the Attorney General
J. Objectives and Saucwre of Negotiations
10.7 EPA Arlm;n;~trative Orders
1.
2.
1.
Cross-Reference: Consent Agreement and Order,lnRE: Union Chemical Co.
Inc., Proceeding under Section 3008 of the Resource Conservation and
Recovery Act, 42 U.s. C. S6928, RCRA Docket No. 83-1045
(September 6,1984) [Filed and cited as entry number 3 in 19.5 RCRA
Enforcement Actions].
"Superfund; Proposed Settlement Under Comprehensive Environmental
Response Compensation and Liability Act; Union Chemical Co., Inc.," feder.!l
Rcsnster Vol 52, No. 183 (September 22,1987). Concerning the notice for
first Administtative Order.
Administrative Order by Consent, In the Matter of Union Chemical Co., Inc
Site, Docket No. 1-87-1104 (November 4, 1987).
''Environmental Protection Agency," Federal Re~ster Vol. 52, No. 223
(November 19, 1987). Concerning the notice for second Administrative Qrdc
Administtative Order by Consent, In the Matter of Union Chemical Co., Inc
Site, Docket No. 1-88-1003 (January 13, 1988).
2.
3.
4.
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Page 20
10.8 EP A Consent Decrees
Partial Consent Decree, United States v. Union Research Co.,lnc.,formerly
Union Chemical Co., Inc.,. Raymond G. Esposito; Steego Pans Corp.,formerly
Steego Auro Pans, and Farrar-Brown Auto Pans, Inc.; CM. Laboratories, Inc.;
Nyco, Inc.,. Warerlac Industries, Inc.,.IMC Magnetics Corp.; Rule Industries,
Inc.: R.s. liquid Waste Disposal, Inc.: Ethan Allen, Inc.: and Spencer Press,
Inc.. United States District Comt for the District of Maine, Ovil Action No.
87'{)355 B (August 7.1989).
"Department of Justice: Lodging of Partial Consent Decree; Pollution Control
Consent." Federal Re~Vol. 54. No. 109 (June 8,1989). Concerning the
notice for Partial Consent Decree.
10.9 Pleadings
1.
2.
1.
Cross-Reference: Complaint, In RE: Union Chemical Co., Inc. Proceeding
under Section 3008 of the Resource Conservation and Recovery Act, 42 U .s.C.
S6928. RCRA Docket No. 83-1045 (November 1.1983). With the attached
RCRA Pan B Application [Filed and cited as entry number 1 in 19.5 RCRA
Enforcement Action Records].
Cross-Reference: Answer to Complaint, In RE: Union Chemical Co., Inc.
Proceeding under Section 3008 of the Resource Conservation and Recovery Act,
42 U.s.C. S6928. RCRA Docket No. 83-1045 (December 7. 1983) [Filed and
cited as entty numbcl' 2 in 19.5 RCRA Enforcement Action Records].
Complaint, United StQtU 01 America v. Union Research, Inc.,formerly Union
Chemical Co., Inc.,. RaymondG. Esposito,. Sreego Pans Corp.,formerly Steego
Auto Parts, and Farrar-Brown Auro Parts, Inc.,. CM. Laboratories, Inc.; Nyco,
Inc.,formerly Nyes JapentJ1Tlelac, Inc.,. Waterlac Industries, Inc.: IMC
Magnetics Corp.: Rule Industries, Inc.: R.s. Liquid Waste Disposal, Inc.,. Ethan
Allen, Inc.,. and Spencer Press Company, United States District Comt for the
District of Maine. Ovil Action No. CV-87'{)355 B (November 6. 1987).
Answer. United States of America v. Union Research, Inc.,former/y Union
Chemical Co., Inc.,. Raymond G. Esposito,. Sreego Pans Corp.,former/y Sleego
Auto Parts, and Farrar-Brown Auro Parts, Inc.; CM. Laboratories, Inc.; Nyco,
Inc.,formerly Nyes JapentJ1Tlelac, Inc.,. Waterlac Industries, Inc.; IMC
Magnetics Corp.; Rule Industries, Inc.; R.s. Liquid Waste Disposal, Inc.,. Elhan
Allen, Inc.,. and Spencer Press Company, United States District Coon for the .
District of Maine. Ovil Action No. CV-87'{)355 B (December 21,1987).
Amendment to Answer. United Stares of America v. Union Research Co., Inc.,
et aI., United States District Comt for the District of Maine. Ovil Action No.
CV-87'{)355 B (April 13, 1988).
2.
3.
4.
5.
11.0 Potentially Responsible Party (PRP)
11.1 PRP listS
1.
2.
"Attachment B - Names and Addresses of Potentially Responsible Panies," EP A
Region I (March 23. 1987).
"Union Chemical Company - Parties Receiving Special Notice and Demand
Lener." EPA Region I (May 18. 1987).
"Union O1emical Company - Names and Address of Parties to Whom the
Notification is Being Issued," EPA Region I (February 26. 1990).
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Page 21
11.3 Contnlctor Work Plans and Progress Repons
Union Chemical Site Trust ConlTactor Work Plans and Progress Reports may be
found in 3.7 Work Plans and Progress Reports and 4.7 Work Plans and Progress
Reports.
11.5 Site Level- General Correspondence
Notice Letters
1.
Sample General Notice LettCZ' (signed), EP A Region L Concerning the attached:
A. Sample Notice Letter (dated), EP A Region I (March 23, 1987).
B. "AttaChment A - Request for Information."
c. Cross-Reference: "AttaChment B - Names and Addresses of Potentially
Responsible Parties," EPA Region I (March 23, 1987) [FlIed and cited as
entry number 1 in 11.1 PRP Lists].
D. "AttaChment C - Union Chemical Ranking of Generators by Hazardous
Wasres Gcocrarcd"
E. "Att3Cbmen\ D - Re: SampJe Document"
F. "Attadament E - list of Transporters.-
Sample Special Notice Letter (signed), EP A Region L Concerning the attaChed:
A. Sample Special Notice Letter (signed and dated), EP A Region I
(May 22, 1987).
B. "Union Chemical Transactional Database - Union O1emical Ranking of
Generators by Hazardous Wastes Generated" (May 12. 1987).
C. "Union Chemical Transactional Database - Transactional Printout - Volume
per Waste Typc" (May 12, 1987).
D. ''Union Chemical Transactional Database - Union Clemical Ranking of
Transponers by Hazardous Wastes Transponcd" (May 12, 1987).
E.. Cross-Reference: "Union Chemical Company - Parties Receiving Special
Notice and Demand Letter." EPA Region I (May 18, 1987) [Filed and cited
as entry number 2 in 11.1 PRP Lists].
F. "Negotiations Support Document," Camp Dresser & McKee Inc.
(May 19. 1987).
Sample General Notice Letter (dated), EPA Region I (February 26, 1990).
Concerning notification of potentia1liability and request for information. With the
attaChed: .
A. Cross-Reference: "Union Chemical Company - Names and Address of
Parties to Whom the Notification is Being Issucd," EPA Region I
(February 26. 1990) [Flled and cited as entry number 3 in 11.1 PRP
Lists].
B. "Union Chemical Transaction Database - Union Chemical Ranking of
Generators by Hazardous Wastes Generated (Enclosure B)"
(December 31, 1989).
C. "Enclosure C - Union Qlemical Company - Documentation."
D. "Enclosure D - Union O1emical Company - First Information Request -
InstrUctions. ..
Letter from David E. Boulter, State of Maine Department of Environmental
Protection to Potentially Responsible Party. Concerning notification of potential
liability undCZ' title 38, OtaptCZ' 13-B of the Maine Hazardous Substance, Maner
and Waste Management Laws.
Letter from Michael Jasinski, EPA Region I to David P. Rosenblatt, Burns &
Levinson and Louis Massery, Cooley, Manion, Moore & Jones (Attorneys for
Union Chemical Site Trust) (October 21,1987). Concerning the volumetric
ranking lists.
2.
3.
4.
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Page 22
11.5 Site Level - General CoITespondence (cont'd.)
Steering CommitteelTrustee Cmrespondence
6. Letter from Michael Jasinski, EPA Region I to David P. Rosenblatt, Bwns &
Levinson (Attorney for Union Chemical Site Trust) (May 4, 1988). Concerning
residential well sampling results.
7. Letter from David M. Webster, EPA Region I to James F. Green, North East
Solvents (June 14, 1988). Concerning Resource Conservation and Recovery
ACt identification number.
8. Letter from David M. Webster. EPA Region I to James F. Green. North East
Solvents (June 20. 1988). Concerning clarification of deliverables.
9. Letter from Randy C. Smith. Union Chemical Site Trust to Michael Jasinski,
EPA Region I (January 31.1989) with the attached January 27,1989 Letter from
Timothy J. Hanington. Canonie Environmental Services Corp. for Union
Olemical Site Trust Concerning a potential confliCt of interest due to W.R.
Grace & Company's ownership of shares in Canonie Environmental Services
Coop. .
10. Cross-Reference: Letter from David M. Webster. EPA Region I to James F.
Green, Union Chemical Site Trust (December 14.1989). Concerning
notification of the granting of an extension of time with the attached:
A. Comments Dated August 23. 1989 from David M. Webster, EPA Region I
on the August 1989 "Phase IB Remedial Investigation Work Plan,"
Canonie Environmental Services Corp. for the Union Chemical Site Trust
B. Letter from James F. Green, Union Olemical Site Trust to Michael
Jasinski, EP A Region I and David W. Wright, State of Maine Depanment
of Environmental Protection (October 11. 1989). Concerning notification
of delay and request for an extension of time.
C. Letter from James F. Green. Union Chemical Site Trust to Michael
Jasinski. EPA Region I (November 22. 1989). Concerning a request for
extension of time for project deliverables.
[Filed and cited as entry number 17 in 3.1 CoITespondence].
11. Cross-Reference: Letter from David W. Wright, State of Maine Department of
Environmental Protection to James F. Green, Union Chemical Site Trust
(February 5. 1990). Concerning notice to proceed with the Phase 5, detailed
analysis of alternatives [Filed and cited as entry number 1 in 4.1
Correspondence].
12. Cross-Reference: Letter from David M Webster. EPA Region I to James F.
Green. Union Chemical Site Trust (February 5. 1990). Concerning notice to
proceed with the Phase 5. "Detailed Analysis of Alternatives" [Filed and cited as
entry number 2 in 4.1 Correspondence].
11.9 PRP-Specific Correspondence
Union Chemical Co.. Inc.
1.
Letter from Menill S. Hohman, EPA Region I to Raymond G. Esposito, Union
Chemical Co.. Inc. (August 8.1984). Concerning notification of potential
liability.
Letter from Raymond G. Esposito. Union Chemical Co., Inc. to Michael R.
Deland, EPA Region I (August 10. 1984). Concerning objection to State and
federal agencies enforcing environmental regulations.
Letter from Michael R Deland, EPA Region I to Raymond G. Esposito, Union
Chemical Co.. Inc. (August 22. 1984). Concerning tennination of hazardous.
waste facility license and EP A suppon of the State of Maine ruling.
2.
3.
_._--_..~ ..-'..-
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Page 23
11.9 PRP-Specific Correspondence (cont'd.)
Union Chemical Co., Inc.
Lener from Raymond G. Esposito, Union Chemical Co., Inc. to Michael R
Deland, EPA Region I (September II, 1984). Concerning objections to the
August 22, 1984 Letter from Michael R. Deland.
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Henry
Hinckley (November 15, 1984). Concerning objections to the cost of the
cleanup.
Lencr from Menill S. Hohman. EPA Region I to Raymond G. Esposito, Union
Chemical Co., Inc. (April 27 , 1987). Concerning a notification of the
May 5, 1987 meeting for Potentially Responsible Parties. .
Rule Industries, Inc.
4.
5.
6.
7.
Lener from Merrill S. Hohman, EPA Region I to William Anastos, Rule
Industries, Inc. (February 26,1990). Concerning a second request for
information. .
Pioneer Plastics
Letter from Merrill S. Hohman, EPA Region I to Edward W. Ribolin, Pioneer
Plastics (February 26, 1990). Concerning a second request for information.
Lencr from Merrill S. Hohman, EPA Region I to John B. Jalbert, Pioneer
Plastics Corporation (June II, 1990). Concerning notice of potential liability
and request for information. With the attaChed:
A. "Enclosure A - Union Chemical Transactional Database Summary Repon"
(January I, 1990).
B. "Enclosure B - Union O1emical Transactional Database - Union O1emical
Ranking of Generators by Hazardous Wastes Generated."
C. "Enclosure C - Union Chemical Company - First Information Request"
Trinova Corporation
8.
9.
10. Letter from Merrill S. Hohman, EPA Region I to Nat C. Chang, Trinova .
Corporation (Successor to Pioneer Plastics) (June II, 1990). Concerning notice
of potential liability and request for information.
11.12 PRP Related Documents
Repons
1.
"Spill Containment and Incineration System: Preliminary Design and Capital Cost
Repon." Progress Consulting Services for Union Chemical Co., Inc.
(September 1979).
''Hydrogeologic Evaluation and Development of Ocan Up Plan for Area of
Contaminated Soil," Wright-Pierce for Union Chemical Co., Inc. (July 30, 1981).
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Page 24
11.12 PRP Related Documents (oont'd.)
Repons
The maps associated with the record cited in entry number 3 may be reviewed, by
appointment only, at EP A Region I, Boston, Massachusetts.
3.
"Hydrogeologic Evaluation and Development of Oean Up Plan for Area of
Contaminated Soil- Pan B - Appendix 1," Wright-Pierce for Union Chemical
Co., Inc. (November 17, 1981).
"Waste Analysis Plan," Union Chemical Co., Inc. (lune 4, 1984).
4.
Comments
Comments Dated April 2, 1984 from Peter Garrett, State of Maine Department of
Environmental Protection on the luly 30,1981 ''Hydrogeologic Evaluation and
Development of Oean Up Plan for Area of Contaminated Soil," Wright-Pierce
for Union Chemical Co., Inc. .
13.0 Community Relations
5.
13.1 Conespondence
1. utter from Gerald Brooks to Matthew Scot, State of Maine Department of
Environmental Protection (May 21,1979). Concerning complaint of deteriorating
water quality in Quiggle Brook.
2. utter from Edward M. Logue, State of Maine Department of Environmental
Protection to Brian Powers, Hope's Committee for a Clean Environment
(February 23, 1981). Concerning well sample results.
3. utter from Edward M. Logue, State of Maine Department of Environmental
Protection to Gus 10hnson (February 23, 1981). Concerning well sample results.
4. Letter from Edward M. Logue, State of Maine Department of Environmental
Protection to South Hope Grange (February 23,1981). Concerning well sample
results.
. 5. utterfromloseph N. DeCola, EPA Region Ito lill DeLaney (April 6, 1981) with
the attached "Statement of Deficiencies and Plan of CoITection." Concerning
treatment, storage, and disposal of hazardous wastes.
6. utter from David A. Dumas, State of Maine Department of Environmental
Protection to lill DeLaney (May IS, 1981). Concerning burning of halogenated
solvents and use of chlorine. .
7. Letter from Jill DeLaney to John A. Krueger and Edward M. Logue, State of
Maine Department of Environmental Protection (May 28,1981) with the attached
May 20, 1981"Maine DEP Officials are Weary of Complaints on Fum, They
Say," Bangor Daily News - Bangor, ME. Concerning inquiry on latest test
results.
8. utter from Till DeLaney to William F. Sarro, EPA Region I (May 28. 1981).
Concerning request for an on-site inspection report.
9. Letter from Edward M. Logue, State of Maine Department of Environmental
Protection to lill Delaney (lune 2, 1981). Concerning lab results.
10. utter from William F. Sarro, EPA Headquarters to lill DeLaney (lune 5. 198 I).
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Page 25
13.1 Correspondence (cont'd.)
11. Letter from John A. Krueger, State of Maine Department of Environmental
Protection to Jill De!aney (June 12, 1981). Concerning a response to the attached
May 31, 1981 Letter from Till Delaney.
12. Letter from Till DeLaney to Berny B. Wmen. State of Maine Department of
Environmental Protection (July 14, 1981). Concerning fumes and new site
location.
13. Letter from Joseph E. Brennan, Governor of the State of Maine to Michael
Christensen (September II, 1981). Concerning petition and site regulations.
14. Lener from Edward M. Logue, State of Maine Depanment of Environmental
ProteCtion to Brian Powers (September 15. 1981). Concerning well samples.
15. Letter from David L. Hall to Joseph B. Brennan. Governor of the State of Maine
(September 19, 1983). Concerning the effect of the noise level on the residents.
16. Letter from David A. Bradeen to Joseph E. Brennan, Governor of the State of
Maine (September 26. 1983). Concerning health problem of resident .
17. Letter from Ursula A. Gillis, Concerned Citizens of Hope and Concerned Citizens
of Maine to State of Maine Depanment of Environmental Proteetion
(November 12, 1983) with attached petition from Concerned Citizens of Hope.
Concerning a request for public hearing.
18. Letter from Greg Bogdan. State of Maine Depanment of Human Services to Maine
Citizens (December 8, 1983). Concerning proposed public meeting at Hope
Grange Hall on December 15. 1983 and tranSmittal of "The Prevalence of Selected
Health Problems of Residents Living in the Vicinity of the Union Chemical
Company" (December 1983).
19. Letter from Marion and Harry Merrifield (January 9, 1984). Concerning health
effects and noise levels.
20. Letter from Jane Mitchell to State of Maine Department of EnVironmental
Protection (January 12, 1984). Concerning the issuance of a pennanent license.
21. Letter from Harold Cushman to State of Maine Department of Environmental
ProteCtion (January 16. 1984). Concerning resident's interest in problems on the
site.
22. Letter from Louis M. and B.C. Hart to State of Maine Departtnent of
Environmental Protection (January 25, 1984). Concerning protest of hazardous
waste storage license.
23. Letter from Fred Ribeck. Spectrum Artworks to State of Maine Deparnnent of
Environmental Protection (January 26,1984). Concerning issuance of a
~ent license and photOs of site staCk emissions.
24. Letter from StaCy A. Ladner, State of Maine Department of Environmental
ProteCtion to Fred Ribeck. Spectrum Artworks (February 9, 1984). Concerning
response to photo submission.
25. Letter from Staey A. Ladner, State of Maine Department of Environmental
Protection to Louis M. and E.C. Hart (February 9, 1984). Concerning
"Hazardous Waste Application" file.
26. Letter from Greg Bogdan, State of Maine Depanment of Human Services to Hope
Resident (February 14, 1984). Concerning the attaChed questionnaire and.
"Medical Records Release Authorization" form.
27. Letter from Greg Bogdan. State of Maine Department of Human Services to
Carolie MAJ. Lamer, Concerned Citizens of Hope (February 16, 1984).
Concerning follow-up survey efforts.
28. Letter from Carolie MAJ. Lamer, Concerned Citizens of Hope to David E.
Boulter. State of Maine Depanment of Environmental Protection
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13.1 Correspondence (cont'd.)
29. Letter from Stacy A. Ladner, State of Maine Department of Environmental
Protection to Interested Citizen (March 15, 1984). Concerning proposed public
hearing at Samoset Inn on April 4, 1984.
30. Memorandum from State of Maine Department of Environmental Protection to
State of Maine Board of Environmental Protection (May 2, 1984). Concerning the
attached:
A. Letter from Concerned Citizens of Hope to Henry E. Warren, State of
Maine Board of Environmental Protection (February 23, 1984).
B. Letter from Roger R. Thmiault and Carolie MAJ. Lamer. Concerned
Citizens of Hope to Henry E. Warren, State of Maine Department of
Environmental Protection (April 30, 1984).
31. Letter from Carolie MAJ. Lamer, Concerned Citizens of Hope to Henry E.
Warren. State of Maine Department of Environmental Protection (June 4. 1984).
Concerning requests to Jesume operations.
32. Letter from Henry E. Warren, State of Maine Department of Environmental
Protection to Clifford H. Goodall. Dyer, Goodall and Zeegers (Anorney for
Unioo Chemical Co.. Inc.) (June 14, 1984). Concerning confirmation of
planned State of Maine Department of Environmental Protection actions.
33. Lener from Michael R. Deland, EPA Region I to the Editor, Portland Press
Herald (November 6, 1984). Concerning clean up procedures and removal of
hazardous wastes.
34. Petition. Concerned Citizens of Hope (January 21,1985).
35. Lener from Concerned Citizens of Hope to Henry E. Warren, State of Maine
Department of Environmental Protection (May 10,1985). Concerning the
attached May 1985 petition.
36. Letter from Henry E. Warren, State of Maine Depanment of Environmental
Protection to Carolie MAJ. Lamer, Concerned Citizens of Hope
(May 24. 1985). Concerning Jesponse to petition and site status.
37. Lenerfrom Carolie MAJ. Lamer. Concerned Citizens of Hope to Joseph E.
Brennan. Governor of State of Maine (August 12, 1985). Concerning the
removal of Union Chemical Co., Inc. and its staff from the site.
38.. Letter from Martha D. Merrill to Joseph E. Brennan. Governor of State of Maine
(August 18, 1985) with the attached "An Appeal to Reason by Raymond G. .
Esposito," The Courier-Gazene - Rockland. ME (June 27,1985). Concerning
the removal of Union Chemical Co., Inc. and its staff from the site.
39. Letter from Julie Jones to Henry D. Aho, State of Maine Department of
Environmental Protection (November 19,1985). Concerning proposed cleanup
plans.
40. Letter from Carolie MAJ. Lamer. Concerned Otizens of Hope to James J.
Lysen, State of Maine Depanment of Environmental Protection
(November 20, 1985). Concerning comments on the November 6, 1985
proposed cleanup plan.
41. Letter from David E. Boulter, State of Maine Depanment of Environmental
Protection to Carolie MAJ. Lamer, Concerned Citizens of Hope
(February 5. 1986). Concerning receipt of petition.
42. Letter from Carolie MAJ. Lamer, Concerned Otizens of Hope to Town of Hope
Selectmen and Code Enforcement Officers (February 6, 1986). Concerning
problems stemming from town ownership of the site.
43. Letter from John A. Blanchard, Town of Hope Board of Selectmen to David E.
Boulter. State of Maine Department of Environmental Protection
(February 21, 1986). Concerning suppon for State of Maine Department of
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13.1 Correspondence (cont'd.)
44. Letter from Paul L. Gibbons, Calderwood. Ingrahm & Gibbons (Attorney for the
Township of Hope) to Marc A. Lappe, PhD Consultant
(February 24, 1987). Concerning a request for teChnical assistance with the
attaChed:
A. "Residential Well Sampling in the Vicinity of Union Chemical Company."
B. - "Table 1 - Sampling Results - 3-well OusterS."
C. "Leuer of Intent," Township of Hope.
45. Letter from Paul L. Gibbons, Calderwood. Ingrahm & Gibbons (Attorney for the
Township of Hope) to Marc A. Lappe, PhD Consultant (February 24,1987).
Concerning hazardous waste, drinking water, and safety concerns with the
attaChed:
A. "Union Chemical Sampling," (December 1986).
B. Site Map of Union Chemical and Surrounding Area.
C. "Department of Environmental Protection Laboratory Results,"
OJecemberI5,1986).
D. "State of Maine Department of Environmental Protection Laboratory
Results," (February 11, 1987).
46. Letter from Marc A. Lappe, PhD Consultant for the Township of Hope to Paul L.
Gibbons, Calderwood, Ingrahm & Gibbons (Attorney for the Township of Hope)
(March I, 1987). Concerning the site evaluation.
47. Leuer from David L. Hall, Township of Hope to Resident (April 8, 1987).
Concerning potential effects of contaminants in the water system and citing
Marc A. Lappe's recommendations.
48. Letter Repon from Barry S. Timson, Earth Smface Research for Union Chemical
Co., Inc. to Paul L. Gibbons, Calderwood. Ingrahm & Gibbons (Attorney for the
Township of Hope) (May 9,1987). Concerning a preliminary assessment of
ground water.
49. Letter from Carotie MAJ. Lamer, Concerned Citizens of Hope to Paul L.Gibbons,
Calderwood, lngrahm & Gibbons (Attorney for the Township of Hope)
(May 21,1987). Concerning participation by Concerned Citizens of Hope in the
June I, 1987 meeting.
50. Letter from David M. Webster, EPA Region I to Carolie MAJ. Lamer, Concerned
Citizens of Hope (June 15,1987). Concerning an outline ofEPA Region 1'5
activities since the 1984 removal action. -
51. Memorandum from Marlc H. Bashor, U.S. Department of Health and Human
Services Agency for Toxic SubstanCes and Disease Registry (A TSDR) to The
Record (September 4, 1987). Concerning a response to petition for a health
assessment.
52. Letter from Michael Jasinski. EPA Region I to John A. B1anch~ Township of
Hope (October 9, 1987). Concerning the attached data sheets to be placed at the
Township of Hope Town Hall
53. Letter from Patty D'~ EPA Region I to SteVen and Andrea Bowman
(November 23, 1987) with attaChed list of individuals to whom similar letters were
sent. Concerning thanks for interviews taken in preparation for the Communiry
Relations Plan. -
54. Letter from John A. Blanchard and David Hall, Township of Hope to Michael
Jasinski, EPA Region I (December 11, 1987) with attaChed December I, 1987
Letter from Carotie MAl. Lamer, Concerned Citizens of Hope to John A
Blanchard, Township of Hope. Concerning drinking water and cooking water
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Page 28
13.1 Correspondence (cont'd.)
55. ~tter from Michael Jasinski. EPA Region I to Carolie MAI. Lamer. Concerned
Citizens of Hope (December 28.1987). Concerning the transmittal ofresults from
sampling of residential wells.
56. ~tter from Michael Jasinski. EPA Region I to Marc A. Lappe. PhD Consultant
for the Township of Hope (December 28. 1987). Concerning the transmittal of
. results from samplings of residential wells.
57. ~tter from Michael Jasinski. EPA Region I to John A. Blanchard, Township of
Hope (December 28.1987). Concerning the transmittal of results from sampling
of residential wells.
58. ~tter from Michael Jasinski. EPA Region I to John A. Blanchard, Township of
Hope (FebruaIy 17. 1988). Concerning Township of Hope citizens request for
drinking water and cooking water supplies.
59. ~tter from Michael and Lisa Starrett to Michael Jasinski, EPA Region I
(FebruaIy 24. 1988). Concerning well testing and monitoring.
60. Petition. Citizens of the Township of Hope (March 10. 1988). Concerning health
issues, ~h. and supplemental water supply.
61. Lettc:r from Marilyn R. DiSirio, U.S. Department of Health and Human Services
Agency for Toxic SUbsW1CCS and Disease Registry (ATSDR) to A. Mark
Woodward, Bangor Daily News (March 17. 1988). Concerning the
March 10. 1988 public meeting and prevention measures against potential
exposures. .
62. Meeting Agenda, Concerned Citizens of Hope (March 22.1988). Concerning
health study. water supply. and proposed citizens committee.
63. ~tter from Patty D'Andrea, EPA Region I to Interested Citizens .
(March 23. 1988). Concerning the attached March 17. 1988 ~tter from MariJ yn
R. DiSirio. U.S. Department of Health and Human Services Agency for Toxic
Substances and Disease Registry (ATSDR) to A. Mark Woodward, Bangor Daily
News.
64. Letter from Carolie MAI. Lamer. Concerned Citizens of Hope to Michael
Jasinski~ EPA Region I. Marilyn R. DiSirio and Louise House. U.S. Department
of Health and Human Services Agency for Toxic Substances and Disease Registry
(A TSDR). Cynthia M. Kuhns, State of Maine Department of Environmental
Protection. Bob Frakes and Greg Bogden. State of Maine Board of Health. Randy
C. Smith. Union Chemical Co.. Inc.. and John A. Blanchard. Township of Hope
(March 24. 1988) with attached news clippings. Concerning joint conferences and
public meetings.
65. utter from Marilyn R. DiSirio, U.S. Depanment of Health and Human Services
Agency for Toxic Substances and Disease Registry (A TSDR) to Townshi p of
Hope area residents (March 28, 1988). Concerning establishment of a won.:ing
committee.
66. Letter from Cynthia M. Kuhns. State of Maine Depanment of Environmental
Protection to Carotie MAI. Lamer. Concerned Citizens of Hope
(April 11. 1988). Concerning the March 22. 1988 meeting and supplemental
drinking water provisions.
67. Letter from Michael Jasinski. EPA Region I to Carolie MAJ. Lamer. Concerned
Citizens of Hope (April 12. 1988). Concerning response to March 10. 1988
petition.
68. ~tter from Nancy V. Hicks. U.S. Department of Health and Human Servic~s
Agency for Toxic Substances and Disease Registry (A TSDR) to David L. HJ!!.
Township of Hope (May 20. 1988). Concerning results of the April 18. 19S'
meeting and recommendations on educational seminars for local physicians ar,J
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Page 29
13.1 Correspondence (cont'd.)
69. Letter from Michael Jasinski, EPA Region I to John A. Blanchard, Township of
Hope (July 22, 1988). Concerning transmittal of items to replace and/or add to the
May 1988 "Remedial Investigation/FeaSibility StUdy Work Plan" at the TOYmship
of Hope Town Hall.
70. Letter from Michael Jasinski, EPA Region I to John A. Blanchard, Township of
Hope (August 15, 1988). Concerning transmittal of organic vapor results,
completed soil borings map. and ground water elevations map to be placed in the
Township of Hope Town Hall. .
71. Letter from Michael Jasinski, EPA Region I to Carolie MAJ. Lamer. Concerned
Citizens of Hope (August 15. 1988). Concerning transmittal of organic vapor
results. completed soil borings map. and ground water elevations map.
72. Letter from Michael Jasinski, EPA Region I to Brian Powers, Hope's Committee
for a Oean Environment (August 15.1988). Concerning transmittal of organic.
vapor results, completed soil boring map. and ground water elevations map.
73. Letter from Michael Jasinski. EPA Region I to John A. Blanchard. Township of
Hope (September 12. 1988). Concerning transmittal of data on ground water
elevations. analytical results for semi-volatileslPCB-pesticidesfmorganics, and
analytical results from the air monitoring program to be placed in the Township of
Hope Town Hall.
74. Letter from Michael Jasinski. EPA Region I to Brian Powers. Hope's Committee
for a Oean Environment (September 12.1988). Concerning transmittal of data on
ground water elevations. analytical results for semi-volatiles/PCB-pesticides/
inorganics. and analytical results from the air monitoring program.
75. Letter from Michael Jasinski. EPA Region I to Carolie MAJ. Lamer. Concerned
Citizens of Hope (September 12.1988). Concerning transmittal of attached packet
of data. .
76. Memorandum from Carolie MAJ. Lamer. Concerned Citizens of Hope to Michael
Jasinski, EPA Region I (September 13. 1988). Concerning request for
information.
77. Letter from Carolie MAJ. Lamer. Concerned Citizens of Hope to Michael
Jasinski."EPA Region I (September 22. 1988). Concerning site security and
request for response to the September 13. 1988 request for information.
78. Letter from Michael Jasinski. EPA Region I to Carotie MAJ. Lamer. Concerned
Citizens of Hope (September 27. 1988). Concerning transmittal of maps and the
September 2. 1988 "Health Assessment," U.S. Depanment of Health and Hum:ln
Services Agency for Toxic Substances and Disease Registry (A TSDR).
79. Letter from Michael Jasinski. EPA Region I to John A. Blanchard. Township of
Hope (September 27. 1988). Concerning tranSmittal of maps and the
September 2, 1988 "Health Assessment,tI U.S. Department of Health and Human
Services Agency for Toxic Substances and Disease Registry (A TSDR) to be
placed at the Township of Hope Town Hall.
80. Letter from Michael Jasinski, EPA Region I to Brian Powers., Hope's Committee
for a Clean Environment (September 27. 1988). Concerning tranSmittal of ITlJ P 5
and the September 2.1988 "Health Assessment," U.S. Department ofHea1th and
Human Services Agency for Toxic Substances and Disease Registry (A TS DR).
81. Letter from Michael Jasinski. EPA Region I to Carolie MAJ. Lamer. ConcemeJ
Citizens of Hope (October 24. 1988). Concerning transmittal of the
February 18. 1987 "On Scene Coordinator's Report," EPA Region I, as a parU31
response to the September 13, 1988 Letter from Carolie MAJ. Lamer, Concc:m~J
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Page 30
.13.1 Correspondence (cont'd.)
82. Letter from Michael Jasinski, EPA Region I to Carolie MAJ. Lamer, Concerned
Citizens of Hope (October 24. 1988). Concerning the attached preliminary resul ts
of samples obtained &om the incineratOr and "off-site" areas.
83. Letter &om Michael Jasinski. EPA Region I to John A. Blanchard, Township of
Hope (February 8,1989). Concerning transmittal of the January 1989 "Draft-
Worlc Plan: Phase IB Remedial Investigation and Post-Screening Field
Investigation." Canonie Environmental Services Corp. for the Union Chemical
Site Trust to be placed in the Township of Hope Town Hall.
84. Letter from Ursula A. Gillis and Carolie MAJ. Lamer. Concerned Citizens of
Hope to David L. Hall. Township of Hope (February 16, 1989). Concerning
request for an in-service education program and a morbidity study.
85. Letter from Louise House, U.S. Department of Health and Human Services
Agency for Toxic Substances and Disease Registry (A TSDR) to Ursula A. Gillis,
Concerned Citizens of Hope (March 6. 1989). Concerning plans for an in-service
education program and a morbidity study.
86. Letter from Kymberlee F. Estis. Booz-Allen & Hamilton Inc. to Rick Hamel,
Principal of Hope Elementary School (April 27. 1989). Concerning confinnation
of arrangements for public meeting.
87. Letter from Louise House, U.S. Department of Health and Human Services
Agency for Toxic Substances and Disease Registry (ATSDR) to Carolie MAJ.
Lamer, Concerned Citizens of Hope (July 17, 1989). Concerning a correction to
the March 6, 1989 Letter from Louise House. U.S. Department of Health and
Human Services Agency for Toxic Substances and Disease Registry (A TSDR) to
Ursula A. Gillis. Concerned Citizens of Hope with the attached:
A. Letter from Carolie MAJ. Lamer. Concerned Citizens of Hope to David L.
Hall, Township of Hope (February 16. 1989). Concerning request for an
in-service education program and a morbidity study.
B. Telephone Notes Between Louise House. U.S. Department of Health and
Human Services Agency for Toxic Substances and Disease Registry
(ATSDR) and George Buynowski. U.S. Department of Health and Human
Services Agency for Toxic Substances and Disease Registry (A TSDR)
. (March 8. 1989). Concerning the morbidity study schedule.
C. Telephone Notes BetWeen Louise House. U.S. Department of Health and
Human Services Agency for Toxic Substances and Disease Registry
(ATSDR) and George Buynowski, U.S. Department of Health and Human
Services Agency for Toxic Substances and Disease Registry (A TSDR)
(March 1, 1989). Concerning a telephone conversation with Carolie MAl.
Lamer. Concerned Gtizens of Hope about the in-service education program.
D. Letter from Nancy V. Hicks, U.S. Department of Health and Human
Services Agency for Toxic Substances and Disease Registry (A TSDR) to
David L. Hall. Township of Hope (May 20. 1988). Concerning results of a
meeting on April 18. 1988 and recommendations on educational seminars for
local physicians and residents.
E. Letter from Louise House. U.S. Department of Health and Human Services
Agency for Toxic Substances and Disease Registry (A TSDR) to Ursula A.
Gillis. Concerned Citizens of Hope (March 6. 1989). Concerning plans for
an in-service education program and a morbidity study.
88. Letter from Michael Jasinski. EPA Region I to John A. Blanchard, Township of
Hope (September 6. 1989). Concerning transmittal of the August 1989 "Phase IE
Remedial Investigation Worlc Plan." Canonie Environmental Services Corp. fof
the Union Chemical Site Trust to be placed in the Township of Hope Town Hall.
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13.1 Correspondence (cont'd.)
89. "Hazardous Substances in the Environment and Human Health Effects," Meeting
Handout for the Concerned Citizens of Hope Health Conference
(September 16, 1989).
90. Letter from Michael Jasinski. EPA Region I to Carolie MAJ. Lamer. Concerned
Citizens of Hope (October 23, 1989). Concerning tranSmittal of the
October 9, 1989 "Draft Wetland Assessment," The Sman Associates for Canonie
Environmental Services Corp. for the Union Chemical Site Trust.
91. Lener from Michael Jasinski, EPA Region I to John A. Blanchard, Township of
Hope (October 27, 1989). Concerning tm1Smittal of the "National Priorities List
for UnconttoUed Hazardous Waste Sites-Final Rule Covering Sites Subject to
the Subtitle C Corrective Action Authorities of the Resource Conservation and
Recovery Act," Federal Re~sterVol. 54, No. 191 (October 4, 1989) and the
August 7, 1989 Partial Consent Decree.
92. Lener from Margery L. Adams. EPA Region I to Carolie MAJ. Lamer. Concerned
Citizens of Hope (January 12,1990). Concerning transmittal of the June 6, 1989
Deposition of Raymond G. Esposito, United States V. Union Research Co., Inc.,
Formerly Union Chemical Co., Inc., et al, United States District Coun for the
District of Maine, Civil Action No. 87-0355 B.
93. Letter from John A. Blanchard, Township of Hope to Michael Jasinski. EPA
Region I (January 24. 1990). Concerning the transmittal of Comments Dated
January 14, 1990 from Marc A. Lappe, PhD Consultant for the Township of
Hope on the August 1989 "Phase m Remedial Investigation Work Plan." Canonie
Environmental Services Corp. for the Union Chemical Site Trust.
94. Lener fromKymberlee F. Estis. Booz-Allen & Hamilton Inc. to John Walker.
CDM Federal Programs Corporation (February 8.1990). Concerning attached
Union Chemical Hotline log.
95. Letter from Marc A. Lappe, Ph.D., Consultant for the Township of Hope to Paul
L. Gibbons, Calderwood, Ingrahm & Gibbons (March 13, 1990). Concerning
the March 12, 1990 conversation with Michael Jasinski.
96. Lener from Michael Jasinski, EPA Region I to Brian Powers. Hope's Committee
for a Clean Environment (March 14, 1990). Concerning transmittal of the
attaChed: .
A. ''Draft - Proposed Record of Decision (ROD) Schedule," EPA Region I
(March 13, 1990).
B. "Attachment B - Names and Addresses of Potentially Responsible Parties,"
EPA Region I (March 23,1987).
C. "Additional Names and Addresses of Parties to Whom Notification is Being
Issued," EPA Region 1 (February 28,1990).
D. "Public Involvement in the Superfund Program." EPA Headquaners
(Fall 1987).
"The Superfund Remedial Program." EPA HeadquarterS (Fall 1987).
"Superfun~" EPA HeadquarterS (Fall 1987).
"Superfund Glossary," EPA HeadquarterS (Winter 1986).
"State and Local Involvement In The Superfund Program," EPA
HeadquarterS (Fall 1989).
1. "A TSDR Fact Sheet," U.S. Health and Human Services Agency for Toxic
Substances and Disease Registry (ATSDR).
97. Letter from Michael Jasinski, EPA Region 1 to Carolie MAJ. Lamer, Concerned
Citizens of Hope (March 26, 1990). Concerning transmittal of the attached well
sample results from the Johnson, Melanson, Crabtree, Stanley, Chase. and
Guidely residences, and an EPA field audit
E.
F.
G.
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13.1 Correspondence (cont'd.)
98. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton to John Walker, CDM
Federal Programs Corporation (April 6, 1990). Concerning attached Union
O1emical Hotline log.
99. "Articles of Incorporation," Hope's Committee for a Clean Environment
(April 17 t 1990).
100. Letter from Michael Jasinski, EPA Region I to Marc A Lappe, Ph.D., Consultant
for the Town of Hope, Carolie MAJ. Lamer, Concerned Citizens of Hope, and
Brian Powers, Hope's Committee for a Oean Environment (April 23, 1990).
Concerning transmittal of the February 1990 "Draft Repon - Remedial .
Investigation," Canonie Environmental Services Corp. for the Union Chemical
Site Trust.
101. "Technical Advisor Subagreement," Hope's Committee for a Clean Environment
and Benjamin Ross, Disposal Safety Incorporated (June 25, 1990).
102. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Carolie MAJ.
Lamer, Concerned Citizens of Hope (July 10, 1990). Concerning enclosed fact
sbteton the July 1990 "EPA Proposes Oeanup Plan for the Union Chemical Co.,
Inc. Superfund Site." FP A Region I.
103. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Brian Powers,
Hope's Committee for a Oean Environment (July 10, 1990). Concerning
enclosed fact sheet on the July 199O"EPA Proposes Oeanup Plan for the Union
Chemical Co., Inc. Superfund Site," EPA Region I.
104. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Benjamin Ross,
Ph.D., Hope's Committee for a Clean Environment (July 10, 1990). Concerning
enclosed fact sheet on the July 1990 ''EPA Proposes Cleanup Plan for the Union
Chemical Co., Inc. Superfund Site," EPA Region I.
105. Letter from Michael Jasinsky, EPA Region I to Brian Powers, Hope's Committee
for a Dean Environment (July 24,1990). Concerning discussions at the
July 12, 1990 public informational meeting.
106. ''Technical Advisor Subagreement," Hope's Committee for a Clean Environment
and Marc A. Lappe, Ph.D. (July 26,1990).
107. Letter Repon from Carolie MAJ. Lamer, Concerned Citizens of Hope
(August 2, 1990). Concerning groundwater flow rate under pumping conditions
at the site.
108. ''Technical Advisor Subagreement," Hope's Committee for a Clean Environment
and Beverly Paigin, Jackson Laboratory (August 20, 1990).
109. "Petition," Concerned Citizens of Hope (August 23,1990). Concerning citizens'
demands of the State of Maine Department of Environmental Protection, EP A
Region I and all Potentially Responsible Parties.
110. Letter from Michael Jasinski, EPA Region I to Thomas Sims, AFRCE-ER
(September 4, 1990). Concerning Mr. Sims' request for information.
III. Letter Repon from Carolie MAJ. Lamer, Concerned Citizens of Hope
(September 7, 1990). Concerning incin~ testing.
112. Letter from Mary H. Grcalisb, EPA Region I to Brian Powers, Hope's Comminee
for a Oean Environment (September 20, 1990). Concerning articles of
incorporation.
113. Letter from the U.S. Department of Health and Human Services Agency for Toxic
Substances and Disease Registry (A TSDR) to Residents of the South Hope are.1.
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13.2 Community Relations Plans
1.
2.
"Fmal Report - Community Relations Plan," CDM Federal Programs Corporation
(March 21, 1988).
"Community Relations Plan for Immediate Removal." EPA Region I.
13.3 News QippingsJPress Releases
News Clippings
1. "Union Finn, State Working Together On Complicated Chemical Disposal Plan,"
The Courier-Oazette - Rockland. ME (May 1. 1979).
2. "Hazardous Waste Plant Application Raises Fears Of Hope Residents,"
The Courier-Oazette - Rockland. ME (October 2, 1980).
3. "Waste Firm's Proposed Expansion Draws Fire At South Hope Hearing," Bangor
Daily News - Bangor. ME (October 3. 1980).' .
4. "DEP Recommends To BEP Air Emission Permit Be Granted To Union
Chemical." The Camden-Herald - Camden. ME (October 9. 1980).
5. "Petition Opposes Waste Recycling," The Courier-Gazette - Rockland, ME
(October 9, 1980).
6. "DEP Will Recommend License For Union Chemical," The Courier-Oazene -
Rockland, ME (October 9,1980).
7. "DEP Staff Backs S. Hope Firm Pcrmit," Portland Press Herald - Portland, ME
(October 9, 1980).
8. "Union Chemical President Doesn't See Overwhelming Permit Opposition,"
The Camden-Herald - Camden, ME (October 9, 1980).
9. "DEP Approves Union Chemicallncinerat01'," Bangor Daily News - Bangor, ME
(October 10, 1980).
10. "Hope Planning Board To Meet On Union Chemical," The Camden-Herald -
Camden, ME (October 23, 1980).
11. "Mter Active Response: BEP Postpones Ruling on Union Chemical Co. Air
Emissions License," The Courier-Oazette - Rockland, ME (October 23, 1980).
12. "Hcar1ng Deferred on Waste," Bangor Daily News - Bangor, ME
(October 24, 1980).
13. "Public Notice - The Hope Planning Board Will Hold A Meeting at the South
Hope Grange Hall on October 28th at 7:30 P.M.," The Couricr-Oaz.ette-
Rockland, ME (October 25, 1980).
14. "Chemical Firm Denied Boiler Permit," Portland Press Herald - Ponland, ME
(October 30,1980).
15. "Union Chemical's Permit Refused." Bangor Daily News - Bangor, ME
(October 30, 1980).
16. ''Union O1emicalls Denied Pennit," The Camden-Herald - Camden, ME
(October 30, 1980).
17. "Unrealistic AssuranCeS Asked. " The Courier-Gazette - Rockland, ME
(November 4, 1980).
18. "BEP Grants Air License To Union O1emical Co.," The Camden-Herald -
Camden, ME (November 13, 1980). .
19. "Union O1emical Granted Tempor3!}' Air Emission License by BEP,"
The Courier-Gazette - Rockland. ME (November 13, 1980).
20. "Chemical Recovery Opposed. " The Courier-Gazette - Rockland, ME
(November 18, 1980).
21. "South Hope Resident Sues Union O1emical Co. Owner," The Camden-Herald -
Camden, ME (November 20, 1980).
22. "Hope Planning Board Down By Two; Esposito Re-submits Application," .
The Camden-Herald - Camden ME (November 27, 1980).
23. "Hope Planning Board Back To Full Membership, Hardy Chainnan,"
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13.3 News Clippings/Press Releases (cont'd.)
News Clippings
24. 'Tensions At The Breaking Point In South Hope." The Camden-Herald - Camden.
ME (December 4. 1980).
25. "Something Rotten In Hope, And Elsewh~ " The Camden-Herald - Camden.
ME (December 4, 1980).
26. "Hope Residents Blame Dlnesses On Chemical Plant, " Bangor Daily News -
Bangor, ME (December 5, 1980).
27. "Esposito: Neighbors Suing To Close Plant, " Ponland Press Herald - Ponland,
ME (December 5. 1980).
28. "South Hope Residents Gather TO,Discuss Union Chemical Issue."
The Courier-Gazette - Rockland, ME (December 11, 1980).
29. "Lawsuit Seeks Emission Control, Damages From Union Chemical."
Courier-Gazene - Rockland, ME (December 11. 1980).
30. "Union Chemical Sues Hope B~" Ponland Press Herald - Ponland, ME
(December 12, 1980).
31. "Union Chemica] Seeks To Void Board Decision," Bangor Daily News-
Bangor, ME (December 12., 1980).
32. "A Chemical Plant Brews Controversy." The Boston Sunday Globe - Boston, MA
(December 14,1980). '
33., "No Clue to Pollution in Solvent Reclamation." Bangor Daily News - Bangor, ME
(December 16.1980).
34. "Misconceptions In Hope?," The Courier-Gazette - Rockland. ME
(December 18, 1980). '
35. "Not All One Sided," The Courier-Gazette - Rockland, ME (December 18, 1980).
36. "South Hope Gears Up For Tuesday Night; Union Chemical Application To Be
Pondered," The Camden-Herald - Camden, ME (January I, 1981).
37. 'Toxic Waste Plan Studied In Maine." The Boston Globe - Boston, MA
(January 11, 1981).
38. "Waste Rulings' Rejection Pleases Union Chemical," Ponland Press Herald -
Portland, ME (March 11, 1981).
39. "Cbemical Company Embattled," Bangor Daily News - Bangor, ME
(April 13, 1981).
40. "Board Upholds Union Chemical Building Pcnnit," Portland Press Herald -
Ponland, ME (May 1, 1981).
41. "Maine DEP Officials Are Weary Of Complaints On Firm, They Say," Bangor
Daily News - Bangor. ME (May 20.1981).
42. "Hope Plant Exceeds EPA Standards - Chemical Levels Too High."
The Camden-Herald - Camden, ME (June 4, 1981).
43. "Hazardous Waste Study," The Boston Globe - Boston. MA (August 16, 1982).
44. "Recycling Hazardous Waste - One-Man Project Becomes A Viable. Vital
Business," Maine Sunday Telegram - Portland, ME (December 19, 1982).
45. "Union Says Waste Law Won't Stand," Ponland Press Herald - Ponland, ME
(May 20. 1983).
46. "Firm Calls Violations Only Technicalities." Maine Sunday Telegram - Ponland,
ME (May 20. 1983).
47. "EPA Seeks $15K From Union Chem.," Lewiston Dally Sun - Lewiston, ME
(November 18, 1983).
48. "EPA Fines Chemical Co.," The Courier-Gamte- Rockland, ME
(November 19, 1983).
49. "EPA Fines Union Chemical $15,000," The Camden-Herald - Camden, ME
(November 24, 1983).
50. "Union Chemical Fights Fme." The Camden-Herald - Camden. ME
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Page 35
13.3 News Clippings/Press Releases (cont'd.)
News Clippings
51. "Union Chemical- A Last Minute Reprieve," Maine Times - Topsham. ME
(April 20, 1984).
52. "Town Has Waste Site Problem." The Boston Globe - Boston, MA
(May 13, 1984).
53. "Aftermath At Union Chemical- Maine's Only Hazardous Waste Disposal Facility
Is Closed - Did It Have To Happen," Maine Times - Topsham, ME
(July 19, 1984). .
54. "Union Chemical Hauls Off Drums," Bangor Weekend - Bangor, ME
(July 21, 1984).
55. "Union Chemical Oean Up Begins," The Courier-Gazette - Rockland, ME
(July 21, 1984). .
56. "400 Barrels Removed - Chemical Ceanup Continues," The Camden-Herald -
Camden, ME (July 26, 1984).
57. "Esposito Says Will Seek Relicensing Of Plant," The Courier-Gazette - Rockland,
ME (September II, 1984).
58. "Private Meeting With DEP Is Denied," The Courier-Gazene - Rockland, ME
(September 13, [984).
59. "Union Chemical Seeks Local Area Support, " The Camden-Herald - Camden, ME
(September 13, 1984). .
60. "Plant Relicensing Possible If Regulations Followed," The Courier-Gazette -
Rockland, ME (September 18, 1984).
61. "EPA Crews Called Sloppy," Portland Press Herald - Portland, ME
(October 10, 1984).
62. "Visit Satisfies DEP Officials With EPA's Union Cleanup," Portland Press
Herald - Portland, ME (October 11, 1984).
63. "Union Chemical Cleanup - EPA's Work Questioned In DEP Files," Ponland
Press Herald - Portland, ME (October 30,1984).
64. "State Wants Explanation Of Bmels,"The Comier-Gazene - Rockland, ME
(March 23,1985).
65. "Plant Owner Says Barrels Pose No Hazards," The Courier-Gazette - Rockland.
ME (March 26, 1985).
66. "DEP To Test 400 Barrels At Union O1emical Plant," The Camden-Herald -
Camden, ME (March 28, 1985).
67. "DEP, Esposito Waging Debate Over New Barrels," Portland Press Herald -
Portland, ME (March 29, 1985).
68. "Plant To Get 'Superfund' Oeanup Money," Portland Press Herald - Ponland,
ME (March 29, 1985).
69. "Maine Plant May Join Dump Ust," Portland Press Herald - Portland, ME
(March 30, 1985).
70. "BFA Will List Maine Waste Site," The Boston Globe - Boston, MA
(March 30,1985).
71. "Union Chemical On Superfund List," The Comier-Gazette - Rockland, ME
(March 30, 1985).
72. "Owner Criticizes Superfund Designation," Portland Press Herald - Ponland, ME
(April 3, 1985).
73. "Esposito Defends Union Chemical." Bangor Daily News - Bangor, ME
(April 3, 1985).
74. "Esposito Blasts Superfund Move," Portland Press Herald - Ponland, ME
(April 3, 1985).
75. "Esposito Blasts EPA Action On Union O1emical." The Courier-Gazene -
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- - -. -..
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Page 36
. 13.3 News ClippingslPress Releases (cont'd.)
News Clippings
76. "Road-Entry Pennit Needed To Finish Laying Pipe," Bangor Daily News -
Bangor, ME (June 20, 1985).
77. "Chemical Dispute Still Bums - Barrels At Union Chemical Spark New Calls To
Oose It Down," Maine Sunday Telegram - Ponland, ME (June 23, 1985).
78. ''DEP Lawsuit Seeks Foneiture Of Union Chemical Plant to State:' The
Courier-Gazette - Rockland, ME (Iuly 25, 1985). .
79. "DEP Sues Union Chemical, Seeks Total Removal," The Camden-Herald -
Camden, ME (July 25,1985).
80. "Union Chemical Owner Sues Three DEP Officials," Portland Press Herald -
Portland, ME (July 25,1985).
81. "Fence Dispute Caused DEP Forfeiture Action:' The Courier-Gaz.ette - Rockland,
ME (July 27, 1985).
82. ''Detailed Plan Unveiled For Soil, Water Contamination Oeanup,"
The Courier-Gazette - Rockland, ME (November 5, 1985).
83. "DEP Says Union Chemical Cleanup A Long-Term Job:' The Camden-Herald -
Camden, ME (November 14, 1985).
84. "Hope Citizens Press State for Answers:' Bangor Daily News - Bangor, ME
(January 23, 1986).
85. "Hope Group ~ Recognition," The Courier-Gazette - Rockland, ME
(May 29, 1986).
86. "Court Orders Closing Of Union Chemical," Portland Press Herald - Portland,
ME (June 6,1986).
87. "Union Chemical Well Drilling Begins," The Courier-Gaz.ette - Rockland, ME
(June 24, 1986). .
88. "'Test Wells Drilled To Determine Contamination At Union Chemical," Bangor
Daily News - Bangor, ME (June 25, 1986).
89. "DEP Official Visits Oeanup Site," Portland Press Herald - Ponland, ME
(June 25, 1986).
90. "Plant Oeanup Could Reach $2 Million," The Courier-Gazette - Rockland, ME
(June 26, 1986).
91. "Esposito Blames Neighbors For Prank," Portland Press Herald - Portland, ME
(July 29, 1986).
92. "Sugar Found In Tank At Union Chemical Plant," The Courier-Gazette -
Rockland, ME (July 31, 1986).
93. "Esposito Bids Farewell, DEP Cleanup Continues," The Courier-Gazette -
Rockland, ME (August 2, 1986).
94. "Esposito Off Union Chemical Site," Portland Press Herald - Portland, ME
(August 5, 1986).. .
95. "DEP Still Drilling In Hope:' Portland Press Herald - Portland, ME
(August 23, 1986). .
96. "Portland Firm Assists In Union Chemical Ceanup," The Courier-Gazette-
Rockland, ME (August 26, 1986).
97. "Wells Installed At Union Chemical," Portland Press Hc:rald - Portland, ME
(January 8, 1987).
98. "Chemical Drum Oean-Up Costs Soar," The Courier-Gazette - Rockland, ME
(January 15, 1987).
99. "Waste Worse Than Claimed - Citizens Want PeIjury Charges," Portland Press.
Herald - Portland, ME (January 17,1987).
100. "Companies May Be Billed For Union Chemical Oeanup," The Courier-Gazette -
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.. -- - .--.-. - -
Page 37
13.3 News ClippingslPress Releases (cont'd.)
News Clippings
101. "At Union Chemical Site - Waste Contamination May Be Widespread,"
The Courier-Gazette - Rockland, ME (May 7, 1987).
102. "Pollution Risk Estimates Rise," Portland Press Hera1d - Portland, ME
(May 7, 1987).
103. "Public Meeting Called - Union Chemical Danger Underestimated By DEP,"
The Camden-Herald - Camden. ME (May 7, 1987).
104. "Toxicologist Says S. Hope In Danger," Maine Sunday Telegram - Portland, ME
(May 10, 1987).
105. "Health Risks From The Union Chemical Co. Are Perhaps More Serious."
Bangor Daily News - Bangor, ME (May 11, 1987).
106. ''EPA Urged To Ust Hope Site On Superfund Cleanup Ust," Bangor Daily
News-Bangor.ME(May 13. 1987). . .
107. ''Hazardous Waste - Worst He's Seen," Maine Times - Portland, ME
(May 22. 1987).
108. "EPA Agrees To Begin Well Testing In Hope," The Camden-Herald - Camden.
ME (June 11, 1987).
109. ''Waste Problem Plagues Town." The Boston Globe - Boston, MA
(June 21, 1987).
110. "Selectmen Receive Letter From EPA On Union Chemical Problem," The
Camden-Herald - Camden. ME (June 25.1987). .
111. "Union Chemical orr Superfund, EP A Says Site Work Will Proceed."
The Courier-Gaz.ette - Rockland, ME (July 23. 1987).
112. "Brennan Offers Help On Dropped Waste Site." Portland Press Herald - Portland,
ME (July 28. 1987).
113. "Superfund Exclusion Explained." Portland Press Herald - Portland, ME
(July 31,1987).
114. "Union Chemical Study May Take Two Years," The Courier-Gazctte - Rockland,
ME (August I, 1987).
115. "Watt.r Company Tests For Chemical Runoff," The Courier-Gazette - Rockland,
ME (August 1, 1987). .
116. "Health To Be Surveyed In South Hope," The Courier-Gaz.ette - Rockland, ME
(August 18, 1987).
117. "EPA: Chemicals In Hope Wens," The Camden-Herald - Camden. ME
(September 17, 1987).
118. "Companies A~ To Aid In Qeanup At Union Chemical," Bangor Daily
News - Bangor, ME (September 18, 1987).
119. "Finns To Pay For Cleanup," Portland Press Herald - Portland, ME
(September 18, 1987).
120. "Consultant Opposes Water-Use Proposal," Bangor Daily News - Bangor, ME
. (September 18, 1987).
121. ''Toxicologist Says Hope Contamination 'Nipped In the Bud,'" Portland Press
Herald - Portland, ME (September 18, 1987). .
122. "State And Fed~ Officials Promise More Tests On South Hope Wells," Bangor
Daily News - Bangor, ME (September 23, 1987).
123. "EPA Hedges On Well Testing," Portland Press Hera1d - Portland, ME
(September 23, 1987).
124. "Lappe Warns Hope: Plume Moving." The Camden-Herald - Camden. ME
(September 24, 1987).
125. "Hope Accuses EP A, DEP of Dragging Feet," The Courier-Gaz.ette - Rockland,
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Page 38
13.3 News ClippingslPress Releases (cont'd.)
News Clippings
126. "Wells Near Union Chemical To Be Tested For Contamination," Maine Weekend-
Bangor, ME (October 24, 1987).
127. "Esposito Land Auction Set To Recover Losses," The Courier-Gaz.ette -
Rockland, ME (October 27, 1987).
128. "Proposed Settlement Reached In Union Chemical Ceanup," Bangor Daily
News - Bangor, ME (October 27, 1987).
129. "Firms Agree To Pay Oean-Up Costs," The Couricr-Gaz.ette - Rockland, ME
(October 29, 1987).
130. "Government Sues Users Of Union Chemical Dump," Portland Press Herald -
Portland, ME (November 7, 1987).
131. "EP A Files Suit In Ceanup Case," Evening Express - Portland, ME
(November 7,1987). .
132. ''Lawsuit FiJed Ow:r Chemical Cleanup," The Courier-Gaz.ette - Rockland, ME
(November 10,1987).
133. "EPA Lawsuit Names Union Chemical,"1be Camden Herald - Camden, ME
(November 12,1987).
134. "Chemical Site Ceanup Plan Readied," The Courier-Gaz.ette - Rockland, ME
(December 8, 1987).
135. "EPA Well Tests In South Hope Reveal Toxins," The Camden-Herald - Camden,
ME (January 7, 1988).
136. "Union Chemical Contamination Spreading," Bangor Daily News - Bangor, ME
(January 7, 1988).
137. "More Wells Show Traces of Pollution," Portland Press Herald - Portland, ME
(January 8, 1988).
138. "Water Pollution Spreads In Hope," Maine Sunday Telegram - Portland, ME
(January 10, 1988).
139. "Expert Says Hope Toxins Spreading," Portland Press Herald - Portland, ME
(January 13, 1988).
140. "Union Chemical Pollution Worse Than Fust Expected," Bangor Daily News -
Bangor, ME (January 13, 1988).
141. ''Pollution Exceeding Estimates," The Courier-Gaz.ette - Rockland, ME
(January 14, 1988).
142. "25 Groups Pay $69,000 for Cleanup," Bangor Daily News - Bangor, ME
(January 15, 1988).
J43. "DEP Cautious On Latest Chemical Co. Site Report," The Courier-Gazette -
Rockland, ME (January 16, 1988).
144. "Hope Citizens Angry With Town, Union Chemical," Bangor Daily News -
Bangor, ME (January 18, 1988).
145. "Accord Reached On Site Cleanup," Evening Express - Portland, ME
(1anuary 21, 1988).
146. "Union Chemical Ceanup To Resume," Portland Press Herald - Portland, ME
(January 21, 1988).
147. ''Union Chemical Dumpers Come To Terms With EPA," The Courier-Gaze~ -
Rockland, ME (January 23, 1988). .
148. "Meeting Focuses On Status Of Union Cb~ir.aI,"1be Courier-Gazette-
Rockland, ME (February 20, 1988). . .
. 149. "EPA, DEP Promise Not To Forget Waste Site," Portland Press Herald -
Portland, ME (February 24, 1988).
150. ''Federal Agency To Assess Area Of Defunct Union Chemical Company," Ba!1fo!
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Page 39
13.3 News ClippingslPress Releases (cont'd.)
News Clippings
151. ''EPA Installs New Union Chemical Hotline," The Camden-Herald - Camden, ME
(February 25, 1988).
152. "EP A Opens Union Chemical Hotline," The Courier-Gazette - Rockland. ME
(March 3, 1988).
153. ''EP A Installs Qeanup Hotline," Bangor Daily News - Bangor, ME
(March 3, 1988).
154. "Hazwaste Hotline Set Up," Kennebec Journal- Augusta, ME (March 5, 1988).
155. "Don't Drink Water At Crawford Pond, Says EP A," Bangor Daily News -
Bangor, ME (March 11, 1988).
156. "EPA To Respond," Portland Herald Press - Portland, ME (March 12, 1988).
157. "Agency To Test Waters Feeding Crawford Pond," Bangor Daily News - Bangor,
ME (March 15, 1988).
158. "Possibility Of Pond Contamination Is Said 'Overly Cautious' Warning,"
The Courier-Gazette - Rockland, ME (March 15, 1988).
159. "ATSDR On Union Chemical: Tests On Off-Site Soils Needed,"
The Camden-Herald - Camden, ME (March 17, 1988).
160. "Broad-Based Panel To Study Effects Of Contamination," The Courier-Gazette -
Rockland, ME (March 24, 1988).
161. "Health Study Plan Urged," The Courier-Gazette - Rockland, ME
(April 2, 1988).
162. "DEP OKs Warren Pond Site," Bangor Daily News - Bangor, ME
(Apri112, 1988).
163. "DEP Tests Reveal Crawford Clean, Quiggle Shows Heavy Metals Traces,"
The Camden Herald - Camden, ME (Apri114, 1988).
164. "Union Chemical Listed One Of 7errible Ten'," The Courier-Gazette, Rockland.,
ME (April 16, 1988). .
165. "Waste Site Plans Due For Hearing," Evening Express - Portland. ME
(May 7,1988).
166. "Waste-Site Tests Reveal Solvents," Portland Press Herald - Portland, ME
(May 7,1988).
167. "Qeanup Process Continues At Union Chemical Site:' The Courier-Gazette-
Rockland, ME (May 7, 1988).
168. ''DEP Schedules Union Chemical Public Meeting:' The Camden-Herald -
Camden, ME (May 12, 1988).
169. "Site Work To Begin At Chemical Company," The Courier-Gazette - Rockland.,
ME (May 14,1988).
170. "Chemical Cleanup Set For Fall Start," Portland Press Herald - Portland, ME
(May 20, 1988). .
171. "Union Chemical Cleanup Creeps Ooser," The Courier-Gazette - Rockland, ~1E
(May 21,1988).
172. "Hope Cleanup Plans Slowly Taking Shape," Sunday Sun Journal- Lewis tOn ,
ME (May 22,1988).
173. "Towns Hire Experts To Untangle Red Tape," Sunday Sun Journal- Lewiston.
ME (May 22,1988).
174. "Union O1emical Plant Again On EPA Priority Cleanup List," Maine Weekend.
Bangor, ME (July 16, 1988).
175. "Hope Site Proposed For Cleanup List," Portland Press Herald - Portland, ~1E
(July 16, 1988).
176. "Union Chemical Site Again Proposed For Inclusion On Priority List,"
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Page 40
13.3 News ClippingslPress Releases (cont'd.)
News Clipping,s
177. "Union Chemical Company Site Reproposed Onto NPL," Free Press - Rockland,
ME (July 25,1988).
178. "DEP Reports Finding Additional Spills At CbI'!mIt"..al Site," The Couricr-Ga..zette -
Rockland, ME (July 26,1988). '
179. ''Legislature OKs Water Moratorium," The Courier-Gazette - Rockland, ME
(September 17,1988).
180. "Water Co., Businesses Rap Ponds Bin," The Courier-Gazettc - Rockland, ME
(September 22,1988). ,
181. "One-Year Moratorium On Fish Pond Water Supply Passed In Augusta,"
The Camden-Herald - Camden, ME (September 22, 1988).
182. "Security To Tighten In Wake Of Thefts At Union Chemical,"
The Courier-Gazette - Rockland, ME (September 24, 1988).
183. "Tests For Pond Pollution Yield Minimal Trace Levels," The Courier-Ga..zette -
Rockland, ME (September 27, 1988).
184. "Water Co. Plan Taps Ponds," The Courier-Gazette - Rockland, ME
(November 12,1988).
185. "Water Co. Unveils Fish-Hobbs Plan," The Camden-Herald - Camden, ME
(November 17,1988). .
186. "Hearing To Brief Public On Union Chemical," The Courier-Gazette - Rockland,
ME (January 21, 1989). '
187. "Hearing To Take Up Chemical Report," Portland Press Herald - Portland, ME
(January 25, 1989).
188. "Meeting Slated To Review Study," The Camden-Herald - Camden, ME
(January 26, 1989).
189. "Report Calls Hope Ponds Safe," The Courier-Gazette - Rockland, ME
(January 26, 1989).
190. "Canonie: Fish Pond Is Clean," The Camden-Herald - Camden, ME
(January 26, 1989).
191. "Work Plan For Union Chemical Site Released," The Camden-Herald - Camden,
ME (February 23, 1989).
192. "Union Chemical Plan Lists Next Work Phase," The Courier-Gazette - Rockland,
ME (February 25,1989).
193. "Bill Would Withdraw Water Rights," The Courier-Gazette - Rockland, ME
(Apri129,1989).
194. "Water Bill Is Wrong Solution," The Courier-Gazette . Rockland, ME
(Apri129, 1989).
195. "EPA Orders Clean-Up Cost RecovCJ)'," The CourieI'-Gazeue - Rockland, ME
(May 25, 1989).
196. "Finns To Pay Ccan-up Costs," The Courier-Gazeuc - Roc1rIAnd, ME
(May 27, 1989).
197. "Responsible Parties To Fund Union Chemical Ceanup; &posito Won't Pay,"
The Camden-Herald - Camden, ME (June 1, 1989).
198. "South Hope Site Added To Fecknl Superfund List," Kennebec Journal-
Augusta, ME (September 29, 1989).
199. "Union Chemical Makes Final Supedund List," The Courier-Gazettc-
Rockland, ME (October 21, 1989).
200. "Union Chemical Dump Makes EP A Priority List," Portland Press Herald -
Portland, ME (October 24, 1989).
201. "Federal Aid Available For Hope Clean-Up," The Camden-Herald - Camden, ME
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Page 41
13.3 News ClippingslPress Releases (cont'd.)
News Clippings
o
202. "Private Consultant To Report To Hope Officials On Ecological Report About
Union Chemical," Bangor Daily News - Bangor, ME (October 31, 1989).
203. "Lawyer Urges More Testing At Union Chemical," Portland Press Herald -
Portland, ME (January 23, 1990).
204. "Consultant Disagrees with Study's Conclusions," Bangor Daily News -
Bangor, ME (January 23; 1990).
205. "Lawyer Urges More Testing at Union Chemical," Portland Press Herald -
Portland, ME (January 23, 1990).
206 "Union Chemical Report Doubted," The Courier.(jazette - Rockland, ME
(January 23, 1990).
207. ''Testing of Union Chemical Site Recommended," Bangor Daily News -
Bangor, ME (March 22,1990). .
208. "EP A Says Chemicals Moving Through South Hope Bedrock:'
The Courier-Gazette - Rockland, ME (March 24, 1990).
209. "Private Test Shows Higher pollution In Hope's Water," Portland Press
Herald - Portland, ME (March 24, 1990).
210. "Fonner Chemical Plant Owner Denies Polluting," Bangor Daily News - Bangor,
ME (April 16, 1990). .
211. "Union Chemical Report To Be Topic At Public Hearing," Bangor Daily News-
Bangor, ME (April 25, 1990).
212. "Union Chemical Studies Are Focus Of Meeting," The Camden Herald - Camden,
ME (April 26, 1990).
213. ''Union Chemical Report Focus Of Meeting May 2," The Courier-Gazette -
Rockland, ME (April 26, 1990).
214. "Study Says Hope Wells Safe," Portland Press Herald - Portland, ME
(May 3, 1990).
215. "Canonie Reports Union Chemical Is 'No Danger'," The Camden Herald-
Camden, ME (May 10, 1990).
216. "EPA Confmns Test Results," The Courier-Gazette - Rockland, ME
(May 10, 1990).
217. ''The U.S. Environmental Protection Agency Invites Public Comment On The
Administrative Record And Proposed Plan For The Union Chemical Company.
Inc. Superfund Site in South Hope, Maine:' The Camden Herald - Camden, ME
(July 5, 1990).
218. ''EP A Reschedules Hope Meeting," The Courier Gazette - Rockland, ME
(July 7, 1990).
219. "Hope Oeanup Hearing ntmday," Portland Press Herald - Portland, ME
(July 9, 1990).
220. "EP A To Present Plan For Cleanup At Hope," Bangor Daily News - Bangor, ME
(July 11, 1990).
221. ''Hearing Tonight On Union Chemical Oeanup Plan," The Camden Herald -
Camden, ME (July 12, 1990). .
222. "Chemical Cleanup May Take 33 Years:' Portland Press Herald - Portland, ME
(July 13, 1990).
223. "Site Qeanup Could Take A Generation," The Courier-Gazctte - Rockland, ME
(July 14, 1990).
224. "An Ounce Of Prevention," The Evening Express - Portland, ME (July 18, 1990).
225. "Chemical Cleanup Will Take Years," The Camden Hcnld - Portland, ME
(July 19, 1990).
. 226. "Residents Fear Chemical Legacy," Portland Press Herald - Portland, ME
(August 1, 1990).
227. "Critics Say Cleanup Proposal Falls Short," Bangor Daily Ne~ - Bangor, ~ fE
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Page 42
13.3 News ClippingslPress Releases (cont'd.)
News Clippings
228. "Ceanup Plans Draw Scant Comment," Ponland Press Herald - Portland, ME
(August 2. 1990).
229. "Citizen Renews Call For Health Testing," The Courier-Ga.zettc - Rockland, ME
(August 4, 1990).
230. ''Environmental Protection Agency Extends Comment Period On Contamination at
Hope," Bangor Daily News - Bangor, ME (August 7, 1990).
231. "Union Chemical Neighbors Demand Medical Tests," The Camden Herald-
Camden. ME (August 9,1990).
232. "Comments Halted On Hope Ceanup:' Portland Press Herald - Portland, ME
(August 20, 1990).
233. ~'Hope Residents Play For Time." Portland Press Herald - Portland, ME
(August 21, 1990). .
234. "Request Denied For Comment Extension:' The Courier-Ga.zettc - Rockland, ME
(August 21, 1990).
235. "Let's Not Slow The Ceanup More," The Kennebec Journal - Augusta, ME
(August 22, 1990).
236. "Hope Pressures EP A To Allow Experts To Testify:' The Camden Herald -
Camden, ME (August 23. 1990).
237. "EPA Grants Extension To Hope," The Camden Herald - Camden, ME
(August 30, 1990).
238. "EPA Extends Time For Comment On Union Chemical Plan."
The Courier-Gazette - Rockland, ME (August 30, 1990).
239. "EPA Extends Comment Period," Bangor Daily News - Bangor, ME
(August 30, 1990).
240. "Experts Ready Briefs In So. Hope Ceanup:' The Courier-Gazette -
Rockland, ME (September 1, 1990).
241. Letter to the Editor: "Gift Of Time:' The Camden Herald - Camden, ME
(September 6, 1990).
242. "Panel Says Ceanup Falls Short," Portland Press Herald - Portland, ME
(September 18.1990>..
243. "Hope Ceanup Plan Not Enough, Consultants Say:' Bangor Daily News -
Bangor, ME (September 18,1990).
244. "Experts Say Ceanup Plan Falls Short," The Courier-Gazette - Rockland, ME
(September 20, 1990).
245. "Concerns With EP A Plan Raised," The Camden Herald - Camden, ME
(September 20, 1990).
246. Letters To The Editor: "Protect Hope's Ponds" and ''Recreational Use Of Fish
And Hobbs Pond," The Camden-Herald - Camden, ME.
247. "EPA: Union Chemical Water Cean-Up CouJd Be 50 Years."
248. "Concerned Citizens Of Hope Force The Oose-Down Of Union Chemical," Maine
People's Alliance. .
249. "Well Contamination Or Improved Flow."
250. "$400,000 Superfund Allocation - EP A Begins Union Chern. Ceanup."
'. The Courier-Gazette - Rockland, ME.
25 1. "Chemical Boiler Gets DEP Permit," Portland Press Herald - Portland, ME.
252. "Judge Decides - Union Chemical Dnlm Storage Inaeased. "
253. "EPA Denies Extension For Hope Toxic Waste Study."
254. ''BPA Lengthens Time On Cleanup Plan."
255. "Union Chemical Suit Against Town Only A 'Defensive Action,' Says Esposito."
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Page 43
13.3 News ClippingslPress Releases (cont'd.)
News Clippings
257. "Civil Action Filed Against Esposito."
258. ''Waste Firm Head Sued."
259. "Hope In Hope."
260. "Plant Owner Says Charges Are Lies."
261. ''Toxic Waste Plan Studied In Maine."
Press Releases
262. "Public Notice," WRKD (December 1, 1983). Concerning application for
hazardous waste license.
263. "Press Infonnation," State of Maine Department of Environmental ProteCtion
(June 27,1984). Concerning decision to reject license application.
264. "Environmental News," EPA Region I (August 10,1984). Concerning allocation
of $400,000 from SupeIfund to remove drums and pump storage tanks.
265. "Press Advisory," EPA Region I (August 27,1984). Concerning availability of
EPA representative at the site every Wednesday at 2:00 p.m.
266. "Environmental News," EPA Region I (September 13, 1984). Concerning
$12,000 penalty for violation of hazardous waste management laws.
267. Press Release, State of Maine Department of Environmental ProteCtion
(October II, 1984). Concerning Commissioner Henry E. Warren's response to
critical press reports and cleanup evaluation. .
268. "Press Advisory," EPA Region I (November S, 1984). Concerning press
availability and completion of cleanup operations. .
269. "Environmental News - Public Meeting to Explain Cwrent and Future Plans for
the Union Chemical Superfund Site Announced," EP A Region I
(July 20, 1987). .
270. "Environmental News - EP A and the Maine DEP to Hold Public Meeting," EP A
Region I (September 16, 1987).
271. ''Environmental News - EPA Announces Signing of Administrative Order," EPA
Region I (September 17, 1987).
272. ''Environmental News - EPA Files Suit Against Nonsettlers Who Declined to Join
Consent Orders for Cleanup Work," EPA Region I (November 6, 1987).
273. ''Environmental News - EP A Settles with 2S Additional Parties for Oeanup
Wm," EPA Region I (January 13, 1988).
274. "Environmental News - EPA and the Maine DEP to Hold Public Meeting," EPA
Region I (February 8, 1988).
275. "EPA Starts Hotline," EPA Region I (March 1, 1988). Concerning correction of
the hotline telephone number.
276. ''Environmental News - Public Meeting to Explain Plans for the Union Chemical
Company Superfund Site Announced," EPA Region I (May 6,1988).
277. "Union Chemical Company, Inc. Site Reproposed onto NPL," EP A Region I
(July', 1988).
278. ''Environmental News - EPA and the Maine DEP Announce Public Meeting," EPA
Region I (January 19, 1989).
279. "Environmental News - EPA Releases Draft Plan for Further Field Investigation,"
EPA Region I (February 13, 1989).
280. ''Environmental News - EP A Announces Public Informational Meeting," EP A
Region I (April 1S, 1989). .
281. "Environmental News - Responsible Parties to Pay 100 Percent of EPA's
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13.3 News ClippingslPress Releases (cont'd.)
Press Releases
282. ''Environmental News - Nine Sites in Region Named to Superfund Priority List,"
EP A Region I (September 28, 1989).
283. "Environmental News - EP A and Maine DEP Announce Public Meeting for Union
Chemical Site," EPA Region I (April 20, 1990).
284. ''Environmental News - EP A to Propose Ceanup Plan for Union Chemical
Company, Inc. Superfund Site at Upcoming Public Meeting," EPA Region I
(July 2, 1990).
285. "Environmental News - EPA Reschedules Union Chemical Co., Inc. Superfund.
Site Public Meeting for Thursday, July 12th," EP A Region I (July 5, 1990).
286. "Environmental News - EP A Extends Public Comment Period and Schedules
Additional Public Hearings for the Union Chemical Co., Inc. Superfund Site,"
EPARcgionI (July 31,1990).
287. "Environmenta1 News - EP A Conf1I1tlS Requests for Additional Public Hearings
and Denies Second Extension Request to Public Comment Period for the Union
Chemical Company Superfund Site," EP A Region I (August 17, 1990).
288. "Public Notice," Union Chemical Co., Inc. Concerning flIed application for a
license to operate a hazardous waste treatment facility.
13.4 Public Meetings
1. "Statement for Public Meeting on the Report of the Prevalence of Selected Health
Problems Among Residents Living in the Vicinity of the Union Chemical
Company," State of Maine Department of Human Services
(December 15, 1983). .
2. State of Maine Department of Environmental Protection Meeting Agenda, Public
Meeting for the Union Chemical Co., Inc. (November 6, 1985) with attached list
of attendees. Concerning remedial action alternatives.
3. "To be Read into Record by CCH Rep. at 9 June 1987 EPA Region I Meeting,"
Carolie MAJ. Lamer, Concerned Citizens of Hope (June 8, 1987).
4. EPA Region I Agenda and Meeting Handout, Public Information Meeting for the
Union Chemical Co., Inc. Site (September 22, 1987).
S. EPA Region I Agenda and Meeting Handout, Public Information Meeting for the
Union Chemical Co., Inc. Site (February 23, 1988). .
6. U.S. Department of Health and Human Services Agency for Toxic Substances
and Disease Registry (A TSDR) Agenda, Draft Health Assessment Public
Meeting for the Union Chemical Co., Inc. Site (March 10,1988).
7. ''Draft Public Meeting Summary," CDM Federal Programs Corporation
(March 11, 1988). Concerning the February 23, 1988 Public Information
Meeting for the Union Chemical Co., Inc. Site.
8. Cross-Reference: Letter from Marilyn R. DiSirio, U.S. Department of Health
and Human Services Agency for Toxic Substances and Disease Registry
(ATSDR) to A. Mark Woodward, Bangor Daily News (March 17, 1988).
Concerning the March 10, 1988 public meeting, and prevention measures
against potential exposures [Filed and cited as entry number 61 in 13.1
ColTCSpondence ].
9. EPA Region I Agenda and Meeting Handout, Public Information Meeting for the
Union Chemical Co., Inc. Site (May 19, 1988).
10. ''Draft Public Infonnation Meeting Summary," CDM Federal Programs
Corporation (June 27,1988). Concerning the May 19, 1988 Public Information
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13.4 Public Meetings (cont'd.)
11. ''Draft Public Meeting Summary," Camp Dresser & McKee Inc.
(June 27, 1989). Concerning the May 3, 1989 public meeting.
12. Transcript, Public Hearing for the Union Chemical Co., Inc. Superfund Site
(August 1, 1990).
13. Transcript, Public Hearing for the Union Chemical Co., Inc. Superfund Site
(August 23, 1990).
14. Transcript, Public Hearing for the Union Chemical Co., Inc. Superfund Site
(August 23, 1990).
15. Transcript, Public Hearing for the Union Chemical Co., Inc. Superfund Site
(September 17, 1990).
13.5 Fact Sheets
1. "Setting the Facts Straight," Union Chemical Co.. Inc. (February 27, 1984).
2. "Union Chemical Site Fact Sheet," EPA Region I (July 20, 1984). Concerning
Union Chemical Co., Inc. activities from 1967 to 1984.
3. "Progress and Plans," EPA Region I (August 24,1984).
4. "Progress and Plans," EPA Region I (August 29,1984).
S. "Progress and Plans," EP A Region I (September 7, 1984).
6. "Progress and Plans." EPA Region I (September 14, 1984).
7. "Progress and Plans." EP A Region I (September 19. 1984).
8. "Progress and Plans." EPA Region I (September 27, 1984).
9. "Progress and Plans," EPA Region I (October 11, 1984).
10. "Progress and Plans," EPA Region I (October 25,1984).
11. "Union Chemical Company," EPA Region I (November 9, 1984). Concerning
completion of removal activities on November 8,1984.
12. "Superfund Program Information Sheet," EPA Region I (July 1987). Concerning
surnmaI)' of activities at the site and announcing the July 30, 1987 Public Meeting.
13. "Superfund Program Fact Sheet," EPA Region I (February 1988). Concerning
residential wen sampling program, work plan status, and NPL status.
14. "Remedial Investigation/FeaSibility Study," EPA Region I (May 1988).
Concerning description of the RllFS work plan.
15. "Union Chemical Update." EPA Region I (July 1988). Concerning activities
planned for July and August 1988.
16. "Union Chemical Update," EPA Region I (September 1988). Concerning sampling
pro~
17. "Initial Site Characterization," EP A Region I (January 1989). Concerning
overview of fieldwork undertaken by EP A and State of Maine Department of
Environmental ProteCtion. .
18. "Fact Sheet - EP A Completes Union Chemical Site Field Investigations," EP A
Region I (March 1990).
13.7 Technical Assistance Grants
1.
Letter from Carotie MAJ. Lamer, Concerned Citizens of Hope to Merrill S.
Hohman. EPA Region I (January 2, 1988). Concerning intent to apply for
Technical Assistance Grant
Letter from Carotie MAJ. Lamer. Concerned Citizens of Hope to EPA Region 1
(March 7,1988). Concerning request for Technical Assistance Grant application.
Letter from Chris Jendras, EP A Region I to Interested Citizens .
(March 31,1988). Concerning availability of Technical Assistance Grant
2.
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13.7 Technical Assistance Grants (cont'd.)
4. Letter from Mary H Grealish, EP A Region I to Carolie MAJ. Lamer, Concerned
Citizens.for Hope (April 28, 1988) with attached notice. Concerning response to
the March 7, 1988 Letter from Carolie MAJ. Lamer, Concerned Citizens of Hope.
S. "Hope Group to Receive U.S. Grant," Bangor Daily News - Bangor, ME
(May 10, 1988). .
6. Letter from Mary Edgerton, Maine People's Alliance to Mary R Grealish, EP A
Region I (May 19, 1988). Concerning endorsing the award of Technical Assistance
Grant to Concerned Citizens of Hope.
7. Letter from Brian Powers, Hope's Committee for a Oean Environment to Mary H.
Orealish, EPA Region I (May 27,1988). Concerning intent to apply for Technical
Assistance Grant.
8. Letter from Mary H Grealish, EPA Region I to Brian Powers, Hope's Committee
for aOean Environment (June 7,1988). Concerning response to the
May 27, 1988 Letter from Brian Powers, Hope's Committee for a Oean
Environment.
9. Letter from Mary H. Grealish, EP A Region I to Carolie MAJ. Lamer, Concerned
Citizens for Hope (June 16, 1988). Concerning transmittal of the May 1988 Final
"The Citizens' Guidance Manual for the Technical Assistance Grant Program,"
EP A Headquarters.
10. Letter from Mary H. Grea1ish, EPA Region I to Brian Powers, Hope's Committee
for a Oean Environment (June 16, 1988). Concerning transmittal of the May 1988
"Final - The Citizens' Guidance Manual for the Technical Assistance Grant
Program," EPA Headquarters. .
11. "Second Committee Emerges to Vie for Clean-up Funds," The Courier-Gazette -
Rockland, ME (July 2, 1988).
12. Letter from Ursula A. Gillis, Concerned Citizens for Hope to Mary H Grealish,
EPA Region I (July 5,1988) with attachments. Concerning request to extend the
filing deadline.
13. Letter from Mary H Grealish, EPA Region I to Carotie MAJ. Lamer, Concerned
Citizens for Hope (July 15, 1988). Concerning response to the
July 5, 1988 Letter from Ursula A. Gillis, Concerned Citizens for Hope.
14. Letter from Mary H. Grealish, EPA Region I to Brian Powers, Hope's Committee
for a Clean Environment (July 15,1988). Concerning confirmation of receipt of an
application for the Technical Assistance Grant.
15. Letter from Mary H. Grealish, EPA Region I to Brian Powers, Hope's Committee
for a Clean Environment (July 28, 1988). Concerning the application review
process to take place on August 29, 1988.
16. Letter from Mazy H. Grealish, EPA Region I to Carolie MAJ. Lamer, Concerned
Citizens for Hope (August 11, 1988). Concerning confidentiality of the Technical
Assistance Grant applications during the review process.
17. Letter from Mary H. Grealish, EP A Region I to Brian Powers, Hope's Committee
for a Clean Environment (August 11, 1988). Concerning confidentiality of the
Technieal Assistance Grant applications during the review process.
18. Letter from Carolie MAJ. Lamer, Concerned Citizens for Hope to Mary H.
Grealish, EPA Region I (August 19, 1988). Concerning request for second
extension of application deadline. .
19. Letter from Mary H. Grealish, EP A Region I to Carolie MAJ. Lamer, Concerned
Citizens for Hope (August 26, 1988). Concerning response to the
August 19, 1988 Letter from Carolie MAJ. Lamer, Concerned Citizens for Hope.
20. Letter from Carotie MAJ. Lamer, Concerned Citizens for Hope to Mary H.
GreaIish, EPA Region I (September 2, 1988). Concerning a notice that the origir
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13.7 Technical Assistance Grants (cont'd.)
21. "Concerned Citizens," The Camden-Herald - Camden, ME (September IS, 1988).
22. "EPA Assistance Agreement/Amendment Part I - Assistance Notification
Information" Form, EPA Region I (March 19, 1990).
23. "Environmental News - Hope Citizens Group Receives Superfund Technical
Assistance Grant," EPA Region 1 (March 22,1990).
24. "BFA Awards Grant to Hope Committee:' Bangor Daily News - Bangor, ME
(March 26, 1990). .
25. "Hope Receives Grant for Union Chemical Advisor," The Camden Herald -
Camden, ME (March 29,1990).
26. Letter from Mary H. Grealish, EP A Region 1 to Brian Power'S, Hope's Committee
for a Oean Environment (June 1, 1990). Concerning Hope's Committee for a .
Oean Environment's procurement of a technical advisor, the draft technical advisor
sub-agreement, and the incorporation requirements of the State of Maine.
27. "Technical Advisor Subagreement," Hope's Committee for.a Oean Environment
and Disposal Safety Incorporated (June 25, 1990).
13.9 Work Plans and Progress Reports
1. Letter from Laurie M. Ziegenfus, Booz-Allen & Hamilton Inc. to Michael
Jasins~ EPA Region 1 (April 8, 1988) with attached messages. Concerning
monthly log of telephone calls received on hotline for February and March 1988.
2. Letter from Laurie M. Ziegenfus, Booz-Allen & Hamilton Inc. to Michael
Jasinski, EPA Region 1 (May 13, 1988) with attached messages. Concerning
monthly log of telephone calls received on hotline for April 1988.
3. Letter from Elizabeth Feinberg, Booz-Allen & Hamilton Inc. to Michael
Jasinski, EPA Region 1 (June 29,1988) with attached messages. Concerning
monthly log of telephone calls received on hotline for May and June 1988.
4. Letter from Elizabeth Feinberg, Booz-Allen & Hamilton Inc. to Michael
Jasinski, EPA Region 1 (September 13, 1988) with attaChed messages.
Concerning monthly log of telephone calls received on hotline for July and
August 1988.
S. Letter from Elizabeth Feinberg, Booz-Allen & Hamilton Inc. to Michael
Jasinski, EP A Region 1 (December 2, 1988) with attached messages.
Concerning monthly log of telephone calls received on hotline for September and
October 1988.
6. Letter from Kymberlee F. Estis, Booz-Al1en & Hamilton Inc. to Michael
Jasinski, EPA Region 1 (January S, 1989) with attached messages. Concerning
monthly log of telephone calls received on hotline for December 1988.
7. Letter from Kymberlee F. Estis, Booz-Al1en & Hamilton Inc. to Michael
Jasinski, EP A Region 1 (February 7, 1989) with attached messages.
Concerning monthly log of telephone calls received on botline for January 1989.
8. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Karen Stone,
CDM Federal ProgramS Corporation (March 6, 1989) with attacbed messages.
Concerning monthly log of telephone calls received on bot1iDe for
February 1989.
9. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Karen Stone,
CDM Federal ProgramS Corporation (April 3, 1989) with attached messages.
Concerning monthly log of telephone calls received on hotline for March 1989.
10. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Karen Stone,
CDM Federal Programs Corporation (May 9,1989) with attached messages.
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13.9 Work Plans and Progress Reports (cont'd.)
11. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Karen Stone,
Camp Dresser & McKee Inc. (June 12, 1989) with attached messages.
Concerning monthly log of telephone calls received on hotline for May 1989.
12. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Karen Stone,
CDM Federal Programs Corporation (August 3, 1989) with attached messages.
Concerning monthly log of telephone calls received on hotline for July 1989.
13. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to Karen Stone,
CDM Federal Programs Corporation (September 6, 1989) with attached
messages. Concerning monthly Jog of telephone calls received on hotline for
August 1989.
14. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to John Walker,
CDM Federal Programs Corporation (October 2, 1989) with attached messages.
Concerning monthly log of telephone calls received on hotline for
September 1989. .
15. Leuer from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to John Walker,
CDM Federal Programs Corporation (November 6, 1989) with attached
messages. Concerning monthly log of telephone calls received on hotline for
October 1989.
16. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to John Walker,
CDM Federal Programs Corporation (December 7, 1989) with attached
messages. Concerning monthly log of telephone calls received on hotline for
November 1989.
17. Letter from KymberleeF. Estis, Booz-Allen & Hamilton Inc. to John Walker,
CDM Federal Programs Corporation (January 2,1990) with attached messages.
Concerning monthly log of telephone calls received on hotline for
Decembel'1989.
18. Letter from Kymberlee F. Estis, Booz-Allen & Hamilton Inc. to John Walker,
CDM Federal Programs Corporation (March 8, 1990) with attached messages.
Concerning monthly log of telephone calls received on hotline for
February 1990.
14.0 Congressional Relations
- 14.1 Correspondence
1.
Letter from Olympia J. Snowe, Member of the U.S. House of Representatives to
Berny E. Warren, State of Maine Department of Environmental Protection
(June 26, 1981) with attached letter from Darlene Wellman. Concerning pollution
problem and Quiggle Brook testing.
Letter from Herny E. Warren, State of Maine Department of EnvironmentaJ
Protection to Olympia 1. Snowe, Member of the U.S. House of Representatives
(August', 1981). Concerning an ongoing monitoring program and
hydrogeological study.
Letter from George J. Mitchell, Member of the U.S. Senate to Lee M Thomas.
EP A Headquarters (October 28, 1985). Concerning request for information
regarding EP A's involvement at the site. .
Letter from Michael R. Deland, EPA Region I to George J. Mitchell, Member of the
U.S. Senate (November 26, 1985). Concerning request for infonnation.
Letter from George 1. Mitchell, Member of the U.S. Senate to Michael R. De I and.
EP A Region I (Apri128, 1987). Concerning request for a member of EP A
Region I staff to be present at the May 9,1987 town meeting.
2.
3.
4.
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14.1 Correspondence (cont'd.)
6. Letter from William S. Cohen, Member of the U.S. Senate to Betsy Horne, EP A
Region I (May 5, 1987). Concerning tranSmittal of the attached correspondence.
7. Letter from George J. Mitchell, Member of the U.S. Senate to Lee M. Thomas,
EP A Headquarters (May 12, 1987). Concerning inclusion of site on the National
Priorities List and continuance of the Technical Assistance Grant process.
8. Letter from George J. Mitchell, Member of the U.S. Senate to James O. Mason,
U.S. Department of Health and Human Services Agency for Toxic Substances and
Disease Registry (ATSDR) (May 12, 1987). Concerning a hcalth assessment to be
completed by the 1988 deadline.
9. Letter from Michael R Deland, EPA Region I to William S. Cohen, Member of the
U.S. Senate (May 27, 1987). Concerning acknowledgement of comments from the
Town of Hope citizens regarding their concern about public hcalth threats from the
site. .
10. Letter from Michael R Deland, EPA Region I to George J. Mitchell, Member of the
U.S. Senate (May 27, 1987). Concerning summary of responses to issues raised
at the May 9, 1987 town meeting.
11. Letter from Joseph E. Brennan, Member of the U.S. House of Representatives to
Lee M. Thomas, EPA Headquarters (August 12, 1987) with attached news
clippings. Concerning listing of site on the National Priorities list
12. Letter from William S. Cohen and George J. Mitchell, Members of the U.S. Senate
to Lee M. Thomas, EPA Headquarters (September 16, 1987). Concerning listing
of site on the National Priorities list
13. Letter from Lee M. Thomas, EPA Headquaners to George J. Mitchell, Member of
the U.S. Senate (November 6, 1987) with the attaChed September 27, 1985
"Chemical, Physical, and Biological Properties of Compounds Present at
Hazardous Waste Sites," Oement Associates, Inc. Concerning listing of site on the
National Priorities list, using RCRA regulations, and defining acceptable levels of
trichloroethylene.
14. Letter from George J. Mitchell, Member of the U.S. Senate to Lee M. Thomas,
EPA Headquarters (January 22, 1988). Concerning the listing of site on the
National Priorities List
15. Letter from George J. Mitchell, Member of the U.S. Senate to Lee M. Thomas.
EPA Headquarters (June 21,1988). Concerning listing of site on the National
Priorities List
16. Letter from J. Winston Porter, EPA Headquarters to George J. Mitchell, Member
of the U.S. Senate (August 5, 1988). Concerning a response to the June 21, 1988
Letter from George J. Mitchell. .
17. Letter from WalterR Dowdle, U.S. DepartmentofHcalth and Human Services
Agency for Toxic Substances and Disease Registry (A TSDR) to George J.
Mitchell, Member of the U.S. Senate (August 21, 1989). Concerning evaluation.
presence of contaminants in wells, potential hcalth concern, and need for a morulity
study. .
15.0 Freedom of Information Act (F01A) Management
15.2 Requests
1.
Letter from Benjamin Ross, Disposal Safety Incorporated for Hope's Commi ttU
for a Clean Environment to Evelyn Sullivan, EPA Region I (July 9, 1990).
Concerning request for copies of comments provided by EP A to the PRPs on
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15.3 Responses
Letter from Merrill S. Hohman, EPA Region I to Benjamin Ross, Disposal Safety
Incorporated for Hope's Committee for a Clean Environment (August 16, 1990).
Con=ning denial of FOIA request.
Letter from Benjamin Ross, Disposal Safety Incorporated for Hope's Committee
for a Clean Environment to Freedom of Information Act OffICer, EP A
Headquarters (September 7, 1990). Concerning appeal of denial of FOIA request.
16.0 Natura1 ~ Trustee
1.
2.
16.1 Cold~Spondence
1.
Letter from Gordon E. Beckett, U.S. Department of the Interior FlSh and Wildlife
Service to Randall Maud, BFA Region I (July 21,1987). Concerning the receipt of
EPA's "Trustee Notification Fonn."
16.4 Trustee Notification Fonn and Selection Guide
1.
Letter from Patricia L Meaney forMenill S. Hohman, EPA Region I to William
Patterson, U.S. Department of the Interior Fish and Wildlife Service with the
at1ached '7J1Jstee Notffic.WOll Form."
Letter from Patricia 1. Meaney for Merrill. S. Hohman, EP A Region I to Sharon
Christopherson, U.S. Department ofCommercc National Oceanic and Atmospheric
Administration with the attached "Trustee Notification Fonn."
2.
17.0 Site Management Records
17.1 ~spondence
1.
Letter from Clifford R Goodall, Lund Wille Scott &. Goodall (Attorney for Union
. Chemical Co. Inc.) to EPA Regional Loan Coordinator, EPA Region I
(April 8, 1980). Concerning the attached April 2, 1980 "Application forEPA
CertifICation Statement for SBA Loans," Union Chemical Co., Inc.
Letter from Jeffrey L McNelly, Camden and Rockland Water Company to John A.
Krueger, State of Maine Department of Environmental Protection
(December 19, 1980). Concerning available hazardous waste files on the water
quality in the Camden-Rockland area.
Letter from George Kaplan, State of Maine Department of Environmental Protection
to 1effrey L McNelly, Camden and Rockland Water Company
(December 23, 1980). Concerning response to December 19, 1980 Letter from
Jeffrey 1. McNelly, Camden and Rockland Water Company.
Letter from Jeffrey L McNelly, o.mcten and Rockland Water Company to Edward
M Logue, State of Maine Department of Environmental Protection
(July 31, 1981). Concerning drinking water supplies and the July 30, 1981
"Hydrogeologic Evaluation and Development of Cean Up Plan for Area of
Contaminated Soil," Wright-Pierce for Union Chemical Co., Inc.
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Henry D. Aho,
State of Maine Department of Environmental Protection (June 14, 1985).
Concerning effect of withdrawal of water from Fish Pond on the flow of Quigg le
Brook.
2.
3.
4.
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17.1 Correspondence (cont'd.)
6. Letter Report from Lake Environmental Services of Maine for Hobbs Pond
Association to John James, State of Maine De~nt of Environmental Protection
(September 13, 1985). Concerning review of the Camden and Rockland Water
Company Great Ponds Act permit application.
7. Letter Report from Wallace W. Hinckley, State of Maine Department of Human
Services (October 4, 1985). Concerning the withdrawal of water from Fish Pond.
8. Letter from Roberta N. Staples, Save Fish-Hobbs Pond Committee to John James,
State of Maine Department of Environmental ProteCtion (October II, 1985).
Concc:ming the attaChed petition.
9. Telephone Notes BetWeen Tony Leavitt, State of Maine Department of
Environmental Protection and Brad Caswell (February 24, 1986). Concerning
unused production well.
10. Memorandum from Tony Leavitt, State of Maine Department of Environmental
Protection to File (February 28, 1986). Concerning February 26
through 27 p 1986 water sampling trip.
11. Memorandum from Tony Leavitt, State of Maine Department of Environmental
Protection to File (April 9. 1986). Concerning new monitoring well locations.
12. "Regional Water Study - Mid Coast Maine," Whitman & Howard. Inc. for
Mid-Coast Maine Water Study Commission (December 1986).
13. "Camden and Rockland Water Company - Priority Pollutant Analysis and Dioxin
Scan for Fish Pond and Grassy Pond," Whitman & Howard. Inc. for Camden and
Rockland Watr.rCompany (September 1987).
14. Letter from Michael Jasinski, EPA Region I to Kenneth A. Jacobson Jr., Camden
and Rockland Water Company (January 13, 1988). Concerning transmittal of
summary resultS for volatile organic compounds detected in residential wells. .
15. Letter from Michael Jasinski. EPA Region I to Jeffrey L. McNelly, Camden and
Rockland Water Company (September 12, 1988). Concerning transmittal of
surface-water and sediment samples and ground water elevation measurements.
16. Letter from Kenneth A. Jacobson Jr., Camden and Rockland Water Company to
Customer (November 14, 1988). Concerning use of Hobbs and Fish Ponds for
additional water supply with the attaChed:
A. "Camden and Rockland Water Company Information Sheet Hobbs & Fish
Ponds" (November 1988).
B. Map of Hobbs and Fish Ponds and Surrounding Area (July 13, 1988).
17. Letter from Dana Paul Murch, State of Maine Departtnent of Environmental
Protection to Stephen Bost, Member of State of Maine Senate and Herbert Clark,
Member of State of Maine House of Representatives (May 12, 1989). Concerning
the moratorium on withdrawal of watr.r from Hobbs and Fish Ponds.
17.2 Access Records
2.
Letter from Rebecca L. Hewett, State of Maine Department of Environmental
Protection to John E. Dority. State of Maine Department (May 27. 1988).
Concerning the installation of monitoring wells in the Department of Transportation
right of way on Route 17. .
Letter from John A. Blanchard. Township of Hope to Randall Smith, Nashua
Corporation (June 17, 1988). Concerning access to property owned by the Hope
V olunt.eer Fire Departmenl
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17.2 Access Records (cont'd.)
3. .
Cross-Reference: Letter from Mark 1. Leibrock, Canonie Environmental Services
Corp. for the Union Chemical Site Trust to Mr. and Mrs. lohn lensen
(September 2, 1988) with the attached fcmn IetU2'S sent to the following residents:
A. Dr. and Mrs. Kenneth Guiseley.
B. Ms. Arlene Crabtree.
C. . Mr. and Mrs. Elmer Hart.
D. Mr. and Mrs. Harold Cushman.
E. Mr. and Mrs. Dana Winchenbach.
F. Mr. and Mrs. Robert Shaw.
G. Mr. and Mrs. Donald Pushaw.
R Mr. and Mrs. Hemy Hastings.
1 Mr. Charles Lawson.
1. Mr. Scott Bissett.
K. Mr. and Mrs. Brian Powers.
L Mr. and Mrs. Gordon Talbot.
M Mr. and Mrs. Charles Martz.
N. Mr. and Mrs. William Bryant.
O. Ms. Hope Chase.
P. Mr. and Mrs. Harold Menifield.
Q. Ms. Sandra MacAvoy.
R. Mr. and Mrs. Steven Bowman.
S. Mr. and Mls. Lewis Merrifield.
T. Mr. and Mrs. J~ Patins
U. Mr. Dennis Hall.
V. Mr. and Mrs. Albert Hastings.
W. Mr. and Mrs. Neil Fogg.
X. Mr. George BUIT.
Y. Mr. Bruce Melanson.
Z. Mr. and Mrs. Dinsmore.
AA. Mr. and Mrs. Stanley.
Concerning the third quart='ly residential well sampling round to be penormed on
September 16, 1988 [Filed and cited as entry number 12 in 3.1 COITespondence].
Letter from David Wright, State of Maine Department of Environmental Protection
to lames F. Green, Union Chemical Site Trust Fund (October 25, 1989) with
attachment. Concerning restoration of ~ at the Gus lohnson Estate accessed by
Canonie Environmental SeMces Corporation.
4.
17.4 Site PbotographslMaps
1. Photographs and Maps, Concerned CitizJens of Hope (September 22, 1987).
The oversized records cited in entries numbered 2 through 13 may be reviewed by
appointment only, at EP A Region /, Boston, Massachusetts
2.
3.
10" X 10" Black and White Aerial Photograph Showing the Union Chemical Co.,
Inc. Site, EPIC Roll 711030, Frame 262 (May 11,1971).
10" X 10" Black and White Aerial Photograph Showing the Union Chemical Co.,
Inc. Site, EPIC Photo #19078 (May 18, 1972). .
10" X 10" Black and White Aerial Photograph Showing the Union Chemical Co.,
Inc. Site, EPIC Frame 18804 (May 8, 1973).
10" X 10" Black and White Aerial Photograph Showing the Union Chemical Co.,
Inc. Site, EPIC Frame 8926 (April 17, 1977).
10" X 10" Black and White Aerial Photograph Showing the Union Chemical Co.,
Inc. Site, EPIC Roll 9060, Frame 52 (May 4, 1980). .
4.
s.
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17.4 Site PhotographslMaps (cont'd.)
7. 10" X 10" Color Aerial Photograph Showing the Union Chemical Co., Inc. Site,
EPIC Roll 84/121, Frame 212 (September 18,1984).
8. "Site Analysis," The Bionetics Corporation (May 1988).
9. "Union Chem.lCanonie - 87-072 - Inspection of Wells B6 through B14 - MDEP"
Video Tape (May 21,1988).
10. "Union Chemical- EPA Book I" Photo Album, CDM Federal Programs
Corporation (September 29,1988).
11. "Union Chemical - EP A Book 2" Photo Album, CDM Federal Programs
Corporation (September 29, 1988).
12. "ODW Video Tape Log" Video Tape (August 30, 1989).
13. "Well NPW & Well OPW Video Survey" Video Tape (September 28, 1989).
17.5 Site DescriptionslChronologies
"A Brief Historical and Economic History of Union Chemical Co., Inc.," Union
Chemical Co., Inc. (August 13, 1979).
Cross-Reference: "Union Chemical Site Fact Sheet," EP A Region I
(July 20, 1984). Concerning Union Chemical Co., Inc. activities from 1967 to
1984{Fi1cd and cited as entry number 2 in 13.5 Fact Sheets].
Cross-Reference: "Unicm Chemical Site Chronological Fact Sheet,"
(February 18, 1987) [Filed and cited as pages 10 to 14 of entry number 1 in
2.5 On-Scene Coordinator's Reports].
Cross-Reference: "Union Chemical Company Site Fact Sheet," State of Maine
Department of Environmental Protection (May 1987) [Filed and cited as Appendix
A of entty number 2 in 3.6 Remedial Investigation (RI) Reports).
17.7 Reference Documents
1.
2.
3.
4.
U.S. Environmental Protection Agency. Office of Communications And Public
Affairs. Glossa~ Of Environmental Tenns And Acronym List (19K-lOO2),
December 1989.
17.8 State and Local Technical Records
1.
1.
Memorandum from Gerald Bates, State of Maine Department of Environmental
Protection to Steve Groves, State of Maine Department of Environmental ProteCtion
(July 2,1981). Concerning the public water supply.
Memorandum from John A. Kroeger, State of Maine Department of Environmental
Protection to File (July 7, 1981). Concerning air quality complaint at South Hope.
Memorandum from John A. Kroeger, State of Maine Department of Environmental
Protection to File (September 9, 1981). Concerning air quality comp1aint from
Carotie MAJ. Lamer.
Memorandum from John A. Kroeger, State of Maine Department of Environmental
Protection to File (September 15,1981). Concerning air quality complaint from
Frances Tibbetts.
Memorandum from John A. Kroeger, State of Maine Department of Environmental
Protection to File (September 23, 1981). Concerning air quality at the site.
Memorandum from Nonnan Anderson, State of Maine Department of
Environmental Protection to David A. Dumas, State of Maine Department of
Environmental Protection (April 13, 1982). Concerning toxicity assessment of air
emissions.
"Ambient Air Monitoring Program," John Fancy Inc. Technical Services
(October 20, 1982).
2.
3.
4.
s.
6.
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Page 54
17.8 State and Local Technical Records (cont'd.)
8. Letter from Edward M Logue, State of Maine Department of Environmental
Protection to Raymond G. Esposito, Union Chemical Co., Inc.
(March 31, 1983). Concerning attached results of water samples.
9. Letter from Clifford H Goodall, Dyer, Goodall and Zeegers (Attorney for Union
Chemical Co.,Ine.) to David A. Dumas, State of Maine Department of
Environmental Protection (March 15, 1984). Concerning air emission license and
level of lead emission.
10. Sample Results (November 29, 1984).
11. Letter from Raymond G. Esposito, Union Chemical Co., Inc. to lames Lysen,
State of Maine Department of Environmental Protection (May 31,1985).
Concerning proposal for handling the ground water problem.
12. Letter from Henry D. Abo, State of Maine Department of Environmental Protection
to Raymond G. Esposito, Union Chemical Co., Inc..(Iune 3,1985). Concerning
the attached water sample results. .
13. Letter from lames Lysen, State of Maine Department of Environmental Protection
to Raymond G. Esposito, Union Chemical Co., Inc. (June 5, 1985). Concerning
transmittal of unsolicited proposal.
14. Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Henry D. Aho,
State of Maine Department of Environmental Protection (June 10, 1985).
Concerning State of Maine Department of Environmental Protection's decision
regarding Union Chemical Co., Inc.'s proposal.
15. Letter from Henry D. Abo, State of Maine Department of Environmental Protection
to Paul L. Gibbons, Calderwood, Ingraham, & Gibbons
(June 11,1985). Concerning transmittal of attached analytical data.
16. Letter from lames K. Richard, Acheron, Inc. to Rebecca Hewett, State of Maine
Department of Environmental Protection (December 8, 1986). Concerning
transmittal of the attached results of the bail well tests performed in the summer of
1986.
17. Letter from Cynthia M Kuhns, State of Maine Department of Environmental
Protection to Bill Knowlton, Knowlton Well Drilling (March 10, 1988).
Concerning request for information on wells drilled in the vicinity of the Union
Chemical Co., Inc. property.
18. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Hatch Well Drillers (March 10, 1988). Concerning request for
information on wells drilled in the vicinity of the Union Chemical Co., Inc.
property .
19. Letter from Cynthia M Kuhns, State of Maine Department of Environmental
Protection to Leonard and Wilfred Cross, Earl A. Cross and Sons
(March 10, 1988). Concerning request for information on wells drilled in the
vicinity of the Union Chemical Co., Inc. property.
20. Letter from Cynthia M Kuhns, State of Maine Department of Environmental
Protection to'J.M. Reilly and Sons, Inc. (March 10, 1988). Concerning request for
information on wells drilled in the vicinity of the Union Chemical Co., Inc.
property. Cyn f Main De f.
21. Letter from thia M Kuhns, State 0 e partment 0 EnVlI'onmental
Protection to Brackett and Sons, Inc. (March 10, 1988). Concerning request for
information on wells drilled in the vicinity of the Union Chemical Co., Inc.
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19.0 Resource Conservation and Recovery Act (RCRA) Records
19.1 Conespondence
1.
Letter from David W. Tordoff, EP A Region I to Raymond G. Esposito, Union
Chemical Co., Inc. (January 22, 1980). Concerning potential for a hazardous
substance spill and the proposed rules for spill prevention.
"Site Visit Report," The MITRE Corporation (January 29, 1982).
Letter from Dennis A. Huebner, EP A Region I to Raymond G. Esposito, Union
Chemical Co., Inc. (March 24,1983). Concerning comments on a Hazardous
Waste Permit Application from Union Chemical Co., Inc. .
Letter from Conrad O. Desrosiers, EPA Region I to John A. Krueger, State of
Maine Department of Environmental Protection (September 27, 1983). Concerning
tranSmittal of the attached summary of violations.
Letter from Menill S. Hohman, EP A Region I to John Brochu, State of Maine
Department of Environmental Protection (March 14, 1984). Concerning the
program for analysis and monitoring of potential contaminant sources.
Letter from Henry E. Warren, State of Maine Department of Environmental
ProteCtion to Raymond G. Esposito, Union Chemical Co., Inc. (May 25,1984).
Concerning cessation of operation of the incinerator.
Letter from William Walsh-Rogalski, EPA Region I to Clifford R GoocWl, Dyer,
Goodall & Zeegers (Attorney for Union Chemical Co., Inc.) (May 30,1984).
Concerning enforcement actions.
Letter from Raymond G. Esposito, Union Chemical Co., Inc. to Henry E. Warren,
State of Maine Department of Environmental ProteCtion
(May 31.1984). Concerning request to resume operation of incinerator.
Letter from Henry E. Warren. State of Maine Department of Environmental
ProteCtion to Clifford R Goodall. Dyer, Goodall and Zeegers (Attorney for Union
Chemical Co., Inc.) (June 6, 1984). Concerning clean-up proposal and pennission
to resume incinerator operation.
2.
3.
4.
s.
6.
7.
8.
9.
19.2 Notification Fonn - Part A
"Hazardous Waste Pennit Application" Form. Union Chemical Co., Inc.
(June 6, 1983).
Letter from Perry Cogburn, State of Maine Department of Environmental Pro~tion
to Raymond G. Esposito, Union Chemical Co., Inc. (February 14, 1984).
Concerning tranSmittal of the attaChed Part A Application.
19.3 Notification Form - Part B
1.
2.
Cross-Reference: RCRA Part B Application, Union Chemical Co., Inc. [Filed and
cited as an attachment to cotty number 1 in 19.5 RCRA Enforcement Action
Records].
19.4 RCRA Facility Inspection Reports
1.
1.
2.
3.
Memorandum from Catherine McNair, EP A Region I to Robert O'Meara. EP A
Region I (June 2.1982). Concerning the January 13, 1982 inspection report.
"RCRA Inspection Checklist" Fonn, EPA Region I (February 2.1983).
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Page 56
19.5 RCRA Enforcement Action Records
1.
Complaint, In RE: Union Chemical Co.,Ine. Proceeding under Section 3008 01
the Resource Conservation and Recovery Act, 42 U .s.C. 56928, RCRA Docket
No. 83-1045 (November 1,1983) with attached RCRA Part B Application.
Answer to Complaint, In RE: Umon Chemical Co.,Ine. Proceeding under Section
3008 olthe Resource Conservation and Recovery Act, 42 U.s.C. 56928, RCRA
Docket No. 83-1045 (December 7, 1983).
Consent Agreement and Order, In RE: Umon Chemical Co., Ine., Procuding
under Section 3008 01 the Resource Conservation and Recovery Act, 42 U .s.C.
56928, RCRA Docket No. 83-1045 (September 6, 1984).
2.
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Section n
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GUIDANCE DOCUMENTS
EP A guidance documents may be reviewed at EP A Region I, Boston, Massachusetts.
Genera' and Site.SnecUk.EPA Guidance Documents
1.
"Protection of Wetlands (Execudve Order 11990), Appendix D:' Federal Re~ster (Vol. 42),
1977. .
2.
u.s. Environmental Protection Agency. Guidance Manual for Minimizin~ PoI1ution from
Waste Disposal Sites (EPAl600/2.781142), August 1978.
U.S. Environmental Protecdon Agency. Municipal Environmental Research Laboratory.
Carbon AdsOt:ption Isotherms for Toxic Oreanics (EPAl600/8.80/023), April 1, 1980.
3.
4.
u.s. Environmental Protecdon Agency. Municipal Environmental Research Laboratory.
Costs of Remedial Re!iponse Actions at Uncontro11ed Hazardous Waste Sites, April 15, 1981.
U.S. Environmental Protection Agency. Office of Ground- Water Protection. Ground -Water
ProtectiOT\ Str3teey (EP Al440J6-84/oo2), August 1984.
5.
6.
u.S. Environmental Protection Agency. Office of Research and Development and Office of
Emergency and Remedial Response. Review of In-Place Treatment TechniQJJes for
Contaminated Surface Soils - Vo1ume 1: Technica1 Eva1u~ii~~ (EPA/54012-84/oo3a),
September 1984.
"Nadonal Oil and Hazardous Substances Pollution Contingency Plan," Code of Federal
Reeu1ations (Title 40, Part 300), 1985.
7.
8.
Record of Decision, McKin, Gray, Maine, EPA Region 1, Boston, Massachusetts,
July 22, 1985.
Memorandum from William N. Hedeman, Director, U.S. Environmental Protection Agency
Office of Emergency and Remedia1 Response to Toxic and Waste Management Division
Directors, Regions I-X (OSWER Directive 9280.0-02), August 1, 1985 (discussing policy on
flood plains and wetland assessments for CERCLA Actions).
9.
10. Memorandum from Gene Lucero, U.S. Environmental Protection Agency Office of Waste
Programs Enforcement to Addressees CODirector, Waste Management Division, Regions I, IV,
V, vn, and VID; Directo~, Emergency and Remedial Response Division, Region n; Director,
Hazardous Waste Management Division, Region ill; 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 Supetfund Enforcement sites).
11. Clement Associates, Inc. Chemical. Physica1 and Biolo~ica1 Properties of Compounds Present
W .. (OSWERDirective 9850.3), September 27, 1985.
12. "National Primary Drinking Water Regulations; Volatile Synthetic Organic Chemicals; Final
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_.~.._--
Page 58
13. Memorandum from 1. Winston Porter, U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Addressees ("Regional Administrators, Regions I-X;
Directors, Environmental Services Division, Regions I-X; Regional Counsels, Regions I-X,
Director, Waste Management Division, Regions I, IV, V, vn, and vm; Director, Emergency'
and Remedial Response Division, Region n; Director, Hazardous Waste Management
Division, Region ill; Director, Air and Waste Management Division, Regions n and VI;
Director, Toxics and Waste Management Division, Region IX; Director, Hazardous and Waste
Division, Region XU) (OSWER Directive 9850.0-1), November 22, 1985 (discussing
endangerment assessment guidance). .
14. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Glossary (WHIFS-86-007), Winter 1986.
15. Memorandum from Barry L. Johnson, Associate Administrator, ATSDR to U.S.
Environmental Protection Agency Regional Superfund Programs, June 16, 1986, (discussing
A TSDR health assessments on NPL sites).
16. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Mobite Treatment Technolo~es for Superfund Wastes (EPA 540/2-861003 (f»,
September 1986.
17. Record of Decision, Kellogg-Deering Well Field, Norwalk, COMectiCUt, EPA Region I,
Boston, Massachusetts, September 25, 1986.
. .18. U.S. Environmental Protection Agency. Superfund Public Health Evaluation Manual
(OSWER 9285.4-1), October 1986.
19. U.S. Environmental Protection Agency. Comprehensive Environmental Response.
Compensation. and UabilitY Act of 1980. as Amended October 17, 1986.
20. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
~~:rin~~~ ~~~~:~~ ~~ifc~;:iI~~:~~~a;g:~.phys~lChemiCal Methods.
. 21. "Hazardous Waste Management Systems; Land Disposal Restrictions; Final Rule,"
Federal Reiister (VoL 51, No. 216), November 7, 1986.
22. U.S. Environmental Protection Agency. Office of Ground-Water Protection. Guidelines for
Ground-Water Classification under the EPA Ground-Water Pro~tion Strate~.
December 1986.
23. Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Regional Administrators, Regions I-X; Regional Counsels.
Regions I-X; Director, Waste Management Division, Regions I, IV, V, vn, and vm; Director,
Emergency and Remedial Response Division, Region ll; Director, Hazardous Waste
Management Division, Regions ill and VI; Director, Toxics and Waste Management Division,
Region IX; Director, Hazardous and Waste Division, Region X; Environmental Services
Division Directors, Regions I, VI, and vn (OSWER Directive 9355.0-19),
December 24, 1986 (discussing interim guidance on Superfund selection of lemedy).
24. Memorandum from L. M. Thomas, U.S. Environmental Protection Agency to Assistant
Administrators, Associate Administrators, Regional Administrators, and General Counsel,
January 7, 1987 (discussing interim policy for assessing risks of "dioxins" other than
2,3,7,8-TCDD) with attached: U.S. Environmental ProteCtion Agency. Risk Assessment
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Page 59
25. CDM Federal Programs Corp. Data qualitY Obiectives for Remedial Response Activities:
DevelQptT1C11t Process (OSWER Directive 9355.0-7B), March 1987.
26. CDM Federal Programs Corp. Data QualitY Objectives for Remedial Response Activities:
Example Scenario: RIIFS Activities at a Site with Contaminated Soils and Groundwater
(OSWER Directive 9355.0-7B), March 1987.
27. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance for Coorclinatine A TSDR Health Assessment Activities with the Superfund Remedial
Process (OSWERDirective 9285.4-02), March 11, 1987.
28. U.S. Environmental Protection Agency. Office of Water Regulations and Standards. Quali~
Criteria for Water 1986 (EPA/440/S-861OO1), May 1, 1987. .
29. Memorandum from J. Winston Porter, Assistant Administrator, U.S. Environmental
Protection Agency to Regional Administrators, Regions I-X (OSWER Directive 9285.4-02),
May 14, 1987 (discussing final guidance for the coordination of ATSDR health assessment
activities with the Superfund 1'Cmtnia1 process).
30. "National Primary Drinking Wm:r Regulations - Synthetic Organic Chemicals; Monitoring for
Unregulated Contam;nSlnts; Final Rule," Federal Re~ster (V ol52 No. 130), July 8, 1987.
31. Memorandum from J. Winston Porter, 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, IV, V, VII,
and VIII; Director, Emergency and Remedial Response Division, Region D; Director,
Hazardous Waste Management Division, Regions m and VI; Director, Toxies 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).
32. U.S; Environmental Protection Agency. Office of Solid Waste and Emergency Response:.
Additional Interim Guidance for Fiscal Year 1987 Record of Decisions (OSWER Directive
9355.0-21), July 24, 1987.
33. Memorandum from Henry L Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response and Gene Lucero, U.S. Environmental Protection Agency
Office of Waste Programs Enforcement to Waste Management Division Directors, Regions I-X
and Environmental Services Division Directors, Regions I, VI, and W, August 11, 1987.
(discussing land disposal restrictions).
34. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. fJJ.blK
Involvement in the Superfund Propm (WH/FS-87-004R), Fall 1987.
35. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund (WH/FS-87-OO1R), Fall 1987.
36. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. ~
Superfund Remedial Pro&J'3.m (WHIFS-87-OO2R), Fall 1987.
37. U.S. Environmental Protection Agency. Center for Environmental Research Infonnation.
A Compendium ofTechnolo~es Used in the Treatment ofH~7.arrlOUS Waste
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Page 60
38. Record of Decision, Davis Liquid Waste, Smithfield, Rhode Island, EPA Region I, Boston,
Massachusetts, September 29,1987. .
39. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Office of Emergency and Remedial Response. Interim Final Guidance on Removal Action
Levels at Contamina~ Drinkine Water Sites (OSWER Directive 9360.1-01), October 6,1987.
40. Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Regional Administrators, Region I-X (OSWER Directive
9834.11), November 13,1987 (discussing revised procedures for implementing off-site .
response actions) with attached "Revised Procedures for Implementing Off-Site Response
Actions."
41. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
A Compendium of Superfund Field OJ)Crations Methods (OSWER Directive 9355.0-14),
December 1987.
42. Record of Decision, Keefe, Epping, New Hampshire, EPA Region I, Boston, Massachusetts,
March 21, 1988.
43. Record of Decision, Cannons Engineering Corporation, Bric1gewater, Massachusetts,
EPA Region I, Boston, Massachusetts, March 21,1988. .
44. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
(EPA/5401l-88/001, OSWER Directive 9285.5-1),
Ap~ 1988. .
45. Memorandum from Timothy Fields Jr., U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Superfund Branch Chiefs, Regions I-X and OHM
Coordinators, Regions I-X, April 19, 1988 (discussing information on drinking water action
levels ).
46. U.S. Environmental PrOtection Agency. Office of Water. Interim Sediment Criteria Va1ues for
Nonpolar J.{ydTQphobic Orianic Contaminants (SCD #17), May 1988.
47. Memorandum fann J. Winston Porter, U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Regional Administrators, Regions I-X; Regional Counsel,
Regions I-X; Director, Waste Management Division, Regions I, IV, V, VII, and VIll; Director.
Emergency and Remedial Response Division, Region 11; Director, Hazardous Waste
Management Division, Regions m and VI; Director, Toxics and Waste Management Division.
Region IX; and Director, Hazardous and Waste Division, Region X (OSWER Directive
9835.1a), May 16, 1988 (discussing interim guidance of potentially responsible party
participation in .remedial investigations and feasibility studies).
48. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
CERCLA (Comprehensive Environmental Response. Compensation. and Liabi1i~ Act)
CompHance with Other Laws Manual (EPN540/G-891OO6, OSWER Directive 9234.1-01),
August 1988.
49. "Drinking Water Regulations; Maximum Contaminant Level Goals and National Primary
Drinking Water Regulations for Lead and Copper, Proposed Rule," Federal Re~ster
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Page 61
so. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Technolo~ Screenin~ Guide for Treatment of CERCLA lCornprehensive Environmental
Response. Compensation. and Liability Act) Sons and Slud~es (EPA 540/2-88/004).
September 1988.
51. Record of Decision. Groveland Wells, GroveIand., Massachusetts, £FA Region I, Boston.
Massachusetts, September 30, 1988.
52. U.S. Environmental Protection Agency. Office of EmC'gency and Remedial Response.
Guidan~ for Conductin~ Remedial Investi~ations and FeasibiHty Studies Under CERCLA
(Comprehensive Environmental Response. Compensation. and LiabiHty Act) lInterim Fi~~l)
(EPA/5401G-89/004, OSWER Directive 9355.3-01). October 1988.
53. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites
(EP A/540/G-88IOO.3, OSWER Directive 9283.1-2), December 1988.
54. U.S. Enviromnemal Protection Agency. Office of E1vrgency and Remedial Response.
Guidan~ on Remedial Actions for Contaminated Ground Water at Superfund Sites
(EP A/540/G-88/(03), December 1988.
55. Memorandum from Don. R. Clay, Assistant Administrator, U.S. Environmental Protection
Agency Office of Solid Waste and Emergency Response to Waste Management Division
Directors, Regions I-X and Regional Counsel. Regions I-X (OSWER Directive 9234.1-06).
December 27, 1988 (discussing applicability of land disposal restrictions to RCRA and
CERa.A ground water treatment reinjection; Superfund management review: recommendation
No. 26).
56. Memorandum from Bruce M. Diamond, U.S. Environmental Protection Agency Office of
Waste Programs Enforcement et aI. to Addressees ("Directors. Waste Management Division,
Regions I, IV, vn, VllI; Director, Emergency and Remedial Response Division, Region n;
Directors, Hazardous Waste Management Division, Regions ill, VI; Director, Toxic and Waste
Management Division, Region IX; Director, Hazardous Waste Division, Region X"),
February 9,1989 (discussing interim ~ guidance on soil ingestion rates).
57. Interagency Cooperative Publication. Federal Manual for Identifyin~ and De1ineatin~
Jurisdictional Wetlands. January 1989.
. .
58. Solarchem Environmental Systems. R~ox -1hc.Mvanced Water DecontamjJWjon System.
February IS, 1989.
59. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
A Guide on Remedial Actions for Contaminated Ground Water (OSWER Directive
9283.1-2FS), April 1989.
60. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Technoto~
Evaluation R~:port: SITE PrQ~ Demonstration Test Terra Vac In Situ Vacuum E~tt;~ri~~
System Groveland. Massachusetts. Volume I (EPA/54OI5-89/003a), April 1989.
61. Memorandum from Jonathan Z Cannon to Regional Administrators, Regions I-X (OSWER
Directive 9347.1-02), April 17, 1989 (discussing policy for Superfund compliance with the
RCRA land disposal restrictions).
62. U.S Environmental Protection Agency. Office of Health and Environmental Assessment
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Page 62
63. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
ARARs O's & A's (OERR 9234.2-01FS), May 1989.
64. "National Primary and Secondary Drinking Water Regulations; Proposed Rule,"
Federal Reeister (VoL 54 No. 97), May 22, 1989.
65. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Land Disposal Restrictions: Summary of ReqJlirements. June 1989.
66. U.S. Environmental Protection Agency. Risk Assessment Work Group, Region L
Suwlemental Risk Assessment Guidance for the Superfund Provam (Draft Finan
(EPA/901/5-89/00l), June 1989.
67. Memorandum from Henry L. Longest TI, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response and Bruce M. Diamond, U.S. Environmental Protection
Agency Office of Waste Programs Enforcement to Addressees ('Director, Waste Management
Division, Regions I, IV, V, vn, and vm; Director, Emergency and Remedial Response
Division, Region ll; Director, Hazardous Waste Management Division, Regions ill, VI, and
X; Director, Hazardous Waste Division, Region X"), June 4, 1990 (discussing Superfund
Responsiveness Summaries).
68. Memorandum from Henry L. LDngest n, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors, Waste Management Division, Regions I, IV,
Y, VII, vm et al. (OSWER Directive 9347.2-01), June S, 1989 (discussing land disposal
restrictions as relevant and appropriate).
69. Memorandum from Henry L.LDngest n and Gerald Emison, EPA Headquarters to Addressees
('Regional Waste Management Division DirectorS; Regional Superfund Branch Chiefs;
Regional Air Division Directors; Regional Air Branch Chiefs; OERR Division Directors;
OAQPS Division Directors") (OSWER Directive 9355.0-28), June 15, 1989 (discussing
control of air emissions from air strippers).
70. U.S. Environmental Protection Agency. Office of Emcrgency and Remedial Response.
Interim Final Guidance on Preparine Superfund Decision Documents (OSWER Directive
9355.3-02), July 1989.
71. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
:;uperfund LDR Guide #1. Overview of RCRA Land Disposal Restrictions llDRs) (OSWER
Directive 9347.3-01FS), July 1989.
72. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #2. Comp~ With the California List Restrictions Under Land
Disposal Restrictions llDRs) (OSWER Directive 9347.3-02FS), July 1989.
73. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
t=~~~~~~~e/.~J:~~e~J:~~~ ~::~~~3~~~:~e8~s
74. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #4. Complyine With the Hammer Restrictions Under Land Disposal
Restrictions rLDRs) (OSWER Directive: 9347.3-04FS), July 1989.
75. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
SQperfund LDR Guide #5. Determinin~ When Land Disposal Restrictions (LDRs) Are
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Page 63
76. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #6A. Obtainine a Soil and Debris Treatabili~ Variance for Remedial
Actions. (OSWER Directive: 9347.3-06FS). July 1989.
77. "Protection of Environment," Code of Federal Reeulations Title 40, Parts 190-299, Revised as
of July 1,1989.
78. Memorandum from Louis F. Gitto, U.S. Environmental Protection Agency Air, Pesticides,
and Toxic Management Division to Mcnill S. Hohman, Waste Management Division Director,
July 13, 1989 (discussing the attached OSWER Directive 9355.0-28, Air Stripper Control
Guidance).
79. "National Primary and Secondary Drinking Water Regulations; Synthetic Organic Chemicals
and Inorganic Chemicals; Proposed Rule," Federal Re~ster (Vol. 55, No. 43), July 25, 1990.
80. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA (Comprehensive Environmental Response. Compensation. and J...iabi1i~ Act)
Compliance with Other Laws MarlU41- Part n: Clean Air Act and Other Environmental Statutes
and State Requirements (EP A/540/G-89/009, OSWER Directive 9234.1-02), August 1989.
81. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
St~t~ and Local Involvement in the Superfund Pro~ (9375.s-01IFS), Fall 1989.
82. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Evaluation of Ground Water Extraction Remedies. Volume 1. Sum~ Rt:,port
(EPA/540/2-89/054), September 1989.
83. Record of Dccision, Wells G & H, Wobum, Massachusetts, EPA Region I, Boston,
Massachusetts, September 14, 1989.
84. Record of Dccision, So. Municipal, Petersborough, New Hampshire, EPA Region I, Boston,
Massachusetts, September 27,1989.
85. Record of Dccision, Kellogg-Deering Well Field, Norwalk, Connecticut, EPA Region I,
Boston, Massachusetts, September 29,1989.
86. U.S. Environmental Protection Agency. Off'1ce of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - RCRA ARARs: Focus and Closure
~eqJ1irements (OSWER Directive 9234.2-(4), October 1989.
87. U.S. Environmental Protection Agency. OfflCC of Solid Waste and Emergency Response.
Determinine Soil Response Actim1.Levet Based on Potential Contaminant ~on to Ground
Water. A Compendium of Examples (EPA/S4012-89/057), October 1989.
88. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Ground Water Issue - Performance Evaluation of Pump-and-Trcat RemedWigm
(EPA/540/4-891OO5), October 1989.
89. Memorandum from Hcmy L.l.ongest IT, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response and Bruce M Diamond, U.S. Environmental Protection
Agency Office of Waste Programs Enforcement to Addressees C'Director, Waste Management
Division, Regions I, IV, V, vn, and vm; Director, Emergency and Remedial Response
Division, Region IT; Director, Hazardous Waste Management Division, Regions ill, VL and
X; Director, Hazardous Waste Division, Region X; Regional Counsels, Region I - X"),
October 10, 1990 (discussing suggested ROD language for various groundwater remediabon
-------
Page 64
90. Memorandum from Jonathan Z. Cannon. EP A Headquarters to Regional Directors
(October 18. 1989). Concerning considerations in ground waterrcmediation at Superfund
sites.
91. ,U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Superfund Innovative TechnoloeY Evaluation Pmwam: Technolo~ Profiles
(EPA/540/5-89/013). November 1989.
92. "Risk Assessment Forum Report on Toxicity Equivalency Factors for Chlorinated
Dibenzo-p-Dioxins and Dibenzofurans." federal Relister (VoL 54. No. 214).
November 7, 1989.
93. U.S. Environmental Protection Agency. OSWER Directive Initiation Request. Analysis of
Treatability Data for Soil and Debris: Evaluation of Land Ban I1T\Pact on Use of Superfund
Treatment TechnolOlies (OSWER Directive 9380.3-04), November 30, 1989.
94. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. 1llik
10ssessment Guidance for Superfund - Volume I: Human Health Evaluation Manual
-------
Page 65
104. "A Field Evaluation of the UV IOxidation Technology to Treat Contaminated Groundwater,"
HMC, MarchlAprilI990.
105. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - Summary of Part n - CM. TSCA. and
Other Statutes (OSWER Directive 9234.2-07/FS), April 1990.
106. "Control Technology: A Field Demonstration of the UV !Oxidation Technology to Treat
Groundwater Contaminated with VOCs," Journal of the Air & Waste Manaiement Association
(Vol. 40, No.4), April 1990, pp. 540-47.
'-'.
107. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
ARAR's Q's & A's - Compliance with the Toxixi~ Characteristics Rule: eanJ.
(OSWER Directive 9234.2-08/FS), May 1990.
108. Groundwater Technology, Inc., Feasibili~ Study Analysis. Union Chemica1. South HQpe.
Maine, May 8, 1990.
109. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
ARAR's Q's & A's - Compliance with Federal WaterQuali~ Criteria (OSWERDirective
9234.2-09/FS), June 1990.
110. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
ARAR's O's & A's - State Ground-Water Antide~dation Issues (OSWER Directive
9234.2-11/FS), July 1990.
111. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with the RCRA Toxici~ Characteristics ITC) Rule: Part n
(OSWERDirective 9347.3-11IFS), October 1990.
112. U.S. Environmental Protection Agency. Impact of the RCRA Land Di~al Restrictions of
Superfund Response Actions in Superfund. .
113. U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory.
Awlication of Low-Temperature Thermal Techn010ey to CERCLA (Comprehensive
Environmental Response. Compensation. and Liabili~ Act) Soils.
114. U.S. Department of Health and Human Services. Agency for Toxic Substances and Disease
-------
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UNION cmMICAL CO., INC.
soum H>PE, MAINE
mORD OF DtcrSION
TABLES
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-------
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TABLE;' "
SUMMARY OF SOIL SAMPUNG RESULTS
UNION CHEMICAL SITE
lowest Highest - Geometric Range of Detection
Concentration Concentration Location of Mean Umlts for ND Samples
Frequency Detected Detected Highest Concentration (ppm)
Chemical of Detection (ppm) (ppm) Concentration (ppm) . Highest Lowest
1.1.1-mICHLOROETHANE 145 / 420 0.020 490 N210E210 0.052 25 0.0050
1.1,2,2-TETRACHLOROETHANE 1 / 420 2.7 2.7 N24OE360 0022 \. 50 0.0050
1.1-DlCHLOROETHANE 48 I 420 0.020 1.3 N240E45O 0.02"', 50 0.0050
1.1-DICHLOROETHYLENE 30 / 420 0.020 4.1 N12OE12O 0.027 50 0.0050
mlCHLOROETHYLENE 110 I 419 0.020 46 N24Q~ 0.041 50 0.0050
..:~
1,2-DICHLOROETHANE 2 / 420 0.041 O.~ N270e\oo 0.022 50 0.0050
1.2-DICHLOROETHYLENE-CIS 37 I 355 0.020 3i' N260E140 0.018 25 0.020
1.4-DICHLOROBENZENE 1 / 418 0.56 £:,~ N180E480 0.020 25 0.0200
0.., "
2-BUTANONE 2 I 198 ~Q;'" 12 N215E15O 0.483 1000 0.025
2-METHYLNAPHTALENE 2 / 72 a~. 1.6 N210E360 0.190 1.65 0.33
\,*11
ACETONE 1): 0.21 15 N215E150 0.100 50 0.0050
ANTIMONY 10 10 N180E180 2.818 8.0 5.0
ARSENIC 80/98 5.0 55 MW-4(S) 7.712 5.0 0.10
BENZO(A)ANTHRACENE 2 / 72 0.38 O.A1 POWERS 0.187 1.85 0.33
BENZO(A)PYRENE 2 / 72 0.58 0.61 HASTINGS 0.189 1.65 0.33
BENZO(B)FLUORANTHENE 3 / 72 0.78 0.83 N3OOE60 0.193 1.65 0.33
BENZO(G.H,I)PERYLENE 2 I 72 0.50 0.54 POWERS 0.188 1.65 0.33
BENZO(~FLUORANTHENE 2 I 72 0.42 0.51 HASTINGS 0.187 1.65 0.33
Page {of 3
CanonleEnvircru ~ ~-rlal
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a_._----'- .. - --
,/
I" ""
"J
TABLE \
SUMMARY OF SOIL SAMPUNG RESULTS
UNION CHEMICAL SITE
Continued
Lowest Highest - Geometric Range of Detection
Concentration Concentration location of Mean Umits for NO Samples
Frequency Detected Detected Highest Concentration (ppm)
Chemlcel of Detection (ppm) (pprn) Concentration (ppm) Highest lowest
BIS(2-ETHYLHEXYl)PHTHALATE 11 I 72 0.39 6.6 N210E210 0247 1.65 0.33
BUTYL BENZVL PHTHALATE 1 I 72 0.59 0.59 CSB1 O.,~~ 1.65 0.33
CADMIUM 1 I 98 2.0 2.0 N150E120 1.0 0.10
0.484
CHLOROBENZENE 2 I 418 4.0 12 CS~ 0.022 50 0.0200
CHROMIUM 96198 10 105 N150~ 25.182 0.10 0.10
CHRYSENE 2 I 72 0.71 0.72~ POweb 0.190 1.65 0.33
DI-N-BUTYLPHTHALATE 2 I 72 0.37 1.\~ CSB1 0.190 1.65 0.33
>.
~
COPPER 96196 o~ 131 MW-4(S) 25.280
CYANIDE 7 I 49 18 N235E250 0.752 1.0 1.0
ETHYlBENZENE ~25 626 N210E210 0.108 20 0.0050
FLUORANTHENE I 2 0.40 1.7 POWERS 0.202 1.65 0.33
FREON 113 8.~ 137 0.025 92 N125E225 0.025 25 0.025
INDENQ-(1.2,3-CD)-PYRENE 2 I 72 0.43 0.45 POWERS 0.187 1.65 0.33
lSOPHORONE 10 I 72 0.44 16 N21 0E21 0 0.247 1.65 0.33
LEAD 94198 5.2 219 POWERS 15.633 5.0 0.10
METHYLENE CHlORIDE 48 I 420 0.020 5.7 N240E450 0.027 50 0.0050
NAPHTHALENE 2 I 72 0.87 1.1 N210E210 0.191 1.65 0.33
Page 2 of 3
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o
~
TABLE 1
SUMMARY OF SOIL SAMPUNG RESULTS
UNION CHEMICAL SITE
Continued.
Lowest Highest .. Geometric Range of Detection
Concentration Concentration location of Mean Umlls for ND Samples
Frequency Detected Detected Highest Concentration (ppm)
Chemical of Detection (ppm) (ppm) Concentration (ppm) Highest Lowest
PCB-1232 1 I 18 0.16 0.16 N215E295 0.049 0.8 0.080
PHENANTHRENE 2 I 72 0.72 1.1 POWERS 0.191~ 1.65 0.33
NICKEL 94/96 7.29 65 N150E330 19.8~\.. 5.0 5.0
PYRENE 3 I 72 0.85 1.2 POWERS 0.195 1.65 0.33
SELENIUM 1 1 98 2.0 2.0 N120EOOO 0.<484 1.0 0.10
c~j:
TETRACHLORO~NE 100 1 <419 0.020 600 0.041 50 0.0050
TOLUENE 169 1 <424 ..::.' N195E150 0.183 20 0.0050
0.027 3t~
mANS-1,2-DICHLOROETHENE 1 1 <419 0.034 &)4'. N200E230 0.021 50 0.0050
0.. ..
mlCHLOROFLUOROMETHANE 1.. I <419 .Q:02O 12 N18OE<450 0.023 50 0.0050
.{ ..
XYLENE 110 I <425 o::~ 3600 N21 0E21 0 0.173 25 0.0050
.;.~
ZINC 1)96 21 452 MW"'(S) 65.130
Pa~.of 3
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c
f'
TABLE a
SUMMARY OF GROUND WATER SAMPUNG RESULTS
UNION CHEMICAl SITE
Lowest Highest . Geometric Range of Detection
Concentration Concentrallon location of Mean Umlts for NO Samples
Frequency Detected Detected Highest Concentfatlon (ppm)
Chemical of Detection (ppm) (ppm) Concentration (ppm) Highest lowest
1,1,1-mICHlOROETHANE 45 , 137 0.0005 73 B-6B(f) 0.0065 0.50 0.0005
1,1,2-mICHLOROETHANE 2 , 137 0.061 0.080 8-8B(I) 0.0027 5.0 0.0005
1,1-0ICHlOROETHANE 79 , 137 0.0005 12 8-9A(D) O.QSe3 5.0 0.0005
cr~ '
1,1-0ICHlOROETHYlENE 49 / 137 0.0007 2.7 8-9A(D) 5.0 0.0005 I
mlCHLOROETHYlENE 61 / 137 0.0005 84 8-9B(1) 0.01b:J 0.050 0.0005 . I
~ i
I
1,2-DICHlOROETHANE 5 / 137 0.0006 0.080 ~A(S) 0.0027 5.0 0.0005 I
1,2-DICHLOROETHYlENE-CIS 32 / 91 0.0005 19 M#1- 15(0) 0.0076 5.0 0.0005 I
1,3-DICHlOROBENZENE 2/ 125 0.0059 ~75 MW-15(D) . 0.0027 5 0.0005 I
2-BUTANONE 10 / 69 0.0205 j: ~8 B-12C(S) 0.0531 20 0.0005
2-METHYlNAPHTALENE 1 / 48 ~».027 0.027 B-12B(1) 0.0051 0.010 0.0050
""\'
.~ .
J\t
ARSENIC ~9 , 118 0.0060 0.025 8-1 B(S) 0.0077 0.010 0.0050
BIS(2-ETHYlHEXYl)PHTHALATE 2 / 48 0.19 0.59 8-13C(S) 0.0059 0.010 0.0050
CARBON TETRACHLORIDE . 2 / 137 0.021 0.025 8-5B(S) 0.0027 5.0 0.0005
CHlOROBENZENE 1 / 123 0.0090 0.009 MW-15(D) 0.0028 5 0.0005
CHLOROETHANE 5 / 137 0.0007 0.037 8-2B(S) 0.0036 5.0 0.0005
CHlOROFORM 18 , 137 0.0012 0.77 8-12C(S) 0.0033 5.0 0.0005
CHROMIUM 5 , 118 0.0070 0.037 MW-13A(O) 0.0049 0.050 0.0050
COPPER 9 I 165 0.0070 0.26 B-14C(S) 0.0249 0.050 0.0050
CY ANIOE 4 I 1 04 0.012 0.028 B-13B(I) 0.0052 0.010 0.010
[THYlRENZ£NE 22 I 137 00010 2.7 B-3A(S) 0.0087 50 0.0005
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--
o
.~
TA8LE a
SUMMARY OF GROUND WATER SAMPUNG RESULTS
UNION CHEMICAL SITE
(Contfnu!Kl)
Lowest Highest Geometric Range of Detection
Concentration Concentration location of Mean Umlts for ND Samples
Frequency Detected Detected Highest Concentration (ppm)
Chemical of Detection (ppm) (ppm) Concentration (ppm) Highest lowest
CYANIDE 4 , 104 0.012 0.028 8-138(1) O.~ 0.010 0.010
ETHYLBENZENE 22 , 137 0.0010 2.7 8-3A(S) o.~ 50 0.0005
FREON 113 10 , 45 0.10 17 4(1) 0.0156 5.0 0.0005
.:,,""
ISOPHORONE 8 , 48 0.034 0.32 M~13A(D) 0.0083 0.010 0.010
LEAD 18 , 121 0.005 ~027 8-12A(D) 0.0030 0.005 0.0020
METHYlENE CHLORIDE 20 , 137 0.0006 ~ 8-68(1) 0.0036 5.0 0.0005
NICKEL 4 '118 1:9.055 0.07 8-98(1) 0.0248 0.050 0.010
~:\
.~. ...c
TETRACHLOROETHYlENE 4 , 137 .~b.Oo50 0.15 MW-14(S) 0.0027 5.0 0.0005
TOLUENE ~4 , 137 0.0006 4.4 MW-15(D) 0.0088 50 0.0005
TRANS-1,2-DICHLOROETHENE 2 , 98 1.7 8.5 MW-15(D) 0.0025 5.0 0.0005
TRICHLOROFLUOROMETHANE 2 , 136 0.0007 0.0014 RES weU.-2 0.0026 5.0 0.0005
VINYL CHLORIDE 1 , 137 0.0076 0.0076 8-88(1) 0.0038 5.0 0.0005
XYlENE 21 , 84 0.0038 80 8-68(1) 0.0356 50 0.0005
ZINC 26 , 165 0.022 0.27 NPW 0.0299 0.060 0.040
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o
_. .-
,-\
C.J
r
TABLE g
SUMMARY OF SURFACE WATER SAMPUNG RESULTS
UNION CHEMICAL SITE
Lowest Highest Geometric Range of Detection
Concentration Concentration location of Mean Umlts for NO Samples
Frequency Detected Detected Highest Concentration (ppm)
Chemtcal of Detection (ppm) (ppm) Concentration (ppm) Highest Lowest
1 ,1 ,i-TRICHlOROETHANE 3/ 23 0.0006 0.0270 WT-1W 0.0003 0.0005 0.0005
1,1-DICHlOROETHANE 3/ 23 0.0007 0.0160 WT-1W ~ 0.0005 0.0005
TRICHLOROETHYlENE 1/ 23 0.0007 0.0007 ~-1W 0.0003 0.0005 0.0005
1,2-DICHLOROETHYLENE-CIS 4/ 23 0.0007 0.0047 "t -1W 0.0003 0.0005 0.0005
ARSENIC 1/ 23 O.01oo ~: CPW 0.0052 0.0100 0.0100
FREON 113 3/ 11 0.0006 WT-1W 0.0004 0.0005 0.0005
lEAD 1/ 23 ~"\9.0110 0.0110 NWC 0.0027 0.0050 0.0050
METHYLENE CHlORIDE 2/ 23 ."" 0.0016 0.0021 CPW 0.0003 0.0005 0.0005
TETRACHLOROETHYlENE ~ 1/ 23 0.0011 0.0011 WT-1W 0.0003 0.0005 0.0005
ZINC 3/ 30 0.0210 0.0600 NWC 0.0255 0.0500 0.0200
CanonieEnvircnrrenta1
I
I
\
I
i
\
\
-------
-,
o
f'
TABLE ..,.
SUMMARY OF SEDIMENT SAMPUNG RESULTS
UNION CHEMICAL SITE
Lowest Hlgh8!!t Geometric Range of Detection
Concentration Concentration location of Mean Umlts for ND Samples
Frequency Detected Detected Highest Concentratfon (ppm)
Chemical . of Detection (ppm) (ppm) Concentnatlon (ppm) Highest Lowest
ANTIMONY 11 31 6.60 6.6 WT-3S 2.704 6.00 5.00
ARSENIC 121 32 5.00 33 NWC2 3.611 5.00 0.10
ANTHRACENE 11 19 0.49 0.49 OM SED O.a.- 0.90 0.33
BENZO(A)ANmHRACENE 21 19 1.30 1.4 OB-:J SED ~~ 0.90 0.33
; .1 {B)FlUORANTHENE 21 19 1.10 1.4 00-2 SED 0.90 0.33
BENZO~FlUORANTHENE 21 19 0.94 0.95 £ SED 0.269 0.90 0.33
",."
CADMIUM 11 32 1.40 P' NWOD 0.481 1.00 0.10
CHROMIUM 29 1 32 7.20 NWC SED 15.991 5.00' 0.10
CHRYSENE 31 19 ~41 1.6 OM SED 0.297 0.90 0.33
COPPER 23 1 31 .' .60 274 NWC2 10.847 5.00 5.00
)..
FlUORANTHENE -041 19 0.45 2.2 OB-3 SED 0.330 0.90 0.33
INDENO-(1,2,3-CD)-PYRENE 21 19 0.68 0.72 OB-3 SED 0.261 0.90 0.33
LEAD 31 1 32 6.30 156 OB-3 SED 17.302 0.10 0.10
PHENANTHRENE 31 19 0.45 2.1 OB-3 SED 0.300 0.90 0.33
NICKEL 26 1 31 6.70 54 NWC2 12.421 5.00 5.00
PYRENE 41 19 0.59 2.9 QB-2 SED 0.349 0.90 0.33
SELENIUM 31 32 1.00 1.2 WT-3S 0.502 1.00 0.10
ZINC 31 I 31 9.50 347 NWD02 42.322
CanonieErwirmn~~ntal
-------
.. ~. ---- -~
- -. -- -.- .-- ~
X-8
l TABLE 5
SUMMARY OF FACIUTY SAMPUNG RESULTS
UNION CHEMICAL SITE
0 &nged Geometric
Frequency Detected Mean
d ConcentratIonS Concentration
Chemical Residue Detection ~ (ppm)
Incinerator Equipment
2.3.7.8- TCDD 0/6 0.0000145
Other TCDD 2/6 0.00081 . 0.0017 0.000106
2.3.7.8-TCDF 5/6 0.000012.0.0028 0.000130
Other TCDF 4/6 0.00057.0.0129 ~ 0.000376
1.2.3.7.8-peCDD 2/6 0.00012.0.0016 0.000066
Other PeCDD 3/6 0.00019.0.0218 0.000420
1.2.3.7.8-PeCDF 5/6 ~.0.0159 0.000395
Other PeG:DF 5/6 0:;0016.0.0785 0.001260
XX2.3.7.a-HxCDD 3/6 0.0001 .0.0059 0.000136
o Other HxCDD 4/&.. 0.0011 ~.0188 0.000802
'. ..~
XX 2.3.7.8-HxCDF 5 I':>'::}» 0.0011-0.052 0.000950
Other HxCDF 5/i< 0.000024-0.0708 0.001700
1.2.3.4.6.7.8-HpCDD ..<\ 5/6 0.00034 . 0.0163 0.000572
Other HpCDD '\~~~. 5/6 0.00027.0.0148 0.000683
1.2.3,4.6.7.a-HpCDF 5/6 0.00013.0.0966 0.002030
Oth~DF 5/6 0.000035 . 0.123 0.002718
OC'. ) 4/6 0.00087-0.0259 0.001190
OCDF \>'>' 5/6 0.00075.Q.0782 0.003093
Antimony 2/4 21-44 8.72
Arsenic 1/4 a.3 3.37
Benzo(A) Anthracene 1/4 8.2 3.48
Benzo(B) F1uoranthene 1/4 8.1 3.47
Cadmium 3/4 4.9 - 40 5.73
QvonUn 4/4 13 - 810 210.66
~ 1/4 12 3.83
Copper 3/4 40 - 4850 109.65
Dimethyl phthalate 1/4 1100 6.67
Ethylbenzene 1/2 19 0.22
Fiouranthen8 1/4 10 3.66
Lead 3/4 155 -9200 199.35
Mercury 1/4 0.24 0.12
( Methylene chloride 1 /2 61 0.39
Nickel 3/4 64 - 712 90.58
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'-. ",- . --
---~. -
X-9
(
TABLE 5
SUMMARY OF FACIUTY SAMPUNG RESULTS
UNION CHEMICAL SITE
Range of Geometric
Frequency Detected Mean
of Concentrations Concentration
Chemical Residue Detection ~ (ppm)
Phenanthrene 1/4 8.1 3.58
Pyrene 1/4 16 4.12
Styrene 1/1 326 326.00
Zinc 4/4 9.5 -1010 152.29
StRl Bundlng Area ~
1,1,1-Trichloroethane 6/9 0.087 -19 0.88
Trlchloroethytene 3/9 ...4.034 - 33 0.13
.01<:.;
Acetone' 1/3 '~ 0.29 0.18
Antimony 4/5 $>'9.4 - 22 10.5
o ArsenIc 4 /.f!:... 10 -19 9.56
Bis (2-ethyt-hexyf) phthalate 2 / \:>:~ 160 - 1800 98.32
Butyl benzyt phthalate 1/1.< 25 5.14
Cadmium ~ 5/5 8-35 17.7
Chromium '('\< 5/5 219 -1170 557.7
Copper ..'*"..... 5/5 607 -1910 843
Cyanldt. 5/5 1.0 - 27 6.39
OimEit~~late 1/3 6.4 4.14
Ethytb8itane 3/9 0.062 - 38 0.51
lsophorone 1/3 14 5.37
Lead 5/5 1360 -4010 2365
Mercury 5/5 1.3 - 20 2.77
Nickel 5/5 137 -814 263
Selenium 2/5 1.2 -1.4 0.73
SUver 4/5 5.3 -13 6.47
T etrachloroethytene 6/9 0.031 - 920 0.54
Toluene 3/9 1.7 - 28 1.12
Trichloroftuoromethane 1/9 0.0089 0.08
Xytene 4/9 0.029 - 270 1.16
Zinc 5/5 890 - 5450 1923
(
Page 2 of 3
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~ ----
- ----"-..
c.
TABLE 5
SUMMARY OF FACIUTY SAMPUNG RESULTS
UNION CHEMICAL. SITE
<)
Range d
Detected
ConcentrationS
~
Chemical Residue
Frequency
d
Detection
Miscellaneous
1 .1 ..oichloroethane
1.1.1-Trichloroethane
Chromium
Cis-1.2..olchloroethylene
Copper
Lead
Nickel
T etrachloroethytene
Trichloroethylene
Zinc
0.012
0.0057
30
0.61
17
19
~ 17
': .0.0024
a::OOO5 .0.02
62
o
1 /3
1 /3
1 /1
1/3
1 /1
1 /1
1 /1
1/3
2/3
1/1~:.
\ff >,
~
>-:\:$:tPRACHLORODIBENZODIOXIN
\r.~~ACHLORODIBENZODIOXIN
ftEXACHLORODIBENZODIOXIN
HEPT ACHLORODIBENZODIOXIN
OCT ACHLORODIBENZODIOXIN
TETRACHLORODIBENZOFURAN
PENT ACHLORODIBENZOFURAN
HEXACHLORODIBENZOFURAN
HEPTACHLORODIBENZOFURAN
OCTACHLORODIBENZOFURAN
LEGEND:
TCDD
PeCDD
HxCDD
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X-25
(
TABLE b
CONTAMINANTS OF CONCERN
UNION CHEMICAL SITE
Chemical Constituent
Ground Water ~ Sediment Surface Water Incinerator
Facilities
Still Bulldina
Misc.
Volatile Organics
1,1-Dichloroethane X X X
1,2-Dlchloroethane X
1,1-Dlchloroethytene X X
Chloroform X
Methylene Chloride X <\.
T etrachloroethytene X X X X X
Trichloroethylene X X X X
Xylene X X X
, a ~~
Dioxins and Furans
0 2,3,7,8-TCOO ~(:.. X
~~:»-
.~
Inorganics
Arsenic X X X X X X
Lead ~~ X X X X X X
~..., -',
Nickel \.: ~" X X X X X
Zinc X X X X X X
PAH's -0
Benzo(a)anthracene X X X
Benzo(a)pyrene X
Benzo(b)ftuoranthene X X X
Benzo(g,h,Qperyiene X
Benzo(K)ftuoranthene X X
Chrysene X X X
Fluoranthene X X X
Indeno(1.2,3-cd)pyrene X X
Phenanthrene X X X
Pyrene X X X
Note:
a
Oioxlns and Furans are considered as a total 2,3,7,8-TCOO toxicity equivalent.
Page' of 1
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. -
X-3D
(
TABLE ?
EXPOSURE PATHWAY SUMMARY
ExDosure PathwaY
Current Site Conditions
future Site Develocment
Ground Water
Ingestion
Inhalation During Water Use
Dermal AbsOrPtion During Water Use
Sols WIthin Fence (See Note b)
InckSentaIlngestlon
Dermal Absorption
Inhalation
On-Slte Sols Outside d Fence (See Note b)
Incidental Ingestion .
Dermal Absorption
Inhalation
Off-Slte SoDs (See Note b)
Incidental Ingestion
Dermal Absorption
Inhalation
o
Surface Water
Inhalation
Dermal Absorption
Sediment
Ingestion
Dermal AbsorpttQ1\'t
~~
Plant FacDlties ~...
Incidental Ingestion
~ Adsorption
Notes:
~
X
a
a
X
a
a
x
x
x
x
a
x
x
~ a
)0
x
x
a
a
x
x
x
x
x
x
X
a~
JIi
a
x
x
x
x
x
. ExposYre pathway which is qualitatively evaluated In the baseline risk usessment
b For the risk assessment, three areas are considered separately for exposure to sons.
These areas are: 1) the portion d the site which is enclosed by the chain link fence. 2) the
portion d the UCC property which is outside d the fence, and 3) the off-site area. that is.
the area oft d the UCC property. The three areas are shcMn on Figure 48.
x Exposure pathway which is quantltatNely evaluated In the baseline risk assessment.
(
Page ,
-------
-
\
o
TABLE 6
SUMMARY OF EXPOSURE ASSUMPTIONS
f',
Exposure
Pathway
Exposure
Population
Exposure
Frequency
Exposure
Rate (a)
Exposure
Duration
Relative Absorption Factors(a)
Volatile Semlvolatlle
Organics Organics lnorganlcs
Ground Water (Current Site Conditions and Future Site Development)
Ingestion
7O-kg Adults
Dally
2 liters/day
70 years
100%
100%
100%
Facilities Residues (CUrrent Site Conditions)
Ingestion ~kg Children (Age 6 - 11) 20lyear 100 mg/day 5 years .~ 100% 1 00%(b)
70-kg Children (Age 12-18) 20lyear 100 mg/day 7 years 100% 100%(b) I
o I
Weighted Average(c) 53 kg 20lyear 100 mg/day <' 12 years 100% 100% 100%(b) I
Absorption ~kg Children (Age 6 - 11) 20lyear ~ mg/day t 5 years 50% 5% Negligible
70-kg Children (Age 12-18) 20lyear '. mg/day 7 years 50% 5% Negligible
:\:..
Weighted Average(c) 53 kg 20lyear 500 mglday 12 years 50% 5% Negligible
~~
...
o...Sft. Sol WIthin Fence (Current SII8 ~
Ingestion ~kg Chlldren,of e 6 - 11) 20lyear 100 mg/day 5yeaFS 100% 100% 100%(b)
7O-kg Chndren (Age 12-18) 20lyear 100 mg/day 7 years 100% 100% 100%(b)
Weighted Average(c) 53 kg 20lyear 100 mg/day 12 years 100% 100% 100%(b)
Absorption 3O-kg Children (Age 6 - 11) 20/year 500 mg/day 5 years 50% 5% Negligible
70-kg Children (Age 12-18) 2O/year 500 mg/day 7 years 50% 5% Negligible
Weighted Average(c) 53 kg 20/year 500 mg/day 12 years 50% 5% Negligible
><
I
tAl
.......
CanonieEnvircnrnt,~ Jtdl
-------
.-' 'V r
'\
TABLE 8
SUMMARY OF EXPOSURE ASSUMPTIONS
(Continued)
Reletlve Absorption Fectors(e)
Exposure Exposure Exposure Exposure exposure Voletile Semlvoletile
Pethway populetion Frequency Rate(e) Duration Organics Orgenlcs 'norganlcs
On-Slte SolI Outside of Fence (Current SIte ConditIonS)
Ingestion 3O-kg Children (Age 6 - 11) 40/year 100 mg/dey 5 yeart 100% 100% 100%(b)
7O-kg Adults (Age 11 - 70) 40/yeer 100 mg/dey 60 yes,. 100% 100% 100%(b)
Weighted Average(c) 67 kg 40/year 100 mgldey 65 yet,. 100% 100% 100%(b)
Absorption 3O-kg Children (Age 6 - 11) 40lyeer 500 mgldey 5 yeers 1: 5% Negllgfble
7o-kg Adults (Age 11 - 70) 40lyeer 500 mgldey 60 ~f8 5% Negligible
Weighted Average(c) 87 kg 40/year 500 mgldey 6Syears 5% Negligible
Off-Site Soli (Current Conditions) ~
Ingestion 16-kg Children (Ages 1 - 6) 100/ye8r ~::: 5 years 100% 100% 100%(b)
3O-kg Children (Age 8 - 11) 100lyear 5 years 100% 100% 100%(b)
7o-kg Adults (Age 11 - 70) t~: 100 mgldey 60 years 100% 100% 100%(b)
Weighted Average(c) 63 kg 107 mg/dey 70 years 100% 100% 100%(b)
9~'.
Absorption 16-kg Children Q 1 - 6) 100lyeer 500 mg/dey 5 years 50% 5% Negligible
3O-kg Children (~ 6 - 11) 100lyeer 500 rng/dey 5 yeers 50% 5% Negligible
7o-kg Adults (Age 11 - 70) 90lyear 1000 mgldey 60 years 50% 5" Negligible
Weighted Average(c) 63 kg 911year 929 mg/dey 70 years. 50% 5" Negllgtble
><
I
W
(X)
-------
.-. 0 r'.
\
TABLE 8
SUMMARY OF EXPOSURE ASSUMPTIONS
(Continued)
Relative Absorption Factors(a)
Exposure Exposure Exposure Exposure Exposure Volatile Semivolatile
Pathway Population Frequency Rate(a) Duration Organics Organics Inorganlcs
On-Slte Soli (Future Site De\oelopmem)
Ingestion is-kg Children (Ages 1 . 6) 100lyear 200 mg/day 5 years 100% 100% 1 00%(b)
. 3O-kg Children (Age 6 . 11) 100lyear 100 mg/day 5 years 100% 100% 100%(,b)
7O-kg Adults (Age 11 - 70) 90lyear 100 mg/day 60 years 100% 100% 100%(b)
Wefghted Average(c) 63 kg 91lyear 107 mg/day 70 years 100% 100% 100%(b)
Absorption is-kg Children (Ages 1 . 6) 100lyear 500 mg/day 5 years ~ 5" Negligible
<,,50%
3O-kg Children (Age 6 - 11) 100lyear 500 mg/day 5 years ~~ 5" Negligible
70-kg Adults (Age 11 - 70) 9O/year 1000 mg/d.y ~ 60years 50% 5" Negligible
Weighted Aversge(c) 63 kg 91/year 929 mg/day . 70 years 50% 5" Negligible
Surface Water (Current Site Conditions) ~
~
Absorption 3O-kg Children (Age 6 - 11) .(j~r ".368 cclday(d) 5 years 100% 100% 100%
~'.
7O-kg Mulls (~1 - 70) 7/year 4.368 cclday(d) 60 years 100% 100% 100%
Wefghted Average(c) 67k 7lyear 4.368 cclday(d) 65 years 100% 100% 100%
Sediment (Current Site Conditions)
Ingestion 3O-kg Children (Age 6 . 11) 7/year 100 rng/day 5 years 100% 100% 1 00%(b)
70-kg Adults (Age 11 - 70) 7lyear 100 mg/day 60 years 100% 100% 100%(b)
Weighted Aversge(c) 67 kg 7/year 100 mg/day 65 years 100% 100% 100%(b)
Absorption 3O-kg Children (Age 6 - 11) 7/year 500 mg/day 5 years 50% 5" Negligible
70-kg Adults (Age 11 - 70) 7/year 500 mg/day 60 years 50% 5" Negligible ><
I
Weighte~ I\verage(c) 67 kg 7/year ~ mg/day 65 years 50% 5" Negligible (.oJ
\D
-------
Exposure
Pathway
----- .
,
0..-
. TABLE 8
SUMMARY OF EXPOSURE ASSUMPT10NS
(Continued)
Exposure
Population
Exposure
Frequency
Exposure
Rale(a)
Exposure
Duration
Notes:
Values taken from U.S. EPA risk assessmenl guidance documents.
(a)
(b)
(c)
(d)
Relative absorPflon fador for lead Is 30 percent for adults and 50 percent for children ages 1 - 6.
Weighted average used only for estimation of carcinogenic risks.
Based on dermal permeability constant of 0.00084 cm/hOUr. 2.6 hours of exposure per
event. and 2,000 square centimeter skin area (hands. forearms. feel, end lower -<.'
legs of child or hands and feet of adult). For PCE. the exposure rate Is 988 cubic centi/\teters/day
~
besOd on 8 cIorm8I ponneabIIly constant of 0.19 cmJhour 1?>
~
\)
r
Relative Absorption Factors(a)
Volatile Semlvolatile
Organics Organics lnorganlcs
~
><
I
~
o
-------
----
'1
o
r-
TABLE q
SUMMARY OF RISK ESTIMATES BY MEDIUM AND
EXPOSURE ROUTE
CURRENT SITE CONDITIONS
UNION CHEMICAL SITE
Excess Cancer Risk
!XDosure ScenartR
Ingestion of Ground Water
Average
Case
Chemicals
Contributing
Most to Risk
1,I-DCE, 1,I-DCA
5E-06
Worst
~
2E-05
Ingestion of On-Site Soil Arsenic!
Within the Fence 3E-07 5E-07
Absorption of On-Site Soil PCE, 1,1~
Within the Fence 7E-I0 1E-07
Ingestion of On-Site Soil 5E-~
Outside the Fence lE-06 Arsenic
Absorptfon of On-Site Soil 7E~
Outside the Fence lE-06 PAHs 1,I-DCE
Ingestion of Off-Site Soils 2E-05 3E-05 Arsenic, PAHs
Absorption of Off-Site Soils 5E-06 7E-06 PAHs
Ingestion of Sediments 6E-07 3E-06 Arsenic
Absorption of Sediments IE -07 5E-07 PAHs
~
Hazard Index Chemica 15
Average Worst Contributing
Case ~ Most to Risk
1E-03 9E-03 Toluene,
~ 1,I-DCE,
1,I-DCA
t 2E-03 6E-03 Arsenic, Lead
3E-06 2E-03 PCE
6E-03 2E-02 Arsenic, Lead
4E-06 4E-04 1,I-OCE, PCE
0.1 0.3 Arsenic, lead
3E-06 5E-06 PAHs
5E-04 5E-03 Arsenic, Lead
4E-08 3[-07 PAHs
><
I
co
w
-------
- .-"-" -- ---
.-
o
('
TABLE q
SUMMARY OF RISK ESTIMATES BY MEDIUM AND
EXPOSURE ROUTE
CURRENT SITE CONDITIONS
UNION CHEMICAL SITE
(Continued)
Excess Cancer B!1k- -
Chemicals Hazard Index Chemicals
Average Worst Contributing Average Worst Contributing"
IXDosure Scena~~ Case ~ "ost to Risk Case till... "ost to I!ll.k
Absorption of Surface Water 3E-08 4E-08 Arsenic 9E-05 1£-04 PCE
Ingestion of Incinerator
Equipment Residues 4E-06 4E-05 2,3,7,8-TCOD ~ 9E-03 0.4 Lead
Absorption of Incinerator
Equipment Residues 9E-07 1£-05 2.3.7.8-~ lE -06 4E-06 PAHs
Ingestion of Still Building
Residues 3E-07 I£.~ Arsenic. PCE 0.1 . 0.2 Lead
Absorption of Still Building
Residues IE.'\) 2E-06 PCE 2E-05 4E-02 PCE
Ingestion of Miscellaneous
Facilities Residues 2E-ll 3E -11 1,I-DCA lE-03 tE-03 lead,
Nickel
Absorption of Miscellaneous
. Facilities Residues 6E-l1 6E-11 1, I-DCA, PCE 3E-07 2E-01 PCE
><
I
00
.J>o
-------
--.
o
TABLE 10
SUMMARY OF RISK ESTIMATES BY MEDIUM AND
EXPOSURE ROUTE
FUTURE SITE DEVELOPMENT
UNION CHEMICAL SITE
!xcess Cancer ~
Exposure Scenario
Ingestion of On-Site
Ground Water
Average
Case
Worst
~
IE-OI
6E-04
Chemicals
Contributing
Most to Risk
I.I-DCE. I.I-DCA. TCE
~
Hazard Index
Average Worst
Case ~
0.3
<\. 2&
Ingestion of On-Site Soil$ 2E-06 3E-05 Arsenic '\ 2E-02
Absorption of On-Site Soils 4E-07 6E-05 PCE, I. I-DeE 3E-05
~
~
\)
0.5
0.3
f'.
Chemicals
Contributing
Most to Risk
Methylene
Chloride.
I.I-DCE
Lead. PCE
PCE
CanonieEnvircnmel
><
I
00
-------
.~
"
...;
'.
TABLE II
INITIAL LIST OF REMEDIAL ALTERNATIVES
FOR THE UNION CHEMICAL SITE
(Continued)
IV. OfJ-Site Surface Soi~lternatiYes
1. Alternative OS-1: No Action;
2. Alternative OS-2: Limited Action.
~
~
~
\)
~.
-------
(
TABLE II
INITIAL LIST OF REMEDIAL ALTERNATIVES
FOR THE UNION CHEMICAL SITE
r
1. Alternative MM-1: No Action;
2. Alternative MM-2: Limited Action;
3. Alternative MM-3: Ground Water Extraction, On-Site Treatment, and
Discharge to Quiggle Brook;
4. Alternative MM-4: Vacuum-Enhanced Ground Water Extraction, On-
Site Treatment, and Discharge to Quiggle Brook; .
5. Alternative MM-5: Ground Water Extraction, On-Site Treatment, and
Reinjection; ~
6. Alternative MH-6: Vacuum-Enhanced Ground Water Extra\tion, On-
Site Treatment, and Reinjection
II. Source Cont~1-!Jternat,ves
1. Alternative SC-1: No Action;
2. Alternative SC-2:
3. Alternative SC-3:
4. Alternative~+.~:
5. Alternative ~~5:
6.~~1\ernative SC-6:
7. ~ernative SC-7:
Treatment.
III. ~ities Manacement Alternatives
o
'\
Limit~tion;
Site C~P1ng;
Soil Excavation and Off-Site Disposal;
Soil Excavation and low-Temperature Aeration;
In-Situ Soil Aeration;
Soil Excavation and High-Temperature Thermal
1. Alternative F-1: No Action;
2. Alternative F-2: Limited Action;
3. Alternative F-3: Facilities Decontamination Only;
4. Alternative F-4: Facilities Decontamination and Demolition;
5. Alternative F-5: Facilities Demolition and Off-Site Disposal
Without Decontamination.
(
. . - - -----.--
CanonteEnvirmmental
.-.------. ._~- ~--
-- - ..-. -
.. . - - --. .." -...-
-------
--- --- - .-- ------- --
.- ------ --
-' - -
TABLE 18\
COMPARISON OF REMEDIAL ALTERNATIVE COSTS
c.
~
J. Manaaement of Miaration
Altern at ives
Alternative MH-l: No Action'
Alternative MM-2: Limited Actiona
Alternative MM-3: Ground Water
Extraction, On-Site Treatment,
and Discharge to Quiggle Brook
Alternative MM-4: Vacuum-Enhanced
Ground Water Extraction, On-Site
Treatment, and Discharge to Quiggle
Brook (if SC-l, SC-2, or SC-3 is
implemented)
Alternative MM-4: , Vacuum-Enhanced
Ground Water Extraction, On-Site
Treatment, and Discharge to Quiggle
, Brook (if SC-5 or SC-6 is implemented)
~lternative MM-5: Ground Water
Extraction, On-Site Treatment,
and Reinjection ~
Alternative MM-6: Vacuum-Enhdctd
Ground Water Extraction, On-Site
Treatment, and Re;~ection (if
SC~I, SC-2, or !~)iS implemented)
Alternative'MM-6: Vacuum-Enhanced
Ground Water Extraction, On-Site
Treatment, and Reinjection (if
SC-S or SC-6 is implemented)
c
12 vrs
100 vrs
4,192,000
$890,000
$895,000
5,014,000
5,175,000 .
6,068,000 7,029,000 7,218,000
~
5,108,000 ~ 6,037,000 6,220,000
~ 5,689,000 5,862,000
4,806,000
6,593,000 7,615,000 7,810.000
5,633,000
6,623,000
6,818,000
-------
. .. - - -. - -- . --
l
TABLE la
COMPARISON OF REMEDIAL ALTERNATIVE COSTS
(Continued)
Case A Case A Case A Case B
10 ppm 1.0 pplD 0.1 ppm 0. 1 ppm
Oction Oction Oct ion Oction
II. Source Control Alternatives
Alternative SC-l: No Action 78,000 78,000 78,000
Alternative SC-2: Limited Action 101,000 101,000 J01,OOO
Alternative SC-3: Site Capping 404,000 602,000 °956,000
Alternative SC-5: Sol1 Excavation 1,579,000 2,210,000 3,059,000 3,553,000
and Low-Temperature Aeration
Alternative SC-6: In-Situ Soil 1,980,000 3,009,000 3,9~0
Aeration
Alternative SC-7: Sol1 Excavation 2,542,000- 4,108,000- 6,256,000- 7,531,000-
and High-Temperature Treatment 5,201,000 7,025;400 9,569,000 11 ,076,000
~ Present Worth
Of Alternati ve
~jtjes Manaaement Alt~rnltives ~
Alternative F-l: No Action
~
Alternative F-2: Limited Actf~~
Alternative F-3: Facilities
Decontami nat i on ~
A 1 ternat he F-4: ;f"ac nit i es
Decontamina&10n and Demolition
Case I
Case lIc
Alternative F-5: Facilities
Demolition and Off-Site
Disposal Without Decontamination
78,000
128,000
217,000
778,000
1,196,000
1,813,000
(~
-------
TABLE' a
COMPARISON OF REMEDIAL ALTERNATIVE COSTS
(Continued)
(
'~
}V. ~te Surface Soi1-!Jternatives
, '
Alternative OS-I: No Action
Alternative 05-2: Limited Action
(Without Additional 50il Sampling)
Alternative 05-2: Limited Action
(With Additional Soil Sampling)
o
1256,000
$282,000
~,
~
I
o
~
~
\>
aAssumes 30 years of operation and maintenance.
beost shown is an estimation which includes low-temperature aeration of concrete.
cCost shown is an estimation which includes disposa' of concrete in I RCRA landftll.
---
i
,
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Table 13
TABLE OF ARARS
UNION CHEMICAL SITE
REQUIREMENTS
REQUIREMENTS SYNOPSIS
RCRA -- Standards for Owners
and Operators of Permitted
Hazardous Waste Facilities, 40
CFR 264.10 - 264.18
This regulation sets out
general facility requirements
for waste analysis, security.
measures, inspection, training
and location. Requirements
apply to the storage,
treatment and disposal of
hazardous waste.
RCRA -- Preparedness and
Prevention, 40 CFR 264.30 -
264.37
This regulation outlines
safety requirements and spill
control requirements for
hazardous waste facilities.
Facilities must be designed
and operated to minimize the
possibility of a release of
hazardous waste. Facilities
must maintain specified
equipment and aisle space.
RCRA - Contingency Plan and
Emergency Procedures, 40 CFR
264.50 - 264.56
This regulation outlines the
requirements development of a
contingency plan and emergency
procedures to be used in
explosions or fires, and
requires that threats to
public health and the
environment be minimized. .
RCRA -- Manifest system,
Recordkeeping and Reporting,
40 CFR 264.70 - 264.77
This regulation details the
manifesting requirements for
an on-site facility that
stores, treats or disposes of
hazardous wastes.
RCRA -- Groundwater
Protection, 40 CFR 264.97 -
264.99
Under this regulation,
groundwater monitoring
requirements are outlined for
facilities that store, treat,
or dispose of hazardous waste.
RCRA -- Closure and Post-
Closure, 40 CFR 264.110 -
264.120
This regulation details the
specific requirements for
closure and Post-closure of
hazardous waste facilities.
-------
RCRA -- Waste piles, 40 CFR
264.250 - 264.269
RCRA -- containers, 40 CFR
264.170
RCRA -- Land Disposal
Restrictions, 40 CFR 268
Executive Order 11990,
protection of Wetlands, 40 CFR
Part 6, Appendix A
Executive Order 11988,
Floodplain Management, 40 CFR
Part 6, Appendix A
Clean Water Act, Permits for
Dredge or Fill Material, 40
CFR 230
Safe Drinking Water Act,
Maximum contaminant Levels, 40
This regulation establishes
procedures for operating
requirements, closure and
post-closure requirements for
waste piles. Excavated soils
held in waste piles prior to
treatment must comply with
this requirement.
Hazardous wastes held in
containers on site must comply
with the requirements of this
regulation.
These applicable regulations
outline land disposal
requirements and restrictions
for specified hazardous
wastes. contaminated soils
and facilities residues which
are derived from FOOl through
F005 wastes may not be
disposed of upon the land
unless treated to the
treatment levels specified in
40 CFR 268.41, or unless a
treatability variance is
obtained under 268.44.
To comply with this applicable
requirement, the remedy must
minimize the destruction, loss
or degradation of wetlands and.
enhance the beneficial value
of wetlands.
To comply with this applicable
requirement, the remedy must
reduce the risk of flood 10s5
and restore and preserve the
beneficial value of
floodplains.
Under this applicable
regulation, no activity that
adversely affects a wetland
shall be undertaken if a
practicable alternative that
has lesser effects is
available.
MCLs have been promulagated
for a number of organic and
-------
---- ,,---- -
- -- - ._-
CFR 141.11- 141.16
Clean Air Act, National
Primary and Secondary Air
Quality Standards, 40 CFR
50.6-50.7 .
Clean Air Act, NESHAP
standards, 40 CFR 61
Clean Air Act, Emissions
Standards for Equipment Leaks,
40 CFR 61. 240
Maine Waste Management Law, 38
MRSA i 1301 et seq., and Maine
Hazardous Waste Management
Rules, Chapter 800-802, 850,
851, 854, 856-857
Maine Solid Waste Management
Rules, Chapters 404, 405
inorganic contaminants. These
levels regulate the
concentrations of contaminants
in public drinking water
supplies, and are relevant and
appropriate since the
groundwater aquifer at the
Site is a drinking water
source.
This relevant and appropriate
regulation specifies maximum
primary and secondary 24-hour
concentrations for particulate
matter and ozone.
NESHAP standards for
demolition of buildings
containing asbestos are
applicable and will be
attained by the selected
remedy. The NESHAP standard
for emissions of vinyl
chloride from air strippers is
relevant and appropriate and
must be attained by the soil
treatment and vacuum-
extractions systems.
This relevant and appropriate
regulation specifies methods
to be taken to control leaks
of volatile hazardous air
pollutants from equipment.
These applicable regulations
incorporate RCRA hazardous
waste regulations, including
standards for hazardous waste
facilities and manifesting
requirements. These
regulations also provide
additional requirements,
including standards for
environmental, facilities
locations, and requirements
for waste piles and storage
facilities.
These applicable rules
regulate disposal of
construction/demolition
-------
Maine Natural Resources
Protection Act, 38 MRSA S 480-
A, and regulations thereunder
at Chapters 305, 310
Maine Air Pollution Control
Laws, 38 MRSA S 581-611, and
regulations at Chapters 100,
105, 109, 110, 114, 115, 116
Asbestos Abatement
Regulations, Chapter 136
Maine Water Pollution Control
Law, 38 MRSA S 411, et seq,
and regulations at Chapter
. 580, 584, 581.
Maine standards for
Classification of Fresh
Surface Waters, 38 MRSA S 468
Maine standards for
Classification of Groundwater,
38 MRSA S 470
debris, and disposal of
special waste.
This relevant and appropriate
statute and its regulations
prohibit the degration or
destruction of streams and
brooks by prohibiting
alteration in or adjacent to
protected natural areas
without a permit. At this
Site, removal of soil or
alteration of structures next
of streams must not cause
unreasonable soil erosion, and'
must meet other standards.
This applicable law and its
associated regulations detail
the requirements and
limitations of state air
emission regulations,
including Maine Ambient Air
Quality Standards, for
specific substances.
This applicable regulation
sets forth Maine's
requirements regarding
handling and disposal of
asbestos.
This applicable law regulates
the discharge of waste to
surface water bodies. Treated
groundwater discharged to
Quiggle Brook must achieve
federal ambient water quality
criteria for the beneficial
uses of the brook, or site
specific numerical criteria.
Quiggle Brook is classified as
a tributary to a Class GPA
water (and as Class B water)
under state water quality
standards.
The groundwater at the site is
classified as Class GW-A, of
such quality that it can be
used for domestic drinking
water.
-------
Maine Water Pollution Control
Law,. 38 MRSA S 420, 421
Maine site Location of
Development Law, 38 MRSA 481,
and Chapters 374 and 375
Maine Reduction of Toxics Use,
Waste and Release Law, 38 MRSA
S 2301 et seq.
standards and criteria to be
Considered
Proposed MCLs and MCLGs
Maine Rules Relating to
Testing of Private Water
Systems for Potentially
Hazardous Contaminants, 10-
144A CMR, Chapter 233
OSWER Directive 9355.0-28,
Control of Air Emissions from
Superfund Air Strippers at
Superfund Groundwater sites
Reference Concentrations
This law requires a 300-foot
zone between a solid waste
disposal area and a classified
body of surface water.
Portions of this statute and
its regulations are relevant
and appropriate, including the
no adverse effect of
development rules, noise
abatement rules, and traffic
restrictions.
This relevant and appropriate
law requires that facilities
must take examine, plan and
implement means of reducing
the amount of toxics used and
released.
Proposed Maximum Contaminant
Levels and proposed non-zero
Maxi~ Contaminant Level
Goals were considered in the
establishment of groundwater
cleanup goals.
These rules establish Maximum
Exposure Guidelines (MEGs)
based on federal standards,
health advisories and
toxicological information.
MEGs are used in determining
whether to waive fees for
testing for potentially
hazardous contaminants in
private wells.
This guidance relating to
control of air emissions from
strippers is relevant to the
design of emissions controls
for the vacuum extraction
system and the UV/oxidation
system.
Reference Concentrations
established by EPA and
published in EPA's Integrated
Risk Information System (IRIS)
-------
Maine Department of Human
Services Policy, "Derivation
of Interim Exposure Guidelines
for the Hazardous Air
pollutant program," dated
March 27, 1985
or BEAST are to be considered
in establishing appropriatae
levels of emissions of
hazardous substances into the
air from the components of the
remedial action.
This document sets out rough
guidelines for exposures to
hazardous air pollutants,
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