United States
Environmental Protection
Agency
Office of -
Emergency and
Remedial Response
EPA.'ROD.R05-84.'004
August 1984
SEPA
Superfund
Record of Decision:
Laskin Poplar Oil Site, OH
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-84/004
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION ()R/()Q/RLl '
Laskin Poplar Oil Site, OH 6. PERFORMING ORGANIZATION CODE
7. AUTHDR(S) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD ReDort
401 M Street, S. W . 14. SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Laskin Poplar oil site includes several storage tanks and
retention ponds of waste oils, on about 9 ac re s in northeastern Ohio,
Ashtabula County. The waste oils contain PCBs, phenols, PAHS, sludges
and other organics, and both soils and surface waters have become
contaminated. The site has been involved in mudslides and flooding,
and runoff and seepage into Cemetery Creek pose the most obvious and
immediate threat of environmental contamination.
The cost-effective remedial alternative for this site includes:
off-site incineration of contaminated water and waste oil above and
below 50 ppm PCB, using established technology. The capitol cost for
the selected alternative was estimated to be $1,043,000; no O&M ac-
tivities were required for this Final Action.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI Field/Group
Record of Decision
Laskin Poplar Oil Site, OH
Contaminated' media: sw, soil, oil
Key contaminants: PCB s, PAHs,
phenols, waste oil, sludges
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None
t.
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOL.ETE
/
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Include a brief (200 words 01 less) factual summary of the mosl sil!!nitkanl information ,.01lIalll,'.1 III II,,' 1"1'011. II Ih,' '''''0,1 nllll;lIlI\ a
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Prepared ill coop~ration wllh. I 'allslalloll 01, 1''':'''111".1 OIl ,.0n""."I1..' ..r.
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E PA Fo,m 2220-1 tRn, .-77) CR....,..)
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RECORD OF DECISION
INITIAL REMEDIAL ALTERNATIVE SELECTION
Site:
Laskin/Poplar Oil, Jefferson, .Ohio
Documents Reviewed
I have reviewed the following documents describing the analysis of cost-
effectiveness of remedial alternatives of the Laskin/Poplar Oil site:
- Focused Feasi bility Study, Laskin/Poplar Oil Site
- Summary of Remedial Alternative Selection
- Responsiv~ness Summary
- Letter froln Robert H. Ma.tnard, Director, Ohio Environl:1e1tal
Protection Agency
Description of Selected Remedy
- Removal of contamil1ated water froln the site for incineration
with the oil
- Removal of oil contaminated witn less than 50 ppm PCB's for
incineration.
- Removal of oil with greater than 50 ppm PCB's for incineration
Declarations
Cons i stent wi th the Comprehens i ve Envi ronmenta 1 Response Co'npensat i on
and Liability Act of 1980 (CERCLA), and the National Contingency ?lan
(40 CFR Part 300), I have determined that the removal and off-site disposal
of all liquids in the above yround al1d in ground tan~s is a cost-effective
initial remedial measure necessary to minimize the release of hazardous
substances so they do not migrate to cause har~ to public health, welfare
or the envi ronment.. The State of Ohi 0 has been consu 1 t~d and agrees wi t'1
the selected remedy. This action will require no future operation and main-
tenance activities.
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2
I have also determined that the action being take~ is consistent with
a permanent remedy at the site, and is appropriate whe~ balanced against
the availability of Trust Fund mo~ies for use at ot~er sit~s. I~ addi-
tion, the off-site transport and destruction is more cost-effective than
other remedial actio~s.
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Responsiveness Summary
Laskin/Poplar Oil
Past Federal cleanup activities have resulted in mitigation of the most
imminent health hazards at the Laskin/Poplar Oil site. Several emergency
actions were taken after the site was discovered and during critical
periods such as mudslides and flooding. A Superfund Planned Removal action
was conducted at the site between July and October 1982. This action re-
sulted in the removal of 302,000 gallons' of waste oil for incineration,
treatment and release of 430,000 gallons of contaminated water and solidi-
fication of 205,000 gallons of sludge, which were placed into Tank No.4.
Prior to the initiation of the Planned Removal, the citizens were briefed
at a public meeting on the proposed actions which included removal of the
waste oil for incineration. There was complete acceptance of any action
which removed the contaminated materials for proper off-site disposal.
The Focused Feasibility Study addresses 450,000 gallons of contaminated
liquids remaining at the site and concluded that they must be removed from
the site as soon as possible, to protect the public health, welfare and the
environment. The study recommends that all of the these liquids be removed
for incineration.
The study was made available at the public libraries in Jefferson, Ohiq
and Ashtabula, Ohio. A press release indicating the study's availability
was issued to the Cleveland newspapers and to local newspapers.' A copy of
the study was also mailed to citizens who have indicated an interest in the
site and to the steering committee which represents the generators of the
waste.
There were no responses received as a result of this comment period, which
extended from May 11,1984 to May 27, 1984.
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Summary of Remedial Altern~tive Selection
Laskin/Poplar Oil
Jefferson, Ohio
SITE DESCRIPTION
The Laskin Poplar Oil site of about 9 acres is in northeastern Ohio within
Jefferson Township in Ashtabula County, west of the village of Jefferson.
It is bounded on the north hy a wooded ravine throug~ which Cemeta~ Creek
flows; on the south, by open fields and the Ashtahu1a County fairgrounds;
on the west, hy a wooded area and hase,a11 fields; and on the east, hy
Poplar Road and the fairgrounds. (See Figure 2-1)
The site contains the residence of Mr. Alvin Laskin, owner of the property;
a series of greenhouses; four hoi1ers used to heat the greenhouses; a
boiler stack; approximately thirty-six storage tanks; one retention pond;
a freshwater pond; and miscellaneous hui1dings and sheds. Approximat~ly
450,000 gallons of oil and water-oil mixtures are stored in the tanks.
SITE HISTORY
The greenhouses on the Poplar Oil Company site were in operation for ahout
80 years. Approximately 30 years ago, boilers were installed to heat the
greenhouses. During the 1960's storage tanks were installed to hold
waste oil to fire the hoilers. The oil was not analyzed before acceptance,
and oil containing PCR's phenols, and other hazardous substances was accepted.
When the greenhouse business deteriorated, the owner ~egan picking up,
reselling, and disposing of waste oil. The company's activities also
included oiling roads in Ashtabula County and a near~y horse racing track.
Through a series of legal actions, the company is now in receivership, and
all on-site business activities relating to oil have essentially stopped.
Past Federal cleanup activities have resulted in the ~itigation of the
most fmminent health hazards. Several emergency actions were taken after
the site's contamination was discovered and during critical periods such
as mudsljdes and flooding. Superfund Planned Removal cleanu~ actions
reMoved 302,000 gallons of waste oil for incineration; treated an1 released
430,000 gallons of contaminated water; and solidified 205,000 gallons of
sludge which was placed in Tank No.4. Also, a cover was huilt onto
Tank No.3 and the north wall was removed froM pond lee (See Figure 2-3)
These actions were accoMpli~herl between July and Nove~~er 1982.
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LAKE
ERIE
OHIO
o @
10
5
MILES 15
FIGURE 2.'
VICINITY MAP
LASKIN/POPLAR
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IT]
POND."
",,,.. WA rE" fIONO
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NO' '0 SCAl(
-" r_..
on "UK" 0' A..",
.. ~,.,.. 0' Oh
SOU"C" .
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(/ft
8It1CK 0
ifACt(
..U" NOUW
AND GA"AGf
OMfNMOUlfI
"0
FIGURE 2.3
COMPANN:O~~:R OIL
LASKI
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2
CURRENT SITE STATUS
The liquids on the site are characterized as:
Oils with PCB Content of 50 ppm or Greater
o
Approximately 250,000 gallons total are contained
in 3 tanks.
o
Other priority pollutants and:metals are also in
the PCB oil including: carcinogenic volatile organic compounds,
carcinogenic and noncarcinogenic base/neutral compounds,
phenol, and potentially toxic metals.
The main component is waste oil with an estimated
heating value of 18,000 Btu per gallon.
o
o
The oil also contains suspended solids.
Oils With PCB Content of Less Than 50 ppm
o
Approximately 100,000 gallons are in 24 tanks.
o
Other characteristics are the same as for the oils
with greater than 50 ppm of PCB, ;nc1uding the
volatiles, base/neutral compunds, phenol. and
metals.
Contaminated Water
Discussion
Approximately 100,000 gallons of water with high
suspended solids and bottom sludges are in Tank
No.3. An oil sheen can be observed on the water
surface.
The presence of these l;qu;ds ;s a potential health hazard and
is a logistics barrier to the further investigation of the site
and an evaluation of final re~edial actions.
There is a continuing potential for health and environmental
hazards from the presence of the liquids on site. Release
of the contaminated liquids would pose a pu~ic health and
environmental threat.
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3
The most obvious and immediate threat is from contamination entering
Cemetery Creek. A fire would probably be accompanied by a spill releas-
ing some or all of the substances.
Cemetery Creek runs along the northern edge of the property. Runoff or
seepage into the creek may be contaminated by the existing conditions
at the site. Cemetery Creek flows into the Grand River, which is the
main drinking water supply for nearly 25,000 people in Ashtabula County.
Discharge of contaminated oil and waste to Cemetery Creek may have al-
ready introduced PCB's into the aquatic ecosystem. Since PCB's are fat
soluble, the potential exists for concentration in the aquatic food chain
and eventually into the human system. Bioconcentration factors for PCB's
in fish range from about 3,000 to 274,000. Some wildlife species (mink)
are more sensitive than humans, and the present EPA criterion is based
on the bioconcentration in salmonid fish and toxicity to mink.
Contamination of Cemetery Creek could lead to ingestion of PCB's and
other contaminants. This could occur either by contamination of drinking
water supplies or by ingestion of contaminated fish.
Some of the organic contaminants are bioconcentrated. Examples are the
higher molecular weight polynuclear aromatic hydrocarbons (PAH's) such
as phenanthrene, naphthalene, anthracene, and pyrene. These compounds
could be ingested by humans and wildlife eating contaminated fish.
With these potential health hazards
are on site and the logistics block
toward an eventual remedial action,
prudent that the liquids be removed
ticable time.
continuing as long as the liquids
they present to further progress
it is considered both necessary and
from the tanks at the earliest prac-
ENFORCEMENT
Litigation concerning environmental problems at this site has been on
file in both state and federal courts since early 1979. The only defend-
ants currently involved are Alvin Laskin and several corporations set
up by him. Laskin and Poplar Oil Company are subject to consent decrees
in both state and federal proceedings, but are effectively judgement
proof.
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4 ..
u.s. EPA has identified some 100 potential responsible parties (PRP's)
who either transported or consigned waste material to the site. These
include a broad spectrum of firms, including both large and small
organizations. Notice and demand letters have been sent to each, begin-
ning in about April 1982. U.S. EPA divided the PRP's into first and
second tiers, based on volume of waste sent to the site, and negotiated
for about 8 months with the first tier group. No acceptable offer was
forth coming, and it is not believed that further negotiations will prove
fruitful.
A referral is currently pending at the Department of Justice seeking re-
covery of a discrete unit of costs incurred to date at the site (some
$1.6 million of CWA 9 311 and CERCLA 9 104 funds) spent in emergencj
or Planned Removal actions.
It is unlikely that PRP action will be forthcoming in voluntary negoti-
ations. As a result, the program office will be sending out unilateral
CERCLA 9 106 orders to four or five PRP's who can be directly linked to .
materials found at the site. In this manner we will determine whether
there wi 11 be any PRP response.
COMMUNITY RELATIONS
A press release was issued on May 10, 1984 which announced the availa-
bility of the Focused Feasi bility Study for review at li braries in Jef-
ferson and Ashtabula, Ohio. Copies were also mailed to interested people
including Congressman Eckart and Senator Metzenbaum. The public comment
period was from May 13 to May 27, 1984. There were no responses received
as a result of this public comment period.
ALTERNATIVES EVALUATION
The evaluation of a limited number of alternatives is controlled by the
following practical and regulatory constraints:
1.
Essentially complete removal from the environment of all liquids
(oil and water) is required to mitigate the potential hazard to
public health. Pond 20 will need to remain as a catch basin until
all contaminated sludges and soils are adequately controlled.
The provisions of 40 CFR 761 (31 May 1979) regulate the disposal of
all PCB containing liquids. At or below 50 ppm PCB, liquids are
non-regulated, except for uses resulting in direct, wide spread
contamination. Above 50 ppm PCB, disposal is regulated and defined.
Mixing, or dilution of clean and dirty oil is not permitted to
achieve a lower PCB concentration to avoid the regulations.
2.
3.
Water to be di scharged to Cemetery Creek must meet criteri a speci-
fied by the Ohio EPA.
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o
5
10
15
20
. .
NO ACTION , S. D '" . A r .1 """";, ........L ,J,.....",;on
Ite at., ""It pp Icatlon . I
ON-SITE CONTAINMENT ",....It .. .......L"",
ON-SITE TREATMENT I nOn-Site
WATER-TO-CREEIC I
Preparations & Negotiations , On-Site
WATER-TO-WWTP / -- (Probably Longer than for Discharge to Creek
Due to Negotiation Time)
OIL-GREATER THAN
50 PPM-PCB CHEMICAL Spec, Bid/Award I Proc~s & Remove
REDUCTION & REMOVAL '
Permit Time . On-Site Commercial Unit
ON-SITE INCINERATION On-Site EPA Unit
Spec, BId/Award
REMOVAL . .
Spec, Bid/Award I Removal
LAND FILLING I
Spec, Bid/Award I Removal
01 L RECYCLE I
OIL TREATMENT &
Spec, Bid/Award I Rpmovol
RECYCLE I
I Removal
INCINERATION
TABLE 2
Comparative Time lines - Months from
Authorization to Implement
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5
Different removal alternatives will apply to the liquids depending on
the handling and disposal regulations. Three categories of liquids are
therefore considered separately.
o
PCB contaminated oil:
50 to 500 ppm PCB concentration.
o
low PCB contaminated oil:
detecta~e to less than
50 ppm PCB concentration.
low level PCB. high suspended
solids. oil and grease. and
. unknown metals concentrations.
o
Contaminated wastewater: .
Alternatives considered were no action. onsite containment. onsite treat-
ment. onsite incineration. and removal offsite for final disposal.
A.
NO ACTION
Pu~ic health considerations have ruled out a "no action" alternative for
the liquids. Even deferring liquid removal until a future full Remedial
Action is considered not prudent. The endangerment aspects of this alter-
native were discussed in the current Site Status of this report. The oils
are flammable and if a fire started a health hazard could exist due to
the combustion products or through volatilization of hazardous substances
from the site. The potential for spillage to Cemetary Creek exists which
could contaminate the water supply for 25.000 people in Ashtabula County.
The environment also could suffer significant degredation from a spill into
Cemetary Creek.
B.
ONSITE CONTAINMENT
The liquid wastes could be stabilized and buried onsite. Stabilization
would require the oil or water to be pumped from the storage tanks and
mixed with a binding agent to form an inert cement-like product. The
stabilized material would then be transferred to a truck prior to solid-
ifying and transporting to a burial area onsite. A contractor specializ-
ing in solidification would be utilized for the actual mixing. stabiliza-
tion. and transport to the burial site. This process may produce noxious
odors in off-gases which could be a nuisance and possibly present operat-
ing problems. Decontamination facilities would also be required to wash
the mixing and transporting equipment.
The burial area would have to be designed to meet RCRA and TSCA require-
ments for hazardous waste disposal since the water and oil contaminants
contain regulated materials. The design considered at other hazardous
sites and as proposed by regulations has been a double-lined clay.
plastic or asphaltic basin with a between-1inerunderdrain system. The
burial site would have to completely contain all materials for a minimum
of 30 years and be continuously monitored. secured. and maintained.
Therefore. a prolonged and scheduled surveillance and maintenance plan
would have to be implemented to constantly protect and identify the in-
tegrity of the landfill. A cost summary follows.
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6
Act ivity Cost Basis
Burial Site $ 360.000 450.000 gallons of liquids
stabilized to twice volume
equals 4.500 cubic yards;
$80/cubic yard for a double-
lined landfill
Permitting 102.800 One-year effqrt 1/2 time for two
people; $200 per day per
person for labor and $50.000
for travel. field laboratory
work. and other expenses and
report preparation
St a bi 1 i z at i on 675.000 4.500 cubic yards produced at
$150 per cubic yard for
materials equipment. hauling.
and 1 a bor
Postclosure O&M 57.000 $5.000 per year (present
worth) at 8 percent per year
Jor 30 years
Tota 1
$I . 192. 000
The overall schedule for containment would be 18 to 24 months. depending
upon the success of the permitting effort.
C.
ON SITE TREATMENT
Contaminated Water
The water stored in Tank No.3 has been characterized as containing a
wide variety of metal. PCB's and other organic contaminants. Addition-
al data and bench tests would be required to confirm a detailed process
design for onsite treatment. However. it is reasonable to consider that
minimum treatment processes would be pH adjustment in the tank with lime
and in-place sedimentation followed by sand and then activated carbon
filtration. Discharge would be either to Cemetery Creek or to a local
wastewater plant. Waste sludges from this process would be packaged and
left on site for disposal during the remedial action.
The treated effluent would be held in storage until laboratory analyses
indicated compliance with the applicable requirements for release. If
compliance was not met. retreatment would be required. NPDES permit
standards for discharge to the creek would need to be met. If discharge
is to a treatment plant. transport to the plant and a discharge fee
would be required.
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7
Care would have to be taken in the handling, pumping, and onsite storage
of the water before, during, and after treatment. An accidental spill
could result in the possible contamination of soil at or around the'
storage tank. If the waste is to be transported or pumped to another
location onsite, then it could spill anywhere, including Cemetery Creek.
Treatment and discharge to the creek are essentially the process used
in the 1980 removal of contaminated water from Ponds 19 and 20. In
that operation~ approximately 830,000 gallons of water were treated
at a cost of aboJt $400,000.
Therefore, the minimum cost for processing about 100,000 gallons of water
in 1984 to meet requirements for discharge to the creek is estimated at
between $200,000 and $285,000, considering that one-fourth to one-third
of the costs would be fixed and not directly related to the volume pro-
cessed. A cost summary follows.
Activity
Fixed Cost
Cost
Basis
$133,000
Fixed costs (mobilization/
demobilization, labor
administration, etc.) at
1/3 of 1980 total cost
Treatment
32,000
Treatment costs for 100,000
gallons at 32 cent per gallon
(treatment cost at 2/3
of 1980 total fixed cost)
Permitting
40,000
Pilot studies and permit
preparation at 5 man-
months plus expenses
Escalation
77,000
Escalation at 10% per year
for 4 years for both fixed
and treatment costs
Total
$282,000
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8
If fixed costs were 25 percent of total costs, the esti~aterl cost for
treatment would be $249,000. If treat~ent proceeded well, the onsite
operation would take ahout one month.
Cost for the alternative of onsite pretreat~ent and discharge of
pretreated water to a local wastewater treatment plant would prohah1y
be less than for discharge to the creek hecause it is expecterl that, if
suitah1e arrangements could be made with a treatment plant, thp treat-
ment requirements would he extensive, though not as stringent ~s for
discharge into the creek. Costs for this alternative are estimat~~ as
follows:
Activity Cost
Pilot Studies $ 4,000
Fixed Costs 98,000
Basis
Two week effort and
expenses
One-~a1f of costs for
treat~ent for discharge to
creek (includes escala-
tion to 1984)
Treatment
20,000
At 20 cents/gallon treated
Plant Fee
2,000
Preliminary estimate
Total
$124,000
This estimate is based on the 1980 water treatment overall cost and
volume with some adjustments made for escalation anrl other factors noted
above and should be considered as a conceptual estimate only. Approxi-
mately one month's time would be required for the onsite operation, and
the overall time period would he heavily dependent on obtaining agree-
ment at a treatment plant to accept the wastewat~r.
Greater Than 50 ppm PCR Oils
If these oils were treated onsite to reduce the PCR cnncentration to
less than 50 ppm, they could he sold as fuel outside )hio or incinerated
at the only permitted incinerator in Ohio.
PCB reduction processes are designed to reduce by che~ical means the
PCB's into chemically smaller, harmless compounds. T,e processes are
used by electric utilities to clean transformer oils that have residual
PCB concentrations. The oils to he treated must be free of suspended
material, moisture, and sludges to prevent the sodium-~ased reactant
chemical from blinding or decomposing. There is one commercial pro-
cess that can reduce PCB-contaminated oil without pretreatment. The
vendor is presently treating 100,000 gallons of oil containing paint
sludge and PCB's to a level of less than 50 ppm PC~. Their treatment
equipment is portable, and treatment is being done onsite in another
stat~. Limited commercial experience exists with this process on PCB-
contaminated waste oils, and the technology is still under development.
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9
The costs for onsite chemical treatment to reduce PCB's are summarized as
follows:
Activity
PCB Reduction
Cost
Basis
$750,000
Additional Crew
70,000
250,000 gallons at $3 per
gallon--includes operators
.One month cleanup would
require two men to evacuate
tanks, clean up,
decontaminate, etc.
Lab Costs
15,000
$835,000
Estimated
Total
A period of 4 to 6 weeks should be allowed for chemical reduction of the
PCBls.
Some environmental concerns exist. Onsite pumping, transporting, and
treating of wastes could cause spillage or a fire. PCB reduction chemicals
(especially elemental sOdium) are explosive and could pose a threat if
not handled properly. Also, waste sludges generated from either pretreat-
ment of the oils or the process must be disposed of in a safe manner.
Less Than 50 ppm PCB Oils
This type of oil does not require onsite treatment since it can be sold
for fuel or incinerated.
D.
ONSITE INCINERATION
Contaminated oil could be incinerated and water evaporated onsite by us-
ing a portable incinerator. There is one commercially available portable
incinerator and one owned by the U.S. EPA. Both incinerators are fully
equipped and designed to provide the temperature and residence .time re-
quired for organics destruction and also to provide flue gas scrubbing
and monitoring capabilities.
Ash disposal is a consideration for any onsite incinerator and could be
disposed of with the ultimate site cleanup.
Based on estimate from the commercial portable incinerator operator, the
cost for portable incineration of the waste oils and water would amount
to approximately $1,800,000 at $4 per gallon. It would take 4 to 5 months
to set up and incinerate the waste materials with a portable incinerator.
Costs for the U.S. EPA incinerator were not estimated but at the estimated
treatment rate it would take about 12 months to burn all the oil.
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10
.;
Several environmental considerations should be explored with this alter-
native: a potential explosion or fire. a spill during the transfer of
waste oil. and out-of-specification incineration gases. An explosion is
unlikely. but its consequences could environmentally impact the site and
its surroundings. A spill could contaminate soil or even enter Cemetery
Creek if the waste oil required hauling to another location onsite.
There could be instances of out-of-specification incinerator gases; but
given the technology and monitoring of the equipment. these should be
short-lived.
E.
REMOVAL FROM
SITE
The contaminated material could be removed from the site by a licensed
commercial contractor and disposed in anyone or combination of the
following alternatives:
o Landfilling
o Oi 1 recyc 1 e
o Oil PCB reduction
o Incineration
and recycle or incineration
1.
Landfil1ing (All liquid wastes)
There are several landfill sites ~n the Midwest available for Laskin
Poplar site wastes. The one used in this estimate is about 150 miles
from the site. Stabilization of the liquids would be done onsite and
the stabilized material transported to the landfill. As discussed pre-
viously. odor production during stabilization could be a problem.
Landfi1ling cost estimates are based on information obtained from a
local hazardous waste contractor for the stabilization and disposal
of water. contaminated oil containing less than 50 ppm PCB's. and oil
with greater than 50-ppm PCB's. A preliminary cost estimate for land-
filling is summarized as follows:
Activity
Cost
Basis
Onsite Stabilization
of Oi 1 and Water
$675.000
Described on page 6.
Transportation
425.000
Estimated at $3.50 per truck
mile. 300 mile round trip to
landfill. 4.500 cu. yds at
27,000 1b/cu. yd., 15T/load.
to
La b Costs
20.,000
Estimate
Disposal at Landfill
31,000
Estimated at $5/ton.
Total
$1,151.000
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11
The estimated cost for landfilling the 011 containing greater than 50 ppm
PCB's is $640.000. The estimated cost for landfilling the oil containing
less than 50 ppm PCB's and water is $256.000 each.
.'
A period of 6 to 8 weeks should be allowed for liquids removal.
Environmental threats posed by this alternative arise from potential acci-
dents during the handling. processing. and transport of the waste materials.
and from the landfill as a long-term contamination source.
2.
A.
Oil PCB Reduction by Chemical Means and Recycle
Less than 50 ppm PCB's
Recycle of wast~ oil as a fuel is a potential disposal route. Waste oils
with PCB contamination of less than 50 ppm can be used as a fuel.
A problem with this disposal alternative is the possibility of inaccurate
waste oil manifesting and the potential of the oils being used for asphalting
or oil-based spraying. both illegal practices and potential paths into the
environment. These waste oils would. therefore. have to be tracked or moni-
tored to assure proper disposal.
The only costs incurred with low PCB oil recycle are the administration of
the contract. supervision to observe and monitor the oil off-loading and
disposal. and some lab analysis. A summary follows.
Activity
Transportation/Recycle
Cost
Basis
o
Recycler will take at
no charge
Supervision
$4.000
Two weeks at $2.000
per week
La b Costs
5.000
$9.000
Estimate
Tot a 1
B.
Greater than 50 ppm PCB's
Chemical treatment may be a possible route for the reduction of PCB contami-
nation levels in oils to less than 50 ppm. This would then allow the oils
to be recycled or incinerated. If the costs for PCB reduction are combined
with the costs for recycling, the resulting costs can be summarized as
fall OWS:
Activity Cost Basis
PCB Reduction $835.000 Oescri bed on page 9
Supervi sian 5.000 Estimate
T at a 1 $840.000
A period of 4-6 weeks should be allowed for PCB reduction and removal from site.
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12 '.
3.
Offsite Incineration
Incineration is a commonly used disposal route for waste oils and even
wastewater. Incineration could be contracted with a firm in Ohio for the
wastewater and oils with less than 50 ppm PCB's. For oils with .greater
than 50 ppm PCB's incineration would have to be done out of state. In
the case of the oil with greater than 50 ppm PCB's, the incinerator equip-
ment must be designed to meet EPA criteria for furnace temperature and
residence time, be fitted with the required air pollution abatement equip-
ment, and be permitted. A cost estimate for incinerating the various
wastes is summarized as follows:
Activity
Cost
Basis
Transportation
Wastewater to incinerator
$ 14,000
90 miles one way at
$3.80 per mile and 20
truckloads
Less than 50 ppm PCB oil to
incinerator
Same
14,000
Greater than 50 ppm PCB oil
to incinerator
105,000
300 miles one way at
$3.50 per mile and 50
truckloads
Incineration
Wastewater
Less than 50 ppm PCB oil
Greater than 50 ppm PCB oil
35,000
35,000
750,000
$0.35 per gallon
$0.35 per gallon
$0.40 per pound, or
approximately $3.00
per ga 11 on
Ons i te Crew
Wastewater
Less than 50 ppm PCB oil
Greater than 50 ppm PCB oil
70,000
Est i mate for all sit e
removal (same as land-
filling)
Lab Costs
20,000
Estimate
Tot a 1
$1,043,000
A breakdown of the total estimated cost for incineration is $900,000 for the
011 w1th greater than 50 ppm PCB, and $71,500 each for water and oil with less
than 50 ppm PCB.. . .
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1 3
If the oil containing greater than 50 ppm PCBls is chemically reduced
and incinerated the costs are as follows:
Activity
PCB Reduction
Cost
Basis
Transporation to incinerator
$835,000
34,200
Described on page 9
90 miles one way'at
$3.80 per mile and
50 truckloads
Incineration
87,500
$956,700
250,000 gallons at $0.35
per gallon
Total
The total incineration cost of all liquids if the greater than 50 ppm PCB oil
1s chemically reduced is $1,134,700.
Onsite PCB reduction would not offset the cost of incineration but, instead,
would increase the total cost for waste incineration.
A period of 6 to 8 weeks should be allowed for liquid removal if each liquid
is removed separately. If all ar-e removed at the same time (two contractors
onsite), the duration could be half as long. The State of Ohio compiles
detailed information on intrastate highway traffic. In 1983 there were 268
highway wrecks or spills that involved trucks. Of that number, 37 were
hauling hazardous wastes. Annually, there are approximately 1.2 million
placarded truck shipments that include chemicals, fuels, hazardous materials,
etc. Recent records show that for the amount of traffic in the state there
are relatively few spills involving hazardous materials. Therefore, with
reasonable care and precautions, offsite transportation from Laskin Poplar
does not seem to pose a significant environmental threat.
Alternatives Evaluation
Each alternative was screened based on the following evaluating criteria:
o Cost of implementation
o Availability of technology--availability of commercial equipment,
services, or technology that ;s required to implement an alter-
native
o Ease of imp1ementation--the relative difficulty required to
actually carry out an alternative
o Schedule--the approximate time to implement the alternative
o Environmental consideration--ability of the alternative to
meet the short- and long-term environmental requirements and
goals established by the U.S. EPA and OEPA.
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14
Onsite containment of oils and water (450,000 gallons) would cost in ex-
cess of $1,300,00 and require 18 to 24 months for implementation. This
alternative would require operations and maintenance cost for at least 30
years.
Onsite incineration of oils and water would cost about $1,800,000 and
would take about twelve months to complete. This alternative would be
very unacceptable to the local residents because of the past incinera-
tion practices by the owner of the site. Both of these alternatives are
ruled out by the high cost and the long time to complete the alternative.
Onsite treatment of the contaminated water followed by discharge to the
creek or a wastewater treatment plant would cost substantially more than
offsite incineration, with little additional environmental benefit.
These alternatives are rejected.
Onsite treatment of the oil containing greater than 50 ppm PCB followed
by recycling or incineration in Ohio is competitive with landfilling or
incineration outside Ohio on a cost basis. The technology to accomplish
this is very new, however, and has been utilized on a very limited basis;
the effectiveness of the treatment cannot be assured. The process uti-
lizes hazardous materials includi09 elemental sodium which presents a
danger of fire or explosion. Since a fire was a prime concern in the
endangerment assessment, the treatment alternative is not considered a
viable alternative. As a result of the previous evaluation, neither on-
site treatment or disposal of any liquidS is considered a viable option.
The contaminated water and the oil above and below SO ppm PCB can be
removed from the site for landfilling. The cost for the contaminated
water and oil below 50 ppm PCB is substantially higher than the other
alternatives. This alternative doubles the volume of the wastes
during the solidification process which must be done on site. Some of
the wastes are very persistent and will remain in the landfill for an
extended period and could cause environmental damage in the future.
The cost to incinerate the oil above 50 ppm PCB is $260,000 more than
landfilling but this process destroys the hazardous substances including
the PCB's, eliminating the future threat posed by them. The benefits
derived far outweight the additional cost.
The below 50 ppm oil could be recycled but this presents management prob-
lems in assuring that the oil does not cause additional problems elsewhere.
By incinerating the oil with the contaminated water the cost is comparable
with pretreatment and discharge to a wastewater treatment plant and recycling
of the oil. (See Table 1 and 2) ,
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15 .
RECOMMENDED ALTERNATIVE
The recommended alternative as evaluated under 40 CFR Part 300.68(j) is
incineration for all three components: contaminated water, oil above 50
ppm PCB and oil below 50 ppm PCB. This alternative is very implementable
and uses established technology. It eliminates permanently the threat of
the hazardous substances to the public health. welfare and the environment.
This is the most cost effective solution to the problem when considered
over the long term.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The recommended alternative is in full compliance with 40 CFR 761 which
regulates the disposal of liquids containing PCB. This alternative pro-
vides a permanent solution to the problem within the guidance of this
regulation. The recommended alternative is also consistent with all
other agency laws and regulations. .
,
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ALTERNATIVE COSTS
Thousand $
Oils With Less Oil s with Greater
Alternative Water Than 50 ppm PCB's Than 50 ppm PCB's Tot a 1
Landfi 11 i ng Offsite 256 256 640 1 ,152
Ons it e Pret rea tment
Disposal at local Waste-
water Plant 124 NA
Oi 1 Recyc 1 e NA 9 NA NA
PCB Reduction/Oil Recycle NA NA 840 NA
Incineration Offsite 71.5* 71.5 900 1,043
PCB Reduction/Incineration
Offs i te NA NA 957 NA
Containment Onsite 288 288 722 ',298
* Incineration Onsite 400 400 1 ,000 1 ,800
*Costs are contingent upon all three phases being disposed of by this option
TABLE 1
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