United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-92/2U
September 1992
PB93-964121
dEPA Superfund
Record of Decision;
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NOTICE
The appendlceilisted In the index that 118 not founct in"thls document have been removed .t the request of "
the issuing agency. They contain material which supplement. but adds no ful1her ~ information to
the content of the document. Allaupptementai material ii, however, con1Bined in the adninialrattve record
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50272 101
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REPORT DOCUMENT~ TlON 11. REPORT NO. I ~ a. A8c:IpI8nI'..~ No.
PAGE EPA/ROD/R05-92/214
4. 1118... IubII8 I. Report D8I8
SUPERFUND RECORD OF DECISION 09/30/92
A1sco Anaconda, OH I.
Second Remedial Action - Final
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U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 14.
15. ... I f' ......., No...
PB93-964121
11. Ab8trKt (LImIt: Il1O WOId8)
The 4.8-acre Alsco Anaconda site is located in Gnadenhutten, Tuscarawas County, Ohio,
within the 50- and 100-year floodplains of the Tuscarawas River. It consists of four
source areas which contained F019 waste (waste water treatment sludge) generated by
the adjacent aluminum products manufacturing facility. Land use in the general area
of the site is mixed industrial, recreational, residential. Several municipal,
industrial, and residential wells are located within a 1.5 mile radius of the site:
however, contaminated site ground water flows towards and into the Tuscarawas River
where it discharges at concentrations below any regulatory levels. Site ground water
is not used as drinking water. Aluminum products have been produced at a neighboring
manufacturing facility since 1945 when it was incorporated as Alsco, Inc. From 1965
through 1978, contamination at the Alsco Anaconda site occurred when waste water and
waste water treatment sludge (FOl9) from the aluminum plant were disposed of in an
unlined settling basin (which consisted of tow impoundments) and a sludge pit. The
F019 waste contained hazardous constituents such as cyanide and chromium. As a result
of overflow form the settling basin and plant waste water treatment discharge, sludge
(See Attached Page)
17. Docum8nl Analpl8 L D88cr\pIot8
Record of Decision - Alsco Anaconda, OH
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: Organics, metals (chromium, lead)
b. Idenliflet8lOpen-End8cI T8m18
c. COSA 11 ReIcIIGroup
18. Av8l18b1Mty Sl8lemenl 11. Security Cia.. (Thia Report) 21. No. 01 Pagea
None 62
20. SecurIty Cia.. (Thi8 Page) 22. Price
Nnnp
272 (4.77)
(See ANSl-Z3I.18)
See Inattucllona on Reveraa
(Formerly NTIS-35)
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EPA/ROD/R05-92/214
Alsco Anaconda, 08
Second Remedial Action - Final
Abstract (Continued)
also became located in a wooded area between the settling basin and the river. The total
volume of sludge and contaminated soil excavated from the source areas to date is
approximately 45,000 tons. A 1989 ROD addressed the Source Material Operable Unit, which
involved the excavation and offsite treatment and disposal of the contaminated sludge and
soil, incineration of a small amount of material containing high levels of PCBs, and
backfilling and revegetating excavated areas of the site. Most of this work has been
completed during. 1992. This ROD addressed the contaminated ground water which
constitutes the second operable unit at the site. The primary contaminants of concern
affecting the ground water include organics such as cyanide, fluoride, and bis
(2-ethylhexyl) phthalate; and metals including, chromium, and lead.
The selected remedial action for this site includes natural flushing and attenuation of
contaminants from the contaminated aquifer, and allowing ground water to discharge onsite
to the Tuscarawas River; installing onsite ground water monitoring wells; installing and
sampling background wells; sampling Tuscarawas River sediment and benthic organisms; and
implementing institutional controls including deed restrictions to prevent installation
of drinking water wells onsite until remedial action levels for ground water have been
achieved. The estimated present worth cost for this remedial action is $504,600, which
includes a present worth O&M cost of $455,400.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up levels which are
SDWA MCLs or proposed MCLs include the following: chromium 0.1 mg/1; cyanide 0.2 mg/l;
fluoride 4.0 mg/l; and bis (2-ethylhexyl) phthalate 0.004 mg/l. Lead is to reach an
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RECORD OF DECISION
SITE NAME AND LOCATION
ALSCO ANACONDA SITE
GNADENHUTTEN, OHIO
--
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the second operable unit at the Alsco Anaconda Site in
Gnadenhutten, Ohio, chosen in accordance with the Comprehensive
Environmental Response, compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent
practicable, the National oil and Hazardous Substances
Pollution contingency Plan (NCP). This decision is based on
the administrative record for this Site. "The attached index
(see Appendix B) identifies the items which comprise the
administrative record upon which the selection of the remedial
action is " based.
The State of ohio has been consulted and concurs.with the
selected remedial action.
ASSESSMENT OF THE SITE"
Actual or threatened releases of hazardous substances from
Site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health,
welfare, or the environment.
this
DESCRIPTION OF SELECTED REMEDY
This operable unit is the second of two that are planned for
this site. The first operable unit was a source control
operable unit. The second operable unit involves contaminated
ground water and sediments at the Site. The major components
of the selected remedial action for the ground water operable
unit (GWOU) of the Alsco Anaconda Site include:
* Natural flushing and attenuation of contaminants in the
aquifer allowing ground water to discharge to the Tuscarawas
River.
* Sampling and laboratory analysis of the ground water from
monitoring wells.
* Installation of background wells, and sampling of those
wells.
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* Institutional controls, including deed restrictions, that
prevent installation of drinking water wells within the site
boundaries until remedial action levels ,for ground water have
been achieved.
* sampling of Tuscarawas River sediments and benthic
organisms.
USE OF NATURAL FLUSHING AND ATTENUATION/GROUND WATER AND
TUSCARAWAS RIVER SEDIMENT MONITORING IN LIEU OF TREATMENT
The united States Environmental Protection Agency (U.S. EPA) ,
has determined that by monitoring the ground water, and
restricting its use until the levels of contaminants in the
water are below maximum contaminant levels (MCLs), background
levels, and/or other health-based standards, cancer risks and
other risks to human health associated with contacting the
ground water can be minimized. .
Natural attenuation is a viable remedy for contamination found
at the Site, since the sludge and contaminated soils, which
contributed contaminants to the ground water and river
sediments, are being removed during the Source Material
Operable Unit (SMOU) remedial action, which is nearing
completion. The ground water and sediment contamination will
be monitored and evaluated to assure that the_contamination
diminishes over time.-
The U.S. EPA uses an acceptable excess cancer risk range of one
in ten thousand to one in one million, with one in one million
being the preferred point of departure for potential
carcinogens. The U.S. EPA has determined that the excess risk
posed by site ground water for combined residential and
recreational use at this Site, prior to implementation of any
remedy, is six in ten thousand for an adult. This level
exceeds the acceptable risk range. However, the U.S. EPA and
the Ohio Environmental Protection Agency (OEPA) believe that
natural attenuation of the ground water will reduce the risk to
an acceptable level over time; restriction of ground water use
until cleanup levels are met will be protective of human health
and the environment. If, based upon monitoring results over
time, the u.S. EPA and OEPA determine that the cleanup levels
are not achievable, then the site remedy will be revisited and
other remedial actions evaluated.
STATUTORY DETERMINATIONS
Consistent with CERCLA and, to the extent practicable, the NCP,
40 C.F.R. Part 300, the selected remedial action is protective
of human health and the environment, complies with Federal and
State requirements that are legally applicable or relevant and
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remedy utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. The remedy fails to satisfy the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element because
treatment of the ground water was not found to be practicable.
Because this remedy will result in hazardous substances
remaining on-site above health-based levels, a review will be
conducted within five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
-,
/' .
b~tcll! IllA;~;!-
. Va ldas V. Adamkus
~~ Regional Administrator
{- u.s. EPA Region V
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StJllMARY OF RBKBDIAL ALTBRBATXVE SELECTION
ALSCO ANACONDA SITE
GIfADBIuIU1"'.rBlf, OHIO
.....*...*
TABLE 01' COIfTBlfTS
I. SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . .. . . .-. . . . . . . . .1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . . .2
III. COMMUNITY RELATIONS HISTORY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5
IV.
SCOPE AND ROLE OF REMEDIAL ACTIVITIES. . . . . ... . . . . . . . . . . . . . .6
V. SUMMARY OF SITE CHARACTERISTICS. . . . .. . . . . . . . . . . . . . . . . . . . . .7
VI. SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . 9
VII. DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
VIII. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES......1S
IX. THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25
.
X. STATUTORY DETERMINATIONS StJllMARY. . . . . . . . . . . . . . . . . . ... . . . . .27
XI. DOCUMENTATION OF SIGNIFICANT CBANGES....~................29
Appendix A--Responsiveness summary
Appendix B--Administrative Record Index
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SUMMARY
OF REMEDIAL ALTERNATIVE SELECTION
ALSCO ANACONDA SITE
GROUND WATER OPERABLE UNIT
GNADENHUTTEN, OHIO
1.
SITE NAME. LOCATION. AND DESCRIPTION
The 4.8 acre Alsco Anaconda National Priorities List (NPL) Site
is located approximately 49 miles south of Akron, Ohio within
the Gnadenhutten village limits. Gnadenhutten, a community of .
about 1,320 residents, is located within Clay Township in
Tuscarawas County. The Alsco Anaconda site is bounded by the
Penn-Central Railroad right-of-way, the Amerimark manufacturing
building and parking lot, Anaconda Drive (County Road 39), and
the Tuscarawas River on the northwest, northeast, southeast,
and southwest, respectively (see Figures 1 and 2). Most of the
site is located within the floodplain of the Tusca~awas River.
The Site contained four source areas, including the northern
and southern impoundments (also known as the settling basin),
the sludge pit, and the wooded area located between the
impoundments and the river (see Figure 2). The contaminated
sludges and soils from these areas are being removed during the
remedial action undertaken in 1992. The only structures
located within the site boundaries are fences and, permitted
wastewater outfalls for the adjacent manufacturing facility.
The site is topographically higher on the eastern side
Amerimark plant. Here, the site consists of fill that
placed to provide a flat driveway for the plant. West
former source areas, the land surface slopes gently to
of the Tuscarawas River.
near the
was
of the
the bank
The Amerimark plant occupies the 19 acres of land adjacent to
the site. The nearest residences are located across Anaconda
Drive and Walnut street from the Amerimark facility.
Land and water resources in the general area are used by both
individuals and local industries. Natural resource development
activities in the area include farming, mining of coal, clay,
sand and gravel, and drilling of oil and gas wells. The
Tuscarawas River is used for recreational purposes as well as
for industrial and agricultural water supplies.
Subsurface materials in the Tuscarawas River valley consist of
unconsolidated fluvial silt and sand deposits, along with
glacial outwash sands, silts, and gravels. This valley fill
overlies relatively flat-lying sedimentary bedrock, mostly
shale and sandstone with minor "beds of limestone and coal,
generally occurring greater than 160 feet below the Site
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bedrock formations of shale, limestone, and coal are mined
locally as economic resources. Within a tWQ mile radius of the
Site, there are several sand and gravel pits in the valley,
with clay and coal strip mines in the valley sides.
The unconsolidated alluvial valley deposits form extensive
aquifers which are the principal water supplies for
municipalities in the valley. Ground water flow in the valley
is generally southwestward. The Gnadenhutten municipal well
field is located approximately 4,000 feet northeast'
(upgradient) of the Alsco Anaconda site. Several wells,
including municipal, residential, and plant wells are located
within a 1.5 mile radius of the site (see Figure 3).
contamination at the site was found in the form of sludge in
the source areas, in the soils beneath the sludges, in ground
water, and in sediments. The soil and sludges are being
addressed under the first operable unit. The contaminants
found in the ground water include antimony, beryllium, total
chromium, cyanide, fluoride, lead, and bis (2-ethylhexyl)
phthalate at levels above the maximum contaminant levels (MCLs)
established under the Safe Drinking Water Act (SDWA). However,
no one is currently drinking this water. The sediments of the
Tuscarawas River in the vicinity of the Site contain elevated
levels of chromium. Polychlorinated biphenyls (PCBs) were
found in 2 of 41 sediment samples. --.. .-.,
II. SITE HISTORY AND ENFORCEMENT ACTIVITY
The Alsco plant was established by Harry (Red) Sugar in 1940.
The facility has manufactured aluminum products since 1945 when
it was incorporated as Alsco, Inc; In 1969 Alsco, Inc. merged
with Harvard Industries. The plant was then acquired by the
Anaconda Company in August 1971. The Anaconda Company was
acquired by the ARCO Chemical Company, a division of the
Atlantic Richfield Company (ARCO), in January 1977. In
December of 1986, ARCO sold the plant to Horsehead Industries;
however, ARCO retained ownership of a 4.8 acre portion of the
property, most of which was used for sludge disposal. This
4.8-acre area constitutes the Alsco Anaconda NPL site.
Prior to 1965, neutralized process wastewater was discharged
directly to the Tuscarawas River. A settling basin was
completed in 1965 at the request of the state of Ohio
Department of Health. During the period from 1965 to 1978, the
unlined settling basin and sludge pit were used for disposal of
wastewater and wastewater treatment sludge. This sludge is a
process waste which is included in the Resource Conservation
and Recovery Act (RCRA) list of hazardous wastes. The sludge
is listed under the waste code "F019" because wastewater
treatment sludges from the chemical conversion coating of
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overflow from the settling basin "and plant wastewater
discharge, sludge is also located in the wooded area (formerly
known as the "swamp" area) adjacent to the settling basin. The
total volume of sludge and soil at the site was originally
estimated in the 1989 Record of Decision (ROD) for the source
material operable unit (SMOU) to be approximately 8,850 tons.
The current estimate is that 33,000 tons of material, including
debris, will require removal. .
since 1978, no solid wastes have been placed in the settlement
basin or sludge pit; wastewater treatment sludges have been
mechanically dewatered at the plant and shipped to an off-site
facility for disposal. However, the treated wastewater
discharge route included the impoundments until October 1980,
when the effluent discharge was rerouted around .the
impoundments to the wooded area, which drained to the river.
In October 1986, the outflow from the wastewater treatment
plant was rerouted away from the wooded area directly to a
permitted outfall at the river. No standing water was present
in the wooded area within one month of the diversion of the
outfall. The treated process wastewater has been discharged to
the Tuscarawas River through a National Pollutant Discharge
Elimination System (NPDES) permitted outfall since 1976.
Based on reports filed by ARCO, the United states Environmental
Protection Agency (U.S. EPA) conducted a preliminary assessment
of the site in 1983. Because of a concern that water resources
might become contaminated from sludge leachate, the Site was
proposed for inclusion on the NPL in October 1984. The Site
was formally placed on the NPL in June 1986.
In November of 1984, ARCO retained International Technologies
Corporation (IT) to perform a Remedial Investigation/
Feasibility Study (RI/FS). In March 1985, RI activities began
at the site. An Administrative Order by Consent was issued in
January 1987 among U.s. EPA, the Ohio Environmental Protection
Agency (OEPA), and ARCO for conducting the RI/FS.
The RI was conducted at the Site from March 1985 through
January 1989. During the study, samples of sludge, underlying
soil, ground water, and Tuscarawas River sediments were
collected at and near the site. An investigation was also
conducted to determine if drums containing waste were buried at
the Site. sections of the draft RI pertaining to ground water
and sediments were not approved by U.s. EPA and OEPA.
Consequently, u.s. EPA split the Site into the SMOU and the
ground water operable unit (GWOU), and requested that a
separate focused FS be completed for the SMOU, as enough
information was available to study cleanup alternatives for the
contaminated sludge and soil at the site. A Focused FS (FFS)
developed for the SMOU, presenting an array of alternatives to
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address the contaminated sludge and soil, was completed in June
1989~ The ROD for the SMOU was signed on september 9, 1989.
In a letter dated June 14, 1989, U.S. EPA requested that ARCO
submit a supplemental RI work plan for the additional
investigations to complete the RIfFS for the GWOU. The primary
goals of the supplemental RI were to evaluate the nature and
extent of affected ground water, to prepare a Baseline Risk
Assessment for the GWOU, and to evaluate potential remedial
alternatives. The work plan and related planning documents
were finalized on January 31, 1991. The supplemental RI was
conducted by ARCO's consultant, ERM-Southwest, between April
and July of 1991. The supplemental RI report was completed in
January 1992. The Baseline Risk Assessment was approved in
June 1992. The FFS and the Proposed Plan for the GWOU were,
completed and made available to the public on August 19, 1992.
The supplemental RI work was performed by ARCO under the
existing Administrative Order on Consent.
Pursuant to its authority under Section 122(e) of the
Comprehensive Environmental Response, compensation, and
Liability Act (CERCLA), U.S. EPA sent. a special notice letter
to ARCO on June 26, 1989, notifying the company of its
potential liability for CERCLA response costs and
responsibility for conducting the design and implementation of
the U.S. EPA's p.ferred alternative for the Alseo.Anaconda
Site. As a result' of this notice letter, ARCO informed u.s.
EPA that Harvard:~t~dustries might also be a potentially
responsible party.,!,(PRP) as a former owner and operator.
Pursuant to its Ci~thority under Section 122(e) (2) (C) of CERCLA,
u.S. EPA notified Harvard Industries of its potential liability
as an additional PRP and invited Harvard to enter into
negotiations with u.S. EPA and ARCO.
Negotiations wit~oth companies were unsuccessful, and on
December 28, 1989~-U.S. EPA issued Unilateral Administrative
Orders to both ARCO and Harvard Industries for the design and
implementation of the remedy for the SMOU. ARCO has written
the required site documents, and is conducting the remedial
action. Harvard has filed a complaint against ARCO to compel
binding arbitration to determine allocation of financial
responsibility. Harvard has not conducted any site remedial
work to date. On April 11, 1991, a petition for involuntary
bankruptcy reorganization of Harvard under Chapter 11 was filed
in u.S. Bankruptcy Court. On May 2,1991, Harvard filed a
petition for voluntary reorganization.
The u.S. EPA is the lead agency responsible for managing the
investigation of the Alsco Anaconda site being conducted by
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III. COMMUNITY RELATIONS HISTORY
The u.s. EPA conducted community relations activities
throughout theRI/FFS for the SMOU to provide interested
citizens and officials information about progress at the Site.
The U.S. EPA distributed a summary fact sheet providing
background information on the Alsco Anaconda Site and the
Administrative Order among U.S. EPA, OEPA, and ARCO in February
1987. A public comment period for the order was held February
4, 1987 through March 5, 1987.
Summary fact sheets describing the results of the RI were
distributed in May 1989. A fact sheet about the FFS and
'Proposed Plan was released in June 1989. The RI and FFS
reports and Proposed Plan for theSMOU were released to the
public in June 1989. These documents were made available to
the public for' review and copying in the administrative record
maintained at the U.S. EPA offices in Region V and in the
information repository at the Gnadenhutten Public Library.
Consistent with Section 113 of CERCLA, the administrative
record includes all documents such as work plans, data
analyses, public comments, transcripts, and other relevant
information used in developing remedial alternatives for the
Site. . .
The notice of availability of Site-related documents, which
also announced the public comment period and public meeting,
was published in the Dover-New Philadelphia Times-Reporter on
June 26, 1989 and July 7, 1989. A public comment period was
held from June 26, 1989 to July 25, 1989. A public meeting was
held in Gnadenhutten on July 11, 1989. At this meeting,
representatives from the U.S. EPA and OEPA answered questions
about problems at the Site and the remedial alternatives under
consideration. A response to the comments received during the
comment period was included in the Responsiveness Summary,
which was Appendix A of the SMOU ROD.
Fact sheets updating the community and interested persons on
progress at the site were sent out in June of 1991 and April of
1992. The April fact sheet discussed the results of the
supplemental RI for the GWOU.
Following completion of the RI/FFS for the GWOU, the U.S. EPA
published a Proposed Plan for remedial action on August 19,
1992. A fact sheet about the FFS and the Proposed Plan was
also published and mailed to interested parties at that time.
The notice of availability of site-related documents, which
also announced the public comment period and public meeting,
was published in the Dover-New Philadelphia Times-Reporter on
August 19, 1992. The RI/FFS Report, Proposed Plan for remedial
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administrative record have been placed in the information
repository.
To encourage public participation in the remedy selection
process consistent with section 117 of CERCLA, the u.s. EPA set
a 30-day public comment period from August 19, 1992, through
September 19, 1992, for the Proposed Plan. A formal public
hearing was held on September 9, 1992, in Gnadenhutten, Ohio to
accept verbal public comments on the Proposed Plan. Interested
parties were given the opportunity to provide comments on the
alternatives presented in the Proposed Plan and elaborated upon
in the FFS. No verbal comments on the proposed remedy were
made during the public hearing; no written comments on the
remedy for the GWOU of the Alsco Anaconda site were received
during the public comment period. ARCO raised a few concerns
about the remedy informally during monthly project meetings,
and submitted the comments in writing after the public comment
period had ended. The attached Responsiveness Summary (see
Appendix A) addresses those concerns.
The remedy for the GWOU was chosen in accordance with CERCLA,
as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA), and, to the extent practicable, the National
oil and Hazardous Substances Pollution contingency Plan (NCP).
The decision for this site is based on the administrative
record. An index of the administrative record is attached as
Appendix B.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
This ROD addresses the second of two planned activities at the
Site. In accordance with 40 CFR 300.68 (c), the remedial
action has been divided into two "operable units", or
components of work: contamination caused by the source
material (SMOU) and contamination of the ground water and
sediments (GWOU). This ROD addresses the contaminated ground
water and sediments at the site.
A Proposed Plan and ROD for the SMOU were completed in 1989.
The response action called for under the SMOU ROD is currently
underway; the removal of the source materials will remove the
principal direct. contact threat to humans and is expected to
stop the future release of contaminants to the ground water and
sediments.
The second operable unit deals with the existing contamination
of ground water and sediments, and considers possible remedies
for addressing these media. The threats associated with
contaminated ground water include the possibility of human
consumption of the water if the site were ever to be developed
residentially. The threats associated with contaminated
sediments include reduction in species diversity of benthic
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organisms (organisms which live in sediments), and transmittal
of contaminants up the food chain. The role of the response
action for this operable unit is to reduce the risk to human
health and the environment posed by the Site. The second
operable unit will be the final response .action for this Site.
v.
SUMMARY OF SITE CHARACTERISTICS
The original RI was conducted from March 1985 through January
1989. Analyses for the u.S. EPA Hazardous Substance List
compounds were conducted in all environmental media. The.
sludge, underlying soil, and ground water on-site were sampled.
Sample results indicated that there were PCBs in the wooded
area sludge, and arsenic in the settling basin sludge, at
levels of public health concern for direct contact exposure.
Subsequent work led to the establishment of cleanup levels for
14 indicator compounds to ensure a thorough cleanup of the SMOU
to levels suitable for future residential development. These
compounds included: arsenic, barium, cadmium, chromium +3,
chromium +6, copper, cyanide, fluoride, lead, manganese, .
.mercury, PCBs, silver, and zinc. These contaminants are being
removed under the SMOU remedial action to health-based or
background levels, or to levels found in u.S. EPA guidance
documents; the levels were determined to be protective of
ground water as well.' The compounds were selected as indicator
compounds based on the following factors: presence of the
compound in soil, toxicity, concentration, solubility
(potential mobility in ground water), prevalence, persistence,
availability of chemical-specific agency risk assessment data,
and a concentration-toxicity screening procedure. .
Unconsolidated sand and gravel deposits underlie the Site,
comprising an aquifer that is the primary source of both public
and private drinking water in the area. However, there are no
drinking water wells between the site and the Tuscarawas River,
which the site ground water flows into. Under a theoretical
ground water drinking use scenario, sample results from the
original RI indicated that chromium, cyanide, fluoride,
nitrate, selenium, and tetrachloroethylene in the upper forty
feet of the aquifer were at levels of public health concern.
The results were judged to be unreliable due to excessive
screen lengths in the monitoring wells. At the end of the
original RI, the extent of ground water contamination remained
unclear. Therefore, a supplemental RI was conducted in order
to better determine the horizontal and vertical extent of
contaminated ground water, the discharge points of the water,
and the actual routes by which exposure to the ground water
might occur. The supplemental RI was completed in January
1992. Wells with discrete screen lengths were installed and
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impact to the biota inhabiting the Tuscarawas River sediments
was also gathered.
The supplementalRI report made the. following conclusions about
the ground water and sediment contamination at the Alsco
Anaconda site:
--The horizontal extent of the ground water which has
contamination levels above MCLs under the SDWA appears to be
limited primarily to the perimeter. of the northern and southern
impoundments and the sludge pit. Some ground water
contamination was found in areas which appeared to be
upgradient, but where additional sludge was found during the
SMOU remedial action. The affected ground water appears to be
. restricted to the upper 15-20 feet of the sand. and gravel
aquifer. The only contaminant found above an MCL in either the
intermediate or deep wells was bis (2-ethylhexyl) phthalate,
found above the proposed MCL in the intermediate depth well.
--The following contaminants were found at levels of public
health concern (see Table 1). Antimony was found at a maximum
level of 0.0187 mg/L, whereas the proposed MCL was 0.005 mg/L
(the MCL will be raised to 0.006 mg/L effective January 1994).
Beryllium was found at a maximum level of.0.008 mg/L, whereas
the proposed MCL was 0.001 mg/L (theMCL will be raised to
0.004 mg/L effective January 1994).. Total chromium was tound
at a maximum level of 0.478 mg/L, whereas the MCL is 0.1 mg/L.
Total cyanide was found at a maximum level of 2.43 mg/L,
whereas the proposed MCL is 0.2 mg/L. Fluoride was found at a
maximum level of 6.1 mg/L, whereas the MCL is 4.0 mg/L. Lead
was found at a maximum level of 0.0806 mg/L, whereas the MCL
was 0.005 mg/L (an action level of 0.015 mg/L has recently
replaced the MCL). Bis (2-ethylhexyl) phthalate was found at a
maximum level of 0.021 mg/L, whereas the proposed MCL is 0.004
mg/L. There is currently no known use of the contaminated
ground water, other than as non-contact cooling water for the
Amerimark facility. Workers are not in contact with this
cooling water.
--Evaluation of historical and current data indicates that
ground.water generally flows towards and into the Tuscarawas
River. The potential for flow under the river was
investigated; it was determined that this was not occurring.
--Dilution calculations for the inorganic and organic
constituents detected at the site suggest that those
contaminants which reach the river are diluted below analytical
detection limits immediately upon discharge to the Tuscarawas
River. Levels are below any regulatory criteria (see Table 2).
During the original RI, sediment samples (near site, upstream
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9
Tuscarawas River to determine the levels of PCBs and chromium
(known site-specific contaminants) in the sediments of the
river. It was suspected that these-contaminants would be
located in the sediments due to past waste discharges to the
river, overland runoff from the sludge, and from ground water
discharge to the river. Average chromium concentrations in the
sediments were 17 mg/kg upstream of the Site, 40 mg/kg adjacent
to the site, and 59 mg/kg downstream of the Site'. PCBs were
found in 2 of 41 samples at an average concentration of 0.29
mg/kg. Table 3 contains the sampling results.
It was unclear as to whether there had been any Site impact
upon the river sediment biota from the elevated levels of
contaminants in the sediments; therefore, further investigation
was done as part of the supplemental RI. Samples of benthic
organisms were taken from the Tuscarawas River. The results
indicate that species diversity may decrease downstream of the
Site. This alteration in the benthic community structure may
be attributable to past Site operations., However, adverse
sampling conditions (high river level, etc.) may have affected
the results. '
VI.
SUMMARY OF SITE RISKS
A Baseline Risk Assessment was conducted based on the
supplemental RI data to estimate the exposure to the',
contaminants in the site ground water. Contaminants of concern
in the ground water include the following: antimony,
beryllium, total chromium, total cyanide, fluoride, lead, and
bis (2-ethylhexyl) phthalate. Each of these constituents was
found in ground water at levels exceeding either its final or
proposed MCL (see Table 1). Carcinogenic, or cancer-causing,
constituents found in the ground water include arsenic,
beryllium, bis (2-ethylhexyl) phthalate, and 1,4-
dichlorobenzene. The full list of contaminants found in site
ground water and evaluated for their carcinogenic and/or non-
carcinogenic effects can be found in Table 4.
Risks from site ground water were evaluated for two general
exposure scenarios: residential and recreational. The
residential scenario assumes that the most affected portion of
the shallow aquifer at the Site will serve in the future as a
domestic water source. This scenario evaluated the use of site
ground water for drinking and showering/bathing. The assumed
routes of exposure to constituents in the affected water were
ingestion, dermal contact, and vapor inhalation. No one is
currently living on the site or consuming the ground water.
Thus, this scenario represents a conservative approach in
calculating potential future risks.
The recreational scenario evaluated risk from incidental oral
and dermal exposure to ground water constituents in the
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10
Tuscarawas River through boating and swimming. Ingestion of
fish which have potentially bioconcentrated constituents from
ground water discharges to the river was also evaluated. This
assumed recreational exposure is possible under both current
and future land use scenarios.
The determination of carcinogenic risk is based upon
calculating how much of an increased risk to humans a chemical
present at a site poses over the average or "background" level
of risk. For the general population, the background risk of
developing some form of cancer in one's lifetime is about one
chance in three, or 33 percent. The u.s. EPA uses a range of
increased cancer risk of between one in ten thousand to one in
one million as the level at which it requires that action be
taken to reduce risk. The specific level which ,is used is
dependent upon circumstances specific to a site. Excess
lifetime cancer risks are determined by mUltiplying the intake
level with the cancer'potency factor. These risks are
probabilities that are generally expressed in scientific
notation (e.g., 1X10~ or 1E-6). An excess lifetime cancer risk
of 1X10~ indicates that, as a plausible upper bound, an
individual has a one in one million chance of developing cancer
as a result of site-related exposure to a carcinogen over a 70-
year lifetime under the specific exposure conditions at a site.
The determination of noncarcinogenic risk of a single--
contaminant in a single medium is based upon the calculation of
a term called the Hazard Quotient (HQ), the ratio of the
estimated intake derived from the contaminant concentration in
a given medium to the contaminant's reference dose.
Noncarcinogenic risks include such risks as the potential to
cause liver damage and reproductive abnormalities. By adding
the HQs for all contaminants within a medium or across all
media to which a given population may reasonably be exposed,
the Hazard Index (HI) can be generated. The HI provides a
useful reference point for gauging the potential significance
of multiple contaminant exposures within a single medium or
across media. If the HI for a risk pathway is less than 1,
noncarcinogenic risk is not expected at a site. If it is
greater than 1, there is a potential for the occurrence of
noncarcinogenic health risks. If the HI is greater than 1,
compounds in the mixture are segregated by critical effect and
separate HIs are derived for each effect.
The r€sults of the human health risk assessment for the site
indicate that the total potential increased cancer risk from
the exposure of recreational users of the river to contaminants
from the site is below one in ten million (see Table 5). All
cumulative HIs are below 1.0 for the various toxicological
categories (see Table 6). These risks are within u.s. EPA's
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11
For the residential scenario, risk values were presented for
residential use only, and for the combination of the two
scenarios (residential and recreational), assuming that the
same individual could be exposed both in the residence (by
ground water consumption) and during recreational activities
(by contact with the river) if he lived on-site. Risk
estimates for the residential scenario do exceed the threshold
values for significant risk. A HI of 1.0 for noncarcinogenic
risk was exceeded in severa~ toxicological categories (see
Table 7). The acceptable cancer risk range was also exceeded.
For children age 0-6, the excess carcinogenic risk was
calculated to be four in ten thousand. For adults, the excess
risk was found to be six in ten thousand (see Table 8). Table
9 shows the risk levels from the residential and recreational
scenarios combined. The Baseline Risk Assessment explains in
detail how these calculations were done.
The Ohio Department of Natural Resources Division of Natural
Areas and Preserves, Natural Heritage Program was contacted
during the original RI in order to address concerns regarding
sensitive biota or habitats. The Heritage Program had no
records for rare or endangered species within a two-mile radius
of the site, and was unaware of any unique ecological sites in
the vicinity of the study area. There are no existing or
proposed state nature preserves or scenic rivers in Tuscarawas
County. A wetlands assessment was also conducted by the u.s.
Army Corps of Engineers. It was determined that site soils
were not hydric and, therefore, the Site was not considered to
be a wetland. However, during the SMOU remedial action, the
overburden has been removed and hydric soils have been revealed
indicating that at some point in the past this area may have
been a wetland.
The Baseline Risk Assessment qualitatively evaluated ecological
risks. Risks to benthic organisms living in the sediments of
the Tuscarawas River, as well as to terrestrial organisms
(i.e., plants) living on-site, were addressed. Ecological risk
was evaluated on the basis of a literature review concerning
bioconcentration/bioaccumulation for on-site and benthic
organisms. The report concluded that terrestrial plant uptake
of contaminated ground water is not expected to occur. In
addition, predicted constituent levels from ground water
discharges to the river were evaluated for toxicity and
availability to aquatic organisms; estimated river
concentrations are several orders of magnitude lower than
aquatic toxicity criteria (see Table 2). Benthic organisms
were collected and identified in a field study. Their
diversity appears to diminish from upstream to downstream of
the Site. The results indicate that adverse effects on benthic
organisms may have resulted from past site operations, which
appear to have contributed to elevated levels of chromium, and,
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These results, however, may have been 'affected by adverse
sampling conditions, such as high river levels, etc.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
"
.~
VII.
DESCRIPTION OF ALTERNATIVES
An array of alternatives for addressing ground water and
sediment contamination at the Alsco Anaconda site was
developed. The remedial alternatives considered were evaluated
based on their ability to be protective of human health and the
environment, attain compliance with Federal and state
environmental regulations, be cost-effective, and use permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practic~ble. The
remedial alternatives considered for this site are briefly
described below.
--Alternative 1:
No Action - Natural Attenuation
--Alternative 2:
Natural Flushing and Attenuation/Ground
Water and Sediment Monitoring
--Alternative 3:
Ground Water Extraction and Treatment/Ground
Water and Sediment Monitoring
Hydraulic Barrier with Ground Water
Extraction and Treatment/Ground Water and
Sediment Monitoring
Alternative 1 - No Action - Natural Attenuation
--Alternative 4:
Estimated capital Cost: $0
Estimated Total Present Worth operations and Maintenance (O&M)
Costs: $0
Estimated Net Present-Worth Costs: $0
Estimated Implementation Timeframe: None
Alternative 1, No Action, is a scenario in which no further
action of any kind will be initiated for the GWOU. It is
believed, based on extensive calculations (see Appendix B of
the GWOU FFS), that the ground water contamination will
naturally attenuate or diminish over time. Three of the
contaminants which were most frequently found in the ground
water above MCLs (cyanide, chromium, and fluoride), and which
contribute heavily to the site risk, are expected to attenuate
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13
Calculations were performed only on selected contaminants.
Calculations 'were not done for all contaminants which exceeded
MCLs because input values needed in the' calculations were not
available (for beryllium, e.g.) for some of those contaminants.
Attenuation calculations were done for 2 contaminants,
chlorobenzene and thallium, which were each detected in ground
water only once. Calculations were done on these contaminants
despite the fact that they were not detected frequently due to
the need to determine the time of attenuation of contaminants
from each class of compounds found in site ground water
(organics, inorganics, etc.) in order to get a better general
picture of when site contaminants from each class would
attenuate. Depending on which hydraulic conductivity input
values are used (see "Compliance with ARARs" section for more
details on the hydraulic conductivity values), chlorobenzene
and thallium may 'attenuate in as little as 15 years or as long
as 53 years.
According to calculations, lead and bis (2-ethylhexyl)
phthalate are the two contaminants which will take the longest
to attenuate; lead could take approximately 150 to 500 years to
attenuate. Lead is, however, commonly found in the
environment. It is unknown how long it may take for bis (2-
ethylhexyl) phthalate to attenuate. However, this contaminant
was found in some of the sludge excavated during the remedial
action, removing a source of this constituent. This
contaminant is ubiquitous.
Based on calculations performed as part of the Supplemental RI
and Baseline Risk Assessment, all contaminants are diluted well
below analytical detection limits at the point at which the
ground water enters the river, even during periods of low river
flow. Under this alternative, there will be no further
assessment of the benthic community or of the impacts the
contaminated sediments may be having on both the organisms
which are present and the related food chain.
Sludge and affected soils will be removed to health-based,
background, or guidance levels and to levels which assure
ground water protection as part of the SMOU remediation;
therefore, the only contaminants which will remain on-site are
those currently within the saturated zone of the aquifer and
the river sediments. with completion of the removal of the
source materials in the fall of 1992, further contaminant
impacts on ground water should be eliminated. Impacts on
sediments via surface runoff will also be terminated. The
sediment contaminants are expected to either become buried
through deposition of new, cleaner sediment upon the old, or
they may be scoured during extreme flood events. The ground
water and sediments will be allowed to "clean themselves up"
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14
Under this alternative, however, there will be no monitoring or
further assessment of the Site over time. The length of time
it will take for the Site ground water to reach the cleanup
levels described below. can only be estimated through
calculations. This alternative does not provide for
installation of background wells which would allow contaminant
levels in site ground water to be compared to levels naturally
occurring in the area. This remedy does not include in and of
itself any protective measures (e.g., institutional -controls)
to ensure that the ground water is not consumed prior to
achievement of cleanup levels. There will be no way to
determine if the river sediments are continuing to provide
elevated levels of contaminants to the benthic community,
potentially damaging the organisms which inhabit the sediments.
The cleanup levels will be determined as follows:
--Concentrations of site-related contaminants that also appear
in background wells shall be reduced to their respective
background concentrations, unless one of the following
conditions results in a higher cleanup concentration; In no
case shall contaminant concentrations be required to be reduced
to levels below background concentrations.
--site~related contaminants with an existing MCL shall be
reduced to a concentration at or below the MCL. ..
--Concentrations of carcinogenic site-related contaminants
shall be reduced to levels that pose a cumulative carcinogenic
risk no greater than 1X10~.
--Concentrations of noncarcinogenic site-related contaminants
shall be reduced to levels that pose a cumulative HI no greater
than one for any specific toxicological group.
Institutional controls are currently in place as part of the
remedy of the SMOU. If the no action alternative were chosen
as the preferred alternative for the GWOU, the institutional
controls currently in place would be in place for perpetuity.
For all other alternatives considered for this operable unit,
institutional controls would be a component of the remedy and
would be in place until the ground water had met and maintained
the cleanup levels for a period of time to be determined during
remedial design.
Alternative 1 will not meet all applicable or relevant and
appropriate requirements (ARARs) for the GWOU. Ground water
monitoring requirements under 40 CFR 264.97 will not be met.
Without ground water monitoring, there is no way to determine
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15
Alternative 2 - Natural Flushina and Attenuation/Ground Water
and Tuscarawas River Sediment Monitorina
Estimated
Estimated
Estimated
Estimated
Capital Cost: $49,200
Total Present Worth O&M Costs: $455,400
Net Present-Worth Costs: . $504,600
Implementation Timeframe: 6 months
This response action is based on the natural flushing and
attenuation of contaminants in the aquifer allowing ground
water to discharge to the Tuscarawas River, as described in
Alternative 1. An additional component is the periodic
sampling of ground water from monitoring wells for laboratory
analysis. possible locations of monitoring wells are shown in
Figure 5. optimum well locations will be determined during
remedial design. The Amerimark facility's active production
well, PW-5, may also be sampled as part of the monitoring
program. For cost purposes, the assumption was made that
sampling will-be done quarterly for the first two years, and
semi-annually thereafter, for a total of thirty years. The
actual monitoring frequency may be adjusted by u.s. EPA, in
consultation with OEPA.This alternative calls for the
installation of background wells so that contaminant levels may
be compared to naturally-occurring background levels. These
background wells will also be sampled regularly.
The contaminants~o be analyzed for include, but are 'not
limited to, those~listed in Table 4. The final list will be
determined during.~he remedial design phase. The data gathered
from the monitoring wells will allow the development of a
database to monitor the chemical conditions of the aquifer over
time. The data will also allow measurement of the degree of
attenuation of the contaminants and overall timeframes for
compliance with MCLs and health-based guidelines for ground
water, and wheth~contaminants are below background levels.
Monitoring will ba discontinued when cleanup levels defined
under Alternative 1 have been met and maintained for a period
to be determined during remedial design. If contaminant levels
increase over time (e.g., over the next ten years) as
determined by an Agency-approved method (such as a statistical
method), u.s. EPA, in consultation with OEPA, may reevaluate
the remedy; an alternate remedy such as an active treatment
technology may be considered.
Sampling of the Tuscarawas River sediments and benthic
organisms will also be conducted. For cost purposes, this
sampling is assumed to occur during years 1, 2, 4, 6, 8, and
10. Again, this.-"frequency may be adjusted by the U.S. EPA, in
consultation with OEPA. When sampling the sediments for PCBs
and chromium, the depth of the contaminants, as well as the
concentration, will be analyzed and determined. The benthic
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16
population will be sampled to determine if there is an
increase/decrease in the diversity or quantity of organisms.
If the benthic community has not improved (i.e., the diversity
and quantity of the organisms has not increased over time),
then u.s. EPA, in consultation with OEPA, will determine
whether an active remedial technology for the sediments is
implementable, and whether the technology should be employed.
The sampling program for the sediments and:benthic organisms
will be fully defined during the remedial design phase.
Institutional controls (e.g., deed restrictions) which restrict
use of the site ground water will be in place until the ground
water has met and maintained the cleanup levels defined under
Alternative 1 for a period of time to be determined during
remedial design.
Alternative 2 will meet ARARS for the GWOU. Ground water
monitoring requirements under 40 CFR 264.97 will be met. MCLs
promulgated under the SDWA and health-based levels.derived
using the Integrated Risk Information System (IRIS) or the Risk
Assessment Guidance for Superfund (RAGS), (IRIS and RAGS are
"To-Be-Considered" requirements, or TBCs), are expected to be
met over time. Calculations performed in the FFS estimate that
all ground water contaminants evaluated except lead and bis (2-
ethylhexyl) phthalate will be attenuated within.15 to 53 years.
Alternative 3- Ground Water Extraction and Treatment/Ground
Water and Tuscarawas River Sediment Monitorina
Estimated
Estimated
Estimated
Estimated
capital Cost: $1,793,520
Total Present Worth O&M Costs: $5,989,900
Net Present~Worth Costs: $7,783,420
Implementation Timeframe: 2 years
This alternative includes all aspects of Alternative 2
(monitoring, institutional controls, etc.). In addition, the
ground water will be extracted and treated. Pumping and
treating of ground water is the only currently available active
technology for this site for removing contaminants from ground
water. This response action will involve the installation of
large-diameter extraction wells; the construction of pipelines
and a treatment facility; and the actual treatment of the
extracted ground water.
The current conditions of the ground water, in terms of both
hydraulics and chemistry, present challenges to ground water
extraction and treatment. The aquifer is extraordinarily
transmissive, which suggests that extremely large volumes of
water must be pumped in order to create a cone of influence
large enough to capture the affected ground water; very large
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17
affected areas in order to flush or desorb the contaminants.
However, pumping the ground water is expected to decrease the
time required for contamination-to-re-ach the cleanup levels
defined under Alternative 1.
Under this alternative, lead will attenuate in less time than
it would take under Alternative 2. However, there is very
little difference in the time it will take chromium, cyanide,
and fluoride to attenuate under this alternative as compared to
Alternative 2 (2 years for Alternative 2 versus 1 year for
Alternative 3). Bis (2-ethylhexyl) phthalate is not expected
to attenuate under either alternative. However, as mentioned
earlier, source material containing this constituent is being
removed.
Alternative 3 will meet ARARS identified for the GWOU. Ground
water monitoring requirements under 40 CFR 264.97 will be met.
MCLs promulgated under the SDWA and health-based levels derived
using IRIS or RAGS are expected to be met over time.
Calculations performed in the FFS estimate that all ground
water contaminants evaluated except bis (2-ethylhexyl)
phthalate will be attenuated within 15 to 52 years.
The treatment system will be built to comply with 40 CFR 264
(general facility standards). Following extraction and
treatment, ground water discharge will comply with NPDES permit
equivalent levels. Any treatment residuals generated from the
treatment of ground water which contain chromium and/or cyanide
will be subject to RCRA Land Disposal Restrictions (LDR)
treatment standards for RCRA F019 listed waste before final
disposal. If activated carbon is used in a filter system, the
spent or used carbon containing cyanide or chromium will be
regenerated ina unit which is in compliance with 40 CFR Part
264 Subpart X. Shipment of treatment residuals off-site will
be done in compliance with all Federal and State regulations.
Alternative 4 - HVdraulic Barrier with Ground Water Extraction
and Treatment/Ground Water and Tuscarawas River Sediment
Monitorinq
with Slurry Wall--
Estimated capital Cost: $2,936,520
Estimated Total Present Worth O&M Costs: $5,989,400
Estimated Net Present-Worth Costs: $8,925,920
Estimated Implementation Timeframe: 2 years
with Injection Wells--
Estimated Capital Cost: $1,998,720
Estimated Total Present Worth O&M Costs: $6,911,800
Estimated Net Present-Worth Costs: $8,910,520
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18
This response action adds an additional component to the
extraction and treatment of ground water described in
Alternative 3. A hydraulic barrier will also be constructed
between the former source areas and-the Tuscarawas River to
prevent migration of any contaminants into the river. This
barrier will also help to limit the amount of river water
pulled into the aquifer, thereby minimizing the amount of water
that will have to be treated by the system. The barrier could
consist of a slurry wall, or of-a series of injection wells.
Ground water extraction and treatment will be performed to
control ground water flow and to remove contaminants from the
aquifer. This alternative is not expected to decrease the
amount of time it takes for contaminants to attenuate from
those timeframes calculated under Alternative 3.
Alternative 4 will meet ARARS identified for the GWOU. Ground
water monitoring requirements under 40 CFR 264.97 will be met.
MCLs promulgated under the'SDWA and health-based levels derived
using IRIS or RAGS are expected to be met over time.
Calculations performed in the FFS estimate that all ground
water contaminants evaluated except bis (2-ethylhexyl)
phthalate will be attenuated within 15 to 52 years.
The treatment system will be built to comply with 40 CFR 264
(general facility standards). Following extraction and
treatment, ground water discharge will comply with NPDES permit
equivalent levels. Any treatment residuals generated from the
treatment of ground water which contain chromium and/or cyanide
will be subject to RCRA LDR treatment standards for RCRA F019
listed waste before final disposal. If activated carbon is
used in a filter system, the spent or used carbon containing
cyanide or chromium will be regenerated in a unit which is in
compliance with 40 CFR Part 264 Subpart X.Shipment of
treatment residuals off-site will be done in compliance with
all Federal and State regulations.
VIII.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
The Nine Evaluation criteria
The GWOU FFS examined the four remedial alternatives in detail,
and evaluated them according to technical feasibility,
environmental protectiveness, and public health protectiveness.
The alternatives were evaluated according to the following nine
criteria, which are used by the u.S. EPA to .provide the
rationale for the selection of the chosen remedial action for a
site.
THRESHOLD CRITERIA
The following two criteria are threshold criteria which must be
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19
o
Overall Protection of Human Health and the Environment
addresses whether or not a remedy provides adequate
protection and describes how r~sks posed through each
pathway are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional
controls. .
o
compliance with ARMs addresses whether or not.a remedy
will meet all of the applicable or relevant and.
appropriate requirements (ARARs) of other Federal and
state environmental statutes and/or provide grounds for
invoking a waiver.
PRIMARY BALANCING CRITERIA
The five criteria listed below represent the primary balancing
criteria upon which the analysis is based. '
o
Long-term effectiveness and permanence refers to the
magnitude of residual risk and the ability of a remedy
to maintain reliable protection of human health and the
environment over time once cleanup levels have been met.
o
Reduction of toxicity, mobility, or volume through
treatment is the anticipated performance of the
treatment technologies that may be employed in a remedy.
o
Short-term errectiveness refers to the speed with which
the remedy achieves protection, as well as the remedy's
potential to create adverse impacts on human health and
the environment that may result during the construction
and implementation period.
o
Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement the chosen
solution.
o
Cost includes capital and operation and maintenance
costs.
MODIFYING CRITERIA
The following two criteria are modifying criteria.
o
state Acceptance indicates whether, based on its review
of the RI/FFS, Proposed Plan, and ROD, the state concurs
with, opposes, or has no comment on the selected remedy.
o
community Acceptance indicates whether, based on
comments received on the RI/FFS and Proposed Plan, the
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B.
comDarative Analvsis of Remedial Alternatives
Each of the alternatives was evaluated using these nine
criteria. The regulatory basis for these criteria comes from
the NCP and section 121 of CERCLA (Cleanup Standards). section
121(b) (1) states that, "Remedial actions in which treatment
which permanently and significantly reduces the volume,
toxicity, or mobility of the hazardous substances, pollutants
and contaminants is a principal element, are to be preferred'
over remedial actions not involving such treatment. The off-
site transport and disposal of hazardous substances or
contaminant materials without such treatment should be the
least favored alternative remedial action where practicable
treatment technologies are available." section 121 of CERCLA
also requires that the selected remedy be protective of human
-health and the environment, be cost-effective, and use
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent
practicable.
This section discusses the relative advantages and -
disadvantages of the remedial alternatives against ,the nine
evaluation criteria. '
" -
Overall Protection of Human Health and the 'Environment
Based on the res'~'ts of the Supplemental RI and the Baseline
Risk Assessment o~; the GWOU, the only direct human exposure
pathway which po~~s unacceptable risk is consumption of ground
water if the Sitf?,;', is developed and water supply wells are
installed. (Risks posed to humans via the recreational
scenario were within the acceptable risk range.) In addition,
contaminated sediments potentially pose a threat to the
riverine community.
~
All remedial alter~atives except Alternative 1, No Action,
provide protection of human health and the environment.
Alternative 1 does not allow for any kind of monitoring or
assessment of the site over time; thus, there is no provision
for addressing the site if, in fact, the contaminants in the
ground water and sediments do not attenuate over time. since
it is not protective, Alternative 1 will no longer be
considered a viable alternative, and will not be evaluated
further.
Alternative 2, Natural Flushing and Attenuation with Ground
Water and Sediment Monitoring, does not utilize a treatment
technology for ensuring overall protection of human health and
the environment. However, this alternative does involve
monitoring the ground water and sediments to confirm that
attenuation is occurring and it provides the opportunity to
reevaluate the remedy if attenuation does not occur. It also
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includes institutional controls to prevent human exposure to
the contaminated ground water. This alternative is protectiv€
of human health and the environment. --
Both Alternatives 3 and 4 involve the use of an active remedy
which employs currently available technology. An additional
component of the remedy involves monitoring the aquifer and
sediments in order to ensure the remedy is working. Without
any kind of monitoring, there is no way to determine if the
site has achieved cleanup levels. Again, institutional
controls will be in place until the cleanup levels are met.
These alternatives are protective of human health and the
environment.
Currently, there is no direct pathway for human exposure. The
only potential pathways which may result during the
implementation of Alternatives 2, 3, and 4 are temporary and
related to potential exposure of construction or monitoring
personnel during implementation of the remedial alternative.
However,' the possibility does exist that the aquatic population
is being exposed to harmful concentrations of the contaminants
present in the sediment. The studies which were performed
during the original RI and the supplemental RI ascertained the
presence of contaminated sediments and the apparent impacts to
the benthic community from the contaminants. 'However~ it was
unclear if the benthic community was recovering from exposure
to the contaminants or if it was continuing to be impacted.
The possibility of removing the contaminated sediments has been
evaluated (see FFS)i it has been determined that the dredging
process could pose significant risks to the riverine system.
Unless it can be determined that the benthic population is
continuing to be impacted by the presence of the contaminants
which remain in the sediments, dredging will not be considered
as a remedial technology. By monitoring the sediments and the
affected organisms (Alternatives 2, 3, and 4), it can be
confirmed that the levels of contaminants which are present
will be attenuated over time, and that benthic organism
populations are recovering.
ComDliance with ARARs
A summary of the ARARs evaluated for the alternatives is
provided as Table 10. Major ARARs are discussed below.
Alternatives 2, 3, and 4 will meet ground water monitoring
requirements under 40 CFR 264.97. Alternatives 2, 3, and 4 are
expected to attain ground water MCLs under the SDWA, compliance
with Federal and state Water Quality Discharge Standards, and
compliance with all health-based criteria and guidelines over
time, as discussed below.
-------
22
Calculations in the FFS, Appendix B, estimate that under
Alternative 2, all ground water contaminants for which
calculations were performed, except lead and bis (2-ethylhexyl)
phthalate, will attenuate within 53 years. These calculations
were performed using the hydraulic conductivity (the amount of
ground water flowing through a given area of the aquifer during
a given time period) obtained through studies which were
performed during the supplemental RI. If a different hydraulic
conductivity value is used, one obtained from an aquifer pump
test which was performed on this aquifer in 1972, then the
calculations estimate that all of the contaminants evaluated,
except lead and bis (2-ethylhexyl) phthalate, will attenuate
within 15 years.
Alternatives 3 and 4, which involve active remediation, will
result i.n attainment of ARARs more rapidly than Alternative 2.
The calculations which were performed estimate that all ground
water contaminants evaluated, except bis (2-ethylhexyl)
phthalate, will attenuate within 52 years. If the hydraulic
conductivity value from the pump test is used, it is estimated
that all of the contaminants, except bis (2-ethylhexyl)
phthalate, will attenuate in the same amount of time regardless
of the alternative chosen--15 years. The basic difference
between active (Alternatives 3 and 4) and passive remediation
(Alternative 2) is that the attenuation timeframe for lead
would be reduced under the active remediation Alternatives, 3
and 4.
The two hydraulic conductivity values which were used to
perform the calculations were obtained by two different
methods. This is the reason for two such disparate sets of
calculations and cleanup timeframes. The calculations provide
an estimate regarding the amount of time it may take for the
aquifer to attain the cleanup levels. The Agencies consider a
hydraulic conductivity value obtained by performing a pump test
to be more representative of actual conditions than the method
used during the supplemental RI. Therefore, it is believed
that the calculations performed using the higher hydraulic
conductivity value are probably a more accurate reflection of
the way the aquifer will react under the various alternatives.
However, because it is impossible to know exactly how long
remediation will take, a monitoring component is a part of
Alternatives 2, 3, and 4.
The treatment system described as part of Alternatives 3 and 4
will be built to comply with 40 CFR 264 (general facility
standards). Both alternatives involve pumping the water from
the ground, treating it to remove the contaminants, and then
discharging the water to the river. Following extraction and
treatment, ground water discharge will comply with NPDES permit
equivalent levels. Any treatment residuals generated from the
treatment of ground water which contain chromium and/or cyanide
-------
23
will be subject to RCRA LDR treatment standards for RCRA- F019
listed waste before final disposal. If activated carbon is
used in the filter system, the spent or used carbon containing
cyanide or chromium will be regenerated in a unit which is in
compliance with 40 CFR Part 264 subpart x. Shipment of
treatment residuals off-site will be done in compliance with
all Federal and State regulations.
Lona-Term Effectiveness and Permanence
Alternatives 2, 3, and 4 provide approximately the same degree
of long-term effectiveness and permanence. Alternative 2,
although it does not employ an active remedy, provides for
monitoring the ground water and sediments to confirm that the
remedy is effective. If the remedy does not prove to be
effective, the site remedy may be reevaluated and an alternate
remedy considered. In order to evaluate the effectiveness of
the remedy, at least every 5 years (until cleanup levels are
met) the accumulated data will be evaluated through an Agency-
approved method (such as a statistical method) in order to
determine if there has been an increase or decrease in the
contaminant levels over time. After reviewing the data, U.S.
EPA will determine whether the selected remedy will continue or
if an alternative will be assessed. .
Alternatives 3 and 4 employ active remedies with -a-monitoring
component. By monitoring the ground water, it can be
determined that the remedy is working.
All of the alternatives should result in a concentration
decrease in ground water contaminants over time. The source
materials will be gone due to the SMOU remedial action, and
those contaminants found in the aquifer should decrease to
levels protective of human health and the environment.
Reduction of Toxicitv. Mobilitv or volume
Alternative 2 will not provide for a reduction of toxicity,
mobility or volume of contaminants through treatment. The
remedy proposed under this alternative is a passive one,
allowing the contaminants found in the aquifer and sediments to
attenuate naturally. However, the remedy of the SMOU, which
consisted of removing the source of the ground water and
sediment contaminants, has employed a removal and treatment
system. Even though Alternative 2 does not employ a treatment
technology, there should be a reduction in the volume of the
contaminants.
Alternatives 3 and 4 both involve the reduction of toxicity,
mobility or volume of ground water contaminants through
treatment. Under these alternatives, the ground water will be
-------
24
should result in a decrease in the
contaminants in ground water. The
under Alternatives 3 and 4 is more
2.
concentrations of
estimated remediation time
rapid than under Alternative
None of the alternatives being examined will employ an active
technology for the remediation of the sediments. However, it
has been determined that dredging of the sediments at this
time, the only viable active treatment technology for
sediments, would probably result in greater damage to the
riverine system than leaving the sediments in place. Through
monitoring of the sediments and benthic populations, it can be
determined if treatment of the sediments is warranted. The
sediment and benthic study will be conducted over a 10 year
period, unless the timeframe is adjusted by the Agencies.
Since a source of continuing sediment -contamination is being
removed, the sediment and benthic community should both improve
in quality over time. The monitoring will allow a qualitative
and quantitative assessment to be made. If the benthic
community has not improved (i.e., the diversity and quantity of
the organisms has not increased over time), then' U.S. EPA, in
consultation with OEPA, will determine if there is an .
implementable, active technology available for remediation of
the sediments and whether this technology will be employed.
Short-Term Effectiveness
The monitoring activities planned under each of the remedial
alternatives present very low risks to site personnel by the
creation of temporary exposure pathways during well
construction and sampling activities. Alternatives 3 and 4
will take longer to implement than Alternative 2 because
construction activities (treatment plant construction, slurry
wall construction, etc.) are executed as part of the remedies.
Precautionary measures under all alternatives will include
protection of workers from direct contact with contaminated
ground water and sediments.
Institutional controls will be in place under each alternative
to prevent consumption of the ground water before cleanup
levels have been met.
Imp1ementabilitv
All of the remedial actions can be implemented using
established technology. Alternative 2 is easily implemented
since it requires minimal design and minor well construction
and ground water analyses. Alternatives 3 and 4 are more
difficult to implement and would require detailed
extraction/treatment system design. Construction and
maintenance of a hydraulic barrier (Alternative 4) may be
-------
25
aquifer beneath the Site, making this alternative the most
difficult to implement.
Cost
capital and annual operation and maintenance costs increase
from Alternatives 1 to 4 due to the increase in complexity of
each alternative. capital costs range from zero in Alternative
1 to .$2,936,520. in Alternative 4 (with a slurry wall) .
Estimated net present worth costs range from zero in
Alternative 1 to $8,925,920 in Alternative 4 (with a slurry
wall). Costs are described under each alternative in section
VII. Tables 11, 12, and 13 contain detailed cost estimates for
each of the alternatives except the no action alternative.
state Accegtance
The state concurs with this ROD. A letter from OEPA indicating
this support can be found as Appendix C.
community Acc8Dtance
The only comments
from a PRP, ARCO,
proposed remedy.
proposed.
received regarding the proposed remedy were
which did not raise objections to the
The community appears to accept the remedy as
IX.
THE SELECTED REMEDY
In summary, the selected alternative, Alternative 2, provides
the best balance among the alternatives with respect to the
criteria used to evaluate remedies. u.s. EPA and OEPA have
determined that by monitoring the ground water, and restricting
its use, risks to human health associated with contacting the
ground water can be minimized. Although numerical cleanup
levels for all contaminants have not yet been determined, at a
minimum, ground water shall be monitored until the following
cleanup standards have been met. Concentrations of Site-
related contaminants that also appear in background wells shall
be reduced to their respective background concentrations,
unless one of the following conditions results in a higher
cleanup concentration. In no case shall contaminant
concentrations be required to be reduced to levels below
background concentrations. site-related contaminants with an
existing MCL shall be reduced to a concentration at or below
the MCL. Carcinogenic site-related contaminants shall be
reduced to levels that pose a cumulative carcinogenic risk of
no greater than 1X10~. concentrations of noncarcinogenic site-
related contaminants shall be reduced to levels that pose a
cumulative HI no greater than one for any specific
-------
26
risk levels have been achieved, the residential Use scenario,
as outlined in the Baseline Risk Assessment for the GWOU, will
be used.
The preferred alternative will allow the contaminated ground
water and sediments time to "clean themselves up", since the
source of the contamination (the sludge and contaminated soil,
which have been contributing contaminants to the ground water
and sediments for many years) is being removed during the SMOU
remedial action. The ground water and sediment contamination
will be monitored to ensure that it diminishes over time. If
contamination does not lessen, or if it increases over time,
the remedy will be revisited and an alternative remedy (such as
ground water extraction and treatment) will be reevaluated.
The Agencies believe this remedy is the most cost-effective.
It is also protective of human health and the environment.
Restrictions on ground water use will be in effect until the
cleanup levels have been reached and maintained. Institutional
controls including deed restrictions will prohibit consumption
of contaminated ground water. The levels of ground water
contaminants reaching the Tuscarawas River are extremely low,
and do not exceed any regulatory criteria. These levels are
expected to decrease further in the future, since the source
material will be gone. .
Based on the information available at this time, u.s. EPA and
OEPA believe the preferred alternative would be protective of
human health and the environment, would comply with ARARs, and
would be cost-effective.
This alternative will not satisfy the preference for treatment
as a principal element. However, the Agencies do not believe
the cleanup of the aquifer will be significantly improved
through an active treatment system, to the point of justifying
the greatly increased expense. The removal of the source
material will eliminate the source of ground water
contamination. Alternatives 3 and 4 will lead to reduction of
the ground water contamination levels more rapidly than
Alternative 2. However, the estimated timeframe for the
aquifer to attenuate, or flush itself clean of contaminants as
described _in Alternative 2, is not significantly greater than
if a treatment system were utilized. The two contaminants
which take the longest time to attenuate are lead and bis (2-
ethylhexyl) phthalate. Lead will be cleaned up faster under
Alternatives 3 and 4. Bis (2-ethylhexyl) phthalate, however,
will not attenuate under any of the alternatives. Lead may be
present due to naturally occurring background contamination.
Bis (2-ethylhexyl) phthalate has been found in some of the
sludge during the remedial action; removal of the source may
lead to a decrease in the levels of bis (2-ethylhexyl)
phthalate in the site ground water. .
-------
27
If the monitoring results of the ground water and sediments do
not demonstrate that the contaminants are being flushed from
the aquifer over time, that the sediment contamination levels
are decreasing, and that the benthic populations are
recovering, then the u.s. EPA, in consultation with OEPA, will
revisit the site remedy and other remedial alternatives will be
reevaluated. In order to determine if the contaminants are
being flushed from the aquifer, the accumulated data from the
jground water monitoring program will be evaluated. . The data
will be examined 1) to determine if there has been a decrease
in contaminants over time and 2) to determine if the aquifer
will, in fact, flush itself clean within the approximate
timeframes that the FFS calculations estimated. The benthic
data will also be examined to evaluate whether the benthic
population is showing an increase/decrease in diversity. In
addition, the extent of the sediment contamination will be
assessed in order to determine if there is another source of
the contaminants or whether the contamination is being either
buried or flushed from the system over time.
x.
STATUTORY DETERMINATIONS SUMMARY
pro~ec~ion of Ruman Real~h and ~he Environmen~
1.
The selected remedy provides a sufficient degree of overall
protection of human health and the environment', by permitting
the contaminated qround water to "clean itself up" while
preventing exposure through the use of institutional controls
until cleanup levels have been met and maintained. Benthic
populations will be monitored to determine whether the
diversity of benthic organisms living in the sediments near the
Site increases following removal of the source materials.
Any short term risks associated with implementation of the
selected remedy will be minimized by the use of good
construction practices. .
2.
A~tainmen~ of ARARs
The selected remedy will attain all Federal and State ARARs as
described in section VIII and Table 10 of this ROD. The
chemical-specific, action-specific, and location-specific ARARs
and TBCs (other criteria, advisories, guidance and proposed
standards that are not legally binding, but that may provide
useful information or recommended procedures) for the selected
-------
28
Chemical-sDecific ARARs
MCLS promulgated under the SDWA (40 CFR Part 141)
40 CFR 264 Subpart F including 40 CFR 264.92 (ground water
protection standards) and 40 CFR 264.97 (general ground water
monitoring requirements)
Section 303 and 304 .of Clean Water Act regarding .water quality
standards and Federal water quality criteria
Section 3745-1-07 of the Ohio Administrative Code regarding
State water quality standards
Action-sDecific ARARs
29 CFR 1910 regarding general industry standards for
occupational safety and health
40 CFR Part 264.100 regarding development of a corrective
action program following release to ground water from a waste
unit
40 CFR Part 264.117 which outlines post-closure care and site
security
Section 3745-54-92 of the Ohio Administrative Code regarding
ground water protection standards
Section 6111.04 of the Ohio Revised Code which prohibits
pollution of waters of the state
Location-sDecific ARARs
40 CFR Part 6 Appendix A/Executive Order 11988 regarding
construction in floodplains
To-Be-Considered criteria
Ground Water Classification Guidelines ,published by the u.s.
EPA Office of Ground Water
IRIS, which provides information utilized in risk calculations
and development of cleanup goals
RAGS, which provides direction in preparing health-based and
-------
29
3.
Cost-Effectiveness
The selected remedy provides overall cost-effectiveness. The
alternative provides protectiveness through the use of
institutional controls, and, at the same time, allows the
aquifer to "clean itself up" at a cost millions less ($504,600
versus $7,783,420) than the active remedies. This alternative
allows the Agencies time to discern whether source material
removal has effectively solved the ground water problem, and,
at the same time, allows for the option of selecting an
alternative remedy in the future if this is not the case.
4. utilization of Permanent Solutions and Alternative
Treatment Technoloqies or Resource Recovery Technoloqies to the
Maximum Extent Practicable
The selected remedy provides the best.balance with respect to
the nine evaluation criteria as described in section VIII of
this ROD. Treatment technologies are not utilized in this.
alternative; however, this alternative provides protectiveness
while being cost-effective. The removal of the source
materials and the ensuing decrease in the ground water
contamination levels which should follow will result in a
permanent solution to the ground water problem. It is a
statutory requirement to utilize permanent solutions to the
maximum extent practicable; the combined remedy for both
operable units at the Alsco Anaconda site fulfills this
statutory requirement.
5.
Preference for Treatment as a principal Element
The selected remedy does not utilize treatment as a principal
element, and, therefore, does not satisfy the statutory
preference for treatment. However, the principal threat (the
source material) is being removed under the SMOU remedial
action. Ground water and sediment treatment is not, at this
point, cost-effective and does not provide a significantly
greater amount of protection. If the selected remedy proves
unsuccessful, an active treatment alternative may be
reevaluated in the future.
XI.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the GWOU of the Alsco Anaconda Site was
released for public comment in August 1992. The Proposed Plan
identified Alternative 2, Natural Flushing and Attenuation/
Ground Water and Tuscarawas River Sediment Monitoring, as the
preferred alternative. u.S. EPA received no comments during
the public comment period. Therefore, it was determined that
no significant changes to the remedy, as it was originally
-------
.J."
t
I MaL
ICIIIO
o
ICIIIO 2000
~--~~_.
DID
.oao
5CIOO
&OlD
7CIOO FEET
1,-:'1"'" -
-~_. ...-- I
~_.~---~... -.- -
SOURCE: USGS GNADBHJTTEN 7.5 MNJTE QUADRANGlE. 1912: REVISED 1985
ERrt-.5oathwest. in~
NEW OIUANS. UU8AHA HOUSTON. TEXAS
FIGURE 1
LOCATION MAP
ORIGINAL
.,.
....
..,
a::
..
o
.
..
;;
DAlE 6-27-91
W.o.ND.' 5-48A007
ALSCO ANACONDA SITE
-------
. = Previously Installed Wells
. = Shallow Wells
. = Intermediate-Depth Well
. .
l' ".'.
I ;'..
II = Deep Wells
~:- = Water Supply Wells
1:J
1
~
~
i
u
C:
Ii
Q.
\0
1"1\
1
vi
~
Sice Boundary
(4.717 Acre,)
Walnut Street
pw,~
) +.
.
MW
I 1
.
.
i
r
I
I
I
I
I
I
I
I
I
I
.
.
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I
.
.
.
QJ
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o
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10
~.
Alsco Aluminum
Processing rlant
!~,- ;-.:..;t.:..:~ .
.~,
~p
PW
4
loading
Dock
\\
Cherry Street
Office
Building
I
-------
;'
/
/
/
., . .
.
.,/
" .
" "'. .
.
GNADENHUTTEN
.
I
..
.
-,
.
,
I
LEGEND
REFERENCEI
IT. 1989
9
40}00
. WATER WELL
20,00
SCALE IN FEET
ERrt-5oathwvst. inc.
NEW ORLEANS. LOUISIANA HOUSTON. 1IXAS
FIGURE 3
REGIONAL MAP SHOWING
WATER WELL LOCATI.ONS
..
..
= DA 1£ I 0 - 7 - 9 I W.O.NO.
..
15-70
ALSCO ANACONDA SITE
GNADENHUTTEN. OHIO
-.
-------
w S11I£U
00\-
ALSCO ALUMINUM Dr_-~J \-
PROCESSINC PLANT
~ 0: I II
0:
I:!! -J rSlTE BOUNDARY
B «
II:: ~ (4.717 ACRES)
~ ~ DOWNSTREAM
~ SAMPLING
z TRAVERSES
CI'I ~
TUSCAR RIvER
~S -
TR-2
WlWO
~ ~=.Iot1II"O.
rijOOJ lUll' au" AU """,IIID
o
.
400 IlOO
--.-,
fin
sc.u
0000 ,-- lUll' can,AU
ERM-Soathwest. In-c~
..--~ .....
-- LClCAI,OId rCII
...- ..-ItUIIAftS
__Dl.
_c.-
B
......... ICICA- '111
IOI1IC _,""'0
10,,111"" IDAS
..-
, ..n;o.- ...
-------
ERrI-5oathwvst. inc.
NEW ~s. LClUlSANA HOUSTON. 1DAS
APPROXIMA TE
LIMITS OF
EXCAVA TION
a::
10.1
~
a::
en
011
~
011
a::
011
(.)
rn
~
~
o
DA1£ 8-22-9 I
W.o.NO.
PENN-CENT
RAL RAILROAD
o
SWAMP
AREA
o
o
D WASTEWATER
TREATMENT PLANT
LEGEND
o
APPROXIMATE SHALLOW MONITORING
WELL LOCATION
" APPROXIMATE INTERMEDIA TE DEPTH
MONITORING WELL LOCATION
o 75.
150
SCALE
FEET
15-70
NOTE: ADAPTED FROM IT CORPORATION (1989)
FIGURE 5
APPROXIMATE MONITORING WELL
LOCA TIONS
GROUND WATER OPERABLE UNIT
ALSCO ANACONDA SITE
-------
~ABLE 1
CONSTITUENT GROUND WATER CONCENTRATIONS COMPARED TO MCLa
AI8CO ANICO"aa &its
GnaCl8ftftUG8n. Ohio
~ftG8ot Ufetlln.
CQftC8f88- Mean 1'4""
. 0.- concenn'" MCL MeL Advi8arY
C on.lINen' (motU (.) JmalU (b) (mCIIU Sta... ~ Es.-HCoMlC.. I~U !mCIIU
Alum"'um 0.108-23,2 S.11 0.01 TO 0.2 F. SMCL e
A ntlmon" NA 0.0"8 O.OtlO.OO8 I' e 0.001
A,..nlC 0.0051-0.021 0.010 0.05 R 0.001 Cd)
B8Iium 0.03Z2 -0.108 0.251 2 F Z
9ery\8IUm NA 0.0088 0.001 I' E 0.0008 Cd)
Calcium' 63.1-.23 151
Chtomlum lto." 0.0414-0.478 0.011 0.1 F e 0.1
CoDa" 0.0058-0.043' 0.0"
CODD8F 0.0033-0.258 0.041 1.3 I'
;ron 0.215-87.' 18.3 0.3 F. SMOL e
_.ao 0.0011-0.0808 0.013 0.005 F e
"'a9n8"'" 1 1 .4-210 55.1
Ma,....... 0.221-'2.4 ~.2O 0.05 F. SMOL e
M8tcurv 0.00038-0.00'2 0.0002 0.002 F 0.002
Nidi.' 0.0'0-0.07" 0.018 0.1 I' 0.1
Potauaum 1."-2'.' 8.20
su".- NA 0.011 8 0.1 F. SMeL E 0.1
Sodium 15.1-'82 82.Z 20 (..
Thallium NA 0.0028 0.002IQJJ01 P O.OOCM
Va""'" 0.011 -0.al1. 0.011 0.01
Zinc 0.01"-0.- 0.081 I F. SMCL 2
To.' cya_8 0.0058-2.43 0.358 0.2. P e 0.2
Fluor... O.S -'.1 t." 4 F.R e
N".. o..-e.' 2.M 10 C88 H) F
N"" NA 0.018 1 (U H) F
b~ (2 - EthVIh.avl) 0.008-0.0IZ1 0.008 o.~ p e
"n....""
ChIorOO8ftZ8ft8 NA 0.0088 0.1 F 0.1
, .2 - Dic:hIarOD8ftZ8f NA 0.1108 0.' F(f) 0.'
1.6-01ctllOl008ftUna NA 0.0088 0.015 F 0.071
XVlene. NA 0.0018 '0 F 10
NOTES:
A"."" 818 far ~..I_" ...._1 T T
(a. NO va.... ar. ......- tra8"''''''' ana ......................... .vera"'. ........ ....Ie"""
(b) Th8 mean COI-,.4I - -- .-_..... U'" -............. 0"''''''''''''' .....a~"'" _it -- ......
far NO va..... .....- - ... .-.........,., -..... 1 ~..... The _"'11 ~ .... i8 .... In
1ft" cotulnn far -- - I" - - ... A80 n. .......... 8II"'",1Iic8""'''' ,,*.~"
(e) S..........r..tr-,""
F - F'tn8I 0 - Ord P - .......'1'" R - U.........
(d) Th..--r.ar."~ '0-."""
(.) L8V81" 1M Orlnldnl waw ""'MI-'I"" ~ (OweL) In'" ".IIl8". L.I8IIM......,.......,.....
(guid8M8 onf¥ far ........ .
(f) Valu. far O-OIch*A8I1 .......... --.........
'01 E - e-...-.... I . - - --- -A''''''' IOCL .
Muimum value. f."..--"" ant¥ -..............'" -...-.a.,. ............... de""''''''''
Source: U.$. EPA. Ot11C8 crI W.w. Drtn1dn9 w.- .......-- and H8dh AdVi8G'i8L April , II'.
SIICL. II
...., MOL
-------
Indicator
Constituent
Antimony
Arsenic
Barium
Beryllium
Chromium (+6)
Chromium (Total)
Cobalt
Copper
Flouride
Lead
Mangane.
Mercury
Nickel
Silver
Thallium
Vanadium
Zinc
Total cyanide
Nitrate
1.2-DichlorobenZene
1.4-Dichlorobenzene
Bis(2-ethylhexyl) phthalate
Chlorobenzene
Xylenes
NOTeS:
TABLE 2
RIVERINE CONCENlRA TlONS COMPARED TO
AMBIENT WA TER QUAL TJY CRITERIA
Riverine (a)
Concentration
(mg/U
9.54E-07
1.43E-06
4.62E-05
4.oeE-07
2.44E-06 (b)
2.44E-05
2.20E -06
1.32E-05
3.11E-04
4.11E-06
8.S2E-04
8.12E-oe
J~.83E-06
:'f!.81E-07
'1.02E-07
, :'4;' se-06
'1:83E-05
':"1.24E-04
4.8OE-04
9._-06
4.08E-07
.1 ;07E-06
~E-07
',1..53E-07
Aisco Anaconda Site
Gnadenhutten. Ohio
Human Health Criteria ,
Criteria For Criteria For ",
Water & Organi8m Organi8m
Ingestion Ingestion
(mg/U (mg/U
1.48E-01 4.SOE-02
2.2OE-06 1.75E-OS
1.00E+OO NA
3.70E-06 6.41E-05
5.00e-02 NA
1.70E+02 3.4:£+03
NA NA
5.00E-OZ NA
NA NA
5.00E-02 NA
5.00E-02 1.00E-01
1.441:-04 1.481:-04
1.3E-01 1.00E-01
5.00E-02 . NA
1.3OE-02 4.eaE-02
NA NA
5.00e+OO NA
2.00E-Q1 NA
1.00E-01 NA
4.00E-01 2.8OE+00
4.00E-01 2.eoe+00-
NA NA
NA 4.88E-01
NA NA
Fresh Water
Criteria for prot8C1iOn of
Organisms
Acute
(mg/U
9.00E+00
3.8OE-01
NA
1.30E-01
1.8OE-02
9.8OE-01
NA
1.8OE-02
NA
8.20E-02
NA
2.4OE-03
1.8OE+00
4.10E-03
1.4OE+OO
NA
3.2OE-01
2.20E-02
NA
U2E+00
1.12E+00
NA
2.5OE-01
NA
Chronic
(mg/U
1.8OE+OO
1.SIOE-01
NA
5.3OE-03
1.10E-02
1.20E-01
NA
'1.2OE-02
NA
3.2QE-02
NA
1.2OE-05
9.8GE-02
1.2CE-04
4.00e-02
NA
4.7OE-02
5.2OE-03
NA
7.83E-01
7.83E-01
NA
5.00e-02
NA
SOUrcll: ,IRIS. U.S. EPA Hedt'I EIfICtI AIIaIment Summary Tab188 for 1881. U.S. EPA Quality Crtt8ria for W".
May. 1988. U.S. EPA Drinking Water ReguJatian8 and H88Ith AdviIori88. April 1881. '
NA - Not Available
(8) Riverine corftAt.b.uwn appJi. to the point wh8r8 the ground - m... the river.
Riverine cor-.b.tion - maximum concentration 'X dilution tactDr
(b) For lack of 8peci88-8pecific information, one tenth of the totIIJ chromium WU U8Umed to be in the '
hexavalent 8t8te. The maximum Cr (+6) valueli8ted W88 calcUlated .. 1/10. max concentration of tDtIIJ Cr.
-------
TABLE
3
SYrnm8Y of CtYomurn and Pot;u..,..t8d ~ R88&*
Fer th8 NO\I8f'I108f 1988 RIwr s....dio.18fIt S8mpI88 ia)
J.IIco An8cGnda Sit8
Gn8d8nt'UII8n. Ohio
POLYCHLORINATED .
SAMPLE lDemFICATION TOTAL CHROMIUM BIPHENYLS :1
("..a) (DI (~a) '\
I u......: I
'I RS-2-1 .38 O.18U (ej
RS-2-2 70 O.18U
RS-2-3 78 O.18U
RS-2-4 67 O.18U
RS-2-5 83 O.18U
RS-2-6 61 O.18U
, RS-2-7 82 O.18U
ir RS-2-8 74 O.18U
RS-2-9 51 O.18U
'\ O.18U
I Ad"''' Plant I O.18U
; RS-4-2 78 O.18U
I RS-5-2 120 \' O.18U
RS-6-2 82 O.18U
RS-7-1 120 O.18U
RS-7-2 60 O.18U
RS-7-3 68 O.18U
RS-7-4 . 0.18U
RS-7-5 81 O.18U
RS-7-6 58 0.18U
RS-7-7 58 O.18U
RS-8-2 120 0.1'"
RS-8-2 100 0.4""
RS-10-1 180 O.18U
RS-10-2 IS O.18U
RS-10-3 85 0.18U
RS-10-4 2St O.18U
RS-10-5 32 O.18U
RS-11-2 48 0.18U
RS-12-2 55 0.11(8) -
o...........m:
RS-14-1 120 O.18U
RS-14-2 65 O.18U
RS-14-3 71 O.18U
RS-14-3 67 O.18U
RS-14-5 40 O.18U
RS-14-6 51 O.18U
RS-14-7 48 0.18U
RS-14-8 100 O.18U
~...,oda RS-1.2.3 T,.".... 17 O.18U
c....."oMI R8-4.5.8 T,.".... 38 O.18U
c...."," ---. R8-7""""""" 48 o.18U
COI.~ """"RS-10.1'.12Tr8888 33 O.18U
c...."..... RS-13.14.15Tr8888 sa 0.18U
NOTES:
-------
TABLE <1
FINAL CONSTITUENTS OF CONCERN
Aisco Anaconda Site
Gnadenhutten, Ohio
1,2-DichlorobenZene
1 ,4-Dichlorobenzene
Antimony
Arsenic
Barium
Beryllium .
bis(2 -ethylhexyt)phthaJatB
Chlorobenzene
Chromium (+6)
CobaJt
Copper
Fluoride
Lsad
Manganese
Mercury
Nickel'
NItrate
Silver
ThaJUum
T0ta8 Chromium
Total Cyanide
Vanadium
Xylenes
Zinc
\\0 I
''\
-------
TABLE. 5
RECREATIONAL SCENARIO ~ SUMMARY OF CARCINOGENIC RISK
Alsco Anaconda Site
Gnadenhutten. Ohio
Cancer Slope
Route of Intake' Factor
Age Group exposure (mg/kg/day) (mg/kg/day)-1 Risk
0-6 Oral 2.0E-11 1.75 3.6E-11
0-6 Dermal 9.3E-13 1.94 1.8E-12
0-6 Fish Ingestion 3.9E -08 1.75 6.9E-08
Adult Oral 1.7E-11 1.75 3.1 E - 11
Adult Dermal 2.0E-12 1.94 3.9E-12
Adult Fish Ingestion 3.4E -08 1.75 5.9E-08
0-6 Oral 5.8E-12 4.3 2.5E-11
0-6 Dermal 2.6E-13 86.0 2.3E-11
0-6 Fish Inge.tion 2.3E -09 4.3 9.9E-09
Adult Oral 5.oe-.12 4.3 2.1E-11
Adult Dermal 5.7E-13 86.0 4.9E-11
Adult Fish Ingestion 2.0E-09 4.3 8.5E-09
0-6 Oral 3.8E-12 0.014 5.1E-14
0-6 Dermal 3.0E-15 0.016 4.6E-17
0-6 Fish Ingestion NA 0.014 NA
Adult Oral 3.1E-12 0.014 4.4E-14
Adult Dermal 6.4E-15 0.016 1.0E-16
Adult Fish Inge.tion NA 0.014 NA
Child Total = 8E-08
Adult Total - 7E-08
Constituent
Ar.enic
Beryllium
Bls(2 -ethylhexyl)phthalata
NOTE:
NA = Bloconcentration factor not available.
-------
TABLE 6
RECREATIONAL SCENARIO - SUMMARY
OF NONCARCINOGENIC HAZARD INDICES
Alaco Anacand8 Site.
Gnadentlutten. Ohio
Total HI Total HI
0-6 Aqe8 Adult
Central Nervou8 System. Arsenic 0.08 0.02
Cyenide
Mang."..
M.cury
Th8IIIum
Vanedium
Xy18n88 .
1.4-Dlchlorobenz....
ChIorobenzene
Bla(2-8Ihythexyt)phth818t8
Cardicw8acul8r Ar88f'lic 0.0005 0.0001
Barium
NItr8t88
Xyten.
BlOOd NItrat88 0.02' 0.004
Zinc
Copp.
Renal Chrcamium (+6) 0.14 0.03
Chromium (Tot8I)
Mercury .'
Th8IIium
V8n8dium.
1.2-Dichlorobenzene
Xy1an88
Hepatic Anenic 0.08 0.02
Baryllium
Chromium (+8)
Chromium (Tot8I)
Mang."...
Xy1ene8
Gastrointntinal Anenic 0.02 0.004
AntImony
Cop.,.
V8n8dium
Zinc
Immunological Zinc 0.0003 0.0D005
D.m8tological Anenic 0.07 0.01
BeryllIum
Qvarnium (+8)
Chromium (Tot8I)
Cob8It
NIck..
SIIv8r
'ThIIIIIum
Reproductive ~ 0.01 o.OOS
D8V8IopmentaA B8rium 0.02 0.004
Copp.
FIourIde
Genetic AntImony 0.00002 0.000004
BarytUum
NOTES:
NA a Bioconcenvation factor not available
NO = 0088 not bi08ccumul8t8/bioconcentrate
-------
TABLE 7
RESIDENTIAL SCENARIO - SUMMARY
OF NONCARCINOGENIC HAZARD INDICES
AI.co AnllConda Site
Gnad.nhutl8n. Ohio
Total HI Total HI
0-6 Aa.. Adult
C.n..al N.rwu. Sy.t8m Ar88nic. 15.8 6.8
Cyanid.
Manpnne
Mercury
ThaIIUn
Vanadium
Xy..,..
1 .4 -Dlc:hIorob8nZ8"8
Chlarobennne
BI8(2 -.thylh.xyI)ph1h8lat8
Cardlovaacul8r Araenic 3.0 1.3
BariUm
Nib'"
Xy"'"
Blood NItra.. 0.' 0.3
Zinc
Copper
R.nal Chromium (+8) 2.3 1.1
Chromium (Total)
Mercury
ThaIIUn
V...dIum
1.2 -Olchloroben&8M
Xy18na8
H.patlc Ar88niD 8.1 3.8
Beryllium
Chromium (+6)
Chromium (Total)
Manpn888
Xy18n88
aa...ointeatinal Ar88No 4.2 1.8
A..llmony
COJtP8I'
ZInG
Vanadium
Immunological ZInc 0.1 0.04
Oermatolo9ica1 Ar88ftio 3.8 2.1
BeryllIum
Ctwamlum (+8)
Ctwamlum (Total)
Cabd
NIde..
...
TIIdum
Raproduc:1lv8 """'" 8.7 2.8
O.wlopm.ntal B8rium 7.4 3.1
CoPP8'
FIouride
G.n.tic Antimony
s.ytllum 1.4 0.8
- : '"
-------
TABLE 8
- RESIGENTIAL SCENARIO - SUMMARY OF CARCINOGENIC RISK
Alsco Anaconda Site ... .
Gnadenhutllln, Ohio
Canc8' Slope
Route of Intake Factor
Constituent Age Group ExPos," (maJkg/dav) (mg/kg/day) -1 Risk
ArHnic 0-6 Oral 1.53E-04 1.75 2.7E-04
0-6 Dennal 1.15E-07 1.94 2.2E-07
Adult Oral 2.63E-04 '1.75 4.6E-04
Adult Dermal 1.51E-07 1.94 2.9E-07
8erytlium 0-6 Oral 2.19E-05 4.3 9.4E-05
0-6 Dennal 1.65E-08 86.0 1.4E-06
Adult Oral 3.76E-05 4.3 1.6E-04
Adult Dermal 2.15E-08 88.0 1.9E-06
8is(2-ethythexyt)- 0-6 Oral .9.86E-05 0.014 1.4E-06
phthalate 0-6 Dermal 1.34E-09 0.016 2.1E-11
Adult Oral 1.69E-04 0.014 2.4E-06
Adult Dermal 1.75E-09 0.016 2.7E-11
1,4-0lchlorob8nzene 0-6 Oral NA NA NA
0-6 Dermal NA .NA NA
0-6 Inhalation 6.o4E-06 0.024 1.4E-07
Adult Oral NA NA NA
Adult Dermal NA NA NA
Adult Inhalation 9.85E-05 0.024 2.4E-06
Child tat8I - 4E-04
Adult taI8I .. 6E-04
NOTE:
NA - Not Applicable
-------
.. Carcinogenic Risk
TABLE 9
Summary of Total Site Risk
Alsco Anaconda Site
Gnadenhutten. Ohio
Noncarcinogenic Hazard Indices:
Central Nervous System
Cardiovascular
Blood
Renat -
Hepatic
Gas1rointestinat
Immunologicat -
Dermatologicat
Reproductive
Developmental
Genetic
Child
0-6
4E-Q4
16.0
3.0
0.6
2.4
9.2
4.2
0.1
3.9
6.7
7.4
1.4
Adult
6E-04
6.8
1.3
0.3
1:0
3.8
1.7
0.04
. 2.1
2.8
3.1
0.6
NOTE:
Risk values and Hazard Indices are the sum of values for the
residentiat and recreationat scenarios.
-------
,
Type
of
ARAR
c
A
A
A
A
A
L
A
A
A
L
c
c
A
A
Table 1 0
SUMMARY OF APPLICABLE OR RELEVANT AND APPROPRIA IE HEQUIREMENTS
(ARARs)
Ground Water Operable Unil
Aisco Anaconda 811e, Gnadenhunen, Ohio
---,-- ------. u_----
Applicable Of Relevana and AI...atlv8 1 Allemallve 2 Allernallve 3 Allemallve 4
Appropriate Requlrem8'l" No Action - Nalural flushing and Anenuallon Ground Water Extracllonl Uydraullc Barrier and
(ARARs) and Other Advisories Nalural AlienuaUon Glound Water and SedIment T leatmentlDlschargelOround Ground Watel ExtracUon
Monhorlng Waler and Sedlmenl Moollollnll T realmentlDlscharoelGround
-+----. -.. -+_.+---- Wal!!!! Sed~~~ ~~~~~!~g
Resource Conservallon and Does nOl comply wllh CO!"PIIes wllh 40 CfR 264 Complies with 40 CfR 264 CompIlIJS wllh 40 CFR 264
Recovery Act (RCRA) 40 CFR 264 Subpart F Subpart F Subpart F Subpart f
~~ ~ 264 Subpart F --..-.. - --"----.- -+-- --. --- --- . ----
40 CFR Pan 262 NA NA Complies with 40 CfR Part 262 Complies with 40 CfR Part 262
40 CFR Part 263 NA NA Complies wllh 40 CF~ Part 283 Complies with ~~ Cf!! Part 26~
40 CFR Part 264 NA NA Compiles with ~~ Part 264 Complies wlt~ ~~ CF!! ~!!! ~~~
--
40 CFR Part 264.100 Does nOl comply with Complies with 40 CFR 264.100 Complies with 40 CFR 264.100 Complies wll1140 CFR 264.100
40 CFR Part 264.100
--.-- --. -- - -_.---
40 CFR Part 264.117 Does nOl comply with Complies wllh 40 CfR 264.117 Complies wilh 40 CFR 264.117 Complies wiltl 40 CfA 264.117
40 CFR Part 264.117
-- T .. --..- -----.---- -....--.-- -.--- - .-
40 CFA Pari 264. 18(b) NA NA Complies with 40 CFR Complies with 40 CrA
Pa~~64:!8(bt ~!!!~:!8(bl-- .. -..- w_.
40 CfA Part 264 Subpan E NA NA Complies with 40 CFR Pan 264 Complies with 40 CfA Part 264
SubP!~ ~---- Subpa'! ~-- ----- - _. ---- -
40 CFR Part 264 S~bpart X NA NA Complies with 40 CFR Complies wilh 40 CFA
J Subpa~ ~ - SubP!~~--- _..
., --.-..-----.
40 CFR Pari 268 NA NA Complies wilh 40 CFA Part 268 Compll~~ CFA Part ~68
40 CFR Part 6 Appendix AI NA Complies wllh 40 CfR Part 6 Complies wllh 40 CFR Part 6 Complies with 40 CFR Part 6
executive Order 11988 Appendix AlExec. Older 11988 Appendix AlExec. Order '! 988 . ~pp!.ndl~ ~~)(~; ~~~! ! ~ ~~~
-.-
Sa'e Drinking Water Act MCU are achieved aller MCLs ar. achieved allll MCls are achieved In Irealed MCls are achieved In Iroated
natural ahenuallon natulal aUenualion ground water g~~~~ ~~! -
-.-----.---- .. -.
Section 303 and 304 CompO. wllh Ct.an Wat~r Act Complies wllh Clean Water Act ComplllJS with Clean Water ACI Complies wllh Ctean Weiler Act
Ct.an Water Act Secllons 303 and 304 Secllons 303 and 304 Sections 303 and 304 Sections 303 and 304
. - - ---.. ------- - -.-
Section 402 Ctean Water Ac8 NA NA Complies wllh Clean Waler ACI, Compll85 with Ctuan Waler Acl.
(National Pollutant Discharge Section 402 Section 402
Elimination Svstem) '-.-..- ------- --..-----
Occupallonal Health and Sa'eI, NA Compiles with 28 CFR 1810 Complies with 29 CfR 1810 Complies with 29 CFR 1910
ACI 29 CFR 1910 -
- --. n .. -_._- ..------- +-..- -. -
-------
Type
of
ARAR
Table I 0
SUMMARY OF APPLICABLE OR RELEVANT AND APPROPRIA It; REQUIREMENTS
(ARARs)
Ground Water Operable Unit
Alseo Anaconda She, Gnadenhutten, Ohio
A
-~ --
AppIIcUI8 or ReIevanI and AIIernatlve1 AUernatlve 2
Appropriate Requirement. No Action - Natu,al flushing Ind "nenuallon Groll
(ARARs) and Other AdvIsorteI Natural Allenuatlon Ground Water and SedIment Treat
Monhoflng Waler a
--.-
Ohio Admlnlstratlv8 Code: 00II no8 comply wtIh Compll.. with Complies
Ground Water Protection Section 3745-54-92 Section 3145-54-92 Section 3
Secllon 3745-S4~92
- .~..
Ohio Revised Code: Acts Does nol comply with Complies with Section 6111.04 Complies
01 Pollution Prohlbhed Section 6111.04
Seellon 6111.04
Ohio Admlntstrat've Code: 8IIt8 Complies with Section CompU.. wllh Must co
Waler Quality Standards Section 3145-1-07 Section 3145-1-07 3745-1-
Seellon 3745-1-07
Ohio Revised Code: Approval NA NA Complie
01 Plans lor Disposal 01
Waste, Secllon 6111.45
.-
Alternative 3
nd Wat. Extracllonl
mentIDIsct'8rgelOraund
Ad Sediment Monitoring
with
145-54-92
with Seetlon 6111.04
A
c
mply with Secllon
07
s with Seellon 6111.45
A
At &CO ANACONDA TEa XlTAIIlE...t..U
A= Action-specific
C= Chemical-specific
L= Location-specific
"
------------... n-__-
Alternatlv' 4
ttydraullc Barrier and
Ground Waler Ext, acllon
T realmenllDlsctlargelGrouml
Wat!! ! Sediment ~~!!~~!!!g
Complies with
Section 3145-54-92
---- -- --
Complies wilh Seelion 6 t 11.04
. -------_..- - ..- --' . .. .
Must comply wilh Seellon
3745-1-07
--.-.- -.-. .
.... .-- .. .....
Complies wilh Seellon 6111.45
-------
TABLE 1 1
Cost Estimate lor Alternative 2
Ground Water and SedIment Monitoring
CAPITAL COSTS
lIem
Unit Cost
Units
,
~
I. Sampling and Analysis Plan Preparallon
A. labor
B. Expenses (computer usage, copying, mailing
costs. etc.)
II. Shallow Monitoring Weilinsialialion (2-lnch PVC wells
Installed to an average depth of 40 1881) .
III. Deep Monitoring Weliinstalialion (2-lnch PVC well
Installed to an assumed depth of 100 leel)
IV. Background Weilinslallation (2-lnch PVC wells Installed
to an average depth 01 40 leel)
60 I hour
2,000 'lS
150
1
9.000
2,000
2.000 Iwell
1
14.000
10.000 Iwell
2.000 Iwell
10.000
3
6.000
SUBTOTAL
CONTINGENCY AND OVERHEAD (20%)
TOTAL CAPITAL COST
41.000
8.200
49,200
OPERATION AND MAINTENANCE (0 & M) COSTS
Item
Unit Cost Units ~
950 Isample (a) 36 34.200
125 Ireport 4 500
915 'sample (a) 3 2.925
300 'sample (b) 12 3,600
200 Isample 6 1.200
80 Ihour 80 6,400
80 /hour 60 4.800
53.625
n.m
64.350
I. Annual a & M Costs. Years 1 and 2
A. Sampling and Analysis 01 Groundwater on a Quarterly
. Basis (9 samples/quarter; cost Includes labor and
equipment lor sample collection)
B. Quarterly Reports 01 Chemical Analysis Results
For Groundwater Samples
C. Sampling and Analysis 01 Background Wells (1 samplel
weillyear; cost Includes labor.lqulpment. and reporting
0' resuns)
D. Sampling and Analysis 01 Sediments on an Annual
Basis (12 sampleslyear; cost Includes labor and
equipment for sampre collection)
E. Collection 01 Macrolnvertebrate Samples (6 samples/year.
Including 3 backup samples; cost Includes labor and
equipment for sample collection)
F. Biological Analysis of S Macrolnvertebrate Samples
G. Briel Report Summarizing the Relulll of the Macroln-
vertebrate and SedIment Sampling and Aftalysls
SUBTOTAL
CON11NGENCY AND OVERHEAD (20CMI)
-------
TABLE 11(conl'd)
PRESENT WORTH 0 & M COST, YEARS 1 AND 2
($64,35OJyear for vears 1 and 2 . a 5~ discount rate)
Item
II. Annual 0 & M Cost.. Vea,. 4, 6, 8. and 10
A. Sampling and Anal. at Groundwater on a Semi-Annual
Basis (9 sampleslhall year; cost Includes labOr and
equipment lor IImple collection)
B. ~I-Annual Report. of enemlcal Ana.l~s,l.t ~esults f.- 1 . 'i:.: :,'h,.
For Groundwat. Samples i "~': -~~, ',If!:.
C. Sampling and Analysl. of Sediments on an Annual Basis
(12 aampleslVear; COSt Includes labor and equipment
lor sample colleclion)
D. Collection 01 Macrolnvertebrate Samples (6 samples/year,
Including 3 backup samples: cOlt Includealabor and
equipment for IImpl. collection)
E. Biological Anal- of 3 Macrolnvertebrale Samples
F. Briel Report Summarizing the Reaun. 01 the Macroln-
vertebrale and Sediment Sampling and Analysis
SUBTOTAL
CON11NGENCY AND OVERHEAD (20%)
ANNUAL 0 & M COSTS, YEARS 4,6, 8, and 10
PRESENT WORTH 0 & U COST. VEARS 4, 6. 8, and 10
($39,8401year lor vears 4,8,8. and 10 ~ a 5°" dlscounl rate)
III. Annual 0 & U COSI., Years 3, 5, 1,9, and 11 thrpugh 30
A. Sampling and AnalySIS 01 Groundwaler on a Sdml-Annual
Basis (9 sarnpleslhall vear; cost Includes labor and
equipment 101 IImple collection)
B. Semi-Annual Report. 01 enemlcal Analysis Results
For Groundwat. Samples
SUBTOTAL
CONl1NGENCY AND OVERHEAD (20°.41)
ANNUAL 0 & U COSTS, YEARS 3,5,7,9, and 11 THROUGH 30
PRESENT WORTH O&MCOST, VEARS 3, 5, 7, 9. and 11 THROUGH 30
(82O,82OfW8U lor year. a,s, 7, 8, and 11 through 30 . . 5.. dl8caunl rate)
119.700
Unit Cost Y!!!1! ~
950 Isample (a) 18 11,100
125 ',eport 2 250
300 Isample (b) 12 3,600
115 Isample 6 1,050
80 Ihou, 80 6,400
80 /hour 60 ugg
33,200
6,640
39.840
113,900
950 Isample (a)
17,100
18
125 " eport
2
~
17 ,350
uzg
20,820
-------
TABLE 1 1 (cont'd)
lIem
TOTAL PRESENT WORTH 0 & .. COST, YEARS 1 THROUGH 30
NET PRESENT WORtH COST FOR AlTERNATIVE 2
(ratal capilli COlI . TOIII ,.nwonh 0 &.. COSI)
,
,
(a) Analysis '01 Ta. voIalile organic compounds. TAL melals, cyanide, and nuorlde.
(b) An.lrsl. '01 PCBa and lotll chromium.
LS-Iumo sum
Casl (f)
455,400
,
504,600
/
-------
TABLE 1 2
CosI Estimate lor Alternative 3
Ground Water Exlrac:tlonlTreatmentJDlscharge
CAPITAL COSTS
"
Item
Unll Cost
Unlls
Cost ($)
r. Sampling and Analysis Plan Preparation
A. Labor
B. Expenses (computer usage, copying, mailing
costs, etc.)
II. Shallow Monitoring Well Installation (2-lnch PVC wells
Installed to an awrage depth 01 40 leeI)
III. Deep Monitoring wen Insaallallon (2-lnch PVC well
Installed to an assumed depth 01 100 leeI)
tV. Background WeltlnslaUatlon (2-lnch PVC wells Installed
to an average depth 01 40 leet)
V. Recovery Weliinstallalion (t2-lnch PVC wells
Instanedto .n average depth of 40 1811)
VI. Recovery Well Equipment (pumps, piping, etc.)
VII. Groundwater Treatmenl System Design and Inslallallon
(assumed 500 gpm capacity)
VIII. Preparation 01 NmES Permillor Discharge 01 Trealed
Waterato thl Tusearawu River
60 1 hour
2.000 ILS
150
1
2.000 Iwell
1
9,000
2,000
14,000
10,000 Iwell
. 2.000 Iwell
8,000 Iwell
3.
5
10,000
6,000
60 Ihour
1
1
60
40,000
10,000
1,400,000
10,000 ILS
1,400,000 /LS
3.600
SUBTOTAL
CON11NGENCY AND OVERHEAD (20%)
TOTAL CAPITAl COST
1,494,600
298.920
1,193,520
OPERATION AND MAINTENANCE (0 & ..n COSf~
lIem
Unit Cost Units ~
950 Isample (a) 36 34,200
125 Ireport 4 500
915 Isample (a) 3 2,925
300 Isample (b) 12 3,600
I. Annual 0 & M Costs, Years 1 and 2
A. Sampling and AnalySIs 01 Groundwater on a Quarterly
Basis (9 samples/quart...; cost Includes labor and
equipment for sample collection)
B. Quarterly Reports of Chemical Analysis Results For
Groundwater Samples
C. sampling and Analysis 01 Background Wells (1 samplel
wellIyear; cOlt Inctudes labor.lqulpment, and report-
Ing 01 results)
D. sampling and Analysis 01 Sedlmenls on an Annual Basis
(12 sampleslylar; COSllncludeslabor and equipment
-------
lIem
TABLE 1 2 (COOI'd)
Unit COSI
200 Isample
Unlls
~
"
E. Collecllon 01 MacrolnV8f1ebrale Samples (6 sampleslyear.
Including 3 backup samples: cost InclUdes labor and
equipment lor sample collection)
F. Biological Analysis 013 Macrolnvertebrate Samples.
G. Briel Report Summarizing the Resulls Onhe Macroln-
vertebrale and Sediment Sampling and Analysis
H. Operallon and Maintenance 01 Groundwater Exlractlon
and Trealment System
SUBTOTAL
CONT1NGENCV AND OVERHEAD (200Al)
ANNUAL 0 & M COSTS. VEARS 1 AND 2
PRESENT WORTH 0 & M COST. VEARS 1 AND 2
($424.35Wyear lor ,ears 1 and 2 . a 5"" discount rale)
II. Annual 0 & M Costa. Vears 4. 6. 8, and 10
A. Sampling and Analysis 01 Groundwater on a Semi-Annual
Basts (9 sampleslhall year: cost Inctudes labor and
equipment lor ample collection)
B. Semi-Annual Reports 01 Chemical Analysis Resulls
For Groundwater Samples
C. Sampling and Analysis 01 Sedlmenls on an Annual
Basts (12 sampleslyear; cost Inctudes labor and
equipment lor sample cotlectlon)
D. CoIlecllon 01 Macrolnvertebr"l Samples (6 s~mpllslyear.
Including 3 backup samples: cost Includes labor and
equipment lor sample cotlectlon)
E. Biological Anatysts of 3 Macrolnvertebrall Samples
F. Briel Report Summarizing the Resufts 01 the Macrotn-
vertebrate and Sediment Sampling and Analysts
G. Operallon and Malntenanc. 01 Groundwaler extraction
and Treatment System
SUBTOTAL
CON11NGENCY AND OVERHEAD (20%)
ANNUAL 0 & M COSTS. VEARS 4.6, 8, and 10
PRESENT WORTH 0 & M COST, VEARS 4, 6. 8. and 10
(S400.02Olyear lor years 4.6. 8. and 10 @ a 5"" dlscounl rail)
6
I 1,200
80 Ihour
80 thour
80
60
6,400
4,800
300,000 Iyear
300,000
353,625
70.725
424,350
789,000
950 Isample (a) 18 17,100
125 Ireport 2 250
300 Isample (b) 12 3,600
200 lsample 6 1,200
80 Ihour 80 6,400
80 thour 60 4,800
300,000 Iyear 300.000
333,350
66,670
400,020
-------
TABLE. 1 2 (coord)
lIem
III. Annual 0 & M Costs. Years 3.5. 7. 9. and 111hrough 30
A. Sampling and AnatyslS 01 Groundwater on a Semi-Annual
Basis (9 sampleslhall year; cost Includes labor and
equlpmen1lor aample coIlecllon) .
B. Semi-Annual Report. 01 Chemical Analysis Results
. For Groundwat. Samples
C. Operallon and Maintenance 01 Groundwater Exlracllon
and Treatment System
SUBTOTAL
CON11NGENCV AND OVERHEAD (20%)
ANNUAL a & M COSTS. YEARS 3. 5. 7. 9. and 11 THROUGH 30
PRESENT WORTH 0 & M COST. YEARS 3.5.7.9. and 11 THROUGH 30
($38O.82CJ1year lor years 3. 5. 7. 9. and 11 Ihrough 30 f!1 8 5-.. discount rate)
TOTAlPRESENTWORTHO&MCOST. YEARS 1 THROUGH 30
Unll COSI
950 Isample Ca)
125 Ireport
300,000 Iyear
UnllS
Cosl ($)
18
11,100
2
. 250
1
300,000
311,350
63.470
380,820
4,057,000
5.989.900
NET PRESENT WORTH COST FOR AlTERNA11VE 3
(Total capital cost. Total present wonh 0 & M cost)
7.783.420
J
.
Ca) Analysis lor TCL voiatlle organic compounds, TAL melals. cyanide. and 'Iourlde.
(b) Analysis 'or PCBs and total chromium
-------
TABLE 1 3
Cost Estlmale 'or Allernallve4
Hydraulic Barrier and Graund Wli. ExtrICtIonlf.ealmentIDlscharge
CAPITAL COSTS
Item
Unit Cosl
I. S:~t:'r: and Analysis Plan Preparation 1'::4.'..
B. Expenses (compuler usage, copying, mailing
costs, 1Ic:.)
II. Shallow Monitoring Well Installation (2-lnch pvc wells
Installed 10 an awra... dtpIh o' 40 1eeI)
III. Deep Monitoring WeI,nstallallon (2-lnch PVC well
Installed 10 an allUmed deplh 01100 '881)
IV. Background WelllnllaIIlllon (2-lnch PVC wells Inslalled
10 an averlge deplh 0140 feel)
V. AecoveryWeIIIRII8IIation (12-lnch PVC wells
Installed 10 an -age depth 0140 '181)
VI. Recovery Will Equlpmem (pumps, piping, elc.)
VII. Groundwat. T.lalmlnl system Design and Inslallatlon
(assumed 500 gpm capacity)
VIII. Preparation 01 NPOES Permillor Discharge 01 Trealed
Waler.lo Ihi Tuscarawas RIver
IX. Slurry Wallinstailition
X. Inlectlon WeIIlnltanatlon
A. Inlectlon Weill (12-lnch PVC weill Installed 10 an
average depth of 40 'eeI)
B. DesIgn and Instalatlon of Inlectlon Well Waler JJ
Supply System (system would UII the TUSClrawas
Alver IS a water IOUrcl and provldl 'or Ireatment
d. Ihe RIM water prior 10 Injection )
C. Inslallatlon d. PIezometers to Monitor Groundwaler
Bevallona and Help Delermlne Optlmallnlectlon
Aales (1-lnch PVC piezometers Installed 10 an
average deplh 0140 ._)
SUBTOTAL WITH SLURRY WALL II INJECTION WELLS .
CQN11NGENCY AND OVERHEAD~) V\IITH SlURRY WALL II INJECTION WELLS
.
: - :,--~~:; ~~..
60 I hour
2.000 ILS
2.000 Iwell
10,000 Iwell
2,000 Iwell
8,000 Iwell
10.000 IlS
1.400,000 IlS
60 /hour
30 Isq. II.
8,000 Iwell
125,000 ILS
1,500 Iplez.
TOTAL CAPITAL COST wrrH SLURRY WALL
TOTAL CAPITAL COST WITH INJECTION WELLS
Unilli
150
1
31,750
2,447,100
489,420
7
3
5
1
1
60
5
1
4
"
~JI)
9,000
2,000
14,000
10,000
6.000
40,000
10.000
1,400,000
3,600
952.500
40,000
125,000
6,000
II
II
1.665,600
333,120
2.936.520
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TABLE 1 3 (cont'd)
OPERATION AND MAINTENANCE (0 & N} COSTS
Item
I. Annual 0 & M ColI, Vea,,' and 2
A. 8ampRng and Anal. 01 Groundwat. on a Quarterly
Basis (9 sampl8llquan.: cost IncludeS labOf and
equipment 'Of IInIple collection)
B. Quarterl, Reportl 0' Chemical Analysis Results
For Groundwat. Samples
C. Sampling and Analysis 01 Background Wells (1 samplel
welUyear; C06t Includes labOr, equipment, and reponing
of resuns)
D. Sampling and Analysis 01 Sediments on an Annual Basis
(12 lampleslyear; cost Includesllbor and equipment
lor sample collection)
E. CoIlecllon o' MacroInvertebrate Samples (6 samples/year;
cOSllncludlllabOr and Iqulpment for ample collectIOn)
F. Biological Analylll 0' 3 Uacrolnvertebrat. Samples
G. Briel Report SummarIZing the Resultl of the Macroln-
venebrat. and Sediment Samplng and Analysll
H. Operation and Maintenance o' InlICtlon wen SyStem
I. Operallon and Maintenance 01 Groundwater extraction
and Tr..'m- System
SUBTOTAL WITH SLURRY WAll II INJECTION wellS
CONTINGENCY AND ovetHEAD~) WITH SlURRY WAll II INJECTION WEllS
ANNUAL a & M COSTS, YEARS 1 AND 2 WJTH SLURRY WAll'
ANNUAL 0 & M COSTS, YEARS 1 AND 2 W.TH INJECTION WEllS
PRESENT WORTH 0 & M COST. YEARS 1 AND 2 WITH SLURRY WAll
($424.3501ye1r tOt ,ea" 1 and 2 . a 5~ discount ratl)
PRESENT WOR11t 0 & M COST. YEARS 1 AND 2 WITH INJECTION WellS
($484.35Q/ye1r lor '88rl 1 and 2 . a 5~ discount ra,.)
II. Annual a & M Costs. Years 4, 6. 8, and to
A. SamplIng and ~,. 01 GroundWlt- on a Semi-Annual
Basil (8 arnpIIMIaI' yur; cOSllnctud.labOf and
equipment 'or ampll callectlon)
B. Semi-Annual AIpoIII 01 Chemical Analysis Results
For Groundwlt. Samples
C. Sampling and Analysis 01 Sediments on an Annual Basis
(6 sampleslhalf year; cost Includ8llabor and
,- -... __a ,-- ....""'"..... ",,,UAt""tlnn\
.'
lInil CoSI
Yn!1J
36
4
3
12
6
80
60
1
1
353,625 . II
70,725 II
950 Isample (a)
125 Ireport
975 Isample (a)
300 Isample (b)
200 Isample
80 /hour
80 Ihour
50,000 Iyear
300,000 Iyear
. .
,
~
34.200
500
2,925
3.600
1.200
6.400
4,800
50;000
300.GGG
403.625
80,725
424,350
484,350
789.000
900,600
950 Isample (a) 18 17,100
125 Ireport 2 250
-------
TABLE 1 3 (conl'd)
Ilem
D. Collection of Macrolnvertebrale Samples (6 sampleslyear.
Including S backup amplest COlt Includ..labor and
equipment for ample collection)
E. Biological Anal- 0' :I Macrolnvertebrale Samples
F. Briel Report Summarizing the Resull. of the Macroln-
verlibrale .nd Sediment Sampling and Analysis
G. Operallon .nd M.lnlenance ollnlldlon Well Syslem
H. Operallon .nd Maintenance 01 Groundwater Extracllon
and Treatment S,.-
SUBTOTAL WITH SLURRY WALL II INJECTION WELLS
CON11NGEHCY AND OVStHEAD~) WITH SLURRY WALllllNJECTtON WELLS
ANNUAL 0 & U COSTS. YEARS 4. 6, 8, and 10 WITH SLURRY WALL
ANNUAL 0 & M COSTS. YEARS 4.8. 8. .nd 10 WITH INJECTION WELLS
PRESENT WORTH 0 & M COST. YEARS 4. 6. 8. & 10 WITH SLURRY WALL
(8399.l4OIyear for Y88,. 4.8.8. and 10. a 5~ discount rate)
PRESENT WORTH 0 & M COST. YEARS 4.6.8. & 10 WITH INJECTION WELLS
($459.84Ofyear lor Y8811 4.6.8. and 10" a 5~ discount rate)
III. Annual 0 & M Cos8. Year. 3. 5. 7. 9. and 11 through 30
A. Sampling and Anal,... 01 Groundw... on . Semi-Annual
Basis (9 sampleslhall year. COSIlnciudes labor and
equipment '01 umpte collection)
B. Seml-Annuat Report. of Chemical Analysis Resulls
For Groundw.t. Sampl.. '
C. Operallon and Maintenance ot InJecllon Well System
D. Operation .nd M.lntenance 01 Groundw.t.. extraction
and Treatment System
SUBTOTAL WITH SLURRY WALL II INJECTION WELLS
CON11NOENCY AND OVStHEAD~) WITH SLURRY WALl II INJECTION WELLS
ANNUAL 0 & U COSTS. YEARS 3, 5, 7, 9, and 11 THROUGH 30 WITH SLURRY WALL
ANNUAl 0 a M COSTS. YEARS S. 5. 7. e. and 11 THROUGH SO WITH INJECTION WELLS
.
Unit Cost
175 Isampte
80 Ihour
80 /hour
50.000 Iyear
300.000 Iyear
950 Isampte (a)
125. Ireport
50,000 Iyear
300.000 ~ear
Units
~
,
'1,050
6
80
60
6,400
4.800
50,000
300,000
333,200
88,640
II
II
383,200
78,640 .
399,840
459.840
1,143,400
1,315,000
18 17,100
2 250
1 50,000
1 . 300.000
317,350 II 367,350
63,470 II 73,470
380,820
-------
TABLE 1 ~ (coord)
lIem
PRESENT WORTH 0 & M COST. YEARS 3.5.1.9, and 11 THROUGH 30 WITH SlURRY WALL
(838O.82Qfy8ar for ,.,. 3.1. 7. t. and 11 through ao @II W cIacount 'III)
PRESENTWOFmt 0 & M COST. YEARS 3. 5. 7.8, and 11 THhOUGH 30 WITH INJECTION WEllS
(1440.82Qfw8u for ,.,. 3. 5. 7. t. and 11 through 30 ., I 5. discount ratl)
TOTAl PRESENT WORTH 0 & M COST. YEARS 1 THROUGH 30 WITH SlURRY WAll
~
4,0/1,000
4,696,200
TOTAL PRESENT WORTH 0 & M COST. YEARS 1 THROUGH 30 wrrn INJEcnON WEllS
5.989.400
6.911.800
NET PRESENT WORTH COST fOR AlTERNATIVE 4 WITH SlURRY WAlL
(fatal CllPllII CGI8 . Tolaf ,.... wonh 0 & U cost)
NET PRESENT WORTH COST fOR AlTERNATIVE 4 WITH INJECIION WB.1.8
(fatat CllPllII CGI8 . Tal" ...1 wonh 0 & U cost)
8.925.920
8.910.520
~
~
(a) Analysis 101 Ta. volatile organic compounds, TAL metals, cyanide, and Iluoride.
-------
.......~
State cf Ohio Enri1v~ ProtediOD Agency
;: .0. Box 1049. 18CO Wa18rMark Dr.
CgJ~.t1/)US. Ohio 43i56-0149
(614) 644-3020
FAX (614) ~:12-
Geo"38 V. Voinovic:tl
Govwnor
Dol'I8Id R 5chrvgaDIs
DIr8c:tor
septt~m.ber 29, 1992
Mr. 'laldus V. Adamkus
Reqi()nal. Admi.nistrator
Uni. t(~d States Environmental. Protection Agency
Reqic)n V
77 Wf!St .Jackson Boulevard
chicago, IL 60604-3590
~V~~
Dear Mr.~US:
The ohio Environmental Protection Agency (Ohio EPA) has received
and reviewed the September 28, ~992 final. Record of Decision
(ROD) for the Ground Water Opercs.ble Unit (GWOO) -at the Alsco -
AnaccJnda Superfund site in Gnadenhutten, Tuscarawas County, Ohio.
The :ROD for the GWOU is the second of two RODs for the A1sco
AnaccJncia site, the first of whi.ch acidressed the Source Material
operzLble Unit (SHOU). Ohio EPA concurs with Al-cernative #2, the
selec:ted remedial alternative for the GWOtT at '::his site. The
selec~tad alternative includes the following components:
*
Natural flushing and attenuation of contaJu.inants in the
aquifer, allowing ground water to discharqe to the
Tu~carawas . River;
*
Sampling and laboratory analysis of the ground water from
monitoring wel1.s;
*
:Installation of background wel.ls, and sampling of those
wells;
*
Institutional controls, including- deed restrictions, that
prevent instal1.ation of drinking water wej.l,s wi thin the si~.
boundaries until. rem8d.ia.l action leve1.s :for ground water
have been achieved; and
sampling of Tuscarawas River sediments and benthic
organisms.
*
The estimated net present worth cost of the seJ.ected remedy is
$504,600. The estimated total. present worth of operation and
maintenance costs are $455,400.
* p",- gn -,-1'8P8"
-------
The ROD sDecifies that U.s. EPA, in.consu~tation with Ohio £PA,
will revisit the site remedy if monitoring re~ults of the ground
water and sediments do not demonstrate that the. contaminants are
being flushed from the aquifer over time; that: the sediment
contamination leve~s are decreasinq; and that the benthic
populations are recoverinq. Because the ROD does not set forth
clear criteria by which to make those judqements, Ohio EPA
believes that it 15 very important that a cle~ procedure and
supportinq rational~ for interpretinq the data collected over
time and acting on those interpretations be developed in the
RD IRA work plan and fully defi.ned in the .r:.emedialdesign.
Ohio EPA
the best
with the
the best
believes that the selected remedy for the GWotJ provides
balance among the alternatives and that, in combination
rGD1edial action beinq taken for the SHOt] , it provides
response to the conditions at the Alsco Anaconda site.
Since~, ~ '
)fp.),JJuf, V !
',--- // --r/ v -- ;C[/oam-');ff., \...---' poJ'
D)11m:tU R. scbjreqardUS, Director
~hio ~tal Protection Agency
DRSlmns
Distribution:
Jan carlson, Acting Chi~, DERb~
Cindy Hafner, Section Hanaqer, IFSS, DERR
J"enifer Kwasniewski, section M8.naqer, T&PSS,
Christine Osborne-Hurd ley , SEI)C., DEEm.
Debbie S1.aDerS, RPM, U.s. EPA
John Kelley, OJIf!'IH ~ranch, U.s. EPA
------- |