United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R01-93/079
July 1993
PB94-963710
&EPA Superfund
Record of Decision
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50272-101
REPORT DOCUMENTATION I 1. REPORT NO. 2. 3. Recipient's Accession No.
PAGE EPA/ROD/ROl-93/079
4. Title and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 07/21/93
"Lrnemaster Switch, CT 6.
First Remedial Action - Final
7. Author(s) S. Performing Organization Rept. No.
9. Performing Organization Nama and Addr..a 10 Project TsskIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(0)
12. Sponsoring Organlllltion Name and Add,... 13. Type of Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplement.ry Note.
PB94-963710
16. Abstract (Llmh: 200 words)
The 90-acre Linemaster Switch site is a manufacturing facility located in Woodstock,
Connecticut. Land use in the area is predominantly residential and commercial, and
includes woodlands, grass meadows, wetlands, several ponds, and streams. The aquifer
under the site is classified as a potable water source and used for residential and
commercial purposes. The site was used for small-scale farming and for residential
purposes until 1952, when Linemaster began to manufacture foot-operated switches at the
site. Solvents, including paint thinners and TCE, were utilized onsite as part of
Linemaster's degreasing and spray painting operations. Between 1969 and 1979,
Linemaster used an estimated 100 to 600 gallons per year of TCE, and subsequently
disposed of approximately 20 to 200 gallons per year in an onsite dry well located to
the east of the manufacturing building. Beginning in 1980, the State and EPA conducted
several site investigations which indicated the presence of VOCs, including TCE, in the
drinking water supply at concentrations above drinking water standards. In 1986, the
State required Linemaster to design and implement an Interim Removal and Treatment
System (IRTS) to address ground water contamination and remove the former dry well and
its contents. Design of the IRTS began in 1987, and it was implemented in 1992,
reducing present contaminant levels in offsite ground water to' below drinking water
(See Attached Page)
17. Document Anslysls s. D8sc:rlptors
Record of Decision - Linemaster Switch, CT
- First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), metals (arsenic)
b. Identlfle"'Open-Ended Terms
c. COSATI FleldlGroup
1S. AvsUablllty Statement 19. Security Class (This Raport) 21. No.olPagas
- None 114
20. Security Class (ThIs Page) 22. Prlca
None
(S.. ANSI-Z39.1S)
SHlnstructions on Rel/erse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS.3S)
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EPA/ROD/ROl-93/079
Linemaster Switch, CT
First Remedial Action - Final
Abstract (Continued)
standards. In 1989, the dry well and 1,000 gallons of hazardous liquid also were removed
offsite. In 1987, EPA required Linemaster to perform a site investigation and drinking
water well monitoring program and, if necessary, provide alternate water supplies in the
vicinity of the site. In 1991, EPA required Linemaster to perform a second, more
detailed, site investigation that confirmed contamination of the aquifer beneath the site,
and identified an area of soil contaminated with VOCs in the vicinity of the manufacturin~
building and former dry well. This ROD addresses a final action for soil contamination in
. these areas and ground water contamination in the aquifer beneath the site. The primary
contaminants of concern affecting the soil and ground water are VOCs, including benzene,
PCE, TCE, toluene, and xylenes; and metals, including arsenic.
The selected remedial action for this site includes installing an in-situ vapor extraction
system to extract soil vapors, followed by treatment with carbon filters to remove VOCs
from the vapors prior to discharge as air emissions; dewatering the soil in conjunction
with the vapor extraction process; conducting periodic soil sampling to evaluate the
effectiveness of the remedy; providing a contingent remedy for enhancing the vapor
extraction with air sparging, if the sample analysis indicates slow removal of the VOCs;
fencing the area of soil contamination; continuing operation of the existing ground water
extraction and treatment system, which consists of air stripping followed by carbon
adsorption, with discharge of the treated water onsite to surface water and the air
emissions to the atmosphere; treating any contaminated water from the soil dewatering
process within this system; providing a contingent remedy for using ultraviolet oxidation
instead of air stripping, if this treatment becomes more cost effective in the future;
monitoring onsite and offsite ground water; and implementing institutional controls,
including deed and ground water use restrictions. The estimated present worth cost for
this remedial action is $3,249,000, which includes an estimated annual O&M cost of
$2,733,000 for 35 years. The estimated present worth c~st for the contingent remedy is
$4!459,000, which includes .an estimated annual O&M cost of $3,572,000 for 35 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil cleanup goals are based on protecting the quality of ground water
in the vicinity of the site and were developed using a predictive leachate model (Summers
Model), and include PCE 10 ug/kg; TCE 5 ug/kg; toluene 1,000 ug/kg; and xylenes 100 ug/kg.
Chemical-specific ground water cleanup goals are based on SDWA MCLs, State standards, or
riSk-based levels, if standards are not available, and include arsenic 50 ug/1; benzene 5
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",v
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~ u
u.s. ENVIRONMENTAL PROTECTION AGENCY
REGION I
RECORD OF DECISION
LINEMASTER SWITCH CORPORATION SUPERFUND SITE
WOODSTOCK, CONNECTICUT
"
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o4I'~'O 874~
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING. BOSTON, MASSACHUSETTS 02203-2211
Q"
DECLARATION FOR THE RECORD OF DECISION
LINEMASTER SWITCH CORPORATION SUPERFUND SITE
WOODSTOCK, CONNECI1CUT
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for the Linemaster Switch
Corporation SupcIfund Site in WoodstOCk, Connecticut, developed in accordance with the
Comprehensive Enviroiunental Response, Compensation and Liability Act of 1980 (CERCLA),
as amended, 42 U.S.c. ii 9601 ~ sea. and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), as amended, 40 c.F.R Part 300. The Region I Administrator has been
delegated the authority to approve this Record of Decision (ROD). .
The State of Connecticut has concurred with the selected remedy.
STATEMENT OF BASIS
This decision is based on the Administrative Record which has been developed in accordance
with Section 113(k) of CERCLA and which is available for public review at the Bracken
Ubrary, Academy Road, Woodstock, Connecticut, and at the Region.1 Waste Management
Division Records Center in Boston, Massachusetts. The Administrative Record Index
(Appendix E to the ROD) identifies each of the items comprising the Administrative Record
upon which the sel~on ~f the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to the public bealth or welfare or to the environment.
"'O"S.T.O.,..
. .
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.. SAVEm -
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.
.
DESCRIPTION OF THE SELECTED REMEDY
This ROD sets fanh the selected remedy for the Linemastcr Switch Corporation Superfund
Site. which includes both source control and management of migration components to obtain
a comprehensive remedy.
The major components of the seleCted source control remedy include:
.
In situ vacuum extraction of contaminated soil to remove volatile organic compounds
(V0Cs). Carbon air emission controls will prevent the transfer of VOCs from the
soils to the atmosphere. Soil cleanup levels will be achieved within an estimated three
to ten years. After the vacuum extraction system has been operating for five years,
EPA will evaluate the effectiveness of the system and determine whether the soil
cleanup levels will be achieved within the projected ten-year period using vacuum
extraction alone. If, at that time. EP A determines that the soil cleanup levels will not
be achieved within the projected ten-year period using vacuum extraction alone, the
vacuum extraction system will be enhanced with air sparging or other enhancement
technologies to assure that the soil cleanup levels will be attained within the projected
ten-year period;
.
Institutional controls, that shall consist of a fence surrounding the contamination
source area to restrict access to this area; and
.
An environmental monitoring program.
The major components of the selected management of migration remedy include:
.
Extraction of contaminated groundwater from the overburden and bedrock using
extraction wells;
.
Treaanent of contaminated groundwater using air stripping with carbon air emission
controls. Discharge of treated groundwater to an on-site pond. If current cost
estimates change over the course 'of the remedial action to the extent that ultraviolet
oxidation 1CChnology is determined to be more cost-effective than air snipping, EPA
may implement ultraviolet oxidation in place of air stripping at any time during the
performance of the groundwater cleanup;
.
An environmental monitoring program to include, at a minimum, monitoring on-site
and off-site groundwater monitoring wells and drinking water supply wells. The
monitoring program shall operate until the groundwater is restmed to drinking water
standards at the Site and.is protective of human health and the environment, which is
predicted to occur within 3S years.
Institutional controls that shall include, at a minimum, deed restrictions 10 prevent the
use of untreated contaminated groundwater until the cleanup levels are met
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DECLARATION
Q<,
The selected remedy is protective of the human health and the environment, attains federal
and state requirements that are applicable or relevant and apploptiatc for this remedial action,
and is cost-effective. This remedy satisfies the statutory preference for remedies that utilize
treatment as a principal clement to rcdoce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
t~gh~
Acting Regional Administrator
U.S. EPA, Region I
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vn.
v
IlL
IX.
Contents
L
n.
m.
IV.
v.
VI.
ROD DECISION SUMMARY
LINE~~TER SWITCH CORPORATION SITE
. .
. TABLE OF CONTENTS
Pa2e Number
SITE NAME, LOCATION AND DESCRIPTION.
.... .... .... ... ... .........
SITE HISTORY AND ENFORCEMENT ACTIVITIES
.......................
COMMUNITY PARTICIPATION
...~..................................
SCOPE AND ROLE OF RESPONSE ACTION
.............................
SUMMARY OF SITE CHARACTERISTICS
A.
B.
C.
D.
E.
F.
...... .......... ....... ... ....
SoD. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Overburden Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Bedrock: Grounclwater- ..........................................
Surface Water and Sediments
. .... ... ... ....... .... ... ..........
Air [[[
Water-Supply Wells
. ....... ... ... .... .......... .... ....... ...
S'UMMARY OF SITE RISKS ................................... ... . . . . .
A.
Human Health Risk Assessment .... . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . .
B.
C.
1.
2. Activities and Receptors. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3. Expomre Pathways . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Risk Characterization' ..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
I.a.nd Use ..............................................
Ecological Risk Assessment
.... ..... .............. ..............
DEVELOPMENT AND SCREENING OF ALTERNATIVES
A.
B.
...................
Statutory RequirementslResponse Objectives. .. . . . . . . . . . .. . .. . . . . . .. .
Technology and Alternative Development and Screening. . . . . . . . . . . . . . . .
DESCRIPTION OF ALTERNATIVES
A. Source Control (SC) Alternatives Analyzed
B. Management of Migration (MM) Alternatives Analyzed. . . . . . . . . . . . . . . .
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES.......
A. Evaluation Criteria
B. Summary of the Comparative Analysis of Alternatives. . . . . . . . . . . . ... . . .
1. Overall Protection of .Human Health and the Environment. . . . . . . .
2. Compliance with Applicable or Relevant an.d Appropriate
Requirements (ARARs)
. Long-term Effectiveness and Permanence. . . . . . . . . . . . . . . . . . . . .
Reduction of Toxicity, Mobility, or Volume Through Treatment
.. ...... ..... ... ..... .......... ...
. ... .......... .... .... ...
. ....... ... .... ... ... .... .... ... ........ ...
. ........ ... .... ... .... ....... ....
3.
4.
s.
6.
7.
8-
9.
Short-term Effediveness .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ImplementabDity
...... ............... .... ... ...........
Cost. . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
State Acceptance
Community Acceptance
...... ... ... ... .......... ..............
.. ..................... ...........
i
1
1
3
3
"4
4
S
6
7
7
7
8
8
8
9
9
11
12
13
13
14
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. "..
. -
Contents
x.
XI.
". ROP DECISION SUMMARy
LINEMAS'tER SWITCH CORPORATION SITE
TABLE OF CONTENTS
Pa~e Number
THE SELECTED REMEDY.. . ........... .. .............. ."........ . .. 2!J
A.
B.
C.
Interim Groundwater Cleanup Levels. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2!J
Soil Cleanup Levels .... . . .". . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 31
Description or Remedial Components. . . . . . . . . . . . . . .. . . . . . . . . . . . . .. 32
1. Source Control Component. . .0. . . . . . . . - . . . . . . . . . . . . . . . . . . . . 32
2. Management or Migration Component........ ............... 34
3. Other Components or the Selected Remedy. . . . . . . . . . . . . . . . . . .. 38
STATtrrORY DETER?fINATIONS ................................. -. 39
A. The Selected Remedy is Protective or Human Health and the Environment.. 39
B. The Selected Remedy Attains ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . . - .. 40
C. The Selected Remedial Action is Cost-Effective. . . . . . . . . . . . . . . . . . . . . .. 42
D. The Selected Remedy Utilizes Permanent Solutions and Alternative
Treatment or Resource Recovery Technologies to the Maximum Extent".
Practicable. . . . . . - - . . . . . . . . . . . . . . . - . . . . . . . . . - . . . . . . . . . . . . . .. 44
The Selected Remedy Satisfies the Preference for Treatment Which.
Pennanently and Significantly reduces the Toxicity, MobDity or Volume or
the Hazardous Substances as a Principal Element. . . . . . . - . . . . . . . . . . . .. 4S
XII.
DOCUMENTATION OF SIGNmCANT CHANGES -................... -.. 486
xm. STATE ROLE
E.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . .. 47
,
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ROD DECISION SUMMARy
L~~R SWITCH CORPORATION Sm:
I
I.
APPENDICES
APPENDIX A . nGtJRES
APPENDIX B . TABLES
APPENDIX C - RESPONSIVENESS SUMMARy .
APPENDIX D - STATE OF CONNECTICUT CONCURRENCE LEI IU{
APPENDIX E- ADMINISTRATIVE RECORD INDEX
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...
ROD DECISION
Linemaster Switch CorDoration Site
Page 1
I.
SITE NA}IE, LOCATION AND DESCRIYrION
The Linemasrcr SwitCh Corporanon Site (the Site), is located on PIaine Hill Road in the Town of
Woodstock, ConneCticut (Appendix C, Figure 1). The Sire is bounded on the north and east by
Route 169, on the west by PIaine Hill Road and on the south by State Route 171. The Site consiStS
of 90 acres of land, and is located on a hill.
Prior to 1952, the Sire was used for residential pmposes and small scale farming. Starting in 1952,
the Linemasrcr SwitCh Corporation (Linemaster) began manufactUring foot operated switChes at the
Site. Currently, Linemaster manufaCtures electrical power switChes, air valves, electrical cord sets
and metal name plates at the Sire. Linemasrcr's manufacturing building is located near the center
the Site, and on its topographic high point.
In addition to Linemastcr's manufacturing facility, several residential parcels and a commercial
parcel, on which a restaurant is located, are also located on the Site. These parcels are owned by
Linemaster's principal shareholder.
The Site includes woodlands, grass meadows, wetland areas, and several ponds and streams. The
wetlands are located primarily on the perimeter of the Site at the bottOm of the hill near Route 169.
The aquifer under the 'Site is classified as GA by the State of Connecticut Department of
Environmental Protection (CI' DEP), or suitable for direct human consumption without the need for
treatment.
The Site is surrounded mainly by residential property, with mOSt of the nearby residences located to
the northeast, cast and southeast. Linemaster as well as all other residential and COmnku.;ial
property located on and in the vicinity of the Site obtain their drinking warcr from individual
bedrock and overburden wells.
A more complete dcsaiption of the Site can be found in the "Remedial InvestigationlFeasibility
StUdy, Linemasrer S\\.;tCh Corporanon, Woodstock, Connecticut,. December 1992, in Section 1 of
Volume 1
n.
SITE IUSTORY AND ENFORCEMENT ACTIVITIES
Prior to 1952, the Site propeny was used for residential purposes and small scale farming. In 1952,
Linemaster began manufacturing foot operated switChes at the Site. As pan of Linemastcr's
manufacturing 'operations, paint thinner, trichIoroethene (TCE) and other chemicals wcrc used.
Paint thinner use began in 1952.for a spray painting operation. From 1969 through 1979, TCE was
used for vapor degrcasing Operations. Reportedly, the esrimflted amount 'of TCE used between
1969 and 1979 was approximately 100 to 600 .gallons per year. Of this amount, approximately 20
to 200 gallons per year were disposed of in a dry well located to the cast of Lincmaster's
manufacturing building. The exact amount of TCE and other wastes discharged to the dry well is
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ROD DECISION
Linemaster Switch CorDoration Site
Page 2
~ - .-
In 1uly 1980, cr DEP conducted a Site inspectton of the facility pursuant to the Resource
Conservation and Recovery ACt (RCRA) and, in 1uly 1984, it conducted a Preliminary Assessment
pursuant to the Comprehensive Environmental Response, Compensation, and Liability ACt
(CERQ..A). Following a review of cr DEP's reportS, EPA conduCted Site investigations in
December 1985 and February 1986. During both the CT DEP and EPA's investigations,
groundwarcr samples WCl'C taken from Linemasrer's production wens and several ICSidcntial war.er-
supply wells located near the Linemasrer facility. Results of sampling and analysis indicated the
presence of voIatile organic compounds (vOCs), primarily TCE, at levels above the Stare and
federal drinking water Standards.
On April 8, 1986, CT DEP issued an Abatement Order to Linemasrer requiring the company to
investigate the eXtent of groundwater, surface water and soil contamination, and to take actions
necessary to min1m1~ or eliminate the contamination. In February 1987, pursuant to the
Abatement Order, Linemaster initiated investigations and thereafter began to design an Interim
Removal Treatment SyStem (IRTS) to address groundwater contamination.
On September 24, 1987, EPA and Linemasrer signed an Administrative Order By Consent under
which LineI113Stcr agreed to perform a Site investigation and a drinking water wen monitoring
program, and to provide alternate water supplies, as necessary, in the vicinity of the Site.
In June 1989. pursuant to the CT DEP Abatement Order, Linemasrer removed the former dry well.
At that time, approximately 1,000 gallons of hazardous liquid were removed from the wen and
disposed at a licensed hazardous waste Storage facility.
On February 15, 1990, EPA added the Linemasrer Switch COIpOration Site to the National Priorities
List (NFL) making it eligIole to receive federal Superfund monies for investigation and cleanup..
On September 30. 1991, EPA and Linemasrer entered into a second AdminiStrative Order By
Consent under which Linemasrcr agreed to conduCt a Remedial Invcsligation/Feasibility Study
(RIIFS) at the Site under EPA supervision.
In June 1992, pursuant to the cr DEP's Abatement Order, Linemasrcr implemented the In~
RcmovalTreatmcnt SyStem (IRTS). The IRTS extracts contaminaled groundwarcr from six on-sire
bedrock weDs. The contaminated groundwarcr is ttcatcd to drinking water standards using an air
saippcr followed by activated carbon and is discharged intO an on-site pond Currently the
emissions from the air stripper discharge to the aanosphere untreated.
Lincmastcr' hired a contractor to perform the RIlFS. In August 1992, Linemasrcr's contractor
submitted the first draft of the RJ/FS to EPA. In a letter dated September 29, 1992, EPA provided
its comments on the first draft of.the RIlFS to Linemaster. In December 1992, Linemasrcr's
contractor submitted a revised draft RIlFS to EPA. In a letter dated March 31, 1993, EPA provided
its comments on the revised draft RIlFS to Linemaster. Linemaster's contractor responded to
EPA's comments in a final addendum to the RJ/FS, dated April 13, 1993.
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ROD DECISION
Linemaster Switch COrDoration Site
Page 3
.
Linemastcr has been active in the remedy selection process for the Site. Technical comments
presented by Linemaster during the public comment period have been included in the
Administrative Record. A summary of these comments as well as EPA's responses are included in
the Responsiveness Summary, Appendix C of this document
.: ,
A more detailed description of the Sire history can be found in Section 1 of V olumc I in the
Remedial InvestigatioD/Feasibility Study report (December 1992) at pages 6-7.
m. COMMUNITY PARTICIPATION
Throughout the Site's histOry, community concern and involvement has been minimal. EPA has
kept the community and other interested parties apprised of the Sire activities through'infomwional
meetings, fact sheets, press releases and public meetings.
In 1987, EP A released a community relations p~ which outlined a program to address community
concerns and keep citizens informed about and involved in activities condUCted at the Site. On
June 12, 1991, EPA held an informational meeting in the Woodstock Town Hall to describe the
plans for the Remedial Investigation and Feasibility StUdy (RJIFS). While fiDa1i~f1g the RIlFS,
EP A conducted interviews with local citizens and officials in February and March of 1993 and
updated the community relations plan. The RIlFS, and final addendum to the RIlFS, were
completed in April 1993. On Aprill, 1993, EPA published a notice in a local newspaper
announcing the availability of the final RI/FS and presenting a brief ,description of the Proposed
Plan.
On April 14, 1993, EPA held an informational meeting in the Woodstock Town Hall to discuss the
results of the Remedial Investigation, the cleanup alrcmatives presented in the Feasibility Study and
the Agency's Proposed Plan for the remediation of the Site. A1so during this meeting, the Agency
answered questions from the public. EP A made the administrative record available for public
review at EP A's offices in Boston and at the Bracken Library in Woodstock, Connecticut on April
15, 1993. From April 15, 1993 to May 14, 1993, the Agency held' a thirty day public commcnt
period to accept public comment on the alternatives presented in the Feasibility Study and the
Proposed Plan and on any other documents previously released to the public.
On May 5, 1993, the Agency held a public hearing to discuss the Proposed Plan and to accept any
oral comments. A transcript of this meeting, and a summary of the commentS and the Agency's
'response to comments arc included in the Responsiveness Summary, Appendix C of d1is document
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected. remedy was developed by combining components of different source control and
management of migration alternatives to obtain a comprehensive approach for Site remediation. In
swDnwy, the remedy provides for the following: reducing the VOCs in the soil within the Zone 1
area; preventing continued release and further migration of ~us substances to the groundwater
(and therefore to the surface water as well); restOring contaminated groundwater' to drinking water
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ROD DECISION
Linemaster Switch CorDoration Site
Page 4
- -
The principal threat to human health and the environment that will be addressed by this remedial
action is the ingestion of COntIDnif1ated groundwater.
v.
SUMMARY OF SITE CHARACTERISTICS
Chapter 9, Volume IV of the Remedial Investigation/Feasibility Smdy contains an overview of the
Remedial Investigation. The significant findings of the Remedial Investigation are summarized below.
Four source areas (labeled Zone I, Zone 2, Zone 3, and Zone 4) were investigarcd during the RI.
The results of the investigations are presented below.
A.
Soil
Zone 1: former dry well and paint settling booth.
Based on the results of the RI. the Zone 1 area is considered to be the primary source area
for this Site. Elevated levels of volatile organic compounds (v0Cs) are present in the Zone
1 soils due to the disposal of hazardous subStances into the dry well, which was located in
this zone. VOCs are also present under Linemaster's manufacturing b~g (which was
not specifically included in any defined zone for pmposes of the RI. but is considered to be
part of Zone 1 for purposes of the remedial action). Due to the difficulties associated with
sampling beneath the building, the magnib1de and extent of VOCs under the building is
. unknown, though it is estimated that approximately 38% of the contaminated soil at the Site
is located directly under Linemaster's' manufacturing building.
In the Zone 1 area. the maximum concentration of TCE detected was found at levels
exceeding 4000 parts per billion (Ppb). This concenttation represents a 1cvel that is eight-
hundred (800) times the cleanup 1cvel for TCE of S, established for the remediation of the
soils pursuant to this ROD~ as provided in Appendix B, Table 17.
Low levels of semi-volatile organic compounds (SVOCs) were detected in samp1cs from this
area but these contaminants were determined to be from laboratory contamination and are
not considered to be of significant concern.
The ranges of nab1ral1y occurring metals concentrations in soils were established based on
the analytical results from soil samples collected from eight locations both on and in the
vicinity of the Site. The concenttations of metals in soil samples collected during the RIlFS
investigations were compared to the m:n~imum background concentration for each mew to
identify. areas where elevated concenttations of metals were present
Elevated concentrations of arsenic, barium. cadmium. chromium, lead, and zinc were
identified in soil samples collected from Zone 1. Concenttations of these metals were
highcst in the vicinity of the former dry well and generally increased with depth, suggesting
that the concenttations may be related to the presence of metals in the overburden
groundwater. Elevated concentrations of arsenic, chromium, and lead detected in samples
collected from the fanner paint settling booth location may be due to the presence of
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i ,
ROD DECISION
Linemaster Switch Corooration Site
Page 5
.
The primary exposure area (Zone 1) is cunently capped with a pOlypropylene COver to
reduce exposure, rainwater inf1ltration and fugitive dust
A more detailed summary of contaminants can be found in Tables 1 and 2 in Appendix B.
Zones 2, 3 aDd 4: former facility wastewater disposal system, fonner Blakely residence
leaching field, and the paint shed area. ,
Soil sampling conduCted in Zones 2 and 3 contained low and non-detectable levels of
VOCs. This contamination is likely from the migration of contaminated groundwarcr from
Zone 1. Due to the slightly elevated levcls of VOCs in the Zone 4 area, Zone 4 was
incorporated into the Zone 1 areal Ji.e.. the primary source area) for the Feasibility Study.
SVOCs were deteCted in Zone 4. However, this contamination is suspected to be from
minor fuel ~leases and not considered to be of significant concern.
. '
Concentrations of cadmium, chromium, lead, selenium, and zinc exceeding the maximum
background soil concentrations for these metals were detected downslope of the brick dry
well in Zone 2. The slightly elevated concenttations in these samples may be related to
metals leaching out of plumbing fixtures and piping, or may be associared with the
discharge of facility wastewater to the brick dry well. In addition, slightly elevated
concentrations of several metals were detected in Zone 3 soil samples collected in the
vicinity of the former Blakely leaching field These Zone 3 soils are not believed to have
been significantly impacted by historical Site operatio~.
In Zone 4 soil samples, barium, cadmium, chromium, and nickel were the metals that most
commonly ex~' the maximum background concentrations. A genemI trend of
increasing metals concentrations with depth suggests that the elevated concentrations of '
these metals in the Zone 4 soils may be influenced by metals which are naturally occurring
in ,the overburden groundwater. Elevated levels of arsenic concentrations were only detected
in the soils and fill material present irTm1ediately below the paint shed floor.
B.
Overburden Groundwater
The RI found that VOCs, mainly trichloroethene (TCE), are migrating from the Zone 1
source area to the northwest, north, northeast, east, southeast and southwest through the
overburden soils (Figure 2, Appendix A). The primary direction of flow is to the east-
nonheast following the natural hydraulic gradient Dming low flow seasons, groundwater
discharges from the overburden into the surface water bodies near the Study area boundaries.
I Heruzfter in this ROD, all refertJU:es to Zone 1 shtzll mean both the orea lDbeled as Zone I
tlIId the orea /Qbekd as Zone 4 in the RI. as well as the oretl of contaminated soils 10caud
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The highest concentrations of tOra! VOCs were 817,000 ppb, found in overburden
groundwater at the angled monitoring well with the screen located underneath Linemastcr's
manufacturing building. High tOra! VQC concentrations were also found downgradient of
Linemaster's manufactUring building, within 10 ~eet of the former dry well location
(420,507 ppb). The exrrcmely high VQC concentrations at both these wells indicate that a
significant amount of the contamination Still remains in the Zone 1 area.
Some SVOCs were detected at low levels in groundwater samples. However, the presence
of these compounds was determined to be from laboratory contamination only, and therefore
is not of significant concern. .
Slightly elevated concentrations of tora! arsenic, beryllium, cadmium and nickel were .
identified in Zone 1 monitoring wells. These compounds are believed to be naturally.
occuning.
All contaminants found to date have been dissolved in the surrounding groundwater.
However, due to the high levels of TCE detected, TCE may exist as an undissolved liquid
referred to as free phase Dense Non-Aqueous Phase Liquids (DNAPLs). Because current
technology cannot easily locate free phase DNAPLs, their possible existence is based on
circumstantial evidence at this Site, and the amount of free phase DNAPLs, if they exist, is
not possible to determine. If pockets of free phase DNAPLs are slowly' dissolving and
contarmnating surrounding groundWater, then they may continue to be a long-term source of
contarmnation in the aquifer.
c.
Bedrock Groundwater
VOCs and TCE are also migrating from the Zone 1 source area in all directions in the deep.
bedrock. Like the overburden groundwater, the primary direction of groundwater flow in
the deep bcdroc1c is also to the east-northeast, which appears to coincide with the two major
fracture traces. Groundwater migrates horizontally at a higher rate in the deep bedrock than
in the sha1low bedrock at the Site (Figme 3, Appendix A). Although the shallow bedrock is
more weathered, the deep bedrock has larger and more transmissive fncture openings.
Relatively high horizontal groundwater flow velocities were calculated for a number of deep
bedrock wells. During certain seasons', groundwater also discharges from the bedrock to the
ponds on the eastern portion of the Sile.
Under the Safe Drinking Water Act, EPA has set Maximum Contaminant Levels (MCLs) as
safe standards for drinking water. The MCL for TCE is 5 ppb. The highest concentration
of TCE found in the deep bedrock on-site was 58,000 ppb, which significantly exceeds the
MCL for TeE. Most of1he contamination detected off-site during the RI was detected in
the bedrock.
Since the implementation of the Interim Removal Treatment System (IRTS), pursuant to cr
DEP's Abatement Order, the contamination found in all off-site bedrock wells no longer
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Linemaster Switch COl"Doration Site
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. .
A more detailed summary of the contaminants found in the bedrock groundwater can be
found in Table 4 in Appendix B.
D.
Surface Water and Sediments
. "
Low concentrations of VOCs have been detected in surface water samples collected from
Ponds 1.2, and 3 and in sediment samples collected from Pond 1. TeE. cis-l,2-
dichloroethene. and chloroform arc the VQCs that have been detected in surface water
samples. Cis-l,2-dichloroethene was the only VQC detected in the sediment samples.
The presence of VOCs in the surface waters and sediment in Pond 1 arc believed to be
related to recharge by the contaminated groundwater and may also be related to the
discharge of Pond 3 overflow into the eastern Stream syStem just nonh of the inlet to Pond
1. The low conccntrations of chloroform detected in Pond 2 arc believed to be the result of
laboratory contamination. The VOCs deteCted in Pond 3 arc believed to be related to the
. diversion of contaminated groundwater to the pond by the Blakely leaching field curtain
drain.
Low levels of arsenic. chromium and lead were the only metals detected in both the surface
waters and sediments. Their presence is believed to be the result of natural accumulation.
No SVOCs were detected in the surface waters and sediments at the Site. .
E.
Air
During the RI, an air pathway analysis was performed for the TCE sources at Lincmaster.
The sources of TCE evaluated included an area source overlaying the TCE contamin!l~d
groundwater and two air Strippers utilized to remove TCE from the groundwater. The
highest concentration was eStimated to occur within 100 meters of Linemaster's
manufacturing building. The cmrcnt levels of air emissions were not found to cxcccd
applicable federal or state laws or regulations.
F. .
Water-Supply Wells
Elevatcci levels of VOCs were detected in on-site water-supply wells and in several water-supply
wells surrounding the Sire. The somcc of these contaminants was found to be the Site.
Carbon filter ttcatmcnt systems are cmrcndy being used at on-site water-supply wells to
etiminate the risk associated with ingestion of on-sire groundwater.
The levels of contamination in the on-site and off-site water-supply wells increased from
1986 to 1.988. During this time. TCE was detcetcd at concentrations above MCLs (i.e..
above 5 ppb) during more than one sampling event at four active off-site water-supply wens.
Since 1988, and the implementation of the IRTS. the levels bave decreased to their current
level Quarterly sampling results during 1992 and 1993 have not indicated TCE
concenttations above 5 ppb at any active water-supply well outside of the Site. Linemastcr
Switch Corporation has provided carbon filter tteatmcnt systems for two of the active off-
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ROD DECISION
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Page 8
- -
A complete discussion of Site characteristics can be found in the Remedial Investigation
Repon on Pages 8-1 through 8-23. A more detailed summary of contaminants can be found
in Table 3 of Appendix B.
VI. SUMMARY OF SITE RISKS
\ .
A Human Health Risk Assessment (HHRA) and an Ecological Risk Assessment (ERA) were
performed to estimate the probability and magnitude of potential adverse human health and .
environmental effeCtS from exposure to contaminants associated with the Sire. The public health
risk assessment followed a four step process: 1) contaminant identification. which identified those
hazaIdous substances which, given the specifi~s of the Site were of significant concern; 2) exposure
assessment, which identified actual or porential exposure pathways, charactcrizcd 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
Don-carcinogenic risks. The results of the human health risk assessment for the Site are discussed
below, followed by the conclusions of ~e environmental risk assessment
A.
Human Health Risk Assessment
The number of COntamil]ants detected at many Superfund sites is often too large to fully
quantify all possible health risks. Therefore, a subset of these compounds, known as
contaminants of concem, are usually selected to serve as a focus for further risk .
characterization. However, in the HHRA for this Site, all thiny-five contaminants detected
were considered contaminants of concern (Table 5, Appendix B). A summary of the health
effects of each of the contaminants of concern can be found in Section 3, pages 24-32 of the
risk assessment
Potential human health effects associated with exposure to the contaminants of concern were
estimated quantitatively or qualitatively through the development of several hypothetical
exposure pathways. These pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future uses, and location of the Site.
1.
Land Use
The land on which the Site is located is currently zoned for industrial use. However,
portions of the Site arc used for residential purposes. It is assumed that the future
land use of the Linemaster Switch Gorporation Site will continue to include
residential purposes. The Site is also surrounded by residential neighborhoods, an
elementary school, the Woodstock Town Hall, and a few restaurants.
The businesses and residences located on and in the vicinity of the Site are known to
obtain drinking water from the overburden, shallow bedrock and deep bedrock
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-
2.
Activities and Receptors
Current populations potentially exposed to Site contaminants were considered to be
workers on the Site, trespassers, residents on the property, and residents of the
surrounding area. Current risks have been estim:ltP'd for residential chronic exposure,
and worker sub-chronic exposure.
Due to the industrial ~d residential uses of the Site, two distinct activity patterns are
believed to be prevalent on the Site. The first is maintenance activity penaining to
the manufacturing facility and grounds, the second is residential exposure assnciated
with typical play activities of young children and outdoor activities of adults (e.g.
landscaping, gardening, and jogging). In addition, a variety of wort activities have
occurred on the Site including: erosion conttol projects; instaIIation of drainage
systems; and landscaping of the grounds.
Small children have been identified as the primary sensitive sub-group. It is likely
the children will enter the Site for a range of reasons including: to take a shOrt-cut
from one residential allotment to another; to explore nature; and to visit the three
smface water bodies on-site.
Future populations potentially exposed include the current populations and other
workers present at the Site for limited time periods during the COnstruction of the
remedy. Future risks have been quantified for residents only, as residential
exposures are generally of longer duration and the parameters used to estimate risk
for worker exposure will not change from current land use to future land use.
In the future, the current activities were assumed to continue on the Site. . Additional
activities associated with the building of new residences were also assumed to occur
in the futUre.
3.
Exposure Pathways
The information collected on activities .associated with the Site and the surrounding
area is used to characterize the Site with respect to the physical environment and the
potentially exposed populations. Cmrent and future contami"ant migration pathways
are identified that could resUlt in human exposure to the contaminants originating at
the Site. The pathways that were selected for quantitative evaluation are those
considered to pose a significant. risk to human health. These pathways are described
in more detail below.
Inresnon of Groundwater
Cmrently, groundwater originating from the overburden. shallow bedrock and deep
bedrock aquifers under and in the vicinity of the Site is used as a potable water
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The futUre construction of new residences will most likely result in the continued use
of the aquifers as untreated drinking water sources. Potentially exposed populations
include future adult and child residents.
Risks were estimated for groundwater ingestion under the C1U1'Cl1t scenario. Risks
calculated for current exposure from the ingestion of groundwater are identical to
future exposure scenarios.
\ '
InI~estion of Soil
The primary exposure area (Zone 1) is currendy capped with a polypropylene cover.
However. this cover is not assumed to keep trespassers out and/or work activity from
occmring in this area. and therefore contact with the surface soil is likely on these
occasions by trespassers and workers. Potential risks were characterized assuming
trespassers will gain access to the somce area through unattended or open gates.
In the future. the construction of residences. utilities and the remedy are assumed to
occur. Following construction exposure. potential exposures include incidental
ingestion of excavated sub-surface soil brought to the surface during gardening.
landscaping. recreational. and construction activities.
Risks were estimated under current land use for chronic adult and child exposure to
surface soils of Zone 1 (0-2 ft) and sub-chronic worker exposure. Under future land
use. risks were esrimated for chronic adult and child exposure to sub-surface soils of
Zone 1 (0-8 ft.).
Inhalation of VaDOl'S .
Because VOCs are currcndy present in the soil, the inhalation of vapors originating
from soils at depths of 0-8 feet, by both workers at the Site and adult and child
residents of the nearby area. is likely. However. before exposure may occur the
compounds must diffuse through the soil which will decrease their conccntration. In
addition. once the compounds volatilize in the air above the soil, additional dilution
will 0CC1D' as a result of tUrbulent mixing. For these reasons, air concentrations, even
for a potential receptor located directly above the most concentrated soils, are
expected to be minimal
Based on the water to air partitioning coefficients of the conUiminants detected in
surface water and their low concentration levels. associated inbalation risks from
surface water vapors are Dot considered to be a significant concern.
Under a future use scenario. conStruction workers could potentially be exposed to
vapors originating from sub-surface soils at depths of 0-8 feet. Residential risks
would also increase as a result of new construction potentially on or near the source
areas. While construction workers may be exposed to higher vapor concentrations
when excavating trenches. n:sidential exposures are generally of longer duration, and
therefore chronic and sub-chronic risks based on residential exposure will also be
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ROD DECISION
Linemaster Switch Corooration Site
Page 11
Risks associated with acute exposure for construCtion workers may be addressed
through a review of permissible exposure limits set by the designalCd occupational
health and safety agency. Risks due to inhalation exposure were quantitatively
evaluated for the pathway of greatest chronic exposure: future adult residentiaL.
.
.
.
In summary. the exposure pathways evaluated in the HHRA were: 1) ingestion of
overburden groundwater within the Site; 2) ingestion of bedrock groundwater within
the Site; 3) ingestion of groundwater outside and north of the Site; 4) ingestion of
groundwater outside and south of the Site; 5) ingestion of soil within the Site; and 6)
inhalation of vapors during excavation of soil within the Site. A more thorough
description of the Site risks can be found in Section 4 of the Human Health Risk
Assessment and in Table 6 in Appendix B.
For each pathway evaluated and, where possible. an average and a reasonable
maximum exposure estimate was generated corresponding to exposure to the average
and the maximum concentration detected in that particular medium.
B.
Risk Characterization
Excess lifetime cancer risks wen: determined for each exposure pathway by multiplying the
exposure level with the chemical specific ,cancer factor. Cancer potency factors have been
developed by EP A from epidemiological or animal studies to reflect a conservative "upper
bound" of the risk posed by potentially carcinogenic compounds. That is, the true risk is
unlikely to be greater than the risk predicted. The resulting risk estimates are expressed in
scientific notation as a probability (e.g. 1 x u)'6 for 1/1,000,000) and indicate (using this
example). that an average individual is not likely to have greater that a one in a million
chance of developing cancer over 70 years as a result of Site-related exposure as defined to
the compound at the stated concentration. Current EP A practice considers carcinogenic risks
to be additive when assessing exposure to a mixture of bazmdous substances.
The hazard index was also calculated for each pathway as EPA's measure of the potential
for non-carcinogenic health effects. A hazard quotient is ca1cu1a1Cd by dividing the
exposure level by the reference dose (RID) or other suitable benchmark for non-can:inogenic
health effects for an individual compound. Reference doses have been developed by EP A to
protect sensitive individuals over the course of a lifetime and they reflect a daily exposme
level that is likely to be without an appreciable risk of an adverse health effect. RIDs ~
derived from epidemiological or animal studies and inCmporale uncertainty factors to help .
enslR that adverse health effects will not occur. The hazard quotient is often expressed as
a single value' (e.g. 0.3) indiCating the ratio of the stated exposure as defined to the reference
dose value [m this example, the exposure as characterized is approximately one third of an
acceptable exposure level for the given compound). The hazard quotient is only considcrcd
additive for compounds that have the same or ~ toxic endpoint and the sum is ICfcrred
to as the hazard index (HI). (For example: the hazard quotient for a compound known to
produce liver damage should not be added to a second whose toxic endpoint is kidney
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. '. -. ..
Tables 7 and 8 ~ Appendix B depiCt the carcinogenic and non-carcinogenic risk: summary
of on- and Off-sIte areas for the contaminants of concern in groundwater, soil, and air.
These hav~ been evaluated to reflect present and potential future exposUJe pathways
corresponding to the average and the reasonable maximum exposure CRME) scenarios.
Of all the exposure pathways evaluated, only ingeStion of groundwarcr extracted from wells
located within the Site poses a significant risk to human health. This risk is due to the
VOCs present in the groundwater. The risk is primarily driven by ttichIorocthene, cis- 1,2-
dichIorocthene, 1,2-dichIorocthene, and vinyl chloride. Risk from the ingestion of arsenic in
the groundwater also exceeds threshold levels due to the natUrally occurring presence of
arsenic in area groundwater. The eStimated risks to human health from all other exposure
pathways evaluated were determined not to exceed the non-carcinogenic hazard index
aiterion of 1 or the carcinogenic upper-bound of the lifetime cancer criterion range of l~
for total organics and inorganics.
\ )
c.
Ecological Risk Assessment
The primary objective of the baseline Ecological Risk Assessment (ERA) was to evaluate,
and quantify where possible, the existing ecological risks to ecological receptors from
exposure to Site-dcrived contamination of soil, sediment, and smface water.
The ecological risk assessment considered potential exposures of terrestrial, wetland, and/or
aquatic flora and fauna to contaminants in soil, sediments, and surface water. The
assessment identified the following exposure pathways: 1) direct plant uptake of water-
soluble contanrinants via roots from soil, sediment, and surface water; 2) dermal absorption
of contaminants into both invertebrate and vcncbrate an;m",J5 from direct contact with soil,
sediment, and/or surface water; 3) respiratory intake of contaminants from smfacc water via.
gills of fish and transdcrmaIIy by amphibians; 4) in-take into foliage and/or inhalation by
anima 1$ of vapors from VOCs released from soils, sediments or surface water into the
annospherc; 5) direCt ingestion of soil, sediment, and/or smface water by invertebrate and
Vertebrate species; and 6) direct ingestion of conraminated foodlprey.
Table 9 found in Appendix B summarizes the levels of contamination detected in the
wetland and aquatic exposure zones and the hazard quotient associated with each
contaminant The ecological risk assessment concluded that the Site consists of typical
assemblages of plant and animal habitats for the northeastern region of Connecticut In both
the wetland and upland areas that were relatively undisturbed by grounds-keeping efforts,
species composition, distribution and diversity appeared typical for the area. No unusual
signs of stress to individual plants were observed. In the maintained portions of the Sire,
areas within the TCE plume path appeared no different from areas outside of the influence
of the plume. Also, adjacent undisturbed wetlands appeared healthy. Surface water and
sediment contaminmts attributable to Site activities pose no significant risk to aquatic
organisms or wetland habitats on-site or in downstream Ireas receiving surface water
discharges from the Site.
.
.
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." .- ...'"
In conclusion, based on the results of both the HHRA and the ERA, 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 Specifically, the human health risk assessment identified groundwater ingestion as
posing probable health risks exceeding EP A risk management criteria.
"VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A.
Statutory RequirementsIResponse Objectives
Under its legal authorities, EPA's primary responsibili~ at Superfund Sires is to undertake
remedial actions that are protective of human health and the environment In addition,
Section 121 of CERCLA establishes several other statUtory requirementS and preferences.
including: a requirement that EPA's remedial action. when t;omplete, must comply with all
federal and more stringent state environmental standards. requirements. criteria or .
limitations, unless a waiver is invoked; a reqtrlrement that EP A 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 to "be consistent with these
Congressional mandates.
Based ~n preliminary information relating to types of contaminants. environmental media of
concern, and potential exposure pathways, remedial action objectives were developed to aid
in the development and screening of alternatives. These remedial action objectives were
developed to mitigate existing and future potential threats to human health and the
environment EPA's response objectives were:
Source Control ReSDOnse Obiectives
.
. .
Prevent or mitigate the continued release of hazardous substances to the
groundwater and surface water by removing the opportUnity for contaCt
between precipitation and groundwater and the contaminatcci soils;
Reduce the concentrations of VOCS in the soil within the Zone 1 area so that
concentrations of VOCs in the groundwater will not exceed drinking water
standards and will not pose a risk to human health and the environment
.
Mana!etnent of Mieration Resoonse Obiectives
.
Eliminate or minimize the threat posed to human health and the environment
by preventing exposure to groundwarcr contaminants;
Prevent further migration of groundwater contamination beyond its current
extent; and,
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ROD DECISION
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-. .. . .
.
Restore contaminated groundwater to drinking water standards, and to a level
that is protective of human health and the environment, as Soon as
~~re. .
B.
Technology and Alternative Development and Screening
CERCLA and the NCP set fonh the process by which remediaI actions an: evaluated aDd
selected. In accordance with these requirements, a range of alternatives were developed for
the Site. .
\ I
With respect to source control, the RIlFS developed a range of alternatives in which
treaanent that reduces 'the toxicity, mobility, or volume of the hazardous subStances is a
principal element. This range included an alternative that removes or deStroys hazardous
substances to the maximum extent feasible, eliminating' or minimi~ng to the degree possible
the need for long term management. This range also included alternatives that, treat the
principal threats posed by the Site but vary in the degree of treatment employed and the
quantities and charaCteristics of the treatment residuals and untreated waste that must be
managed; alternative(s) that involve little or no treatment but provide protection through
engineering or institutional controls; and a no action alternative. In addition, with respect to
groundwater response action, the RIIFS also developed a limited number of remedial
alternatives that attain Site-specific remediation levels within different time frames using
different technologies; and a no action alternative.
As discussed in Chapter 11 of the Feasibility Study, the RIlFS identified, assessed and
screened technologies based on imprementability, effectiveness, and cost. These.
technologies were combined into source control (SC) and management of migration (MM)
alternatives. Chapter 12 of the Feasibility Study presented the remcdia! alternatives
developed by combining the technologies identified in the previous screening process in the
categories identified in Section 300.430(e)(3) of the NCP. The pmpose of the initial
screening was to narrow the number of potential remedial actions for funher detailed
analysis while preserving a range of options. Each alternative was then evaluated and
screened in Chapters 13 and 14 of the Feasibility Study.
In summary, of the nine source control and six management of migration remedial
altemativesinitially selected for consideration in the FS, seven source control alternatives
and three management of migration alternatives were retained for detailed analysis. Table
10 in Appendix B identifies these ten alternatives (seven source. control alternatives-and
three management of migration alternatives) that were retained through the screening
process, as well as those that were eliminated from further consideration.
vm. DESCRIPI'ION OF AL TERNA TlVES
This Section provides a narrative summary of each alternative evaluated. A detailed assessment of
each alternative can be found in Sections 13 and 14 of the Feasibility Study and in th~ FS
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.. -. ...
A.
Source Control (SC) Alternatives Analyzed
The source control alternatives that underwent detailed analysis for the Linemasrcr Switch
Corporation Site are the following:
.
SC-1 No Action;
SC-2 Containment;
SC-3 Vacuum Extraction;
SC-4 Vacuum Extraction With Enhancements;
SC-S In-Situ Biodegradation;
SC-6 On-Site Incineration; and
SC-7 Thermal Stripping.
.
.
.
.
.
.
All seven sow"cc control alternatives would require the COnstruction of a fence and warning signs
around the Zone 1 area. All source control alternatives, except for the no action alternative (SC-
1), would require shon-term controls such as worker 4O-hour safety ttaining, and worker
personal protective equipment. The seven source control alternatives are summarized below.
Alternative SC-l: No-Action
Alternative SC-l was evaluated in detail in the FS to serve as a baseline for ..comparison
with the other Source Control alternatives under consideration. Under this alternative,
limited actions would be taken to prevent access to the contami"ated soils in the Zone 1
area. A fence with warning signs would be constructed and maintained around ponions of
the Zone 1 area. Daily inspections of the fence would be conducted to assess the integrity
of the fence. An environmental monitoring program. which includes periodic soil sampling,
would be implemented to assess the natural attenuarlon of son contaminants. Monitoring
data would be evaluated every five years.
Estimated Time for Design and Consrruction: 2 to 3 months
Esrimmed Time for Restoration: Not Applicable
Estimated Capital Cost: $ 34,500
Estimated Operation and Maintenance Cost: $ 1,409,000
Estimated Total CoSt: $ 1,443,500
Alternative SC-2: Containment
The containment alternative involves placing an impermeable, multi-media RCRA Subtitle C
cap over a portion of the. oZone 1 area not already covered by impervious materials. A large
. part of the Zone 1 area is located underneath Linemaster's manufactUring building and
paved areas and would not be covered by the multi-media cap. The cap would be used to
reduce infiltration of precipitation into the soil and would reduce the amount of
contamination migrating from the area to groundwater.
2 All Operation & MainttNZIrCe (O&M) and Totill cost°tStitnllIes in this Record of Decision
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The cap would be consttucted over an area of approximately 12,100 square feet, adjacent to
Linemaster's manufacturing building. The cap would be four feet thick and consist of four
layers of materials: a low permeability soil layer, a synthetic membrane, a drainage layer of
fine sands and a layer of topsoil for a vcgetative cover. In order for Lincmasrcr to continue
current manufacturing operations, it would be necessary to maintain the existing elevations .
as nearly as possible. This would require excavation of approximately four feet of soil.
The estimated volume of soil that would be excavated is approximately 2,300 cubic yards.
Due to the levels of contaminants in the soil, it is csrimSltcd that approximately 300 cubic
yaros of material, out of a total of 2,300, would require off-site disposal.
\ '
"~
The cap would be inspected quarterly to check for crosion, intrusion by burrowing animals
or deep rooted plants, seeps, proper slopes, ponding and the integrity of the vegetative
cover. Also, groundwatcl' monitoring would be conducrcd on a quarterly basis to monitOr
the effectiveness of the cap. The monitoring data would be reviewed every five years to
determine if additional remedial actions are ncccssazy.
Estimared Time for Design and Construction: 12 months
EStimtlted Time for ReStOration: Not Applicable
Estimated Capittzl Cost: $ 429,000
Estimated Operation and Maintenance Cost: $ 1,409,000
Estimated Tottzl Cost: $ 1,838,000
Alternative SC-3: Vacuum Extraction
The soils in the Zone 1 area are contaminated with VOCs. The Vacuum Extraction
alternative consists of IICating the soil vapors and the groundwater in the Zone 1 area to
remove the VOCs from the soil. A series of soil vapor extraction wells would be installed
to extract contaminated vapors from the soils. The vapors would be extracted by blowers
which would then pump dle contaminated Vapors through carbon filters. The carbon filters
would remove the VOCs from the vapors prior to their discharge as air emissions to the
atmosphere.
The vacuum extraction system would be operated in conjunCtion with a dewatering system.
Since high groundwater levels hinder the effectiveness of the vacuum extraction system, it
would be necessary to removc as much of the groundwarcr in the area of the extraction
wells as possible. The groundwater extraction system would be integrated with the vacuum
extraction system. Each vacuum extraction wen would contain a dewatering pipe.
Contaminated warcr from the dewatering of the Zone 1 area soils would be treated by the
groundwarcr treatment facility to be implemented as part of the management of migration
response.
Like the other source control alternatives. this alternative would also include environmental
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. -... ... .
Estimated Time for Design &: Construction: 12 to 18 months
Estimated Time for Resrorarion: 3 to 10 years
Esrimmed Capital Cost: $ 446,000
Estimated Operation &: M ainrenance CoSt: $ 784,000
Esrimmed Total CoSt: $ 1,230,000
Alternative SC-4: Vacuum Extraction With Enhancements
This alternative is essentially the same as SC-3 except the vacuum extraction system would
be enhanced. The primary choice for enhancement would be air sparging.
Air sparging would involve the installation of injection wells in conjunction with the
extraction wells. Air would be injected below the groundwater table. Air bubbles
contacting the contaminants would cause them to volatilize and be captured by the vacuum
extraction syStem.
Like the other source control alternatives, this alternative would also include environmental
monitoring and an evaluation of the data every five years.
Estimated Time for Design &: Constl"UCtion: 12 to 18 months
EStimmed Time for Restoration: 3 to 10 years
Estimmed Capital Cost: $ 695,000 .
Estimated Operation &: MainreNUlCe CoSt: $ 834,000
Estimated Total CoSt: $ 1,529.000
Alternative SC-5: In-Situ Biode!m!dation
Biodegradation is the decomposition of VOCs by naturally occurring microbial organisms.
Microbes need energy and carbon for growth and maintenance. .
In-situ aerobic biodegradation would involve pumping contaminated groundwater to the
smface, treating the extracted groundwater, enhancing the ttcatcd groundwater with nutrients
and oxygen, and then reinjecting the enricbed groundwater into the CODmmi~ated area.
Groundwater would be pumped to the smface from recovery wells, which would be installed
around the perimeter of the Zone 1 area. The groundwater would then be treated by the
groundwarer treatment system to be implemented at the Site. and then passed through
another unit where nutrients and oxygen are added. This oxygen and nutrient enhanced
groundwater would then be reinjected via injection wells centrally located in the Zone 1
area. Air would also be injected into the groundwater beneath the surface to supply funher
oxygen to the groundwater. Microbes would aerobically break down the VOCs into energy
and carbon.
. Like the other source control alternatives, this alternative would also include environmental
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. .
Estimated Time for Design and Consrrucrion: 16 tI) 28 monzhs
Estimated T~ for Resroraricn: 1 tI) 10 years
Estimated Capiw Cost: $ 394,000
Estimated Operation and Mainrenance Cost: S 1.122.000
Estimated Tow CoSt: $ 1,516,000
. Alternative SC-6: On-Site Incineration
The on-site incineration alternative would involve excavation of all the soil in the Zone 1
area except the soil under Linemastei's manufacturing building. Excavated soU would be
incinerated to thermally destroy all VOCs. Approximately 26,000 cubic yards of soil would
be incinerated on-site with one of the following types of mobile incinerators: a rotary kiln
incinerator, an infrared incinerator, or a fluidized bed incinerator. The mobile incinerator
would be located in a treatment area nonheast of the manufacturing facility. The incinerator
. would also be equipped with emission control equipmenL
Soil would be excavated, screened to remove boulders and large Stones, transported to the
treatment -area, incinerated and returned to the excavation. area.
Like the other soUrce control alternatives, this alternative would also inClude environmental
monitoring and an evaluation of the data every five years.
Esrimmed Time for Design and Construction: 6 monzhs
Estimated Time for Resroraricn: 20 tI) 23 months
Estimmed CapiraI Cost: $ 13,588,000
Estimated Operation and Maintenance Cost: S 322,000
. Estimtzted Tow CoSt: $ 13.910,000
Alternative SC-' Thermal StriDDinl!
The thermal stripping alternative is similar to the on-site incineration alternative except for
the type of technology utilized to treat the soils. In this alternative, the excavated soU
would be transported to the treatment area (described in Alternative SC-6) and loaded into a
feed hopper. The soU would be screened and fed to a thermal processor by a conveyor belL
The processor would tra.nspon the soil by augers which rotate like screws. The augers .
contain heated oil. The soil would be heated, by contact with the hot augers, to a
temperature at which the VOCs would volatilize. Fans would remove the voJati1ized VOCS
from the .thermal processor and would transfer them to an afterburner and air pollution
control device which would destroy the VOCs. The processed soils would then be letmned
to the excavation area. .
Like the other source control alternatives. this alternative would also include environmental .
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. .... - . -
Estimtzred Tinre for Design and Conirrucrion:
EsriniDted Tinre for ReStOration: 5 10 6 years
Esrimtzted Capital Cost: $ 7,338,000
Estimated Operation and Maintenance CoSt:
Estimated Total CoSt: $ 7,785,000
7 monlhs
$ 447,000
B.
. Management of Migration (MM) Alternatives Analyzed
Management of migration alternatives address COntaminants that have migrated from the
original source of contamination. At the Linemastcr Switch Corporation Site, contaminants
have migrated from the Zone} source area to the nonhwest, north, northeast, east, southeast
and southwest via groundwater. Of these directions, the primary mction of flow is to the
cast-nonheast. Dming certain high water seasons, groundwarcr discharges from the .
overburden and bedrock into the smface water bodies near the StUdy area boundaries. The
management of migration alternatives that underwent a detailed analysis in the Feasibility
Study for Linemaster arc the following:.
.
MM-! No-Action;
MM-4 Air Stripping; and
MM-S Ultraviolet Oxidation.
.
.
A summary of each management of migration alternative can be found below.
Alternative MM-!: No-Action
Like Alternative SC-l, Alternative MM-} was evaluated in detail in the FS to serve as a
baseline for comparison with the other management of migration alternatives under
consideration. Under this alternative, it is assumed that operation of the existing Interim
Removal Treatment System would be discontinued and the groundwater would be restored
by natural attenuation. In addition, a fence with warning signs would be consaucted and
maintained around portions of the Zone 1 area to I'Csttict access, while institutional controls
would place restrictions on future development. Enmonmcntal monitOring, primarily
groundwater sampling of both monitoring wells and water supply wells, would be required
to evaluate contamhlant migration. Monitoring data would be evaluated every five years.
Esrimmed Time for Design and Constniction: Not Applicable
Estimated Time for ReStOration: 500 years
Estimated Copital Cost: $ 34,500
Estimated Operation and Maintenance Cost: $1,364,000
Estimated Total Cost: $ 1,398,500
Alternative MM-4: Air striDDim~
Cmrently, under the existing Interim Removal Treatment System (IRTS), contaminated
groundwater is collected by six groundwater exttaction wells located on-site. All of the
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.... ..... .
and prevent further migration of groundwatcI' contaminants. Currently. the groundwater
from the extraction wells is treated by an an- stripper and carbon adsorption system. The an-
containing the VOCs discharges directly to the atmospnere. Alternative MM-4 (Air
Saipping) would require continued 'operation of the eXtraCtion weDs and an- stripping and
carbon adsorption technology at the Site. In addition, Alternative MM-4 (Air Stripping)
would require the an- containing the VOCs to be passed through a vapor phase carbon
adsorption filter to remove the VOCs from the air prior to discharge to the aanosphere. The
contaminated carbon would be replaced once per year.
The treated water would flow out of the bottom of the an- stripper and would be piped to
another carbon adsorption filrcr at the bottom of the an- stripper to remove any remaining
contaminants. The treated water flowing out of the carbon filrcrs would be discharged
through a pipe to Pond 3.
Institutional controls. including deed restrictions, would restriCt future development.
Environmental monitoring, primarily groundWater sampling of both monitoring wells and
water supply wells. would be required to evaluate contaminant migration. Monitoring data
would be evaluated every five y~ars.
. '
EStimated Time for Design & ConstrUction: 6 monlhs
EStimated Time for Restoration: 35 years
EStimated Capital Cosr: $ 70,000
EStimated Operation &: Mainte1llJ1lCe Cost: $1,949,000
EStimated Total Cost: . S 2,019,000
Alternative MM.5: Ultraviolet Oxidation
Like the MM-4 (Air Stripping) Alternative, this alternative involves the coDection and
treatment of the contam;nared groundwatcI'. However, in this alternative ultraviolet
oxidation and carbon adsorption would be used to treat the contaminated groundwater water
collected from the groundwater exttaetion wells. In this process, ozone or hydrogen
peroxide is added to the extracted groundwater. The solution is then exposed to ultraviolet
light in a reactor. The ulttaviolet light causes the ozone or hydrogen peroxide to (ann
molecules that, because they arc highly reactive, break down the VOCs into carbon dioxide,
water and harmless chloride salts. The carbon dioxide and chloride salts remain dissolved in
the water and the water is passed through carbon filters to remove any remaining
contaminants necessary to meet discharge standards prior to discharge to Pond 3. The gases
from the reactor are passed through a catalytic decomposer which converts the remaining,
ozone to oxygen prior to discharging to the aanosphere.
J Capilal costS lor Alternative MM-4 (AiT Stripping) include !!!J!! the COSt of ins111lling tJir
emission controls. T~ capilal cost estimtzte of SlO,Ooo does not inclllde the tlCtIIIIl cost of 1M
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.. . -. ....
institUtional controls, including deed reStrictions, would reStrict futUre development.
Environmental monitoring, primarily groundwater sampling of both monitoring wells and
water supply wells, would be required to evaluate cont:trmnant migration. Monitoring $fa
would be evaluated every five years.
Estimated Time for Design &: Construction:
EStimated Time for ReStOration: 35 years
Estimated CapiraJ Cost: $ 191,900
EStimated Operation &: Maintenance Cost:
Estimated Total CoSt: $ 2,930,400
8 10 12 months
$ 2,738~OO
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
Evaluation Criteria
Section I21(b)(l).of CERCLA presents several factOrs that at a minimnm EPA is required to
consider in its assessment of alternatives. Building upon these specific statutory mandates,
the National Contingency PIan articulates nine evaluation criteria to be used in assessing the
individual mnedial alternatives.
A detailed analysis was performed on the alternatives using the nine evaluation criteria in
order to select a Site remedy. In Section IX. B.. below, is a summary of the comparison of
each alternative's strength and weakness with respect to the nine evaluation criteria. These
criteria are sUulwiuized 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 or 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.
2.
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.
Prima" Balancin2 Criteria
The fonowing five criteria are utilized to compare and evaluate the elements of one
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Page 22
.. .. - ~ .. ..
3.
LODg-tenn effectiveness and )Jer'ID8JIence addresses the criteria that art 1ItiIi2ed 10
assess alletnati..,. for the long-limn effectiveness and ~ they affom, along
with the degree of cenainty that they will prove SUccessful.
4.
Reduction of toxicity,mobility, OJ" volume through treatment admesses the degJ
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1.
Overall Protection of Human Health and the Environment
Except for Alternative SC-! (No ACtion), all of the SC altenwives would provide
overall proteCtion of human health and the environmenL Currently, the Site poses a
continued threat to groundwater and to the l'Csidents who utilize the groundwater.
Alternative SC-! (No ACtion) docs not include measures to minirm~ the continued
migration of COntaminants to the groundwater and thus would not provide overall
protection of human health and the environment.
Alternative SC-2 (Containment) would provide a threshold level of overall proteCtion
of human health and the enviropment by containing the contaminants with an
~4Ua;able cap. The cap would reduce the migration of the contaminants into the
groundwater by minimizing infiltration but would not prevent the venicaI migration
of contaminants due to gravity. The COntaminated soils located beneath the cap. and
beneath Lincmaster's manufactwing building, would remain a continual source of
groundwater contamination.
. .
Alternatives SC-3 (Vacuum Extraction) and SC-4 (Vacuum Extraction With
Enhancements) would provide overall protection to human health and the
environment through treatment of all the contaminated soils in the Zone 1 area,
including the soils beneath Linemaster's manufacturing building. Treatment of the
Zone 1 Ilea soils would prevent further migration and contamination of the
groundwater, enabling the l'Cstoration of contaminated groundwater to drinking water
standards.
Alternative SC-5 (Biodegradation) would also provide overall protection, if sufficieDt .
dispersion of the microbes can be achieved
Alternatives SC-6 (On-Sire Incineration) and SC-7 (Thermal Stripping) would
provide protection by treating a portion of the contaminated soils. Although
Alternatives SC-6 (On-Sire Incineration) and SC-7 (Thermal Snipping) would
provide threshold levels of overall protection, neither of these alternatives would
address the CODrarmnated soils beneath Linemastcr's manufactUring building which
would remain a continual source of groundwater contamination. . .
Except for MM-! (No Action), the management of migration alternatives would
provide overall protection of human health and the environmenL Alternative MM-!
(No Action) would l'Cstore the groundwater to drinking water standards in
approximately 500 years through natUral attenuation. Since exposure ro the
contaminated groundwater may not be effectively prevented for this length of time,
MM-! (No ACtion). would. not be protcetive of human health and the environment.
Alternatives MM-4 (Air Snipping) and MM-5 (Ultraviolet Oxidation), would provide
an equal degree of overall protection of human health and the environment by
treating the contaminated groundwater. Further migration of contaminated
groundwarcr would be prevented and the groundwater would be restored ro drinking
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. -
2.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Except for SC-2 (Containment), all of the SoW'Ce control alternatives would achieve
ARARs. SC-2 (Containment) consists of capping the contamin=lt~d soils. However
under this alternative, no cap would be placed over the area of contaminated sons '
currently covered by Linemastcr's manufacturing building. Because the cap wouJd
only be placed over a portion of the COntamh1ated soils, this altenwive would not
satisfy the requirements of RCRA, 40 c.F.R. 1264.310.
All the management of migration alternatives. would achieve ARARs. The only
difference between the alternatives wouJd be the time it takes to achieve ARARs.
Alternatives MM4 (Air Stripping) and MM-5 (Ultraviolet Oxidation) would reStOre
groundwater to drinking water standards in 35 years. Alternative MM-l (No Action)
would restore groundwater in 500 years.
A list of ARARs can be found in the Addendum to the Feasibility Study. ARARs
that pertain to the selected remedy can be found in Tables 13 - 15 in Appendix B at
the end of this document
3.
Long-term Effectiveness and Permanence
Alternative SC-! (No Action) relies on institutional controls, Le.. a fence, and would
not provide effective or permanent teductions in long-tcnn risks because VOCs from
the soils would Continue to migrate to the groundwater.
Alternative SC-2 (Containment) would not eliminate the continued venical migration
of contamination under the cap and under Linemaster's manufacturing building. In
addition, although impermeable caps have an expected life of 30 to 50 years,
environmental uncertainties can shonen the life of the cap.
Alternatives SC-3 (Vacuum ExU'aCtion) and SC-4 (Vacuum Extr3Ction With
Enhancements) would provide long-term effective teduction in risks associateC1 with
Site contaminants as well as permanence through treatment of all the contaminated .
soils. After the completion of treatment, DO funher controls would be necessary.
Both of these alternatives would operate for at least three, and more probably len
years, to achieve the remedial objectives. Alternative SC-3 could be modified and
enhanced to Altcmative SC-4 in order to improve the efficiency of the system by
adding enhancements such as air sparging.
If sufficient dispersion of the microorganisms can be achieved, Alternative SC-S
(Biodegradation) would also provide effective %eduction of risks as well as
permanence by substantially elirpinating the contaminants in the sou.
Alternatives SC-6 (On-Site Incineration) and SC-' (Thermal Stripping) would not
climinatc the continued vertical migration of contamination beneath Linemaster's
manufactUring building. The soil remaining under the building and paint shed would
not receive any treatment 8nd contaminants would continue to migrate into the deep
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. -
With respect to the Management of Migration alternatives, Alternative MM-l (No
. Action) would not eliminate long-tenn risks because it would take approximately 500
years to restore the groundwater to drinking water standaJds through natural
attenuation.
Management of Migration Alternatives MM-4 (Air Saipping) and MM-5 (Ultraviolet
Oxidation) would e1imin~te the long-term risks associated with exposure to groundwater
by restoring the groundwater to drinking water standards within 3S years. With the aid
of emission conttOls, Alternatives MM-4 (Air Saipping) and MM-S (Ultraviolet
Oxidation) would permanently destroy contamination and would not transfer contaminants
to the atmosphere which would contribute to the formation of ozone.
4.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternatives SC-l (No Action) and SC-2 (Containment) would not provide any
reduction in the toxicity, mobility or volume of contalTrinants through the use of
treatment technologies.
Alternatives SC-3 (Vacuum Extraction), SC-4 (Vacuum Extraction With
Enhancements) and SC-5 (Biodegradation) would treat all the contaminated soils in
the Zone 1 area and would therefore significantly reduce the toxicity, mobility and
volume of the contaminants at the Site. Also, Alternatives SC-3 (Vacuum
Extraction) and SC-4 (Vacuum Extraction With Enhancements) would require air
emission CODttOls on the vacuum extraction system to prevent the transfer of
contalTrinal1ts via the soil vapor Stream to the air.
Alternatives SC-6 (On-Site Incineration) and SC-7 (Thermal Saipping) would treat
only a portion of the contaminated soils in the Zone 1 area and therefore would not
achieve the same reduction in toxicity, mobility and volume as SC-3 (Vacuum
Extraction), SC-4 (Vacuum Extraction With Enhancements) and SC-5
(Biodegradation). The contaminated soil remaining under Linemastcr's
manufacturing facility, comprising approximately 38 percent of the total eStimated
volume of soils contaminilted by VOCs, would remain a continual source of
groundwater contamination.
Alternative MM-l (No Action), would not treat the contaminated groundwater. and
therefore would not provide reductions in toxicity, mobility or volume through
treatmenl
Alternatives MM-4 (Air Sttipping) and MM-5 (Ultraviolet Oxidation) would provide
significant reductions in the toxicity, mobility and volume by treating the
contaminated groundwater. In addition, both alternatives would provide complete
desauction of the contamination through treatment and air emission controls. and
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-
s.
Short-term Effectiveness
Alternative SC-l (No Action) would pose minimal impact on human health and the
environment during the construction period because construction involves only the .
installation of the fence, which could be completed in two to three months. It is not
expected that threatS to the community and workers will be encountcrcd. As is uue
for all alternatives, workers should follow safe working practices and wear protective
clothing where or when appropriate. The No Action alternative, however, would not
reduce the mobility, toxicity or volume of the contaminants, thus continuing the
existing unacceptable environmental impaCt
SC-2 (Containment) would present slightly greater short-term impacts due to fugitive
dust generated during excavation to construct the cap. However, dust control
measures would be initiated to minimi7.e the generation of airborne contaminants
during construct:ion and air monitoring would be performed. The cap could be
constructed in six to eight months. Impacts to workers would be minimized with
protective equipment and worker safety training would be reqWred.
Alternatives SC-3 (Vacuum Extraction) and SC-4 (Vacuum Extraction With
Enhancements) would present minima] short-term impacts on human health and the
environment The construction period would take approximately twelve to eighteen
months, and the implementation period would take three to ten years until cleanup
goals are achieved. During this entire period, workers could be protected with
protective equipment from fugitive dust attributed to construction. Dust control, air
monitoring and worker safety training would also be required.
Alternative SC-5 (Biodegradation) would. provide ~nima1 impact during
construction. Neither the 'employees nor the nearby residents would be at risk during
on-site well installation and system operation. Contaminated soil would be treated
in-situ, thereby eliminating risks associated with excavation, especially air quality
impacts due to conmminared dust particles. Dust control, air monitoring, worlccr
safety training and personal protective equipment would be required.
Alternatives SC-6 (On-Site Incinemtion) and SC-' (Thermal Stripping) would pose
significant shan-term risks during ConstruCtion activities due to fugitive dust.
Worlcers could be exposed to contaminants via dermal contact and/or the iQbaJation
of dust or volatilized organics. Although air monitoring, dust control, worker safety
training and personal protection equipment would all be required, the risks to
workers would be greater than the minima] risks to workers presented by all of the
other source control alternatives. In addition, unlike any of the other alternatives
under consideration, the performance of this alternative would pose a risk to the on-
site ponds and wetlands because excavation could lead to increased erosion and
transport of contaminated soils to the ponds and wetlands. The time for restoration
for alternatives SC-6 (On-Sire Incineration) and SC-' (Thermal Stripping) is tWenty
to twenty-three months and five to six years, respectively.
Alternative MM-l (No Action) includes construction of a fence and would also result
in minimal short-tenn impacts. However, restoration of the groundwater to drinking
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. . - .. - .
years. It would not be possible to prevent exposure to contaminaa:d groundwu:r for
this length of time.
Alternative MM-4 (Air Snipping) would include only the construction of emission
controls onto the already existing air stripper on-site. A groundwater extraction,
treatment and discharge syStem has already been conSuucted and presumably will
continue to operate as part of the Remedial Action. Conmuction of the emission
controls (required by Alternative MM-4) would provide minim::!1 impacts bUt
construction could release fugitive dust. To minimize or prevent such exposure to
workers or residents, dust control measures, air monitoring, worker safety ttaining,
and personal protection equipment would all be required.
Alternative MM-5 (Ultraviolet Oxidation) would also provide minimal shan-term
impacts, slightly greater than those of MM-4. Removal of the existing air Stripper
followed by the construction of the ultraviolet oxidation system could be designed
and consttuca:d with minim::!1 impacts and Construction completed within 8 to 12
months. Again, dUSt control measures, air monitoring, worker safety training, and
personal protection equipment would all be required.
ti.
Implementability
Alternative SC-l (No Action). consists of the construction of a fence and
environmental monitOring, and would be relatively easy to implement Alternative
SC-2 (Containment) would also be readily implcmentab1c. Impermeable caps are a
widely used technology and the materials necessary for constrUction arc available
locally.
Alternatives SC-3 (Vacuum Extraction) and SC-4 (Vacuum Extraction With
Enhancements) have been used successfully at other Sites and arc also readily
implcmentable. The materials and services for construction are available 1ocal1y.
Since biodegradation is not a .well developed technology, Alternative SC-S
(Biodegradation) would require significant pilot testing prior to implementation.
Alternatives SC-6 (On-Site Incineration) and SC-7 (Thermal Stripping) would be
easily implementable. On-site incineration is a proven technology and thermal
stripping is an accepted innovative technology. The equipment that SC-6 would
require is readily available. While specia1izcd services and matcrlaIs for Alternative
SC-7 may not be available locally, there arc several contractors in the eastern part of
the country who could provide equipment
All of the source controls alternatives therefore would be readily implementable. or
. feasible to the same degree, except for Alternative SC-5 (Biodegrada~on) which
would require significant pilot testing.
All of the management of migration alternatives would be readily implementabIc.
ConstrUction of the fence (required by MM-l, the no action alternative) would be
easy to implement Alternative MM-4 (Air Saipping) would also be readily
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-"'. ~ ...
already been constructed at the Sire and is currently operational. Presumably, this
sYStem would continue to Operate as part of the Remedial ACtion. The addition of
emission control equipment would be required, and would be easy to implemcnL
The consttuction of the ultraviolet oxidation system (required by MM-S) might
require pilot testing during the design, but would also be readily implementable.
Cost
7.
- .
. A comparison of the estimated total present wonh costs for each Source Control
alternative is as follows:
Total
Total Operation &
Alternative Canital Maintenance Total Costs
SC -1 S 34,500 $1,409,000 $ 1,443,500
SC-2 S 429,000 $1,409,000 $ 1,838,000
SC- 3 S 446,000 $ 784,000 $ 1,230,000
SC-4 S 695,000 $ 834,000 $ 1,529,000
SC-5. S 394,000 $1,122,000 $ 1,516,000
SC- 6 SI3,588,000 $ 322,000 $13~910,000
. .SC-7 S 7,338,000 $ 447,00Q $ 7,785,000
A comparison of the estimated total present wonh costs for each Management of
Migration alternative is as follows:
Alternative
MM-! .
MM:"4
MM-'
Total
Canital
S 34,500
S 70,000
SI91,900
Total
Operation &
Maintenance
SI,364,OOO
$1,949,000
S2,738,500
Total Costs
SI,398,500
$2,019,000
$2,930,400
8.
State Acceptance
The State's comments on the RIlFS and Proposed Plan, as received during the public
comment period, and the EP A's responses to their comments are summarized in the
Responsiveness Summary in Appendix C of this documenL
In general, the state supported the preferred alternatives set forth in the Proposed
Plan. Among other specific issues, the State commented on the desirability of
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x.
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. -... . - .
9.
Community Acceptance
The comments received from the community on the RIlFS and Proposed PIan during
the public comment period, and the EPA's responses to the comments arc also
Summarized in the Responsiveness Summary in Appendix C of this document.
In general, comments received from the community did not raise any objections to
the prefeIrCd alternatives set forth in the Proposed Plan. Lincmasrcr also submitted
comments as a potentially responsible party. Lincmaster commented on the use of
air emission controls on the preferred air snipping alternative and the soil cleanup
levels described in the Proposed Pian.
...
THE SELECTED REMEDY
The remedy selected to address the contamination at the Linemastcr Switch Corporation Sire
includes: Source Control alternatives SC-3 (Vacuum Extraction) and SC-4 (Vacuum Extraction
With Enhancements); and, Management of Migration alternatives MM-4 (Air Snipping) and MM-S
(UlttavioIet Oxidation). A detailed description of the cleanup levels and the selected remedy is
presented below.
A.
Interim Groundwater Cleanup Levels
Interim cleanup levels have been established in groundwater for a subset of the contaminants
of coneem identified in the Baseline Risk Assessment and were selected to be rcprcscntative
of the contaminmts detected at the Site. Interim cleanup levels have been set based on the '
ARARs (e.g., Drinking Water Maximum Contaminant Level Goals [MCLGs] and MCLs) as
available, or other suitable criteria described below. Periodic assessments of the protection
afforded by remedial actions will be made as the remedy is being implemented and at the
completion of the remedial action. At the time that Interim Groundwater Ceanup Levels
' identified in the ROD and newly promulgated ARARs and modified ARARs which call into
question the protectiveness of the remedy have been achieved and have Dot been exceeded
for a period of three consecutive years, a risk assessment shall be performed on the residual
groundwater contamination to determine whether the remedial action is protcctive. This risk
assessment of the residual groundwater contamination shall follow EP A procedures and will
assess the cumulative carcinogenic and non-carcinogcnic risks posed by ingestion of
contaminated groundWater. The risk assessment will be based on a comprehensive analysis
of the groundwater including all contaminants historicaI1y detected or potentialIy present in
the contamination plume", H, after review of the risk assessment, the remedial action is Dot
determined to be protcctive by EP A. the remedial action shall continue until either protective
levels arc achieved, and are not exceeded for a period of three consecutive years, or until
the remedy is otherwise deemed protective. These protective residua1levels shall constitute
the final cleanup levels for this Record of Decision and shall be considered pcrfonnance
standards for any remedial action.
The aquifer under the Site is classified as GA by the cr DEP and should be suitable for
direct human consumption without the need for treatment The groundwater to the east and
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ROD DECISION
Linemaster Switch COl"Doration Site
Page 30
.
groundwater tributary to a public water supply watershed or for groundwater within the area
of influence of community or non-community supply wells. Under the Groundwater
ProteCtion Strategy, EPA has classified the aquifer beneath the Site as a Class llA aquifer.
MCLs and non-zero MCLGs esrablished under the Safe Drinking Water Act are ARARs.
Interim cleanup levels for known, probable, and possible carcinogenic compounds (Classes A, B,
and C) have been established to protect against potential carcinogenic effccts and to conform
with ARARs. Because the MCLGs for Cass A & B compounds are set at zero and arc thus not
suitable for use as interim cleanup levels, MCLs and proposed MQ..s have been selected as the
interim cleanup levels for these Classes of compounds. Because the MCLGs for the Class C
compounds are greater than zero, and can readily be confirmed, MCLGs and proposed MCLGs
have been selected as the interim cleanup levels for Class C compounds.
Interim cleanup levels for Cass D and E compounds (not classified, and no evidence of
carcinogenicity) have been established to protect against potential non~ogenic effects
and to conform with ARARs. Because the MCLGs for these Classes are greater than zero
and can readily be confirmed, MCLGs and proposed MCLGs have been selected as the
interim cleanup levels for these classes of compounds.
In situations where a promulgated State standard is more Stringent than values established
under the Safe Drinking Water Act, the Srate standard was used as the interim cleanup leveL
In the absence of an MCLG, an MCL, a proposed MCLG, proposed Ma., State standard, or
other suitable criteria to be considered (ie., health advisory, state guideline) an interim
cleanup level was derived for each compound having carcinogenic potential (Ouses A, B,
and C compounds) based on a 1~ excess cancer risk level per compound considering
exposure to contaminated groundwater by ingestion. In the absence of the above standards
and criteria, interim cleanup levels for all other compounds (Casses D and E) were
established based on a level that represent an acceptable exposure level to which the hwnan
population including sensitive subgroups may be exposed without adverse affect during a
lifetime or pan of a lifetime, incOIporating an adequate margin of safety (hazard quotient =
1) considering exposure to contaminated groundwater by ingestion. If a value desaibed by
any of the above methods was not capable of being detCC1Cd with good precision and
accmacy or was -below what was deemed to be the background value, then the practical
quantiflCation limit or background value was used as appropriate for the Interim
~~d~aean~um -
All Interim Groundwater Cleanup Levels identified in the ROD and newly promulgated
ARARs and modified ARARs which caJl into question the protectiveness of the remedy and
the protective levels determined as a consequence of the risk assessment of residual
contamination, must be' tnet at the completion of the remedial action at the points of
compliance. On-site, the points of Compliance will be ~ughout all groundwater at the
Site, including groundwater beneath Linemaster's manufacturing building. Off-site, the
points of compliance shall be throughout all groundwater within the contamination plume
(See Figures 2 &. 3 in Appendix A), including all groundwater where levels of
contamination previously exceeded MCLs. EPA has estimated that these groundwater
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ROD DECISION
Linemaster Switch COnJoration Site
Page 31
. - .
These interim cleanup levels are consistent with ARARs or suitable To-Be-Considered
(TBC) criteria for groundwarcr, attain EPA's risk management goal for remcdiaI actions and
are determined by EP A to be protective. However, the true test of protection cannot be
made until residual levels are known. Consequently, at the time that Interim Groundwater
Cleanup Levels identified in the ROD and newly promulgated ARARs and modified ARARs
which can intO question the protectiveness of the remedy have been achieved and have not
been exceeded for a period of three consecutive years, a risk assessment will be performed
on residual groundwar.cr contamination to determine whether the remedial action is
protective. This risk assessment of the residual groundwater' contamination shall follow
EPA procedures .and will assess the cumulative carcinogenic and non-carcinogcnic risks
posed by ingestion of on-site groundwater. If, after review of the risk assessment, the
remedial action is not determined to be protective by EP A, then remedial actions shall .
continue until either protective levels are achieved and are not e)f~ed for three
consecutive years or until the remedy is otherwise deemed protective. These protective
residua11evels shall constitute the final cleanup levels for this RecOld of Decision and sha11
be considered peIformance standards for any remedial action.
Table 16 in Appendix B summarizes the Interim Ceanup Levels for carcinogenic and non-
carcinogenic contaminants of concern identified in groundwarcr.
B.
Soil Oeanup Levels
Based upon data developed in the RI and the Baseline Risk Assessment, remedial measares
to address risk associared with possible exposure to source soils are not warranted because
present and future risks are within or below EPA's acceptable carcinogenic risk range or for
the Don-carcinogens generally below a Hazazd Index of one. However, available data
indicates that area soils are the primary source of release of VOCs to groundwater. This
phenomenon may result in an unacceptable risk to those who ingest contaminated
groundwater. Therefore, cleanup levels for soils were established to proteCt the aquifer from
potential soil leachate. The Summers Model was used to estimate residual soil levels that
are not expected to impair future ground water quality. The interim cleanup levels for
groundwater were used as input intO the leaching model H the predicted protective soil
level was not capable of being detected with good precision and accuracy, then the practical
quantirJCation limit was selected as the cleanup level for soils. Table 17 in Appendix B
summuizcs the soil cleanup levels required to proteCt public health and the aquifer which
were developed for the groundwater contaminants of concern detected above the interim
groundwater cleanup levels.
These cleanup levels in soils are consistent with ARARs for groundwater, attain EPA's risk
management ,goal for 1'1;Iiiedial actions, and have been determined by EP A to be pro~ve.
These cleanup levels must be met at the completion of the remedial action through~ut all
soils, including the soils beneath Linemaster's manufactUring building.
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ROD DECISION
Linemaster Switch CorDoration Site
Page 32
. . .
C. .
Description of Remedial Components
,
The selected remedy for the Site has two major components, a source conlrOl component to
address the contaminated soils and a management of migration component to address the
contaminated groundwater. EPA selected two alternatives (SC-3 and SC-4) for the SOun:e
conlrOl component and two alternatives (MM-4 and MM-S) for the management of
migration COmponent Each of the COmponents are described below.
..
L
Source Control Component
Two alternatives were selected to treat the contaminated soils: SC-3 (Vacuum
Extraction) and SC-4 (Vacuum Extraction with Enhancements). By selecting two
alternatives, EPA retains the flexibility to address the soils through vacuum
extraction alone, or to enhance the vacuum extraction system if necessary.
Based on current information, EPA estimates that both SC-3 (Vacuum Extraction)
and SC-4 (Vacuum Extraction with Enhancements) will achieve the soil cleanup
levels within the same time frame: three to ten years. The actual efficiency of these
alternatives cannot be evalUated, however, until after implementation. For this
. reason, Alternative SC-3 (Vacuum Extraction) alone will first be implemented at
. the Site. After the system has been operating for five years, EPA will evaluarc the
effectiveness of the system and determine whether the cleanup levels will be
achieved within the projected ten-year period using vacuum extraction alone. If, at
that time, EPA determines that the soil cleanup levels will not be achieved within the
projected ten-year period using vacuum extraction. alone, the vacuum extraction
system will be enhanced with air sparging or other enhancement technologies, as
determined by EP A, to assure that soil cleanup levels will be attained within the
projected ten-year period. In making this determination, EP A will at a minimum
evaluate the results of soil borings drawn from within the Zone 1 area at the .
conclusion of the first five year period of operation of the vacuum extraction system,
and the results of soil vapor samples taken on an ongoing basis during the first five
year period of operation of the vacuum extraction system
Both alternatives arc described in more. detail below.
SC-3: Vacuum Extraction
The Vacuum Extraction alternative consists of treating the soil vapors and the
groundwater in the soun:c area, Zone 1, to remove the VOCs from the soil.
Following construction of a fence to limit access, a series of soil vapor eXtraCtion
wells will be insWled to extract contaminated vapors from the soils (Figure 4,
Appendix A). The vapors will be extracted by blowers which pump the
contaminated vapors through carbon filters. The carbon filacrs will remove the
VOCs from the vapors prior to discharge to the atmosphen:. .
The vacuum extraction system will be operated in conjunction with a dewatering
system. Since high groundwater levels hinder the effectiveness of the vacuum
extraction system, it will be necessary to remove as much of the groundwater in the
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ROD DECISION
. Linemaster Switch COl"Doration Site
Page 33
integrated with the vacuum extraction system. Each vacuum extraction well" will
contain a dewatering pipe. Contaminated Water from the dewatering of the Zone 1
area soils will be treated at the groundwater treatment facility discussed in the next
section (Management of Migration). -
Approximately 3S vacuum eXtraCtion wells will be installed in the Zone 1 area. The
vacuum extraction wells will be spaced approximately 30 feet apan throughout d1e
entire Zone 1 area, including within Linemaster's manufacturing building. Figure S
in Appendix A identifies the proposed lOCations of the extraction wells and control
buildings for the system. The vacuum extraction wells will be approximately 40 feet.
deep. A pilot test was conducted in 1989 to assess the feasibility of the vacuum
extraction technology. The results indicated that vacuum extraction was a viable
technology for the Site. A new pilot test will be conducted to verify the number and
locations of the vacuum extraction wells.
"The vacuum eXtraction wells will be connected to blowers with Polyvinyl chloride
(pVC) piping. The blowers will produce a vapor flow rare of approximately 300
cubic feet per minute. Vapor phase granular activated carbon will be used" to treat
the vapors from the blowers prior to discharge to the atmosphere.
Actual operation would likely be OD an intermittent basis to maximize the
effectiveness and efficiency of the extraction system. The construction time is
esrimflted at twelve to eighteen months and the duration of remedial activities will be
from three to ten years. Soil cleanup levels will be achieved within ten years from
the start of operation of the source control reme4Y.
SC-4: Vacuum Extraction With Enhancements
As described more fully above, Alternative SC-3 (Vacuum Extraction) alone will first
be implemented at the Site. After the system has been operating for five years, EP A
will evaluate the effectiveness of the system and determine whether the cleanup
levels will be achieved within the projected ten year period using vacuum extraction
alone. If, at that time, EPA determines that the soil cleanup levels will not be
achieved within the projected ten year period using vacuum extraction alone, EP A
will consider using methods to enhance the effectiveness of the vacuum eXtraction
system to assure that soil cleanup levels will be attained within the projected ten year
period. -
Such enhancements may include additional vacuum extraction wells, additional
dewatering wells, and different dewatering techniques such as trenches or horizontal
wells. EPA may"81so consider enhancing the vacuum eXtraCtion system with another"
technique known as air sparging.
Air sparging was evaluated in the FS as a separate alternative, Alternative SC-4
(Vacuum Extraction With Enhancements). Air sparging would involve the
installation of injection wells (Figure 6 in Appendix A) in conjunction with the
extraction wells. Air would be injected below the groundwater table. Air bubbles
contacting the contaminants would cause them to volatilize and be captured by the
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ROD DECISION
Linemaster Switch COl'"Doration Site
Page 34
2.
Management or Migration Component
Conauninanrs, principally VOCs, are present in the groundwater beneath and down-
gradient of the Zone 1 source area. EPA has selected two 'alternatives to treat the
contaminated groundwater: Altcmative MM-4 (Air Stripping) and Alternative MM-5
(U1travioIet Oxidation). By selecting two alternatives, EPA retains the flexibility to
treat the groundwater using an air stripping system, or to sWitch to an ulaaviolet
oxidation system if ulaaviolet oxidation proves to be less expensive than air
stripping.
o
Both MM-4 (Air Stripping) and MM-5 (Ulaaviolet Oxidation) requile active
restoration of the groundwater. These alternatives are equally effective and provide
for equal degreeS of protection and permanence. Based on the COSt estimates in the
FS, Alternative MM-4 (Air Stripping) is more cost-effective than Alternative MM-5
(Ultraviolet Oxidation). Alternative MM-4 will therefore be implemented at the Site.
If. however, cost eStimates change over the course of time to the eXtent that EPA
determines that the air stripping system is no longer as CoSt-effective as the
ultraviolet oxidation syStem, Alternative MM-5 (Ultraviolet Oxidation) may be
implemented in place of Altcmative MM-4 (Air Stripping) at any time during
performance of the ~undwater cleanup. Both alternatives are dcsa:ibed below.
MM-4: Air StrlDDing
Currently. contaminated groundwater is collected and treated by an on-sire air
stripper as required by CT DEP's Abatement Order. The on-site air stripper transfers
the contaminants in the groundwater to the atmosphere. For the management of
migration component, EPA's selected remedy requiles the continued collection and
treatment of contaminated groundwater by an on-sire air Stripper, but also requires
that air emission controls be used in conjunction with the air Stripper to prevent
contaminants from being discharged to the atmosphere.
Presently, the contaminated groundwater is collected by the six on-site groundwater
extraction wells that comprise the Interim Removal Treatment System (JRTS). AIl of
the groundwater extraction weDs 8Je located in the deep bedrock. The locations of
the groundwater extraction weIIs were selected to contain and prevent further
migration of groundwater contaminants. As part of the long-term cleanup pIan. the
Dumber, locations and pumping rates of the groundwater exttaction wells wiII be
. evaluated to reaffirm current locations and determine if modifications are needed to
restore groundwarer throughout the Site to the cleanup levels as soon as practicable.
Currently, the grOimdwater from the extraction wells is treated by an. air stripper and
a carbon adsorption system. The treatment system is located on the Linemasrer.
property, within a smaIl building south of Linemaster's manufacturing buDding.
Figure 1 (Appendix A) shows' the current locations of the exttaction wells and the
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ROD DECISION
Linemaster Switch Cornoration Site
Page 35
. a . . ... -
Figure 9 in Appendix A shows the schematic of the air Stripper and carbon
adsOIption tICatment syStem. Groundwater from the groundwater extraction wells is
pumped through individual pipes to an equali7.ation tank within the treatment
building. Groundwater from the dewatering of the Zone 1 area soils is also be
pumped to the equalization tank. The equaH"r.Ition tank controls the flow of the
groundwater entering the treatment system. The water is then pumped from the
equaJi~tion tank to the top of the air stripper and allowed to cucade downward
against a CUIrent of air being fed into the bottom of the Stripper by a blower. An air
stripper is designed to take advantage of the readincss of VOCs to volatilize, or
evaporate, when exposed to the air.
Cmrcntly, the air containing the VOCs discharges directly to the atmosphere.
However, EPA's selected remedy requires the air containing the VOCs to be passed
through a vapor phase carbon adsorption filter to remove the VOCs from the air
prior to discharge to the atmosphere. The chemistry of carbon is such that many
different chemicals will readily attach themselves to carbon atoms and would thus be
removed from the air stream. The con~minated carbon must be replaced and
recycled at least once per year.
The treated water flows out of the bottom of the air Stripper and is piped to another
carbon idsmption filter at the bottom of the air Stripper to remove any remaining
con~nnnants. The treated water flowing out of the carbon filters is discharged
through a pipe to Pond 3. .
Alternative MM-5: IDtraviolet Oxidation
As discussed above, EP A has also selected ultraviolet oxidation as an alternate means
of treating the contaminated groundwater at the Site. EPA has determined that both
. air stripping and ultraviolet oxidation would be effective technologies for treating the
groundwater contamination. PIcliminary cstimates of the cOStS indicate that air
stripping fmcluding carbon adsorption) is the most cost-effective alternative. The
tOtal cost of Altemative MM-4 (Air Stripping) is $2,019,000,4 while the total cOSt of
Alternative MM-5 (tnttavio1et Oxidation) is $2,930,400. If, as discussed above, COst
4 As staled in lootnDte 3, the capitlll costS/or Alttnzative MM-1 (Air Stripping) include!l!!!l the .
cost of inst/llling air emission controls. The capilizl cost estimlltt 0/$70,000 does not include
the tlCtutzl cOSt 01 the air stripper or the lRTS which LiMnrtzster Iuzs Dlrttzdy built tmd
cUTrenlly optrilles ill the Sire. HowtVer, tVen if these costS were inclwled in the cost estimalt,
the rot4l cost of A~l'NZlivt MM-1 (Air Stripping) would still be Ius thizn the total cost 01
Alternmive MM-5 (Ulzraviolet Ozidmion). EPA estimDus that tOtal cost/or the groun.dwtuer
c01llili1rrMntJair stripping system, including insUll14lion ofwells, air Stripper tmd emission
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ROD DECISION
Linemaster Switch COl"Doration Site
Page 36
.
estimates change over the course of time to the extent that EP A determines that air
stripping is no longer as COst-effective as ultraviolet oxidation, ultraviolet oxidation
may be implemented in place of air stripping at any time during the performance of
the groundwater cleanup.
Ultraviolet oxidation is a groundwater treatment technology. The only component of
the selected remedy that would change if ultraviolet oxidation were implemenll:d
insll:ad of air stripping, is the groundwater treatment system. AIl other components
of the selected remedy, including the groundwall:r collection system and the
discharge system (described above), and the required monitOring and institutional
controls (described below), would remain the same.
Ultraviolet oxidation would be used to treat the Contamin~ted groundwater collected
from the groundwater' extraction wens and sent to the equalization tank.
Groundwall:r collected from the soil vacuum extraction dewatering sYStem would
also be sent to the equaH'larlon tank. Figure lOin Appendix A is a schematic of the
alternate groundwater treatment system. In this prOcess, ozone or hydrogen peroxide
would be added to the extracted groundwater. The solution would then be exposed
to ultraviolet light in a reactor. The u1~violet light would cause the Ozone or
hYdrogen peroxide to form molecules that, because they arc highly reactive, break:
down the VOCs into carbon dioxide, water and harmless chloride salts. The carbon
dioxide and chloride salts would remain dissolved in the Water and the wall:r would
be passed through carbon filters to remove any remaining contaminants if necessary
to meet discharge standards prior to discharge to Pond 3. The gases from the reactor
would be passed through a catalytic decomposer which would convert the ~~;"ing
ozone to oxygen prior to discharging to the aanosphere.
..
..
..
The goal of this remedial action is to restore the groundwater to its beneficial use,
which is, at this Site, an actual drinking water source. Based on information
obtained during the remedial investigation, and the analysis of an remedial
alternatives, EPA believes that the selected remedy may be able to achieve this goal.
GroundWater contamination may be especially persistent in the immediate vicinity of
the contamin:mts' source, where concentrations are relarlv~ly high. Due to the high
levels of VOCs (primarily TCE), DNAPLs, i.e., undissolved chemicals, may be
present and may continue to serve as a long-term source of co~tamination in the
aquifer. The ability to achieve cleanup levels at all points throughout the area of
attainment, or plume, cannot be determined until the extraction system has been
operated and modified as necessary, and the plume response monitored over time.
Based on current data, EP A estimates that the groundwater will be restored to its
beneficial use in 3S years after implementation of the groundwater component of this
ROD, assuming that no free phase DNAPLS exist in the groundwater. During
operation, the system's perfonnance will be carefully monitored on a regular basis
and adjusted as warranted by the performance data collected during operatio.D.
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ROD DECISION
Linemaster Switch Corooration Site
Page 37
. . .... .
a)
at individual wells where interim groundwater cleanup levels have
been attained for a period of three years, pumping may be
discontinued;
b)
alternating pumping at we~ to eliminate Stagnation pointS;
pulse pumping to allow aquifer equilibration and encourage adsorbed
contami"ants to partition into groundwarcr;
c)
d)
installation of additional extraction wells to facilitate or accelerate
cleanup of the contaminant plume; and
e)
periodic reevaluation of remedial technologies for groundwater
restaration.
If the selected remedy cannot meet the cleanup levels following a reasonable period
of system operation, contingency measures and goals that are considered to be
protective of human health and the environment may be considered by EPA. Prior to
considering contingency measures and goals, EPA will evalUate, at a minimum,
whether contaminmt levels have ceased to decline over time and whether these
levels have remained constant for a specified period of time at some Statistically
significant levels over remediation levels, as verified by multiple monitOring wells.
If it is determined, on the basis of the preceding criteria and the system performance
data. that cenain portions of the aquifer cannot be restered to their beneficial use, all
of the following measures involving long-term management may occur as a
modification of the existing system:
c)
d)
e)
a)
engineering controls such as physical barriers, or long-term gradient
control provided by low level pumping, as containment measures;
b)
ARARs will be waived for the cleanup of the relevant portions of the
aquifer based on the technical impracticability of achieving further
conraminant reductions and revised cleanup levels will be established
for the relevant portions of the aquifer;
institutional controls will be maintained to prevent use of groundwater
that remains above health-based levels; .
co~.tinued monitoring of specified wells; and
periodic reevaluation of remedial technologies for groundwater
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ROD DECISION
Linemaster Switch Corn oration Site
Pag~ 38
... .... "'...
The decision to invoke any or all of these measures may be made by EPA during a
fururc review, following a reasonable period of operation of the selected remedy. If
EP A determines on the basis of the stated criteria that MCLsIMa.Gs or other
health-based ARARs cannot be achieved at the Site, a waiver of ARARs will be
invoked, which will be accompanied by an Explanation of Significant Differences
(ESD) or an amendment to the Record of Decision.
3.
Other Components of the Selected Remedy
A groundwater and environmental monitoring program will be implemented to
evaluate the pcrl'ormance of the groundwater trcaanent system and the overall
effectiveness of the remedy. The monitoring program will consist of monitoring the
groundwater and the discharge from the treatment system to Pond 3. Selected on-site
and off-site groundwater monitoring wells will be monitored periodically to
determine if the collection and treatment system is containing and reStoring the
groundwater to drinking Water standards as soon as practicable. The discharge from
the treatment system into Pond 3 will also be monitored to ensure that the discharge
is not adversely impacting .the pond and that ARARs 8Ie not violated.
In addition to the groundwater monitoring wells, the on-site and off-site water supply
wens will continue to be monitOred quarterly to insure that the Water is suitable for
consumption and other domestic purposes. If it is deteImincd that the off-site water
docs not meet drinking water standards or poses an unacceptable risk Ie public
health, carbon filters will be provided to treat the Water. If contamin:.ltion is found in
~y off-site supply well, an evaluation of the effectiveness of the entire groundwater
removal and coIlcction system will be performed as soon as practicable. Based on
this evaluation, adjustn1cntS or modifications to the groundwater collection system
will be implemented to prevent or limit further contaminant migration. If a large
number of off-site water supply wells require treattnent, other alternatives for .
providing potable water may be evaluated and implemented.
On-site wells will require carbon filters until EP A determines that the on-site waa:r
docs not pose an unacceptable risk to public health. If potable water becomes
available from a source other than the aquifer beneath the Site during the course of
the Site remediation, EPA may eliminate the requirement for carbon filters for on-site
wells.
On-site groundwater cUrrently exceeds drinking water standards and poses an
unacceptable risk to public health. institUtional controls shall be placed on the
Linemaster propeny until the Site cleanup levels arc met The instibItionaI controls
shall include deed restrictions which will prohibit the use of groundwater for
consumption or other domestic purposes unless treated prior Ie use. The deed
restrictions will also infonn future purchasers of the propcny of the groundWater
problems associated with the propcny.
A soil monitoring program to demonstrate compliance with soil cleanup levels" and a
pcrfonnancc monitoring program for the soil vapOr extraction system will also
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ROD DECISION
Linemaster Switch Corooration Site
Page 39
. -
effectively to remove the VOCs from the Zone 1 soils. Results will be evaluated to
determine future pumping mes for the SVE wells.
To the extent required by law, EPA will review the Site at least once every five
years after the initiation of remedial action at the Site if any hazardous substances,
pollutants or contaminants remain at the Site to assure that the remedial action
continues to protect human health and the environment. EP A will also review the
Site before the Site is proposed for deletion from the NPL. .
'n. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Linemaster Switch Corporation 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 CX1Cnt
practicable.
A.
The Selected Remedy is Protective of Human Health and the Environment
The remedy at this Site will permanently reduce the risks posed 10 human health and the
environment by eHminating, reducing or controlling exposures to human and environmental
receptors through treatment, engineering controls, and institutional controls. Specifica]Jy, the
risk presented by this Site is the possible ingestion of groundwater that is contamirtared with
YOCs. The selected remedy uses a soil vapor extraction system to treat soils that are
contaminated with VOCs, and thereby eliminate the migration of VOCs &om the soils to the
groundwarer. The selected remedy also uses groundwater pump and treat ccchnology, ie.,
the air stripping or ultraviolet oxidarion system, to contain and reduce the levels of
contamination throughout the groundwater plume. Engineering controls, such as adding
enhancements to the soil vapor emaction system or modifying groundwater pumping rates,
will be implemented if necessary to improve the effectiveness of the seleetcd 1Cmedia1
action technologies. Institutional controls, in the form of deed restrictions, will be
implemented to ptevent the use of untreated contaminated groundwater until cleanup goals.
have been met. Groundwater monitoring will be performed to assure that the COntaminant
plume is receding and that off-site water supply wells do not become contamin:ued..
The selected remedy wiIl achieve potential human health risk levels that attain the 10-- to
ur incremental cancer risk range and a level protective of non-carcinogenic endpoints. and
will comply with ARARs and to be considered criteria. At the time that the Interim
Groundwarer Ceanup Levels identified in the ROD and newly promulgated ARARs and
modified ARARs which call into question the protectiveness of the remedy have been
achieved and have not been exceeded for a period of three consecutive years, a risk
assessment shall be performed on the residual groundwater contamination to determine
whether the remedial action is proccctive. This risk assessment of the ICsiduaI groundwater
contamination shall follow EPA procedW"Cs and will assess the cumulative carcinogenic and
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ROD DECISION
Linemaster Switch Cornoration Site
B.
.
.
Page 40
- - -. -
risk assessment, the remedial action is not deteImined to be proteetive by EP A, the remedial
action shall continue until protective levels are achieved and have not been exceeded for a
period of three consecutive years, or until the remedy is otherwise deemed protective.
These protective residual levels shaI1 constitute the final cleanup levels for this Record of
Decision and shall be considered pcrfonnance Standards for any rerneAilli action.
EP A esrim~~s that soil cleanup levels will be achieved in three to ten years, and that
groundwater cleanup levels will be achieved in 35 years.
.,
Considering all of the clements of the selected remedy, EPA has determined that the
selected remedy is protective of human health and the environment.
The Selected Remedy Attains ARARs
This remedy will attain all applicable or relevant and apPlupriate federal and state
requirements that apply to the Site. Environmental laws from which ARARs for the
selected remedial action are derived, and the specific ARARs include:
Chemical-Soecific
.
Safe DrUiking Water Act (SDW A) - Maximum Contamin~t Levels CMG..s) (40 CPR.
141.11-141.16)
.
Safe Drinking Water Act (SDW A) - Maximum Contaminant Level Goals (Ma..Gs)
(40 CFR 141.50 and 141.51) (non-zero MCLGs)
Resource Conservation and Recovery ACt (RCRA) ~ Groundwater Protection
Standards (40 CFR 264.94)
.
.
Connecticut Standards for Quality of Public Drinking Water (Section 19-13-8102 of
cr Regulations of State Agencies)
Connecticut Water Quality Standards (Section 228-426 of the Connecticut General
Statutes) Subpart IV - Groundwater
.
.
Water Quality Standards and Criteria
Clean Air ACt (CAA) - State Implementation Plan Emission Standards
.
Clean Air ACt (CAA) - National Emission Standards for Hazardous Air PoDutants
(40 CPR 61)
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ROD DECISION
Linemaster Switch COl"Doration Site
. <.
.
.
.
.
Page 41
. .... - .. ..
Location-Soecific
.
None (No activities are contemplated that will take place in or affect wetlands)
Action-Soecific .
.
Resource Conservation and Recovery Act (RCRA) - Facility Standards. (40 CFR.
264) .
.
Resource Conservation and Recovery Act (RCRA) - General Facility Standards (40
CPR 264.10 - 264.18)
.
Resource Conservation and Recovery ACt (RCRA) - Preparedness and Prevention
(CFR. 264.30 - 264.31)
.
Resource Conservation and Recovery ACt (RCRA) - Contingency Plan and
Emergency Procedures (40 CPR 264.50 - 264.56)
Resource Conservation and Recovery Act (RCRA) - ManifeSting, Reeordkeeping, and
Reponing (40 CFR 264.70 - 264.77)
.
.
Resource Conservation and Recovery Act (RCRA) - Releases from Solid Waste
Management Units (40 CFR. 264.90 - 264.1(9)
.
Resource Conservation and Recovery Act (RCRA) - Cosure and Post-Closure (40
CPR 264.110 - 264.120)
.
Resource Conservation and Recovery Act (RCRA) - Surface Impoundments (40 CFR.
264~ - 264.249) .
.
Clean Water Act (CW A) - National Pollutant Discharge Elimination System
(NPDES) (40 CFR. 122, 125)
.
Resource Conservation and Recovery ACt (RCRA) - Air Emission Standards for
Process Vents (40 CFR 264 Subpart AA)
Resource Conservation and Recovery ACt (RCRA) Air Emission Standards for
Equipment Leaks'(4O CPR 264 Subpart BB)
Water Quality Standards (Section 22a-426 of the Connecticut General SWUtes)
Water Pollution Control (Section 22a-430 of the Conriecticut General Statutes)
-------
ROD DECISION
Linemaster Switch COI"Doration Site
Page 42
. - ... -
To Be Considered
.
Safe Drinking Water Act (SDWA) - Maximum Contaminant Level Goals (MQ.Gs)
Environmental ProteCtion Agency (EPA) - Risk Reference Doses (RIDs)
.
.
Environmental Protection Agency (EPA) - Carcinogen Assessment Group Potency
FactOrs .
."
.
Environmental Protection Agency (EP A) - Health Advisories and Acceptable In.take
Health Assessment Documents
.
Environmental Protection Agency (EPA) - Groundwater Protection Strategy .
.
Ambient Water Quality Criteria (A WQC)
Office of Solid Waste and Emergency Response (OSWER) - Air Stripper Conrrol
Guidance (Directive 9355.0-28)
.
A detailed listing of ARARs can be found in Tables 14-16 in Appendix B of this Record of
Decision. These tables give a brief synopsis of the ARARs and an explanation of the
actions necessary to meet the ARARs. These tables also indicate whether the ARARs are
applicable or relevant and apptopriate to actions at the Site. In addition to ARARs, the
tables describe standards that arc To-Be-Considcrcd (TBC) with respect to rcmcdiaI actions.
." .
c.
The Selected Remedial Action is Cost-Effective
In the Agency's judgment, the seleCted remedy is cost-effective, i.e., the remedy affords
overaII effectiveness proportional to its costs. In selecting this remedy, once EP A identified
alternatives that arc protective of human health and the environment and that attain, or, as
appropriate, waive ARARs, EP A evaluated the oVCIall effectiveness of each alrerrwive by
assessing the relevant three criteria: long term effectiveness and permanence; reduction in
toxicity, mobility, and volume through ~atment; and short term effectiveness, in
combination. The relationship of the overall effectiveness of this remedial alternative was
determined to be proportional to its costs. The present worth costs of this remedial
alternative arc:
Combined Source
Control &. Management
of Migration
Alternatives
SC-3 &. MM-4
SC-3 &. MM-5
SC-4 &. MM-4
SC-4 &. MM-5
Cauital
$516,000
$637.900
$765,000
$886,900
Operation &;
Maintenance
$2,733,000
$3,522,500
$2,783,000
$3,572,500
Total Costs
$3,249,000
$4,160,400
$3.548,000
-------
ROD DECISION
Linemaster Switch COl"Doration Site
Page 43
. .. . a -
Of the source control alternatives, the estimated total costS of Alternatives SC-l (No
Action), SC-2 (Containment), SC-3 (Vacuum Extraction), SC-4 (Vacuum Extraction With
EnhancementS), and SC-s (Biodegradation) are all between $1 and $2 million. The
estim:!red total costS of SC-6 (On-Site Incineration) and SC-7 (Thermal Stripping) arc both
over $7 million. Specifi~y, the range of esrim:!ted total COStS for the source control
. alternatives, from the least to the most expcnsive alternatives, is: $1.230,000 (SC-3,
Vacuum EXtraction); $1,443,500 (SC-I, No Action); $1,516,000 (SC-s, Biodegradation);
$1,529,000 (SC-4, Vacuum Extraction with EnhancementS); $1,838,000 (SC-2,
Containment); $7,785,000 (SC-7. Thermal Snipping) and $13,910,000 (SC-6, On-Site
Incineration). .
The selected soil vapor extraction remedy (SC-3) is the least expensive source control
alternative ($1,230,000), in pan because several of the other alternatives, including the no
action alternative, include the cost of 30 years of monitoring. SC-3 (Vacuum Extraction)
does Dot include 30 years of monitoring.
If enhancementS such as air sparging are added to the soil vapor extraction remedy, ie.,
Alternative SC-4 (Vacuum Extraction With EnhancementS) is performed, the estimated total
cost of the source control remedy will be $1,529,000. This amount is greater than the
estim:!red total cost for SC-l (No Action), and SC-s (Biodegradation) and SC-3 (Vacuum
Extraction), but is less than the estimated total COStS for SC-2 (Containment), SC-6 (On-Site
Incineration) and SC- 7 (Thermal Stripping).
In comparing the effectiveness of the source control alternatives, SC-3 (Vacuum Extraction)
and SC-4 (Vacuum Extraction With Enhancements) both treat the VOCs present in the soils
and therefore provide permanence. Both alternatives also treat all of d1c contaminated .soils,
including soils located under Linemaster's manufacturing building. Although SC-4 (Vacuum
Extraction With EnhancementS) is more expcnsive than SC-3 (Vacuum Extraction),
enhancements to the SVE system, such as air sparging, will only be implemented if EPA
determines after the SVE system has been operating for five years that performance of soil
vacuum extraction. alone will not achieve soil cleanup levels within the estimated ten year
period. .
Of the source control alternatives that were not seleCted, the No Action alternative eSC-l) is
not considered to be protective of h~ health and the environment because it does not
include measures to minimize the continued migration of contaminantS to the grcWldwa.ter..
SC-S (Biodegradation) may Dot be as effective as SC-3 (Vacuum Extraction) or SC-4
(Vacuum Extraction With Enhancements) in the long term because SC-s (Biodegradation) is
Dot.a proven technology. Alternatives SC-2 (Containment), SC-6 (On-Site Incineration) and
SC-7 (Thermal Stripping)~ the three most expensive alternatives considered, do not reduce
the mobility and volume of contaminants to the same degree as SC-3 (Vacuum Extraction)
and SC-4 (Vacuum Extraction With Enhancements).
Compared to all of the source control alternatives, no other alternatives provide the same
degree of protection and long-term effectiveness as SC-3 (Vacuum Extraction) and SC-4
-------
ROD DECISION
Linemaster Switch Corooration Site
Page 44
. - - '- ...
Of the management of migration alternatives, the range of esrim~ted toCLI costs from the
least to the most expensive alternatives is: $1,398,500 (MM-l, No Action); $2,019,000
(MM-4. Air Snipping); and $2,930,400 (MM-S, Ultraviolet Oxidation).
The No ACtion alternative, MM-l (No Action), is not considered to be protective of human
health and the environment because groundwater' would not be :n:stored to drinking water
levels through natural attenuation for 500 years.
~.
Both MM-4 (Air Snipping) and MM-5 (Ultraviolet Oxidation) are equally effective and
provide for equal degrees of protection and permanence. The esrlm~ted total costs of MM-4
(Air Stripping) are less than the estimated total costs of MM-S (Ultraviolet Oxidation).
MM-5 (Ultraviolet Oxidation) will only be implemented at the Site if COSt estimates change
over time such that it becomes less expensive to perform ultraviolet oxidation than air
strippiJ,tg over the long-term Operation of the groundwarcr pump and treat system.
D.
The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or
Resource Recovery Technologies 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 permanent solutions and alternative treatment technologieS or :n:so1Il'CC
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) :n:d~ction of
toxicity, mobility or volume through treatment; 3) short-term effectiveness;
4)implementabiliry; and 5) cost. The balancing test emt)hasized long-term effectiveness and
permanence and the reduction of toxicity, mobility and volume through treatment; and
considered the preference for t:n:aanent as a principal element, the bias against off-site land
. disposal of untreated waste, and community and state acceptance. The seleCted :n:medy
provides the best balance of trade-offs among the alternatives..
The selected source control alternatives, SC-3 (Vacuum Extraction) and SC-4 (Vacuum
Extraction With Enhancements), provide long-rerm effeCtiveness and permanence because
VOCs in the soils will be treated and destroyed. In addition, emission controls will preveDt
the transfer of VOCs &om the soils to the atmosphere. Following completion of the source
control component, no further controls on the Site soils will be necessary. These
alternatives reduce the toxicity, mobility and volume of soil contaminants through treatment.
The iaiplementation of these alternatives will have mini~t adverse impacts on workers .
(such as inhalation of fugitive dust), and any such impaCts can be controlled with protective
equipment, and other protective measures. Alternatives SC-3 (Vacuum Extraction) and SC-4
(Vacuum Extraction With Enhancements) are also readily implementable. Of all of the
source control alternatives considered, Alternative SC-3 (Vacuum Extraction) is the least
expensive. Alternative SC-4 (Vacuum Extraction With Enhancements). approximately
$300,000 mo:n: expensive than SC-3 (Vacuum Extraction), is among the least expensive
source control alternatives conside:n:d for the Sire. Both CT DEP 1\I1d the community are
-------
ROD DECISION
Linemastel" Switch COl"Doration Site
Page 4S
- -. -
None of the other source control alternatives provide the same levels of protectiveness and
permanence. Alternative SC-l (No ACtion) is not proteCtive of human health and the
environment because it does not minimize the migration of COntaminantS from the soils to
the groundwater. Alternatives SC-2 (Containment) does not meet ARARs, does not use
ttcatmenr, and does not prevent the migration of contaminantS located under the cap and
under Linemastcr's manufacturing building. Although Altcnwive SC-S (Biodegradation)
employs treatment, it is not a wen developed technology and would n:quire significant pilot
testing prior to implementation. Alternatives SC-6 (On-Sire Incineration) and SC-?
(Thermal Stripping) also use treaancnt, but these alternatives do not address contaminared
soils located under Linemaster's manufacturing building. SC-6 (On-Sire Incineration) and
SC-? (Thermal Stripping) would also expose workers and residentS to short-term risks
associated with the excavation of the soil, and would be considerably more expensive to
perfmm than the selected alternatives.
Of the Management of Migration altcmatives, both MM-4 (Air Snipping) and MM-S
(Ultraviolet Oxidation) provide long-term effectiveness and permanence by reducing
contamination present in the groundwater. They both reduce toxicity, mobility and volume
of contaminantS through groundwater pump and treat technology. In addition, both of these
alternatives use controls to prevent the transfer of contaminantS to the atmosphere. To
promote short-term effectiveness, these alternatives require the use of institutional controls
to prevent the Use of contaminated groundwater until cleanup levels are mel Both .
alternatives are also me readily implementable and cost-effeetive. In addition, both cr DEP
and the community are Supportive of the selected management of migration altenwives.
The only other Management of Migration a1tcmative~ MM-l, No ACtion, is not pro1eCtiye of
human health and the environment be-~use groundwater would not be restored CD drinking
water standards for. 500 years.. .
For the above reasons, the Agency has determined that the selected source control and
management of migration remedy utilizes permanent solutions and alternative ttcatmcnt or
resource rccoveJy technologies to the maximum extent practicable.
E.
The Selected Remedy Satisfies the Preference 101" Treabnent Which Permanently and
Significantly reduces the Toxicity, Mobility or Volume of the Hazardous Substances as
a Principal Element
.The principal element of the selected remedy is the soil vapor extraCtion system and the
groundwater IrCatmcnt system. The source control Component of the remedy will capture
the VOCs in the Zone 1 area, thereby providing significant reduCtion in the toxicity.
mobility and volume of the contaminantS at the Site through treaancnL In addition, carbon
emission controls will be used so that contaminated vapors released from the soil vapor
extraction system are not transferred CD the atmosphere. The groundwater treatment system
will effectively contain and treat the contaminated groundwater. In addition. the carbon
adsorption system will assure that contaminated vapors released from the air stripping or
ultraviolet oxidation system are not transferred ro the atmosphere. The selected remedy
therefore satisfies the statutoIy preference for ttearment which pcrmanendy an~ significandy
-------
ROD DECISION
Linemaster Switch COl"Doration Site
Page 46
. ... .. .
xn. DOCUMENT A TION OF SIGNIFICANT CHANGES
EP A presented a proposed plan (preferred alternarlve) for remediation of the Linemaster Switch
Cmporarlon Site on April 14, 1993.
The source control portion of the preferred altcmative included:
.-
.
restoration of the soils by vacuum extraction with enhancements such as air sparging
as necessary;
.
monitoring to evaluate the perf'OImance of the remedy; and,
.
a fence to limit ~ess. .
The management of migration portion of the preferred alternative included:
.
restoration of the groundwater by extraction and treatment either by air stripping or
ultraviolet oxidation; "
.
monitoring to evaluate peIfmmance of the remedy; and,
.
institUtional controls to prohibit the use of untreated contamin.Qted groundwater.
. .
The remedial action selected in this document includes the following changes from the preferred
alternatives described in the Proposed Plan. Due to adminiStrative error. some of the interim
groundwater cleanup levels 1is1cd in Table 1 ~ ~e Proposed Plan did not include the correct MCL
numerical listing. Table 16.in Appendix B of this ROD has corrected this error. In s1l1mDaly, the
interim cleanup levels were changed for the following compounds: benzene, 1.2-dicholoroctbane.
and mcthylethyIkerone. In addition, the following compounds were erroneously included on the list
of interim" groundwater cleanup levels in the Proposed Plan. and have been removed from the list of
interim groundwater cleanup levels as presented in Table 16 of this ROD: trans-l.2-dichlorocthene.
mcthyleterbutylether. and xylenes. The following compounds, however. were added to the list
presented in Table 16 along with their interim groundwater cleanup "levels: belyUium, carbon
tetrachloride. chloroform, chloromethane. 1.1,2.ttichloroetbane, acetone, cadmium. and 2-hexanone.
In addition. the Proposed Plan erroneously indicated that all of the source control alternatives
complied with ARARs. However. as correCtly shown in the FS Addendum, Alternative SC-2
(Containment) would not comply with ARARs. Under this alremalive. the placement of a cap over
a portion of the contaminated soils would not meet RCRA requirements because a ponion of the
soils would remain beneath Linemaster's manufacturing building. This ettOr has been COl~~ted in
this ROD.
Fmally. the Proposed Plan did not clarify how or when EP A intended to determine whether
" enhancements to the soil vacuum extraction system would be required. The process for making this
-------
ROD DECISION
Linemaster Switch Cornoration Site
Page 47
". - ~ - -..
xm. STATE ROLE
The Connecticut Department of Environmental Protection (CI' DEP) has reviewed the various
alternatives and has indicated itS support for the selected remedy. The Swe has also reviewed the
Remedial Investigation, Risk Assessment, Feasibility StUdy and the. Feasibility StUdy Addendum to
determine if the se1ccted remedy is in compIiancc with applicable or relevant and appropriate State
Environmental laws and regulations. The State of Connecticut concurs with the scIccted remedy for
the Lincmaster Switch Cmporation Site. A copy of the declaration of concmrcnce is attached as
Appendix D.
-------
APPENDIX A
RECORD OJ' DECISION
LINEHASTER SWI~CJI CORPORA~ION SUPERJ'UNI) SITE
LZS'1' OF J'IGURES
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
Figure 9
Figure 10
- site Location Map, Linemaster Switch Corporation Site
- Extent of TCE Contamination in OVerburden Groundwater
- Extent of TCE Contamination in Bedrock Groundwater
- Alternative SC-3: Typical Extraction Well
- Alternative SC-3: Vacuum Extraction System Layout
- Alternative SC-4: . Typical Injection Well
- Al ternati ve SC-4: Extraction Trench
- Alternative SC-4: Process Orientation
- Alternative MM-4: Air Stripper Schematic
- Alternative MM-5: Ultraviolet Oxidation Schematic
-------
FICURE 1
LINEJlASTER SJYlTCH CORPOP.ATION SUPERFUND SITE
~
.~
"
1,
"0
.
N
.
.
..
TOWN H.W.
--,
/ \
I .. \
\ I
"-_/ .
p
II &
.....&
LEGEND:
.
~
RESIDENCES CONSIDERED NORTH
OF' UNEWASTER F'AClUTY
RESIDENCES CONSIDERED SOUTH
OF UNEILUTER FACIUTY
("'\
-
wtb
CROUNDWATER TREATMENT
PROVIDED FOR PRIVATE WELLS .
INTERIM REMOVAL SYSTDI
-------
Figure 2
Extent of TCE Contamination in Overburden Groundwater
.
. .
...
t
II
...
..-
WW-IAdb $
. Figure 3 .
Extent of TCE Contamination in Bedrock Groundwater
U
.
. .
. ...
t .
w
..-
1IW-'4411
LECEND:
----
TCE CONTAt.llNATlON IN GROUNDWATER
(CONCEHTRATION IN PARTS PER BIWON)
-,..
-------
FIGURE
ALTERNATIVE SC - 3
TYPICAL EXTRACTION WELL
..
GRADE
ACCESS SOX
GRADE 1
....... .......
-.........
~ ~::::: :: :::::: ::: :t~~i~~b:: :: : : : ::
1..IIIIIIIIIIIII:I~.III:I:I.li...i:
.. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. .. .. .. .. ...... .... .. .. .... .. ..
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~j : ~: : :: :: : : : : : : : : : : :
: : : : : : : : : : : : : : : : . -2 . ~~t:t~I~: : : : : : :
~ ~ ~ ~ ~ ~ ~.~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
: : : : :: : :: :: :: :: : ~a-: ~GER HOt.E : : : : : .
a:::::::::::::::::::::::::::::::::::::
. . . : : : : : : : m;OTm:r\ti: : : : : : : :
.. .. .... .. .. .......... .... .. .. .. .. .. .. .. .. .. .. ..
.. ................ .....
.. .. ................ .. .... .. .. .. .. .. .. ..
.. ............ .. ...... .. .. .. .. .. .. ..
.......... .... .... .... .. .. .. .. ..
.... .. .. .. .. .. .. .. .. .. .. .. .. ..
.... .... ................
.. ..................
..........
!!!~!~~~!~!~~~f!f~~~~
PIPE TO SL.OWER
-
: : : : : : : ~~~tt: . : . . . :
.............. ~:C:AP
:~~~~~~~~~~~~¥.~~~~+~~~~~~~~
:~!~~!~!!!~rffff!!!~~~~~~!~~!!!!!~~~~:
:::::::: ~~,"$iNt1E:PEL=fEt5:::::::::
~~j~~~~~jj~~~~~~!!~~~~~!~!!!jj~~~::::.
: : . . . :CO~$E: : : : : : : : : : : . .
::::::s. AND."::::::"
.. .. .. .... ............ .. ..
.. .. .. .. .. .......... .... ..........
.... .. .. .. ........ .. .... ......
.. .. .. .. .. ...... .. .. .... ....
.. .. .. .. .. ...... .. .. ....
...........
.. .. .. .. .. ...... .. ..
...... .. .. ......
PI . PRESSURE INDICATOR
FM . FLOW METER
(CONNECTION POINT)
-
I rz- PVC ClSCHARGE
TO GROUND-WATER
EXTRACTION HEADER
LlNEMASTER SWITCH CORPORATION
-------
Figure 5
Alternative SC-3: Vacuum Extraction System Layout
PROPOSED
CONTROL
BUilDING
LIMIT
INTERIM
REMOVAL
TREATMENT
SYSTEM
J
PAINT -
SHED
PROPOSED CONTROL BUilDING
. PIPE FOR TRANS FE RING
CONTAMINATED GROUNDWATER
TO TREATMENT SYSTEM
GARAGE
LINEMASTER
FACILITY
EXTRACTION WEll
DIWrlNC Nor TO SCAl.!'
...-.--... ...................-.-..... -..-..
...--..-----...-
-------
."
FIGURE 6
ALTERNATIVE SC - 4
TYPICAL INJECTION WELL
GRADE
.. ........... ........................
ACCESS BOX
GRADE 1
----r
12'":
--!.
PIPE FROM BL.OWER
....................................... ...
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
:::::::::::: :tHREAc:EO :cAP:.:..::: ::.: .
.................................~.... ..
.. .. .. ........ .... .... .... ...... .. .. .. ....
.. .. .. ........ .. ...... .... ........ .. .. .. ..
.....................
.....................
...... ........ ...........
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. .... .. .. .. .. .. .. ..
.. .. .... .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. .. .. ..
.. .. .... .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. ..
..............
.. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
.. .. .... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. .. .. .. ..
....................................... ..
-
..........................................
...........................
. . . .o8.. ... . . .... ... . .
. . ........ .. .. .. .. . . .
:;::~:C,ij.:::
. . ... . . . .. . . . . . .. . . . . . . . . . . . .. . . . . .. . . . . .
. . . . . . . . . . . . . . . .. . . .. . . . . . . . . .. . .. . . . . .
. . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . .
. . . .. .. . . . . . . . . . . . . . . .. . . . .. . . . . .. . . . . .
: : : : : : : : : : : : : : : : :J(j-: AUGER' . . . . . . . . .. . .
:::::::::::::::::~:::::::::::::::: :
. . . .. . . . . . . . . . . . . . . . .. . . . . . . . . . . . .. . . . . .
. .... . ............
. .. . . . . . . . . . . . . . . . .
... .... .......... ............ .........
. .. .. .. . . . . .. . . . . . . ........ .. .... .. . . .
. . . .. . . . . . . . . . . . . . . . ..... .. .. .. .. .. . . .
: : : : : : : : . . : :GBOIJND..'WATER nB\;E: : : : : :
... ..:: :::~i:Nt~~~::::::::::
. . . . . . . . . . . . . . . . . .. . . .. . . . . . . . . . . . . . . . .
. ........
. .............. .... .......... ..........
...................-..................
. . . . . . . .. . . . . . . . . . . -=-. . . .. . . . . . .. . .. . .. .. . . . .
... ............... ...... ...... ..........
........................... .,_.........
.. ... ............ ............... ......
......................................
......................................
. . . . .. . .. . . . . . . . . .. . ..... .. .. ... ..... . . ..
::: :::'.::::PWG:: :::::: :::::::::::::
::::::::::: ~E:$M:i::::::::::::::
. . . . . . . ..... . . . . . .. . . . . . . . . . .. . . .. . . . . . . . . .
. . . . . .. .. . . . . . . . . . ....... .. .. ..... ... . .
......................................
::::::::::::::::::::::::::::::::::~:::
: : : : : : : : : : : : : : : : : : : St..a'rtED:P.VC: : : : : . .
. ............... ....... ...............
.. ..... .......... ............. ........
.. ............o8.. ...... ...... .........
. ...........o8.... ...... ...............
.... ........ .... ......... .... .........
.. .......... .... ......... .... .........
........... ..o8... ........ .............
..................... .................
. ............ .... .................. ...
... ......... ............. ..... ........
......................................
[[[
[[[
... ......... ..........................
......................................
................................... ............. .......... ...... .... .....................
-------
FIGURE 7
ALTERNATIVE SC - 4
EXTRACTION TRENCH
AIR 5L.OWER
IMPERMEASL.E
SEAL
DISCHARGE
-=>
LlNEMASTER SWITCH CORPORATION
-------
. .
NOTE:
EXTRACTION ~ROCESS MAY INCLUDE
TRENCHES AND .lOR WELLS
FIGURE 8
ALTERNATIVE SC - 4
PROCESS ORIENTATION
..
IMPERMEABL.E
SEAL.
EXTRACTION
WELL.
EXTRACTION PIPE
CSL.O'n'ED PVCJ
GRADE
FROM BLOWER
-
...
---..-..-.....-. TO SLOWER
...~":". -.-------.....x:--- -COARSE SAM) OR
\ \ GRAVEl. BACI
-------
r:tGtrRE 9
. "
Alternative MM-4: Air Stripper and Carbon Adsorption Treatment Schematic
Carbon Ad8arpllon Filt-
TIUllClIUt III
AmIoapft-
EqvlJlzallonf
Sealing Tank
y
SoIic:s :II CII-site
Di8pasaJ
UI8CI ~ :II
V8ftCIOr tar
Reg-.n
r,.8I8CI GtauncIwaI8r
IDPond:S
-------
FI:GURE 10
" .
Alternative MM-5: UV/Oxidation and Carbon Adsorption Treatment Schematic
eoftl8minar8d Gtounc:w.r
From Exn=oft Wells
. ".,..
EquillzadOfti
Sellllng TanJc
.....
UYlOddatlon Reactor
Uwa c.aon to
Vtftdor lor
Rev-.on
-
Soids II» Ol-Sire
Disposal
Ozone or
~
P-lid.
rreat8d Gtaurlctwatar
toPoncI:I
-------
Table ~
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table ~l
Table 12
Table 13
Table 14
Table 15
Table 16
Table 17
APPENDIX
B
RECORD OF DECISION
LINEHASTER SWI!1'CH CORPORA!1'ION SUPERF'OND SITE
LIS!1' OF TABLES
- Baseline Risk Assessment: Zones ~ & 4 Surface Soils
- Baseline Risk Assessment: Zones ~ & 4 Sub-surface Soils
- Baseline Risk Assessment: On-Property Till Groundwater
- Baseline Risk Assessment: On-Property Bedrock Groundwater
- Baseline Risk Assessment: Contaminants of Concern
- Potential Exposure Pathway Summary
- Carcinogenic Risk Characterization Summary
- Non-carcinogenic Risk Characterization Summary
- Summary of Surface Water Contamination, Water Quality
criteria, and Hazard Indices for Aquatic Biota
- Summary: Screening of Al ternati ves
- Summary: Source Control Alternatives
- Summary: Management of Migration Alternatives
- Chemical~Specific ARARs and TBCs for the Selected Remedy
- Location-Specific ARARs and TBCs for the Selected Remedy
- Action-Specific ARARs and TBCs for the Selected Remedy
- Interim Groundwater Cleanup Levels
- Soil Cleanup Levels for the Protection of Human Health
-------
'rABLE 1
Unemastef Switch Baseline Risk Assessment
Soli; Zones 1 and 4
SUrface (D-2 ft) Data Summary
volam. Organics
cis-1 ,2-Clc:hJoroe1hene 47.2 93S OW.$( 3 '0
Ethylbet1Z8fte 2.5 9.1 OW.1t 1 '0
81rad1Jotoethene 15.4 200 OW"," 3 32
oluane 10.5 180 B-38 3 '0
1,1,1.Trichloroethene 2.9 11 8-25 1 2B
ric:hJc:Iroe1hene 66.6 1200 B-38 13 32
Xylena 6.5 100 OW.1t 5 27
Semi.Volatile.
OI-n-butylph1hala1e 563.1 2050 OW.2t 1 4
Metals
Arsenic, Total 10305.8 20700 8-47 12 12
Cadmium, Total 6536.3 40300 B-34 9 12
...
Prtmary surtace
-------
TABLE 2
Unemaster Switch Baseline Risk Assessment
Soli; Zones 1 and 4
Sub-surface (G-8 ft) Data Summary
" .
Volatile Organics
1.1.1 -Trichloroethene 9.1 11.0 B.25 (0.2) 1 78
Acetone 31.3 460.0 MW-1Ots (5-7) 1 54
cis-1,2-Dichloroethene 25.0 938.0 OW-5t (0-2) 4 54
Ethylbenzene 84.5 2. 750.0 B.23 (6-7) 4 58
Tetrachloroethene 80.1 2.800.0 MW-1Ots(5-7) 9 80
Toluene 274.5 7.577.0 B-23 (6-7) 10 58
Trichloroethene 122.6 4.022.0 B- 7 (4-S) 22 80
Xylenes 264.4 8.300.0 MW-1Ots (5-7) 11 58
Semi-V olatf/es
B/s(2-ethylheXYQphthaiate 1814.8 13.229.0 B-50 (3) 3 12
Di-n-butylphtha/ate 536.7 2.050.0 OW-2t (0-2) 2 12
Metals
Arsenic. Total 11220.9 38.100.0 B.51 (31 26 26
Cadmium. Total 4500.9 40.300.0 B-34 (0~2) 14 23
Primll/Y Subsurface
-------
T~LE 3
Unemaster Switch Baseline RisJ( AsSessment
On-Property 'Till Ground Water Data Summary
VolatDe Org8nica
Ac:8lone 2129.. 50.000.0 Mw161 3 49
Benzene ".7 54.0 MW161 5 1 3 T7
CaItIon I8UadIIoricIe 47.5 1..0 MW17TS 5 2 5 72
2.ChIoro8UIyI vinylltll8t 1.2 5.4 GW30 1 6
ChIorotorm 58.7 17.0 DW01TPT 100 0 6 ~
1.1-DictIIoroethane 109.5 813.0 MW10TD 1. 72
1,2.Dic:htoroethane 70.9 7.8 MW17TD 5 2 . 72
1,1-0idllolO8ltlene 76.6 275.0 MW10TD 7 9 10 72
1,2.0idllolO8ltlen8 Ga.2 1,950.0 MW10TD 70 3 6 6
cis-1,2-CictIIoto8It18I11 803.5 25.000.0 MW161 70 13 34 66
Irans-1,2-DictIIoroeltlene 2.5 28.7 MW30 100 0 1 1.
Oic:hIcIRImelhane 236.6 1.810.0 MW10TD 5 6 6 ~
1,2-DidIIolqlr'Clpllle 169.9 420.0 MW161 5 1 2 72
ElhylblnZllne 75.4 460.0 0w01TPT 700 0 13 68
2-Hexan0n8 766.3 2.100.0 MW161 2 49
M81hy11sobuty1 KetDIII 7068.3 350,000.0 MW16T 2 63
Methyl ethyl ketone 1360.5 38.000.0 MW161 2 49
T8\IaChIoroetJIe 132.1 1,800.0 DW01TPT 5 17 21 87
1.1.1- TrichIoro8Ihan8 103.1 1.700.0 DW01TPT 2!XJ 6 24 . 80
1.1,2- TrichIoI'a8UIane 71.9 23.0 MWEPMT 5 1 2 71
T oIu8ne 2529.6 64.000.0 MW16T 1000 12 23 68
TridIIatoettI- ~1.9 800.000.0 MWZST 5 59 68 ~
. VInyl acaID 728.0 1.830.0 MWlMT 1 .9
Xylene 164.0 1.200.0 MW2ST 10000 0 13 59
Me,...
Alsenlc 15.5 185.5 MW12T 50 3 30 52
BerylDum 1.7 .87.0 MW23T 1 17 18 37
C&dmium 63.3 757.0 MW23T 5 13 ,. 37
MCL.. Muimun Conl8llin8nt I.8w8I (EilA. 1S2: Drinking Wal8t Regula-a 8IId HaIti AcYisori8sj
11U...XLS
-------
TABLE ..
Unemastar Switch Baseline Risk Assessment
On-Prop.fIY Bedrock Ground Water Data Summary
Votat118 Organics
Act*- 158.9 3.6CO.0 GWoeDB 13 132
Benzene 8.~ 28.0 MW17DB1 5 2 6 151
CattIon ..,... 7:1. 1 ~.O GWOSDB 2 150
ChIoroIonn 6.8 30.7 GW10DB 100 0 3 260
Chiolanelhane 53.8 63.0 MW11CB2 5 213
1.1~ 11.8 120.0 MW10S8 .7 217
1,2.CidllclraetIlane 11.6 2.8 GW10DB1 5 0 2 213
1.1-Diclllaraethene 8.5 83.0 MW10S8 7 10 35 270
1,2~ 2.315.5 6.800.0 GW10DB3 70 33 34. ~
a.1,2-Did11oraelhene 274.6 15.000.0 GW10DB3 70 29 85 145
llans-1,2-Dic:tIIcn8lhene 280.6 10.177.0 ' GW10DB 100 30 57 190
DicIIIarodiIuolameIhane 50.0 8.9 MW12D84 1 207
Dic:tIIoramelhane 0.8 24.0 GW36D8 5 1 1 52
1,2~ 18.2 33.0 MW06DB3 5 5 12 214
Elhytbenzene 13.7 230.0 MW10S8 700 0 10 150
2-Hexanone 89.0 eso.O MW10S8 2 132
Metllyllsobulyl K8Icne 76.1 1.180.0 MW10SB 6 156
Tell'acllloraelJlne 11.8 430.0 GW12DB 5 28 39 269
Toluene 210.3 7.800.0 MW10SB 1000 11 78 175
1.1.1- T rictIIoto8lhane 5.5 59.0 MW10SB 200 0 25 269
1.1,2- Tric:hIorcI8lhane 8.2 3.3 GW10DB1 5 0 1 212
Tric:IIIoroIthene 3,859.3 59.000.0 GW10DB 5 177 .' 214. 278
TriclllonIIIuoram8Ihae 0.6 2.4 GW36DB 1 53
Vinyl aceW8 84.2 264.0 GW10DB1 1. 132
VInyl chlaride 20.3 10.0 GW10DB1 . 2 1 2 212
Xylene G.2 760.0 GW10DB3 10000 0 24 1~
"etals
Arsenic .1.2 513.0 GW10DB3 50 ZO 112 131
ElerylUn ..:7 75.0 MW27SB 1 26 ~ 7:1
Cadmil8n 7.1 87.0 MW15C81 5 21 27 73
IICL. WaImum ConI8mIn8I LM8I (EPA, 1182; DrtnIdn; w.., R8guIIIians IIId HIIIII Ad¥iIaII8I)
..
BROCI<.XLS
-------
TABLE
5
-.
Un.m...., SwItch BueIIM Rbk "--,
Conl8mlnanla 01 Concem
Grounclw8'" Ezpoaun Zanes
Voidl..
Aca-
Benz.".
CaItIon cbuIiIe
CaItIon I8II8dIIoride
2.cNc1raat11J1 WIyt ....
CNan:iIomI
~
~.~
D~
1.1..Qic:1da1oe111
1,z.~
I.I~
t.Z~
c:il-I.2-Dic111otoe1llent
118M- ,,z.oicNoloelll8ll
W..""*"-
1,Z.DidIb....._-
~
2""-
M8t!lyl1II¥ --
""1/IyI~u.-
MaI/IyII8I1 buIyI"" (UTBE)
1.1,2.2.Tatr8CNcND81b8118
T~
TaIuIM
1.1.'. TIi.~........
, .1,2.TjicllloRllll1illll6
TIIdIboedIe-
T~
V..,.-
VInJI cNarida
X,.,..
II
II
]I
]I
]I
II
II
II
II
. .
]I
I
II
II
II
II
II
II
I
]I
]I
]I
I
II
II
II
I
I
]I
II
II
II
.
II
]I
.......
AI8nic, TOIII
BaryIUn. TOIII
CIcImUII. TOIII
]I
]I
II
II
I
.
.. he ......-......------.
......-------...--........,...----.... j
...............,....---- .,
.
-
-------
TABLB .
'ot,...,.. 1.'111' 'ethw.,. 8V111"'''
B: .',~P'fIT7~fl?r~:~ ;r:~:"':?:;~:~~ TrI.7'?;~7]~?;;:"~~:! ~?~T.:~;.~';T:' {~-:. ,:'~:~,::!:;i':::.7~'~:7n?fF\ ~I~, '~~~it:?~'::~::"~~~.~':;7",;'~.\' :;'f~;:;' r;'7.; ~.;~.~~~~;;:';:~~~~~\~~~~It::~
' . '{' I.~I"~~"J./.i ~ .. ~ . ~.~".,::}. ~ !.~~':~!.,~.....; ,:,)~.II}I : ~ . ~!.....::.;: ,'~. 1:--,' :i;--"':~~~;:',.' \~.!:.:'.,:' ,.~' ';,:~::, ,',~ ..\. ~.':'i! r..~.\~ '.;..\ ;~..' ':'. -'I:':' ~ 1.'---':)' L.'-~/"'="~" .. '."~
" I ,',' ':.,' ., 0" .'~H.,:.i! .-.:.t~-f :-;'.- '''.:'~'.t:i J..' -:. '."~ .....~1" 'i1!.~: J'....',.. , -'"..,- \. ~ .' .... './"'1' -. ,';' . - .~'. ,", " 1" ~ ,.~t... ,- ,I;' "
, ~~~J1lt~~."":J...""",,-,,,, ,,;,,.:1... ,.,'--:t-_".i;:.A''''':''~ .~.,:.-:,l.,.;[-,'.",jut.,,,,,.(..I,..... J.".\~,JW:,.I,..l~' ~""hll!....:[:t.~lt.iUU""';"'~'~'I\...;~..illl:'.!i,""".b:,
tnII,1tI1on
IntlllIIIan 01 VIpOII On.", WOIbll '.'''1011 of vepor' voI8III18d from 801 during -II
MIl 8IId ClId RHId8nI, end ,te'MlIan telllll....
Construction Worall
I Intllllllon of P'rllcullln Rnld8nll. H~ v8Cf8',led !If": ",",''''OIl otllrbam8 pertlcul,'..
Construction WorIrIII IIII~ ..." II dirt 1II1d"" or,""",,1n VlhIe... uMd In '''' I'''.
For cOIIII,uctlon_Ir"" '.'''Ion 01 flll\1cuI,'.. " po"IbI,.
,.lttlon 01 p8I\1c'" II accounlld lor In !nonllan pllhw,y.
:I InhtI8I1on of Ita_... VIpOII Mull IIId ClId Rnld8nl, III,,,,,,,,,, In Ih8 .... hIv. VI" low "","Mlln" 80 IhII
pelhwey - naI quenlltllwlly "''''''',d.
""'1.lon
4 .II!on of FugIIlwI Plllld.. ""IdenI, H'." v'V""td "'8; 1II-'1Ion end lubttqU8n1lngttllan
COIIIlructlan WClllrtll on" ..." In dill billing lcenl'lo ",enIlonId ,bov,. For
canolrucllan wark.." "'II"0on o' PM""I 'I polllbl.,
ConIlmlntnl "","'Ian eccounlld lor In !non.1an "'1" p..hw.y,
. Jnctttlloll oI8oIIIB8dIm8n1 0.811. MIll end OJId Rnld8nl, Incld8nlailnOlll1on oil" durt"" ,te'MlIan ICI"'IIII
COIIII,uclloII WorIrI" IIId WOIII optllU-
T'"","",
. '''0111I0Il 0I801188d1m'''' 011.811' N- Highly toe,and ,GUIce ."a: 011'111, .,.., nof
chlrld.rtlld, ThII pllhny.., naI quantl"IY.., .."lull,d,
, """'lion of Ground WII" MIl IIId OJId R.IdenI, OIrICl'''II''IIan 10, '" ldul' end chlldr", In th.
'UflCMldlng commun'U.. Ihrough ti'1nII1ng WlI"
("Iumld unI""ed)
8 ,",,"Ion 01 PI"'" N- No tgr\cull... OIlIortlcullu" within 'Iudy ....
I """,'Ian oIlurtac. WII" MIll end OJ" R.IdenI, Incldtnl,I 1n1l'l11on 0"""- w8l" during fIllY.
end poIlnd., ~"I 1111 .. ti'lnIdng .tI"
.0 ,,,,,,11I0Il of Aquelk: Il1011 N- No 8VId8nc, or I.",,,,, In II. "udr ....
0,,,,,.. eo....
" Derm" ConItd wlh 8oIIIB8dIrn"" 0.811 Adul end ClId R"IdenI, 801 8dh8r,ncl 1o IIdn durtng 'te"IIlon teI"'I'"
COIIII,ucllon WOt"" end _II optllU-
T'npu.."
.2 Dtrm" Con\td with 8oM18d1rn"" 01..81. N- Highly Iocllred .ourc. "'II: 011..11, '''" nof
charldtrllld. Thll pelhw., WI' noI qUlnlltUw" .Ifull,d.
., Dermal ConIld wRIt Ground WeI" MIl end CI.. RllldenIl DlrICl corbel 10 grClllld WII" (.lIumed U""""d) willi,
.,bltl1lng end wllI1I"".
14 Dermal Cord'd wRIt en_", 818p11g8 Adul end ClId R.Id8nI, D8c:"I.ed conIlCt 'I" "'d Incllaed ,nl.,InC.to upl.k.
"due. rIItr, InIlgnlllc.... compl'ed 10 IngnUon pelhw',..
.11 Dermal Con\lCI wIIh 8urllce W.," MIll .nd OJId RII"'IIIII DIrICl conlllCI 1o .urtllC. WI'" Whh playing In I"n.
PoI""I8IIuIur. ,.potur. WhIle wailing or bit""'"
-------
TABLE 7:
CARCINOGENIC RISK CHARACTERIZATION SUMMARY
00
i:i.;;:!i{i~!:::i.:::~::~1;ia~£;a.~~hig{::~~ki::'::@'~:a~id:iiti6;::~:::~~:;~;:~!£ii~;~:tiaB::::!::~:f::::::Gi8=iitiit;~f.::::;:;~;:::)::;::::::~~
Estimated Incremental
Source of Groundwater Cancer Risk
Average Kazimum
On-Property Overburden Aquifer 9E-03 lE-O 1
On-Property Bedrock Aquifer 2E-03 3E-02
Off-Property (North of Site ) 9E-0 5 lE-O 3
Off-Property ( South of S ite ) lE-O 4 2E-0 3
-"~Ir~
Estimated
Source. of Soil Incremental
Cancer Ri sk
Average Kaximum
Z ones 1 and 4 . Surface Soil lE-O 5 3E- 0 5
,
Z ones 1 and 4 ; Sub-surface Soil 6E-0 8 2 E- 07
Z ones 1 and 4 . Sub-surface ( Future Use S cenario ) 2E- 0 6 5E- 0 5
,
:~it¥'ll!ill:~J~w:ii]:'e~!i!g~~;r~!i;~:.~:;w.6h:i¥i:g£~:~! ;;i£I~~;W;::~:f:;'-~::!£B~~I~:l~sii~:\:~:~:::t~i~:g?~t:::!!:;:[~::1::.!;::t:;:'~;;!:::N>.1
Incremental
Source of Vapors Cancer Ri sk
Estimated Average
~ones 1 and 4 . Sub-surface ( Future Use Scenario ) 2 E-O 8
-------
TABLE 8:
NON-CARCINOGENIC RISK CHARACTERIZATION SUMMARY
':.::::i@i~.;j~i;4,ia~;b:iiidijiii£gi::.::!i!'~H6::;.:&h~~~£~ri.iii~i~~:i:.i:!&E;'\.Iii~ii'€igji:!.;:;:~i;.::;:d~g~&jiat:~f,';:;:i:;::,iji:;:!:
Estimated Hazard Index
Source of Groundwater
Average Haximum
On-Property OVerburden Aquifer 5E+0 1 6E+ 02
On-Property Bedrock Aquifer 7E+0 1 4E+ 02
Off-Property (North of S ite ) lE-O 0 2E+0 1
Off-Property ( South of S ite ) 2E+0 0 2E+ 0 1
.
Estimated
Source of Soil Hazard Index
Average Haxim1Dl1
Z ones 1 and 4 ; Surface Soil 3 E- 0 1 lE+ 0 0
Z ones 1 and 4 . Sub-surface S 0 il 9 E- 0 3 4 E- 0 2
'
.
Z ones 1 and 4 ; Sub-surface ( Future Use Scenario ) 3 E-O 1 2E+O 0
;::!!f.::::~!j::1!i::;i:.::I$I"~~a:$._~~~it~:~~j~li.jk~'::i!~:iiiii€~:£i:li:ti:g~":!:i~~i:1'::!Dn:im:;~~':::~f:i:!:;,~~g¥j:'!iii]:::~::.!i1:i1~::::j::.:::::.:;
Hazard Index
Source of Vapors Estimated
Average
Z ones 1 and 4 . Sub-surface ( Future Use S cenario ) 6E - 0 5
-------
.
,
TAD! .'
. Summlrv 01 Surf8C8 WII8r Conl8mlnltlon Wa- Qllllhv Crllerla Ind Huard Indlce. lor Aauallo Bioia al thl UnemllSler SWllch Slia.
EXPOSURE lDNE OONCENTRATIONS (tbt lOCATION OF NUMDER OF DETECTS AWOO HAlARD aUOT1ENT
ANDOONTAMINANTS AVERAGE MAXIMUM MAXMUM HUMBER OF SAMPlES 'chrum:!' AVERAGe MAXIMUM
upsmEAM (SW",SW. 15)
lnorganlcl
Arsenic, T oIaI 1.58 3.2 SW-3 I/J Q 0.03299 0.06667
. . "OI1'~'
VoIL"I. Org...lo Compoundl
I 2. 1chI~1h"'" '-'3 3 SW~ t/4 tt6oo' 0.00010 0.0002G
fJ~~~ ~f1enl 0.49 t.2 SW~ 114 I 1600' 0.00004 0.00010
2.86 6.7 SW-4 114 21900 0.00013 0.0003 I
lnorg~n~.
Arsen . 0111 2.93 0.1 SW.' 2/4 48 0.06094 0.18958
, . "''''''., , ........,..,
VoI'IIIl>!ir~flo Compoundl
V.tl.= ~'*'. 0.34 0.9 IW.7 In 11600' 0.00003 0.00008
1.20 &.9 W.7 In 21900 0.00005 0.00027
~r9~nlC8 2.8 .
en ,Total 1.69 SW~ in 48 0.03521 0.05417
ru: u.w:,~ "I: U.u:M:J'
T -",:;"'IU,
Vol.lIl. Or9...Io Compoundl 1.31 2 SW.9t'SY/.IO 314
O1Iorolonn '240 0.00106 0.00161
=~~nlci
, T 0111 1.34 t.8 SW-!IJSW'IO 3/4 48 0.02780 0.03333
HI: U.U
-------
TABLE 10
SUMMARY OF SCREENING OF
SOURCeCONTRO~A~TERNA~VES
~
Ac:TIOH UMmNG El"FEc:t'IVENess IMPI.EMENrA8IUTY CCST STAtUS
CHAIU.~lsnCS
No AcIIDro None ...... V... Law !no"'1I8I8IIMr No\ C8IttI8I .... ......
se.. II...., Law Equip... "- HIgIt O&M ....
Prot....I1.._-e Law
~-::;( None ~ YoIune High T$OA~ No\ ~ .... ......
8C4 ........, Law ECIUIIa. .. "- HIg/I O&M ....
~U_- Law
"- keep.... ....... YoIune HIgh InoA~ HIgh c..., .... ........
......... IUIe b8Iow ......, ...... ECIUIIa... "- HIg/I O&M ....
SC4 wMr_ ".,~ IoIedUn
IIIr 101"" """", YoI- High TSO A¥8i8IIiItr ....... C8IIit8I Law .........
......... ,.....,. II8IWI8Ir IoIedUn ECIUIIa... "-- HIgh O&M Law
sc.. ""'ad1.--a IoIedUn
IINIIIu Soh- H8iiiii88 V-- ......... T$O A¥III8IIIIIy ....... c-.. ....... .........
'~d.~ ....--. ....., 01--..,. IIeIIUIIy .... EQUIp." "- HIgh O&M .......
8Co4 ".,...... ........
o...aa. EuawatIon ..... V... Law ITSO A¥8i8IIiItr ....... c..., HIgh II8Iu.od
1na-.6..1 ~ II8IIMIIIty H1;II Equip... "- HIgh O&M ......
sc.e '"""---- Mlfth
n..r.... =--- ....... V... ....... irsoA~ ........ c..., HIgh ........,
81IfppIn; ~ ........, ....... Equip... "- HIgh O&M ........
se.7 . HIgh
Ofr.aa. Elcevatlon H8nd1- Volune ....... no Av....., ........ C8/IIt8I ...... .......
.......... I8qWad ReI8bIIy HIgh EqUp." "-- Hoh O&M Law
sc.. ,",t"II~_-. HJcIh
0fr.88. ~ ........."..... ....... 1'SO A¥8I8IIIIy ....... c....., ...... .........
&.8018 ....... II...., Law equlp,l"- Law O&M Law
ac.e .......
'.
.
SUMMARY OF SCREENING OF
MIGRATION MANAGEMENT ALTERNATIVES
UUITIHG EFFEC:m/ENEss 8oIPI.EMEHTAIIU1Y COST 8fA'I'US
ACnON
CHARACTERlS'nCS
No AcIM N.- HMcIe, ¥cIIuIII8 Law TSO AYIIIIIII, NA CII/I8I Law ......
....., ........, .... EqIIIp,I~ HIgh O&M ....
Pn:I18~~.... Law CanIIIiMd ....
~ F- 8.... ........ VCIIuIft. HIgh TSD..........., NA CepII8I ........
AquIlar ........, .... EqIIIp,I ~ ........ OIM '- IC4
I0IIoI4
~ .1"£1 Law EInINItd
""""'" SounIe- ...... YCIIuIfte HIgh TSD ""....., NA C8pIIIII .......
....... ~
IIudge a.- 8" ""'-- Law EqIIIp,I "--. HIgh ......
MM03
I'ftIt8 eI' --II .... ........
......, VCIIuIfte High rrso Aw8IIU8Ir filA c....., ......
IIIr Oft-Gaa
...... TreallMftl ~ HIgII Equip, I ~ ...... OIM '-
IAU 1'raIa._I&I' Medium ReI8InecI
H""', "CIIuIft. HIgh TSD A¥8I8bIIIy NA CepII8I M8CIuIft
WIOald8I011 ,-
.....5 .....- ........, HIgh EQIIIp.I "'-. Medium OIM HIgh
Ptat.c8v_.. HIa!I
~. VoIunt. HigII TSO A,,8iI8IIIIIy NA CepII8I ...... EllMlaI8d
CItch8rge to c:.paclly EquIp.I'--' HIgh O&M ......
~1W FuaIr. Upgracl. ReIaIIIIIr HI9h
MM.. ~.. Law
-------
,
,
TABLB 11
SUMMARY-SOURCR CONTROL AL TERNA TIVBS
LlNRMASTBR SWITCH CORPORATION
SC-I $C-2 $C-3 SC-4 SC-5 SC~ $C-'
CRJTI!RIA NO ACTION C'ONTAINMBNT VACUUM AIR SPAROINO DIODBORADA110N ON-Sm 11IERMAL
BXTRAC110N INCINERATION S11UPPING
A. OVURAIJ. The lence would control The cap would n!duce ConIlnued mlaratlon 01 Conllriued mlanllon Conllnued mlanllon 01 Contll11inllion Conlllllinilion
PROTECTION OP clermll contla with .011 the ri.k 01 mlaration conllmlnl/ll' Into the of conllmlnllllllnlO conllmlnlnt. 1n10 lhe n!mlinlna batuth n!mlinina batuth
HUMAN HBALm ri.b. OII-.lte mlanllon of Cllllllmlnlllll Into cleep bedroc:lt 8qulfer !he deep bedrock deep bedrock Iquller the IlCilil)' Ind pint the Ilcilil)' Ind
AND would COIIIlnue I' the bedrodc lquller. would be ellminlted. lquller would be would be elbnlnlted. .hed would re.ult In pllnl .hed would
nNVIRONMnNT conllm"'lnll mlanle OII-I/Ie mlaration ellmlnlled. the co.nlnued re.ullI In the
from the IUlIO lhe would continue II mianllon of conllnued mlaratlon
bedroc:lt Iqulfer. conllmlnllll. move conllmlnlnl. 10 the of CllllllmlnllllliO
from the lill to the deep bedrock the deep bedrock
bedroc:lt Iquller. lquifer. Iquifer.
D. COMPIJANCB Chemlcal-lpIIClllc OIemlcal-.peelllc OIemlcal..peelllc OtemlClI-lpIIclfie Chemlcal..peclllc ARAR. Chemlca(-.peeilic Chemlral..pecilie
WlTII ARARS ARAR. lor aroundwller ARAK. lor ARAR. lor aroundwller ARAR. for lor aroundwlter would be ARAK. lor ARAR. lor
would be met within aroundwller would be would be met within 3S aroundwlter would be md within 35 )'un. aroundwlter would aroundwlter would
500 ynn. There Ire no md within 5110 yean. ynn. 1111. tec:hnoloa)' md wIthin 35 yun. Thl. technololY would be met within 35 be mel within 35
lalon-tpeclllc ARAR. Thl. lltemldve would would comply with IU 1111. technolOl)' would comply with IU the )'eln. Action- yeln. AClion-
lor thl. lltemlllvl. not meet the lalon- the Ictlon- IIId Ioutlon- compl)' with IU lhe lalon- Ind locatlon- .peclllc ARAR. .poelfic ARAR.
.peelllc ARAR. lor .pedJ1c ARAR.. Ictlon- IIId locatlon- .peclllo ARAKI. pertllnln, 10 I.nd pertllnlna 10 Iind
conllinment ./nee the .peclllc ARAR.. di,poIII rellrialon. di'po'il re.triaion.
Wllte I8Ider the wID be met throulh wilt be met throulh
buUdlna would noc be treltmenllo DDA T lreltmenllo nDAT
. capped. level. or Ihrouah I level. or Ihrouah I
In:8l1bilily vlrilllCe. lreillb/III)' Vlrilnce.
I Thl. technoloa)' ril Thl. technololY
meet III other Ictlon- will meet IU cther
Ind locallon..peclllc lalon- and.
ARAR.. 10001Ion'.redne
ARAR..
Page I of 1
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TABLB II
(CONTlNUBD)
SUMMARY.SOURCB CONTROL ALTERNATIVES
LlNBMASTER SWITCH CORPORATION
se-. SC2 sc., se... sc-, sc-, sc-,
CRR'BIUA NO AcnON COHI'AINMI!N1' (rACUUM AIR SPARGlNa BIODEORADA110N ON.SITU 11I1!RMAL
I!XTRAcnoN INCNEItA110N STRIPPING
Co LONO-'mRM
IIfFI!CTM!NI!Ss
AND
I'I!ItMANI!NCB
I) MaFIIIIde of ala.. wouI.iwMIn II Corum"'... .......... "''''aI daIt -.LI be "'...aldak-.tclbe ."''''.1 dak m.)' be rooIuood SoD nac acay.1ed IIIId. III. SoD nac acanled und.
1t"'''aI RIIk. ..-.. tam III. lID "'0 lite mIueecI pam....., ""'ueod pam......lI)' .....,.........11)' lluuuah r.eIGrJ IIIcI p8InI Ihed would lite r.CIoIy IIId polnl ""'"
amun'''- waul. daauah -1m'" TNI"" daauah -1m1lL IreItmenL TIClIed I0Il 11111 CUlIlnUO 10 pole . riIk 10 1110 woulll CUldnue 10 pelle .
-llnue but . ... fila. 8011 .... pounllwl" ........ T....1ed ...u w...'" pelle pound.I" would polO 110 pound.I" due 10 III. rlok I. !he a-nIIwl"
pole no dak pravill" no no dak pro"'deII 1U1IIc:I1II1 rlok p_ldeII no 10110 CUlllnued wnlcaI mllJltlon du. 10 III. CUldnued
10110 .""""""""1. -unlcallan CUI be "'amedJlt. prodllCtl JWuJ\. 01 ClllIIIn/nonI8. wnlClt mllJltlon .,
proI!uc18 -IL .chI""ed bet- -lImInonli.
Injeed... .... ulnctlan
weIIo.
2) Aclequ.CJ 01 Tho ,- oemIIIned Tho IIIIIIII-11,. cap V.cuum ulnctlan w...J' AIr .......... w..... BlocIean"'lIan woutll fndnlll8l1an waulll mlllallO 11Iamd 1111....... w...'"
CantroI8 willi n-I '"cUlI)' wautll red- III. rid! 01 mlll,lI. III. -dnueo! mid.... III. _dnued mllI,"" III. condnueo! releo.. !he mlallilon 0' mld,lI. III. mllIIlI... ",
-dl, wID JI18YIn\ -1In.... l1li11111... ", mI...llan .r -Inlllll Id.... of oonllmlnllllllO ", -1Im/n8n1l1O lite 'oep CUlIIIn/nonI8 In I-I oIhw CUlIlm/n8nI8 In IlUI
unl"""'" ..,. CUlI8mInen.. 10 .... ... lnIo III. doep hedrodt !he deep lleclrac:It oqull.. bcdrac:lt oqull.. ShOll 8nd Ih8n un.. III. llulJolina IIId aIh. Ih8n un" lite
......... ""01110 8qU1f.. lona-tenn manltorlna waul. JIIlni Ih", Lm..\enn buUdln. .nd JIIlnt "'eo!
Inopecdon -III be bo required 10 .11_1Ite IIOIIlGrina -.tll bo I.... lam manllaM,
""Iulnol ... ....... ell'ccdy-...r -Inlalt 8nd ""IUIreclIO lIotoanIn. .... ....Id bo ""IUIreclICl
. "'.rIt)' 01 the cap. wrIf)' III. 11dr: 01 """edn"'. ImJlle:& ", III. -omInlllon clelermlne III. Impoe:& at
......,- InotIlulloaal "'-procIuc:&l. nmllnlna WId. III. !he -Inld""
! CUI""," would be IINctIlftll. ranlln"" und. III.
requlrecl to pmv.. ftJlIIr8 IlNc:&wa.
deYdaprn-.
Page 2 of 7
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TABLE J J
(CON11NUBD)
SUMMARY-SOURCB CONTROL ALTERNATIVES
LlNEMASTER SWITCH CORPORATION
SCI SC2 SC, SC4 sc., sc-, Ie.?
CtUI1IItIA NO AcnON CONrAINMIINI' VACUUM AIR SPAROINO SIODI!ORADAnON ON-1m 11IERMAL
mmtAcnON lNaNl!RA110N S11UPPlNO
1tcIJa1llllt, fit leU. .alaI, III the CIp .culd be IIIddpetell V- Ulncdan -N Ak 1JIIrp., _141 n8IIh BlodepellllOll wauld _II fnelnenllon _141 raullin . 11Icnnd .lIIpplna _141
ec.-Je '11101 end InnIIudand 10 nrallD Inll~ ,. !O -ull In I perman.. In . penn_I ...ludon. In . pennal1Cl1' 101I11on. pennllllll' ...Iullan 'or thl be I penna.-,
em""'. Faa would "'18. Subl....." th. ""'-Ian. .u. 1nIa- II All. -""lilt II Camlnueel manllorina -141 llcaVlled ...u.. SoIII lqlC 'or the .011 vOCe In eoIIt eaGefl' ,.
Sur....... .chIlYl drInkIn. wa.. .chIlYl drfnkIn. ..ater achllY' drinkIn. water underneath the ""DeII...a tho eoU und-ea'" the
o.roJccl, T_led, ..nell"'a In around....... nanell"'a In lJ'IWId..a... III/Iellnla In around...... Cappm.. 3'" _.lnlna). . ""Ddln.a CapptDl. ""
. Ree,cIed. _alnlna).
3)Depeoflt No ""'011 In loaldl" SD.ht ~ In ComplelO .....ctlanln eo....ldo aeduc:danln Complllle reduction In MaJar reduallon In volume. MaJar reduallonln
IIapecaed Roducdon mobIIIl". vol- -"WI,. No NIfuadat In 1oIldl" mobllll, ..41 1OIIcII" mobWI, ..41 toltall" mollWI, ..41 volume. SoU nmalnlna. un". the vol- loil _alnlna
III Toddl" 1oI1eI., ... "'- volume. volume. ""Dolin. ...1141 not lie l8l11a tho hulldln. would
MohIlIl"... a!fooled. DOt be l!feclOd.
Volume.
Page 3 of7
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. ~ ~
TABLE II
(CONTINUED)
SUMMARY.SOURCe CONTROL ALTERNATIVES
LlNEMASTBR SWITCH CORPORATION
Ie-I IC.2 IC.' IC... IC-' IC-II sc.,
CRm!JUA NO ACI10N CIONI'AINMENI' VACUUM AIR IPAROINO BIODI!ORADA110N ON-Irm 11lliRMAL
I!XTRACJ1ON INONERAnON STRIPPINO
4) Depe 10 WIIIch Nal IJIIIIfcabl8 Hal .pplJClbIe OIqIICIcI, 1msY..1bI. OIqIldeI, 1msY..lble OIqIldcI, "",,,..Ible Compldcl, "",,,..Ible Compldcl, "",,,enlble
TlUlmontli
ImwawIbll
S) T"..... No t'8IIucdea of No l'86Jcdea 01 GIllin" No ..wu.s. No .._" ..........1 (or d...."'lIen to CaumIn- would ftlllain Conllmln- wauld ftIIIeLt
o-tlt, of Cllfafnll contlmlnutte Wi,1 chlodcle to -. I8IclemOlIll buIIdlnp IIId undemOlIll buIIdlnp .nd
....... dill wm ~ .ouIdcondnue to mlplle ...dd cml/nue to mlplle Into
a..1n Imo lIIe deep bocIroct !he deep becIrock aquifer.
aqullcr.
6) Depe to WhIdI No -am.. No -1m.. HIah ftIcIuctlon In hlDtlf.. III.,. ftIcIuctlon In 1118/1 ftIcIucden In hUlnft of III", recluctlen In hUlrd. (.. IIIp ftIcIuctlon In hllard. (01'
Tl8ltment a...- ~ of pallnd.... hUlnII. Sau- o( CUI1'aIt COIIllmlnl" mlA. IOiIlhat .. IU.....Iee!. IOD IIIlt II clelYllee!.
die Inh... u.zu.. conllmlnlllon .18ftlRcontI, .....,d.I" 1- o( .....,nd....... Mlplllon hlurd .ould MIIJ.llon hnlnt would
.It die II... reclucecl C81lImlnlllon C81lImlnlllon IlanlflCllltI, ran.1n .1111 IOU aM.llle ran.1n .1111 .0D under lIIe
lIanJflcenll, ftIcIucecI ftIcIucecl buDdln.. buDdln..
a. lIIORT-TERM
I!FFI!CJ1YENESS
I) ShIilt.T- RI8b No Id.dm" Dull ....... ....... Uall ddt to !he ,..,Uo UaIo ddt to !he pubUo Uule ddt to !he pubUo wauld ele......llon would ,000enle e'CI".Idon would ,enenle
10 Communll, /none.. .... OIIIIItIIIctIon -Id poll wauld nruh (I'11III the wauld -II rn.m !he reaull (""" !he InIllUlllon of lianJliClnl ..lI'bOI'n dUll lianlflClnl .lI'bOI'n dUll
Durin. allllllcllal "'-1 dab wadd .... Increa...d rIdt "fa nllU..\Ion of ulr8allGa -IIU.II"" o( weUI. wella. 111... would be conccnt;r.dCIIII. Dual would --III"".. Dual .ouId be
Action. be poaocI. ....I.\Ion. IUak would be ..u... There amdd be . III.,., poIenll.1 (or ml'lIlIon of be IUppreued '" WI" or IUppl'ellOcl b, Wlter or
minim.. -- Dale poIendll of "pol'" Ie Injected mlOftIOI'8enlaJIII Into chanlc:aI IppUCldon. chanlc:aI 'ppUClllon.
conllmlnltecl eoU wauld amplo,.. (",,"!he !he deep Wrack aqullar. """"'11 .Ir ImplCII (""" PoIcmi.1 .It LnplCII ("""
' be OIco..llOcI. IICIpi o( ".polllpllJed Indn....... would be 1henn.1 IItIpper would be
rn.m !he pallnd. -tmIIed '" eml..lona contmllcd by eml..iona
C811n11 dOYiCel. C811n11 dOYi_.
2) PatentI.. Imp.cu No Increa.. OYer "'"-I plIII8:II.. ........ ~... ....... ~YI ....... protectIye equlpn.. PenoneI pmlectJye Penond protectI..e equlpnll\t
en Wildt.. !bin. ..... dab would equipment -Id -.vi equlpmenl would-.al equlpnent would COIIItaI would conllOl damll 8Id equipment would_nil would eontrol damllind
Rtllledld Action. b8 pol". dwm.llnd Inh.latlon denn.I IIIdlnh.llllon denn.1 Indlnhll.llon Inhllilion ..poeuN pllII.l,.. dennllllldlnhll.llon 1nh.1.llon ..r-uN ",,"'w.,..
..,....... pllII..,.. l.poI'" pllII..,.. .lpnlUN flllII.I", .."""UN pllllw.,..
Page 4 of 7
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(
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,
<
TABLB 11
(CONTINUED)
SUMMARY.SOURCE CONTROL ALTERNATIVES
LlNEMASTER SWITCH CORPORATION
se-I SC2 SCJ se... se-' se.' sc.,
atm!IUA NO ACltON CONI'AINMI!Nr VACUUM AIR SPAROINO BIODEORADA110N ON.sm 11 IP.R MAL
I!J01tAC11ON INClNI!RA110N STRII'I'INU
J) en.............. Cenlamlnl'" _I' Net . rellabla medtool to Comemlnllll mI...dan, eo...mJn8llt 1811'111011. ConIImInIlll ml.nllon. IIadI AlII""ah rnudt 0' th. Alth"'ah much 0' th.
Impeeto. a811Imao ID be JeI-od canll'al air-alia mJandon IIadIhorizodeD,endlnlD tJoIh hem-IU, en' InID horizonllU, an' Inll tho deep a81tamlnoled IOU w...1d conllmlnlled IOU w...ld
ID tho -Irao...-,I WI vi a811Im1nanu. vOCe tho 'ocp bodroct equlf-. tho 'eep bodJaCk aquifer. bod...... equlf.... would be be nmocIllled. tho I0Il be nmocIllled. th. IOU
wnlcd ,-'wa. _Id a8111nue ID b8 .add be mlll,"Io4. _Id be mlll,"Ied. 18111,"104. ConIImlnlled IOU WIder tho bullcIIn. would WlcIcr th. buliclin. .ould
mI....lI- JeI...od ID the ConIImlnlled IOU ConIImlnatod IIU -eel nmovecl dud... ...1 amlln... ID JelUII conlin... to JelUI.
-lraunonl WI ¥eItIe8I nmovocl ""dna .If! &Irina ..u "'IIUIII- ""IIU.IIOIII ....Id be amllm,"",,11 ID tho amtamlnenll ID tho
pound.... mlandon ""IIUld- .ould b8 waul. be dlapc18111 ", on. dilpoeecI fII on...... pound.... SlIckp"od pound.a.. SlodpDod
'. thouah tho nil .ould b8 dilpoeod fII oIl..l... II... Conl8m1noled ConIImIn.1c
-------
;. ,
. .
. ,)
TABLB 11
(CONTINUED)
SUMMARY-SOURCE CONlROL ALTERNATlVBS
LlNBMASTBR SWITCH CORPORATION
sc.. SC-2 SC.!' SC-4 SC., SC-6 se-?
CRII'BRIA NO AcnON CONTAINMIINT VACUUM AIR SPAROINO BIODeORADATION ON.SITU 11IERMAL
BXTRAcnON rNClNI!RA110N STRlI'I'INO
P. IMPIJ!MI!NI'ABIUI'Y
I) TedWcall'euIIIIIItJ ,.... ""UI- .. 1 Cap InItIUldaft wauW VIIIIIIIII UInCdCII .. 1 Althauah IIDI 1 cmunanI, 11Ie lechnol.., 18 lIot well T_lmall would noquIN T_lmall would """,be
almpll \lilt trlih IIIIdU, ftIqU'" of .II1II1" commcnl, IIIeII ..811 teeIuIol.., In dill developed to _I moIIllludon of mo"lIIudon of 1pOCI.u-r
IVlUlb1. malerlall. -atructltat Ictlvld.. lechnol..,. ""terllllind I".. of "ppUCldon. the chJorInale4 h,chcuttono. opocIllIzed eopdpmrm. equlpmmL Technolo8J"
equ'pmCIIl 118lC1dU, materll" and equlpmatl Conolden"lo ,,"",dI'ICIII Tedlnolo8J .. ""-nln. mono IYlnlbl..
IYIUI"I.. InIttUadon of to -lNetthl lit Inti pIIot.acall teetIn. danonatnle4. Slick Sohl...I,"1 monltodn.
the weUa Ind eoUectlon 'P"..In. 1'- I... w...ld t.o requbee!. monltorln. would be w...ld be -II.,.
1,1Ian In the fl""" wUJ _dU, ovIUI"I.. 1n1ll1l.tI... of the weUa -...". RcrollJn. Ind Rcrillin. Ind andln.
requlnl ooonIlnollan Inltlllition of the weUa II1II dlllllbution 1'- andlna w...ld hive to be would h.YO \0 be
Inti oaIIectlon I,,!em In Inti cmlnll or tho Injocted COOrdlnlle4 with COOnlinlle4 wi'"
the fl""" ..W roqube malall" would roqufre UClvatiOlL UClY.tlOIL
coonIInldOlL coonIIn.tlon and lnaalllYl
monltorln..
2) Admlnlltndy. No pemt1tI nquIred. No pamItI nquIred. No pemt1tI NqUIrecI. No pamll8 roqulred. No pamll8 ftIIIIIImI. No pamll8 required. No pamll8 roqulred.
PaIlllWI,
!) AVlUlloWl, of StnI- StnI- end mllaf8la ~ end mll8ltla ServI- end ml18ll11 ServfCM Ind mllalill injection end utnctlon ScnIeot end mllalill Spedlllzed 18IYI- Inti
and ""111111 wauld be IYlUable WotIId be 1.IUlbll _Id be IVIOlblllocall,. ..ClUld be IVIOlbl, malalill would be ma, be nubblo locaII, malal'" Ire not IYIUlblo
1ocaII,. 1ocaU,. IoeIU,. IYIUlblo IIICIU,. depa.clin. on tho demand locaU,. but th.... I'"
. SpeclllIzed lapertbe for I UmIIe4 Nppl, of leYenl contrlClon In tho
wauld be roqubecI \0 opocIllIzed equlpmlllL eolian part of "'0
develop"'o COlInII}'.
mI""","nlama. PIlot
teetIn. would be """,bee!
to develop IIqllld now
nl...
Page 6 of7
TABU II. RHCORD OP DHClSION
-------
o
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TABLBI1
(CONTINUED)
SUMMARY -SOURCE CONTROL AL TERNATlVBS
LlNEMAS'lER SWITCH CORPORATION
SCI SC2 1e3 SC-4 ses SC-6 SC.1
CIUt1!IUA NO AcnON CONrAlNMllNr VACUUM AIR SPAROINO BIODEORADAnON ON-sm nR!RMAL
I!XTRAcnON INClNERAnON STRIPPINO
O. COST
I) ape"l eo. 134,soo 1429,000 S446,ooo 869S,OOO $394,000 11'.588,000 81,338,000
2) Talal oaM
CollI (N. I're8ent 11,409,000 81,409,000 8114,000 '834,000 '1,122,000 '322,000 $441.000
V....) ;
3) Teul NIl ~ '10443.5110 .. ,1".000 '1,230,000 81,529,000 '1,5 16,000 '13.910,000 81,7",000
Vdue
IL IrAT! DIuIIed IIIIIIImInf8 aM DuIW -II.... o..JIooI-II .n. DtuIIecI -II Iftd DuOed -lIlnd o..JIed _II In. DdoUooI_II .nd
AOCI!PI'ANCB ~ .VlU..... ...,........ .nO.... In NIpOn" .nn.b/8 In -pan- .VID,".1n -pan- .".i..... In -pan1e8 .nU.bleln -pan... ",.O.bl. In
A""".. C cl ROD. A"""dI. C cl ROD. AfPllldia C cl ROD. Appaulla C cl ROD. AfPllldi. C cl ROD. Appelldia C ." ROD. AfPllldia C cl ROD.
lCOMMUNrrY DuIW IIIIIIImInf8 Ind Dulled _II en. o..nool-II 8114 DlaDed _II end DuUed -lIlnd o..ned _II Ind o..JIooI -II Iftd
Acx:J!PI'ANCB ~ .".D..... 118pan111 .nn.... In 118p111\1f8 enD.bI. Ia 118p111\1f8 .VlD.bI. In I18pan... .".O.ble III -pan1e8 .".U.blelll I18pan... .VlO.bI. In
AFPflldi. C cl ROD. Appell" C ." ROD. AfPllldQ C elROD, AfPlllclia C el ROD. Appelldia C el ROD. Appelldia C el ROD. AfPllldia C el ROD.
f ,
"
Page 1 of 7
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T. 12
MIGRA110N MANAGi....cln' SUMMARY TABLE
LlNBMAS'lER SWITCH CORPORATION
CRrrERIA MM-' MM-4 MM-5
NO ACTION AIR STRIPPING UV,uXIDATlON
A. OVERALL PROfEcnON OP HUMAN Omundwarer mfaradon aft the .Ite would Control of poundwater mlpltlon air the .Ite Control of lfOundwater ml.ratlon olr
HBALm ANO mE ENVIRONMENT condnue aftec:dn. abutter' well.. Public would be achieved and trealed water would be the .lte would be achieved and treated
health eJlpolUl'e to contamlnarect JIOundwater dI.charged to the on-.lte pond. Management water would be discharged to the on-site
would be a chronic ri.k. or mlgntlon will reduce the potential ror orr. pond. Management oC migration will
.Ite contamination. reduce the potential Cor orC-slte
contamination. VOC. would be
destroyed by the UV /Oddation 'ystem.
,
B. COMPLIANCE wmr ARAKI SOW A and CT drlnkln. water quality and SDWA and CT drlnkln. water quality and SOW A and CT drinking waler quality
Ifoundwater quality .tandards would be met lroundwller quality .tandards will be met and groundwater qualily .tandanls will
within 500 ycan. within 35 years. be met within 35 years.
C. LONG.TBRM EPPBC11VENESS AND a.ellne public health and environmental risk Control of the Oow of contaminants would Control of the Oow of contaminants
PERMANENCB would remain u at presenL Only natural mbtlmlze the risk. Groundwater would be would minimize the risk. Groundwater
attenuation would occur. restored to clrlnkln. water .tandards and would would be restored to drinking Wlter
I) Ma.nltude of Re.ldual Risk not pose a residual nsk. Itandanls and would not pose . residual
nsk.
.
,
loC6
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T 12
(Ct JED)
MIORATION MANAOI:.MgNT SUMMARY TABLB
LlNBMASTER SWITCH CORPORATION
CRlI'ERIA MM-I MM-4 MM-5
NO ACTION AIR STRIPPINO UV/oXIDATION
2) Adequacy of Controls. No Acdon will have no effect on Oroundwater pumping hu created an lrea Oroundwater pumping had created an
conlrolllng!he groundwater IrInsport of of control especially In !he norlh and cut area of control especially In the nor!h and
conllmlnanll off !he lite. No Action would portion of the She. Addldonal weUs could cast portion of !he she. Additional wells
rely on Instltulional controll to restrict weU be added If additional conlrolll Rqulred. could be added If additional control II
. installation and/or provide Individual The syslem hu controlled !he mlaratlon of Rqulred. The syslem hu controlled
treatment units. contaminants off !he Site. migration of contaminants off !he site.
Rellablllly of ConIroIJ. No Action would result In !he continued The collection and treatment systems would The collection and treatment Iystems
mllrallon of conlamlnanll off !he lite. have limited service lives. Pumps would would have limIted service lives. Lamp
required replacement every nve years, while replacement would be frequenl. Pumps
major components would be expected to would required repllCemcnt every five
lut 10 to U years. None of !he equipment years, while major components would be
would be difficult to replace. expected to lut 10 to 15 years. None of
!he equipment would be difficult to
replace.
D. REDUcnON OP TOXICITY, MOBR.rrv
OR VOLUMB
I) T~ealment or Recycling Proccue. and !he None Removal and destruction of VOCs In Removal and destruction of VOCs In
Material. Treated. groundwater by air 8bippfngllld carbon groundwater. By UV /Oxidation and
. adsorpdon. cubon IDters.
2) Amount of HuudoUi SUbsl1RCel None Reduce concentration of VOC. below Reduce concentration of VOCs below
Dealroyed, Treated, or Recycled. drinking water ltanduds drinking water standards.
20f6
TARt! 12. RIlCORD OP DECISION
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'I ". . 12
(CONI'INUED)
MIGRATION MANAGEMENT SUMMARY TABLE
UNEMASTER SWITCH CORPORATION
CRlJ'ERIA MM-l MM-4 MM-'
NO AcnON AIR STRIPPINOR UV,{)XlDATlON
3) Delree or Expected Reducdon In Toxicity, No reduction In toxicity, moblllt)', or "Iah level of reduclion In toxicity, mobiUty Hlah level of recfuclion In toxicity,
Mobility, or Volume Throup Treatment. volume throuah treatment. and volume of VOCI In aroundwlter. mobility Ind volume of VOCs In
vael would be destroyed. aroundwater; VOCs would be destroyed.
4) Delree to Which Treatment Is Imvenlble, Not applicable, No trealntent. Tho treatment proceSI II completely The lrellntent process Is completely
irreversible. It does not, however, preclude Irreversible. It does not, however.
the inclusion of olber technoloales. preclude the inclusion of other
technoloales,
5) Type and Qulndty of Residuals that Will Not appllclble. No lrellntenL VOCs collected In the euban flIterI would VOCs not oxidized would be collected by
Remain. require destruclion by orf-slle reaenerltlon. the cubon OIterl, which then would
require off-site regeneration,
6) Decree to Which Treatment Reclucea the Not appHeable. No trealntent. Slplficlndy reducel the potendaJ for Slgnificandy reducel Ibe potendal for
Inherent Hulrds It the Site. eantlet with contlmlnlted aroundwlter. contlct wllb contaminlrcd aroundwlter.
E. SHORT-TERM EFFEcnVENBSS
,
I) Sf1ort-Tenn Rlsts to the Community DurIn. There would be a contlnuln. Ihreat to off- Construction of the emission controls would Addidonal CORStrucdon would Involve
Remedial Acdon. lite water lupply wel". present no risks to the community. equipment Installadon onJy which would
present no risk to Ibe community.
30f6
-------
T . 12
(el JED)
MIGRATION MANAGEMENT SUMMARY TABLE
LlNEMASTER SWlJ'CH CORPORATION
CRITERIA MM.. MM-4 MM.~
NOACI10N AIR STRIPPING UV,uXIDATION
2) Protection of Worken DurIng RemedJaI Not applicable. No add1t1onal Increl8e over ConslrUctlon of emission controls would Worken would be trained In health and
Action. present risb would be posed. pose minimal risk to worken. Worker. ..rely procedure. and would use proper
would be trained In health and ..rery penonal prolectlve equipment against
procedures and would use proper protective deonal and inhalation exposure pathways.
equlpmenL
3) Environmental Impacts. ContlUlllnanll would continue to mIgrate off The groundwater environment would The Ifoundwater environment would
tho .Ito In tho bcdruck aquJrer. benefit. No negative environmental ImplCts benefit. No negative envlronmenlal
would be anticipated. Impacts would be anliclpated.
4) Time Until Protection I. Achieved. Minimum nalUral remediation tlmo for tho Approximately 6 months would be required Approximately 8.12 months would be
bedrock aquifer would be approximately 10 conslrUct the emission control system. required to evaluate equipment, design
500 yean. At the current rate of VOC removal, the system and complete conslrUcdon. AI
remediation of the deep bedrock aquifer the current rate of VOC removal,
would be achieved In approximately 3~ remed1atlon of the deep bedrock aquifer
yean. would be achieved In approxlmalely 35
P. IMPLEMENT ABIUI'Y yean.
t) Technical Peaslbillty. No equIpment would be required. The existing groundwater collection syslem The existlnllroundwater collecllon
appear. 10 be functioning weiland can be .ystem appears to be functioning well and
r easily upgraded If nece18ary. The treatment WI be cully upgraded if necessary.
technology Is well proven and hu been UV,uxldation Is . relatively new
effective In removing contaminants. technology. Pilot testing may be
necessary 10 develop design parameten.
4016
-------
o
,
~
. -12
(COJ ....ruED)
MIORATION MANAOEMENT SUMMARYTABLB
LlNBMASTER SWITCH CORPORATION
CRrrERIA MM-l NO AcnON MM-4 MM-5
AIR STRIPPINO UV~XlDATlON
2) Admlnlstrllive PeulbUhy. No pennlll would be required. institutional No pennh. would be required. Agreementl Althouah new equipment would be
controls would have to be eoordlnated with may have to be neaodated with abuuen to Installed, no pennlll would be required.
the Town of Woodstock and the Stale of allow periodic monitorlna to uses. the Aareements may have to be neaollaled
ConnecticUL effecdveness of the extraction well nelwork. with abullen 10 permit periodic
monltorina 10 UIeS. the effectiveness of
the extraction well nelwork.
"
3) Availability of Services and Malerials. Oroundwater .amplln. would continue to be The exlsdn. system Is functlonlnllo meet Services and material. are reedlty
performed. all dlschar.e requirements. No orr-she .vall.ble.
IUpport currently Is required.
O. COST
1) Total Capital Co.t $34,500 $70,000' S191,900
. SI.949,OOO S2,738,500
2) Total OAM Co.t (Net Present Value) SI,364,OOO
3) Total Net Present Value 51,398,500 52.738,500 52,930,400
1
Repre.ent. ani, the co.t 01 In.tall1nlJ air emillion contra". The e,UII/lhd c/lpUd C08t for tn8tallaUon /lnd con8trucUon
of the IJroundwater contatnment .y.tem and air .trlpper va. '545,510.
50U
-------
T -' .J2
(~- -. JED)
MIORA110N MANAOEMBNT SUMMARY TABLE
LlNBMASTER SWlrCH CORPORATION
CRlI'BRIA MM.J NO AcnON MM-4 MM.'
AIR STRIPPINO UV,uXIDATION
H. STATB ACCBPrANCB ne.aUed commenl8 and IeIpOnIeI available Detailed commenll and response. avallible Detailed commenll and response. available
In AppendIx C of ROD. In AppendIx C of ROD. In AppendIx C of ROD.
f. COMMUNITY ACCBPfANCB Detailed commenl8 and NIpOIIIeI ava/llble Detilled commenll and NIIpOIIIe. availible Detilled comments and Nsponse. IVllllble
In Appendix C of ROD. In Appendix C of ROD. . In AppendIx C of ROD.
6016
-------
TAba..~ 13
CHEMICAL-SPECIFIC ARARs and mcs
FOR 11m SELECTED REMEDY
LINE MASTER SWITCH CORPORATION
WOODSTOCK, CONNEcncur
RBQUJRBMBJtn' STArns RBQIDRBMBNT SYNOPSIS CONSIDERA110N IN TUB ROD
At,r",ORITY
GROUNDWATER
Federal SDW A.Mulmum RelevlRl 8I1d Approprille . MCL8 hIve been promulalled for a number of Th, rilkl 10 human heallb clue 10
Requlremen.. Cantamllllllt Levell (MCLI) (40 CFR -on oraanlc 8/ld InolJanlc conlamlnanll. Thele conlUmption of aroundWller were I..elled
141.1 1-1~1.16) level. rquille Ibe ooncenll8l1on of CCIIIl8mbtanu In Ind concentratlonl of concem Ire eompared
drlnklnl wlter luppllel. In thll cale, MC1.8 are to the MCLa. The lelected remedy mult
-"dem! ",levant 8/ld appropriate for aroundwller attain MCLI.
bee.ule 8/1 aquifer al the llle II uled for drinkbta
.Iler aad II I potential lOUrco of drinldn, waler.
RCRA . Ground.llter Ptdec:tIIIII St8IIdarci RelevlRl 8/ld Appropriate 11Ie RCRA ,roundwaler pmtectJon nandant II RCRA-MCL8 may be Uled or ACl.8 may be
(40 CPR 264.94) ell8b1llhee1 from aroundwaler mllllllOrina of RCRA developed at Ibe llle 10 Identify levele of
pennltled lreatment, lIonao or dilpo.al racllll.le.. conlamlnatlon lbove which humin hcalth or
11Ie ltaadlnt II lei It either In elllitina or propoaed the environment II It rhk and provide In
RCRA-MCL. bac:karound ooncenll8l1on, or an IndlcalOr when eonec:tive action I. neealal}'.
ahem ate conCCf\lI8l1on protective of human health
and the environment
Stato R,oquhanentl Comcc:tlcul StlRdanta for Qualily of PIIblic RelevlRt 8I1d Appropriate Connecticut hal adopted the SDW A MCtA to Promulalled Slale llIndantl Ira uled II
Drinklna Water (Section 19-13.8102 of CT reaullto _1I8t111111 01 oonlamllllnlllll public cle8ll-up levell when more l!rinaent than
. Reaulallml of Stlte Aaendel) drlnklnl waler luppliel. Connecticut "andlntl Ire Peden! requlremenll.
more Itrlnaent thin SDWA MCL for lome
ccmpClundl.
Comectlcut WIler Qullity Standantl Applicable CooneCtlcut hu Idopted the SDW A MCtA to StltO Itandlntl for TCB Ind oIher
(SectIon 221"'26) Subpart IV . Ground.ater reaulato contamlnanll In certain around.lter. con.tltum" Ire elcceded In the aroundwlter
allbe .Ite. Promula.ted Slale llandant. Ire
uled II clean.up levell when more llrinaent
than Pedenl requlrementl.
TARLS 13, Rf.CORD OF DnClSION
-------
TABLB 13
(CONTINUED).
CHBMlCAL-SPECIFIC ARARs and mcs
FOR 11m SELECTED REMEDY
LlNBMAS'JER SWITCH CORPORATION
WOODSTOCK, CONNECTlClJI'
AtT11IORrrY RBQUlRBMBNI' STArns REQUlRBMRNT SYNOPSIS CONSIDERATION IN TIIB ROD
Federal Crlieri. BrA IIIIt Relerence DoseII (RfDJ) To Be Con8lde~ RID'. Ire dOle level. developed by BPA lor EPA RID. .re Uled to chancterbe .lIb due to
Advlloriel and _carcfnoaadc efrecu. eapolure to ccntamlnantl In lroundwller, II
Ouldance weB .1 ocher medii.
BrA Carclnoa.. To Be Conaldend BPA Carclnoaenlc pocency Picton Ire aled 11Ie88 IICIon .re Uled to Illell health dlb
Allellment Oraap to compute the Indlvlduallncrementll cancer lrom camnolen. praent It the .lIe.
Potency Picton d.k re.ulllni from elpoeure to Clrclnoaen..
ErA Health AdvI.oriea To Be Conaldend Intended lor U88 In qulUtatlve public health U'ed. If ldequate data eU111n .lIelllnl health
and Acceptable Intake Health evaluation 01 remedial altematlve.. d.b lrom Inleltlnllroundwater al the .11e.
Allellmen' Documenll.
EPA Groundwlter Pnltec:don To Be Con8ldend Providea clallification and reetontlon laal. 1111. .tntelY I. con.ideted In conjunction with
Stnteay ollroundwater baed on It. vulnenblUty, the PcdenJ SDW A and Connecticut Water
UIe, and value. Quality Standard..
SDW A Manum ConIamlnant Relevant and Apprapble (for non-aro MCW. are health.baled 11m 118 and do not Non-zero MCLO. mU'1 be an.ined. 7.cro
Level 0011. (MCLO.) (40 CFR MCW.), ocherwlle To Be Con.ldCRd conlider COlI or feallbUhy. A. health 1081., MCW. wUl be ccn.ldeted In ulellinl health
141.50 and .51) MCW. .re eetabli.hcd at level. II which no ri.b.
known or anticipated adver.e efreeta on the
. health of per.on. occur and which allow lor
an IdeqUlte mlrlln 01 .I'ely.
!
Ambient Wlter Quality Criteria To Be Conaldend A WQC are hellth baled enlerla th., have A WQC can be uled to ch.nder1ze health dlb
(A WQC) been developed lor 95 carcfnoacnlc and clue to contaminant concentntlon. In drinklftl
_c:arclnoacnlc compoundl. Wiler.
TAB~I~R~RDOPDE~roN
-------
.
.
TABLB 13
(CON11NUED)
CHEMICAL-SPECIFIC ARARs and THCs
FOR THB SELECTED REMEDY
LlNEMAS'lER SWITCH CORPORATION
WOODSTOCK, CONNECTICUT
AtmIORrJ'Y RIJQUlRBMHNT STA11JS REQUIREMBNT SYNOPSIS CONSIDERA110N IN TUB ROD
SURPACB WA11!R .
Fedelld Cdterll, Amblenl Wiler Quility Crlleria To Be Con.ldered A WQC I" h8ll1!h-bued Crllerll thll hlft A WQC een be u.ed 10 chlracterlr.e humin heal!h rI.b
AclvlsorIel end . been developed lor 95 cardnolenle and a.lOdated wl!h either Inlestlon 01 waler or can'Ulllpiion 01
GuIdance noncarelllOladc compound. aqualle oraanl.m. end 10 "I.urlace waler dl.charae Uml...
. Becau.e !he 'Urllce Wiler II !hI. .lte Is not u.ed I' I
drlnklnl wiler 'CUR:e', !he A WQC Is developed 10 prcIecI
aquille o'lenl.m. lrom canllmlnlnl upoIu" end 10
pruect humin hell!h lrom ccllllumlni COIIllmlnlled bloll.
Comec:dcut Wiler Quelll)' SlIndlntl 8Id AppUeeble Thlle IIIndlrd8 provide erllerll lor OIemleeli relea.ed 10 .urlace waler Ind .roundweter mU'1
RelUlllor)' a...llleedoni clllllfylni end mllnlllnlni !he qullll)' of not de,rade !he de.llnetect quelll)' ~ the wiler.
Requlremenll Ircundwaler and .urlace wiler
AIR
Fede'" CAAoSll1e fmplemflllldon PlII'I Relnll'll and AflPlVl'rllI' Emlllion IIIndenil de.llned 10 IllIIn Sllte Implemenlllion Plan requlremenll I" enlon:eable
Requlremenll IImllllon Sl8Idanii NatlOlllI Ambienl AI, Qualll)' SlIndard. ARAR. end mU'1 be alllined.
CAA.Nllionel Emlllion SlIndlni. lor Relevant and Apprapt.. Emlllion Slendlnli lor Hezlntoul AI, 11IIIe .Iendlrd. would COIItrolthe ai, dl.chelle lrom II,
, Hlardou. AI, PoUullnll (40 CPR CSI) PoUUIlnIl I" thOle fo, which no II, qUl1I1)' .!ripper. or .Imll., typa 01 trealmenl.
.lIndlnl. edit.
ComectJeul AI, Poliullon Control Reaulilion. (221. ReleVlnl and Apprapflle Slendanll were developed prlmlrll)' 10 a.cavllion Ind emlllion cantrol. for .011. trulment and
Relulalor)' 174-29 end 174.3) replale .tack emlllion.. emillloni I- lroundwller treatment ,y'lem. mult IIIIIn
Requlremenll !hI. ARAR.
TABLB 13, RECORD OP DECISION
-------
(
(
.
.
- T 14
LOCATION-SPE<'...~ ARARs and mcs
FOR TIm SELECTED REMEDY
LINEMAS'mR SWITCH CORPORATION
WOODSTOCK, CONNECTIcur
AUTHORrrY REQUJRHMRNT STATUS RI!QUJRnMI!NT SYNOPSIS CONSml!RA110N IN TUB ROD
WB'I1..ANDSIFLOODPLAIN
Pedenl Requlrementl Nona Nane Nane There Ire no IreII of the lite within the lloodpllin.. No Ictivldel Ire
CCIIIlempllled Ihll wID IIlte pllee In or Iffect well8nd..
5I.e Requlremenll None Nane None There Ire net 11811 of the 1118 within the nooclpilin.. No Ictlvlllel Ire
CCllllemplated thll wID llite place In or I«ect wetland..
TARI.B 14, RnCORD Of DIIClSION
-------
(
c
I
.
Tr. : IS
ACTION-SPECl RARs and TBCs
FOR 11m SBLt.~fED REMEDY
LINEMASTER SWITCH CORPORATION
WOODSTOCK, CONNECTIClTI'
AU11IORITY RRQUJRBMBNT STA'RJS RHQUlRItMIlNT SYNOPSIS CONSlDnRA110N IN 11m ROD
(JNOUNI)W A 11IR
Federal RequlrCmenll RCRA Facllily Standlnl.. ReleYlI\tand Appnlpille F.cUlly .1and.nI. lpCCily de.lln, IlOUIIdwaler The .elected remedy mun conronn, 10 the calenl
(40 CPR 264) monilonnl, and elo.ure, and poal dOlUI1l C8111 ror reulble, to the 10YDmlni technical .lIndlnl.. A
.pec:Ulc type. of rac:ilitle8. Iroundw.ter monltorlnl pmlram mult be
Implemented ponu'lII 10 the.e relul.tlon..
RCRA . General P8ClU1)' Stand.rda (40 ReleYlII1 and Appnlpille Oeneral r.cIIlty requirement. oudlne leneral w..le Any r.eUh)' will be con.truc:ted, renced, poaled
CPR 264.10.264.11). -1)'11.. .eeonl)' meuure., In.pectlont. and tralnlnl and operated In 8c:CXInlanc:e with thl. requlremenL
requlremenll. AU worken wUl be properly lralned. Proc:e..
w.lte. wUl be eVllulled ror the eh.racleriltic. or
hazanlou. wllte. to u.e.. rurther handlin,
requlremenll.
RCRA . PrepaJ'lldne.. and Plnentlon (CPR Relevanl and Appnlpille Outline. ~Iremenll ror ..rd)' equlpmenl and .plD S.rel)' .nd communlc.llon equlpmenl will be
264.30 . 264.31) c:anIlOL m.inl.lned .1 the .ite. Local .uthoritie. will be
r.mUlarized with the .lIe operation..
RCRA . Contlnaenc:y Plan and Rmeraency Releyanland AJlPlVPlllle OuIIlne. reqUlremenll ror aneraenc:y procedure. 10 Plan. will be develqlCd .nd Implemented durlnl
PnIce&II'III (40 CFR 264.50 . 264.56). be uted roUowlnl caplotlon" fire.. de. .ile work Inc:ludlnlln.1111..ion of monitorlnl wdl.
and Implemenlltlon or .ile remedie.. Copie. or
. the plan. wiD be kept on-lile.
TABLB 15, RECORD OP DRaslON
-------
Ti. " '15
(C01" "JBD)
AcnON-SPECIFIC ARARs and TOCs
FOR nm SELECTBD REMEDY
LINBMASmR SWITCH CORPORATION
WOODSTOCK, CONNBcnCUT
AtmlORrrY RHQUJRRMI!NT STAros RHQUIRHMBNT SYNOPSIS CONSIDBRA110N IN mB ROD
GROUNDWATER
RCRA - Mllllleltln., RecordIreeplna, Relevlnl and Approprflle Spedne. the reconlkeepln, and reportln. Record. ollidlily IClIY/IIII will be developed and mllntalned
Feclelll Requlrementa and Reportln. (~O CAt 264.70 - requlremenll lor RCRA ,adllde.. durin. remedlll Ictlm..
264.77).
RCRA - Relalll 'ran Sefid W..re Relevlnl and Approprflle DelIO. lequfremenll lor re'pm.e. 10 rellllll A .roundwlter ,",Iflm will be developed In accordance with
Mana.emenl Unlll (~O CFR 2~.90 . 1lOIII Solid WI.te Manalemenl Unll', the lequlremenu.
264.1(9).
RCRA . CoeIlAl and POII.QOIUre (40 RelIY1n1 IIId Approprflle DelaO. 'podOc !eqUlremenll lor elOlun! and ThOle paltl 01 the re.ulatlon ooncemed with lonl-tcnn
CFR 264.110 - 264.120). poII-c!oeun! ~ hiunlou. WUle 'ecOida. mmltorfna and malnlenance ~ the .ile will be InCOrporiled Inlo
the dlll,n.
RCRA . Surflce JmpowlClmenta (40 RellYlnl and Approprille DelIO. the dalan, oon'llUctlm, operation, Action wlU comply with dean eIO'Un! requlremenl',
CAt 264.220 . 264.2~9). mm/lorinl, In.pealon, IIId -11n,Clle)' plan.
lor I RCRA .urfacelmpoundmenl. AI.o
provide. three elo.ure option. 101' CERCLA
.Ite.; clean dOlure, comalnmenl do.ure, and "
allema'e dOlure.
. CWA - NIiIonaJ PoDutanl DI.chlll' AppUcable Any point--rei dl.chl"e mU'1 meel Groundwater treated on-.ite Ind dl.chUlecr 10 I 'Urflce waler
mlmlnatlm Synem (NPDBS) (~ NPDBS lequlremenll which Include will need 10 comply with the water 'l"aOly 'lIJIcJanb Cltabli.hed
CAt 122, 125). complllllCl with corre.pmdln, Wiler quality by the .tate.
I18OOln18; Cltabll.hmenl 01 I dl,cheral
mmltorin. ty.tem; and complellm 01 repler
dl.cha"e monilorin, record..
TABLB U, RECORD OP DBClSrON
2of4
,
-------
,
(
TABLB 15
(CONTINUED)
ArnON-SPECIFIC ARARs and TBCs
FOR nm SELECl'BD REMEDY
LlNEMASTER SWITCH CORPORATION
WOODSTOCK, CONNEcnCur
AUTlIORrIY RBQUlRBMBNT STA11JS REQUlRBMBNT SYNOPSIS CONSIDERA110N IN TUB ROD
AIR
PedenJ Requlmnenll RCRA «) CPR 264 Subpa" AA, Air Rei...., Iftd ApproprtMe Reaula... racUhle. dra' hl\le opel8don. The .elec:tecI remedy, beceu.e h win have ai, emlnlon.,
8mb.lon St..da"" rOl''--'' Venll. Involvlnl air aniniom above paniculu levell, mu.t conform to the.. requlmnenll.
when appropriate.
RCRA «) CPR 264 Subpa" DD, Air Rel....t and AJIPIOI'fIate Requlrementl lovemlnl relpoille to equipment U durinllmplementatlon of ..Iected remedy. equipment
P.mlllion SI8Ida"" for Bquipment lub It facilltie. dral may ceu.e ai, emlnlon.. leab occur the IelpanlC mull be In confonn.ncc widr dril
Leak.. Subpart.
OSWER Directive 9355.0-21, Air To Be Con.lclered OuIcbnee reaardlnl ule 01 ai, eminlon conlroll The .elec:tecI remedy .hould addren drl. luicbnee.
Stripper Control Guidance. a' CBRCLA .Ite..
TABLB 15, RECORD OP DECISION
-------
'". ,
TA. " ; -5
(CON'" u~lJBD)
AcnON-SPECIFIC ARARs and TBCs
FOR THE SELECTBD REMEDY
LlNEMASTER SWITCH CO~PORATION
WOODSTOCK. CONNEcnCUT
AU1110RITY RDQUIRDMDNT S'rA1tIS RDQUIRUMIlNT SYNOPSIS CONSIDIlRAll0N IN TUB ROD
OROUNDWATBR
ConnecIIc:ut Requlnmentl Water Quality SlIndani. (228-426) Relev8\t uuI Apprapt., Re8lCIIlbie -troll or bell mana.ement practlcel U ....aCllabie -troll or BMP II required, treatment
(BMP) may be requl~d on a c8Ie.by-an baili. radlity and dllchar... mUlt med thell requi~enll.
Waler Pollution CalInII (228-430). Awllcable Contalne ~.ulatlOlll re.anlln. dllcharal Uquld dilcharaa win need to comply with thell
requlmnentl. ~.ulatiCIII.
Dllcharae Permit Replatlan, (228- Relev.., and Appraprlate The.. requl~entl lupplement the CW A NPDBS Groundwater waled on-lite and dllchlraed to a ludace
430) requl~entl. waler wW need to oomply with the watu qUllily
ltandanll 8\d complete IVUtlne mooitorin. ..d
reconlkeepln. actlvitl...
TAnlO 15, RBCORD 01' Dl!asroN
40'"
. .
, ,
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TABLE 16:
rNTJRrH GROtrNDWATER CLEANUP LEVELS
~ . Carcinogenic Interim
Basis Level of
- .. Contaminants of Cleanup
Risk
v ~ Concern (etass) Level~
arsenic (A) 50 MCL 1.1E-04
benzene (A) 5 MCL 1.7E-06
beryllium (82) 4 MCL 2.1 E-04
carbon tetrachloride (82) 5 MCt 7.8E-06
chloroform (82) 100 MCL 7.3E-06
chloromethane (C) 6.5 RS- 1.0E-06
1,2-dichloroethane (82) 5 MCL S.SE-06
1,1-dichloroethene (C) 7 MCL S.OE-05
dichloromethane (82) -5 MCL 4.5E-07
1,2-dichloropropane (82) 5 MCL 4.1 E-06
tetrachloroethene 5 MCL 3.0E-06
1,1,2-trichloroethane (C) 5 MCL 3.4E-06
triChloroethene (S2) . 5 MCL . 6.6E-07
vinyl chloride (A) 2 MCl 4.6E-OS
SUM 4.5E-04
- Derived from a risk-based equation using USEPA standard default exposure parameters
assuming a residential use of grpundwater.
Non-carcinogenic Interim Basis Tatget Hazard
Contaminants of Cleanup Endpoint Quotient
Concern (~ Level~ of Toxicity
acetone (0) 3700 HQ 6ver/kidney 1
cadmium (0) 5 MCl kidney 0.3
1.2-dichloroethene (cis)(O) 70 MCL blood 0.2
2-hexanone 1500 HQ 6ver/kidney 1
methylethylketone (0) 1800 HQ none observed 1
1,1,1-trichloroethane (0) 200 MCL 6ver 0.06
toluene (0) 1000 MCL liver/kidney 0.1
" HI Uver/kidney 2.4
-------
TABLE 17: SOIL CLEAmJp LEYELS
FOR THE PROTECTION OF HUMAN HEALTH AND THE AOUIFER BASED
ON '!'HE SUMMER'S MODEL
"
<.
Carcinogenic
Contaminants
of Concern (class)
1,2-Dichloroethane(B2)
Dichloromethane(B2)
Tetrachloroethene
Trichloroethene(B2)
Soil
Cleanup
Level
(p.g/kg)
4.0
3.0
10.0
5.0
Basis for
Model
Input
MCL
MCL
MCL
MCL
Residual
Groundwater
Risk
5.5 E-06
4.5 E-07
3.0 E-06
6.6 E-07
...
."
"" -
Soil
Non-carcinogenic Cleanup Basis Target Residual
Contaminants of Concern Level for Endpoint Groundwater
(class) (p.g/kg) Model of Tax. Hazard
Input Quat.
cis-1,2-Dichloroethene(D) 50 MCL blood 0.2
Toluene (D) 1000 MCL liver/kidney 0.1
1,1,1-Trich1oroethane(D) 300 MCL liver 0.06
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APPENDIX D
RECORD OP DECISION
LnmHASTER SWITCH CORPORATION SUPERFUND SITE
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STATE OP CONNECTICU'l" S LETTER OP CONCURRENCE
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SENi EY: DE? L:lcal ~s istanc~ ; 6-30-93
2: 33?!1 ;
2e:!===7932~
617 573 9662;= 2
ST~TE OF CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
e
"a
.
Jun. 30. Ui!
Xr. Paul X,ouah
Actinl R'lio~al Admini.trator
va VA Jt.'lio~ I
J!Z 'ede:a1 luildtna
JOlton, kA~ZZ03
r IlAAL f
Dlar J£J. 1\...0662(1
!h. CODnecticut :Depar='Z!.t of Environmental Protection (C'1' D!P) con;Ul'1
with the federal !nv1ronm.~tal 'rotlction Aaenc7'. (IPA) ..l.ct.~ rlmed1 at the
Linemuter Switch Corporation Superfund Site :1D 'oociltock. Connlcticut. ~e
.elected remedy includ8' IOU vapor extraction uc! CrclmdwaUr clewatlrinl to
reduce YOlatile orl&Z!.1c compound 1 (VOel) in the 1011. '1'ht remed7 allo
1ncorpo=atel the IxistinS Iro~d.&ter eztract1~ and &1= It:ipp1n& ",tem which
ha. been m operation linee June 1882. p~r,uaut to Cf DIP'. 1114 Abaullient
01'cl8r. !h. .11,cteeS r81DIdT dll aeSe! carbau acborptiou to the ezbtinl .ir
Itr1pp1:11 unit. "aular enviroZ!.lllental IIIOn1torinS is Al.o r.quired. '1'0 !Alure
. tbat the ramed1 il protective of human hlalth and the e:v!ro:meftt, the ent1r.
r8medy w111 b, evaluated .very fivi T1art, al ID&ftdated in the Comprehen.ive
InvirOZ!.mental lelpona., Compen.aticn and Liabilit1 Act (CIICLA).
!he relDed, ~8 d.l~ribe4 tn d.tail in the PropO'8d 'laQ dat.d April. 1883.
Concurre:ce with !PA'. .el8cted remedy for the L1Z!.emaate: Switch
Corporation.S~perfUDd Site lhall LD no yay affect the Co==i..ionlr'l author1~1
to tnltitute &D1 procl.dtnl to prevent 0: abltt violation. of 1aw, prevlnt O~
abate polluUcm, recover coati ad natural 1'lIOurce dauB", and to imPOI.
penaltill for violation. of 18W, including but Z!.ot 118!tld to violat1an. ot anT
p.rmit iaeued by the Commi..ianer.
.......
Sincerely,
lJ~
faothy I.. I.
Co=i.douer
E..ne)'
nlXaLPV.1Ew
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(PrWcd 011 alC)'CIecs Paper)
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