United S2ati!.s O
Environmental Protection Erne., |/py and
Agency Remeq^i Response
EPA/ROD/R01 -93/077
June 1993
SEPA Superfund
Record of Decision:
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!O272-101
,..-"
REPORTDOCUMENTAll0N 11. REPORT NO.
PAGE EPA/ROD/ROl-93/077
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Pinette's Salvage Yard (Amendment), ME
First Remedial Action - Final
7. Author(a)
2
3. Reclplant'a Accealon No.
S
Report Date
06/02/93
&
a.
Performing Organization Rept No.
8.
Performing Organization Name and Add-
10
Project TulclWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. SponlOl'lng Organization Name and Add....a
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
13. Type 0' Raport & Period Covar8d
800/800
14.
1S Supplamentary Nat..
PB94-96370S
16. Abstract (Umlt: 200 worda)
The 9.45-acre Pinette's Salvage Yard site is a vehicle repair and salvage yard located
approximately one mile southwest of the town of Washburn, Aroostook County, Maine.
Land use in the area is predominantly residential, general industrial, and
agricultural. Part of the site contains an undeveloped area with a forest and
wetlands. The water supply for residences located within a one-half mile radius of the
site is obtained from private wells located in the deep bedrock aquifer below the site.
Municipal wells, used to supply drinking water to residents in Washburn, are located
one mile northeast of the site. In June 1979, a private contractor removed three
electrical transformers from Loring Air Force Base and brought them to the site. The
transformers ruptured while being removed from the delivery vehicle, spilling 900 to
1,000 gallons of dielectric fluid containing PCBs onto the ground. In 1983, EPA
performed a removal action, which included excavation and offsite disposal of
PCB-contaminated soil from the site. Subsequent onsite investigations by EPA revealed
the presence of a wide range of PCB concentrations in the surface and subsurface soil.
A 1989 ROD addressed a final remedy for the contaminated soil and ground water at the
site; however, repeated issues with implementation and design on the solvent extraction
treatment system have caused EPA to reconsider certain components of the originally
(See Attached Page)
17. Document Analyels a. D8IIcriptora
Record of Decision - Pinette's Salvage Yard (Amendment), ME
First Remedial Action - Final
Contaminated Medium: soil
Key Contaminants: VOCs (benzene), other organics (PCBs)
b.
ldantlfiaralOpen-Ended Tarms
c.
COSATI FleldIGroup
18. Availability Statamant
18. Security Clue (Thl. Raport)
None
31. Security CIa.. (Thi. Page)
None
21. No. 0' Page.
34
22. Price
(Saa ANSI-Z39.18)
s..lnatructiona on Rev.,...
OPTIONAL FORM 272 (4-77)
(Formerly NTI8-35)
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EPA/ROD/ROl-93/077
Pinette's Salvage Yard (Amendment), ME
First Remedial Action - Final
Abstract (Continued)
selected remedy. This ROD amends the 1989 ROD and modifies the remedy for contaminated
soil remaining at the site as a final action. The primary contaminants of concern
affecting the soil are VOCs, including benzene; and other organics, including PCBs.
The amended remedial action for this site includes incinerating soil contaminated with
greater than 500 mg/kg PCBs offsite at a TSCA permitted facility, with offsite disposal of
soil containing greater than 50 mg/kg, but less than 500 mg/kg at a TSCA permitted
landfill; excavating and disposing of soil containing greater than 5 mg/kg of PCBs and/or
other organic contaminants at either an offsite TSCA permitted landfill or a State special
waste landfill; moving PCB-contaminated surface soil in the top 12 inches of onsite soil,
containing between 1 and 5 mg/kg of PCBs, into the excavated areas onsite; and
backfilling, regrading, and revegetating the excavated areas. The ground water remedy
selected in the 1989 ROD is not affected by this amendment. The estimated present worth
cost for this amended remedial action is $3,017,000.
PERFORMANCE STANDARDS OR GOALS:
The excavation goal for PCBs of 5 mg/kg was selected based on a State cleanup level that
is slightly more stringent than a 10-5 excess cancer-risk level. Chemical-specific
excavation goals for unsaturated soil are based on a 10-5 excess cancer-risk, and include
benzene 260 ug/kg; chlorobenzene 12,000 ug/kg; 1,4-dichlorobenzene 26,000 ug/kg;
chloromethane 30 ug/kg; and 1,2,4~trichlorobenzene 4,836 ug/kg. Chemical-specific
saturated soil excavation goals also are based on a 10-5 excess cancer-risk, and include
benzene 20 ug/kg; chlorobenzene 42 ug/kg; 1,4-dichlorobenzene 42 ug/kg; chloromethane 30
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RECORD OP DECISION AMENDMENT
PINETTE'S SALVAGE YARD SITE
DECLARATION
SITE NAME AND LOCATION
Pinette's Salvage Yard site
Washburn, Maine
STATEMENT OF PURPOSE
This decision document presents an amendment to the united States
Environmental Protection Agency's (EP~) Source Control portion of
the selected remedial action chosen in a Record of Decision
signed on May 30, 1989 (lithe 1989 ROD") for the Pinette's Salvage
, Yard Site, in Washburn, Maine. This amended selected remedy was
chosen in accordance with the Comprehensive Environmental
Response, compensation, and Liability Act of 1980 (CERCLA), as
amended, 42 U.S.C. ~. 9601, et sea., and is consistent, to the
extent practicable, with the National oil and Hazardous
Substances Pollution contingency Plan (NCP) , 40 CFR Part 300.
This amendment is made in accordance with section 117 of CERCLA,
42 U.S.C. ~ 9617, and 40 CFR ~ 300.435(c)(2) (ii). The Regional
Administrator has been delegated the authority to approve this
amendment to the Record of Decision.
The State of Maine has concurred on this amended selected remedy
and determined, through a detailed evaluation that the selected
remedy is consistent with Maine laws and regulations.
STATEMENT OF BASIS
This decision is based on , the Administrative Record compiled for
this Site which was developed in accordance with section 113(k)
of CERCLA. The Administrative Record is available for public
review at The Washburn Town Offices in Washburn, Maine and at the
EPA Region I waste Management Division Record Center in Boston,
Massachusetts., The Attached index (Attachment A) identifies,the
items which comprise the administrative record upon which the
selection of the remedial action is based. '
DESCRIPTION OF THE ORIGINAL SELECTED REMEDY
The remedial action selected for Source control in the 1989 ROD
consisted of: .'
1)
Off-site 'incineration of PCB-contaminated soils greater
than 50 ppmi and
2)
On-site solvent extraction of additional PCB- and
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DESCRIPTION OF TH~ AMENDED SELECTED REMEDY
The amended source control remedy will consist of:
1)
Off-site incineration of PCB-contaminated soils greater
than 500 ppm: and
Off-Site land disposal at a feder~lly permitted Toxic
Substances Control Act (TSCA) secure landfill of all
soils contaminated with PCBs at concentrations greater
than or equal to 50 ppm and less than 500 ppm: and
2)
3)
Off-Site Land Disposal at either a State of Maine
licensed Special Waste Landfill, or a federally
permitted Toxic Substances Control Act (TSCA) secure
landfill of all soils contaminated with PCBs at
concentrations greater than or equal to 5 ppm and less
than 50ppm and/or contaminated with other organic
contaminants greater than the action levels listed in
Table 1.
All other aspects of the 1989 selected remedy remain unchanged.
DECLARATION
The amended selected remedy is protective of human health and the
environment, attains ARARs (except as discussed in the 1989 ROD
with respect to the groundwater component, which is not subject
to this amendment) and is cost effective. The amended 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 amended selected remedy utilizes
alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.
This amended selected remedy does not change the groundwater
portion of the 1989 ROD: therefore, this amended selected remedy
does not chanqe the 1989 requirement of a waiver from a state
ARAR due to the technical impracticability from an engineering
perspective .of collecting particulate-bound PCB's from the
groundwater at the Site. Additionally, because the amended
selected remedy could still likely result in hazardous substances
(PCBs) remaining in groundwater on-site above health based
levels, a review will be conducted (at a minimum) within five
years after commencement of the remedial action to ensure that
the remedy continues to provide adequate protection of. human
health and the environment. ..
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.~?/J
If?"7
~~g{ ~c?
Date
Regional Administrator
Record of Decision Amendment
Pipette's Salvage Yard Site
Washburn, Maine
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RECORD 01' DECISION AHEHDKENT
PINETTE'S SALVAGE YARD SITE
TABLE 01' CONTENTS
Paae Number
I. SITE DESCRIPTION AND RATIONALE FOR 5
PROPOSED AMENDMENT
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 8
1.II. COMMUNITY RELATIONS HISTORY 11
IV. SUMMARY OF SITE CHARACTERISTICS 12
V. DESCRIPTION OF ALTERNATIVES 12
VI. COMPARATIVE ANALYSIS OF ALTERNATIVES 14
VII. THE AMENDED SELECTED REMEDY 19
VIII. STATUTORY DETERMINATIONS 20
IX. STATE ROLE 22
Fiaure Number/Title
1. Site Location Map
2~ site Vicinity Map
3. Current Site Features
Table Number/Title.
l.
2.
Soil Cleanup Levels
Source Control ARARs affected by Amended ROD
Attachments
A.
B.
C.
Pinette's Salvage Yard Site Administrative
Pinette's Salvage Yard site Responsiveness
Pinette's salvaqe Yard Site State of Maine
Concurrence Letter
Pinette's Salvaqe Yard Official Public Hearinq Transcript,
April 13, 1993
Record Index
Summary
Declaration of
D.
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RECORD OF DECISION AMENDMENT
PINETTE'S SALVAGE YARD SITE
DECISION SUKMARY
I.
SITE DESCRIPTION AND RATIONALE FOR PROPOSED AMENDMENT
The Pinette's Salvage Yard (PSY) site is located on Gardner Creek
Road (a.k.a. Wade Road) approximately one mile southwest of the
town of Washburn, Aroostook County, Maine, in the northeastern
corner of the state (see Figures 1 and 2). The town of washburn
has a current estimated population of 2,200 residents, and
consists of various family-owned and operated stores, an .
elementary school and high school, Town Hall and med~cal center.
A portion of the Pinette's Salvage Yard (PSY) site is privately
owned and operated by 'Roger J. Pinette and his family as a
vehicle repair and salvage yard. Damaged vehicles are stored
and/or dismantled, from which recovered parts are sold, on an
infrequent basis at present. This portion of the site is
situated within the parcel of land currently owned by Roger J.
Pinette and Cynthia C. Pinette (granted, with warranty covenants,
as joint tenants) which consists of 9.45 acres.
.
The remainder of the PSY site consists of an area south of
Gardner Creek Road where contamination has come to be located
through surface water runoff from the salvage yard area located
north of the road. This smaller area is part of a larger tract
of land that is privately owned by A.E. Albert Farms, Inc. It is
currently undeveloped.
Land use within a one mile radius of the site consists of
residential, general industrial, agricultural and undeveloped
forest and wetlands. Residential zoning (with a one acre minimum
lo~ size) and agricultural zoning predominates adjacent to the
PSY site. Other areas along Gardner Creek Road consist of
residential homes both northeast and southwest of the site;
agricultural areas north and south of the site (as well as
surrounding areas); wetlands to the northeast, northwest, and
south of the site; and general industrial facilities located near
Main Street in Washburn and the intersection of Gardner Creek
Road. To the southwest of the site, Gardner Creek Road becomes a
dirt road and eventually separates into several logging roads.
The forests in this area are used for lumber production, and
numerous hunting camps have been established for recreational
outings. -
Natural resources at,the site and in surrounding areas include
groundwater, surface water, fish and game, agriculture,
wetlands, and forests.
Approximately 8-10 residences housing 20-30 people are located
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within a half mile radius of the site. Many of these residents
obtain their water from private wells which are primarily located
in the deep, bedrock aquifer near the site. The majority of
residents located within the town of Washburn obtain their
drinking water from the Washburn Water Company. The municipal
wells used to supply potable water to these residents are located .
approximately one mile northeast of the site on Church street in
Washburn and are approximately 100 feet deep.
The surface water bodies in the area of the site consist of the
Aroostook River, Gardner Creek, -Gardner Creek Branch, and Salmon
Brook (see Figures 1 and 2). Fishing, trapping, and duck hunting
are the primary recreational activities conducted at these .
locations.
The .PSY site is located approximately 1,500 feet northwest of the
Aroostook River, as shown on Figure 2, a major waterway in
northeastern Maine that is used as a natural and recreational
resource. Regional and local planning officials have
successfully completed a recent $60 million effort to clean up
the Aroostook River. This extensive cleanup effort has produced
better water quality, enabling the public to use the river for
boating and swimming, and as a potable water source in certain.
areas. Atlantic salmon and trout, both environmentally sensitive
and selective species, are now found in the Aroostook River
indicating that the water quality is excellent.
The wetlands, agricultural and woodland areas surrounding the
site are used primarily for such activities as hunting, trapping,
horseback riding, snowmobile and motorcycle riding, and camping.
The agricultural areas are predominately used for potato and pea
farming. Some farms in the area raise cattle, horses, and other
livestock. Various animals such as moose, bear, deer, mink, and
waterfowl have been observed in the areas surrounding the site.
The remedial investigation field work performed at the PSY site
identified several additional site-specific characteristics as
described below:
o ground surface elevations range from approximately 480 to
470 feet above mean sea level (msl) north of Gardner Creek
Road, and 475 feet above msl or less south of the road where
the topography becomes steeper;
o surface water drainage flows south to southeast on the
western portion of the site, and approximately due east on
the eastern portion of the site prior to discharging into
individual culverts located under Gardner Creek Road;
o four (4) distinct lithologic soil units include: surface
soils (alluvium), a clay/silt confining unit, a sequence of
glacial till/glacial outwash, and a bedrock unit (consisting
6
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. --..-..- --... -- _. . .
of an upper, weathered and fractured zone, and a deeper,
less fractured bedrock zone):
o wetland areas consist of the eastern pond/drainage ditch,
the western pond and those areas west-northwest of the site,
the "groundwater breakout" area south of Gardner Creek Road,
and a large a~ea located adjacent to Gard~er Creek Road
approximately 300 feet east-southeast of the site;
o two (2) distinct aquifers (shallow overburden and glacial
till/fractured bedrock) are separated by an intervening clay
layer:
o the clay layer separating the two aquifers is found at a
depth of 2.to 6 feet below the ground surface, extends to .
depths of up to 12 to 16 feet, and varies in thickness from
2 to 3 feet in the northern portion of the site (where it
may become discontinuous) to greater than 1Q feet in the
southern portion of the site north of Gardner Creek Road:
. 0 the clay unit has low permeability (approximately 2xlO-7
cm/sec) relative to the overlying alluvial aquifer, and.
therefore is an aquitard allowing limited downward movement
of groundwater and contaminant transport: .
o the clay unit (aquitard) creates a "perched" groundwater
condition in the shallow alluvial aquifer, resulting in a
saturated thickness ranging from two to three feet: the base
of the shallow aquifer crops out south of Gardner Creek Road
which results in the discharge of groundwater in the
"groundwater breakout" area; and
o the clay unit (aquitard) also in turn creates semi-
confined conditions in the underlying glacial till/fractured
bedrock zone.
A more complete description of the site can be found in the Final
Supplemental Remedial Investigation (SRI) report (Ebasco, 1989a).
The purpose of the Amended Record of Decision is to formally
. specify changes to the previously iS$ued Record of Decision. The
Amended Record of Decision describes the changes adopted,
presents an evaluation of technologies which were considered
pursuant to the original Record of Decision. In addition, it
presents the rationale for changing the Record of Decision, t~e
state and public perspectives on the change, an explanation of .
how the change differs from.the original. Record of Decision, and
a Responsiveness Summary which is EPA's response to public.
comment on the change.
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II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
site History
In June 1979, three electrical transformers from Loring Air Force
Base located near Limestone, Maine, were removed from the base
under a written agreement with a private electrical contractor
hired by the base. Allegedly, the transformers were brought to
the site where they apparently ruptured while being removed 'from
the delivery vehicle. Approximately 900 to 1,000 gallon~ of
dielectric fluid containing polychlorinated biphenyls (PCBs)
spilled directly onto the ground.
From October 4 to'November 4, 1983 approximately 1,050 tons (800
cubic yards) of PCB contaminated soil and assorted debris were
removed for disposal as part of an EPA authorized -Immediate
Removal Action. A 1985 Deletion Remedial Investigation resulted
in the determination by EPA, in consultation with Maine DEP, that
the Site was not suitable for deletion from the National Priority
List.
A Remedial Investigation/Feasibility Study of the Site was
conducted from 1984 to 1989. The Remedial Investigation was
performed to characterize the geology, hydrogeology, and
distribution of contaminants in the soil, ground water, surface
water, and sediments at the Site. The Feasibility Study
presented and evaluated various remedial alternatives, including
the treatment alternatives selected in the 1989 ROD.
Based on the Feasibility study, EPA proposed a preferred
alternative for the site in a ,Proposed Plan dated March 1989.
Following a public comment period, the preferred alternative was
established by EPA as the final remedy of the Site in the 1989
ROD. After issuance of the 1989 ROD, EPA completed the Remedial
Design in June 1990. EPA's construction management contractor
solicited proposals from engineering construction firms to
implement the Remedial Design in accordance with the 1989 ROD.
EPA's contractor evaluated' the proposals and awarded the
subcontract for the cleanup in October 1990. The following
spring, EPA began cleanup activities at the Pinette's Salvage
Yard Site (see "Cleanup Set to Begin" Fact Sheet, January 1991).
Solvent extraction is an innovative treatment technology which
has not yet been implemented at the full-scale level. The
ability of individual solvent extraction companies to achieve
desired cleanup objectives has, ~o date, been based on bench-
scale and/orpilot-sc:ale treatability testing, (see "A Citizen's
Guide to Solvent Extraction," March 1992 (EPA/542/F-92-004) Fact
Sheet). Most solvent extraction companies do ,not have full-scale
units pre-built which are immediately availa~le for use. The
solvent extraction company initially hired to treat the Pinette's
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. .- --. . -- -... .
Salvage Yard soil demonstrated the ability to remove PCBs to the
desired objectives established in the ROD in a treatability test
and committed, in October 1990,' to deliver a fully fabricated
unit to the Site. .
Through early to mid 1991, the fabrication of the treatment unit
was delayed. In late 1991, the new owner reportedly contemplated
selling parts of 'the company. At that time, all work on the
treatment uriit was suspended. Eventually this company abandoned
its plans to support the Pinette's salvage Yard site cleanup.
Despite the setbacks with the construction of the solvent
extraction treatment unit, work on other aspects of the' cleanup
continued at the Pinette's Salvage Yard site. During the first
year of cleanup activities, EPA's contractors secured the site
with a six-foot chain linked fence, set up support services, and
excavated and removed approximately 410 cubic yards of the most
highly contaminated soil to a federally permitted incinerator in
Coffeyville, Kansas. As excavation progressed, it became evident
, that there was a larger volume of this highly contaminated soil
than originally estimated. However, soil excavation was halted
when incinerator capacity, nationwide, was no longer capable of
accepting additional soil for treatment. Progress was made in
treating contaminated groundwater; approximately 160,000 gallons
of contaminated groundwater was successfully treated to
established Maine drinking water quality guidelines and drained
back into the ground.
As a result of the solvent extraction company's failure to meet
its commitments to the Pinette's Salvage Yard cleanup, none of
the moderately contaminated soil (5-50 ppm) was treated during
the first year. Without a commitment to complete the solvent
extraction treatment unit, EPA's contractors requested proposals,
from other solvent extraction companies, including those
evaluated in the original Feasibility Study, to perform the work
in 1992. EPA's contractors were able to find only one solvent
extraction company which was willing to construct and deliver a
treatment unit to the site in 1992. Other solvent extraction
companies either did not respond to the requests or proposed
project schedules which would have required up to 18 months of
fabrication and treatment costs several times higher than those
in the current subcontract. The solvent extraction company,
whose schedule EPA considered acceptable, demonstrated its
process was capable of meeting the ROD objectives through a
treatability test and resumed fabrication of'a partially
constructed treatment unit in April 1992. '
The second solvent extraction treatment unit was delivered to the
Pinette's Salvage Yard site in June 1992, as' scheduled. The
company estimated the treatment unit would be fully operational
and able to treat soils at a rate of 42 tons per day. As
reported in EPA's Fact Sheet, "EPA Resumes Cleanup,",June 1992,
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the cleanup was expected to be completed by November 1992.
Efforts to operate the new treatment unit were hampered by
mechanical and process problems. Although the treatment unit was
able to successfully treat very small volumes of soil, the
operation of this particular unit was severely hampered by
material handling problems including repeated breakage of the
soil conveyance mechanisms. Additionally, the system was
rendered inefficient due to problems with fine ground soil
particles clogging solvent lines and hampering the soil drying
system. By August 1992, the solvent extraction company had
" reduced its expectations to a soil treatment rate of 17 tons per
day. The unit was continually being shut down," repaired, and
modified. By "August, only 14 cubic yards of soil had been
treated to below. the cleanup objectives established in the 1989
ROD. At "that time, the treatment unit ~as again shut down for a
three week period in order to undergo several major design
fabrications. These changes included mechanical devises to pre-
sort soil particles prior to treatment, improvements to the soil
conveyance mechanisms, addition of a settling tank to remove fine
soil particles, and improvements to the soil dryer.
Despite these fabrication changes, performance problems
continued. In September 1992, the solvent extraction company
advised EPA that the maximum treatment rate of the unit would be
6 tons per day. By this time, a total of only 56 cubic yard of
soil had been treated to meet the objectives of the ROD: however,
of these 56 cubic yards of soil, 42 cubic yards contained high
levels of residual solvent requiring additional measures to
reduce the solvent levels to acceptable levels prior to re-
placement in the ground. "
As a result of these difficulties, at the end of the second
construction season less than 1% of soils containing between 5
. and 50 ppm PCB had been successfully treated and were acceptable
for re-p1acement in the ground. In order to treat all remaining
soils at these concentrations by the end of a thirq construction
season in 1"993, the treatment unit "Would have to undergo.
extensive design and construction modifications and would have to
treat soils at a rate of 48 tons per day; a rate that would
" exceed the original performance estimate provided by the solvent
extraction company. In November 1992, the cleanup subcontractor
advised EPA and its construction management contractor of its
lack of confidence in its ability to complete the Pinette's soil
cleanup using the current solvent extraction unit and expressed
its disinterest in undertaking the major design and fabrication
qhanges required f~r the solvent extraction treatment unit.
Despite the complications with the treatment unit, work
progressed on other aspects of the Pinette's Salvage Yard cleanup
in 1992, approximately 281 cubic yards of soil containing greater
than or equal to 50 ppm PCB were incinerated off site. .A
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. H . -.
damaged culvert and the contaminated soil beneath it leading to
the wetlands off-site were excavated and replaced with clean soil
and a new culvert. The contaminated wetland area was excavated.
However; additional volumes of contamination were identified in
areas including the wetlands. As a result of this addi~ional
soil contamination, the restoration of the wetlands will be
completed in 1993. . 440,000 gallons of contaminated ground water
were treated in accordance with Maine drinking water quality
guidelines and drained back into the ground.
B.
Enforcement Activities
On March 6, 1989, EPA notified four (4) parties who owned or
operated the facility, generated haza~dous substances that were
shipped to the facility, arranged for the disposal of hazardous
substances at the facility, or transported hazardous substances
to the facility of their potential liability with respect to the
site. .
In addition,' technical comments presented by the Potentially
Responsible Parties (PRPs) during the initial comment period
submitted in writing, and are included in the Administrative
Record. No comments were received by any of the PRPs on the
proposed plan to amend the 1989 ROD. .
were
To date, special notice has not been issued in this case.
III.
COMMUNITY RELATIONS HISTORY
Throughout the Site's history, community concern and involvement
has been low. EPA kept the community and other interested
parties apprised of Site activities through an informational
meeting, fact sheets, press releases and public hearings.
Additionally, EPA has conducted several television and radio
interviews and has been available to the public during all site
visits.
In June 1988, EPA released a community relations plan which
outlined a program to address community concerns and keep.
citizens informed about and involved in the remedial activities
being performed. a the site.
In issuing the original 1989 Record of Decision (ROD), EPA
published a Proposed Plan on March 8, 1989. On March 14, 1989,
EPA held an informational meeting, and on April 11, 1989 EPA held
a public hearing to accept oral comments on the original proposed
plan and administrative record. The public comment period for'
the 1989 ROD ran from March 15, 1989 to April 14, 1~89.
In issuing this amended ROD, EPA published a Proposed Plan on
March 12, i993. On March 17, 1993, EPA held an informational
meeting, and on April 13, 1993, EPA held a public hearing to
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accept oral comments on the proposed plan to amend the 1989 ROD
and the administrative record, including the new information
which was considered in making the proposal. The official
transcript of the hearing provided as Attachment D. The public
comment period for the Amended ROD ran from March 18, 1993, to
April 16, 1993.
IV.
SUMMARY OF SITE CHARACTERISTICS
The soil cleanup at the Pinette's salvage Yard site has been
ongoing since 1991. During the two construction seasons, EPA has
partially completed cleanup activities. The Site has been
fenced, a concrete pad and equipment decontamination facility
have been installed, approximately 440,000 gallons of groundwater
have been treated and discharged, and approximately 1600 cubic
yards of soil have been excavated. Of these soils, 711 cubic
yards have been inc~nerated off-site, 259 cubic yards are stored
on-site in covered containers, and the remaining 630 cubic yards
are in covered stockpiles on-site. The excavated area has been
, partly backfilled with clean soil, but part of this area remains
as an open pit which collects groundwater during wet periods.
A complete description of the site characteristics can be found
in the 1989 ROD or the "Final Supplemental Remedial Investigation
and Public Health Evaluation Report," 1989.
v.
DESCRIPTION OF ALTERNATIVES
As a result of the difficulties experienced to date in
implementing on-site solvent extraction treatment for soils
containing between 5 and 50 ppm PCB, EPA and the State of Maine
Department of Environmental Protection (DEP) have been unable to
complete' the soil cleanup at the Pinette's Salvage Yard Site.
Therefore, EPA has considered alternatives which will meet the
objective of achieving a timely and cost-effective cleanup while
providing overall protection of human health and the environment
in compliance with all applicable or relevant and appropriate
requirements (ARARs).
The oriqinal remedy specified in the 1989 ROD was selected
following a comparative evaluation with numerous other
alternatives, based on conditions which existed at the time the
original Feasibility Study was prepared. As described above, the
present conditions, at'the site are considerably differen~ from
those which existed at, the time of the 1989 Feasibility Study.
However, during the evaluation of alternatives for completion of
the soil cleanup, EPAconsidered these'original alternatives and
how they would apply to current Site conditions. Following are
brief descriptions of these remedial alternatives.
Alternative #1: Minimal No Action: This alternative serves as a
baseline for comparison with other remedial alternatives under
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consideration. Under this alternative, no additional remedial
activities would occur at the site. EPA's contractors would
demobilize all equipment and secure the Site. Stockpiles of soil
would remain on-site and the flooded excavation would be left
open. The concrete pad and perimeter fence would be left,intact. ,
As was the case in the original no-action alternative, certain
institutional actions would be conducted, including obtaining
land use restrictions; posting warning signs; conducting a public
education program; installing additional monitoring wells;
monitoring the groundwater, surface water, and sediment for a 30-
year period; and conducting a review of the Site conditions every
five years.
Alternative #2: On-site capping with Slurry Wall: This
alternative was also evaluated in the 1989 Feasibility Study~
This alternative, as originally conceived, would have involved
placing an impermeable cap over contaminated soils on-site and
constructing a slurry wall extending into the clay layer
underlying the site. This alternative is no longer appropriate
to current site conditions, because 'much of the most highly
contaminated soil and groundwater have been removed from the
Site. In order to implement this alternative now, all soil
currently stored or stockpiled on-site would have to be replaced
into the open excavation, and then the cap and slurry wall would
be constructed. '
Alternative #3: Off-Site Disposal: The 1989 Feasibility Study
included an evaluation of a remedial alternative consisting of
off-site landfilling of all soils contaminated above EPA's
selected action level. EPA has included off-site disposal as a
component of the amended selected remedy. All soils remaining on
site containing greater than or equal to 5 ppm PCB and less than
500 ppm PCB will be excavated and disposed at an off-site TSCA-
permitted landfill. This alternative consist~ of a significant
portion of the amended' selected remedy, which also includes off-
site incineration of some of the PCB contaminated soil. . (See the
discussion of EPA's'amended selected remedy on page 19).
Alternative #4: Incineration: The 1989 Feasibility Study included
an evaluation of a remedial alternative consisting of ,excavation
and either on-site or off-site incineration of all contaminated
soils above EPA's selected action level. Off-site incineration
was a component of EPA's Preferred Cleanup Plan selected in the
1989 ROD. In the original Plan, all soils containing greater
than or equal to 50 ppm PCB, originally estimated at.360 cubic
yards, were specified to be incinerated at an off-site TSCA-
permitted incinerator. To date, 711 cubic yards of such soils
have been incinerated. EPA's amended selected remedy includes
o~f-site incineration of an additional volume of soil, estimated
at 51 cubic yards, containing greater than or equal to 500 ppm
PCB. (See the discussion of EPA's amended selected remedy on
page 19). '
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Alternative #5: On-site Solvent Extraction: The 1989 Feasibility
Study evaluated .an alternative comprising excavation and on-site
treatment by solvent extraction of soils containing contamination
above EPA's selected action level. This process involves the use
of a solvent to remove PCBs and other organic chemicals from
soil. This was a component of EPA's Preferred Cleanup Plan
selected in the 1989 ROD. The selected remedy specified on-site
treatment of soil containinq between 5 and 50 ppm PCB, and soils
contaminated with other organic chemicals (benzene, .
chlorobenzene, and others) by solvent extraction technoloqy. As
described previously, EPA has experienced difficulty in
implementinq this component of the selected remedy at the
Pinette's Salvaqe Yard site.
Alternative #6: On-site Dechlorination: The 1989 Feasibility
Study included an alternative consisting of excavation and on-
. site treatment of soil contaminated above EPA's selected action
level usinq a dechlorination process. This innovative technology
would involve mixing excavated soil with a combination of .
chemicals, forming a reagent capable of detoxifying PCBs through
the removal of chlorine atoms from the PCB molecule.
Decontaminated soils would be replaced on-site and the
contaminated reagent would be disposed at a licensed off-site
incineration facility.
Alternative #7: In-situ Vitrification (ISV): The 1989
Feasibility Study included an alternative to treat contaminated
soil above EPA's selected action level using an in-situ
vitrification technology. This innovative technoloqy would
involve placing electrodes in the soil in the area to be treated.
A hiqh power electrical current would be passed from the
electrodes to the soil, resulting in the melting and
transformation of the soil to a glass-like material. . In the
process, organic contaminants would be destroyed/volatilized, and
inorganic contaminants would be bound/fused together. Off-gases
would be collected by carbon filters within a hood placed over
the area to be treated. In order to apply this technoloqy to
current site conditions, all stockpiled soil would have to be
replaced in the open excavation and the area would have to be
qraded prior to application of the technoloqy.
VI.
COMPARATIVE ANALYSIS OF ALTERNATIVES
Section l2l(b)(1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. Buildinq 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
14
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nine evaluation criteria in order to select a site remedy. The
following is a ~ummary of the comparison of each alternative's
strength and weakness with respect to the nine evaluation
criteria. These criteria are summarized 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. Overall Protection of Human Health and the Environment
addresses whether or not an alternative provides adequate '
protection and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment, engineering
controls, or institutional controls.
The amended selected remedy will provide overall protection of
human health and the environment by preventing direct contact,
ingestion, and inhalation of Site contaminants. Alternative #1
(the no-action' alternative) would not provide overall protection,
as current conditions would remain intact. Alternatives #5, #6,
and #7 would potentially provide a lower degree of overall
protection due to uncertainties regarding availability and
implementability of solvent extraction, dechlorination, and in-
situ vitrification technologies.
2. ComDliance with Federal and state ADPlicable or
Relevant and ADDroDriate Reauirements (ARARs) addresses whether
or not an alternative complies with all State and Federal
environmental and public health laws and requirements that apply
or are relevant and appropriate to the conditions and cleanup
options at a specific site. If an ARAR cannot be met, the
analysis of the alternative must provide the legal grounds for
waiving this requirement.
The amended selected remedy will comply with all ARARs.
Alternative #1 (the no-action alternative) would not comply with
ARARs. Alternatives #2 and #7, requiring soii containing greater
than or equal to 50 ppm PCB to be replaced into the ground may
not comply with Toxic Substances Control Act (TSCA) ARARs.
similarly, Alternatives #5 and #6 may not comply with TSCA for
treatment of soil containing greater than or equal to 50ppm PCB.
This amended selected remedy does not change the groundwater
portion of the 1989 ROD. Therefore for the groundwater component
of the remedy, ,the ARARs "analysis in the 1989'ROD remains in
effect.
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.
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, 3. Lena-term Effectiveness and
ability of an alternative to maintain
human health and the environment over
have been met.
Permanence addresses the'
reliable protection of
time once the cleanup goals
The amended selected remedy will be a long-term effective'and
permanent cleanup solution at the Pinette's Salvage Yard site.
Because all contaminated soil would be disposed off-site, there
would be no long-term maintenance required at the Site to ensure
the permanence of the remedy. Alternative #1 (no-action) would
not provide long-term permanence and effectiveness. Other
alternatives which would remove all contaminated soil from the
site (#4, #5 & #6) would achieve long-term effectiveness and
permanence. Alternatives which would contain contaminated soils
on-site (#2 & #7) would require some degree of site maintenance
to achieve long-term effectiveness and permanence.
4. Reduction of Toxicitv. Mobilitv and Volume Throuah
Treatment addresses the degree to which alternatives employ.
recycling or treatment that reduces ,toxicity, mobility or volume,
including how treatment is used to address the principal threats
posed by the site.
The amended selected remedy will achieve substantial reduction in
toxicity, mobility and volume of contaminants through treatment.
This alternative would include destruction of contaminants in all
soil containing greater than or equal to 500 ppm PCB and in 81%
of soil containing greater than or equal to 50 ppm PCB. Based on
analyses conducted during the soil cleanup to date, incineration
of these soils would result in permanent destruction through
treatment of 90% of all PCBs originally present on-site in soils
containing greater than or equal to 5 ppm PCB. Only 10% of PCBs
originally present on-site would be disposed in an off-site
landfill. Therefore, this alternative would be consistent with
EPA's policy at PCB sites to reduce the principal threats to
human health and the environment through treatment.
Alternatives #1 and #2 involve no treatment. Alternative #6
would achieve maximum reduction in toxicity, mobility, or volume
of contaminants through treatment by incineration or
dechlorination, respectively. Alternative #5 would achieve
reduction of volume of contaminants by concentrating them into
the solvent extract, which would then be destroyed through a
secondary off-site incineration process. Alternative #7 would
reduce the toxicity and volume of contaminants by volatilization
during the extreme temperatures of vitrification. Any remaining
contaminants which were not completely volatilized would be
rendered immobile through solidification of soil into a vitrified
mass.
5. Short-term Effectiveness refers to the likelihood of
adverse impacts on human health or the environment that may be
16
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posed during the construction and implementation of an
alternative until cleanup goals are achieved. The cleanup ~f the.
Pinette's Salvage Yard Site has been ongoing for two construction
seasons. Although EPA has taken steps to maintain a secure site,
including all appropriate public health and environmental
precautions, nonetheless the site has been in a.disturbed '
condition for a period of time exceeding that anticipated by the
1989 ROD. The longer this period of disruption'continues, the
more short term risks are posed to the community and workers at
the site.
The amended selected remedy will be completed in the shortest
. time, because the site, which has been in a disturbed state since
May 1991, could be restored to original conditions at the end of
the 1993 construction season. '
Alternatives other than the amended selected remedy, with the
exception of the no-action alternative (#1), would require
additional time beyond the 1993 season, thus subjecting the
community, workers, and the environment to prolonged disruption
and ~hort-term risks. Maintaining the solvent extraction
component of the currently selected remedy will result in ,
extension of the disrupted site conditions for at least 18 to 24
months, and there is no certainty that any other vendors will be
successful in implementing this technology at the Site. The
other alternatives would also extend the duration of current
conditions, due to the anticipated redesign and reprocurement
required to implement different technologies than those currently
specified in the 1989 ROD.
All alternatives except no-action (#1) will cause increased
vehicle traffic in the vicinity of the site. The amended
selected remedy will result in the arrival and departure of an
average of two to three trucks over a four to six week period to
complete off-site shipment of contaminated soils. Transporters
will be licensed and would comply with ,all Federal and State of
Maine regulations for transportation of hazardous waste. , Other
alternatives would not involve transportation of wastes off-site
and would therefore not require the resulting vehicular flow.
However, these other alternatives would require substantial
, vehicle traffic to install different equipment than is currently
on-site.
6. ImDlementabilitv refers to the technical and
administrative feasibility of an alternative, including
availability,of materials and services needed to implement the
alternative. .
The amended selected remedy is fully implementable at the
Pinette's Salvage Yard site. Standard earth moving techniques.
and equipment will be used, and the availability of off-site
incineration and disposal facilities has been confirmed for the
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1993 construction season. EPA's experience indicates that the
implementability of the solvent extraction component of the 1989
selected remedy is significantly more uncertain at the Pinette's
Salvage Yard Site than anticipated during the original remedy
selection process in 1989.
EPA has worked with its contractors over two construction seasons
to bring two different units to the site. In order to have been
able to make the solvent extraction unit functional for the
Pinette's Salvage Yard soil cleanup, major engineering and.
fabrication modifications would have been necessary. The
subcontractor expressed a strong reluctance to undergo such
modifications at its cost, and such modifications in no way would
have guaranteed success. ..
There are no other solvent extraction vendors who have
commercially available treatment units suitable f~r the Pinette's
salvage Yard site. EPA's contractors requested proposals from
other solvent extraction companies, including those evaluated in
the o~iginal Feasibility study, to perform the work. in 1992.
EPA's contractors were able to find only one solvent extraction
company which was willing to construct and deliver a treatment
unit to the site in 1992. other solvent extraction companies
either did not respond to the requests or proposed project
schedules which would have required up to 18 months of
fabrication and treatment costs several times higher than those
in the current subcontract. In November 1992, the clean-up
subcontractor who was performing the work advised~PA and its
construction management contractor of its lack of confidence in
its ability to complete the Pinette's soil cleanup using the
current solvent extraction unit and expressed its disinterest in
undertaking the major design and fabrication changes required for
the solvent extraction treatment unit.
Alternatives #6 and #7 also include innovative treatment
technologies (dechlorination, in-situ vitrification) whose
commercial availability and implementability are similarly.
uncertain. Neither of these alternatives are implementable in a
time-frame which allows EPA to complete the s9il cleanup at the
Pinette's Salvage Yard Site within a cost-effective timeframe.
Alternatives #1 (no-action) and #2 (capping with slurry wall) are
both implementable, although neither is appropriate for current
site conditions.
7. ~ includes the capital (up-front) cost
implementing an alternative as well as the costs of
maintaining the alternat1ve over the long term, and
. worth of both capita~ and oper~tion and maintenance
of
operating and
net present
costs.
The amended selected remedy can be completed with minimal
additipn to the current funding of the existing contracts.
current selected remedy, due to uncertainty of the
The
18
. '-'--..'
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implementability of the on-site solvent extraction component,
leaves cost uncertain until the cleanup is achieved. So far, the
original unit costs associated with the solvent extraction vendor
have remained unchanged. However, there are certain unit price
components of the project, such as water treatment and analyses
which are paid on an as-performed basis and are controlled by the
duration of the project. Additionally, construction management
costs are largely dependent on the duration of the project,
particularlY with regard to on-site resident engineering. More
significantly, the risk of failure of the current approach
carries with it the risk of potential costs to terminate the
current subcontract, redesign a different remedy, and procure a
new subcontractor.
The amended selected remedy can be implemented by the current
contractors, with minimal redesign, thereby avoiding costs
associated with termination and re-procurement.
. Modifvina cri~eria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received public
comment on the RI/FS and Proposed Plan.
8. state AcceDtance 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. The state of Maine is in agreement with EPA on
the Proposed Plan and has concurred with the ROD amendment.
9. Communitv Acceptance addresses the public's general
response'to the alternatives described in the proposed Plan. EPA
held an informational meeting in Washburn, Maine on March 17,
1993. Local press, a town official and three Washburn residents
attended the meeting to learn about the proposal to amend the
1989 ROD and to answer questions. On April 13, 1993, EPA
returned to Washburn to hear oral comments on the proposal. The
town official read for the record that the Washburn Town Council
had unanimously voted to endorse the ROD amendment. See Public
Hearing Tran~cript (Attachment D) and the Responsiveness Summary
(Attachment B).
VII.
THE AMENDED SELECTED REMEDY
The amended selected remedy is the result of a re-evaluation of
material contained in the Administrative Record, for the 1989
ROD, as well as material reflecting the experiences and new
information developed since 1989 which has been added to the
Administrative Record. In, the judgement of EPA, the amended
selected remedy represents the best balance among the evaluation
-------
criteria when compared to the other alternatives.
The amended sel~cted remedy addresses a fundamental change in the'
approach for cleaning up contaminated soil at the Site (Source'
Control). EPA is not proposing to change the cleanup approach in
the 1989 ROD for addressing contaminated groundwater at the Site
(Management of Migration). .
The amended selected remedy for Source Control is a combination
of the originally selected remedy and a modification of others
evaluated in the 1989 Feasibility Study. The amended selected
remedy includes the destruction of approximately 762 cubic yards
of. soils at an off-site TSCA-permitted facility. 711 cubic yards
of this soil has already been incinerated, and .approximately 51
cubic yards of soil may 'contain greater. than or equal to 500 ppm
PCB. The actual. soils containing greater than equal to 500 ppm'
PCBs will be incinerated at an off-site.TSCA-permitted facility.
The amended selected remedy also involves the disposal of
approximately 209 cubic yards of soil remaining on-site.
containing greater than or equal to 50 ppm PCB at an off-site
federally permitted TSCA secure chemical waste landfill.
Further, the amended selected remedy consists of removal and
disposal of soil contaminated with PCB concentration greater than
or equal to 5 ppm. This would involve excavating contaminated
soil, reducing its moisture content, and disposing of the wastes
at either a State of Maine licensed special waste landfill or an
off-site federally permitted TSCA-secure chemical waste landfill.
The excavated areas would be filled with clean soil, regraded and
revegetated to return the site to its original condition.
All other aspects of the 1989 ROD for So~rce Control would remain
the same.
VIII.
STATUTORY DETERMINATIONS
The amended selected remedy for. implementation at the Pinette's
salvage Yard Site is consistent with CERCLA and, to the extent
practicable, the NCP. The amended selected remedy. is protective
of human health and the environment, attains ARARs (except as
discussed in the 1989 ROD with respect to the groundwater
component, which is not subject to this amendment) and is cost
. effective. The amended 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
amended selected remedy utilizes alternate. treatment technologies
or resource recovery technologies to the maximum extent .
practicable. .
The Amended Selected Remedv is Protective of Human Health and the
Environment
20
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- -' .. -~. - ...-
- .--. -~ .- n.
The amended selected remedy at this Site will permanently reduce
the risks posed to human health and the environment by
eliminating, reducing or controlling exposures to human and
e~vironmenta1 receptors through treatment, engineering controls, .
and institutional controls: more specifically the amended
selected remedy will permanently remove from the Site all
contaminated soil containing PCBs at concentrations exceeding
protective health levels.
A complete description of the site Risks can be found in the 1989
ROD.
The Amended Selected Remedv ComD1ies with ApD1icab1e or Relevant'
and ADDroDriate Reauirements (ARARs)
The amended selected remedy will attain all applicable or
, relevant and appropriate federal and state requirements that
apply to the site. Because this amended selected remedy does not
change the groundwater portion of the 1989 ROD, the amended
selected remedy does not change the 1989 requirement of a waiver
from a State ARAR due to the technical impracticability from an
engineering perspective of collecting particulate-bound PCB's
from the groundwater at the Site~
Environmental laws from which ARARs for ~he amended selected
remedy are derived, and the specific ARARs are discussed in Table
2. '
The Amended Selected Remedy is Cost-Effective
In the Agency's judgment, the amended selected remedy is cost
effective, (i.e., the remedy affords overall effectiveness
proportional to its costs). In selecting this amended remedy,
once EPA identified alternatives that are protective of human
health and the environment and that attain, or, as appropriate,
waive ARARs, EPA evaluated the overall effectiveness of each,
alternative by assessing the relevant three criteria--long term
effectiveness and permanence: reduction in toxicity, mobility,
and volume through treatment: and short term effectiveness, in
combination. The relationship of the overall effectiveness of
this amended remedy was determined to be proportional to its.
costs. The following estimates of cost and construction duration
are inclusive of the work to complete all aspects of the Source
Control cleanup at the Pinette's Salvage Yard Site, and are for
actions to be performed subsequent to the proposed ROD amendment.
Estimated
Estimated
Estimated
Estimated
Estimated
Time for Design and Construction: '5 months
Time of Operation: 4 months'
Capital Cost: $3,~17,000,
operation and Maintenance Cost: $0
Total Cost (Net Present Worth): $3,017,000
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The Amended Selected RemedY Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technoloaies to the
Maximum Extent Practicable
Once the Agency identified those alternatives that attain or, as
appropriate, waive ARARs and that are protective of human health
and the environment, EPA identified which alternative utilizes
permanerit 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. The amended
selected remedy provides the best balance of trade-offs among the
alternatives. '
The amended selected remedy provides essentially the only
practicable means of cleaning up this site. Although both it and
the remedy selected in the 1989 ROD are protective and comply
with ARARs (except for the groundwater componene which is not at
issue here), and are equivalent in terms of long-term
effectiveness and permanence, the 1989 ROD remedy has proven not
to be implementable at this site within any reasonable cost and
time parameters. Although the amended remedy eliminates the
solvent extraction technology, EPA will still treat approximately
90% of all PCBs originally present on the Site.
The Amended Selected Remedy Satisfies the Preference for
Treatment as a PrinciDal Element
The principal element of the amended selected remedy is the off-
site incineration. This element addresses the primary threat at
the Site, soil contaminated with PCBs in excess of 500 ppm. The
amended selected remedy satisfies the statutory preference for,
treatment as a principal element by aChieving a substantial
reduction in toxicity, mobility and volume of contaminants
through treatment. The amended selected remedy includes
destruction of contaminants in all soil containing greater than
or equal to 500 ppm PCB and in 77% of soil containing greater
than or equal to ~O ppm PCB. Based on analyses conducted during
the soil cleanup to date, incineration of these soils would
result in permanent destruction through treatment of 90% of
PCBs originally present on-site in soils containing greater
or equal to 5 ppm PCB. only 10% of PCBs originallY present
site would be disposed in an off-site landfill. Therefore,
all
than
on-
this
22
. .. . -.. - - _.- .._._~.._- ---.- -.-- -.. ---.... -- .-'- --.. -.
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alternative would be consistent with EPA's policy at PCB sites to
reduce the principal threats to human health and the environment
throuqh treatment.
IX.
STATE ROLE
The State of Maine has reviewed the various alternatives and has
indicated its support for the amended selected remedy. The State
believes that the amended selected remedy is incompliance with
applicable or relevant and appropriate State Environmental laws
and requlations. The State of Maine concurs with the amended.
selected remedy for the Pinette's salvaqe Yard Site. A copy of
the declaration of concurrence is attached as Attachment C..
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\c.~
~
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6~ ,
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CANAOA
CANAOA
P~;:scuE
I
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REFERENCE: C" ASSOC:A'rION.
AMERICAN AUTOM~B~AINE 1987 E:)ITION.
HIGHWAY MAP O. ,
I" : 10 MII..ES.
- . ~ - -'_.._.'~---'~-
SITE
@
I
20
10
0 MII..ES
SCAI..E IN
~- I
FIGU~:. MAP
lOCATION -
SITE - - YARO SITe;
T--'S SAI..VAGe;
-------
- -----. ---. -. .- -..
" \
,..f0".. .
'- "
RE;:-~~E1\jC:::
u. S.G.S. 1.5' TOPOG~':'~HICQUAORANGi..E MAP
WASHeuRN, MAINE. OAT~ OF pI10TOGRAPHY
E;:)ITEO: 1964, SC':'L.E: 1":2000'.
@
.
OIREC~ION OF F\..OW
o
2C::
I
4000
\..::G~NO:
SCA\..E
IN
F~~
~iGURE 2
SiTE VICINITY MAP
P!',jETTE'S S,:,~v':'G:: YA~O SITE
POOR QUAU"N.
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IŁ'')use ,\\,' ** ~
(I tf!!j R_sidenee ~\ \ -.:.h0;-- - -' ** ..:tt:? s.::on..
t /. b" -- - ;:...-. .':<:<:<:.. pond
) ~- "" ~ * ~-----l.tJ -..., ." "..' Drainag.'
I I . I . ''', Ditch
/ I ~ :.K * Gara e .
/ . . ..:.;. I OW.II
. Gravel Oriv.way......: I" 6 ~~ :~::;;~~ I House
/~-If'i:'- c=:J [J ,- 3 - -I 2U !Per1cing } . Ga~.
I /,1,~ I 2" O--?i\-O '\ / ;Itt EjJ
I / 0 \..J \ I .:.'.:.'
1/ I \: I' I ~ f ~ R.s;d'.nce
I I Support Trail." I
J J .
1 I Gardner Creek Roa 1.
--
:::=;.--
.
Not to Seal.
()
Orainag.
Ditch
. Discharge
~ Ar.. ~f Contamina~on
~ ~ * W.Uands Araa
- Fene.
@ Stored Contaminated Soil
1. RECHARGE TRENCH
2. COOLING WATER FEED TANK
3. SOLVENT EXTRACTION TREATMENT UNIT
4~ WASTE WATER TREATMETN HOLDING TANKS
5. WASTE WATER TREATMENT SYSTEM
6. CONTAMINATED SOIL STOCKPll..E AREA
7. TREATED SOIL STOCKPll..E AREA
8. SECURITY STATION .
FIGURE 3
CURRENT SITE FEATURES .
Pinette's Salvage Yard Site
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- _._~ -~ . .
- ... . --
.r
Table 1
Soil Cleanup Levels
Pinette's Salvage Yard site
contaminant
Soil CleanuD Level
PCBs
Benzene
. Chlorobenzene
1,4-Dichlorobenzene
Chloromethane.
1,2,4-Tri~chlorobenzene
5 ppm *
260 ppb (unsaturated); 0.42 ppb (saturated)
12,000 ppb (unsaturated); 20 ppb (saturated)
26,000 ppb (unsaturated); 42 ppb (saturated)
. 30 ppb (unsaturated); ).05 ppb(saturated)
4,836 ppm (unsaturated): 7.8 ppm (saturated)
* Additionally, PCB-contaminated surface soils containing qreater than
1 ppm but less than 5 ppm,located anywhere within the top 12-inches
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Table 2.
.
SUPPLEMENTAL ARARs (POST-ROD)
I'
!
ACTION ARAR STATUS REQUIRfiMnNT,SYNOPSIS
Disj10salln PCD Mnrking Re(IUirements Applicahle Prcsents 're~luirements for marking PCD containers and stornge areas
Orrsite '40 CPR 761.40 IIpplicableto the PCD soil stored onsite. Requirements will be followed
Landfill during the RA:
pcn Mnrking Pormat Applicllhlc I'rescnts fornlllt rC(luircments for mnrking PCD containers np('llicahle to
40 CrR 761.45 "cn containcrs onsite. Recluircments will he fulluwed during Ihe RA.
pcn Storage for Disposal Applicllhlc I'rcscnts stornge reqnirements such as container type, secondary
40 CrR 761.65 containment, IInd stOlcture ly('IC. A('I('Iticahle 10 storage of I'CDs for
dispusal in excess uf 50 1'('1m. Requirements will be followed during the
RA.
pcn Chcmical Waste Lmulfill Applicahle I'rcscnts sl:mdarcls which nlllst he mct hy fllcility in ordcr to ncccpt pcns. '
40 crR 761.75 Offsite dispusal fltcility will meet these stnndards.
pcn Decuntaminntinn Applicnhle I'rcscnts the mcthod tu decontaminate containers. Ap('Ilicahle to storage
40 CPR 761. 79 container!. if thcy are to be cleaned instead of being dis('losed.
Rccinirelllcnts wilt hc fulluwed if contniners nre to he cleaned.
pcn Waste Disl,usal Rccords Applicllhle Idcntifics manifcsting IInd notice requirements for rCDs. A('I('Ilicahle to all
nnd RC('Iorts I'cn activities. RecI,iirements will be follQwed during the RA.
40 CPR 161.202 - 161.210
Records and Rellllrts Applicnhlc if > 4Skg; fistahlishes annual re('lorting and recordkeeping requirements.
40 CPR 161.180-161.193 R&A if < 45kg Recluirements wilt he foll~)wed during the RA if > 45 kg is generated
annually.
Maine lIazardnus Waste AI'plicahlc I'rovides reqnircmcnts fur identificaiion of hazardous waste, generators
Regulations-Code of Maine and transpurters of hazardous waste. Since peDs over 50 ('I('Im are
Regulations IUI7JIfCIIIUS in Maine, these regulations are' applicable tn the identification,
CMR 850, 851, 853 gcncratiun and transpnrtation of hazardous waste. Requirements will he
follnwcd dnring the RA.
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Table 2 (Continued)
SUPPLEMENTAL ARARs (POST-ROD)
. ACTION ARAR STATUS REQUIREMENT SYNOPSIS
Disposnl In Mnine ~olid Wash:' Rcgulnliuns Al'l'licnhlc l(c11"ircll1cnls fur suil cunlnminnlcd wilh PCIJ!i < 50 ppm. Applicahle 10
Offsile .Specinl Wnstes. Ihuse suils cunlaining less than 50 ppm rCDs. Requirements will be
l...nndfill CM R 405 fillluwcd dming Ihe RA, unless exeml't.
EP A RCRA Oenemtor Stnndnnls R&A Provitfes requirements for generators of hazardous wastes. There are no
40 CPR 262 RCRA hnznrdou!i waste at the site; however, PCDs over 50 ppm 8re
fUllAmlnus in Mninc; therefore, it is relevnnt nl\ll aPI,rnprinte.
pcn Spill Cleanup Policy To nc Cnnsiclered J:slnhlishcs criteria EPA will use to determine adequncy of cleanup of
40 CFR 161.120-161.135 sl,i11 s rcsulliug f mm the rclense uf nllltcrinls contnining pcns al
concentrntions L. 50 ppm. Policy applies to spills which occur after
514187. To he cunsidered since spill occurred before 514181.
Ouidance on Remedinl Actions To ne Cunsiclered Provides EPA guidance for PCD remediation aClivilies al Superfund sile.
fur Superfnnd Sites with pcn These guidelines will he considered since Ihe remedial aClion is an EPA
Cuntaminalion rcmt."diatiun of a SUI1Crfund sile contaminated with PCDs.
OSWER Direclive
EPA 54010-90/007 (AUllllsl '90)
EPA Office of Offsile Policy To nc Cuusiclcred Provides aprroval for offsile disposal fncililies. Aprlicable for offsile
Approval' clisrnsnl of pcns. Requiremenls will be followed 'during the RA.
1I'1..ml\
'}
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Table 2 (Continued)
APPLICAnIUTY or LAND RAN (40 erR 268)
ACTION ARAR STATUS HEQlIIRI1MI1NT SYNOPSIS
Disposal in RCRA-land Dan Apl,licahle Nn RCRA-lisled w:lslcs are known 10 exist onsile. A review of all analytical dala from
Orrsit~ landfill (40 crR 268) soil sllll\l'les indicllted there wcre no RCRA-characteristic wastes within the area fur.
excllvation and disl'0s:ll offsite. Since there arc no RCRA wastes for offsite disposal,
this re'lnircmcnt is only IIl'rlicllhle if a RCRA characteristic waste is identified after
excnvlltion (i.I:., hy Ihe disrosal fllcility waste screening rrocess).
Consolidation of RCRA-Lnml nnn, Arl,licllhlc No RCRA-listcd wastes nre known to exist onsite. A review of all analytical dnla from
Soil Onsite (40 crR 268) soil slllnl'les imlicllted only 2 detect inns of chnnninm (mlt of 42 8I1mpll:s) which conld
potcntinlly filii the TC limits. (All other TC constituents were at levels which would
nnt exceed TC limits). Uowever, the chromium levels were estimated values and would
I'0tentinlly cxeeed TC chromium limits only if 100% leaching occurred. rurthermore,.
thcse suils wuuld hc consolidakd within the Mme area of contamination, 50 -I,lacemcnt-
wOII!dnnt oeenr. Since placemcnt wllllid not IIccur, Land nlln would not he triI1Gcn:d.
These rCII"ircmcnts are emly IIpplicahle if placement occurs.
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ATTACHMENT C
RECORD OF DECISION AKBNDHEN'r
PINETTE'S SALVAGE YARD SITE
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. ..1 .---Z5-'~ T\.E 09'04 ID' TEl.. ..:), ~}-z6 .4fJm PIll
".\~~~:f~ STATE OF MAINE .
(8) . ~~=:MENT OF ENVIRONMENTAL PRO~~':N
'1;",,, ",,,,,~ ~ . COMM\IIOIP
DIMIM "ICMMO
CINn' =MMIIIIONIR
May 12, 1993
PaullCeoulh
. Acdnl Restona1 AdminisuatOr
U.S. Bnviromnentll Protection Aaency
1FK Buildlna (HPS-cAN1)
Boston MA 02203-2211
Subject: ROD Amendment for Pinette's Salvage Yard
Dear Mr. K.eou8h:
The Maine Department of Environmental Protection has reviewed the May 10, 1993
Draft Record of Decision Amendment (R.OD) with regard to the Alternative Rcmedial
ACtion Remedy for the Pinette Salvage Yard Superfund Site in Washburn, Maine. The
Department concurs with th:e amended selected remedy based upon an understanding
that: I
A.
Soils contaminated with PCB's at concentrations greater than ~OO ppm. will be
Sent off-lite for incineration. .
s.
Soils contaminated with PCB '5 at concenuations greater than or equal to 50 ppm
and less than '00 ppm will be disposed of oft. site at a federally permitted Toxic
SubStlnCes Control Act (TSCA) secure Iandfi11. .
Soils contaminated with PCB's at concentrations pter than or equal to S ppm
and less than '0 ppm will be disposed of off.site at either a federally permitted
TSCA aecme 1andfU1 or a Maine licensed special waste facility,
c.
D.
The Department's financial obligations for this site w~ be 11m1ted to a maximum
of ten percent of the costs of the remedial action including aU futUre maintenance.
Based upon the State Superfund Contract. the Department's cast share will not
exceed $732, 776 dollarS. .
E.
A review wUl be conducted within five years after commencement of the
remedial action to ensure that the remedy continues to provide adequate
protection af human health and the enviro
Pootolt' brand ~ 7171 ...-.
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The Departmen~ shan receive monthly status reportS from the BPA contractcr.
and will be awarded rcuonable opportunity to review monitcrin, plans and
participate in any meetinp rc,arcSinl this site. .
The Depanmeni looks forward to working with the EP A to resolve the environmental
problems posed by dUs site.
f.
Sincerely, 17
,((;.tu." t, I ~f." ''ff--
Dean C. Mmiott .
Commissioner
cc: Michael Barden
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