United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-86/036
Sept 1986
SEPA
Superfund
Record of Decision
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TECHNICAL REPORT DATA
(Please read InslI'UCtlonS on the revene before com"letingj
1. REPOAT NO. \2. 3. RECIPIEN r's ACCESSION NO.
EPA/ROD/R05-86/036
.. TlTL.E AND SUBTITL.E 5. REPORT DATE
SuPERFUND RECORD OF DECISION September 26. 1986
Arcanum Iron and Me tal, OH 6. PERFORMING ORGANIZATION CODE
7. AUTHORISI 8. PERFORMING ORGANIZATION REPORT NO.
e. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EL.EMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
u. S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Wash ington, D.C. 204 60 800/00
15. SUPPL.EMENTARY NOTES
HI. ABSTRACT
The Arcanum Iron and Metal (AIM) site is a 4.5 acre site located in '!Win Township '
Darke county, OH just southeast of the city of Arcanum and 25 miles northwest of "'
Dayton. The AIM site operated as a lead battery reprocessing facility from the early
1960 s until 1982. Du r in g this operation, battery casings were split to extract lead
cores for smelting. Battery acids gener a ted from this operation were dumped in a large
steel tr ou gh and allowed to dr a in to a low area. Reprocessing of the plastic and black
rubber battery casings generatea lead oxide sludge and lead particulates which collectec
on the gr ound sur face and surface ponas onsite. Past practices at the facility included
bur ial of some mater ials in ons i te pits. Results of the surface soil and soil bor ing
samples tak en dur ing the RI indica te tnat lead is the primary contaminant of concern
with antimony and arsenic leading the contaminants of secondary concern. Lead was
detected in on site and offs ite monitoring wells but not in the six offsite res iden tial
wells sampled. Lead contamination was also found in onsite and offsite surface water
and sediments and three onsite buildings. In addi tion, an estimated 3,800 cubic yards
of shredded battery cas ings exist onsite.
The cost effective remedy selected includes: removal of onsite contaminated soils tc
500 ppm lead and disposal in offsite RCRA Subti tle C landfill; removal of offsite soils
to background lead concentrations and disposal of soils above 500 ppm in offs ite RCRA
(See Attached Sheet)
17. KEY WORDS AND DOCUMENT ANAL.YStS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI Field/Group
Record of Decis ion
Arcanum Iron and Metal, OH
Contaminated Media: gw, sw, soil,
sediment
Key can taminan ts: lead, antimony, arsenic,
heavy metals
18. DISTRIBUTION STATEMENT 19. SEcuRITY CLASS I Tlus Reportl 21. NO. OF PAGES
None 40
20. SECURITY CLASS iThis pagel 22. PRICE
None
!PA 110,",2220-1 (A.". .-77)
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M
EPA/ROD/ROS-86/036
Arcanum Iron and Metal, OH
16.
ABSTRACT (continued)
Subtitle C landfill and soils between bacKground and SOOppm onsite:
continued ground water monitoring semi-annually: improvement of site
drainage: removal of battery casings, conduction of treatability studies,
and placement in RCRA Subtitle C landfill: cleaning or demolishing
contaminated onsite facilities: and deed restrictions on site land use and
aquifer use in the affected areas. Total capital cost of the selected
alternative is estimated to be $9,929,000 with annual O&M costs
approximately 837,000.
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~ .
"
~cCOKD OF DECISION
REHE8IAL ALTERNATIVE SELECTION
SITE: Arcanum Iron and r1etal Site
DOCUt1ENTS REVIE~/ED
I am basing my decision prinarily on the following documents describing the
analysis of cost-effectiveness of remedial alternatives for the AIM site:
- ?inc.l '";~i"1=:(~::: :'1'.'es"':~;ction Report,l\rcanuTTl Iron and t1etal Site,
August 9, 1985.
- Public Comnent Feasi~ility Study, Arcanum Iron and Metal Site,
July 15, 1986
- Summary of Remedial Alternative Selection, Arcanum Iron and Metal
Site, August, 1986.
- Arcanum Iron and Metal Site Responsiveness Summary, September, 1986.
DESCRIPTION OF SELECTED REMEDY
o Remove onsite contaminated soils to 500 ppm lead.
offsite in RCRA Subtitle C landfill.
Dispose of soils
o Remove offsite soils to background lead concentrations. Dispose of
soils above 500 ppm in RCRA Subtitle C landfill. Soils between back-
ground and 500 ppm placed onsite.
o Continue monitoring the groundwater semi-annually.
o Inprove site drainage.
o Remove remaining battery casings and place in a RCRA Subtitle C landfill.
o Demolish or clean contaminated facilities onsite.
o Oeed restrictions on the site land use and aquifer use in the affected
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-2-
DECLARATIONS
Consistent with the Comprehensive Environmental Response Compensation, and
Liability Act of 1980 (CERCLA), and the National Con~ingency Plan (40 CFR
Part 300), I have determined that the remedy outlined above at the Arcanum
Iron and Metal Site is a cost-effective remedy and provides adequate
protection of public health, welfare, and the environment. The State of
Ohio has been consulted and agrees with the approved remedy. In addition,
the action will require future operation and maintenance activities to
ensure the continued effectiveness of the remedy. These activities will
be considered part of the approved action and eligible for Trust Fund
monies for a period of one year.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, the off-site secure disposition is more cost-effective
than other remedial action, and is necessary to protect public health,
welfare or the environment. .
¥:.d6 /~!()
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~.. .
SUI1MARY OF REt1EDIAL At. TERNt.. ~T;:~ S::~EC7IOr;
ARCANUM IRON AND MEiA~ s:::
SITE LOC';;!O;: Ar~f1 DES:RIDTION
The Arcanum Iron and Metal Site (AIM) is ~Gca~ed in Twin Township, Darke
County, Ohio just southeast of the city o~ A~canum and 25 miles northwest
of Dayto~, Onio (Figure 1). It is borderec or th€ north by Pop Rite
Lane, on the east by the Baltimore and Ohio Railroad tracks and an agricul-
tural field, and on the west and south by a~:",icul:urcl fields. The site
covers about 4.5 acres. The surrounding topograohy is nearly level;
however, tne site is within a watershed arec that includes about 15
acres immediateiy wes: of the site. Sur7ac~ runo&: is cnanneled to
Sycamore Ditcr (Figure 2).
The AH< s~t: is H c. ,ura'" agricuiturs :.- I,l~ :learest population
center is tne :ity of Arcanum with 1.94~ ~esisen:s. The residential
populatior wi:nin c 3 mile radius of tne sitE was aporoximately 3,360
in 1980.
One aauifer. having both an uppe~ and iowe- zone, was identified at
tne site. Tne upper zone does not feed we~is usee fo- aomestic or
municipal water supolies in the immediate areC. o~ the site. Surface
waters frotT tne site enter Sycamore Ditcr. vie Co storrri sewer that
discnarges uDstream of tne Arcanum Waste Water Treatment Plant lagoons.
Tne wate- ir, Sycamore Ditch empties into Pair.ter CreeK.
Pertinent features of the site include the followin~: the former saw
building. tne former office building, chain-link fencE, battery case pile.
a pi le of contami nated so; lJrom.:.an. .emergency removal action, and an
.abandoned storm sewer. ..Batterfic.itsings~are.alsostorec in tne saw building.
Pertj-nent features adjaceot..:t~the..:site. include a storm sewer, croplands, a
fa~lTr'house, and the. fonrrer:-".J),op~.Rtte-;,Plant... -.- .---. ...
- _.~~i:~:.;.. ~ . .... .-~..-.~-.':~-~.~~.~:~..:~~~1:S-~~:~~~.':-- ~:.~.~-~~;~~..
-. :....~.i.fF-~H!STORY. . . -.- .:.-_._-O-.~;~:.~~:~~r~~~.':7~ . ,........ ~~:~...:.
----- _.'" -" '~-'.
-' - --.
. .. - .
.:.~:.~.~~~~~.:..~.:.. -.~...- ~:~,~~~~::::.;~;:¥j;;t~tJ~~.. . ..:._.-...:..~~~~ ..
.. .:....' . ~Jhe.:~A1Ms i te operated -as,)::l e~~ji.a~~.~ireprocess i ng facil ityfrom .the. early
-. ..-::'~;:~::~--::~-.-:'196!I':s:. unt i 1 1982.=~ .Ttre:;;lM.:~:rac{:r;tf~ikcepted automobi 1 e and:-_; ndustria1-
. "~:~...';'::G-'-.'~.battir; es for. reproces if;(g-.~}~CQiifjl1g;:.tiJij,c.o perat ion, b atte ry cas in g5 ..:were
"......!.:-::;.:' -J".":.:._;~t:~ . ~-':"'-."-_-:,:""~,__.~r~.:~~.:~~:=_.. . .. '-. '.
. ." .' "- ~',.~-.,..-.::- :~:~~::-- . ~'. :~.'-'~.~~.~~~~,~~'~~~~~~-".'~'
. ..'.. _. -_.=-.~"
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-------
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OHIO
10
MILD
. AFICANUM
FIGURE 1.2
VICINITY MAP
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LOCATION OF, C
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APPROXIMATE SEDIMENT SAMPLE LOCATION
@
1800
I
LEGEND
SD 4001 SAMPLE LOCATION IDENTIFICATION
o
13.'
LEAD CONCENTRATION (~/kg)
RESIDENTIAL WELL SAMPLING LOCATION
809
SCALE IN FEET
6
RWOOO1
o
OUTFALL STRUCTURE
FIGURE '.8
RI SEDIMENT AND RESIDENTIAL WELL
SAMPLING lOCATIONS '
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- 2 -
split to extract lead cores for smelting. This operation generated
plastic and black rubber casings and battery acids. After the casings
were splitt the sulfuric acid was dumped into a large steel trough in
the middle of the saw building and allowed to drain outside to a low
area in the ground surface. The lead cores were extracted from the
casings for smelting. The lead smelter facility may have emitted lead-
containing particulates during op~ration.
The plastic battery casings were stockpiled and then reprocessed. During
reprocessingt lead oxide sludge was gener'ated and then piled for re.cyc'ling
behind the saw building. During dry weathert the lead oxide sludge became
a dust hazard and was controlled by wetting down with water. This
generated water contaminated with suspended lead oxide particulates and
soluble lead salt that flowed out of the back of the saw building through
a small pipe and collected in pools on the ground surface. The plastic
battery casing stockpile also generated runoff contaminated with lead
oxide which tended to pond around the stockpile during rainstorms. The
black rubber casings were ground into chunks and stockpiled onsite.
These rubber chips contained concentrations of lead. During rainstormst
lead particles were washed off into surface ponds onsite. Past practices
at the Arcanum facility included burial of some materials in onsite pits.
The earliest Ohio EPA file reference regarding the Arcanum site is 1964
when a fish kill was reported tn Painter Creek caused by contamination
conveyed via Sycamore Ditch. The Ohio Department of Health requested the
owner to initiate a program for collectingt neutralizingt and disposing
of battery acid. In October 1973t the Ohio EPA's Division of Waste ~1anagerlent
and Engineering made the first of many site visits to investigate AIM's
operation. In January 1974t the Ohio EPA requested that the owner of
the AIM site apply for a Permit to Install an acid treatment system.
Ohio EPA spent the next 2 years trying to get AIM to install.the treatment
system and adhere to the conditions and restrictions of the permit.
In June 1979t Ohio EPA requested enforcement proceedings and litigation
by the Ohio Attorney General. In October 1979t a Consent Decree was
signed by the site owner to clean up the site. Howevert cleanup efforts
were not satisfactorily completed. SubsquentlYt AIM was found to be in
contempt of court in April 1980.
Since April 1980, the Ohio EPA and the Ohio Attorney General's office
have continued to pursue legal actions for the cleanup of the AIM site.
In September 1980t a Citation and Notification of Penalty was issued to
AIM for failure to install a treatment system. The Ohio EPA requested in
April 1982 that legal action be taken to close the AIM facility. No
legal action was taken because the owner ceased operation in December
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- 3 -
/" .
In September 1982, the Ohio EPA proposed the site for inclusion on the
U.S. EPAls National Priorities List (NPL) and submitted a Hazard Ranking
System score of 62 to the U.S. EPA. The score was high enough to include
the site on the NPL in December 1982.
In January and February of 1986 approximately 300 cubic yards of lead
contaminated ~oils from a site in downtown Arcanum ~ere placed on the AIM
site during an emergency removal action conducted by the owner of the AIM
site. The ow~er of the AIM site had operated the downtown site as a
battery recycling facility prior to startup of the AIM facility. -
CURRENT SITE STATUS - Summary of RI Data
During 1984, the U.S. EPA conducted a Remedial Investigation at the AIM
site to determine the nature and extent of contamination at and near the
site. The tasks and data are reported in the Remedial Investigation
Report dated August 1985.
Soils
Surface soil and soil boring samples taken at the Arcanum site show that
lead is the primary contaminant of concern with antimony and arsenic
leading the contaminants of secondary concern. Both lead and antimony
are components of automobile batteries and therefore can be attributable
to site activities. Ouantities of lead in soil, both on and offsite,
appear in orders of magnitude greater than background levels. Lead con-
tamination ranged onsite from 1,520 mg/kg to 58,600 mg/kg and was
greatest near the former processing areas. The vertical extent of con-
tamination in the former process areas was estimated to be 9' and the maximum
volume of onsite contaminated soils was estimated at 39,500 cu yds. The lat-
eral extent of surface soil contamination offsite is estimated to extend 250
feet east of the site based on a 1 imited 'number of data points. The
offsite contamination is believed to be the result of airborne lead from
the site's former smelter.
The U.S. Public Health Service, Centers for Disease Control, has stated that
lead concentrations in soil greater than the range of 500-1000 mg/kg threaten
the health of children in residential settings. There are locations within the
site which have lead concentrations that coulrl cause daily chemical intake
(DCI) values to exceed the Acceptable Daily Intake (ADI) levels when the ADI
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- 4 -
'.
an ingestion rate of 2 liters/day. Lead DCI levels exceeded ADI levels
for all onsite surface and subsurface soils and two nonbackground offsite
surface soils. The site is currently zoned industrial in a sparsely
populated, rural setting~ Site access is-limited by a surrounding fence;
therefore,presently public exposure due to direct contact with lead
in soils is unlikely.
Because of the high clay content of the site's soil, leaching of lead to
the groundwater is considered a difficult path of contaminant migration.
Inhalation of dust particles contaminated with lead may increase he~lth
risks since lead is known to cause ~oxic effects by inhalation.
The background concentration of antimony was estimated to be less than
15 mg/kg based on surface soil and soil boring samples expected to be
uncontaminated by site activities. Most surface soil samples onsite and
some nearby offsite areas showed concentrations above the assumed back-
ground concentration. Surface soils near the saw building also showed
elevated concentrations of antimony (127 mg/kg and 167 mg/kg). The max-
imum concentration for antimony was 2,550 mg/kg found near the former
smelter. Arsenic was detected in all surface soil samples except
two. In the onsite surface soil samples, the arsenic concentration
ranged from non-detectable to 58 mg/kg. I" the onsite subsurface samples,
arsenic was detected at levels higher than the off-site subsurface soil
samples (9.2-36 mg/kg, onsite NO off site). Cancer risk levels were
calculated for arsenic because it has an ingestion cancer potency. The
risk levels were calculated using a conservative scenario involving
potential future exposure of people to surface soils or excavated subsoils
in a residential setting and an industrial setting. The excess lifetime
cancer risk associated with both maximum and average arsenic concentrations
are presented for surface soils. Only maximum arsenic concentrations
were used in the subsurface soils. Those results are summarized in Table 1.
Groundwater
Based on the Endangerment Assessment in the RI report, lead is the
only site related groundwater contaminant of concern. All the onsite
monitoring wells had lead contamination and the concentration range
was 23 to 176 ug/l. Background samples measured 5 and 12 ug/1. The primary
drinking water standard for lead (50 u9/1) was exceeded onsite and the
DCI exceeded the ADI in all the onsite wells. Deep and shallow wells
appear to be equally contaminated. Lead contamination has not been found
above the primary drinking water standard in offsite monitoring wells.
Also, lead was not detected in the six offsite residential wells in the
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Subuni t
----
1"1\1\1-1:. 1
SUMMARY OF EXCESS CANCER RISKO) fROM INGESTION or SOIL
SOli. Or-UtAn"E UNIT
Loca t ion
..----- -" -
S:1mple5 1005-1007
On-Si te Surface Soils
All others
Subsoils
On-site
OU-site
Off-site Surface Soil
Background (200 I)
S;.\mples 3006 &. 3007
AII.Remaining Samples
NOTES
I\r~cnic
.C0!1~.--~I~_!! ~I !~9.'.!J.!.!!d~
lG(.5)
11,(,«(')
'13(5)
:D«(')
EU"f~$ C.1nccr Ris1«2) (
.~~~,lcnti~l- ' "/o~~~r I,)
3[-3 J (,[-.5
2L-3 111>5
II :.-2 71:../'
1,1 ='--3 ?,F-)
7 l:'-:~ 1[-:'
)(.
(7)
J7)
Ii 8(5)
117«(')
11 (5)
2.7(6)
~)E-3
91:-3
2\:-3
5E-{'
2[..1,
7.r.-I,
11[-)
IF-5
1.
2.
3.
4
5.
6.
7.
Potential risk only, currently no one is facing the calculated excess ri'" .
lJased on ingestion of soil containing arsenic - (arsenic cancer potcnc:' : 15 (rne!kg..d:1Y», (5)
Calculated using a LASI Y. f = 0.02& x 0.115 = 0.0126 m~/kg-day.
Calculated using a !.ASI x f = 0.0002116 mg/kr, day.
Maximum conccntDtion found in subunit.
Average concentration found in subunit.
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- S -
Surface Water and Sediments
The AIM site watershed area, shown in Figure 2, includes 4.5-acre AIM
site, which ~s primarily covered by grass and weeds, and 14.9 acres
immediately west of the AIM site, which is cultivated and currently
planted. The watershed area gently slopes to the east and p~oduces
surface ~unoff that dr3ins across the AIM site where it is intercp.pted by
a IS-inch corrugated steel pipe storm sewer located approximately 2S0
feet south of the AIM site's northe~st property corner. The storm sewer
carries the potentially contaminated runoff approximately 1,700 feet east
where it drains into Sycamore Ditch and subsequently flows into Painter
Creek. This storm sewer may extend to the west under the site.
The RI hydrologic study determined that the capacity of the existing
IS-inch storm sewer is too small to properly drain all of the surface
runoff produced during heavy rainfalls, causing potential flooding of
both offsite and onsite property. The worst potential for flooding
occurs during a I-hour rainfall. Three onsite topographic depressions,
identified in the RI, tend to collect and trap approximately 4,700 ft3
of the surface water.
The potential exposure of humans to contaminated surface water could occur
through dermal absorption or ingestion. Due to the fact that site access
is limited, potential exposure of humans to contamination from the site
that is carried to Sycamore Ditch and beyond to Painter Creek is more
likely to occur.
RI data indicate that lead is the contaminant of concern in the samples
taken from Sycamore ditch. The likely contribution from the site extends
1200 feet from the storm sewer outfall. Analytical results showed a 4 to
30 fold increase over the upstream lead sample. The highest sediment concen-
tration before the Waste Water Treatment Plant's lagoon outfalls is 339 ppm.
Lead DCIs exceeded the ADI for lead in mid-stream sediment samples, assuming
the sediments were dried and exposed for ,ingestion. Affected receptors woulrl
include aquatic life in Sycamore ditch and possible human exposure during
low to dry creek levels.
Facilities
There are three structures onsite, two were process related and one was
an office building. One of the former process buildings, the saw
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- 6 -
the building are contaminated. The other process building, -the former
smelter building, is just a small open shed located near the southern
boundary of the site. The office building is abandoned. Since it did
not house process equipment, it is unlikely that it is contaminated.
The onsite ~torm sewer, if it exists, should be located, excavated anrl
removed to eliminate it as a possible conduit foroffsite contaminant
migration.
Battery Casi ngs
There are two stockpiles of shredded battery casings at the site; one in
the saw building and one located at the south end of the site. The south
pile is from the former process operations; it measures about 75 feet in
diameter and 8 feet high. The saw building is bulging from the load
imposed by the casings that are deposited there. Battery casings are
estimated to be 10 feet deep. The total volume of shredded battery
casings is estimated to be 3,800 cubic yards. Samples from the shredded
casings exceeded the EP toxicity test concentrations for lead and there-
fore should be classified as a hazardous waste. There was an attempt to
render the chips non-hazardous with a water wash but this was not sucess-
ful. These chips are inaccessible to the local population because they
are within the locked site compound.
ENFORCEr1ENT ANAL YS IS
The Ohio EPA and the Ohio Attorney Generalis Office initiated various
investigations and enforcement proceedings beginning in 1964. The owner's
-cleanup efforts were never satisfactory, but before any penalties could be
pursued, he closed the site in December 1982. The State's efforts were
instrumental in getting the site on the National Priority List also in
December 1982. '
In 1983 the Ohio Attorney General's Office continued its efforts to get
the owner to take clean up actions outside of the Superfund program.
In October 1983 the negotiations to get the non-remedial actions done
were terminated due to lack of good faith bargaining on the ownerls part.
Meanwhile, the U.S. EPA had written a Remedial Action Master Plan on how
to proceed at the AIM site.
On February 13, 1984, a notice letter from the U.S. EPA's Director of the
Waste Management Division in Region V was sent to the owner and former
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- 7 -
Feasibility Study (RI/FS) would be performed at the AIM site. The owner
decided not to fund the RI/FS. On July 22, 1986, a notice letter was
again sent to the owner to give him the opportunity to execute the chosen
remedy detailed in the FS. It is unlikely the owner will perform the
recommended remedial action, thus monies from the Superfund Trust Fund
will be expended.
ALTERNATIVES EVALUATION
Public Health and Environmental Objectives
The selection process used to obtain a single recommended assembled
alternative as described in the NCP, Section 300.68 (i) Selection of
Remedy, is one that provides for "selection of a cost-effective remedial
alternative which effectively mitigates and minimizes threats to and
provides adequate protection of public health, welfare and the environment.
This will require selection of a remedy which attains or exceeds applicable
or relevant Federal public health or environmental standards."
The adequacy of protection of public health, welfare, and the environment,
provided by each alternative was evaluated based on the alternative's
attainment of substantive provisions of other Federal public health and
environmental standards. In areas of concern where no standards are
available, Acceptable Daily Intake (ADI) levels and a statement from the
Centers for Disease Control were used to guide the selection process.
The following list identifies EPAls specific public health and environmentil
objectives for remedial action at the Arcanum Iron & Metal Site and the
Federal Standards and/or guidelines used to attain the objectives:
o
To prevent direct contact with contaminated onsite and
offsite soil. ADI levels for lead and CDC's published
statement concerning elevated lead levels in children
were used as guidelines.
o
To maintain safe drinking water 'for the population that
could be affected by groundwater contamination. The
applicable portions of the National Primary Drinking
Water Regulations (40 C.F.R. Part 141) were used.
o
To prevent contaminant migration via surface water
run-off from the site and to prevent direct contact of
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- 8 -
tam in at ion was evaluated using the same guidelines
imposed on soil.
o
To prevent contaminant migration via direct contact with
contaminated structures on site. To prevent contaminant
migration via abandoned utilities. Soil guidelines were used.
o
To el iminate the direct contact threat and the possibility
of leaching contaminants to groundwater posed by the above
ground, onsite storage of battery casing chips. Soil qui de-
lines were used.
Alternatives Considered
The assembled alternatives (AA) considered (Table 2) are presented in operable
units according to the category of remedial action under which they fall.
The alternatives were assembled in this manner to provide a range of acceptable
options to be evaluated in detail. The five different operable units were
needed to address the different routes of contaminant migration.
Soil - Onsite Source Control Measures
The detailed evaluation of an available soil treatment technology was considered.
The technology involved washing the soil with a solvent, EDTA*, to reduce the
lead content in the soil and to recover the lead in the solvent. It was deter-
mined that the soi15 at this site were too high in clay content to be treated
with EDTA. Therefore, excavation options to various safe lead clean up levels
were considered.
AA-l
Excavate soil to background lead concentrations.
Dispose of soil offsite.
AA-2
Excavate soil to lOOmg/kg lead concentration.
Dispose of soil offsite.
AA-4
Excavate soil to 500~g/kg lead concentration.
Dispose of soil offsite.
Excavate soil to lOOOmg/kg lead concentration.
Dispose of soil offs;t~.
AA-3
AA~6
No Action
-------
TaIIl.
t
----------------------------------- - - - -. - 4 - .
. ~ -- ------ - --- ------ - --- - - ---- -- ---- ------ ---- - ---------- ------------------------ ------------------ --- -- ----- -------- - - -- - -- -- - --- - - - - - - -- - -- - ---
AA-f>. 110 Act Ion.
AsW8blfd AJt.MlitIYft for 111.111.1
ActaOll .t the AlII Sit.
M-I. Soil RNov.1 to ~id CorIe",- M-i'. Soli ANav.1 10 lNd Coran- M-Jo Sol I I/f8ov.1 10 lns Th.n
tr.taOM 1111<* JU ../kg tntaol'll 1111011 100 Ig/kg :iOO 19/kg
AIH. Soil Af8OY.I to ltid CoricIn- AA-5. C'PPlng
tr.tlons 1111011 1,000 IIQ/kg
.Ith C.PPlng
Soil
fINov. onslt. .nd Offllt. soil to
IIIcklNlUNI corantr.tlOll .Ith dls-
~I .t . ReAlI COIIIIa.nt I.ndhll.
Esta..tfd vol- 39,000 cu yds.
Avd gyPS" to .11 anslt. ,,111 off-
"t. soil .rrlS, blCkhll th.
..UV.tlon, grie..NI r.veg.t.t..
GrOUnd..t.r
--------
c..l\t i"'lIIt _\tori",. 'Mt.1I td.
dltaonll _utorlng .11, INI
11l1li" bi'Nlllllly. Includft
WlllIa", -by rIIldlntall .111.
-- DOtlllltl.1 .. '01' '" .1-
trlCtaOft IN! trtltlillt l,st...
III. Oft iddltaonll 80111 tori" datI.
Surf - Wltrr INI SIIII8I!II&
- -----------------
IiHoYf IN! f'WIIl- 'BOrOI. I, 100
flit of storl -- ~t_n 511.
InCI Syc8ft DitCh. OrIdgr I,~
'Nt of Syc.--. DitCh. Dlspos.1 of
cont.aNII'd WIII...t .t IICAA COl-
plI.llt IlNIh II.
Soil
hc.v.t. anslt. soil .Ith 1.111
cornntr.taons grrAtrr th.1I 100
Ig/kg, .NI ..c.v.t. off 51 t. soil
.Ith Ifill corantr.taOM grtltrr
th.n 30 Ig/kg. llickh 11 th. 'IC'V-
.taOll, gypsUl Iddltaon to .11 on-
Sit. IJId off Sit. soil IrI'S, grid.
.NI rIYIgIt.t.. DISOOSII.t I RLRA
C08llIa.nt I.ndh II of soil fn18
OIl .nd off Sit. .rI.S .Ith llid
cOlICIntr.t loro!i grtitrr thin 100
8IJ/kg. Estilltfd vol- 33,000 cu
ydS. OnSlt. disposil of soil fn18
offsit. Irr.s .Ith ltid COIICIft-
tr.taOM bI1t- 30 IN! 100 Ig/kg.
Groundtoit.r
---------
58.. "t.
SurflCl Wltrr Ind Sfdlll!llt
- ------ ------- -- --------
~ IS ~H.
Soil
Soil
EICIV.t. OMit. soil .Itll llid con- [llelv.t,.1Id rt8VI OMit. .nd
cefttrltaons grrltrr thin 500 III/kg, offllt. soil .Itll l.iII coran-
INI .lclv.l. off Sit. soil .ith 1.111 tr.taor" grtltrr thin 1,000 III/kg
COllCllltr.t 10M g~.trr tn.r, 311 fOl" offllt. dllDOSII .t I Ik.~ cor
IIQ/kg. llickhll tn"ICAntaon, phlftt flellaty. Estilltfd vol-
gyps- Iddltlor, to .11 onslt.,nd i!O,ooo cu yll"lli. hc.v.t.offslt.
offsltf soil IrtiS, grldl.nd re- soil .Ith INd COIICIIItr.taOM ..
Vlgltlt.. DII~I". IIlRA cor- t- Ju INI 1,000 l19/kg .nd pllCI
pla.nt I.Nlhll of soIl fNII on Ind OMit. for dlljlOlll. 6YPSUlIdd-
off Sit. .Ith 1.111 cornntr.taOM ItaOll to .11 OIIIlt. .NI off Sit.
gre.trr th.n 500 IIQ/kg. Estalltld -It blckfa 11, grill. IN! c.~ IN!
vol- 2\1,000 CU ydS. IIMlt'-das- reYegl'tlt. the lit..
posIl of soil froll offllt. .rtlS .IUI
llid COI'ICIIItrltaOM bI1t- Ju .nd
500 Ig/kg.
Soil
Soil
[lcIV.t. flffsat. soil .Ith INd con- No Action.
['Intr.t Ions grtltrr thin 31.' 8g/kg
.NI pllCl OMIt.. Clflr.NI grub
lit., Idd gyps- to .11 onslt. Ind
off Sit. soil _S, grid', CAP IN!
rev."t. the lit..
GroundIoItrr 6roundl8iltrr Grou~trr 6r0undt0itrr
------- ------- ------- ---
&.. ., M-I. s.r II M-I. s.r II AA-I. No ~taon.
!.urflCl Wltrr .nd SIIII...t
Surf ICI Wltrr INI Sldl...t
--------------- ------- ---
------------------
II!8oYe .nd rrollCl .pprOllllt.ly
1,100 tilt of stn - bI1t-
II t. Ind Svr8ft DI tCh. OrIdgr
l,tOO fftt of Syc..... Ditch.
0150051 of WIII...t OMit. .nd
cflv.r ,nlh cl'ln faU IIoItl'rlil.
S- '5 M-J.
SurflCl Wltrr .NI SId....nt
SurtlCl IiItrr .nd !
------------------
-----------------
II!8oYe INI I'IIIIICI losoullt.ly
1,100 flit of off"t. ,torI -
bI1t- "t. ind SYCIlOl"l Dltcn.
Drldg. 1,200 flit flf Syc8Of"l DI tCh.
DlsOOSI of WIIIII!IIIS oro!ilt.. 1:.0
the WIIlllllt Iiong .lln thl soil.
-------
FadlitJ"
----------
DIcoIIt_IMt. S8 bulldlll1), colll!Ct
aNi trNt dI!COnt_INtJon ~Iut 10M.
51 udlJl! dlsDO!MI off Sit. at ACRA roe-
ro8IIlIant laNlflll. RI!8OV. ..Istlng
OI\SI t, stOMl wwr.
IIiIttery CaSIIIC)5 Stockolll!'i
----- - --. ------- --.. -- -- .--
II!mw lh~dI!d bAtt!"y CAS I I'II\s
fNJ8 thl! SAM building and th'
OI\Slt' stong\! pIlI' and dlsDOW of
ollsltp at ACRA r08llliant f~lllty.
Cost a, b
lablp
~
Ik~bll!d AltprNtJ v~ f(A' 1INI!d1.1
Arl10n .t tM AlII Sit.
FaellitJ"
Faelll t I"
----------
------..---
S- AS M-I.
,",1I1h S8 buIldIng aNi dlSDOSI!
ollsltp .t a ACRA --.Itt~ hell-
Ity. R--vt' '''5t1nQ O""ltp 51'Jf"11
_.
IIiIttpry [Hlngs Stockpll"
!lattpry CaSings StockpllP5
--- ------------ ---------....
------------------- -------
s- .s ~2.
AA-2 Includl!'i ,...",.1 and ollsltt'
dlsPMlI of Itochpi led bAU.ry
Cl5l1lqS at a III:RA c08plI.nt facility.
1II1h1l.g of bAtt.,.y caslI'!IS fo\l~
by 01l51tp dlslJQul .t . 111:l1li per-
.IU~ f~i..ty 15 .n ootlon.
Cost
Cost
.PrI!Int
. Worth
CaPital
IMt
----------------------------- - ------------------- --------------------------------
0&" Prftent
IMt Worth
CaPItal
IMt
01" Prl!wnt
IMt Worth
[.pI t.1
Cost
Facilltl"
-- --_. ----
s- as All-3.
8.U.ry CaSlnqS Stockpllt'
.. --- -------- --.. -- - -- - _.--
s- as M-~, M-J.
Lost
- ----------------------------- ------------------------ ---------------------------- ----
0&11
Cost
Prewnt
Wort h
CaPlt.1
IMt
-------------- -------- ---------
"18,-'?7,OOO '18,078,000 137,000 tl7,3-'?,OOO tlr.,'J'J3,OOO
837,000 '10,278,000 ''J, 'J2'J,OOO '37,000
- ---"------------------------
'11,177,000 '10,7'5,000 M6,000
. IMt "l181t" for Alt-ti- 1 to ~ do not Includl! optional groundlllt!" I'draction.NI trNt8fllt of battl'rY CHlngs.
Sl!ll!Chon of tlll!W ootional ~Ial act iOlllllOUld IncrI!a~ pI"I!WfIt IODI'th !!Shut. by '7,710,000
~ IMt "h8lt" arl! baWd on 1'186 dollars.
C M - A5W8bl~ AItI'rNtJv,
----------
Faclhtl"
.S- as MoJ.
!lattt'ry [a\lngs Stoc~OIIP5
----------------------- --
s- .5 M-~. J.'.
IMt
0&11
IMt
Prl!wnt
Worth
CaPita:
[05t
------------ -- - ----- - -- -- ---..--
------------- -- - ------- -----
J, 7'J7, 000 'J, J(,5, 000
w.. 000
Faclhht'l
No Art Ion.
, -
BaU.ry [.~Ing~ Stockpll!!S.
No Art Ion.
- - -- - - - - -- -- - - - --- - --- ---
Cost
0&11
[05t
PrI!5I!nt
Worth
-- -- - - - - -- -- - ------ - - - ----- ----
[.Plt.1
C05t
0&11
[('5t
to
--- -----------------.. --- -- - ---- - ---
to
-------
- 9 -
Soil - Offsite Measures
AA-l
"Excavate soil tc background lead concentrations.
Dispose of soil offsit~.
AA-2"
Excavate soi1 above lOOmg/kg lead concentration.
Dispose of soil offsit~.
Excavate soil betwegn 3Omg/kg and lOOmg/kg lead
and p1 ace onsite..
AA-3
Excavate soil above 500mg/kg lead concentration and
dispose of this soil offsite.
Excavate soil between 30mg/kg and 500mg/kg lead and
place onsite.
AA-4
Excavate soil above lOOOmg/kg and dispose of this
soi 1 offsite.
AA-5
Excavate soil between 30mg/kg and lOOOmg/kg and
p1 ace onsite.
Excavate offsite soil with lead concentrations greater
than 30mg/kg lead concentrations and place onsite.
AA-6
No Action
Soil - Closure Activities
AA-l,2,3
Backfill excavated areas with clean soi~, treat the re-
maining soil with gypsum to promote immnbi1iza1ion of
the lead, grade and revegetate.
AA-4,5
These alternatives would incorporate alt the artivities
in AA-l,2,3 but in addition would inc1Ln1e a RC'A cap over the
contaminated onsite area.
AA-6
No Action
Groundwater - Offsite Measures
AA-l,2,3,4,S
-------
"
- 10 -
contaminant migration.
contaminant levels.
Optional pump and treat based on
AA-6
No Action~
Surface Water and Sediment - Offsite Measures
AA-l,2
Remove and replace offsite storm sewer. Dredge con~aminated
sediments froM Sycamore Ditch and dispose of them offsite.
AA-3,4,S
Remove and replace offsite storm sewer. Dredge contaminated
~ediments from Sycamore Ditch and dispose of them onsite.
AA-6
No Action.
Surface Water and Sediment - Closure Activities
AA-3,4,S
Treat sediments brought onsite with gypsum.
clean fill along with the soil.
Cover with
AA-6
No Action.
Facilities - Onsite Source Control
AA-l,2
Decontaminate the "saw" building, collect and treat the
decon solutions, dispose of sludge offsite. Remove
existing onsite storm sewer.
AA-3,4,S
Demolish the "saw" building, dispose of offsite. Remove
existing onsite storm sewer and dispose of offsite.
AA-6
No Action.
Battery Casings Stockpile - Onsite Source Control
AA-l,2,3,4,S
Remove battery casings onsite and dispose of offsite.
AA-2,3,4,S
-------
- 11 -
AA-6
from the casings was
It remains an option
alternative does not
page -1..L-
No Action.
believed to be potentially feasible.
even though the final recommended
include it. See explanation on
There are no strictly onsite alternatives. The onsite RCRA landfill
alternative in the FS was eliminated because offsite disposal allows for
future use of the site and the associated long-ter~ monitoring would not
be required. Assembled Alternative 5 provides for disposal of conta~in-
ated onsite/offsite soils under a RCRA cap, but the battery casings would
be removed from the site. This alternative would fully comply with RCRA
closure requirements.
Other than health considerations, the assembled alternatives were evaluaterl
by applying technical, environmental, and cost criteria. The definitions
of these criteria and their subparts appear in the Feasibility Study in
Chapter 3 and the results of applying them are summarized in Table 3.
The final assembled remedial alternatives were screened based on the threat
to the public via direct contact with the lead contamination at the site and
on cost effectiveness, i.e., how well the public health and environmental
goals would be met for the esti~ated cost of the alternative.
COt1~1UNITY RELATIONS
There has been moderate community interest at the Arcanum Iron and Metal (AIM)
site.
Approximately 25 residents and local officials attended each of the public
meetings. The first of two meetings was held in July, 1984 to brief resid€nts
on planned Superfund actions at the site. At that meeting, residents and
officials were most concerned about a pile of battery casings on the site.
They expressed concern that the casings were unsightly and could create an
a; rborne contam;natton probl em. .
A second meeting was held in July 1986 to present the results of the Remedial
Investigation and Feasibility Study. The concerns at that meeti~g were
mostly about when the site would be cleaned up and the issue of ¥ho
should pay for the cleanup. The farmer adjacent to the site had specific
comments in the choice of remedy as it affected his property. T~e comments
of record along with EPAls responses to the comments are listed in
-------
Tlble I , . of 9)
EVAI.UATI~ OF ASSDtlUD ALTEIIJIATIVES
EvaluatIon Criteria
A..el8l> led
Alternative
~
TItle Ind
o.lcrlpllon 01 """..-bled
Alternative
Technical
!II.. I r........tal
tona-Te...
(Operallon)
Pre lent
Public SalelY ~
Short-Te...
(ConatrUC:Ilon)
Inlt I tul lonal
Sllety
11IP1_nlabll ity
Reliability
, -
eoat. ,b
Clpll a I 06H
~~
$18,UI,OOO $18,018,000 $)J ,OlIO
Soli Reeovol 10 Leld Concen-
trltlonl Below )0 .a/l
-------
'..""'Ied
Alternative
~
Title and
Pe.ulptlon 01 ..._Ied
AI ternatl ve
Facilities
Pecont..lnate aav bulldlna,
collect and treat decont..1-
nation .ollitiona, .llIdae
dl.po.al at ICRA-c08pliant
la"d 1111, and r....."e ex latina
on.tte aluDI sever.
Battery Cadnl' Stocl
-------
Table ) of 9)
Aou8bled Tille and Technical Eo" I rOl8t!nt al £o8,8,D
Altf'rnat Ave De.crlpt Ion of A.._led Short-Teno ....... -Te no Pre.ent Capllal 0611
"UOIber AHernat I"" lellabillt, 18P1_ntablllt, Sa fet, (Conatruc:t 100) (OperaUoo) InaUtut looal Public Safety ~ Coa' Cos'
Groundwater " .
Continue .....Horlnl. In.tall Prov Ide. for lelaUvely PotenUal laata"atloo PotenUal for LI.It. future leduces potenUal coo-
.ddltl......1 .....Horlnl well. potential al8Pla to con'8lnatl00 of ...118 "III .11"Uon of Irounclwater t_lnant e"""aure to
and ..-ple bl.nnually. detect Ion of l-rle...nt. eapolure to CAuae little eda tI na uee at the the public by datecUon
Inrludea s88pllnl ne.rby lutur. coot..l- work 'orce dhturb.nce. cont8ln.ted one. of ch.nle. In cont81-
re.ldentl.1 well.. A.I.81 netloa or durlnl coo- Iroundwater. nant concentration..
potential need f~r an .llraUon of Itruetton.
ex' ract Ion and treat-.ent u I.Unl
syste'8, h'lied on addU lonal Iroundw.ter
IWIOHorlng dati. cont..lnat ton.
Pro"lde. for
potenUal fu.
ture 18P1_nta-
t Ion of an
extraction and
t reat_nt
.yat_.
Surf.ce W.ter and Sedl...nt .. 0 0
lIe..we and repl.ce .pprod- ProvIde. ade- lequlre. dredl- PotenUai lacreaaed PoteaUal 5to.. a_r leduces potenUal
.ately 1.700 It of .to.. qua t e dra I n'le. Inl. tranl- cont..lnaat truck traffic. lourca of con- rep lac_nt cont..lnent upo.ure
sewer between .Ite and reduces flood- portaUon. and .apolure to duet .enera- t81naUon .., disrupt to the public.
Syc...,re Pitch. Deedle Inl potenUal. oUaltedla- work force Uon and (..IaUna rail .e,.."lce.
I .700 It of Syc880re Pit ch re80vel poten- poaal of durlnl nolae. off.lte etono
and dhpo.e o' .polla at a tlal _rce of approd..tel, con.tractlon.. a"""r) re-
IICRA-c08pllant facility. contlnulnl ..sO cubic ..".d. le-
cont81naUon yarda of aedl- duced flood-
(e...tlnl _nt. Inl potential.
ofhlle .to..
sewer).
F.clIIUe. 0 .. .
Decont..ln.te a... bulldlnl. Re8Dvel CollecUon and Potential Incr.aaed PotenUal lulldlnl de- "Ial.tzea coot81neat
collect and treat decont..l- con...lnantl t reat...nt 01 cont..lnant truck trafftc. _rce of fu- cont81nat Ion eapo.ure to tho public.
nation solutlon-, 81udae froe 8av decoot..lnatl... eapo.ure to duat .-..- ture cont81- allow. future
dlsposa. at a ICItA-cD8lpliant bulldlnl. aolutlon """Id work force tI.... and aalloo .1... - U8e.
landrl II. and re8>ve ealst- e 11.lnatea be the 8081 dur I nl con- nol.e. aat.d. Futur.
In& on.tte ator. .ever. future dl fflcult Ite. at ractlon. u.a of ....
cont_lnat Ion to I "1>1 e8t!ftt . bulldlnl
due to onalle ""nltor Inl poa.lbl..
.10"" RVer. """Id be
required.
laact loc.tlon
anet quantity of
ealatlnl ooalte
etora .ever
unknown.
-------
Assellb led
Alternat Ive
~
Tille and
Description 01 A.._led
Ahef1Ultive
Battery Ca.lnls Stockpile
Re80ve shredded battery
caslnls Ir08 the la.. bulldlnl
and the onllte ~torale pile
and dhpoae 01 at IICRA-
cmapllant facility. Conduct
..nllneerlnl studleo to
deteralne leulb1llty 01
..uhlnl battery ca.lnl..
5011 lIe80vai to Le.. Than
SIlO ../kl
~
beavate onalte loll ..Itb
lead concentration. areater
than SIlO ../kl, and excavate
olilite loll ..Ith lead con-
centratlona ,reater than
~ ../kl. Backft 11 tbe
excavation, lyPIU8 addition
to all onllte and offllte
loll areaa, Irade and revele-
tate. Dlapoaal at a
RCRA-cD8pl1ant landft 11 01
soli Ir08 on and offalte
areaa wltb lead concentra-
t lona Ireater than SIlO ../kl.
Onllte dllpolal 01 a01l Ir-
olfllte areu with lead
concent rat Ion. between )() and
SIlO al/kl.
Groundwater
Continue IIOrIltorlnl. InaUIi
additional IIOrIltorlnl _11.
and luple biannually.
Includeo 188pUnl nearby
r..ldentlal _111. Allell
p"tent lal need lor an
extraction and treat_nt
"y"t.., baaed on additional
.....Itorlnl data.
Gt.
~
Technical
IeUabllity
tab Ie 1 (Pile" of 9)
H
Re~\J'e.
cont_lnanta
fr08 tbe lite.
.
lIe80vee blahly
cont_loated
10111, reducee
potential of
future aur lace
..eter and
Irounclwater
cont.lnaUon.
.
Provldea lor
potentlel
detect Ion of
luture cont-I-
nat I... or
allr8t Ion 01
exletlnl
Iroundvater
cont_lnatlon.
Provldee for
potent lal lu-
ture lapl_nta-
lion 01 an
eatract ton and
tceatl8ent
ayate..
lapl_ntability
o
Requlrel
tr aneport and
dleposal 01
cont..lnated
caalnle. Can
be lapl_nted
relathely
quickly.
lequlr.. eaca-
vaU... 01 eo1l,
tnneport and
dlepoeel 01
cont..lnated
e01le. "'et
lapart lerle
quanUU.. of
1011 lor cover
..terlala.
May requtre
peralaalon to
excavate
ollaUe.
..
lelathely
alolple to
lapl_nt.
Safety
o
PotenUal
contaalnant
e.po"ure to
work lorce
durlnl re8OVal.
Pot enUal
cont_lnant
eapolure to
work lorce
dor I nl con-
ItrucUon.
PotenUal
contaalnaU...
expo"ure to
work lone
durlnl coa-
etrucUon.
Short -tera
(Cone t rue Uon)
t:nvtr_ntal
Luna -tera
(OperaUon)
IneU tutlonal
PubUc Safaty
Pnaent
~
..
"Inl.hea pub 1 Ic
..poaure to
cont.lnanu.
..
Increaeed truck Potential le80vai
traffic, duet enune 01 lu. laprovea
leneraUon, and ture cont.ln- poulblUty lor
1101.... .e- aU"" to reualnl alte
qulrea r_Inl Iroundweter and and a-
approd_tely aorface vater bu11dlnl.
1,900 truck eU.loeted.
loeda 01 Iean.ea poten-
..tertel. Uel lor direct
contect.
Incre..ed
truck uefflc,
duat ..nen-
Uon, and
nohe. .e-
qulree ep-
prod..tely
I ,200 truck
loede lor
beuUnl 01
8011.
.
10ata11eUon
01 ...l1a ..III
c.... Utt Ie
dlaturbance.
.
leducad poteo-
Ual lor IU-
tura coot..l-
oetioo 01 aur-
fece vater and
Iroundwater.
PotenUel lor
allnUoa 01
edat 101
coot-loatad
Irounctwater.
.
8011 r880V81
..I II el1- lor
"alted rauea
of tbe eUe.
LlaUa lutura
Ir""""'eter
u.. et tbe
aUa.
Cost8,b
Capltel
~
06H
wst
$10,218,000 $9,929,000 $n ,OlIO
.
leducea coataaloant
eapoaura to tbe pubUc.
leduc.. potenUal coo-
taalneot a.poaure to
tbe pubUc ., detecUoa
01 cbanaea 18 coot..l-
-------
As..e.hlf!d
AlI.ernat 1 YP'
"_her
Tit Ie and
llescrlpt Ion 01 Au_led
Alternat lye
Surface Water and Sedl-nt
Rel80ve and replace .pproat-
_tely 1,100 ft 01 at ora
sewer between lite and
Syu80re Oltch. Dredge
1,100 It 01 SYCQ80re Oltch
and d hpoae 01 apo I 10 onalte
and cover with clean (III
asterlal.
hcllit I...
1Ilo.,II sh ..v buildIng vI th
disposal at a ICIIJI-p"..ltted
1.
-------
ASSf>abl..d
Aht'nJallve
Tille and
(lesnlptlon 01 Aose8bled
Alternative
ffu...el
addition tn .11 ootilte and
oll.lte areal, backllll,
,rade. and cap. and
revele. ate the aJte.
(;roundwater
(;ont Inue 8Onltorlna. Inllall
add It lonal IIOt'Iltorlna weill
alld ...ple biannually.
Illeludes I..pllna nearby
re.ldentlal weill. blul
potent lal need for an
ext ract Ion and treat.ot
6Y6te., based"" add It lonal
.unltorlnl data.
Surface Water and Sedl-nt
Re80ve and replace
appr...I.ately 1,100 H of
stur. sewer between site and
Syca80re IIltch. Predae 1,200
H of SY<080re Pit ch and
dlsp06e of Ipolll ",,"ite.
"'cilltiu
Pe80llsh law bulldlna with
disposal II HCRA-penaltted
facility. He80ve eahtlna
(lUll I t~ stor. .ever.
CI
b
Techn 1<0 I
He liability
Table I (Paae b ul 9)
waler conta.l-
nat Ion.
Provldel for
detect Ion 01
'uture
cont..lnat 100 or
.Iaratlon of
ulltlna
. aruundwater
cont_lnallon.
Prov ldel for
potential future
I.pl_ntatlon
01 an clltractlon
and t reat_nt
"y"t-.
H
Provldel ade-
quate dnlnaae,
reducel flood-
Ina potenllal,
reduces poten"
t la I of future
cont_Inallon
due to edltlna
offllte atona
sever.
H
Re80ve8 cont..-
Inated .41"
bulldlna, ell.-
Inatea. future
cont_lnlllon
due to onllte
stOr8 .ever.
18ple_ntablll ty
excavate
oll<e.
it
Relatively
11...le to
1...le-nt.
Rellllvely
118ple to
18pleMnt.
RellUvely
11...le to
18p1...nt.
bact locIUon
Ind quant It y
of ealollna
",,"ite Itor.
sewer unknown.
Safety
Potentlll
cont_lnlnt
eapo8ure to
work force
durlna Con-
Itructlon.
o
Potenlla I
cont..l.....t
eapolure to
work force
durlna
conltructlon.
PotenUa I
cont..lnent
eapolure to
work force
durlna
deeoll lion.
Short -Ter.
(Cona true: tI on)
soil for
offslle
dlaposal.
+
Inatallallon
of wella will
cauae II It Ie
dloturbance.
Incre..ed
truck trlfflc,
dult ae08re-
tlon end
noloe.
Increlled
truck trlfflc,
duat aenerl-
lion, and
nol... Truck
l18ullna of
deeo II 11011
rubble ..y
dloturb
c-.nlty.
fnv I ron8eot ..
Long-Ter.
(Opeutilln)
Porentlll for
.Igrlllon of
ealotlna
conr-lnated
aroundwlrer.
. 0
Porentll I
_rce of
cOllt.lut Ion
(11181 IDa
offalte Irona
I....r) r...ved,
reduced flood-
Ina potent.. I.
H
PotenUI I
lource of
furure coo-
t .lnaUOII
ell.lnated.
Inar I tut I..nal
LI.lu furure
aroundwater
U8e.at the
aire.
Srona aewer
repleceeent
..y dflrupt
rail aervlce.
Cont.lnlted
bulldlna Ind
atara aever
re80ved.
C.Utila."
Puhllc Safety
rr~6cnr
Wurth
l;uSI
+
Reducel porentlll
cont-Inant eJlpo8ur~ to
the public by derecll'ltJ
of chInlea In contael-
nant concentration..
+
Reducel porentlll
conr..l.....t eapoaure
to the public.
+
PorenUl1 lource of
future Cont.IDltlon
ell8luted. Public
eapolure ro cOllt.l-
nared arrucrure .Inl-
.hed.
Cal.IL"
eo.t
III>fI
-------
ASPi...hlf"d
Alternallve
NU8bt". -
Tit Ie and
IIP.nlptlon 01 A......,led
Altern8tlve
lIattery C..lnsa Stoc"plle
Re80ve shredded bau rry
..slnls Ir.. the s... bulldln.
a~d Ihe onslte storale pile
an" dlapose 01 at Mr.IIA-
«.pllant laclllty. C.onduct
englnf'erlng studa., to
"pter-Ine leaslbllity 01
washing bat tery c88Inl'.
S
r.opp I nl
Soli
hcnate oltslte loll wIth
lead concent rat lon8 Ireater
thon )0 -./"1 and ploc<
onslt~. Clear and Irub alte.
0...1 IYpsua to all ons Ite and
offslle soil areaa. Irade.
cap. and reveletate the .Ite.
Groundwater
Conllnue .....lto,ln.. Inltall
add It lonal 8OItlto,ln. _110
and lallple bIannually. In-
dud.. a""Plln. ...arby ,eal-
dentlal wella. Aaaeaa poten-
tIal need (0' an eat,actlon
and t reat8ent ayst~. baaed on
add It looal 8Onlto,lna data.
Sur lace llatn and Sedl....t
Me80ve and replace approal-
...toly 1,100 It o( ollalle
ston8 .ev~r hetveen lite and
SYUBIOfC Ditch. Dredse 1,200
le..t nf Syc880re Ditch and
dlspuse of spol'l nnslte.
C;LT611IS-1
TechnIcal
Reliability
11III1_ntablllly
..
o
Requl'u
tranaport and
dhpo181 of
contMlnared
c..ln.a. YO
be 11Ip1_nted
,elathely
qulc"ly.
Ite83vel cont--
Inanu (,.. the
lite.
..
Does not ,e-
80ve aoll con-
t..tnantl.
Reducu poten-
tial fo, futufC
lurface vater
and .,ounclwate,
conU.lnation.
SllIple to
11Ip1_nt.
l18y require
pe...I..lon to
eacavate
oUalle.
..
Provldel for
potentlll
detection of
future cont..-
Inat Ion 01'
.llrot Ion o(
ealotlnl
.roundwate,
contMlnltlon.
Provldu for
potential
11Ip1_ntatloo
01 an eatractlon
and treat_nt
ayBlnl.
Relatively
aillple to
IlIple-nr.
..
Provldu ade-
quate dralna,e.
reducu Hoodln.
potent 'al. re.
aoVei potentlll
aouree of con.
IInulna conU.-
+
Relat Ively
118ple to
IlIple_nt.
Table I ,
Safety
o
Potential
cont..lnant
eJLpoaure to
vor" force
durlnl
re8O¥a' .
Potential
cont..lnant
..poaure to
work (orce
durlnl con-
I trUC tI on .
Potent III
cont..loant
eapo...re to
-,,, (orce
durlna con-
It ruet Ion.
o
Potential
cont ..Inant
expo8ure to
work fol'c.
durlna con-
Itruetlon.
o( 9)
Sl10rt -Te...
(Conatructlon)
1nere..ed
true" traffic,
dun lenere-
lion, end
nolI..
"qulree
rnoov lna
app,oat_tel y
1,900 trUC"
loadl of
..terlel.
Incr.aled
truc" traffic,
dult lenera-
tlon, end
notl..
+
InlteUnlon
of _Ue will
caule UUle
dllturbenu.
locree..d
true" trefflc,
dult lenero-
tlon end
nolle. Dis-
ruption of
aarlculturol
EnvironaenUI
Lonl-Te...
(Operot 100)
++
'otent 101
IOUrce of
future con-
t_lnat too
to Iroundwate,
and lurf.c.
water e1l81-
natecl. ""'.u
potent III for
direct contact.
'otentlal (or
aurface vater
Ind Iround-
vater cont_I-
nation r_loI.
'otentlal for
811ret Ion of
eatltlnl
coot_loated
I,ounclwater.
o
'otentl.1
eourC8 of con-
tMlnetlon
(edltlnl
ItO" lewer)
re80ved t re-
duced floodlnl
Inlt Hut lonal
Re...al
IlIprovel po"-
Ilbillty for
raullnl lIte
Ind 18W bulld-
1"1.
Cont..lnlted
loll and the
up ..y 1I81t
future uae 01
Ille.
Cont..lnatecl
I'oundwater
not reaoved.
Lt.IU future
Irounclwater
ule It the
8Ite.
Sto.. _r
repl.cnoent
..y dllrupt
r.II aervlce.
Public Slfety
Pre lent
~
..
"Inl.hel public
eapolure to
cont_lnantl.
Cost a.b
Capita'
Cost
0.
OYI
Cost
$],1'11,000 $J,J6S,OOO $106,000
o
leducu contMlnant
upo"ure to the public.
+
leducea potentl.1
cont_loant eapo...re
to the public by
detection of ch8aae" tn
cont_loant concentra-
tlonl.
leducel potential
contMloant eapolure
-------
Table 1 (Pale 8 of 'I)
Ane.bled
AI ternat i ve
~
Title and
llescr Iptlon of Au..led
Alternathe
lavlr_ntal
Lana-Te...
(OperaU...)
Public Safety
Preaent
~
Technical
Sbort -Te...
(Coan rue U on)
InaUtuUonal
18PIe8enUblllty
Safety
Rellebll1ty
Inatlon (ealat-
Ina offelte
ato... e.-r).
ecUvlUu"'" potenUel.
rell lenlce.
rael l1Uu
De... I hh aa.. bulldlna ..lth
dllpoaa' at RCRA-pe...ltted
lacility. Ie...ve edlUnl
on.lte ator8 lewer.
H
PotenUal
_rce of
future cont..-
InaU... ""1-
nated.
+
+
Coat..lneted
bulldlni end
Itn... _r
r....ved.
+
PotenUel _rce of
future c...tulnaU...
el1.lnated. Public
++
Re8OVe8 can-
t..lnante fr-
n.. buUdlnl,
e l1elnetee
future coo-
Rehtlvely
II...le to
1...I_nt.
bact loutl...
end qU80t Ity
of ealetlnl
"'Ilte ItO'"
.ewer unknown.
PotenUel
c...t..lnant
eapoaur. to
won force
durlnl c...-
ItruCU....
locreeeed
truek trefflc,
duet le...re-
tI..., end
oolae. Truek
heul1na of
de8D 11 tI...
rubble ..y
dhturb
c_lty.
eapoaure to
contulneted atrueture
.Inl.hed.
t ..Inet Ion due
to onal te eto...
.ever.
eo8t8.b
Capital
('.nIt
0611
~
Battery Callnll Stockpile H 0 0 H . H
lI....ve Ihredded battery Ie..,.. coo. Requirea 'otenUel Inc..ee..d Potentlel --"el "Inl.h.e public
clalnaa fr- the u.. bulldlnl t..lnute fr- treneport end contulnut truek treUlc, _rce of ""ro..ee .apoeure to c...-
end the onalte etorele pile the lite. dhpoael of eapolure to duet le...r.- future CllClt_- polelllility for t_lnantl.
and dlepoa. of .t RCIA- c...tulneted work force Uon, end IneUIICI to r-lna elt.
co.pUent recll1ty. Conduct culnl.. Cen durlnl r_el. 1101... Ir"""""lter end I'"
en,lneerlnl Itudlea to be 1...I_nted Re",1 ree ..... lurfece bulldlna.
deter.loe feealbility of re leUv"y .._Inl ..et... ell.I -
..uhlnl "auery culnla. qulclLJ y. .pproal..tely Dated. --e.
1,900 truek potentlel for
10ed8 of .I..ect CllCltlCt.
..terlel.
b No Act Ion SO $0 SO
~ .. 0 ..
No ectlon. Doe. not re80ve lID conat ructlon lID chanle. lID cODnruc- 'otentlel fo.. Coat_lnetd PotenUal for
eoll cont..1 - ..equlred. tI... ..elated c...tlllUl... .011 at 8Ur- pollilc eapolure
nanU, poten- eUICtI. audIC. vet... fece "y""e Ie hlah.
t lal for luture end around- elte _.8IIIe.
aur face ".t8.. vet.r CODt_-
end Iroun""eter lutl.
cont..lnetlon .._In..
e.tlt..
Croundw.ter .. 0 ..
No acUon. Doe. not l'e80ve lID conatruetlon lID chaole. I
lID con.true- PotenUel for Key 11.lt u.e Doe. oot pro-
cont.ln.ted required. U... rel.ted contl....lnl 0 f Clll8lte end ..Ide for c...-
Irounclwat er. effecu. Irouadvater offalte t_IRIOt de-
Doea not pro- coot_lnetl... Iroundvater. tec tI... .....
vide for de- ud .llraUon _Itorlnl.
lectlon of of coot..1 -
tuture con- nated Iround-
I aIIto.t ton or ".tel' re,,'na.
-------
--. -_._~
A!IIst'".bled
Alleln..t Ive
Huabt!1
-.---
Till.. and
\)eo. I Ipt Ion oi 'ssp_led
Altrlnallve
Surface Water .nd Sedl-nt
No 8("tI011.
hcJl Il I...
"0 action.
onslle aauery Caaln.s
StodpJle
No action.
TechnIcsI
Table I
ltellabJl Ity
Safety
.I~ral Ion 01
e.lst Ina
conl..lnated
,roundvater.
Floodlna poten-
t 1.1 retl8tna.
...Iatlnl ato..
sever re.etnl .
.ouree of future
cont..tnat Ion.
doe. not re80ve
cont..tnated
aedl-nr.
Doe. not re-
8)ve .ource 01
cont_tnaotl.
Do... not re-
.,ve lourCf: of
cont ..Inaotl.
lsopl_tablll ty
..
No conltructlon
requ I red.
..
No conltructlon
requ Ired.
..
No
eon.tructton
requIred.
o
No chanle.
o
No chanle.
o
No chanae.
a
CoSI est hut~s fur
Select Ion 01 these
b
Coal est laates are
AI Ulnat \y... I to S do not Include optional Iroundvater eatract Ion
opt lonal re"'dlal act I....a would Incre..e pr...ent worth e.t I..te by
based on 1986 doll....
G'.T611/S
I;\.TI>IJ/S.q
'of 9)
Short-TO'..
IConstruct Ion)
En" I ro<8<'f1U I
Lana-TO'..
1000r.t Ion)
Public Safety
Institutional
..
No con.tnrc:- Floodl... poten- Cont I nued Pountl.1 for
tlon re hted tlal r_ln., cOllt..l- public eapo.ure
dfect.. potent lal oaud runoff. h hlah.
louree 01 con.
t..lnat Ion
luhtlnl .to..
lever) reuln..
sedl-nt con-
..Ioantl ..e.
..In. lource
of cont lnulnl
COIIt ..lnatiOll.
..
No conatnrc:- Source of Stnrctur.....y Poteotlal for
tlon re lated cOllt..lna- be unu.ab I e public espoaure
effecta. tlon re..lna. for luture h hlah.
Indu.t rial
purpoa....
..
No construe- Source of Structurea and Potential for
tlon related cOllt..loa- .lte ..y be public eapoaure
effect.. tlon r_lo.. unu..ble lor I. hlah.
liability of future
cont..loaoU Industrial
..y be hlah. purpoae..
and treat_ot or vashlnl 01 b.ttery c..ln.s r..-dlal .ctlona.
$1,110,000.
Present
Worth
Coat. .'"
Capital 1\Yt
~~
O'
-------
- 12 -
o ,
"
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The five action alternatives are required to comply with all applicable
or relevant federal regulations. These are highlighted in Chapter 6 of
the Feasibility Study. The two federal environmental laws that figured
most. prominently in the selection process were the Comprehensive Environ-
mental Response, Compensation, and Liability Act of 1980 (CERCLA), and
the Resource Conservation and Recovery Act (RCRA). (Specifically, Subtitle
C, concerning the handling of hazardous waste and the Hazardous a~ Solid
Waste Amendments of November 8, 1984, which expanded the requirements and
coverage of the already existing RCRA law). The National Oil and Hazard-
ous Substances Pollution Contingency Plan (NCP) 40 CFR Part 300, governs
the overall process of how the alternatives were developed and se1ecterl
pursuant to the CERCLA Act Section 105. Applicable portions of RCRA
govern the handling, transporting and storing of any hazardous wastes
found onsite. RCRA also governs closure requirements for waste management
units.
One final environmental law, the Clean Water Act (CWA), is applicable to
this site in so far as the site may be discharging lead to navigable
waters via storm water run-off. The implementation of the chosen remedy
should prevent any future discharge of lead to Sycamore Ditch. In the
unlikely event that a groundwater pump and treat action becomes necessary,
requirements of the CWA would be considered before any offsite discharge
occurred.
In addition to CERCLA, RCRA and CWA environmental laws, the Procedure for
Planning and Supplementing Off-Site Response Actions (Off-Site Policy)
published in the Federal Register on November 5, 1985, is a policy adopterl
by the EPA which "governs the selection of a facility for any off-site
storage, treatment of or disposal of hazardous substances which may be
necessa ry" under CERCLA or RCRA. The pol i cy a1 so covers EPA I s stand on
treatment in connection with CERCLA actions. What this means for this
site is: 1) Any offsite landfill chosen for storage of lead contaminated
soils must be in compliance with the Soljd Waste Amendments of 1984 as
they pertain to land disposal facilities; and 2) Treatment, recycling or
reuse of wastes must be considered to promote permanent methods of manag-
ing hazardous substances. Both of these requirements were addressed in
considering alternatives.
The U.S. EPA's decisionmaking process in selecting a remedial action
alternative is the functional equivalent of the National Environmental
Policy Act (NEPA).
COMPARISON OF ALTERNATIVES
-------
- 13 -
The substantial difference between the alternatives involves the soil
operable unit. In the discussion that follows, alternatives are compared
and eliminated based on the soil operable unit. Table 3 presents the
comparison of alternatives in detail.
Assemb"led Alternative AA-6 - No Action
The no action assembled alternative is ineffective in preventing further
contaminant migration and does not reduce the existing contamination at
the site. The Exposure Assessment concludes that there is potential for
exposure to the public from contaminants at the site at levels that may
adversely affect" health and welfare. Remedial action is therefore requir-
ed to reduce or minimize this exposure. Since the stated goal of protect-
ing the public health is not addressed in this alternative, it is eliminated
from further consideration. However, it is presented in here and in
Table 2 and 3 as a baseline for comparison.
Assembled Alternative AA-5 - Capping (Present Worth Estimate $3.8 million)
The U.S. EPA believes that capping alone, provided by AA-5, may not provide
long term protection of groundwater resources because of the nature of the
buried materials that would be left onsite: buried shredded battery casings and
very high lead soils (maximum found was 56,800 mg/kg). In this case, the
stated goals of protecting the public's health and the environment are ad-
dressed, but the potential for future problems due to leaching of lead to
the groundwater would remain. Therefore, this alternative is eliminated
from further consideration.
Assembled Alternatives AA-1 and AA-2 -
Soil Removal to Lead Concentrations
Below 30 ppm and 100 ppm (Present
Worth estimates $18.4 million and
$17.3 million respectively)
Assembled alternatives AA-1 and AA-2 have the potential to provide the
greatest environmental and public health benefits because of the relative-
ly low lead cleanup levels achieved. However, the actual benefits derived
from achieving these levels would not be significantly greater than those
derived from the two remaining higher levels (500 ppm and 1000 ppm).
This is because there are no residences on the site. Thus, the two lower
levels would be more appropriate if the site were zoned for residential
uses. Since the cost of AA-1 and AA-2 are about twice as much as the two
remaining and do not provide substantially greater public health and
-------
- 14 -
Assembled Alternatives AA-3 and AA-4 -
Soil Removal to Lead-Concentrations
Below 500 ppm and 1000 ppm/Capping
(Present Worth estimates $10.3 million
and $11.2 million respectively)
Alternative 4 would leave approximately 1000 ppm lead in the soil onsite
under a RCRA cap. Since AA-3 and AA-4 have similar environmental and
public health benefits, the U.S. EPA chose the more conservative level Of
500 ppm. Under AA-3, the site would be "left with a maximum lead s.oil
level of 500 ppm and the excavated ~reas would be covered with clean
topsoil. This alternative is preferable to a RCRA compliant cap that
must be maintained and which would severely 1 imit the future use of the
site. The existing information provided by the Exposure Assessment and
the Centers for Disease Control form the health basis for recommending
assembled alternative AA-3 for the Arcanum site.
DETAILED SUMMARY OF THE U.S. EPA's RECOMMENDED ALTERNATIVE
The present worth of the U.S. EPAls recommended alternative, AA-3, is $10.3
million with an annual O&M cost of $37,000 and consists of these elements:
Soil
o
Detailed soil testing and analysis of lead, antimony, and arsenic
during remedial design and cleanup to more accurately define the depth
and areal extent of onsite and offsite soil contamination.
o Excavation of contaminated soil onsite with lead concentrations
above 500 mg/kg with disposal at an existing RCRA compliant landfill.
assumed to be located 600 miles from the AIM site for cost estimat-
ing purposes. Estimated volume is ,20,000 cu yards.
o
Excavation of the soil from offsite areas with lead concentrations
between 30 mg/kg and 500 mg/kg and placement ons;te to be covered with
clean fill and graded to promote site drainage.
o Soil left onsite with lead concentrations between 30 mg/kg and 500
mg/kg will be tested for EP toxicity or equivalent at the time of
Remedial Action. Soil which fails the toxicity test will be disposed
of at a RCRA Subtitle C compliant landfill.
Currently RCRA is using the EP toxicity test as one means to characterize
a hazardous waste. It may be replaced by a different test before Remedial
-------
. "
- 15 -
o
Gypsu~ addition to all onsite and offsite soil excavation areas to
further immobilize remaining lead. The U.S. EPA believes that this
treatment, together with the local geology, will prevent the further
migration of lead to the groundwater. .
o
Gypsum addition to soils going offsite to a RCRA Subtitle C landfill.
The U.S. EPA believes that hazardous substances taken from an NPL
site should be treated before disposal offsite.
Groundwater
o
Installation of additional monitoring wells offsite and hydraulically
downgradient from the site. Continue monitoring these and residential
wells to assess potential need for the groundwater extraction and
treatment system. Test for VOC's periodically along with the inorganic
parameters.
o
Conduct soil column leach tests on the remaining gypsum treated soil
during remedial action to assess whether soil removal to the 500 mg/kg
lead concentration provides for long term protection of groundwater
resources in the site area.
o
If the groundwater pump and treat option is exercised, the technical
requirements of an NPDES per~it must be met.
Surface Water and Sediment
o
Install a new, larger offsite storm pipe between the adjacent farmer's
fields to improve site drainage. The technical requirements of an NPDES
permit must be met.
o
Clean out the existing offsite storm sewer to rid the pipe of any residual
site contamination. Prevent site surface drainage from entering this
pipe via plug or similar device.*
Dredging of sediment from approximately 1,200 feet of Sycamore Ditch
with lead concentrations between 30 and 500 mg/kg to be dried, treated
with gypsum, and placed onsite beneath. the clean fill cover material.
Dredging is expected to be conducted during a low water flow period in
the ditch to minimize drying and storage requirements and sedi~ent
migration caused by the dredging operation.
o
Facilities
o
Detailed structural and contaminant evaluation of the onsite buildings,
utilities, and other site facilities during remedial design to determine
the best method to deal with each one: deconta~ination, or demolition
and disposal.
* The extent of contamination and the condition of the pipe may precipitate
-------
- 16 -
o
Either demolition with offsite disposal, or decontamination of the
onsite buildings, utilities, and other site facilities, depending
on the ~esults of the facilities evaluation. (Demolition was assuMed
for costing purposes.)
Battery Casings
o
Disposal of the battery casing chips at a RCRA Subtitle C compliant
1 andfill.
During the FS period, the U.S. EPA evaluated an innovative technology
involving washing and treating the battery casing chips for metallic
lead recovery. The present worth estimate for the treatment system,
including washing 3,800 cubic yards of battery casing chips and dis-
posing of the chips at RCRA-permitted landfill* approximately 125 miles
from the Arcanum site, is $9,442.00. In comparison, the present worth
cost of directly disposing of the battery casing chips in a RCRA COM-
pliant landfill is $1,157,000.
Although the above-described RCRA compliant disposal option meets all
present applicable and relevant federal standards, regulations, and
criteria and is considerably less' costly, the NCP encourages the eval-
uation of innovative treatment technologies as alternatives to the
direct landfilling of hazardous materials. The FS revealed that the
existing treatment technology is not feasible at this particular site.
In addition, treatment of the chips would not provide substantially
greater public health or environmental protection at the AIM site than
direct disposal at a RCRA compliant landfill. Therefore, direct disposal
of the battery casing chips is recommended.
In anticipation of future land disposal restrictions, however, it is
consistent to recommend in this Record of Decision, that in addition
to taking the battery casings offsite to a RCRA Subtitle C compliant
landfill, treatability studies on the battery casings be performed
to determine a way to render the waste nonhazardous before landfilling.
The treatability studies will be performed during the design phase
of this project, and if sufficiently successful, treatment could be
performed before disposing of the wastes offsite. The treated battery
casings will be disposed of at a .RCRA, Subtitle C landfill.
Genera 1
o Attempt deed restrictions to limit future use of the site.
The restrictions would prohibit future development of the land for
residences. Also, the deed restrictions would prohibit the use of
groundwater beneath the site or the installation of wells onsite.
* The nearest RCRA interim status site was used in this cost estimate. The
site would have to be in compliance with RCRA Subtitle C requirements at
-------
- 17 -
STATE ASSURANCES-
Section 104 (c)(3) of CERCLA sets forth the ~tate financial responcibility in
remedial actions provided under CERCLA. The State financial responsibilites in
the proposed remedial action would include payment or assurance of payment of
10% of. the costs of remedial action and assurance of all future maintenance
costs of the remedial action.
The Ohio EPA will send the Region V Regional Administration a letter ~cknowl-
edging the State's financial obligations in this remedial action.
The Operation and Maintenance costs will be covered under a State Superfund Con-
tract between the State and the U.S. EPA at the completion of design of the
five operable unit~.
OPERATION AND MAINTENANCE (0 & M)
The estimated present worth of groundwater monitoring is $378,000. The budget
includes installation of 12 additional monitoring wells downgradient of the
site and the costs associated with mobilizing a crew for 5 days every 0 months
for a 30 year period to collect samples. The samples would include nearby
residential wells. Analytical costs are included in the estimate. Annual O&M
is estimated at $37,000. The U.S. EPA is responsible for 90% of the cost for
the first year of O&H and the Ohio EPA is responsible for the remaining 10%.
Subsequent years are solely the responsibility of the Ohio EPA.
SCHEDULE
Complete Enforcement Negotiations
August, 1986
Approve Remedial Action (sign ROD)
September 16, 1986
October 1, 1986
Start Remedial Design
Complete Remedial Design
October 1, 1987
Invitation for Bid
August 2, 1987
State Superfund Contract
November 2, 1987
Start Construction
November 2, 1987
Complete Construction
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FUTURE ACTJVITIES
In anticipatiQn of future land disposal restrictions on solid hazardous wastes,
the U.S. EPA recommends performing treatability studies on the battery casings
with the goal being to render them non-hazardous. The costs i~curred for doing
treataDi1ity studies during the design phase will be a very small portion of
the overall Remedial Design budget. If the studies indicate that treatment can
render the battery casings non-hazardous, they may be eligible for disposal in
a less costly land disposal faci1ity~
Continue monitoring of groundwater via monitoring and residential wells. This
program may indic~te the future need for an extraction and treatment system or
reevaluation of the decision to leave some contaminated soils onsite. There-
fore, the site will not be deleted from the NPL so that the U.S. EPA retains
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APPENnrx A
Responsiveness Summary
Arcanum Iron & Met~l site
September 1986
I. OVERVIEH
I)uring the public cOlT11T1ent perior!~ the I/.S. EPA recolTtmended a combined alternative
to deal with five components of the site: soils. groundwater. surface water. $ite
facilities. and battery casings. The residents were mainly concerner! with when
something would be done at the site and the perceived inability of th~ governlTtent
to make the responsible party pay for' the clean up. A farming couple livit'g
adjacent to the site expresseri specific concerns about technical aspects of the
chosen ref'1edy. They.' and a few people at the public lTteeting. expressed concern
about health effects of being exposed to lead. No cOl11f'l1ents were received frofTl
potentially responsible parties or local officials.
II. RACKf1ROUNI1 ON COM~'J~ITY INVOLVEf1ENT ANn CONCERNS
According to the COlTtmunity qelations Plan. cOlTtmunity interest in the site was
expressed in the late 1970s when Ohio EPA investigated the site. nue to residents'
concerns about their drinking'water wells. OEPA sampled a well near the site. When
the site was proposed for the NPL in 1982. there was press coverage.
At U.S. EPA and Ohio EPA's RIfFS kickoff meeting in July 19R4. residents expresser!
concern about the length of time between inclusion on the NPL and the start of the
RIfFS, enforcement against PRPs. battery casings remaining on site. and effect of
soil contamination on nearby agricultural fields.
Agency Response: EPA staff described at the meeting the Superfunrl
process. including time frames and Agency enforcement procedures.
Soils frof'1 adjacent farlTt property was sampled and evaluated during
the RI. The battery casings were evaluated during the FS.
\.Jhen the RI report was published in Fall 1985. a Darke County COlTtlTtissioner brought
to Ohio EPAls attention that the report didn't include the years AII1 operated at
the site of the current ArcanulTt Fire StatioPi. Subsequent Ohio EPA and U.S. EPA
investigation and sampling led to excavation and removal of lead contaminanterl soil
from portions of one city block. including several residential yards. The work was
conducted by the AIM site owner. under a consent order issued by 1/.5. EPA Region 5.
The end of the ~I coincided with the first slowrlown experienced when Superfund
expired in Fall 1985. The Region explainer! to local officials and the media that
the AIM site would be targeted for slowrlown at the end of the Feasibility Sturly.
Since then. officials and reporters have checked periodically on the status of the
law's reauthorization.
Overall. few concerns were expressed during the RIfFS. Community relations activi-
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I I I. SIH1~1ARY OF PIJBL IC
COMMENTS RECEIVE!) nURING PUBLIC COMt1ENT PERIOn AND
AGENCY RESPONSES
Comments Made during the AH1 site's publ ic comfTIent period are summarized briefly
below. The comme_nt period was held from July 18-August 11, 1986. Three persons
offered verbal comments at the public meeting; one submitted a list of questions;
one comment 1 etter was recei ved. 411 comments were from residents; nei ther local
officials nor PRPs submitted comments.
Remedial Alternative Preferences
1. Several commenters stated that they want the site cleaned up, without specify-
ing a preference. for an alternative. One cOlTIITIenter asked that EPA choose a
refTIedy that is appropri ate to the 1 evel of threat, that the Agency not spend
more money than is necessary.
Agency response: EPA belives that the alternative chosen will address all
areas of concern (on- and off-site soil, surface water, groundwater, on-site
facilities and battery casings), and thus cleanup the site and protect public
health and the environment. EPA also believes the cleanup chosen is the fTlost
cost effective availahle.
2. The adjacent farfTIing family had several specific comments about portions of
t he remedy.
Soil. The. couple requested that no soil be refTIoved from their property because
they feel any repl acement soil would not be of the same qual ity for farming.
Agency response: The chosen cleanup would remove all offsite soils contaminatfd
with lead above the background level of 30 parts per million (ppm), and replace
it with clean topsoil. In order to know more precisely where the offsite co".-
taMinated areas are, additional safTIples will be taken during the design phase
of the project. It fTlay be that most of the offsite contaminated soils are
located in an unfarmed area west of the access road that leads to to titre
adjacent farm. If the sampl ing indicates that the lead contamination extenrl,s
into the adjacent farm, EPA would strongly recommend removing soil around Ue
house, at least. The federal Centers for Disease Control have indicated thit
elevated lead blood levels in children may result if soils contain betwe.en
500-1000 ppm in residential settings. The Agency is cleaning to backgrou1!1d
levels to provide a conservative margin of safety, and to prevent further
movement of the lead in the soil into the groundwater.
Storm Sewpr Removal and Repl acement. The farmer requested that the exi stimg
storm sewer not be removed because it I S used to drain the farm and because
resulting soil compaction would disrupt the growing conditions of the soil.
Agency response: The storm sewer needs to be repl aced with a 1 arger pi pe 10
handle run-off froM the site during heavy rain. EPA can accomplish this iDy
.putting a new sewer on the northern boundary of the farm, as requester:lnn
the comment.
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EPA will plug the existing sewer where run-off fro~ the site enters the pipe,
leaving the rest of the existing sewer available for the farm. (EPA will at-
tempt to c1ean oot any resiciual conta~inants in the pipe.) -In adciition, EPA
wi 11 instruct its contractors to conduct the work when it is conveni ent to the
farm (non far~ing months), and to preserve the topsoil and redistribute it on
the field as close to its original condition as possible.
nrinkinf Water_. The far~ing couple asked that the far~'s drinking water well
be samp ect twice a year because of proximity to the site. They al so said that
thei r well had not been sa"1pl ed for at 1 east a year -and a half, although they
had been tolrl it woulci be sa~pled twice-yearly.
Agency response: EPA will include the farm's well in its se~i-annual (twice-
yearly) sa~pl ing, which will be used' as an early warning of possible ground-
water conta~ination migration. r1onitoring wells and other residential wells
will be included as well. This monitoring will continue for 30 years, as part
of operation and ~aintanence at the site.
3. The adjacent farming family asked that Pop Rite Lane be restored to its original
condition after clean up.
Agency response: EPA will require its contractors to ~aintain the Lane cturing
cleanup, and to restore the Lane to its original condition when the cleanup
is co~pleted.
Health Effects
1. A CO~"1enter asked what health ri sks woul rl he i nvol ved duri ng the cl eanup,
and what information is available on health risks from being exposed to the
lead smelter exhaust when the site operaterl.
Agency response: Ouring the cleanup, there is a potential for lead dus.t gett-
ing into the air. Refore the cleanup can begin, the contractors will have to
sub~it to EPA a health and safety plan to mini~ize any threat to cleanup
workers or to adjacent neighbors.
EPA contacted the federal Agency for Toxic Substances and Oisease Registry
regarding possil:>le health problems from the' s~elter. ATSnR said that the only
way to know for sure whether an indivic1ual is suffering fro~ previous exposure
to the smelter is to get a blood test for lead poisoning. This test is avail-
a~l e through the f1arke County Department of Health.
Enforce~ent Action
1. One co~menter questioned whether AIM's operations met existing rules.
Ag,ency response: The owner and operator of Arcanu"1 Iron and Metal viol atec1
provisions of the Clean ~Jater Act hy du~ping hattery acid onsite and letting
it flow to Sycamore nitch. Ohio EPA signed a consent order with the owner to
have hi~ install a treat~ent system to neutralize the acid. The owner tried
to install the syste"1, but it never operated properly. Rather than fulfill
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2. Several commenters askerl whether the site owners are responsible for cleanup
and when the Age.ncy would negotiate with the potentially res~onsible parties.
Several commenters expressed frustration that those responsible for the conta~-
ination are IIgetting away with it.1I
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Agency response: The Superfund law includes past and current site owners as
parties liable for cleanup. Also inclurled are site operators, generators of'
waste ~hat went to the site, and transporters of waste to the site.
The Superfund law has provisions for responsible parties to perform the neces-
sary studies, cleanup and maintenance at a site, under EPA oversight. When a
responsible party chooses not to, or cannot, undertake any of the. necessary
activites at a site, EPA undertakes.the activities and reserves the right to
recover costs at a later date. In July 1984, EPA notified potentially respon-
sible parties that they could conduct the remedial investigation/feasibility
study under EPA Qversight. The parties chose not to. In July 1986, the Agency
gave the parties the opportunity to conduct the cleanup proposed in the Feasi-
bility Study. However, the Agency determined during negotiations that the
parties could not conduct the cleanup adequately. Therefore, EPA will perfor~
the work and attempt to recover costs later. The cost includes everything EPA
will have spent on the investigation, the cleanup and long term ~aintenance.
The site owner did pay for the cleanup of the Arcanum 2 site (fire station
area) in early 1986.
3. One commenter specifically requested that taxpayer money not be used for the
cleanup unless absolutely necessary.
Agency response: Response #2 expl ai ns why EPA wi 11 pay for the cl eanup up
front. To cl arify, the taxpayers have contri buted di rectly only 13% of the
Superfund. As the law now stanris, the majority of the funrl co~es from a tax
on industries using certain feed stock che~icals. (Although the taxpayer may
pay indirectly through the cost of products made out of these chemicals.)
Congress ~ay change this funriing structure when it reauthorizes the law.
Other Co~~ents
1. A few co~menters askerl how they could contact their Congress~an or otherwise
influence the reauthorization of Superfund.
Agency response: The AIM site is within the 8th Congressional nistrict, repre-
sented by Thomas Kindness, 646 High St., Hamilton OH 45013.
2. Commenters had questions regarding past and future ti~ing. What led to the
initial investigation of the site? Why hasn't EPA taken action before now?
When can cleanup begin?
Agency response: The first examination of the site was in 1904 when fish died
in, Painter Creek. OEPA took action to correct operational problems in the
late 1970s (see earlier response). U.S. EPA began its involvement with the
site when it w~~s listed in Oecember 1982 on the National Priorities List of
hazardous"waste.',s,ite eligible fo.r investigation and cleanup. It took from July
1984 to JU,ly 1986 to investigate'the site and evaluate cleanup alternatives.
It typi:<:,-~JJy ta;k-es ,one and one- h.alf:to two years to learn enough about a site
to ch.oa~~~$_c;T,~\~p that w;l~ '.~2;.~~telY protect health and the envi ron!T1ent.
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The Agency is ready to begin the engineering designs for the cleanup. The rle-
sign work is exp~ted to take about a year; the construction ~hase is expected
to take another one to two years. Past experi ence at other Superfund si tes
shows that this is a typical schedule. '~ork on the design and construction
cannot begin until Superfu~d is reauthorized or other funds become available.
IV. REMAININ~ CONCERNS
At the publ ic meeting, several people questioned whether the ArcanulT1 2 site could
have contaminated wells or groundwater beneath the fire station, or whethe~ con-
tamination from theAP1 site could have spreart downtown. One commente-r offered
her well for sampling, another commenter suggested that EPA M"iY want to use a
well SOlltf) of town for monitorif1g. .
Agency response: EPA.does not helieve contamination from the site has spread to
the downtown area. EPA will be installing monitoring wells ilT1TT1ediately offsite
to detect as soon as possible contaminants that may migrate. For tl1is reason. a
well south of town would not be suitable for an early warning well. EPA does not
bel ieve the ArcanuM 2 site will have affected the city's water, as the city's
water supply is not downgradient of the site. There are few private wells in town.
However, Ohio EPA dirt sample the commenter's well for leart. The results are
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-Community Relations Activities Conducted
at Arcanum Iron ~ Metal Site
June 1q83
Community interviews conducted for
Community Relations Assessment
Community Relations Plan finalized
June 1984
July 1984
* Press rp.1ease issued to announce
public meeting & start of RI/FS
Public meeting held to describe the
Superfund process and the RI/FS plans
for the AIM site
September 1985
Information repository estahlished at
Arcanum Public Library
Telephone calls made and letters sent to
residents regarding well water results
IJpdate mailed announcing availahility of
R I report, anrl summari zi ng results. IJpdate
included "Superfund Contingency Plan Sitr
List" fact sheet from headquarters. (The
AIr1 site was targeted for slowdown.)
necember 1985-
January 1q86
Fact sheet distributed, meetings held and
phone contact maintained with residents,
local officials and reporters regarding
emergency cleanup of the Arcanum 2 site.
April 1986
Letter sent to residents confirming earlier
drinking water results.
July 1986
Press release and fact sheet issued to
announce availability of FS, start of
public comment period, and describing
the recommended alternatives.
PUh1ic meeting held to describe RI/FS
findings and to take comments.
August 1986
- _..-.Publ i-c comment period concl uded.
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* Press releases, -i.J~(rif~_s ar.fd~fact she_ets::.;w'~,r-e_..d__\$tributp.d to local officials,
-media, and residentS:;,:pn th..~T:~site matling-"U.~:~,~~ntact was maintained ...lith
- :locaJ.~off;c;als t11'~."":' Q1! ~--,he RI/FS. nh\Q.>E:P~;;j:@'rticipated in the public
;'riie.ea~s. -~i:.:. ~_:,£~ -: ";~\~.?~i"1~'- --.
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