United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-86/035
September 1986
Superfund
Record of Decision
Fields Brook Sediment, OH
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TECHNICAL REPORT DATA
(Pt~lU~ nad !nSllUctions on th~ r~v~n~ Mf(N~ com"/~ting)
1. REPO"T NO. r 3. ReCIPIENT'S ACCESSION NO.
EPA/ROD/R05-86/035
.. TlTL.E AND SUBTITL.E 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 30, 1986
Fields Brook, OH 6. PERFORMING ORGANIZATION CODE
7. AUTHORISI 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EL.EMENT NO.
". CONT!'IACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD RepOrt
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPL.EMENTARY NOTES
16. ABSTRACT
Fields Brook is located in the City of Ashtabula, Ohio and drains a 5.6-square mile.
watershed (defined as the "site"). The 3.5 mile main channel of Fields Brook fl~s
through an industrial area that is one of the largest and most diversified
concentrations of chemical plants in Ohio. The brook empties into the Ashtabula River
which subsequently flows into Lake Erie 8,000 feet downstream of its confluence with
Fie Ids Brook. Industrial sources have contaminated the sediment in Fields Brook with a
variety of organic and heavy metal pollutants, including TCE, PCE, chlorobenzene, vinyl
chlor ide, arsenic, zinc, mercury and chromium. Base-neutral compounds including
hexachloroethane, toluenediamine and toluene diisocyanate also have been detected in
Fields Brook sediments. sediments taken from the Ashtabula River in the vicinity of
Fields Brook are contaminated with PCBs. The U.S. EPA believes that the amount of
contamination entering the brook at this time has been substantially reduced due to the
recent development of pollution control laws and discharge permitting requirements.
The selected remedial action for the Fields Brook site includes: provisions for the
excavation of contaminated sediment from Fields Brook, the temporary storage and
dewatering, and the thermal treatment of a portion and the solidification and onsite
landfilling of the remainder. Based on criteria presented in the ROD, approximately
36,000 cy of contaminated sediments will be solidified, and 16,000 cy will be thermally
(see Attached Sheet)
17. KEV WORDS AND DOCUMENT ANAL.YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA T I F ield/Group
Record of Decision
Fields Brook, OH
Contaminated Media: sediments
Key contaminants: VOCs, TCE, PCE, base-
neutral compounds, PCBs, arsenic, chromium
zinc, mercury
18. DISTRIBUTION STATEMENT 19. SECURITY CL.ASS IT/lis Report) 21. NO. OF PAGES
None 72
20. SECURITY CL.ASS IT/lis pagel 22. PRICE
None
'"
!PA 110'''' 2220-1 (R... "-77)
PlutVIOUS EOITION 'I O.IOI..ETIl
-------
EPA/ROD/R05-86/035
Fields Brook, OH
16.
ABSTRACT (continued)
treated. The remedy also includes treatment of waste water from the
dewatering process, and provision of O&M costs for one year. The estimated
capital cost of the remedy is $35,100,000 with annual O&M costs of $72,000.
~
-------
RECORD OF DECISION
Remedial Alternative Selection
Sita:
Fields Brook Sediment Operable Unit. Ashtabula. Ohio
p
Documents Reviewed:
I am basing my decision on the following documents describing the analysis
of the cost-effectiveness of remedial alternatives for the Fields Brook
Sediment Operable Unit. Ashtabula. Ohio:
- Remedial Investigation - Fields Brook Site. Ashtabula. Ohio.
CH2M Hill, March 19~5.
- Feasibility Study - Fields Brook Sediment Operable Unit,
Ashtabula, Ohio, CHZM Hill, July 1986.
- Summary of Remedial Alternative Selection.
- Responsiveness Summary, September 1986.
Description of Selected Remedy:
- Provisions for the excavation of contaminated sediment from
Fields Brook, the temporary storage and dewatering, and the
thermal treatment of a portion and the solidification and 1andfilling
of the remainder. The breakdown is based on criteria in the
Summary of Remedial Alternative Selection. Subsequent water
treatment is also included.
- First year Operation and Maintenance costs to provide for 10ng-
term monitoring after the remedy has been completed.
Declarations:
Consistent with the Comprehensive Environmental Response Compensation. and
Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR
Part 300), I have determined that the excavation and thermal treatment/
landfilling of Fields Brook Sediment is a cost-effective remedy and provides
adequate protection of public health, welfare. and the environment. The
State of Ohio has been consulted and agrees with the approved remedy. In
addition, the action will require future operation and maintenance activ-
ities to ensure the continued effectiveness of the remedy. These activities
will be considered part of the approved action and eligible for Trust Fund
monies for a period of one year. .
-------
-2-
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust fund monies for a period of one
- yea r.
...
The U.S. EPA will undertake additional remedial investigations/feasibility
studies to address any ongoing sources of contamination to Fields Brook and in the
Ashtabula River (if deemed appropriate) and evaluate proposed remedies. If
additional remedial actions are determined to be necessary a Record of
Decision will be prepared for approval of the future remedial action.
.Ii-
Jf~fu )o-f-' 19$6 -
Date
..
4~a~. A am:£;;?
L
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FIELDS BROOK SEDIMENT OPERABLE UNIT, ASHTABULA, OHIO
iITE'LOCATION AND DESCRIPTION
Fields Brook is located in the City of Ashtabula, Ashtabula County in
Northeastern Ohio (Figure 1).
The brook drains a 5.6 square mile watershed
(defined as the "site" for the purpose of thi~ study), the eastern portion
draining Ashtabula Township and the western ~ortion' draining the City of Ashta-
bula (Figure 2).
The 3.5 mile stretch of main channel begins just south of
u.S. Highway 20, about a mile east of State Highway (STH) 11.
From this point
the stream flows northwesterly, under U.S. Highway 20 and Cook Road, to just
north of Middle Road.
Then the stream flows westerly to its confluence with
the Ashtabula River.
From Cook Road downstream to 5TH 11, the stream flows
through an industrial area that is one of the largest and most diversified
concentrations of chemical plants in Ohio.
Downstream of STH 11, to near its
confluence with the Ashtabula River, the brook flows through a residential area
in the City of Ashtabula (population, 24,449 in 1980).
Fields Brook is con-
sidered a navigable body of water which varies greatly in width and depth.
Some
of the areas surrounding the brook are thickly covered with vegetation.
The
Ashtabula River empties into Lake Erie about 8,000 feet downstream of its
confluence with Fields Brook.
The City of Ashtabula's drinking water intakes
are located within Lake Erie.
SITE HISTORY
Industrial sources have contaminated the sediment in Fields Brook with-a variety.
of organic and heavy metal pollutants.
Organic compounds reported in sediment
-------
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IR'E
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-------
2
sampled during previous studies of Fields Brook include volatile organic compounds:
.
chlorobenzene, 1,1,1 - trichloroethane, l,l,2-trichloroethane, 1,I,-dicloroethene,
tetrachloroethene, trichloroethene, and vinyl chloride; base-neutral compounds:
~
hexachloroethane, hexachlorobutadiene, toluenediamine, and toluene diisocyanate;
chlorinated benzene compounds: 1,2,4-trichlorobenzene, hexachlorobenzene; and
polychlorinated biphenyls (PCBs).
Metals (zinc, mercury, chromiuM, lead, and
titanium) have also been found in the sedimen~ at c~ncentrations reported by
the United States Environmental Protection Aifency (U.S. EPA) in the Toxic
Summary Report (April 1982) to be above background.
The Agency believes the
amount of contamination entering the brook at this time has been substantially
~
reduced due to the recent development of pollution control laws and discharge
permitting requirements.
Chemical analysis of sediment core samples, collected by the U.S. Army Corps of
Engineers (COE) in 1982, indicated sediment in the Ashtabula River in the
vicinity of Fields Brook may be regulated under the Toxic Substance Control Act
(TSCA) because of the presence of PCBs.
Analysis of tissue from fish caught in Fields Brook and the Ashtabula River
prior to 1982 indicated the presence of chlorinated organic compounds such as
PCBs, hexachlorobenzene, and hexachlorobutadiene.
Because of possible fish
contamination with PCBs and other organic chemicals, on March I, 1983, the Ohio
DepartMent of Health and Ohio EPA issued a health advisory recommending that
people not eat fish caught in a 2-mile reach of the Ashtabula River from lake
Erie to the 24th Street Bridge.
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3
The Fields Brook site was first proposed for inclusion on the National Priorities
List (NPL) in October of 1981.
It was included on the NPL in September of 1983,
~it~ a Hazard Ranking System (HRS) score of 44.95.
~
CURRENT SITE STATUS
The U.S. EPA conducted a remedial investigation (RI) at the Fields Brook site
beginning in 1983.
Sampling was conducted in.two phases, during the summers
of 1983 and 1984, and included sediment, surface water, industrial effluent,
macroinvertebrate, and fish samples.
Results of the RI are summarized
according to environmental medium in Tables 1 and 2 and Figures 3 through 8.
EVALUATION OF PUBLIC HEALTH RISK
Potential risks from contaminated sediment, surface water and fish from Fields
Brook are based on the assumption that the site would be used in the future
for both residential and industrial/commercial development.
These estimated
risks are theoretical quantifications, and are presented separately.
For
carcinogens, the potential risks are reported as excess lifetime cancer risks,
which is defined as the incremental increase in the probability of getting
cancer compared to the probability if no exposure occurred.
For example, a
10-6 excess lifetime cancer risk represents the exposure that could increase
cancer by one case per million people exposed.
The risk levels were calculated
using the U.S. EPA Carcinogen Assessment Group cancer potency values.
For noncarcinogens, those substances with EPA published acceptable chronic
daily intakes (AICs), the daily chemical intake was calculated dependi.ng on the
exposure route and then compared to the AIC.
to be without lifetime risk when taken daily.
An AIC is the dose that is anticipated
-------
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tilinsiwioo* »>
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fuoiHMi location
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CONSTITUtNt* Hf PONTIO MOVI
OUANTITATION LIMITS HI
INDUSTRIAL IFFLUENT
VU
-------
Rcar:h
I ." rex Tr Ibulary
0'; Trlbulary
: "'Ile 11
Tr ibutary
, '~amp.d Tributary
; i -,caltoll 9)
,',:nall('d Trlhutary
'[,'KaUon 22)
: j e Ids Brook
r.~O\'P. Ortrex
'; ribulary
!':~lds "rook
! r(",m 5Tllll to
drlx
, jbulary
:dds Brook
I ,,, "shlallu1a
"Jer to
. ';'1111
. , hl libu 1 a
;. ~ "er
Slallonlng
1\10ng
fI('l~
Brook
10600
7900
6500
3600
13000
10600 lo 19900
6400 to 10(,00
o to 6400
TAbLE I.
CONCfmJ..:I\T10N RI\N(;t~; IW O\~r;"NIC nJt1)'('"NII~; HOPE t'Pf(lIlUI'I'!.Y
Pt-:'ITCTt:D IN !;E01tIt:NT ~lIm'Ll!.i -
Total
ro1ych10rlnllled
rH phcuy 1
COlllpounds II'C"'!;)
Total
IIcJachloro-
butalllrm,'
Ran!Jell
Total
VoliJlt 1r
Or IJim 1(;
COIII['01ll1l15 IVOC)
. --
hl!J/k'1)
Total
roly""dcar
III0llliltll:
~~l)(JUllfls I PHI')
NO-24,98?
22-466,000
3-202
7. ~J
34.5
4-144,000
23-820,000
NO-791
5-4,825
.10- 2,401)
tm-46, 1 "14
NO-2,3oo
NO
NO-180,265
NO-41,204
\' '
110-5,400
110-18,092
"
,
Tot..l
Chlul"l".,lrtl
(',f'o7..'n'!
[on'p"'~I_n~~
l','~nO-3f11 ,OrjO
300-015,400
III>
.10
tm
tm
NO
1,716-309,300
NO-330
tJo- 3 22 ,712
tlO-5,1I80
ND-9, ](.0
'nIe rllnges of concenlraUon shown In this table are for sc(1Imenl :;runplcs lakC'n frolll 0 to 70 III('"he!; in drpth.
~ . ~:
2'i0-140,000
tm-l,544
NO
Tnti11
r'hlloalatc
~~'~~'~~~
110-) ,6'.19
tm-2,5<11
OOf,
537
t:D
tID- 29,130
tJO-2,100
tlt)-l 5(,,250
"plow t"r rl'li1nUt..llton limit h"v~
ta1s ar"! calr:ull1tf'd uslnl') concr.nlr,,1 tonS rC'rorl ell 1n I\ppcn,Hx r.. Compnlln,ls det.ecl.,.1 ,,1 concrnt rilt lOllS
t,. a Includ(!11 In lhe lolals 1I~~umtn'J a valup. ('(Illill 10 Ihr 'I"illIlll..I Ion I imtt..
(. fI<)ure 3-1 for slr('i.lm !;tilllonlrllJ "I the lr 1101I\,,rlr5 from t.l1\~ \,ollllu"III"l' wJth rl,'l.l~ Brook.
In
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TA-BLE Z.
SIMMIIT nF IAIIORI\1'fIRY ANAI.YS I!: 11t'!:1I1.r.; F"'" "'~II TI~;~;Ur. !:,,"rr.r:; ('OI,lFlTt1J "URIN(; nrl.O!: III'~ 11tJU111111. 11IYESTlGllTlUf
-.
Or'J~'!.!~("!""[,~""~"- '.~'JI . -- - I!'.!!i-"nlc r"'lC1Uf1.b I.,!~!.-_-
1,1,2,2- I'nl, ,.
::~III.I~ Fish a..n9lh ..... , Chloro- Tet f8rhl oro- T~trllf"hloro- Tr h-hloro. <:I,lorlnllt('<1 lIe.8chloro. Fluor- Ifr,- ""r- !;..I..-
I-I -.M ~['.!...,.! ~!'!'!:!!!! ,,1111"'0 rl "rnl! rl "rill! -~'('h"!!I!L ~n_~~ IInU,('n!! "r~,,"lc !.I-'-,!~ ~rC!.! "
_. !~..~- ~1'!'el!!- ---- ----..-- ----- ~II~ ~:!'.!l !.'.! ". !;11vrr 7.1..
~I.!.!"~:
rt 001 016 C8111 58) 2,700 ).69 1.67. 16.]
. .
J'I '0 I 006 Rock Bass 15) )]2 :1.19 .006 .010 0.0]] 0.14 10.
n ""2 002 Cal1l no 1,550 4.18 .011 .026 .007 3.0') 0.30 0.11 40,
I I (' 1 0]1 Brown
Bullhead "4 319 1.44 .006 .440 .2R8 .141 1.36 0.81 0.14 n.
1"1 I '13 001 Cal1l .50 1,150 1.15 .007 .016 0.44 16.
... '-~) 011 I",r9...ooth
I!a~s 141 :119 0.74 0.90 0.25 0.06 0.'0 'I,
1'1 .,'4 001 l.arqr.oul h
lIa5s 175 65 1.07 .011 .007 0.1] 0.15 0.10 0.40 11.
"''''".1'' C"lsh:
II ,"I 017 C8111 5.5 2,350 5.42 .080 .066 .013 11.30 1.96 I. 10 0.11 III.
! I 1/ I 001 IInek Ba u 251 310 8.50 .008 .015 0.'9 0.'.') a.
1'1 (I: 2 004 Carp 446 1,550 17.) .25') .2]] .019 1.66 1.44 0.]7 ~~
I: ",) on ",ad
111111 hrad )]I 476 8.n .016 ,. '11 1.40 0.14 ]I
II PI') ()(\1 Cal1l 3'16 1150 3.75 .015 .on '.'10 1.)0 1.311 4.0 I. ~o ~ f'
II I ,\ OU l.erq...outh \'
8855 195 101 :1.00 .01] 10.n I'
fl I'\'j 008 l.erqt'llOuth 141 55 1.'.18 .010 .OO'J 0.)8 H
P.e~s
..
I '.::. ItlII r.~nds 8«111lnst consu_lnq fish IIUh concentrations of rrn's 9realrr thlln :1.0 81J/~1J In t'dlblt' pnrtlon5 of th.. fIsh.
I'.~;, '1'11 r.~ends 89alnst coosu_ln9 fish IIlth c:onrfmtretlons of .ernrr, qr('al,.r than 1.0 8q/kq In ('111"1" portions of the fI!lh.
C':.
I .1' ,.f., 1
. .
'.
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4
Sediment
Two groups can incur health risks resulting from exposure to contaminated
~diment, residents and adult workers in the area.
Residents near the streams
could ingest contaminated sediment during outside activities, and sediment may
be transported into the houses on hands, clothing, footware, or by pets.
Lifetime ingestion rates were estimated to be about 15 ounces of sediment per
year.
Risks were calculated using both average and maximum concentrations of
contaminants in the sediment based on a 70 year lifetime.
Adult workers whose place of work may be adjacent to the streams could ingest
about 1/10 of an ounce of sediment per year.
Risks for workers were assumed to
occur over a 40 year working lifetime with an average of 8 hours per working
day, and were also calculated using both average and maximum concentrations.
The results of this assessment concluded that in most reaches of Fields Brook
and its tributaries, excess lifetime cancer risks greater than the 10-fi level
could occur due to sediment ingestion.
For example, the excess lifetime cancer
risk for residents near the Detrex Tributary is estimated to be 5x10-2 for
maximum concentrations and 2x10-2 for average concentrations.
In this same
tributary, the excess lifetime cancer risk for workers is estimated to be
5x10-4 for maximum concentrations and 1x10-4 for average concentrations.
The primary chemicals contributing to the risk are 1,1,2,2-tetrachloroethane,
tetrachloroethene, PCB, hexachlorobenzene, and hexachlorobutadiene.
The assessment also concluded that estimated daily chemical intakes fo'r cadmium,
thallium, silver, and mercury approach or exceed the published AIC in a number
of reaches of Fields Brook and its tributaries.
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5
It was also expected that dermal absorption or dust inhalation of sediment
could further increase cancer risks.
~
Surface Water
Residents and casual visitors can be exposed to volatile chemicals in surface
water by wading in Fields Brook and its tributaries.
?
For example, at maximum
observed volatile contaminant concentrations, the excess lifetime cancer risk
due to dermal absorption from wading 5 to 10 times per year in the OS tributary
is 1x10-4.
Exposure to vapors released from surface water could occur for both residents
and workers.
Because vapor concentrations are not available from the site,
only the qualitative statements can be made that exposure to volatile chemicals
would increase.
Fish Consumption
Fillets from bass, perch, catfish, and carp (edible portions) were considered
to assess exposure to contaminants via ingestion of fish.
The health risks
were estimated based on a 70-year lifetime during which 6.5 grams of fish per
day from Fields Brook or the Ashtabula River are consumed.
The estimated excess lifetime cancer risk for the ingestion of contaminated fish
fillets from the Fields Brook area is as high as 1x10-3 although the brooks
contribution is uncertain.
The major chemicals contributing to this risk are
1,1,2,2-tetrachloroethane, hexachlorobenzene, and PCBs.
-------
6
ENFORCEMENT (CONFIDENTIAL) (See Attachment A)
----
AfTERNATIVES EVALUATION
- ------
The major objective of the feasibility study (FS) was to evaluate remedial
alternatives using a cost-effective approach consistent with the goals and
objectives of CERCLA.
The National Oil and Haz4rdous Substances Contingency
Plan (NCP), 40 CFR Part 300.68 (i), identifie~the procedures and criteria used
to select a cost-effective remedial alternative that effectively mitigates and
minimizes threats to, and provides adequate protection of, public health and
welfare and the environment.
The selection should attain or exceed applicable,
relevant and appropriate Federal pUblic health and environmental requirements
that have been identified for the specific site.
The scope of the Fields Brook Sediment Operable Unit Feasibility Study has been
defined as a management of miyration measure to prevent or minimize the release
;
of contaminants from the sediment of Fields Brook and its tributaries, and
therefore eliminate or reduce the risks to public health and the environment.
A remedial action selection and the operable unit approach is warranted
because a permanent remedy to the contaminated sediment in Fields Brook
(and to the exposure resulting from it) is achieved.
Therefore, it is con-
sistent with a permanent remedy and the NCP.
The first step in the evaluation process was to consider the feasibility or site
specific implementability of technologies.
The technologies considere~d but
were eliminated due to site specific inappropriateness are listed in Table 3.
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Table 3-5 (Page 1 of 5)
INAPPLICABLE TECHNOLOGIES FOR THE FIELDS BROOK SITE SEDIMENT
General Response
Action
Access Restriction
In Situ Containment
In Situ Treatmentl
Extraction
Techno logy I
Technology Option
Fencing
In situ stabilization
Injection grouting
Vitrification
K20 process
Ultraviolet!Ozonation
Biodegradation
Chemical Oxidation
Radiation
Bioharvesting
Solvent Extraction
50il Aeration
Comments
Does not prevent the
migration of contaminants.
Not appropriate for
fine sediments.
Not proven for application
to large volumes of wet
sediment in place.
Not proven for application
to large volumes of wet
sediment in place.
Pilot stage, closed sys-
tem only. Unable to pene-
trate deeply into sediments,
not available for in-place
use, end products may
have toxic effect.
~
Not proven for sediments
or wide variety of conta-
minants identified at the
site.
Not generally suited for
heterogeneous waste,
applications limited,
may have environmental
impact by nature of
treatment method.
Not feasible for in-
place applications
Conceptual, limited
effectiveness, slow,
experience limited to
liquid waste streams,
ponds.
Some solvents are toxic,
conceptual, no field tests
with fine sediment and the
variety of contaminants
identified at the site.
Not appropriate for fine
sediments in place
-------
c-;
Table 3-5 (Page 2 of 5)
INAPPLICABLE TECHNOLOGIES FOR THE FIELDS BROOK SIIE SEDIMENT
General Response
Ac tion
Technology/
Technology Option
Comments
Retrievable Sorbents
Conceptual, no field
tests, may be.ineffec-
tive with high concen-
trations.
Removal:
Removal Methods
Mechanical Dredging
(clamshell, dragline,
dipper, bucket,
ladder, sauerman)
The narrow width, shallow
water depth, and irregu-
lar stream bed character-
istics of Fields Brook
and its tributaries are
inappropriate for barge
based mechanical dredging
operations.
Hydraulic Dredging
(hopper, cutterhead,
dust pan, sidecaster)
~
The narrow width, shallow
water depth, and irregu-
lar stream bed character-
istics of Fields Brook
and its tributaries are
inappropriate for these
barge based hydraulic dredg-
ing operations. Inappli-
cable for materials above
the water line.
Pneumatic Dredging
(airlift, pneuma,
namtech, oozer)
"
The narrow width and
shallow water depth are
inappropriate for barge
based pneumatic dredging
operations. Also, the
shallow water column may
limit the effectiveness
of these pneuma~ic
methods. Inapplicable for
materials above the water
line.
Sediment Ireatment
(following removal)
Onsite:
Thermal
Pyromagnetics
Conceptual, more tests
needed, solvent extrac-
tion required for soil.
-------
Table 3-5 (Page 3 of 5)
INAPPLICABLE TECHNOLOGIES FOR DiE FIELDS BROOK SITE SEDIMENT
General Respon8e
Action
Technology/
Technology Option
Comments
W~t air oxidation
More applicable to aqueous
wastes, solids must be
groun~. catalytic reagents
needed for destruction of
chlorinated organics.
Multiple Hearth
Tiered hearths usually have
some relatively cold Spots
which inhibit even and.
complete combustion.
Fluidized Bed
Combuster
Limited applicability due
to difficulties in handling
of ash and residuals.
Molten Salt Reactor
I'
No commercial unit currently
available. Difficulties with
handling and disposing of
ash-contaminated salt.
Plasma Arc Reactor
Conceptual.
throughput.
Limited
Dechlorination processes
Aeurex
Conceptual, solvent
extraction required for
sol1s.
Hydrothermal
Conceptual; not demon-
strated for the wide
variety of compounds
detected in sediment at
the site.
KOHPEG
Conceptual; not demon-
strated for the wide
variety of compounds
detected in sediment at
the site.
.
NaPEG
Conceptual; not demon-
strated for the wide
variety of compounds
detected in sediment at
the site.
-------
...;
Table )-5 (Page 4 of 5)
INAPPLICABLE TECHNOLOGIES FOR THE FIELDS BROOK SIIE SEDL~NI
General Response
Action
Technology/
Technology Option
Comments
PCB X
Conceptual; not dereon-
stratp.d for the wide
vartety of compounds
detected in sediment at
the 3ite.
Goodyear
Conceptual; not demon-
strated for the wide
variety of compounds
detected in sediment at
the site.
C'
"
Aeration
Conceptual, not applicable
for wide range of compounds
found in the sediment.
Ultrav1olet/ozonation
Conceptual, shallow pene-
tration depth.
Radiation
Conceptual.
Solvent extraction
Some solvents are toxic
and may be left at resi-
dual levels.
Retrievable sorben~s
Conceptual.
Air Stripping
"
Questionable application
for limited group of
compounds and not demon-
strated for large volumes
of sediment.
Steam Stripping
Questionable application
for limited group of
compounds and not demon-
strated for large volumes
of sediment.
Biodegradation
Not demonstrated for the
wide variety of compounds
detected 1n sediment at
the site.
-------
Table 3-5 (Page 5 of 5)
INAPPLICABLE TECHNOLOGIES FOR THE FIELDS BROOK SITE SEDIMENT
Genera~ Response
Action
Technology/
Technology Option
Comments
Offsite:
Thermal
Pyromagnecics
Facilit.y with ability to
proce~s iQrge q~anLiti~5
of sediment unavailable.
Wet air oxidation
Fa~ility with ability to
process large quantities
of sediment unavailable.
Water Treatment
Onsite Chemical/Physical
Activated aluminum
Not applicable to treat-
ment of low volume aqueous
waste streams.
"
Solar evaporation
ponds
Climate at Fields Brook
is not appropriate.
~
Spray evaporation
Climate at Fields Brook
is not appropriate.
GLIS06/65
-------
7
The next step in the process was to consider general response actions for the
Fields Brook site.
The following general response actions were considered but
~liminated during the initial screening process using the NCP criteria of cost,
acceptable engineering practice, and effectiveness at addr~ssing site problems.
1.
Sediment collection by means of downstream sedimentation basins or sediment
traps.
These traps or basins would collect contaminated sediment transported
~
naturally by Fields Brook.
Contaminated sediment would have to be periodically
removed from the basins and either be treated or disposed of.
This alternative
was screened out for several reasons.
First, it would take approximately
800 years for all the contaminated sediment to be removed.
Secondly, since
the sediment would remain in place, the current risKs due to direct contact
and sediment ingestion would remain.
Lastly, sediment removal effectiveness
is considered unpredictable, and should a major flood occur, contaminants
could by-pass the structures, with their movement uncontrolled.
2.
Sediment containment by means of capping.
Four different
capping scenarios were evaluated.
They were: 1)
capping with new channel
excavation, 2)
capping integrated with existing brook location, 3)
capping
with in-channel conduit, and 4)
capping with external conduit.
In general,
capping was not considered to be a reliable long-term solution.
It has not
been previously demonstrated to be effective in a flood plain, and should
the cap fail potential exposure of contaminated sediment to the environment
could occur.
For these reasons sediment containment by capping wa~ screened
out.
-------
8
t~chanical excavation of sediment from Fields Brook to the defined 10-4
3.
risk level with temporary diversion.
In this alternative, approximately
99% of the sediment contaminant mass would be removed.
It was screened out
po
because a source of contamination would be left in Fi~lds Brook, primarily
in areas where potential exposure is greatest (residential areas).
The
incremental cost increase of removing the additional contaminated sediment
to the defined 10-6 risk level was not significant compared to the benefit.
;.
The initial screening concluded that the appropriate general response action
for the Fields Brook Sediment Operable Unit would require the mechanical excava-
"
tion of sediment from Fields Brook and its tributaries to the defined 10-6 risk
level or background (whichever concentration is greater), with the temporary
diversion of Fields Brook during excavation.
Thus, the assembled alternatives fo
detailed analysis would all be similar in terms of sediment removal from Fields
Brook and its tributaries.
They only differ in what would be done with the
sediment once it is removed.
DETAILED ALTERNATIVES ANALYSIS
After the initial screening phase was completed, the following alternatives
were developed and examined in detail:
1 )
2)
3)
4)
5)
Excavation of sediment with offsite RCRA/TSCA landfilling;
Excavation of sediment with onsite RCRA/TSCA landfilling;
Excavation of sediment with complete thermal treatment;
Excavation of sediment with partial thermal treatment;
No action.
-------
9
1 )
Excavation of Sediment with Offsite RCRA/TSCA Landfilling (AA-1)
AA-1 includes excavation of contaminated sediment in stream reaches with a
~alc~lated 10-6 or greater risk level (10-6 risk level removal option).
Follow-
ing excavation of contaminated sediment, gravel-filled gabions would be placed
in the disturbed streambed to prevent erosion and promote repopulation by
aquatic species.
The estimated volume of exc~vated sediment is 39,000 cubic
yards.
Additional estimated volumes of 3,90Q cubic yards of material are
expected to be generated during the site work and onsite sediment hauling,
3,600 cubic yards of sand and gravel from the uppermost layer of the interim
storage facility, and 2,900 cubic yards of clay and concrete from the uppermost
-
layer of the curing cell.
It is assumed that onsite solidification of the
excavated sediment would increase the excavated volume (39,000 cubic yards) by
another 10 percent.
Thus this alternative would require the disposal of about
53,000 cubic yards.
Excavated and solidified sediment and waste material would be landfilled offsite
in RCRA- and TSCA-approved landfills.
Sediment and waste with a PCB concentration
of 50 mg/kg or greater would be disposed of in a TSCA-approved facility, and
remaining sediment and waste would be disposed of in a RCRA-permitted facility.
Water generated during onsite dewatering at an interim sediment storage facility
would be collected and hauled offsite to a RCRA-permitted treatment facility.
The total present worth for this alternative is $30.6 million.
Mo re deta i 1 ed
costs are shown in Table 4.
2)
Excavation of Sediment with Onsite TSCA Landfilling (AA-2).
AA-2 incorporates the same sediment excavation plan as AA-1, i.e., removal of
contaminated sediment in stream reaches with a calculated 10-6 or greater risk
-------
TAB L E ~
~57 ~S7:~~7~ ;~~~r.Y (.;
~:J :; ~-t::::~~lvE 1t'J. l
;=;wS Ei\OC.'\ FS
c::: c:.~;:";£\-:-
CDNS-;:'.c;iCN
c.:---
;.;;1
A:,,\:'~:' .
o & ~.
[;~-5
~
1. SC::~Di n~',~ijCN 7Q 10 E57:!'<;.3
RlSX (~,Sr.:-~'Q)
A. ~!~ ~::!DN !=AC:UTY
B. T~~:~-~Tl~~
B. Tr..:.; 7rEtT
1::54, ~::1) ;,)
I-;:~ ..~~ .,
...-......I.i ."
I~c-= '1'\'" $3
-.,"""
SS~:..;~~ . .
."
Sl,~e~.~~ s~
..cS, 0ZJ a.-
..;
111,~ se
1161, e..'I! S~
;- 1Z34,£~ sJ
I.Si,~J 53
Sl,~,~ 10
14,16e\~~ iJ
~,S40,tl3 5~
~,7ae,aea SIll
sse,~ 111
~S,~J $~
1319,1£) Ii!
t18,7.,0ea II!
(15~) ",SI0,~;:e
(~) 13, 74e,e~
S25,3ge,~
I~) t7S9,~
(i~) tl, 770.~
127,800,029
!1~) 1C,780,Zi09
,;;a,&",~~a
1. e
t,;0,b00,15e0
t,;1,608,000
~ A. GE'.:E~ C:;N:m::)iS
B. ~~:.. 7:., ~\J ;~:w et.\S::t.~T:C:.s
c. 51 ~E Prs'"~..-- ~ C~~
O 01".--"""':> -.-.-..
. ."t.:-,:.~ wr ~:t\:J-I'
E. ~::-';'~i:;;j,. !;::(:A',;'7;JN
F. c,'ik.';:;::" ~E57CRA7! C~
~.IN7E~I" CNSIiE SED:~ 5Tu~~~
I
. ,
. .
A. SHE P;:S~i\ATICN
a. c:8.. C!J1\;~;:.;..iCTj~'i
C. FAC:UT!E5
D. CU::~~~ ~y w~:~
Eo :Dire.'!T FIXATi(.'i
3, CiFSm: DIE?OS;(. IF SEDI/J.8.i
"
A. L.~~:NS p.'~ ~.AlJL:~~
B. T5~ iJ;."-~:i..l. F~C:UTi'
C. RC~ Ji,~f:L!. FAC:~!TY
4. :fr:!:t: ~~~ TREAOOIT
c;:\'S':':::'.JC;I~ AND Q&IiI 5UE70TA:.
BID t:=NT~NE~C;ES
5t~~: ~~TIN~~IE5
Qt:-r;:o~:rION Ho'O O&~ TCT~
PEII!!TII~S AND L!SAL Ib)
SERVICES DUF.!~6 CQNS71ilA:TICN
~
TOTr.!.. I~..:J"9iA7ICN COST
EM;j~JUN6 DSIGH W£i Ie)
~
TCTRl ~:T~ :jST (d)
PRE:~ iiQ~:n F~70R
PRSENi IiO~~ Ie)
---
--
TOTri. PRE:2f>' iI1JR7H
t«JTES:
ta) Costs art shown to 3 Slgniflcant figurtS or t~e r~arP5t thousand dollars. See Aapeneix ~
for oetalitd cost tst~3ates.
Ib) Incll:oes envl~T':IIIenul .na nonenviroT\llt!ntal ~eMl1t5, and COIIIIunlty rtl.tioftS.
Ic' I'!'Ic:;;:1tS the Sltlna studY.
(d) Lir.d iCCl:151t:cn nOt lr.:ll:ce~ In ~5t est1~ate.
(e' Prtsent .ort~ .t le~ lnttrest over ~a years.
-------
10
level (10-6 risk level sediment removal option).
Following excavation of
contaminated sediment, gravel-filled gabions would likewise be placed in the
~ ~
~isturbed streambed to prevent erosion and to promote repopulation by aquatic
species.
Disposal volumes are also the same as AA-1.
AA-2 includes sediment solidification and related waste material disposal at an
onsite RCRA/TSCA-type landfill.
Sediment and " wastes with a PCB concentration of
50 mg/kg or greater would be disposed of in a separate onsite cell.
Water generated during onsite work would be collected and treated onsite for
removal of suspended solids and dissolved organic compounds by activated
carbon adsorption.
Treated water would be discharged to the Ashtabula POT~ or
directly to Fields Brook taking into consideration National Pollutant Discharge
E1 imination System (NPDES) requirements.
The total present worth for this
alternative is $18.6 million.
More detailed costs are shown in Table 5.
3) Excavation of Sediment and Complete Thermal Treatment (AA-3).
AA-3 incorporates the same sediment excavation plan as AA-1 and AA-2,
i.e.,
removal of contaminated sediment in stream reaches with a calculated 10-6 or
greater risk level (10-6 risk level sediment removal option).
Foll owi ng
excavation of contam1nated sediment, gravel-filled gabions would likewise
be placed in the disturbed streambed to prevent erosion and promote repopulation
by aquatic species.
AA-3 includes construction of an onsite RCRA/TSCA-type landfill.
The: onsite
RCRA/TSCA-type landfill would be used to temporarily store excavated sediment
during the siting, permitting, design, construction and operation of an onsite
-------
TABLE 6-5
CDST ESiI:1ATE SUP!P!ARY (a)
ASSaIBI.E) At. iERNATIIJE NO. 2
FIELDS 8im( FS
CDST COMPONENT
~
1. SEnIieT EXCAVATION TO 1i ESTIJIATED
iUS!< (8j:1CKGRQUND)
A. 6E?E!U1. CONDITIONS
B. HEALTH AND S~ CONSIDERATIONS
C. SITE P~ARATION
D. DIVERSION OF STREPtM
Eo M€01At4ICAL EXCAVATION
F. CHANtEI.. RESTORATI~
CONSTRUCTION
casTS
AtftR.
o & 14
('(EAR 1-30)
1tE=,LHCB1ENT
(YEAR j0)
TOTAl.. al)lTAI.. CtJST (e)
PRESENT WORTH FACTOR
PRESENT WORTH ( f)
sJ54, - sa. ~
S365,000 ,. ia
S389,- N '$\i
S959,008 18 ~Id
Sl, 500, 008 i0 .~
S469,008 sa Sid
'11,- sa $0
'161,- S8 50
SJ84, - 50 10
$191,- '1,- ,a
'1,92e,~ Si .0
== Ie $8
sa 58
S80i, - sa 50
t645 008 $22,- sl
1694: - $32, - t09't, 008
t306, - $I 18
$273," S8 S8
19,- 18 S0
'111, SiI, - sss, - 1694, IJ0e
'l,sse,- (1~) S6,- (1~) 1104,-
12,101,- (1~) '58, 008 (m) 51.3'3,00a
'14,208,008 s6'3, - J937,000
S8S2, - (~) .1 008 (6") $56,0~a
'994,- (~) sc;. (7~) 166,000
. -.....
116,0_,- $72, - Sl,~0,000
$1, 92i, "08 (~) 50 (6~) S64!~tJ0
'17,_,- '72, - '1,124,000
1.1 9.~9 0. 05i3
=
'17,998,- 1679,000 164,0011
'18,608,008
2. INTERIM OHSITE SEDIMENT STORASE
A. SITE PREPARATION
B. CELL CONSTRUCTION
C. F~ILITIES
D. a.oSURE AND CAPPING
Eo SEDIMENT FIXATION
-
3. ONSITE LANDFILL
A. SITE PREPARATION
B. BERtI CONSTRUCTION
C. CELL CONSTRUCTION
D. F~ILITIES AND MONITORIN6
Eo CAP CQNSTRLCTION AND MAINTENAra (b)
4. ONSITE ~TER TREATJIIENT
A. TREATMENT F~ILITY
B. OPERATION CF sysm
C. DISCHARSE
CONSTRlCTION AND 0&11 SUBTOTAl..
BID CCNTIN6e.tIES
SCtJPE CONTINGENCIES
(15")
(~.)
CONSTRUCTION AND OIM TOTIl.
PEnMITTING AND l.ESI1. (1:)
SER'JICES DURING CONSTROCTION
(~)
mu
TOTAL I>IPl.f!IIENTRTION COST
ENGINEERING DESIGN COST (d)
(1~)
TOTAl.. PRESENT WORTH
NOTES :
(a) Costs are shown to 3 significant figures or the !!t!arest thousand dollars. Set aDpendix /it for detailed
cost est irl1at es. '.
(b) Replacement of landfill caD at year 30.
(c) Includes environmental and' nonenvironmental permits, and community relations.
(d) Includes the siting studr and bench or pilot scale studies for solidification.
(e) Land acquisition not inc uded in cost estilllite.
If) Present IiIOrih at 10" interest over .30 years.
-------
11
thermal treatment facility.
Sediment with a PCB concentration of 50 mg/kg or
greater would be contained in a separate onsite cell.
Solidified sediment
co~aminated with only arsenic (3,000 cubic yards) would be disposed of in a
separate compartment within one of the cells of the new onsite RCRA/TSCA-type
landfill.
An estimated total of about 41,500 cubic yards of contaminated
material would be thermally treated (See Attachment C for thermal treatment eval.).
,
Ash resulting from thermal treatment of the sediment would be considered a
hazardous waste and disposed of in the onsite RCRA/TSCA-type landfill
unless it is demonstrated through testing that the ash could be managed as a
nonhazardous waste.
If conditions require it, permanent landfilling of the
ash from thermal treatment at an offsite RCRA/TSCA-approved facility may
also be considered.
Water generated during onsite work would be collected and treated onsite for
removal of suspended solids and dissolved organic contaminants by activated
carbon adsorption.
Treated water would be discharged to the Ashtabula POTW or
directly to Fields Brook taking into consideration NPDES requirements.
The
total present worth of this alternative is $61.7 million.
are shown in Table 6.
More detailed costs
4)
Excavation of Sediment and Partial Thermal Treatment (AA-4).
AA-4 is the combination of AA-2 (complete onsite landfill) and AA-3 (complete
onsite thermal treatment).
AA-4 incorporates the same sediment excavation
plan as the three previous alternatives, i.e., removal of contaminated ..
sediment in stream reaches with a calculated 10-6 or greater risk level
-------
TABlE 0-,)
CDST ESTIJ!!ATE SU.I9!ARY (a)
ASSaIBlE) HI..~NATIVE NO. 3
FIELDS BROOK FS
CDST COfIQ£NT
-6
1. SEDII'IEHT EXCA'JATION TO 10 ESTIMATe)
RISK (BACK6RIJIJHD)
A. 6a£IR. CtJNDITIDHS
B. I£SI.TH AND SAFETY I»ISIDERATIIJE
C. SITE PREPARATION
D. DIVERSION OF STREAM
E. IEOiANICAI. EXCAVATION
F. CHANNEl.. RESTORATION
CCNSTRLCTI~
COSTS
ANNA
iID!ED IAl.
COSTS
(YEAR 1-6)
ANNUAl.
a & ~
(YEAR 1-30)
rt[cLHC8'!EN T
iYEMR 3~)
3.ONSITE n£iDA. TREAlJEHT (ROTARY KILH)
A. SHE PREPfmATIDN
B. EilJIPMENT
C. INSTAl..LATIDN AND START lP
D. OPERATION OF FACILITY (c)
.. ONSITE WATER THEA'O£NT
A. TREA'O£NT FACILITY
B. IJIEAATION IF FACILITY
C. DI~R6E
~," sa 50
S365,988 50 se
S389," sa 50
1959, - - sa sa
11,S8I,- SII SII
1469,. 58 ~
S488, - . 58
S62J," sa se
~: sa 50
sa S22.-
=:= " sa
sa S32-
'94,. S8 'sa
t288,.. . 51
~338,- . sa
12,-- sa se
tIJ 14,838," 50
S386," " .
t269," " se
19,. " 58
50
il,)
50
,I,)
50
50
2. ONSlTE U1NDFILL
A. SITE P~RATIDN
8. BERM C!JNSTRUCTlON
C. cw. CONSTRUCTION
D. FACILITIES AND MONITORING
Eo TEJlRJIiIRY ClMR
F. CAP CCNSTIUTIDN AND iifAINTeA'G (b)
G. SOLIDIFICATION OF ARSENIC WASTE
50
;0
50
~0
~
56'34,000
50
'0
.0
5J.1
50
J
.
118, -, - 14, aJ8," 154,- i694, M
12,788,- (1~) MaJ, - (1~) '5,- (15") il04,~0
14,581," (15) I~,- (15) sa,. (.:~) 513'3,000
e, 218," S6, Me, - 167,- .937,.
11,761,- (~) 1121,- (~) II,. (6") s~,~1
t2, L~," (3") '181,. (3") 12,- (7") t6c,~00
t29,-,- $6,342,. $70,- $1,06Ia,~0
14,358," (~) ~ (~) 50 (6") $64,~i1
S33,'-, - S6,~ - '70,000 n, 120.-
1.1 4..3553 9.'taS3 d.~73'
W,.,- 127,688, - t660,1»0 J64,0\:0
-
161,781, ..
CQHSTRl£TION AND IJ&II SUBTOTAl.
BID COO'INGOCIES
saJIE CDNTINGEHCIES
(1SS)
(~)
CCNSTIUTIDN AND OIM TOTII.
PERMITTING AND L.ESAL (d)
SERVICES DURINS ClJNSTIu:TION
(n)
(S,,)
TQT~ nR.oorATI~ COST
9I6INEERINS DESIGN COST (e)
(ISJ)
iOiAl. CAPITAl. COST (f)
PRESENT IIJRTH F~R
PRESeNT WORTH eg)
TOTAl.. PRESENT IIJRTH
NOTES:
ea) Costs are silOIfft to 3 significant figures or the nHl"eSi thouund dollars. See appmiix /II for detailed
cost est i8itn. -
(b) ~eDlaC:l!III8nt of landfill c:ap at year ~i.
(c) Total oplrational expenses during clean up activities basad on a unit cost of '70d per cubic yard. This unit
cost could range between S5~ ana $1,508 per cubic yard.
(d) Inc:lWlIS envu'o1'llental and nonenvirol'8ntal ptr'llits, ind COI8UlIitr relations.
eel Inc:ludn the siting study and bench or pilot scale studiRS for so idification and thersil treatment.
(f) Land acquisition not included in cost !Stiute.
(g) Present IIOI"th at 1~ interest over 3a years.
-------
12
(10-6 risk level removal option).
Following excavation of contaminated sediment
gravel-filled gabions would likewise be placed in the disturbed streambed to
-
~revent erosion and to promote repopulation by aquatic species.
AA-4 includes construction of an onsite RCRA/TSCA-type landfill.
Portions
of this onsite RCRA/TSCA-type landfill would be used to temporarily store
about 16,000 cubic yards (approximately 40%) of excavated sediment during the
siting, permitting, design, construction and operation of an onsite thermal
~
treatment facility.
This 16,000 cubic yards of sediment would be subject to
thermal treatment.
The remaining portions of the landfill would contain about
,
36,000 cubic yards of solidified sediment and other material.
Ash resulting from thermal treatment of the sediment will be considered a
hazardous waste and disposed of in the onsite RCRA/TSCA-type landfill unless
it is demonstrated through testing that the ash could be managed as a nonhazar-
dous waste.
If conditions require it, permanent landfilling of the ash from
.
thermal treatment at an offsite RCRA/TSCA approved facility may also be considered.
Water generated during onsite work would be collected and treated onsite
to remove suspended solids and dissolved organic contaminants by activated
carbon adsorption.
Treated water would be discharged to the Ashtabula POTWor
directly to Fields Brook taking into consideration NPDES requirements.
The
total present worth of this alternative is $48.4 million.
More detailed costs
are shown in Table 7.
. .
5)
No Action (AA-5).
AA-5 is the no action alternative.
Under AA-5, no further action of any
kind would be done at the site.
There are no costs associated with this
alternative.
It is presented as a baseline for comparison.
-------
TABLE 6-7
COST ESTIMATE SlJiIItIIARY (i)
ASSEMBlE) ~TEilNATII,IE NO. ..
FIELDS BRCCK Fa
CDST CIJMPONOO
-6
1. SEDIMENT EXC,CMHION TO 1" ESTIMATED
RISK (BACKGROUND)
CCNSTRUCTION
casTS
~
ReEDIAL
CDSTS
('fEAR 1-3)
ANNIA
o & it
(Y~R 1-;)0)
:1EPLH~'"'1ENT
(Y~R 30)
A. GENEAAI. CONDITIONS
B. HEALTH AND S~ CDNSIDERATIOHS
C. SITE PREPARATION
D. DIVERSION OF STRErM
E. ;'lfECHM.~ICAl EXCSWATION
F. DiANNa. ReSTORATION
~.INTERIM STORAGE FACILITY
'354,. sa Ie s8
IJ65 - t8 se 10
1389: - sa 18 Sla
ISS9,. sa 58 S~
11,508,. 58 50 sQ
1469 - ~ ~ S0
- ,
'11,. sa 50 '0
'161,. Ie 50 S0
S384, 088 sa se slit
'167,. 58 $1,008 10
'1,238,. sa 50 10
S488,. t8 se S~
t62J, - 58 sa ~0
11,238,. 58 50 S8
S624,. t8 t22,- 50
S357, - S8 t8 50
S628,. t8 tJ2,- -5654, 000
-- t8 .. S8
$S, 338,. .. 50 10
12,_. .. .8 s8
t8 SJ, 858," .. se
~:= .. .. sa
t8 58 '0
$9,. t8 .. i.
'18, 9.," t3,sse,- 155, - $694,008
12, 848, - C1 "') t385,. C1 "') so,s. US,,} 1104,13138
$4,738, - US,,) $578,008 US,,) sa,. (2~) 1139,009
6, 581J, 008 $4,610,. 169," $937, ~014
11,861),008 (~) $96, . (~) 11,- (6") s:6,0~e
t2, 129, 008 (3") 1144,. (3") ~000 17%) i66,iJta8
~"'0, 5138, 000 .S,IaS8,000 '72, - i1,~0,~0
$4,580,- ("') 58 (~) 50 (6%) - 164, J08
'35, 1.,- 15,059,001 '72," '1,120,0\18
1. a 2.4869 9.4269 0.~13
-
m,l.,. '12, 608, 098 167'3, 000 '64!~
--
148,400,-
A. SITE PREPARATION
9. CELl. aJETRlCTION
C. FACILITIES
D. a.OSURE BY c.cIPPINS
E. SEDI~ FIXATION
3. CNSITE lR4IFIU.
,
A. SITE PREPARATION
B. BERM CONSTRUCTION
C. CELL CONSTRUCTION
D. FACILITIES AND MONITORING
E. IDIPORARY ~
F. C,C¥) ClJNSTRUCTION 11M) ItUN~ (b)
3. OHSITE n£RIIR. TREAMHT (ROTARY KILN)
A. SITE PREPARATION
9. EIlJIPMENT
C. INSTAWTION AND START l.P
D. OPERATION OF F~ILITY (c)
f. CNSITE WATER TREAnEHT
A. TREATfDT F~ILITY
9. OPERATION OF F~ILITY
c. DISCHARGE
:CNSTRUCTION AND 0&11 SUBTOTII.
BID CDNTIN6ENCIES
SCOPE CCNTINSe«:IES
DNSTROCTION AND 0&/11 TOTAl..
PE~ITTIN6 AND LEGit. (d)
SERVICES DURING CONSTRUCTION
<1~~)
(25J)
(~)
(~)
OTAI.. IMPI..E!'1ENTATION COST
ENGINEERING DESIGN COST (e)
OTAL. C~ ITIIl. COST (f)
PRESENT WORTH FACTOR
<151.)
RESOO WORTH (g)
JTIIl. PRESENT WORTH
NOTES:
(a) Costs are shown to 3 significant figures or the nearest thousand dollars. See aDpendix !If for detailed cost estilllc1tes.
(b) Replacgment of landfill cap at year 30. -; -
(c) Total operational expenses during clean up activities based on a unit cost of S70~ per cubic yird. ihis unit
cost could range ~etween $~~~ and 51,500 per cubic yard.
(d) Includes environmental and nonenvironmental perlDits, and co_unity relations.
(e) Includes the siting study and bench or pilot scale studies for solidification and therMil treatment.
. (f) Land acquisition not" included in cost estillite.
(g) Present worth at 10% interest over 30 years.
-------
13
ALTERNATIVE SCREENING PROCESS
The detailed screening process used to select the remedy was performed
~ns;stent with the NCP, 40 CFR Part 300.68(h), U.S. EPAls most recent guidance
concerning the selection of off-site remedial alternatives, and other Agency
guidance as appropriate.
The NCP criteria used in the detailed alternatives
analysis were:
1.
Consideration of established technology and innovative alternative technology
as appropriate.
2.
Detailed cost estimation, including operation and maintenance (0 & M) costs,
and distribution of costs over time.
3.
Evaluation in terms of engineering implementation, reliability, and construct-
ability.
4.
An assessment of the degree of protection provided by a given alternative,
including the attainment of relevant and appropriate Federal standards.
5.
An analysis of whether destruction or other advanced technologies is appro-
priate to reliably minimize present or future threats.
6.
7.
An analysis of adverse environmental impacts.
Consistency with the final remedy.
A summary of the alternatives with respect to the above criteria is presented in
Table 8.
COMPARISON OF ALTERNATIVES
ASSEMBLED ALTERNATIVE AA-5
The no action assembled alternative is ineffective in preventing further
contaminant migration and does not mitigate or minimize the existing threats to
-------
.
ASSEMBLED ALTERNATIVE ASSEMBLED ALTERNATIVE ASSEMBLED ALTERNATIVE ASSEMBLED ALTERNATIVE ASSEMBLED ALTERNATIVE
1 2 3 4 5
ORDER OF
MAGNITUDE .
COST ESTIMATES
T 0181 Cepitalb S;UJ,600,OOQ $17.900.000 $33,400,000 $35,100.000 80
Pr..nt Wonhc $J<),600,00Q $18.600,000 $61,700.000 148,400.000 80
EIiIQ....tion of Ydim8l1' rlR'lOYft contamin-
~~~~N~:::} ann to b«:kground Of 10.6 ,ilk lhel con.
~~~:~:::kgr":~~C;::k ~cr;:~~::==~.~~con. ~::=~~:~::~~~~cm1' cenUlliOns Iwhichever i. gr.aUld. About
16.000 cubic verdi of conwniMtlld .-di.
t8V8J concentrlltiona (~ .. rllk IIV8I concentr.tions hwhlc:hevw rilk lewl COOC8nlra.ion. (lIiItIhi~ ment contlining th. meat mobile oon.8I'1"18n.
PwfOfmence + gr"'8(). Approxim8t8ty 53.000 + " gruterl. ApproxltTIItlly 53.000 + i. "...erl. ApprOxil1\8111y 41.500 ++ ann with.t Ian. 10-6 Mdiment ing8ltion NA
cubic vania dilpoe8d of. SedifMnt CUR yards diapoud of. Sediment cubic vercb therfn8lty treated.
solidified end ditpoted o' 0"- in IOlidlfild and d1tpo88d of in In 0..1.1 fiSk 0' PCS', conceRn.tlOnl gr...., th8n
Rllilbility + RCRA end/Of TSCA tendfiJl. WIlt. + RCRAITSCA tYpe l8ndfill requiring + Arsenic cont8lTlineled sediment + 50 mg/kg .... Ihermally tr..ted. The rl,,",in. NA
uuec:ted 'rom ~imenl dilpoMd 0' ongoing ...intl..nc:e Ind monitoring IOlldi'illd Ind dilPOllld 0' in seperatl Ing contamittlltltd lIdimena will be sohdlfild
o'bltl It RCRA 'acllitv. -. with MPM8" cell 'or PCB con- call 0' onlit. landfill. Thermal trUt.
ImplemltltlbiUtV + IkC8¥8tion performed during &y 0 t8ITIlnat8d sedil'n8flt. Watlr extraCted - ment of sedimenl ORlil' .Iiminal" - Aboul 36.000 cubic yard. of solidified ledi. NA
IUfT8IT* month, and may require from Mellmant and colltCtld from orgenic contam......n... and dbtroya m.nt and Other materia' will be dilpoMd 0'
up to 2 vearl to campi.... landfill trtailld on.i.. and d..c~rgad 99.9999 percent of PCB.. Ash in an on.il' RCRAfTSCA . IYpe "nclflll
Sol... - - to POTW or dir8C1ly to wrface - dispoaaJ in ORlIII RCRAn-SCA - Iiong wilh the rllidual hom IhI thermal NA
wallr. SedirT'llnl '.CilVllion perlormed Iype l8'1dllll. Walar .xtr8Cted Irom U..Ifn8nl facililY. Waler I.tracted from
during dry 5ummar month. and may sedimenl and coliecl8d hom 18Rd- IId,",lnl and colleCted trom the landfill
require up 10 2 yun to wmp"". fUland thermal tr..tment facllitV or lhermal tr..tment 'acililY would be
would be trUltd onlillind dil- lIellld onslte and discharged 10 POTW or
charged 10 POTW or direclly 10 dirac.ly 10 ",rteel waler.
SUrflce """"I'
Will requirl gtn.ltor ID. Shou1d
Will requirl gen..tor 10. Should at..ln SUrfacl W8l'" atand8rdl bec8u..
INSTITUTIONAL ....in aurfKI water mOO-cis beau. contaminan"lr. removed and tr..tld.
CRITERIA f Will require .,.Ir,tor 10. Should Will require gener..or ID. Should contlminan"lr. removed end uutlll. Rehabilitation of brook lhouka en. Area would continul to be unco...
Ittain surf8C8 water atandarda b8cau18 8ItaJn surfac. W8t.r ltand8rdl Rlhabilitation 0' brook 5hould an. hence public U18 0' th8 ...... Land- trolled huardoul _tI sitl.
contamin""1 are removed. Rehabili. bIc8u.. contaminants Ire r8fnOYtld. hence public use of thl ...... Land- 'ill ar. would MId 10 be rezoned
Standlrdl + ..tion 01 brook should .nhance pub. + Reh8bilitation 0' brook thould + 'iII area would need to be rezonld + ,nd dlSignlt8d . hazardoul wate -
lie u.. 0' .... No luning or 1'00 ,n"'nee public UN of..... Lend- and designetld as haurdoul wat, landfill. unl... incinerltor/rhetor
'-ml.. d 0 U$8 changes required. CERClA re. - fill ar.. woukl n~ 10 be rlloned. - land.ili. unle. incinerator/rlactor - .111 i. dIItlrminad to be I non. 0
quires that o"aill diipOl8l of con. des.igft8lad II haz8rdous WII" uh is determined 10 be , non. ha18rdous wllta. A,..nk con...
tamin,,,d sediment be tak.n to tandlill. con.nuctld. Ind contin- , ha18rdous wasil. Af18nic con.. . minetld sedimem sotldi.lld and
Land U./Zonlng ++ pllrmitted halardoul wate manage- - uouaJy monitored in accordance - minated l8cIimem solidified and - diapolld of in separ"l cell 0' -
m.nt 'acilitl.. in compliance with with RCRA. The uacllocation disposed of in seperate cell 0' onN" landfill. Thermal .,...mant
RCRA. Allume. 8OIidifiColilion ColIn and Ingil'll8ring t...ibiliry 0' onlh.l.ndfili. Thermal trealment facility will involve ",eat.r lit.
be dlmonuraled 10 reduc. the Ih.landlill need. 10 be dltlt- 'acllitY will Involve grea..r .h- ing and permitting "'on lhan
mobllilY 01 conlamlnan... mined. Auumh solldific.ltion can inglnd permitting Iffon lhan other .hernali\t8l. Over 5 V""
be der'hOnltrltld !O rlduee Ih. other Ilternaliyes. Over 8 years ...e estimated to Ii... permit.
mobility of conlamiNln... are ..tim.ted to lill, pwmit. bid. design, construct.nd oper.ta
bid. design. construct and operatl an onli.. thermal "..tment
In onli.. thlrmat tr..tment facililY. Assumes soltdificallon can
.acility. be demonllrat8d 10 reduci Ihe
mobilily 01 cooum.nanu.
Cont.mlnena removed and Contaminana rerncwed end Comaminanalrl removed and organic Con!8ftlinaru'lrl removed and mobile
trlltll,.,111 to 0",1.. iancafiU. COntained in ooli.. landfill. conurnlnanu"'l dlnrovad. h81Xtat organic conlaminenu are deslroyed. Migration 0' comaminanu continue..
ENVIRONMENTAL hebiUt r8hebilitattd. no adw8rIa habitat rehabilitated. no adV8r8I rehabllit8l8d. no 8dver. efflCtl Immobill conuminanu are con. Potlnl'I' .s..,... imPKt on wildlife.
l8ined. Habital rllhabilil8.ed. no
CRITERIAf effects anticlP8tlld. Short-term "facu Indeipetlld. Short.l8'm andci.-ted. Shon-term diitUrbanc:8 ad",.,.. IfleclS .",~lp8t8d. Shorl. Bi08CCUmulation 0' conlaminantS
dllturbenc:e dua to ,xcavation + dilturb8nc8 dul to uCMJ8don and +i due to excavation end tnlek traf'ic. ++ larm di51urblnclt due 10 ucave- -- may be occurring. POlenlial
Biological + .00 lruck uaffic. R8habilltllted trYCk traffic. Rehabilitated brook Rehabllll8led brook would bKonw tion and truck traffic. R8habili- 'or human Ingntion 01 con.
brook would b8com8 _t to would b8coma _t to communltV. I+i ..... to communitv. P0l8nd.1 'or caled brook WIiIOukt bkome UIItt to - taminated Ii"'.
Humen + communitY. + Landfill fNy detract 'rom oammunirv. managing the ash 81 1 nonhaL.dou. ++ communilY. POI.,,111 tor:nenage.
waltl. menl of 8Ih as a nonheurdoul W81t1.
PUBLIC HEALTH May be soma expolure to 'ugitiYI dust May be lOme expolure to fygitiva dUll MaV be some expo...1 10 'u"ili~ dust May be lOIne exposure 10 lugilive duSt Unlimited site IlXelll. curr.nt "Ii-
CRITERIAf .nd volatil..; exposur' c:an be mitl- and volatll,,; upoaur. can be mili. and Voll!il8l, exposura can be mid. and yotelil..; expowre can be mili. . :;'~i:e;~:.:~:,::::~~~.
gated. Contaminanu removed and galed. Contamlf18l'1u rerno~.nd IIli- g8111d. ContaminarUi rernc>wd and galed conllminanu rlmoved and
Shan-term - :::.~:~: 1';U~t ingts. - ::=n~:~~=n:~~lion - :i::.:;:~~~= =i=~1 ;~,~- - ~~":~::;;~~= l:i::~1 ;~: -
Orgenic coruaminanu Ifl db. Highly mobil. organic conlamin-
long-term + + + troyed. + In... and PCBs Ire desuoytd. --
NOTES,
'The Am.ican Auociatlon 0' Cost Engineera definaa an Order-o'-Magnilude Estimate as an approximate ntima.. made without
d8UIil8d engin88fing da... It is normally u~ that an estimate 0' Ihis type il occur.te within +5O'K. 10 -~. Sources 01 cost
in'ormation include thl U.S. EPA'. "Compendium of Coli 0' Rernw;li.1 Technologielal Halardoul Waste Siln:' the Means
Sit. Work Con o.ta Guide. CoIl R.'..nee Guide lor Copsuuction Equipment and vendor ellitnllt...
byolal Capital Cost includl indirect COlt lor .ngin_ing lItV~s. legal fnl. administralion cosu and con conunAlnClel.
Re'ar 10 lib.. ~ Ihrough 8.7 lor llU"",,-y of II" COIl hUmatl'or each .""'",tive.
LEGEND
-- EXTAEMEl Y NEGATIvE EFFECTS EVEN WITH MITIGATING MEASURES; CAPABLE OF ELIMINATING AN ALTERNATIVE
NEGATIvE EFFECTS BUT NOT STRONG ENOUGH OR CERTAIN ENOUGH TO BE THE SOLE JUSTIFICATION FOR
ELIMINATING AN ALTERNATIVE; OR OF ONLY MODERATE SIGNIFICANCE
eTOlI1 Prftlnl Worth Colt it bned on 3O-y..r period end 10 perC8nt Inl.rlli. Pr...nl worlh cosu includes r.placement
COlli lor landfill C8PI in Aulmblad Alt-neli.,. No. 2 and 4.
D
OF VERY lITTLE APPARENT POSITIVE OR NEGATIVE EFFECTS. BUT INCLUSION CAN BE JUSTIFIED FOR SOME SPECIAL
REASON; OR NO CHANGE fROM EXISTING CONDITIONS
A POSITIVE OR MODERATEl Y POSITIVE BENEFIT
d'According 10 the Nadonal Contingency Plan and current U.S. EPA policy. environment.!
permlU ar. not required for ontit. Fun(:J.flnanced CERCLA actions. hOYfilwr. the technical
.-.quir,""".. n",.V' to obtain 8 permit .ft required 10 be fulfilled.
+
+ + AN EXTAEMEl Y POSITIVE BENEfiT
ANAL YSIS NOT COMPLETE OR INAPPROPRIATE TO DRAW CONCLUSIONS AT THIS TIME
.
>.
Uk., 10 en O"SII' facility lor dispoNI. the 18nd ull/lomng rlung becomes 0:
.
NOT APPLICABLE
.ndl. D 'or definitions 0' cnteria.
-------
14
public health and welfare and the environment.
The Exposure Assessment concludes
t~at there is a potential for exposure of the public to contaminants at the
site at levels that may adversely affect public health and .welfare.
Therefore,
remedial action is required to mitigate or minimize this exposure.
Thus, the
no action assembled alternative is not appropri.ate and is not recommended by
U.S. EPA.
?
ASSEMBLED ALTERNATIVES AA-1, AA-2, AA-3, AND AA-4
Assembled alternatives AA-1, AA-2, AA-3 and AA-4 all involve mechanical excavation
of contaminated sediment in Fields Brook and its tributaries to the level
defined for the 10-6 excess lifetime cancer risk.
Excavated sediment would be
solidified and disposed of at an offsite RCRA/TSCA facility (AA-1), solidified
and disposed of in a RCRA/TSCA-type landfill constructed onsite (AA-2), thermally
treated at an onsite facility with the resulting ash landfilled onsite
(AA-3), or a combination of onsite thermal treatment and onsite lan~fill (AA-4).
Water generated from sediment excavation, sediment dewatering, sediment solidifi-
cation, or construction and operation of onsite landfill facilities would be
treated either offsite (AA-1) or onsite (AA-2, AA-3, and AA-4).
The extent of sediment removal for these four assembled alternatives would be
the same; therefore, the environmental and public health benefits from sediment
removal at the site would be similar.
U.S. EPA believes that the risk associated
with exposure to or ingestion of contaminated sediment would be reduce~ by
sediment removal to levels that are protective of public health and welfare and
-------
15
the environment.
Onsite and offsite water treatment also have similar environmental
benefits.
Thus, these four assembl ed alternat ives differ primarily in respect
to the treatment and disposal of the excavated sediment.
..
Assembled alternative AA-1 (offsite disposal) has similar. long-term environmental
and public health benefits as AA-2 (onsite disposal); however, its present worth
is greater.
Thus, on the basis of present worth cost only, AA-2 is preferred
Assembled alternative AA-1 has a short~r time frame to implement,
..
over AA-1.
however, there is no assurance that there would be available RCRA/TSCA landfill
capacity, that these landfills would accept the solidified Fields Brook sediment
and that these landfills would be in compliance with the applicable environmental
regulations.
Assembled altenative AA~l also depletes existing landfill capacity
that could be used for disposal of other hazardous wastes, while AA-2 creates
its own landfill capacity.
Alternative AA-1 does not require resolution of
issues relating to siting a RCRA/TSCA-type landfill at the Fields Brook site,
while AA-2 does.
However, based upon the cost and the uncertainty of landfill
capacity and availability, U.S. EPA does not recommend AA-1.
U.S. EPA believes AA-3 has greater long-term environmental and public health
benefits than AA-2 and AA-4, because organic contaminants present in the sediment
would be destroyed through thermal treatment.
U.S. EPA also believes that AA-4
would have greater long-term environmental benefits than assembled alternative
AA-2 because the more mobile and higher risk organic contaminants in about 40
percent of the contaminated sediment would be destroyed through thermal treatment.
Assembled alternative AA-2 solidifies all of the sediment and disposes-of the
solidified sediment at a new onsite RCRA/TSCA-type landfill.
-------
16
Under AA-4. sediment that contains organic contaminants with higher mobilities
(Koc's (soil-water partition coefficients) less than 2.400 ml/g) and greater
risk,(greater than the 10-6 excess lifetime,cancer risk for sediment ingestion).
~
or that contain PCR's greater than 50 mg/kg. would be thermally treated (See
Attachment B).
The organic contaminants in the remaining 60 percent of the
contaminated sediment would be treated through solidification to further reduce
the mobility of the remaining organic contamin~nts ~efore disposal in an onsite
RCRA/TSCA-type landfill.
It is expected that'this 60% of the contaminated
sediment could be successfully solidified and landfilled with long-term reliability.
If this is not the case. this sediment may also be subject to therMal treatment.
All three of these assembled alternatives (AA-2. AA-3 and AA-4) require resolution
of issues related to the technical requirement of the permitting process and the
siting of a RCRA/TCSA-type disposal facility at the Fields Brook site.
In
AA-3. it is possibile that the ash may not be considered a hazardous waste. if.
after thermal treatment the ash is shown to be nonhazardous.
The ash would
then be managed as a nonhazardous solid waste. and disposal at a RCRA/TSCA-type
landfill would not be required.
Both AA-3 and AA-4 also require resolution of siting and permitting issues related
to construction of temporary thermal treatment facilities at or near the site.
This would include demonstrating that operation of the thermal treatment facility
is in compliance with air quality regulations.
Construction of a portable thermal
treatment facility for AA-3 and AA-4 would create additional nationwide thermal
treatment capacity.
This new capacity could be utilized at other CERCtA sites
by transporting and reassembling the portable thermal treatment facility at
-------
17
another site after the contaminated sepiment at Fields Brook has been treated.
Because destruction of hazardous substances possesses greater environmental
-
~nd public health benefits and permanent reduction of the potential risk of
landfill failure, it is considered more reliable in the 10ng term.
Consequently,
U.S. EPA believes AA-3 and AA-4 are preferred over AA-2.
While AA-3 destroys all of the organic contaminants by thermal treatment, AA-4
~
destroys those organic contaminants that are more mobile and have higher risks
associated with them or the sediment with PCB concentrations greater than
50 mg/kg, leaving the relatively less mobile and lower risk contaminants to
be landfilled after solidification.
Thus, AA-4 combines the best features
of AA-2 and AA-3, thermal destruction of organic contaminants with higher
mobilities and higher risk, while using lower cost landfill disposal for the
less mobile or lower risk contaminants.
Assembled alternative AA-4 is therefore
recommended by U.S. EPA for implementation as the cost-effective alternative
for the Fields Brook Sediment Operable Unit.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
In determining appropriate remedial actions at CERCLA sites, consideration must
be given to the requirements of other federal environmental laws in addition to
CERCLA.
Primary consideration is given to attaining or exceeding applicable or
relevant and appropriate environmental and public health'laws, regulations,
standards, and guidelines.
The applicable or relevant environmental and public health standards are reviewed
for each alternative examined in detail and summarized in Table 9.
-------
Law, Regulation,
Policy, or Standard
FEDERAL
Resource Conservation and
Recovery Act (RCRA)
Standards for OWners and
Operators of Hazardous
Waste Treatment, Storage,
and Disposal Facilities
Interim RCRA/CERCLA Guidance
on Non-Contiguous Sites and
Onsite Management of Waste
and Treated Residue
Table 6-2 \'-c1e 1 of 81
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
LAWS, REGULATIONS, POLICIES, AND STANDARDS
FOR TilE FIELDS BROOK ASSF.MBLED ALTERNATIVES
Source of Regulation
Applicability or Relevance
and Appropriateness
RCRA Subtitle C,
40 CFR 260
RCRA regulates the generation,
transport, storage, treatment,
and disposal of hazardous
waste. CERCLA specifically
requires (in Section 104(cl
(31 (BI) that hazardous sub-
stances from removal actions
be disposed of at facilities in
compliance with Subtitle C
of RCRA.
RCRA Section 3004,
40 CFR 264 and 265
Regulates the construction,
design, monitoring, operation,
and closure of hazardous waste
facilities. Subparts Nand 0
specify technical requirements
for landfills and incinera-
tors, respectively.
U.S. EPA Policy
Statement
March 27, 1986
If a treatment or storage unit
is to be constructed for on-
site remedial action, there
should be clear intent to
dismantle, remove, or close
the unit after the CERCLA
action is completed. Should
there be plans to accept
commercial waste at the
facility after the CERCLA
waste has been processed,
it is EPA policy that a RCRA
permit be obtained before the
unit is constructed.
Alternative Affected
AA-l through AA-4. In
accordance with the NCP,
excavated sediment will be
managed as though it is
a hazardous waste.
Landfill design require-
ments apply to the interim
storage facilities of AA-I,
and AA-4 along with the
onsite landfills of AA-2,
AA-3, and AA-4. The in-
cinerator design require-
ments of RCRA apply to
AA-3 and AA-4.
AA-2 through AA-4. The
onsite thermal treatment
facilities will be dis-
mantled, and landfill and
storage facilities will be
capped for closure follow-
ing processing of Fields
Brook waste. This FS
assumes that the technical
requirements of RCRA will
be met. Thus, the onsite
facilities would not be
requir~d to obtain RCRA
permits.
-------
I,aw, Regulation,
Policy, or Standard
Standards Applicable to
Transporters of
Hazardous Waste
EPA Administered Permit
Programs: The Hazardous
Waste Permit Program
EPA Interim Policy for
Planning and Implementing
CERCLA Offsite Response
Actions
Hazardous and Solid Waste
Amendments of 1984
(1984 amendments to RCRA)
.
Table 6-2 (Page 2 of 8)
Source of Regulation
RCRA Section 3003,
40 CFR 262 and 263,
49 CFR 170 to 179
RCRA Section 3005,
40 CFR 270, 124
50 FR 45933
November 5, 1985
PL 98-616, Federal Law
71: 3101
Applicability or Relevance
and Appropriateness
Establishes the responsibility
of offsite transporters of
hazardous waste in the hand-
ling, transportation, and
management of the waste.
Requires a manifest, record-
keeping, and immediate action
in the event of a discharge
of hazardous waste.
Covers the basic permitting,
application, monitoring, and
reporting requirements for
offsite hazardous waste
management facilities.
Discusses the need to consider
treatment, recycling, and
reuse before offsite land dis-
posal is used. Prohibits use
of a RCRA facility for offsite
management of Superfund haz-
ardous substances if it has
significant RCRA violations.
Specific wastes are prohibited
from land disposal under the
1984 RCRA Amendments. This
includes a ban on the placement
of wastes containing free
liquids. Also, solvent-
containing wastes are pro-
hibited from land disposal,
effective November 1986. EPA
is also required to set
treatment levels or methods,
exempting treated hazardous
wastes from the land disposal
ban. To date, these treot-
ment standards have not
Alternative Affected
AA-1. This alternative
may involve interstate
transport of contaminated
sediment to RCRA/TSCA
disposal facilities.
AA-1. CERCLA requires
that offsite disposal of
hazardous substances (con-
taminated sediment) will
be taken to permitted and
inspected hazardous waste
management facilities in
compliance with RCRA.
AA-1 through AA-4. Re-
quirements for selecting
offsite storage, treatment,
or disposal facilities
apply to AA-l. AA-2
through AA-4 consider
solidification or thermal
treatment of contaminated
sediment in accordance
with this policy.
AA-l through AA-4. If
. treatment standards are
not promulgated, ]and-
filling of "Lanned" waste
would not he acceptable
without a successful
demonstration that land
disposal is protective of
human health and welfare
and the environment..
Incineration of the sedi-
ment (ossuming it is to be
managed as though it is a
RCRA wastel may Le the
only applicable treatment
method.
-------
Law, Regulation,
Policy, or Standard
Toxic Substances Control Act
(TSCA)
Permits for Discharges of
Dredged or Fill Material
Into Waters of the u.S.
(Section 404 permit)
Great Lakes Water Quality
Agreement of 1978
Table 6-2 (P
Source of Regulation
40 CFR Part 761
33 CFR 320 to 330,
Section 404 of the
Clean Water Act
International Joint
Commission, Canada
and the United States
.
of 8)
Applicability or Relevance
and Appropriateness
been promulgated. The RCRA
amendments will also restrict
the landfilling of most RCRA-
listed wastes by 1991 unless
treatment standards are
specified.
Applies to the disposal of
liquid wastes containing PCB
concentrations at or greater
than 50 ppm and PCB's that
have migrated from the origi-
nal source of contamination.
PCB concentrations greater
than 500 ppm must be incin-
erated in an incinerator
that complies with 40 CFR
761.70. PCB concentrations
less than 500 ppm and greater
than 50 ppm may be disposed
of in a landfill that
complies with 40 CFR 761.75.
Part 323 requires permits to
discharge dredged or fill
materials into navigable
waters or their tributaries,
including wetlands adjacent
to such waters. Part 322
requires permits for struc-
tures or work in or affect-
ing navigable waters.
This intergovernmental Agree-
ment sets specific water
quality objectives and
develops monitoring and con-
trol programs to eliminate or
reduce the discharge of pol-
lutants into the Great Lakes
basin ecosystem.
Alternative Affected
AA-l through AA-4. Sedi-
ment will be sampled and
analyzed during excavation.
Based upon the data
in the RI report, PCB
levels are between 50 and
500 mg/kg for approxi-
mately 12,000 cu yd of
sediment. For purposes of
evaluation in this feasi-
bility study, it has been
assumed that sediment con-
centrations are below
500 mg/kg. If PCB levels
are found to exceed 500
mg/kg, these sediments
must be incinerated in a
TSCA-type facility.
AA-l through AA-4. The
temporary diversion of
portions of Fields Brook
during excavation may be
subject to the authoriza-
tion procedures of these
regulations.
AA-l through AA-4. Fields
Brook is in the Great
Lakes drainage basin since
it feeds into the Ashtabula
River which feeds into
Lake Erie. Sediment exca-
vation and discharge of
treated water to surface
water shall consider the
specific objectives of
this agreement including
the control of toxic sub-
stances entering the Great
Lakes waters.
-------
Law, Regulation,
Policy, or Standard
Statement of Procedures on
Flood Plain Management and
Wetland Protection
Clean Air Act (CAA)
National Environmental
Policy Act (NEPA)
,
Table 6-2 (Page 4 of 8)
Source of Regu)~tion
Appendix A to 40 CFR 6,
Executive Order 11988,
and 11990
40 CFR 1 to 99
NEPA Section 102(2) (c)
Applicability or Relevance
and Appropriateness
Requires federal agencies to
avoid wherever possible
adversely affecting flood
plains or wetlands and to
evaluate potential effects
of planned actions in these
designated areas.
Applies to major stationary
sources that have the poten-
tial to emit significant
amounts of pollutants such as
NO , SO" CO, lead, mercury,
an~ par~iculates. Regula-
tions under CAA do not speci-
fically regulate emissions
from hazardous waste incinera-
tors, but it is likely that
Prevention of Significant
Deterioration (PSD) provisions
would apply to an onsite ther-
mal treatment facility.
CERCLA actions are exempted
from the NEPA requirements to
prepare an environmental
impact statement (EIS) be-
cause US EPA's decisionmaking
processes in selecting a
remedial action alternative
are the functional equivalent
of the NEPA analysis.
Alternative Affected
AA-I through AA-4. Pre-
cautions will be taken
during excavation of sedi-
ment ~o minimize the im-
pacts on the flood plain
and for the protection of
wetlands. Removal of the
contaminated sedimen~ and
restoration after excava-
tion will improve the brook
conditions. Onsite facili-
ties must be constructed
consistent with standards
established under the
National Flood Insnr-
ance Program. J.ilndtill-
ing of wetlands is not
anticipated.
AA-3 and AA-4. These
regulations may apply to
emissions from the thermal
treatment facility.
..
,.
AA-l through AA-5. The
functional equivalent
of a NEPA review is car-
ried out in U.s. F.PA's
regulatory activities
for CERCLA actions.
-------
Law, Regulation,
Policy, or Standard
Intergovernmental Review of
Federal Program
Relocation Assistance and
Property Acquisition
National pollutant Discharge
Elimination System (NPDESI
Permit
Pretreatment Regulations
for Existing and New
Sources of Pollution
Toxic pollutant Effluent
Standards
US EPA Groundwater Protection
Strategy
Table t
Source of Regulation
Executive Order 12372
and 40 CFR 29. (Re-
places state and area-
wide coordination pro-
cess required by OHB
Circular A-95.1
Uniform Relocation
Assistance and Real
Property Acquisition
policies Act of 1979,
40 CFR 4
Clean Water Act
Section 402,
40 CFR 122, 123,
125 Subchapter N
40 CFR 403 Subchap-
ter N, FWPCA
40 CFR 129
U.S. EPA Policy
Statement
Augus~ 1984
.
.>age 5 of 81
Applicability or Relevance
and Appropriateness
Requires state and local coor-
dination and review of pro-
posed EPA assisted projects.
The EPA Administrator is
required to communicate with
state and local officials to
explain the project, consult
with other affected federal
agencies, and provide a com-
ment period for state review.
Requires that property owners
be compensated for property
acquired by the federal
government.
Regulates the discharge of
water into public surface
waters.
Regulates the quality of water'
discharged into publicly /
owned treatment works (POTWI.
Regulates the discharge of
the following pollutants:
aldrin/dieldrin, DDT,
endrin, toxaphene, benzidine,
and PCB's.
Identifies groundwa'ter
quality to be achieved during
remedial actions based on
the aquifer characteristics
and use.
Alternative Affected
AA-I through AA-5.
AA-I through AA-4. Land
acquisition may be required
for the interim storage
facility, onsite landfill,
onsite thermal treatment
facility, and/or onsite
water treatment facility.
AA-2 through AA-4. These
alternatives may include
discharge from the onsite
water treatment facility
to Fields Brook.
AA-2 through AA-4. These
alternatives may include
discharge from the onsite
water treatment facility
to the Ashtabula POTW.
AA-2 through AA-4. These
pollutants are not ex-
pected to be present in
the discharge from the
onsite water treatment
- plant.
AA-I through
not known at
contaminants
Brook affect
quali t.~'.
AA-5. It is
present if
from Fie)ds
groundwater
-------
Law, Regulation,
Policy, or Standard
Conservation of Wildlife
Resources
Occupational Safety and
Health Act (OSHA)
STATE AND LOCAL
State Hazardous Waste Site
Permit
,
Local Operating Permit or
License for Remedy
State Hazardous Waste
fest and State Permit
License for Transport
Hazardous Waste
Mani-
or
of
Ohio NPDES Permit
Table 6-2 (Page 6 of B)
Source of Regulation
Fish and Wildlife
Coordination Act
29 CFR 1910
Ohio Solid and Hazar-
dous Waste Disposal
Law, and Ohio Hazar-
dous Waste Management
Regulations. Ohio
Administrative Code:
3734-01 through 99 and
. 3745-50 through 69.
zoning, building or
fire code, or local
licensing laws
Ohio hazardous waste
management, hazardous
materials transport,
or commercial driver
licensing regulations.
Ohio Administrative
Code 3475-52, 53
Ohio Water Poilution
Control.
Ohio Administrative
Code 3745-33,
40 Cf'R 123
Applicability or Relevance
and Appropriateness
This act requires agency con-
sultation prior to modifying
any body of water.
Regulates working conditions
to assure safety and health
of workers.
If a new hazardous waste
facility must be created to
handle the wastes for longer
than 90 days, state approval
and/or generator I.D. may be
required as a precondition.
Obtain local permit or license
approving operation of
site facilities.
In general, the manifest
systems require the generator
to obtain a permit to trans-
port wastes on public rights-
of-way within the state, to
use only licensed transpor-
ters, and to designate
only a permitted TSD
facility to take d~livery
of wastes.
Regulates all point source
discharges to surface waters
of the state.
Alternative Affected
AA-l through AA-4. This
applies to the excavation
of sediment.
AA-l through AA-4. ThiH
applies to all workers on
the sit~ property during
excavations, construction
and operation of facilities
AA-2 through AA-4. Per-
tains to the construction
of the onsite interim
storage, onsile landfill,
thermal treatmlmt, and
water treatment facili-
ties.
AA-l through AA-4. "ocal
permits may need to he
obtained for the operation
of the interim storage,
landfill, thermal treat-
ment, and water ti~atmcnt
facilities.
AA-l. A manifest must be
p~epared for the trans-
port of contaminated
sediment to the offsite
disposal facility.
AA-2 through AA-4. Regu-
lates discharge from the
onsile water treatment
facility to Fields Rrook.
-------
Law, Regulation,
Policy, or Standard
Local Approval of Sewer Use
Permit
Ohio Water Quality Standards
Ohio' Pretreatment Rules
State Permit Requirements
for ~missions in Prevention
of Significant Deterioration
(PSD) Areas
State Permit Requirements
for Emissions in Nonattain-
ment Area
Local Approval of Grading
(Erosion Control) Permit
(Ohio has requirements for
erosion control.)
Table 6-~
Source of Regulation
Local sewer connection
and pretreatment ordi-
nances, as well as
some zoning, as sub-
division, and/or
building codes.
Ohio Administrative
Code 3745-1
Ohio Administrative
Code 3745-3
Clean Air Act, Part C;
State Implementation
Plans, Ohio Administra-
tive Code 3704 and
3745-17,18,21,71
Clean Air Act, Part D;
State Implementation
Plans, and Ohio
Administrative Code
3745-31,35
Local grading ordi-
nances or erosion con-
trol ordinances.
.
ge 7 of 8)
Applicability or Relevance
and Appropriateness
Permit, approval, and/or fee
for connection to public
sewer system. Requirements
as to quantity and quality
of effluents discharged to
sewer system.
Establishes minimum water
quality criteria requirements
for all surface waters of the
state.
Establishes state require-
ments and standards regulat-
ing the introduction of
pollutants into POTW's.
A major source of air pollu-
tants such as NO , SO , CO,
hydrocarbons, leid, a~d parti-
culates in PSD area must be
permitted by the state and
is subject to requirements
applicable to PSD areas.
If a major source is in
a nonattainment area for
those pollutants for which it
is a major source, it must
comply with requirements
applicable to nonattainment
areas.
Requirements affecting land
slope and cover, surface water
management, alteration of
natural contours, or cover
by excavation or fill.
Alternative Affected
AA-2 through AA-4. Regu-
lates the discharge from
the onsite water treat-
ment facility to the
Ashtabula POTW.
AA-2 through AA-4. The
designated use of Fields
Brook has been defined as
a limited warmwater aqua-
tic life habitat. Dis-
charges from the onsite
water treatment facility
must meet the necessary
criteria.
AA-2 through AA-4. Regu-
lates the discharge from
the onsite water treat-
ment facility to the
Ashtabula POTW.
AA-2 through AA-4. This
regulation may apply to
the emissions from all
, onsite facilities, partic-
ularly the thermal treat~
ment facility.
AA-3, AA-4. The Fields
Brook site is in a non-
attainment area for ozone.
The thermal treatment
facility emissions should
meet the permit require-
ments.
AA-l through AA-4. Ero-
sion control will be incor-
porated into channel
restoration following exca-
vation and the proper
maintenance of onsite
facilities.
-------
Law, Regulation,
Policy, or Standard
Local Approval of Use Permit
Local Building Permits
(includes electrical,
plumbing, and HVAC)
GLT525/34
"
Table 6-2 (Page 8 of 8)
Source of Regulation
Local Building Code
Local Building Codes
C7
Applicability or Relevance
and Appropriateness
Demonstration through pre-
sentation of evidence or
onsite inspection that
remedial action complies
with the requirements of
local health and safety
laws and ordinances.
Obtain permits for con-
struction
Alternative Affected
AA-I through AA-4. Build-
ing and construction per-
mits would be necessary
for the onsite interim
storage, landfill, water
treatment, and thermal
treatment facilities.
AA-I through AA-4. Build-
ing permits will be
obtained for the onsite
interim storage, landfill,
water treatment, and ther-
mal treatment facilities.
-------
18
The recommended alternative is expected to meet all applicable standards and
requirements listed in Table 9.
.ECOMMENDED ALTERNATIVE
The U.S. EPAls recommended alternative is assembled alternative AA-4, excavation
of sediment and partial thermal treatment.
It consists of these elements:
o
Mechanical excavation of contaminated sediment in Fields Brook and
its tributaries to the defined 10-6 excess lifetime cancer risk level.
For organic contaminants where the 10-6 excess
lifetime cancer risk
level is below current U.S. EPA Contract lab Program (ClP) detection
limits, the detection limits will be used to define the level of
sediment removal.
For inorganic contaminants, background levels (the
upper 99 percent confidence limit) or health based guildlines, whichever
is higher, will be used to define the level of sediment removal.
o
A new onsite RCRA/TSCA-type landfill will be constructed with separate
cells for: solidification of and permanent storage of sediments
containing relatively immobile or lower risk organic contaminants,
including sediments contaminated only with arsenic (36,000 yd3), and a
temporary storage cell for the sediment that will be thermally treated
(16,000 yd3).
The latter cell may permanently contain the residual
from thermal treatment if disposal in a RCRA/TSCA-type facility is
required.
Included in the sediment to be 1andfi11ed is additional
waste due to haul roads and decon stations, demolished part of the
interim storage facility and a demolished curing cell.
Refer to
Appendix M. of the Fields Brook FS for a complete breakdown.
-------
-
r-
19
o
Dewatering and temporary storage in a separate cell of the onsite
RCRA/TSCA-type landfill of 16,000 cubic yards of the contaminated sediment
containing organic contaminants with higher mobility and the highest
sediment ingestion risk, or sediment with PCB concentration greater than
50 mg/kg.
This quantity of sediment will be thermally treated.
o
Solidification, for containment in a separate compartment of a cell in
the onsite RCRA/TSCA-type landfill; of an estimated 2,600 cubic yards
of contaminated sediment where the sediment ingestion risk is strictly
due to the presence of inorganic contaminants (arsenic).
o
Solidification of the remaining quantity of contaminated sediment for
containment in separate cells within the onsite RCRA/TSCA-type landfill.
The total volume after solidification is an estimated 33,400 yd3.
o
The resulting ash from the thermal treatment of the contaminated sediment
will be analyzed to determine whether or not it should continue to be
managed as though it is a hazardous waste.
If the ash needs to be
managed as a hazardous waste, it will be placed back into the original
storage cell of the onsite RCRA/TSCA-type landfill.
If the ash does
not need to be managed as though it is a hazardous waste, it could be
disposed of as a soild waste, in the same onsite facility or possibly
offsite.
o
Water generated during the excavation of contaminated sedim~~t, the
dewatering process, the solidification process, thermal treatment, or
within the temporary storage cell of the RCRA/TSCA-type landfill will
be treated onsite using filtration and a granular activated carbon systc.".
Discharge of treated water will be either to the Ashtabula POTW or directly
-------
20
to Fields Brook taking into consideration NPDES requirements.
The
total present worth of this alternative is estimated at $48.400.000.
~
The annual Operation and Maintenance cost of this alternative is $55,000.
RECOMMENDED ALTERNATIVE SELECTION CRITERIA
The National Contingency Plan, 40 CFR Part 300.68 (j)' states that. "the appropriate
?
extent of remedy shall be determined by the lead agency's selection of a cost-
effective remedial alternative that effectively mitigates and minimizes threats
to and provides adequate protection of public health and welfare and the environment."
-
The lead agency should "consider cost, technology, reliability, administrative
and other concerns and their relevant effects on the public health and welfare
and the environment." Tne recommended alternative meets these criteria and
is cost-effective.
The recommended alternative can be readily designed and
constructed, and would be accepted by the public.
The alternatives which involved total landfilling (both onsite and offsite)
were not considered as effective in mitigating and minimizing the threats to
public health, welfare, and the environment because long-term reliability and
permanence of remedy did not approach that of thermal treatment.
All compounds
including those most mobile (those likely to migrate from a landfill upon
failure) would be disposed of in the landfill under these alternatives.
Thermal treatment offers added benefits beyond that of landfilling of long-term
reliability, and destruction of the most mobile and highly toxic contaminants.
-------
21
While the alternatives to thermally treat all of the sediment (AA-3) and to
thermally treat a portion of the sediment (AA-4) both possessed substantially
eq~iv~lent public health and environmental benefits, the cost of AA-3 exceeds
~
that of AA-4 and therefore was not considered to be cost-effective.
(AA-3)
also did not take into account the relative mobilities and risks of the different
contaminants present in the sediments and the possibility that more than one
technology may be appropriate.
Total thermal treatment would include the
?
treatment of reaches of Fields Brook in which the risk was attributed to compounds
which are not very mobile.
These compounds, after solidification, would be
expected to remain contained in a RCRA type landfill and not represent a potential
-
future problem should the landfill fail.
The additional cost to thermally
treat this remaining quantity was not deemed cost-effective.
The recommended
alternative (AA-4) combines the best features of landfilling and thermal treatment
to arrive at an appropriate solution to the problem.
It is consistent with the
current U.S. EPA Interim Policy for Planning and Implementing CERCLA Offsite
Response Actions, which discusses the need to consider treatment, recycle, and
reuse before land disposal is used, as well as the Hazardous and Solid Waste
Amendments 1984.
Three criteria were considered to decide what portion of the sediment should be
thermally treated as well as what portion could be satisfactorily landfilled
with long-term effectiveness; mobility, toxicity, and concentration of PCBs.
These criteria are more completely described again in Attachment B.
Thus
alternative AA-4 demonstrates long-term reliability, permanence of remedy, and
appropriate technologies to warrant recommendation.
-------
22
OPERATION AND MAINTENANCE (O&M)
Annual Operation and Maintenance (O&M) costs are costs associated with post-clos
acti~ities after completion of the remedial action. such as ongoing landfill
~
maintenance and groundwater monitoring.
The O&M costs were estimated on an
annual basis over 30 years.
The O&M for the recommended alternative will
require ongoing maintenance and monitoring of the onsite landfill and
construction. maintenance. and replacement of the cap.
The costs are described
;.
in Table 6.
The State of Ohio will assume responsibility for long-term O&M of
the remedial action.
The U.S. EPA will enter into a State Superfund Contract
with the State of Ohio to formalize this agreement.
COMMUNITY RELATIONS
There has been public interest in the Fields Brook site throughout the RIfFS.
Public meetings have been held. and there have been a number of letters and
phone calls regarding the site.
Media coverage for the public meetings has
been through the local paper and radio station.
The main concern of the community during the RI/FS was to complete the study as
soon as possible.
The community has stated that it is rather obvious that
Fields Brook represents a health risk and that the U.S. EPA should stop studying the
brook and clean it up.
These sentiments have also been expressed by the Ashtabula
City Counc i1 .
The Citizens For Clean Water have also expressed an interest in
this project and have been kept up to date on the status.
Another concern was that the industries responsible for the contaminat~pn
should be held accountable.
Some extreme animosity toward the industries was
expressed by several people at the latest public meeting.
-------
23
Residents and local officials have also expressed an interest in the U.S. Army
Corps of Engineers proposed dredging of the Ashtabula River and how the Fields
Brook project impacts that project.
~
Many of these concerns were expressed during the public comment period for the
F S.
The comment period was extended to 40 days from the normal 21 days
to accomodate the citizens. and PRPsl request for additional time to submit
comment s.
Comments from residents and the Citizens for Clean Water generally
support the recommendation.
~
The Ashtabula Township Trustees support a different
alternative, but expressed willingness to work with EPA in siting a landfill
and thermal treatment unit.
The comments received and the U.S. EPAls response
to them are detailed in Appendix C.
SCHEDULE
MILESTONES
DATE
Complete Enforcement Negotiations
Approve Remedial Action (sign ROD)
Begin Pre-Design Activities
Award contract for Design
Begin Design
Complete Design
Award contract for Construction
Begin Construction
Complete Construction
September 1986
September 1986
October 1986
January 1987
January 1987
January 1989
March 1989
March 1989
March 1992
b
FUTURE ACTIONS
Future actions for the Fields Brook project can be divided into two general
categories:
activities related to the Sediment Operable Unit, and
1)
2)
subsequent RIfFS activities.
-------
o
24
The necessary pre-design studies related to the sediment operable unit are a
sediment quantification study, pre-burns, a facility siting study, chemcial
characterization of the wastewater that will be generated by remedial activities,
~
bench scale wastewater treatability studies, and a pilot study to determine if
solidification is an acceptable method to reduce organic contaminant mobility.
A sediment quantification study is necessary to re-evaluate the sediment volume
estimates used in the FS.
Implementation of more detailed sampling and analysis
plan would better define the contaminants present, their concentration, as well
as their vertical and horizontal extent.
A radioactive element analysis would
also be a part of this study.
The results of the sediment quantification study
will be used in conjunction with earlier results as the basis for distinction
between sediment to be thermally treated and sediment to be landfilled after
solidification, and for determination of their quantities.
In the event that the
quantities change significantly, the size of the necessary facilities would
need to be adjusted, and would be designed to meet those needs.
Pre-burns are necessary to demonstrate whether the various types of thermal
treatment processes considered are applicable for Fields BrooK's waste.
This
would be accomplished by sending small volumes of Fields Brook sediment to a
number of existing facilities.
A facility siting study is needed to identify feasible locations for the facilities
needed for the recommended alternative (i.e. thermal treatment unit, landfill).
Considerations would include property availability, proximity to the community
and potential impacts on flood plain/wetlands.
This study would be subject
to a public review similar to that in Environmental Impact Statements.
-------
25
Information must be generated on the chemical content of the wastewater that
will be generated during the remedial activities, such as sediment dewatering,
and thermal treatment (i.e., scrubber water).
This information will be necessary
fOr the actual design of a wastewater treatment system and the eventual develop-
ment of direct or indirect discharge limitations.
Similarly, treatability testing
will be necessary to demonstrate the effectiveness of the proposed treatment
technologies at removing the contaminants in the wastewater and to identify other
technologies that may be effective or necessary.
?
Lastly, a pilot or small bench scale study would be needed to demonstrate that
the mobility of organic contaminants can be successfully reduced by means of
-
solidification.
If the study reveals that mobility reduction cannot be accomplished,
the sediment designated for solidification and landfilling may also be subject to
thermal treatment.
In addition to the above mentioned pre-design activities, two subsequent activities
are proposed.
The first is an RIfFS to identify any ongoing sources of contamina-
tion to Fields Brook.
This study would involve a hydrogeological study of the
Fields Brook watershed area.
The second would be a study to address the contamina-
Samples would be taken outside the Corps of
tion in the Ashtabula River.
Engineers federal project area proposed for dredging.
The Office of Policy and
G
Program Evaluation in Headquarters is evluating the appropriateness of this
type of area wide investigation, whether it is evaluating the appropriateness
of this type of area wide investigation, whether it is economically feasible
and within the scope of the Superfund program.
Both of these studies would
include an exposure assessment to determine if any further remedial action is
required.
Both of these studies are also planned to be undertaken concurrent
-------
o
26
with the design of the Sediment Operable Unit.
If remedial action is warranted.
it will be conducted as separate operable units of the Fields Brook site. in
t~me frames consistent with maintaining the environmental benefits of the Sediment
Operable Unit.
~
-------
ATTACHMENT B
THERMAL TREATMENT CRITERIA
The costs associated with landfilling solidified contaminated sediment are
lower in comparison to the costs of thermal treatment and landfilling.
- ~
Beeause of this, a combination alternative that thermally treats a portion
of the sediment and landfills the remainder was viable.
Factors important in differentiating between solidifying before landfilling
or thermal treatment of contaminated sediment are:
;.
o Toxicity
o
Mobil ity
o
Persistence
o
Bioaccumulation capacity
o Leachabi 1 ity
Current data for the Fields Brook site are limited to mobility, concentrations,
and toxicity.
Concentrations and toxicity are combined together and expressed
as the risk of excess cancer due to sediment ingestion.
A methodology based
upon these three types of data was developed to evaluate which contaminated
sediment should be thermally treated.
The mobility or transport of a contaminant through soil or sediment can be
expressed by the absorption coefficients or soil-water partition coefficients
(Koc).
An extensive set of Koc values has been developed by Griffin (Seymour Remedial
-------
o
2
Investigation Report, U.S. Environmental Protection Agency, 1985).
This set
included Koc values for most of the contaminants found in Fields Brook sediment.
~riffin has also derived a classification system based on the relative
r
mobilities of these contaminants.
This classification systeM is:
Koc (ml/g)
o - 50
Mobility Classification
50 - 150
150 - 500
;
Very High Mobility
High Mobility
Moderate Mobility
500 - 2,000
Low Mobility
2,000 - 20,000
Slight Mobility
greater than 20,000
Immobile
Application of Griffin1s classification system to those compounds found in
Fields Brook sediment at levels which represent a greater than 10-6 excess
lifetime cancer risk due to sediment ingestion (as a measure of toxicity),
resulted in Figure B-1, which is a plot of sediment volume vs. Koc.
In
reviewing this graph it is apparent that a breakpoint occurs at Koc value
of 2,400 ml/g, and a volume of 7,800 cubic yards.
Based upon the large volume increase above the Koc value of 2,400 ml/g,
that value was selected as the cutoff between sediment to be thermally
treated and sediment to be solidified prior to landfilling.
This value
indicate~ that compounds with greater than slight mobility according to
Griffin warrant thermal treatment at this specific site.
-------
3
It is uncertain whether sediment with PCB concentrations greater than 500
mg/kg do actually exist in Fields Brook.
However, several analyses indicate
;that PCB concentrations above 50 mg/kg do exist in the sediment.
In determining
the volume of contaminated sediment to be thermally treated. U.S. EPA recommends
that sediment containing PCB concentrations greater than 50 mg/kg be thermally
treated.
This is in accordance with the PCB disposal requirements in 40 CFR
761.60 (a)(4) and (5) which require contaminated soil or dredged materials to
~
be disposed of by incineration or by a chemical waste landfill.
This is
referenced in the U. S. EPA Interim Policy for Planning and Implementing
CERCLA Offsite Response Actions which also states that whenever disposal of PCB's
-
are undertaken they must be incinerated unless the concentrations are less than
50 ppm.
This policy also states that if the concentrations are between 50 and
500 ppm certain exceptions to incineration (primarily disposal in an EPA approve,
landfill) may be implemented.
These guidelines for the disposal of PCB's are
considered both relevant and appropriate for Fields Brook sediment.
Therefore
sediment containing PCB's greater than 50 mg/kg is proposed for thermal treatment.
In summary. the volume of sediment to be thermally treated was determined based
upon three guidelines:
6
o
Mobility
o
Toxicity and concentration
o
PCB concentrations only
About 7.800 cubic yards of contaminated sediment will be thermally t~ated
based upon the first two guidelines.
Another 7.800 cubic yards will be thermally
treated because of PCB concentrations only. for an estimated total volume
of 15.600 cubic yards of contaminated sediment to be thermally treated.
-------
,---
30,000
8
II:
oil(
>
u
iii 20,000
:J
!:!
III
~
:J
-'
g
t-
Z
III
~
o
III
en
10,000
OJ
o
10
.. "111."'..-
III
.. .. 111."'..-
III
.. .. II.'" 8"-
100
1,000 10,000
ml
Koc ,IAFTER GRIFFINI
100,000
FIGURE L.2
SEDIMENT VOLUMES (10-6 SEDIMENT
INGESTION RISK OR GREATER) VS. r{
FIELDS BR()0K"FS,
.ITV
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Appendix K
THERMAL TREATMENT OF SEDIMENT
Thermal treatment is a general term for the destruction of
hazardous organic wastes through the application of heat.
Incineration is currently the most widely used thermal
treatment technology although several new technologies are
emerging. Another technology capable of efficiently treat-
ing Fields Brook sediment is the high temperature fluid wall
reactor developed to pyrolize organic wastes by the Thagard
Research Corporation in Costa Mesa, California and marketed
by the J.M. Huber Company. Pyrolysis is the application of
heat in an oxygen deficient atmosphere in contrast to incin-
eration where combustion by oxidation decomposes hazardous
waste. Each technique has its own advantages and will be
discussed later in the chapter.
~
This appendix summarizes existing and potential facilities
for offsite and onsite thermal treatment of contaminated
sediment from the Fields Brook site.
~
,
OFFSITE RCRA INCINERATORS
Within a 600-mile radius there are three RCRA-permitted
incinerators capable of handling contaminated waste from
Fields Brook: Rollins in Bridgeport, New Jersey; Trade
Waste Incinerator in St. Louis, Missouri; and Chemical Waste
Management in Chicago, Illinois. The three operating
facilities will only accept contaminated sediment that' has
been containerized or drummed. Incineration costs at these
facilities have been estimated to range from $700 to $1,300
per cubic yard of waste material. This does not include the
material or labor cost for excavating, containerizing,
transporting, and storing the sediment, nor the cost of ash
disposal. Considering existing offsite incinerator capac-
ities, material handling difficulties, potential
transportation and shipping constraints, and scheduling
coordination with other users of the incineration
fac!~ities, offsite incineration of the excavated sediment
(10 removals) is expected to require over 10 years to
complete.
OFFSITE TSCA INCINERATORS
Currently, there are five commercial waste incineration
facilities in the United States that have U.S. EPA TSCA per-
mits for incineration of PCB-contaminated wastes. Two of
these facilities burn only liquid wastes and were not con-
sidered further. The other three facilities are Rollins in
Deer Park, Texas; ENSCO in EI Dorado, Arkansas; and Chemical
Waste Management (formerly SCA) in Chicago, Illinois.
Incineration costs at these facilities range between' $1,000
K-1
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u
and $1,500 per cubic yard (excavation, transportation,
storing, and ash disposal .not included).
ONSITE PORTABLE THERMAL TREATMENT FACILITIES
Portable thermal treatment facilities are defined as onsite
facilities constructed or installed to operate for the
length of time necessary to destroy the contaMinants in the
sediment. Once the tnermal destruction is complete, the
portable facility will be dismantled and salvaqedor. reused
at other sites. Portable facilities primarily differ from
mobile units in that mobile units are generally constructed
and mounted on mobile trailers that limit their size and
capacity. The two portable systems considered are a rotary
kiln incinerator and an Advanced Electric Reactor marketed
by the J.M. Huber Corporation.
ROTARY KILN INCINERATOR
The rotary kiln is capable of incinerating solid, sludge,
liquid, and gaseous hazardous wastes either separately or
simultaneously. A rotary kiln is a slowly rotating
refractory-lined cylinder mounted at a slight incline to
horizontal. The tumbling action about its horizontal axis
allows for mixing of the wastes, heat, and air, improving
the efficiency of combustion.
r
A rotary kiln incineration system (Figure K-1) for the
Fields Brook site would consist mainly of the kiln and
afterburner for solids destruction, possibly a waste heat
boiler for energy recovery, and a venturi scrubber for
emi~sions control. Destruction of approximately
41,500 'cubic yards of waste and sediment with a 20 percent
moisture content is assumed to take. over 6 years in a kiln
operating 290 days per year, 24 hours per day, at a feed
rate of 24 cubic yards per day. Operating the kiln
continuously would reduce thermal stress on the refractory,
although some downtime has been a~lowed.
4
Design, installation, and startup of the
assumed to take 1.5 to 2 years.' Siting,
bidding of the incineration facility may
tional 3 to 6 years.
The rotary kiln'would be approximately 20 feet in length and
10 feet in diameter, operating at about 2,200oF. Combustion
temperatures for rotary kilns range from 1,500 to 2,200°F.
In addition to the physical parameters of the unit, resi-
dence time of the material is also a function of the kiln
speed which varies from 0.25 to 1.5 rpm, and the angle to
which it is positioned, usually a 2 to 3 percent rake.
Trial burns, as required by RCRA, will be conducted upon
startup to determine these operating parameters, along with
incinerator is
permitting, and
require an addi-
K-2
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~
<)
ENCLOSED Cdt-.!VEYOR
-LOR SCREW FEEDE:L'
DEWATERED
SEDIMENT .
UNLOADING~
TO ATMOSPHERE llItljJ or. .) SIZE
. REDUCTION
ATMOSPHERE
DUST
COLLECTORS
PACKED
SCRUBBER
VENTURI
SCRUBBER
PARTICULATE
REMOVAL
ROTARY
KILN
INCINERATOR
SCREW
FEEDER
STACK
CAUSTIC OR
BICARBONAn- ,
SCRUBBING j
WATER -- -
AFTER
BURNER
ENCLOSED
CONVEYOR
(OR SCREW
FEEDERI
SCRUBBER
BLOWDOWN
TANK
QUENCH
CHAMBER
I
COMBUSTION I I
AIR ----.... , I
- \- -...1 I
,
,
r
,
COMBUSTION
AIR
,
1
I
,
,
I
! - A MAKE UP
----LYFUt:L
FUEL
STORAGE
ASH DISPOSAL
WASTEWATER TO
GRANULAR
ACTIVATED
CARBON (GACI
TREATMENT
~----------_._~----
CENTRATE
TANK
rp~;';E F;;A-;I~ "
OF BLDWDOWN
l~~~~T~~__J
LEGEND
SCREW FEEDER
..
WASTE STREAM
~--
SUPPLEMENTAL MATERIAL
FIGURE K-1
CONCEPTUAL FLOW DIAGRAM FOR
ROTARY KilN INCINERATION
FIE LDS BROOK FS
- .
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G
~
u
o
the solids retention time, which can be as long as
60 minutes.
Rotary kiln systems usually have a secondary combustion
chamber or afterburner following the kiln to ensure complete
combustion of the waste and gases from the kiln. tiquids
can also be injected into the afterburner for destruction in
some cases. This chamb~r is usually designed to have a gas
residence time of a few seconds with temperatures between
2,200 and 3,000°F.
Wastes with a heating value of 4,000 to 5,000 Btu's per
pound generally do not require auxiliary fuel to sustain
combustion at lower operating temperatures. Sediment from
Fields Brook is assumed to have a low heating value,
therefore burners would be mounted near the kiln to provide
a supplementary source of heat. Approximately 260 gallons
per hour of fuel oil would be needed to maintain 2,2000F.
Solids wastes will be ram fed or conveyed through the high
end of the kiln. Liquid wastes such as the leachate col-
lected at the storage facility could enter through atomizing
nozzles. As the kiln rotates, the waste burns to ash and
moves to the lower end ~f the kiln where it is discharged.
The residual ash would then be placed in the storage facil-
ity and capped once incineration is complete. Laboratory
testing of the ash is required to determine if its content
is nonhazardous in character. If this is the case, it may
be possible to delist the ash in accordance with RCRA regu-
lations.
Incineration produces heat which can be reclaimed and util-
ized. The most frequent form of energy recovery is to con-
vert the kiln's waste heat into steam. Using a waste heat
boiler in the incineration system, the net stearn flow avail-
able for useful work would be 16,000 pounds per hour.' This
is equivalent to 5.6 MW of electricity. Comparison of the
costs and benefits from energy re~overy through a waste heat
boiler should be considered in more detail at the time of
the final design.
High levels of NOx emissions are expected, especially when a
rotary kiln is operated at higher temperatures. Nitrous
oxides are fo~ed from thermal fixation of nitrogen in ~he
air used for combustion'or from organic nitrogen compounds
present in the waste. Emissions of SOx and particulate mat-
ter are dependent on the waste. Sulfur oxides are formed
from sulfur present in the waste material and auxiliary
fuel.
Emission control devices currently available may be categor-
ized as either wet or dry process devices. Dry process
devices include cyclones, dry scrubbers, dry electrostatic
K-4
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~
precipitators (ESP's) and fabric filters or baghouses. Wet
control devices include wet scrubbers and wet ESP's. The
wet scrubber process uses a technique of bringing a contam-
inated gas stream in contact with a liquid. Existing waste
incinerators predominately use wet scrubbers to,control
emissions of. particulate matter and the gaseous products of
combustion. For illustrative and cost estimating purposes,
a wet scrubber, the venturi scrubber, has been selected as
the emission control device to be used with' the rotary kiln.
The venturi scrubber is a high efficiency, high energy gas
cleaning device characterized by typical pressure drops
between 30 and 50 inches of water. The water is injected in
the venturi throat where gases pass through a contracted
area reaching velocities .of 200 to 600 feet per second.
Gases then pass through an expansion section and a large
chamber for separation o£ particles or for further scrub-
bing. High energy venturi scrubbers provide the highest wet
scrubber efficiency with particles in the range of 0.3 to
1.0 urn in diameter.
,
-
ADVANCED ELECTRIC REACTOR
The J.M. Huber Company has purchased the patent on the high
temperature fluid wall reactor from the Thagard Research
Corporation. The Huber Company in Borger, Texas, now
designs and markets arl Advanced Electric Reactor (AER) to
pyrolize organic wastes. Figure K-2 presents the conceptual
flow diagram for the AER.
Pyrolysis is the chemical decomposition of organic matter
through the application of heat in an oxygen deficient atmo-
sphere. Destruction by pyrolysis rather than oxidation
offers several advantages. Higher operating temperatures
(4,0000 to 4,500°F) can be achieved in an AER in contrast
with a rotary kiln incinerator (2,200°F). This allows for
high destruction efficiencies and a fused nonporous ash.
Secondly, typical products produced by incineration such as
carbon monoxide, carbon dioxide, and nitrogen oxides are not
formed in significant concentrations in an electric reactor,
which could be an important consideration in nonattainment
areas (Clean Air Act). The AER also has several inherent
fail-safe operating features~ This lessens the need for
extensive emission controls.
u
The electric'reactor has demonstra~ed the ability to handle
large volumes of contaminated soil with destruction and
removal efficiencies (DRE's) far exceeding the RCRA require-
ments for hazardous wastes incinerators. Removal efficien-
cies for PCB-contaminated waste have been demonstrated at
99.99999 percent. The AER is also well suited for treatment
of material with low heating values (Btu-content) as is the
case with Fields Brook sediment.
K-S
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POST
REACTOR
TREATMENT
ZONES
1
,; ..
ADVANCED
E HCTRIC
REACTOR
SEDIMENT IN
o
.~
~
STACK
GAS
MONITORING
t
HIGH TEMPERATURE
INSULATED lONE
SLIDE VALVE
RESIDUAL
ASH BIN
INDIRECT
COOLING ZONE
::
1
FAN
J
MAKEUP WA TER
AND NaOH
I
ran
~
CAUSTIC
SCRUBBER
IFOR CHLORINE REMOVAl!
WASTE
STREAM
4- NITROGEN
GAS FEED
CAHUON
IllATING
E l ECl ROUE
INSULA TED
SHEll
~
,
:t
>.
"'
~
<
~ .
"'
6 TREATED SEDIMENT
OUT TO REACTOR
TREATMENT ZONES
POROUS GHAPHI fl
HEACTOR CORE
ASH DISPOSAL
ADVA~CED ElECTRIC
REACTOR SECTION
PROCESS flOW DIAGRAM
FIGURE K-2
CONCEPTUAL FLOW DIAGRAM FOR
ADVANCED ELECTRIC REACTOR
f IHDS BROOK FS
")
,
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~.
Solid waste materials are introduced into the top of the
reactor by means of a materials screen feeder that connects
an airtight feed hopper to the reactor. Solid feed streams
must generally be free flowing and reduced to 35 U.S. mesh
size. Assuming Fields Brook sediment is approximately 60 to
80 percent sands and silts, a shredder or jet impactor would
be needed to reduce the particle size of the remaining waste.
Huber Corporation has designed, but not field tested, a trans-
portable unit with a designed feed rate of 20,000 tons per
year. A stationary, commercial scale, reactor permitted
under RCRA and TSCA is, however, maintained at Huber's Borger,
Texas research facility. Assuming one cubic yard of sediment
is approximately equal to 1.4 tons, and allowing for downtime,
destruction of 43,000 cubic yards of waste and sediment from
Fields Brook is estimated to take approximately 4 years.
Design, installation, and startup of the reactor is assumed
to take approximately 1.5 years. Siting, permitting, and
bidding for the facility has not been considered in this
time frame and may require an additional 3 to 6 years.
~
The reaction chamber consists of a tubular core of porous
refractory material insulated in a fluid-tight vessel. In
the reactor, energy is transferred to the waste by radiation
rather than by conduction or convection as with conventional
incinerators. Carbon electrodes are used to heat the reac-
tor core to temperatures between 4,0000 and 4,5000F. Normal
energy requirements for treatment of contaminated soils
range between 800 and 1,000 kWh per ton of material
processed. Nitrogen gas is injected radially through the
porous walls of the chamber to prevent the hazardous
materials from contacting or sticking to the reactor's
walls. This protective gas blanket or fluid wall is
transparent to the radiant energy generated inside the
reactor.
After leaving the reactor, the product gas and waste solids
pass through two postreactor treatment zones used to cool
and further aid in destroying the wastes. The waste resides
ror about 5 seconds at 2,5000F in the first treatment zone,
which is an insulated vessel. The second zone primarily
cools the product gas for about 10 seconds to 1,000°F prior
to emissions control. Particles in the waste gas are
removed via a cyclone and a baghcuse filter followed by an
aqueous caustic scrubber for chlorine removal. Residual
organic compounds and chlorine in the gas exiting the
scrubber are removed through activated carbon beds.
Q
Solids exiting the postreactor treatment zones would be col-
lected in a bin and returned to the onsite storage facility
for disposal. Because of the high operating temperatures
and rapid reactions, the residual remaining is vitrified
K-7
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()
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beads resembling glass shot. Most metal salts are soluble
in the molten glass and become chemically bound within the
residual. The residual may be considered a sterile sand
. with a greatly reduced leachability. It may be possible to
delist the residual as a waste regulated under RCRA through
confirmatory laboratory testing.
ONSITE MOBILE THERMAL TREATMENT FACILITIES
As an alternative to hauling sediment to.offsite
incinerators or using a thermal system constructed onsite,
transporting a mobile incinerator or reactor to the site is
possible. Mobile incinerators are available but their
availability is limited. Existing mobile incinerators or
reactors capable of handling Fields Brook sediment include a
facility operated by Pyrotech, an ENSCO subsidiary, the u.S.
EPA mobile unit, and the high temperature fluid wall reactor
from Vulcan Resources Ltd.
PYROTECH'S MOBILE WASTE PROCESSOR (ENSCO)
-
pyrotech's mobile incinerator occupies a 200-foot by f
200-foot area. The facility consists of seven trailers on
which the incineration, air pollution control, analytical
laboratory, and control room equipment are mounted. Setup
time is approximately 2 to 3 weeks. The solid incineration
equipment includes a rotary kiln which operates betwee.n
1,8000 and 2,0000F. The feed system is a belt conveyor with
a charging hopper plus a ram feeder. Residual ash is
collected in a discharge chute. Liquid wastes can also be
injected into the afterburner which operates between
2,2000 to 2,6000F. Air pollution control equipment includes
a packed bed tower and a steam ejector scrubber.
o
The mobile system is designed to simultaneously incinerate
up to 3,600 gallons per day of liquid waste and 96 tons per
day of contaminated solid material. Sediment with a mois-
ture content of 20 percent together with the desired
destruction efficiency is expected to limit the feed rate to
between 35 and 50 tons per day. Assuming a rate of 40 tons
per day and 290 operating days per year, it would take
approximately 6 years to treat the Fields Brook sediment.
This does not include time for siting, permitting, design,
and construction of the. treatment facility. Currently, the
unit is not permitted to incinerate PCB-contaminated wastes,
although ENSCO has plans for a compliancy test in the near
future.
u.S. EPA MOBILE INCINERATOR SYSTEM
The EPA mobile incinerator consists of major incineration
and air pollution control equipment, 'combustion and stack
gas monitoring equipment, and ancillary equipment--all
K-8
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mounted on four heavy-duty trailers. Each trailer requires
construction of a concrete pad and some type of shelter.
The overall plan area of the four trailers when assembled in
operating configuration is approximately 10 feet by
150 feet. The overall capacity is 15 million Btu/hr.
Additional equipment required for operation, which is.not
included with the four trailers, includes wastewater
treatment and decontamination facilities; feed preparation
equipment; and fuel, sediment, residue, and spare part
storage. This additional equipment occupies another 10 to
12 trailers and the overall size of the incineration complex
could be as much as 2 to 4 acres.
,
The EPA mobile incinerator design appears technically capa-
ble of handling Fields Brook sediment. Test burns of liquid
PCB's demonstrated a destruction removal efficiency of
99.9999 percent. The solids handling capability of the sys-
tem has been tested and refined. The facility is also
equipped with air pollution control and stack gas monitoring
systems. Incineration residue would have to be properly
disposed of either onsite or in a secure landfill offsite.
Initial estimates indicate the capacity of the EPA incinera-
tor is about 30 cubic yards per 24-hour day for material
containing 20 percent moisture and a PCB destruction removal
efficiency of 99.9999. At this rate, it would take approxi-
mately 6 years to treat the Fields Brook sediment, assuming
290 operating days per year.
.~
MOBILE HTFW REACTOR
A mobile high temperature fluid wall (HTFW) reactor to
pyrolize organic wastes similar to the Advance Electric
Reactor has been developed by. the Thagard Research
Corporation and is licensed by Vulcan Resources Ltd. The
.system consists of three trailers occupying a 100-foot by
IOO-foot area. The reactor is approximately 5 feet wide and
30 .feet hiqh. Once the trailers are ~n the site, the setu~
time is about I week. Generally the reactor is run continu-
ously although it can be shut down on weekends without a
1055 in efficiency.
Contaminated sediment is brought to the top of the reactor
via a bucket elevator or conveyor system and then dispersed
through a power feed-through assambly. Some material prepa-
ration may be necessary before the contaminated sediment is
fed into the reactor. Fine grain"sand and silt which will
pass through a IOO-mesh screen can be treated directly.
Larger waste material must be sent through a shredder or jet
impactor to reduce the particle size. To avoid the need for
emission control equipment, lime is frequently added to
highly chlorinated wastes. .
K-9
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/
. The mobile reactor is designed to treat 50 tons of contam-
inated soil per day. Moisture and gases present in the 5ed-
iment may slightly reduce this capacity. The reactor has
achieved DRE'S exceeding the 99.99 percent RCRA requirement,
and the unit is also permitted to treat PCB-contaminated
waste. Energy requirements for the reactor are approxi-
mately 800 kWh per ton of material processed.
Assuming a feed rate of 2.6 tons' per hour and operation for
290 days per year (20 hours per day), a single HTFW reactor
would take about 4 years to treat the Fields Brook sediment.
According to Vulcan Resources, a mobile reactor can be
designed, constructed, and delivered to a site in less than
1 year. This does not include consideration of time assoc-
iated with siting and permitting, which may require an addi-
tional 3 to 6 years.
ONSITE THERMAL TREATMENT PERMITTING REQUIREMENTS
Permitting of a hazardous waste incinerator may require that
a trail burn be performed to establish acceptable operating
parameters for the material being incinerated. The
complexity of the trial burn depends on the nature of the
wastes to be incinerated. A trial burn may not be required
if the incinerator being used has already been permitted to
burn wastes of the same form and of equal or greater
incineration difficulty. A trial burn may also not be
required if the incinerator is similar enough to another
incinerator which is permitted to burn such wastes.
To meet the substantive requirements of obtaining a permit
to operate a hazardous waste incineration facility, a trial
burn may be required in acco~dance with 40 CFR 270. The
trial burn is conducted to detp.rmine the conditions that the
incinerator would be operated at to maintain compliance
required the performance standards. These standards
include, destruction and removal efficiencies (DRE) of 99.99
percent for principal organic hazardous constituents (POHC)
or 99.9999 percent for PCB's and dioxin, controlled hydrogen
chloride emissions not to exceed 1.8 kg/hr, and particulate
matter emissions of less than 0.08 grams per day standard
cubic foot (40 CFR 264).
'C1
The trial burn is also intended to determine the operating
parameters (waste feed, waste restrictions, combustion
temperatu,re, etc.) wh,ich will be specified in the permit.
Therefore~ waste incinerated during the trial burn must be
representative of the waste to be incinerated during the
incinerator operation. An allowance for a trial burn should
be included in the cost estimate to encompass preparing the
trial burn plan, waste steam characterization, operation for
up to 720 hours prior to the trial burn to establish the
K-10
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required operating conditions, a trial burn operation,
monitoring procedures, and sample analyses.
..
In addition to the need to meet the substantive requirements
of a RCRA permit, the onsite incinerator will need to meet
Clean Air Act requirements for air emissions. An NPDES
permit would be required if scrubber water is to be
discharged to a surface water. If the scrubber water is
instead sent to a sewer, the water would be required to meet
federal POTW pretreatment standards.
GLT525/38
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K-ll
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