United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-85/011
July 1985
r/EPA
Superfund
Enforcement Decision Document:
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. \2. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-85/0ll
.. TITLE AND SUBTITLE 5. REPORT DATE
ENFORCEMENT DECISION DOCUMENT .Jul v c; 1 qA5
- - 6. PERFORMING ORGANIZATION CODE
Chem-Dyne, Olt
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency
401 M Street, S. W. ", CONTRACT/GRANT NO.
Washington, D.C. 20460
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE'
800/00 -
-
115. SUPPLEMENTARY NOTES
16. ABSTRACT
The Chem-Dyne site is located within the limits of the City of Hamilton, Butler
County, Ohio, which has an estimated 1980 population of 66,400. The site coye:fs
approximately 10 acres of land, and lies within the bedrock aquifer of the'Great
'Miami River. The Chern-Dyne site probably began receiving hazardous substances as,
early as 1974. ,Addi tionally, Spray-Dyne, one of the numerous Chem-Dyne'~ffiliated .:..
companies", produced anti-freeze on site, by "recycling" chemical wastes and by
using virgin chemicals." By 1976, Chern-Dyne was a rapidly growing corporation storing,
"recycling", and disposing of almost every type of industrial chemical waste.
Operations of Chern-Dyne resulted in uncontrolled releases of hazardous materials. In
five years of operation the facility accepted waste from approximately 200 generators.
The materials handled included pesticides and pesticide residues, chlorinated
hydrocarbons, solvents, waste oils, plastics and resins, PBBs, PCBs, TRIS, acids and
caustics, heavy metal and cyanide sludges, and packaged laboratory chemicals. More
than 30,000 drums and 300,000 gallons of bulk materials were left on site when the
operation closed in February 1980.
The selected remedial action includes: installation of a ground water extraction
system with subsequent treatment of the contaminated water (air emissions from the
treatment system shall be treated by carbon absorption); demoli ton of . onsi tee buildings;
(continued on separate sheet)
17. ' ' KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTlFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Chem-Dyne, OH
Contaminated Media: soil, gw, sw, air
Key contaminants: priority pollutant acid
compounds, volatile organic compounds,
arsenic, chlordane, dieldrin, benzo(a)pyren ~,
hexachlorobenzene and PCBs.
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (Tllis R~po'tl 21. NO. OF PAGES
None 37
20. SECURITY CLASS (Tllis PQg~) 22. PRICE
None
o ,
EPA F- 2220-1 (R....4-77)
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ENFORCEMENT DECISION DOCUMENT
Chern-Dyne, OH
~
Continued
removal of selected soil; and installation of a site cap. Total capital cost
for the selected remedial alternative is estimated to be $11,600,000 and O&M
costs are estimated to be an additional $597,000 per year.
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..
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. .
Enforcement Decision Document
Remedial Alternative selection
SITE:
~~, Hcmilton, "Ohio
OOCUMENI'S RE.VIEWED
.. .
I an basirg my decision on the following doaJments describing the analysis
of the cost am effectiveness of remedial alternatives for the Chern-Dyne Site.
Chern-Dyne Rsnedial Investigation
Chem-~ Feasibility Study
Resp;>nsiveness Sunnary
Proposed Consent Decree
Ranedial Action Plan (Attached to the Proposed Consent Decree)
DESCRIPTlOO OF ~EUL'TED REMEDY
The selected remedy consists of the following elements:
1) A groundwater extraction system with subsequent treatment
of the cont.:minated water. Air anissions fran the treatment
system shall be treated by carbon adsorption.
2 )
Building demolition, selected soil removal with the installation
of a site cap.
The cap ~d be constructed in accordance with
~.
3 )
Performance objectives of the ranedy are described in the Remedial
Action Plan.
DEClARA TIOOS
: -
.
Coosistent with the canprehensive Envirormental Response, Canpensation, and .
Liability Act of 1980 (CERCIA), am the National contingency Plan (40 CPR
.'
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Pan 300), I have deteanined that this remedy at the ~Dyne Site is a
cost-effective rent!dy that provides adequate protection of {)\blic health,
weltare aoo the envirorJnent.
The State of Ohio..has been consulted and
..
Igrees wi th the Q>roved renedy.
In iiddition, the action will rtquire future
operation and maintenance activities to ensure the continued effectiveness of
. the rEmedy.
These activities will be considered part of the ~raved action.
Settlements have been reached between !PA, the State and the respxu;ible
parties based on the selected renedy.
I have also determined that the action bei~ taken is a cost-effective
alternative \!/hen canpared to the other renedial options reviewed.
Jl
5 1985
, , ~
.:/L -Ii v) JI.~
[ATE
Assistant Administrator
Office 9f SOlid Waste and Emergency Response
At tactrnents:
S\m1\ary of Ranedial Aternative Selection
CamuJnity Relations Responsiveness S\J11t\ary
COOsent Decree
Remedial Action Plan
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SUmmarY of Remedial Alternative Selection
~Dyne
Hamilton, Ohio
Site Location and Description:
.
The Chern-Dyne site- is located within the limits of the City of Hamilton, Butler
County, Ohio, which h~ an estimated 19~0 populati~ of 66,400. '!'he site
ocvers approximately 10 acres of land 'on several parcels of ~operty on the
northern border of the city (see figure 1-2).
, '!'he site 18 baJnded 1nmediately on the SJUth by a residential district.
Farther to the south are the business district and i!ldditional residential
districts. It is balnded on the east by a m'-l\icipal park V\ose facilities
include six ballparks and a m'-l\icipal sw1mning pool. Residential dwellirYJs
lie to the east of the park. '!be site is bounded on. the north by the Ford
Hydraulic Canal, which flows west to the Great Misni River. Im'nediately
north of the canal is an 19ricultural field. Approximately 1,500 feet
north of the site is one of Hamilton's two water treatment plants, 1IIhich
punps ground'Nater fran deep wells during the s\.J11t\er J'OC)nths. The site is
bordered on the west by a railroad right-of-way. Next to this railroad
right of 'Nay is the Ra,n!:Dhoff. Canpany, a sheet metal fabrication plant.' Also
to the west is the City of HClTlilton Power Plant. Approximately 75 yardS fran
the site are coal piles and a large petroleum stora;;)e tank for the City of
Hamilton p:JWer plant. Farther to the west are warehouses for the Q1ampion
Paper Canpany, and a snaIl residential area.
A~ the start of initial remedial activities in May 1983, there were ap~oxi-
mately 8,600 drumS, 30 tanks, and 2 cpe~top belowgrade tanks onsite, all
containirYJ hazardous wastes. The tanks and druns contained an estimated
463,000 gal1a'\S of fluid, 109,000 gallons of sludge, and 86,000 gallons of
solids. Dnms were generally in a badly deteriorated coooition; many were
leaking or cpen. Additionally, two below grade truck loading docks, one
gravel lined, were used as hazardous waste .mixing vats. They were full of
hazardous liquids and sllXiges, and their drains were not canpeltely sealed.
Other onsite equi~nt included two tanker trucks (5,000 gallons), four
semitruck trailers, two flat beds, an anpty fuel type tank (300 gallons),
one outdoor reaction vessel (100 gallons), six reaction vessels (4,700 gallons
each), aoo miscellanews debris inside the Chem-Dyne building.
there are five major buildings on the ChEm-Dyne site.
o ChBn-Dyne building
o Boiler building
.. -
o ward ManufacturilTJ bUildjl'YJ '
o Ford building (formerly a Ford tractor
o A blue warerouse (prefabricated)
(see figure 1-4).
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Former operations by Chern-Dyne centered around the Chen-Dyne buildin;;j.
The Chen-Dyne buildil'rJ housed the Chen-Dyne offices, blendin;;j tanks, and
other equipment~ it is presently in a dilapidated state. Three nearby
buildin;;js, the boiler buildin;;j, Ward Manufacturi~ wildi~, and Foro
buildi~, are also dilapidated. There is evidence to indicate that they
were' used tfj the Chen-Dyne Corporation. A detailed inspection of the
buildi~s fourd occasional druns and evidence of hazardous WiSte dr~ining
into the basa1\t!nt of the boiler wildirg. The. blue waretnlse and the
parkirg lot to ~ 8O.Jth of ~ blue WiK'ehouse were also used by the O1ern-D:rne
Corporation to store drumned waste, and there are signs of drum leakage in
the blue warehouse buildirg and on the parki~ lot to the south of the
blue warehouse.
Site History:
The ChBn-Dyne site probably began receiving hazardous s\bstances as early as
1974. Additionally, spray-Djne, one of the numerous Ch~Dyne "affiliated
c:anpanies," produced anti-freeze, on site, by "recycling" chenical wastes
and by usi~ virgin chemicals. By 1976, Chern-Dyne was a rapidly growing
corporation stori~, "recycling," and des~sirg of almost fINery type of
industrial chemical waste. Chern-Dyne produced and sold chemical fuels by
m~xi~ chemical wastes in bulk stor~e tanks, open containers, and gravel
lined "loadi~ docks." Other wastes were "stored" in dI"\.ITIS and tanks,
including at least one old leakilTJ railroaj tank car, in buildings and.
outside on the ground. The Chem-Dyne facility ceased "operatirg" in February
of 1980.
In 5 years of operation the facility accepted waste frem approximately 200
generators. The materials handled included pesticides and pesticide residues,
chlorinated hydrocarbons, solvents, waste oils, plastics and resins, PBB's,
PCB'S, TRIS, acids and caustics, heavy Iretal and cyanide slooges, and
packaged laboratory chenicals. M::>re than 30,000 drums and 300,000. gallons
of bulk materials were onsite when the operations were closed.
Operations of Chern-Dyne resulted in uncontrolled releases of hazardws
materials. Mixirg of liquid wastes was often done in open gravel lined
pits, releasirg noxiws vapors into the atmOsphere, and contaninatilTJ soil
and ground water. Reportedly, 55-gallon druns were punctured with pickaxes
and were allQll'ed to leak, or were dumped onto the ground or into a trough or pit.
Tank cars were reportedly emptied onto the grourd, and into trOughs and se-.-ers.
Fifty-five galloo drums were frequently stored 3 or 4 high, and due to
c:anpression, corrosion and internal pressure allowed their contents to
escape into the erNironnent. Deposition testimony indicates that wastes
were frequently spilled and that at one time a large (X)Ol of waste, referred
to as lake erganax cavered one portion of "'the site surface.
In CNer 5 years. of operation, a n\Jl\ber of envirormental incidents -.-ere
reported at the ChB1\-Dyne facility. Frau 1976 to 1979, there were at
least five fish kills in the Great Miami River that were attributed to
Chern-Dyne operations. O'\e fish kill stretched for nearly 37 miles fran
. the Ford Hydraulic Canal to the tlDJth of the Great Miami River. In 1976,
a series of fires and a f\J1\ing railroa:S tank car incident, created tfj the
improper mixiBJ of chemical wastes, generated active public concern and media
cover5Je.
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Another series of fires occurred in 1979. In addition, continuous odor
complaints were received by local and State authorities from local residents
during certain periods of operations of the site.
.
Legal actions arising out of Chem-D.yne Corporation's handling of waste
material began shortly after Chem-Dyne began handling hazardous waste. In
June 1976 Chem-Dyne filed a $30 million suit against the City of Hamilton
and its officials for-harassment. On September 29, 1976, the State of
Ohio filed a suit against Chem-Dyne and the affiliated Chem-Dyne corporations.
The suit alleged that the companies were responsible for killing more than
a million fish and water animals in the Great Miami River and for emitting
offensive odors into the air. The suit sought compensatory and punitive
damages totalling $340,000 and called for a permanent end to illegal discharges
into Ohio waters and abatement of air pollution nuisances. Both suits
were settled on July 19, 1979, whereby Chem-Dyne agreed to prevent future
pollution and to remove all inventory (waste material) within 12 months.
Chem-Dyne also agreed to drop its suit against the City of Hamilton and to.
pay $75,000 in fines. Chem-Dyne did not comply with the terms.of settlement,
and in fact increased the amount of hazardous waste on site.
The U.S. EPA filed suit against Chern-Dyne, pursuant to the provisions
of RCRA, on December 19, 1979. Two days later, the City of Hamilton
and the Ransohoff Corporation joined in the federal suit against Chem-
Dyne. The suit sought to force Chem-Dyne to stop operations, remove
wastes from the site, and clean up any soil or groundwater contamination.
On January 24, 1980, the Ohio Attorney General filed a motion in the state
court requesting that a receiver be named to assume operations at Chern-Dyne.
The state court appointed Jack Zettler, a Hamilton lawyer and accountant,
as receiver on February 4, 1980. The state subsequently requested
that the Federal court obstain from proceedings in the U.S. action and
defer to the State court. The State represented that the the receiver
would adequately respond to the problems at the Chem-Dyne site. The U.S.
then requested and received a dismissal without prejudice of its filed
action. The receivership, however, removed only 20,000 drums of waste
from the site before ru~ning low on funds, and effectively stopped operating
in 1981.
In October of 1981, the Chem-Dyne site was included on U.S. EPA's Interim
Priority List and in December of 1981 was designated the State of Ohio's
top priority Superfund site. In March of 1982, U.S. EPA expended $50,000
on an Immediate Removal of waste from. & leakiftg bulk storage tank, and
plugging some of the storm dr~ins on the site.
In March of 1982, an action memorandum was signed by U.S. EPA Headquarters,
allocating $3.4 million for surface cleanup and a Remedial Investigation
and F~asibility Study.
Additionally, during 1982 and. early 1983, the U.S. EPA and the State of
Ohio contacted a number of generators of waste materials, who had readily
. identifiable waste left at the site, and requested that they voluntary
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On August 26, 1982, U.S. EPA and the State reached an agreement with over
100 potentially responsible parties (PRP's) for the partial funding of the
removal of contaminated waste from the site and for the RIfFS. More
specificall.Y, the PRP's -agreed to contribute an amount, 2.4 mil\.ion, wh.ich "
was in excess of their estimated proportionate share (.fair share or
volumetric share.) of the estimated:costs of the surface contaminated waste
removal and the conducting of an RIfFS. In the Auugst 26, 1982 agreement,
the U.S. specificially reserved the right to take any action and to seek
to recover costs for any action taken in response to the soil and ground-
water contamination at the site. .
Simultaneously, the U.S. filed a suit to recover additional costs from
certain owners, operators, transporters, and generators of hazardous waste
(PRP's) who declined to participate in the Augu~t 26, 1982, partial settle-
ment. The law suit was subsequently amended to address soil and ground
water contamination, and to add several additional PRP's, some of whom
participated as defendants in the August 26, 1982 settlement. The State
of Ohio filed a similar suit in Federal court on September 14, 1982, and
the State and Federal actions were consolidated into a single proceeding
on November 4, 1982.
The surface cleanup of some 8,600 drums and 33 bulk waste storage tanks,
through an Interagency Agreement with the U.S. Army Corps of Engineers,
took place from May of 1983 to December of 1983. The majority of the
liquid and flammable waste was transported to a high temperature incineration
facility in Eldorado,. Arkansas while most of the solid and semi-solid waste
was disposed of at the CECOS chemical secure landfill in Williamsburg, Ohio.
The total costs of the surface cleanup, cleanup plan and inspection amounted
to over $3.4 million.
"
All containerized surface waste has now been removed from the site. A remedial
. investigation conducted by U.S. EPA's remedial contractor, CH2M Hill, Inc.,
has documented remaining contamination to buildings, soils and the ground
water at the site. The Final Remedial Investigation Report (RI) was released
by U.S. EPA on May 22, 1984. On November 19, 1984, U.S. EPA released the
Feasibility Study (FS) Report for the Chem-Dyne Site. The FS, submitted
herewith, analyzed the RI data to assess the health and environmental risks
posed by contamination at the site and evaluated a number of remedial
alternatives for cleanup at the site in accordance with the National Contin-
gency Plan published July 16, 1982 (40 CFR 300.68). Public comments on the
FS were received until December 28, 1984, and are included as part of the
Responsiveness Summary, also submi.tted with ~his document.
. .. -
Current Site Status:
The Remedial Investigation at the Chem-Dyne site included analysis of the
soils, ground water, nearby surface waters, and on site facilities. Analysis
of onsite soil samples taken from borings, test pits, and the surface has
1ndicaterl extensive contamination consisting of priority pollutant acid
compounds, and volatile organic compounds (VOC's). Several of these contami-
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is considered a human health threat due to direct contact and carryover
by site intruders, ait transport of volatiles and particulates, and the
leaching of compounds into the groundwater and buried conduits onsite.
The quantities of inorganics, base/neutrals, and pesticide contaminants
have been found to be concentrated in the upper 3 feet of soil.at the
site, whil~. the majority ~f VOC's range in th~ upper 6 feet of the soil
horizon. ThE Endangerment Assessment (see FS) conducted for on-site soils,
assuming no action, direct contact with soils and additive effects (no effects
of synergism) of chemicals, determined that exposure to the site soil could
lead to an excess lifetime cancer risk' of 0.05, using the maximum chemical
concentrations found in the top 15 feet of soil, or 4 x 10-4 for the. mean
concentrations of the top one foot of soil. Of the 31 known or suspected
human carcinogens found on the site, the concentrations in soils of arsenic,
chlordane, dieldrin, benzo (a> pyrene, hexachlorobenzene and PCB's would
be the major contributors to this increased cancer risk. Some of these
compounds were found to be widely dispersed ov~r.the site, while others,
such as PCB's, were found only in certain areas of the site.
The Chem-Dyne site lies within the bedrock valley aquifer of the Great Miami
River. The geologic materials underlying toe Chem-Dy~e site are a highly
variable mixture of sands, gravels, silts and clays deposited by glacial
melt waters from recedi~g continental ice sheets. Interglacial streams and
rivers cut deeply into the bedrock of the area and, as the ice receded and
the flows lessened, deposited the materials that now make up the aquifer.
The aquifer generally follows the course of the Great Miami River. It is
approximately 2 miles wide and is bounded on both sides by steep walls of
bedrock. Its thickness is generally around 150 to 200 feet. Because of the
variable nature of stream deposition, the aquifer materials are highly
variable as well. Coarse gravels and cables could be found in some areas
while silt to silty clay lenses could be present in others. The water table
in the vicinity of the site is at a depth of 25 to 30 feet with seasonal and
river-induced fluctuations. Also' lying within the Great Miami River valley
aquifer are a number of industrial production wells (See figure 17) and
. well fields used by the City of Hamilton for drinking water. Production
wells in the area are typically 100 to 150 feet deep, producing 500 gallons
per minute (gpm) or more from the deeper parts of the aquifer. The City of
Hamilton north well field is upgradient 'from the site and would apparently
not be threatened by a groundwater contaminant plume emanating from the
site. However, the city's south well field along with a number of other
water sources are located downgradient from the site (Reference to MCD
Table 11), and could be threatened by a ground water contamination plume
emanating from the site. The variable nature of the aquifer, the close
proximity of the Great ~iami River and the Ford Hydraulic, as well as the
location of several product40n wells presents an extremely complex hydrologic
environmen\. .
As part of the Remedial Investigation, a hydrogeological investigation was
conducted at the site that included installation of 36 monitor wells near the
site, and a hydraulic aquifer pump test. This investigation has been supple-
mented by other investigations which have included installation and sampling
of additional ~onitor wells, monitor well level measurements and permeability
tests, and groundwater modeling. Analysis of data from the pump test and
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groundwater samples fram the monitor wells indicate that a contaminant plume
consisting primarily of VOC's is present near the site and has the potential
for affecting groundwater receptors in the near future (See fig~res 36 and 38).
The RI report estimated the range for groundwater velocities in the vicinity
of the s i te..-IS bei ng betwe~n 0.5 ft" per day to 1.5 ft per day. The report
also indicated-that groundwater flow direction is from east to west beneath
the site with a change in direction to a southerly flow with the course of
the Great Miami River. The report, however, also stated that groundwater
flow is being influenced by the Champion Paper Company wells on the west
side of the river and that portions of the plume could migrate westward and
downward beneath the river. It appears, therefore, that contaminants from
the plume could be taken in by a number of industrial production wells
located within a I-mile radius of the site, presenting near term exposures
due to volatilization of contaminants within these industrial facilities
from the use of contaminated water. The city's south well field is located
east of the river and would be in the path of the southerly component of
plume migration, resulting in long term exposures due to contamination
of the drinking water supply.
Assuming both migration of the plume and leachate from contaminated soils,
the endangerment assessme~t in the FS estimated that contaminants in the
water at both the Hamilton south well field and a well installed in the
future near the site, if used for drinking purposes, would present an
excess lifetime cancer risk of about 9 x 10-5 and 2 x 10-4, respectively
" (See Table 2-7 in FS).
Sampling and observations during the RI have also indicated extensive
contamination of some of the facilities (utilities and buildings) on site.
This type of contamination presents a future source of contamination to
soils and groundwater, and poses a health threat from direct contact and
air exposure. .
Finally, sampling of fish, sediments, and water in the Great Miami River, and.
a tributary, the Ford Canal, did not indicate significant contamination
attributable to the Chem-Dyne site.
Alternatives Evaluation:
'"
The Feasibility Study followed a step-by-step procedure to develope, assess,
screen. and evaulate remedial action technologies and alternatives which
could address problems identified in the RI of the Chem-Dyne site. The goals
of the step-by-step procedure were "to: reduce the range of alternatives to the
most suitable remedial actio~, and to document this decision process. .
.
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Assessment of applicable remedial action technologies (FS Chapter 3) 'was based
on the following criteria: first, technical feasibility; second, environmental,
public health, and institutional effects; and third, estimated present worth,
costs. Remedial technologies were assessed by these criteria in&ependently,
without consfdering possible advantages or dfsadvantages of applying such
technologies in combinations~ ., '
Following assessment of individual remedial action technologies, Massembled-
remedial action alternatives were screened using the same criteria as applied
to the technologies (FS Chapter 4). An example of an assemble~ remedial
action alternative for groundwater is the following: groundwater extraction
with air stripping treatment and discharge to the Ford Canal. In this example,
three technologies are combined or assembled into a single alternative.
Finally, selected assembled remedial action alternatives were analyzed
(FS Chapter 6) based on detailed consideration of the criteria applied to the
remedial action technologies, with particular emphasis on technical perform.ance
and estimated present worth costs.
The objectives of the remedial action alternatives and the various remedial
action technologies evaluated for those alternatives are as follows:
I.
Offsite Remedial Actions [40 CFR 300.68(e)(3)]:
To effectively prevent the further migration of and to remove and
treat the groundwater contamination plume emanating from the Chem-
Dyne site. This plume, consisting primarily of volatile organic
compounds (VOC's), is the result of leaking and spilled wastes
from Chem-Dyne operations. Removing the contaminants from the aquifer
will help protect existing industrial production wells in the vicinity
of the Chem-Dyne site, and the City. of Hamilton south well field.
Remedial action technologies evaluated in the FS to accomplish this
objective were: the use of groundwater extraction wells with treatment
of extracted groundwater by air stripping, and treatment of off gases by
vapor phase carbon. The extracted and treated ground water could either
be discharged to the Ford Canal, deep well injected into a deep aquifer,
or reinjected into the shallow aquifer.
Implementation of the deep well injection technology ;s unfavorable due
to: concerns about possible negative impacts of UIC; institutional
constraint such as the pos~t~o~ of the State of Ohio'that if PR~'s
are-doing the wOfk tpen PRP's must obtain an underground injection
control (UIC) permit from the State of Ohio (which would likely create
delays as its very time consuming); and hegative public comments
received on this technology.
Treating extracted groundwater by air stripping volatiles to different
degrees, and discharging the treated water to the Ford Canal was evaluated
and costs estimated in the FS. The discharge to the Ford Canal would
take into account National Pollution Discharge Elimination System
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state has asserted that the State will require PRP's to obtain a State
of Ohio issued NPDES permit. Reinjection of the extracted treated
ground water i"to the shallow aquifer in order to increase gradients to
extraction wells was a technology "hich was evaluated 1n the Remedial
Action Plan. ....
Source Control Remedial Actions (40 CFR 300.68(e)(2»):
II.
To prevent contact with or migration of contaminated soils at the Chem-
Dyne site. Also. a number of contaminated and dilapidated buildings
on the site present a threat to the health and safety of persons
entering the site. In addition. contaminants from the soils and
buildings are leaching into the ground-water. thereby adding to the
contaminant plume.
Remedial action technologies evaluated in the FS to meet this objective
were: partial removal of contaminated soils and buildings. and.
covering the site with a cap to prevent contact with and leaching of the
remaining contaminants. Contaminated soils and structures removed from
the site would. be transported to a hazardous waste facility permitted to
accept such materials. . Any site cap would conform to the Part 264
technical standards of RCRA. In addition. the FS evaluated a perimeter
cut-off trench around the site which would seal any utilities at the
site which may be a conduit for off site migration of contaminants.
Detailed analysis of .these objectives and alternatives in the FS yielded
four remedial action alternatives which represent a reasonable range of
responses to the endangerment at Chem-Dyne. and which are consistent with the
National Contingency Plan. To summarize the remedial action alternatives. four
tables were presented in the Feasibility Study. These tables present outline
descriptions of the alternatives and the estimated costs. The "no-action" alter-
native was also considered in the Feasibility Study.
Community Relations:
The Chem-Dyne Feasibility Study was released to the publi' on November 19. 1984.
The release of the FS was followed by a five (5) week public comment period which
ended on December 28. 1984. A public meeting was held by the U.S. EPA at the
Hamilton City Hall on December 3. 1984. and was attended by over 100 citizens
from the area. A number of comments were received from the general public and
from the Chem-Dyne defendant steering~ommittee during the public comment period.
These comments and the response of the U.S. EPA to these comments are presented
in the Responsiveness Summary submitted with thts document. .
Following issuance of this document. and upon settlement achieved pursuant to
a si-gned Consent Decree. this document. the Responsiveness Summary. the Consent
Decree. and all associated cleanup plans will be released to the public for
review and comment. In addi.tion. U.S. EPA. in conjunction with the State of
Ohio. will continue community relations activities such as technical updates.
public meetings. etc.. throughout the design. construction and remediation phases
of the cleanup. Additional information on community relations can be found in
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Consistency With Other Environnental Laws:
It is reccmne~ that the technical aspects of the renedial action
alternatives iriti;>lenented at the 01em-I>fne site be consistent with other
applicable environnental laws. Other envirormental laws which appear
to be applicable to the ranedial action alternatives evaluated in the
Feasibility Study are the Resource Conservation am Recovery Act (RCRA),
the Clean Water Act, the. Clean Air Act, the Safe Drinkirg Water Act,
am the 'Ibxic Substances Control Act (TSCA). .
The prollisions of RCRA applicable to ranediation at O1em-Dyne would be
the 40 CFR Part 264 technical standards for the placement of a coyer
system or cap on the site, and the 40 CFR Part 264 SUbpart F Groundwater
Protection staOOards. The partial soil rerooval and"cappirg alternatives
evaluated in the FS are analogous to those actions which would be taken
durirg "closure'" of a RCRA facility. RCRA would require that contaninated
soil either be removed to background (or other standard protective of
hunan health and envirorrnent), or that the soils' be capped on site.
The Groundwater Protection Standards under RCRA Part 264 will apply to
the level of groundwater cleanup achieved by the extraction well systan.
An alternate concentration limit (ACL) will be established at the
waste management unit boundary, (at the Chen-Dyne site, this will trost
probably be the property bou~ary) and will consider ~1e f~ctors outlined
under 40 CFR 264.94, inclooirg impacts on nearby surface water bodies.
It is recrnrnended, oowever, that the ACL derroostration at the Ch~Dyne
site be deferred until the conclusion of the remedial action program
outlined in the Consent Decree. Deferrirg the ACL demonstration will
allow EPA, the State, and the defendants to collect additional information
durirg the course of remedial actions, and refine the fate and transport
models which will be used to dete~ine the effects on potential receptors
of any remaining contanination within the plume at the conclusion of
the renedial action program. In fact, given the uncertainty of contaninant
behavior in ground water, it was the opinion of EPA experts that no
meanirgful concentration limit could be established at this time. 'Ib
ensure that the extraction system is effectively c:>ntrollirg the spread
of contanination durirg this interim period, JOOnitorirg points will be
established down-gradient fran the site and beyond the influence of the
-------
-10-
At these ccrnpliance monitorirg points south aOO southwest of the site,
groundwater quality must not exceed backgroum levels or 10-6 incremental
cancer risk criteria at any time durirg the operatioo of remedial
actioos or thereafter until it is deoonstrated that the groooo water
protection standards have not been exceeded for five consecutive years.
IDeal institutional controls, such as aquifer use restrictioos aoo
well-drillil'Y1 bans will be established durirg the period of remedial
actioo for all areas where groumwater quality exceeds background
conditions.
. .
Any discharge of extracted ground water to the Ford Canal soould be in
ccrnpliance with National ~llutioo Discharge Eliminatj.oo System (NPIES)
requirements. 'the effluent limitations will inclooe limits on VtX:'s,
selected metals, acids, base/neutrals, aoo pesticide priority pollutants.
'Ihe treatment technology to be used to meet the effluent limitations is
air strippirg. .
Air stripping the volatile organic compounds would transfer the VOC's
into the dischargErl gas, an(f \lr.>uld require consideratioo of the substantive
requirements to install and operate the air stripper as a new emission
source under the Clean Air Act. State of Ohio air pollution regulations
require the air stripper to comply with "best available treatment"
(BAT), ~ich is defined by the State as the maxirnLlT\ emission control
achievable by the source taking into account environmental, energy, and
econanic considerations. For these reasons, off-gas scrubbing by
carbon adsorption was inclooed in the remedial action alternatives
evaluated in the FS, and is part of the proposed remedy.
If extracted ground water is reinjected to the aquifer, Underground
In~ectioo Control (UIC) substantive requirements must be considered.
The reinjectioo plan proposed in the RAP is not subject to Section 405
of the new RCRA Hazardous and SOlid waste JWendments of 1984. Section
405 emends Sectioo 7010 of FeRA, and bans injectioo of hazardous waste,
except under certain circ\mlStances. 'Ihe circllnStances present at
Chern-Dyne exsnpt the reinjection system fran a ban under RCRA.
Provisions of the Toxic Substances Control Act (TSCA) would apply to
-------
-11-
Recacrneooed Alternative:
Assembled Alternative fi:). 4 in the Feasibility Study was used as a
basis for negotiations with the PRP's. This alternative is the lowest
cost alternative which is techoologically feasible aoo reliable, aoo
which effectivellURitigates aoo minimizes dcnage to aoo provides crjequate
protectioo of public health, welfare aoo the enviI'Ol'l'Rent at the Chem-Dyne
site. 'lbe remedy described below is consistent with that alternative,
am it is recorrmended that this remedy be implemented at the O1em-Dyne
site. As described abc:we, this renedy o:mplies with the lCP aOO other
applicable environnental laws. This remedy, to be implemented pursuant
to the proposed Consent Decree, is sutmarized below:
Description Of The ~ Remedy
I.
Off-Site R£medial Actions
(i) Ground Water Extractioo/Reinjectioo Systen
This systen will differ fran the ground water extraction systeri
described in the FS in that a number of extraction wells will
be pLlnpi~ throUJhout the identified contaninant plLlne, and a
portion of the extracted ground water, ~fter treatment, will be
reinjected into the shallo~-zooe of the aquifer. The reinjection
of treated water will occur at reinjection wells placed within
clusters of extraction wells in an effort to incre~se gradients
to the extraction wells in order to purge aoo reduce contaninants
(specifically VOC's) in the aquifer.
This systen will have to meet the Samd staooards for groundwater
cleanup as those systens described in the FS. The outenrost
extraction wells of the systen will be placed at the boundary of
the identified IOOppb total VOC contour contCl!tinant pllDe. The
extraction/reinjection systen will be required to establish and
maintain an inward hydraulic gradient, both vertically and
oorizontally, to ensure that contcrninants within the plune
bouooary are contained for rEmJVal aoo treatment. Canpliance
wells to the south aoo southwest of the systen shall be lOOnitored
to ensure that the systen is operati~ effectively. Groundwater
quality at these wells shall not exceed background conditions
as determined by 40 CFR 264.97 or any water quality criteria
for the protect ioo of tu.nan health (based on 10-6 health risk).
..-"':- .-....
.'- '."' -;... ".". '-~
-------
-12-
These standards will provide necessary protection of groundwater receptors,
both iooustrial and drinki~ water, to the south and southwest of the site.
The grouoowater extraction systEm will be operated for a minirnlln of 10
years, aoo the,r;eafter as needed to reduce the contClt\ination in each
IOOnitorirg well within the p1t.me bourrlary to less than 100ppb total
VOC's and until settling defendants demonstrate that concentrations of
total VOC's have becane "effectively constant" in each monitorirg well
within the plune boundary. This dEl'OOnStration must be made throlgh a
rigorous statistical procedure set forth in the settlenent docunents.
If concentrations can be stxJwn to be "effectively constant", it will
mean that further operation of the extraction systEm will not result in
any irnprCNeuent of groundwater quality. It is important to note that
this dEm:nstration is the oontrollirg factor in teminatirg the systEm.
~en concentrations of contClt\inants have becane effectively constant,
fate and transport nDdelirg will be corrlucted, usir.g data collected
throuJhout the l"EJ'I\edial action program, to predict the effects of any
remaining contcsnination on potential receptors. At that time, an ACL
dEm:IDstration may be made following the procedures set forth in 40CFR
264.94. Additional detail~j criteria for monitoring, contingency
mechanisms and shutoff of the systems are in section V of the proposed
Consent D:!cree. An illustration fran the proposed Ranedial Action Plan
of the extraction/reinjection system is attached as Figure 7. This
systEm, involving reinjection into the aquifer, will meet Underground
Injection Control (UlC) requirements. .
( ii).
Groundwater Trea~nt System
Prior to reinjection or surface discharge of the extracted
ground water, the water will be treated to meet the requirements
of the UIC and NPDES programs administered by the State of Ohio.
The extracted ground water will be plnped to an air strippiI'}J
systEm for VOC removal. The design goal for the air strippiI'}J
system shall be to rem:>Ve at least 95% of the peak concentration
of total priority pollutant \0::' s influent to the systEm. This
level of treatment is estimated to meet Water Quality Standards
for human consumption criteria at 10-6 health risk level in the
Ford Canal.
Vapor phase activated carbon shall be provided to remove contcsnination
fran the off gases in the air. stripping system. The Emissions
fran the air strippiI'}J systEm must meet the limits applicable
W1der Federal and State law.
Contirgencies shall be developed and impleuented in the event of
-------
-13-
(a) Existing treatment processes are determined to be insufficient
to allow the discharged effluent to meet permit limitations.
(b)
'!he groundwater treatment system is demonstrated to be a
source of nuisance ordors.
A proposed schematic of this system fran the Rsnedial Action Plan
is attached as Figure 10.
II.
source Control Remedies
( i)
Building Dem:>lition and selected SOil ~al with Site.
Cap.
Observable waste materials remaining within the on-site structures
shall be renpved, provided that such retr::Wal is cost effective and
is to a site approved by u.S. EPA and OEPA. Asbestos waste shall
be disposed of at a site approved for disposal of asbestos. 'lhe
structures themselves shall be demolished with portions either
being salvaged, retv.>ved for disposal off-site, or left on-site as
contour material for the cap (as specified in the COnsent Decree).
Prior to demolition, the buildings on-site will be investigated by
the settling defendants and any portions found to be contaminated
will be de-contaminated or removed for disposal off-site at a u.s.
EPA approved facility.
Excavation and removal of contaminated soils has recently been
undertaken by the defendants. These actions focused on removal of
soils contCl'Rinated with PCB's, and disposal occurred off-site at
U.S. EPA approved sites.
The site shall be covered with a cap consisting of the following
oo~ite construction; a 24 inch layer of clay soil (with a
maximum coefficient of pe~ility of 10-7 cm!sec.); a permable
sand zone; a synthetic liner; and a sand, locn, and topsoil root
zone for vegetative oover. '!be cap shall be graded to prcm:>te run-
off and to minimize soil losses due to erosion.
fobnitoring and long term maintenance of the cap are essential to
proper remediation. ~tailed IOOnitoring, InCiintenance and contingency
provisions are oontained in the proposed Consent ~cree.
An illl.1Stration of the canposite cap construction fran the .Ranedial
-------
-14-
III. Operation and Maintenance:
'!he groundwater extraction and reinjection system shall be operated
for a minim\.IU of 10 years by the Settling Parties to the Consent
Decree. --'!he groundwater treatment system will be operated as
necessary to meet the tenns and conditions of the NPDES and UIe
prograns administered by the State of CJ1io. DJring operation of
the groundwater extraction/reinjection systen, water level
measurBDents will be taken to ensure that both vertical and
horizontal inward hydraulic gradients to the systen are maintained.
Canpliance l1O\itoring wells and monitoring wells within the
system will be s~led with chemical analysis for va:'s and other
ccmpoundS to monitor the effectiveness of the system operation
am mediation. Maintenaooe am replacement of cnuponents of
the groundwater extraction, treatment and rei~jection system will
be undertaken by the Settling Parties as necessary.
Additional IOOnitoring of the Ford Canal will be performed in
accordance with the requirenents of the NPIES. ()Iersight of the
system operation performed by the Settling Parties will be
undertaken by the U.S. EPA, the U.S. Army Corps of ~ineers, and
the Otio EPA. IDeal institutional controls restricti~ aquifer
uses in areas where groundwater quality exceeds background
conditions will be established by the State of Ohio.
Q;>eration of the groundwater e'ttraction/reinjection system may be
tenninated after 10 year!; and an ACL dE!OOl1Stration may be made if .
both of the followi~ performance goals, governi~ ground water at the
site and within the lOOppb total VOC plllOO ooundary, are met:
(a) A roncentration of not nore than lOOppb total priority
pollutant VOC's in each monitori~ a"d extraction well within
the defined lOOppb total va: pltrne ooundary.
(b) !he conce"tration of total priority pollutant VOC's has becane
effectively constant in each monitoring am extraction well
within the defined 100ppb total VOC pluae ooundary.
If after 20 years of q>eration of the groundwater extraction/reinjection
system, both perfocnance goals are still not met, a detennination will
be made as to whether further operation am nodification of the systau
would be cost effective. If the U.S., the State of CJ1io, and the
Settling Defemants to the Cbnsent Decree agree that further operation
would not be cOst-effective and an ACL deoonstration may be made, the
system may be terminated. If the parties disagree, the matter may be
subject to judicial decision. DJring the time in which any such decision
is pending before the Court, the settling defendants will continue to
-------
-15-
'l11e settling defendants must maintain the integrity of the site cap
until such time that they can dErOOnStrate that the cap is no loo;;)er
needed to maintain groundwater standards, or until they can deroonstrate
to U.S. EPA and. the State that another entity is willi~ and able to
continue such mamtenance.
'1he 01em-I>jne PRP's are willi~ to undertake aoo <::art>lete the remedial
alternative set out in this EID. 1be specifics of the proposed settlement
with the O1em-Dyne PRP's, other than the remedial alternative set out
in this EDD, are not discussed in this OOc\Jnent because the proposed
settle-nent oonsideratioos do not leoo weight to or impact the selection
of the renedial alternative set out in .this EID. '!he appropriateness
of the remedial alternative set out herein is to be reviewed on the
basis of this EtD, the attactments hereto, CERCIA, the OCP and U.s. EPA
policy. If the remedial alternative set out herein is unacceptable,
the proposed settlement will be reconsidered accordi~ly.
This EDD has been reviewed by the legal and technical staffs of U.s.
-------
-14-
ENFORCEMENT (Conf ident ial)
In Au:Just of 1982 the u.s. -EPA entered into a settlement agreenent with EUne, but
not all, of the ChEm-Dyne Potentially Resp:>nsible Parties (PRP's) for a partial
reimbursement of the estimated costs of r800ving waste fran the sur~ace of the
Chern-Dyne site. The u.s. then filed a CERCIA actioo, Which was csnemed on two
occassions to add- additional de,fendants and claims, against selected PRP's. - The
u.s. EPA proeeedecf to remove waste fran the surface of the site ana to condu=t an
RI/FS for a deteImination of the appropriate ranaini~ clearlJp activities.
Litigation and settlement n~tiatioos have simultaneously p:'oceeded since filing
of the CERCIA action.
- In the &Inner of 1984 the Court instructed the U. S. to infoIm the defendants of
What the u.s. would be willing to settle for in the lawsuit. We ~re aware that
the RI/FS, and thus the JVD, \«>Uld not be oanplete for several IIDnths. We,
therefore, briefed the Assistant Aaninistrator for the Office of SOlid Waste and
Emergency Response, then Lee nxmas, on this matter and reccmnended a conceptual
settlement proposal. The conceptual settlement proposal, ~ich was approved by
Mr. TlDnas, was calOJlated to be sufficiently conservative so that the R:>D would
require less work, and be less expmsive, than the conceptual settlement prop:>sal.
We- believed that this ~uld allew us to ccrnply with the instruction of the Court,
and to negotiate a rt!!Tledy that would be consistent with, or not less strin;Jent
chan, the R:>D.
The Chem-Qyne PRP's are willing to undertake and oamplete che remedial alternative
set out in this EID. The specifics of the proposed settlement with the O1em-Dyne
PRP"s, other than the rem~:Hal alternative set out in this EDD, are not discussed
in this document because the proposed settlement considerations do not lend weight
to or impact the selection of the rEJ'nedial alternative set aJt in this EDD. The-
appropriateness of the remedial alternative set out herein is to be revie~ on
the basis of this EOO, the attach'nents hereto, CERCIA, the fCP arx1 u.s. EPA policy.
If the remedial alternative set out herein is unacceptable, the proposed settle-
ment will be reconsidered accordi~ly. - -
This EDD has been reviewed by the legal and technical staffs of u.s. EPA Region V
am Headquarters, and by the u.s. Department of Justice.
-------
-15-
SCHEDULE
June 1985
Enforcement Decision
Consent Decree.
Public Comment.
Permit Approvals.
Access Agreements and
Easements Obtained.
Document.
September 1985-
September 1985
Installation of Plume
Definition, Extraction and
Injection Wells.
Building Demolition
and Utilities Rehabilitation!
Abandonment.
October 1985
March 1986
March-September 1986
Completion of Additional
Data Collection and Plume
Definition Report.
Construction of Site Cap
July 1986
Installation of Off-Site
Extraction and Injection Wells
July-August 1986
Construction of Groundwater
Treatment Plant.
September 1986
Start-Up of Groundwater
Extraction. Treatment an~
Re-injection System. .
1986-1996
Operation. Maintenance and
Monitoring of Groundwater
Extraction. Treatment and
Re-injection System
Further OIM of Groundwater
System, if necesary
1996-2006
2006
Further maintenance of site cap
as necessary.
':
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. The Water Conservation Subdistrict
of The ~aJ!U. Conservancy District.
TABLE 11
MAJOR WATER USERS
HAMILTON-NEW BALTIMORE AREA
NAME 0 f
WATER USER
TYPE of
WATER SUPPLY
NUMBER of
PEOPLE SERVED
POTABLE HATER
-----------------------------------------------------------------
1. CINCINNATI MUNICIPAL 760.000'-"
BOLTON PLANT
2. HAMILTON MUNICIPAL 80.000~1'<
SOUTH
3. FAIRFIELD MUNICIPAL 33,000
4. NATIONAL LEAD NON~COMMUNITY 800
5. WATER ASSOCIATION PUBLIC 20.900
NONPOTABLE WATER
-----------------------------------------------------------------
6. SOUTHWESTERN OHIO
WATER COMPANY
INDUSTRIAL
13' Industries
7. FISHER BODY
INDUSTRIAL
1 Factory
~ includes people served from Ohio River water plant(approx.90%)
~~ includes people served from Hamilton North Plant
Page retyped for NTIS-July .24, 1985
-:
20
.-.... . --...
-------
;
~
-------
CARCINOGENS
Fraction
Base/Neutral
Volatile
Pesticides/PCB
TOTAL
GL T114/21
Table 2-1
SUMMARY OF GROUNDWATER CONTAHINATION AND CONSUMPTION CRITERIA--CASE 2
ComDound
Hexachloroethane
Benzo(a)pyrene
Benzene
Carbon tetrachloride
Chloroform
l,l-dichloroethene
1,2-diChloroethane
Tetrachloroethene
l,l,2,2-tetrachloroethane
Trichloroethene
l,l,2-trichloroethane
Vinyl chloride
a. -BHC
13 -BHC
't -BHC
Chlordane
4,4'-DDT
Dieldrin
Heptachlor
PCB
Page Retyped for NTIS - July 24, 1985
Hamilton Well Field
Lifetime
Average Dose
Excess L i fet ime
Cancer Risk
-6
(10 )
Lifetime
Average Dose
~Q/kQ bw/dav)
~/kQ bw/dav)
0.030
0.000016
0.0010
0.00099
0.0055
0.00072
0.0024
0.0078
0.033
0.023
0.039
0.0062
0.06
0.01
0.4
0.7
0.2
0.4
7
0.3
2
O. 1
0.0053
0.0054
0.022
0.0029
0.010
0.025
0.053
0.10
0.077
0.011
0.035 60
0.069 20
90
0.0000031
0.00024
0.00092
0.069
0.00089
0.000049
0.013
0.000057
Future well
Estimated Lifetime
Cancer Risk
-6
110 )
0.4
0.2
0.3
0.7
2
3
0.7
1
10
1
4
0.2
0.03
0.4
1
100
7
2
40
0.2
-------
Table 1 (PaRe 1 of 2)
(FS Table 6-1)
StM1.UY OF E1AKP1.E ASSEHBl..ED A1.1:EIUIAnVE NO. 1 (AA-l)
Co.t E.t1aaU.a
Annual PTeuntb
Operation "
...dial Ac t ion Capital Maintenance Worth
1011
-
bc.a.at. a 10' -d.ep ~rench around the
periMt.r cd r880V, eo11; backfill
wi CIa c1ey
0 buyaUon ad lecUU11q S80,ooo 580,000
lauvau 8Dd r880Ve 2' of 8011 on
aDd offaU. with 6' n8G981 1D
Ana. ., 10, U/U, ad 13;
0 lac.avaUon 1,'00,000 1,800,000
0 t1'8D8po1'tat 10a 2,200,000 2,200,000
0 DiIpO..l 2,900,000 2,900,000
D88011.b aDd r88OY. a.pbalt
parkiDa lot .outh of 111118 war.bou.e
0 D88011t1on aDd &oil lauvatlon 260,000 260,000
0 t1'a.portaUon 390,000 390,000
0 Di.po.81 520,000 520,000
Cap 8IId ...1 eaUre dte witb
8UIUla,er c1ey/ll8lbr8lle eylteID 1,900,000 $17,000 2,100,000
CrClWldvater
btracUon ve11.; sroundvater
rl80Vll till 10-6 canc.r f1.k 590,OOOc
crlt.ria are let 130 ,000 SO, 000
Air .trtpplnl at 99 percent d
total VOC 1'8110'11,1 1,500,000 16,000 1,600,000
Off-p. .crubbul b, ur1>on d
ad80rpUon 1,800,000 4.60,000 3,600,000
'adUtie.
De8011.b ead ~e all bu11d1nI'
and auuctUre.
0 De80UUon 980,000 980,000
0 '%ranlportaUon 610,000 610 ,000
0 D18po..l 770,000 770,000
D88011.b ad rDOV' CGDCnt.
dab cd 10ad1q dock
0 De8DUtion 76 ,000 76 ,000
0 trclpOrtlUon 150,000 1.50,000
0 D1.poaal 190,000 190,000
18ov. tWO ope top auUe buded
caDk8 1,000 1,000
...1 a11 CODDecUoa. to
DOI'tIIIIIut.1'D non ""'1' 10,000 10,000
D8coataloate 8M ni1De
DOr'tbweIt.1'D .ton ''''1' ..pent 15,000 1.5 ,000
-:
GL:r267/51-1
.... "" . -..'"'
-------
laedial Action
ractlttie. (continued)
C1UD ... 81pbon 8ftd Mal ritb II'CNt
lababilitate eai.tin, .to~ aever
(8GUtbuat .ide) 8Dd dec~t_1Dau
...1 eabtiDl abandoned production
..11. riCh II'CNt
In.tHeriD.
..dl tt0D81 .twil.., dedlft, CODltnactton
'88D8,--nt and inlp8ctS.OD (d088 DOt
lDclud. ,.~lttina co.t.)
Subtotal
CoDUq8DC:Y C8 10\)
mw.
Table 1 ('ale 2 of 2)
Calli tli
5,000
97,000
10 ,000
4.100.000
16,.00,000
1,~,000
$18 ,000 ,000
a.11 coat ..tiaatu are Order-" r.Masnitude l."el ..t18lte., i..'.,
..t18lte. have an accuracy of +50 to -30 perceDt.
~..eDt worth ba.ed on 3O-y.ar period.at 10 percent iDtere.t.
21'e.eDt worth bued CID 27-yur period at 10 perceDt 1IIterut.
-pre..nt worth bued em '-year period It 10 percent internt.
GLt267/51-2
COlt E.t1llatu.
Annual
Operation "
Mainten&Dce
543,000
54,000
$597,000
the co. t
Preaentb
Worth
5,000
97 t 000
10 ,000
4.100.000
23,100,000
2,310,000
$25,400,000
-------
table 2 (Pa.e 1 of 2)
(FS table 6-2)
StJHMARy or EXAHPLE ASSEMBLED ALIEMAnVt NO. 2 (AA-2)
a-die! AcUon
!!!!
bunt. ad l"88OYe 3' of 8011;
aD ad offdtl;
o bu.aUon
o %ra.portat1oa
o Itapo.al
DI801hb ad raov8 18pbalt partiDI
lot .outb of blue vlnhOUH
o De80U.Uoa ud SOU Eac.anUon
o trlD.portlt1oa
o Itapo..l
Cap ud Mal _Ure dt. With
8111 U~1er c181/88bru. 81.t-
Crouedvlter
IatJ'8cUoa -11.; IJ'OUDdvater J'88GYal
to d.tlctloa 1181t.
Air ~tr1pp1D& It 90 parcct tocal we
~Il
Off-l&8 .crubb1na by carbon ad.orpUon .
,.dUU..
D88011.b cd r880ge a11 bu11d1nI'
aDd .nucturl.
o De80l1UOD --
o tr.D.port.tlon
o Dhpo.al
D88011.b IDd r880ve concrete
.lab aDd loadinl dock
o DaD 11 UOD
o truaportaUOD
o D1apo.al
188098 ~o open top oo.1te burled
tlDka
...1 ell CODDect1on. to Dortbve.tlrn
Iton ""1'
Decoat_inlte end r81108 Dort!lveat8rn
,ton aever HpeDt
C188D 8" .1pbon and ...1 Witb arout
Ilbab1litate esi.tiDl ,tora .ever
(lCIIUtbu8t ddl) ad d8coat81Date
...1 u18t1q OD8ite _cdoaed
producUaD _11. Witb arout
GL'I267/51-3
Cal)1tal
COlt E.t1mate,a
Annua 1
OperaUOD 6
Maintenance
51,600,000
1,900,000
2,500,000
260,000
390,000
520,000
1,900,000
$17,000
rr...ntb
Worth
. .
$1,600,000
1,900,000
2,500,000
260,000
390,000
520 ,000
2,100,000
130,000 50,000 630,oooc
'00,000 ',200 410,oood
1,100,000 250,000 d
2,000 ,000
980,000 980,000
610,000 610,000
770,000 770.,000
76,000 76 ,000
1.50,000 1.50,000
190,000 190,000
1,000 1,000
10 ,000 10,000
1.5,000 1.5 ,000
5,000 5,000
97,000 97,000
10 ,000 . 10,000
-:
-------
Table 2 (Pale 2 of 2)
Colt EltiJutua
Annual preuntb
Operation "
....d1al AcUOtI Capital Maintenance Worth
11\11 neutn.r.
'''''1 Uw.l .tud1ea, "'1111', COIIltnacUon
una,Dent and 1n.~ct1on (doe. not
iDclud8 p8ra1tt1na COltl) 3.400.000 3.400.000
"tota 18 '17 ,000,000 320,000 11,600,000
CoDt1qaC7 Cat 1~) 1,700,000 32,000 1,900,000
!mAL $11,700,000 $350,000 $20,500,000
ah:: co.t ..t18ate. are Order-of-MaID1tude 189.1 e.t18ate., i..., tbe
co.t ..twte. ban aD accuracy of +50 to -30 perc80t.
'ire.at worth be.ad GD 30-,..1' pedod at 10 percent iDtenlt.
2Z'e.ent vonb beNd GD 950-y..r period at 10 percent intuelt.
-ne.eat .ortb ba.ed OD 5.,..1' period at 10 perc8Dt iDteren.
(J
"7
Gl.t267/51-4
'--\" :.:-.";"".
-------
tabl. 3 (Page 1 of 2)
(FS Table 6-3)
StJMHARY 0' ElAHPLE ASSEMBLED AlnlUlAI1Vt tIO. 3 (AA-3)
lemedial AcUon
!!!!
lacayac. _d 1'88OVe 2'
OD ad off81te;
o 1aca-#.tlon
o !raD.portatIOD
o Diepo.a1
of 8011
Cap 8Dd ...1 ana. of 8011 ad
CODCrete 81ab l'8809a1 vUb 1081
oYer clay 8J.ta
...",. a.pbalt park1.q lot 8ClUtb of
blue varabCN"; esc.v.te and r880Ye
2' of 8011. Mckf111 aDd rep'''';
l'.,lac. suardr.11. aDd catch M.tn
o D880UUOD ad bcavaC10D
o %raDrportaUon
o Dhpo.a1
o l.p.vIDI aDd lackfl111D&
o leplac. suardral1. aDd
catcbba.w
CrCWIdv.ter
Extr.ctl2i v.ll.; ITCNDdvat.r remov.l
until 10 c.nc.r rl.k crlteri. '1" 8et
Air .trtpptn& at 70 percent total we
r~.l
Off-Ia. .crubbln& by carbon .d.orption
facU1Uu
D880l1.h .nd remove Cb..-DyDe. 18rale
aDd boUer ~11d1DI'; b.ckfill aDd cap
ad ...1 vith 10- over cl8J
o D88)U.h
o Ir.n.port.tlon
o DI.po..l
o lacltfill
De8011.b aDd 1'88OY' concrete coal
biD; cap 8IId ...1 vlth loa oyer d.y
o 1)e8)11.h
o %raD.portat1oa
o Dbpo.a1
1I8011lh ad 1'8809' CODcl'et.
81." aDd 10ad1Da dock
o I)e8)U.h
o !raD8pOrtaUou
o ltepo..1
D8c0DC.lut. ford. Wad aDd
b1\18 wanbGuae ba11diD18
-..,.. tWO opeD top ..It. burled
t8DU
...1 a11 CODD8CU.. to DOftIIIM.t.m
.tora '8W81' .....nt
DecODta81Date aDd relin. DOftIIIMlt.m
.toI'8 .8W8r "plDc
GL%267/51-5
C.p1 tal
Co.t E.t1Jllate.'
ADnual
OperaUon "
Ma1nt.n.nce
$1.100.000
1.300.000
1.700.000
980.000
$11,000
260 ,000
390.000
520,000
UO ,000
10,000
2,000
130 ,000
50,000
130,000
620,000
1,000
1-0,000
180,000
100,000
170,000
58,000
24 ,000
45,000
60.000
76 .000
150,000
190.000
420.000
1.000
10 ,000
15 ,000
PreaeDtb
Worth
$1,100,000
1.300,000
1,700,000
1,100.000
260,000
390,000
520,000
130,000
10,000
590,ooOc
130,oood
d
1,200.000
180,000
100,000
170,000
58,000
2- ,000
_5,000
60,000
76 ,000
150,000
190,000
.420,000
-:
1,000
10,000
-------
~
Table 3 (Pale 2 of 2)
18edi81 AcUon
Capital
5,000
C1U1'1 '" 81phOfl aDd ...1 with IrCJIUt
18ba~111tate &al.tin, .tora -.vel"
(eautb.aat 81de) aIId deconta1ute
97,000
Seal m,UDa a~andoned production
_11. Witb p'CJlUt
lDainHrinl
10 ,000
Addl Uaoa1 .tudh., dedlD, COD8tructioa
88ft8aaent aIId In'J)8ction (doe. DOt
tDclude peraittiD& co.t.)
2.200.000
la~total.
CoDUnancy (at 10\)
11,100,000
1.100.000
mw.
512,200,000
aAII co.t e.t1mate. are Order-of-Maan1tude level e.t18atel, 1.e., the
~Olt e.timatel bave an accuracy of +50 to -)0 percent.
~eleDt vonh ~aled on 3O-7ear J)8r1od at 10 percent !nterelt. .
:!TeleDt worth ~aled on 27-7ear period at 10 percent tDtere.t.
-prelent worth ba.ed on 5-7ear period at 10 percent tDtere.t.
'Y
C:U267/51-6
Colt Enimatu'
Annua 1
Operation ,
Maintenance
200 ,000
ZO .000
$220,000
rre.entb
Worth
5,000
97,000
10,000
2.500.000
1.2,600,000
1.300,000
513,900,000
-------
table 4 (Pa,e 1 of 2)
(FS Table 6-40(
StMWlY OF EXAMPLE ASSEMBLED ALn:JlJlJJIVE NO. ,. (AA-40)
Colt I.tiaate.a
Annua 1 Pr..entb
Operation"
--dial AcUon Capital Maintenance Worth
!2!!
lacavau ad reov. ~upou c .c .c
*
I)8oU.1\ 8Dd ft8OV. ..JIbe I t
p8rk1D1 lot lauch of 'lae .anboua. $12.000
0 DaoUUon $12,000
o TranaponUOD .9.000 .9,000
o DS,8po.81 65.000 65.000
C8p 8Dd ...1 aUre .ite 91th
_ltlley,r clay/--br8ll. ayat- 1.9CIO.000 $17,000 2,100.000
GrouDdwater
latracUva _118; arDUlldV8ter r..oval 130.000 50.000 590.000d
UDtil 10 C8D~.r r18k ~riter1a ar. ..t
'
Air .tr1pp1q at " perent total we 1.500.000 1,600.000.
r88OV81 16.000
Off-,a. acnbbina by carbOD ad.~tiOD 1.100.000 46~.000 '~6oo.000.
'adUti..
DI80111b aDd r880ge _11 bu11dtDI'
ad atnacturll
0 Duol1tiOD 980.000 980,000
o %r8D81>0rtatiOD 610,000 610,000
o 1)18po.a1 770.000 770.000
De801i.b aDd r880ve CODcrete
81.b Uld loadUlI dock
0 DaoUUOD 76,000 76,000
o %nnaportatiOD 150.000 150,000
o 1)18poa81 190.000 190,000
I8l1o.1 cwo opeD top ODeUa 1lur1ed
tub 1.000 1,000
Seal all connection. to ~ortbveatlfU 10.000
ICon. 8ewr - 10,000
DecODta1ute ad nUDI aortb-
..Item 1t0fli .ewer HpeDt 15.000 15 .000
Cle. ... .1pboa ad ...1 91da If'OUt 5.000 5.000
I8babnitate u1at1q .tOl'll .ewer
(eoutb...t .ide) ad deCODtatDate 97.000 97.000
...1 81at1q 8baDdoaed proclucUcm 10.000
_11. 91th poaut 10.000
-:
-------
lelledi.l Action
Ena1neerinl
Additional atudi.., de.icn, con.tructian
88fta....nt .nd inapection (doe. not
bel ude pel"81 t t tn. co. tI )
I.tot.l.
ContSApncy C.t 10\)
1'D%AL
Table ~ (Page 2 of 2)
C.~It8l
2.100,000
10,500,000
1,100,000
$11,600,000
Co.t tst1Jnates'
Ann~ 1
Operation 60
Mainun.nce
preeentb
Worth
2,700,000
13,700,000
1,400,000
543,000
54,000
$597 ,000
515,100,000
'All colt ..tiut.. .re Order-of-Macn1tud. 1.".1 .at1aat.., 1..., the
. COlt ..tiut.. haye 8ft .ccuracy of +50 to -30 percant.
~.88nt wortb ba.ed on 3O-,.ar period .t 10 percent IAt.relt.
~ ..-ntity of "Otlpot .011 r880val .,111 be d8tem1ned by .upl1D1 prior
~refor. co.t. for thi' .ction .r. DOt pre..nt.d.
-Preaant worth baNd 011 27-yur period .t 10 perceDt IAter.at.
""'..nt worth ba..d 011 '-year period at 10 percent iDt.relt.
CL%267/51
GLt267/51-8
- ... . -..' .
to and durinc implement.tlon
-------
c
.
! a
I
o
Cl.lMU&..&TlVI ~ IIIIMOVAL, QIII llO&..&TlO".-
to 10
10
20
o
..
L
I
I
-
2
AII""O 1:
ON&. ., ----='
e.
e
.
.
.
.
.
.
.
8
8
.
,
1
,
1
8
: ,
AIt8.A8 '0. : ,
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ON""~
8
8
.
.
.
.8
.
..
.
'.
"
"
.
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.
, .
I:
.
, .
. .
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.
.
.
.
.
.
.
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.
.,.. ...... ell VOC'. - IIN ....... t8 . IwR ia -.a-.... 1.2IO.acm .....
..,... .. -..... '" - ---- 8f IBM --
. '
~oo
A~ AltIAa
,
,
,
\
I
I
1
I
-:
'IOUAE $2
selL CONTANIINAT10N
DISTR I BUTtONS
-------
.~
/
~/
f'~ "t
'.r+, .t~
~~
I t'
I l
I
I
i
"
.~\~
\:~
( ". ;
~.
-'I I ...... .u .. ....... -.....
.......... e. '.'.ell... '.'., .. -
L.D.".
. C"(.-OYN( GENUIJOItS
II(II(Olll ICTION Pt.IN
- e".M-D..' .... DOUNDIII. .
e '''ULOW .1"."e,.ON W.U
. ..fllIlII.'UI IUII"e"o. .'LL
. IIUIC"O.. WIU
- - 011""" Y II"'"-IIUIIP"" eoule,....
--'~ fOIlCIM"'''-''OU''.. II'C""IIDt
FIGURE 1
EXTRACTION-INJECTION
SYSTEM
-------
,
62" VOC/.
TREAUO AHI TO
ATMOSPHERE
"TRACTED
GROUND WATER
.00..
..5 ..IL VOC
VAPOR PHASE
ACTIVATED CARBON
SUAII CONO£"ATf
FROM REGEN~TION
TO HAZARDOUS WAST'
INCINERATION OR LANDFILL
COLLfCTIOIV'
EQUALIZATION SUMP
AIR
STRIPPING
TOWER
NO 0.4' -elL
.. voc
REINJECTION
TO AQUifER
~ -",
/ ,
~S'50~ { CLARIFIER ~ ~2001P"
.4'",. L VOC,. I 0.4~""/L VOC
, /
""""-r( WATER
I FR AC TlON
------L
I --I - -, SlUDGE CAKE
L~-?--~ t------" TO LANDFILL
..... L__-J
SLUOGE
DEWATERING
EFFLUENT
PUMPING SU"
~D
t200 ..-
0.4' -elL VOC
. TREAUO
EFFLUENT TO
FORD CANAL
.1
flgur. 10
SCHEMATIC FLOW DIAGRAM
GROUNDWATER TREATMENT PROCESS
CHEM-DYNE GENERATORS
REMEDIAL ACTION PLAN
Chem-Oyne Sife
-------
--
I"'
ALUMINUM NEUTRON
ACCESS TUIE
~ 100 ",iI
HDPL
. , ~.
."'~'.,i.:e.."....' ......,!.-""",-"........, "''-'';''''_#'''''.'.'' '0..-. ,- ~ L..
:-:c.,,::.....~.~,,:~~,.......~..,:AI~'.=';W.~~ -;;.;r.~--;'r:~~~.. "'.8 ~
~,,,,,,,-~!".'" .- TC)P:.OIL '-'.'-"!J.......~.~~.~:.'.. .' '.:'.
..~:-..;...~~~ ", ,-~...~ .,.:,~..~..-.':..........:;;~...-..
.c.., -;!;.~_...._.\~~.~-, -:-... "':~'..".-"~'" :~.:-.-.......:... ..:,..-,... ::-.:..~=.,~~~.:::.'~
~ ...- '''''.r' ".' ._~.~ ".... .- - .. .', .
, '~~. '.'~' .' ","d ," ',., ''''.~ :~'~~'f '. . >d'
~~"~. ...~~~~~~
~~I::.~i1ii~=~!~~~~'lillllllll~'ilili
::m;~;~;~:~{t.a I.~.. ~.-.~~/~ ,.:~t/. ~~E\~~tll:E LIN!~"::rt(
':;~~~~i~~j1j~j~j~jj~~1\1\;i~~;:~:;::::~t;;~;~~~~~~~1f~~t~~\~\~\1\~I\\~~~~~~~~~~~~~~\~1t\~j1j1jjtj~t1j1j1~j1j1~~jjjjjj1j1j1jjjjjj
,.;:::::::::::::. .HRMEAIILITY a 1.0. 10 . ellt'Me ,,::::::::::::::;:::::::::::::;:;:::::::::::;
",",'.','.'.','.',',',',',',',',',',',',',',',',',',','.',',',',',' .,. . . . . . . . .'.',', .'.', '. ..".".....:.~.:.:.:.:,:,:.~.~,:.:.:.:.~.:.:.:,:.'.:.'.'
';:)[..;;t;~.'
rmmmrmmmmr
::::::::::." FUSE
'.:.. PI"':
TO
".'.'..:':.:':.:.:.:.:':.:':
,'...'....'.',',',.,..'.','.
""........".
. . ,
.. . . . ... ".
'!'I;;:t~":I:I:;I..:::~
.':~''''::~i. ,:,~~:.'
:.'~~.;'"
-.
"
j'i~1.
../'f
.~.
,,' ",
,
..
'V;....,....
COMMON 'ILL. ~,:" . ~.
:,..~ ~ . ~ ~.' r~~ ..~.I. '
~~r ..~". ,.1.' -
1:.' . J. .
~~. ,~ ,
.~a,... . . '.'. .'\",
, ......,.(.. ,- . ..-. ....... :A ': ", ..'
.. ,.. .,. " ~ t.; \"..., , I I \'~.. -..,' I' ,.. ,_1.\ I"~ -.. t.',.' .,,,,,..~..' '-,
. ~r-:1r~:;:~:;~~.I'~S: ~';.~:~~:::}I ;.;.,...,.,~ ;.,~t(;I~~ ~~-;.~-~ '..';.:~ j~~j~.:.~.:~;':~:~:':~~.. :.'.. -: ~ ::~.~~:';::
~tf~:;5~ :i'.!::;1~',,~,'.."r: ;ii~;':):-'..:~.{7t'~~;'t:,:,~"J. "''''''~~~:':\;I';I~~'::: ~~'~~::.':..~~. ... .. :,,~;~~ ~.. -,...~
~Z!:~~~~~ft~~;~~!J~:t~~~'5..~:::}~~~~~f~~~1t'if~~~~~3~~~ ~~~ '. .:;:-;; ~I~~
'...:r,-,") tl~" .',,~,~.~, . NATIVE ,.,: ,~~.~.4j"~'~~""'l~-'~".\"::-;"-'..-'/~'\' ".., \";-4:;""'." ,
._~ .I,C" I,,, ,.., . . ..., ~"L .., I.. I' ,- """ ",,"'--"'\'~ -. ,-,, ,,-....'"
'.':":...t,,. . I'll lOlL' . '~'.t.-r\.~: \';J""!'-."',...,~"',",-, ~.,. '~#,.....",,-.'
. ." "';:.<....~: ~r ~ -,.!'" ~-'~
~~.
.o~
.~..
-:
figure II
COMPOSITE CAP CONSTRUCTION
CHEM-DYNE GENERATORS
REMEDIAL ACTION PLAN
Ch.m-Dyn. Sil.
..... 11/01/11
:..~ ......-.-~"
------- |