United States
Environmental ProtectJon
Agency
Office of
Emergency and
Remedial Response
EPAIROD/R05-87/053
September 1987
rdEPA
Superfund
Record of Decision:
Laskin Poplar Oil, OH (2nd O.U.)
U.S. £nviranmental ~rotectioi'l Agency
Region III Information Resourc~
Center (3PM52)
841 Chestnut Street
. :~~, ~~
Philadelphia, PA 191Q7 2~
,t"
. :..-
Hazardous Waste Collection
Information Reaource Center
US'EPA ReQldn3
"'~>P~t'J07
EPA Report Collection
Information Resource Centf,:]
US EPA Region 3
Philadelphia. PA 19101
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TECHNICAL REPORT DATA
(PiHU rad InflIVCliOfts Oft Ih~ rrll~n~ I»fon co",,,I~linIJ
1. RlltORT NO. 12. 3. RECI"ENT'S ACCESSION NO,
EPA/ROD/R05-87/053
.. TITL.I AND SUITITLI 5. R.'ORT DATE
SUPERFUND RECORD OF DECISION ~".ntember 30. 1987
Laskin/Poplar Oil, OH 1..,eRfiORMING ORGANIZATION CODe
Second Remedial Action
7. AUTHORCS) 8. PERfiORMING ORGANIZATION RepORT NO,
I. 'ER'ORMING ORGANIZATION NAME AND ADDRESS 10. PAOGRAM E~eMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND peRIOD COVEREC
U.S. Environmental Protection Agency IOqn.::a1 ROD ReDort:
401 M Street, S.W. 1.. SPONSO~ING AgENCY CODe
Washington, D.C. 20460 800/00
15. SUltltL.eMINTARY NOTES
18. ABSTRACT
The Laskin/Poplar Oil site, occupying approximately 9 acres, is located in Ashtabula
County, Ohio. Approximately 80 years ago a greenhouse operation began. Boilers were
installed approximately 30 years ago to heat the greenhouses. During the 1960's, tanks
were installed to hold waste oil to fire the boilers. The oils were not analyzed prior
to acc~ptance and oi1 containing PCBs and other ?azardous constituents were accepted.
As the greenhouse business deteriorated, the owner began collecting, reselling 'and
disposing of waste oils containing PCBs and other hazardous constituents. Several
emergency actions were taken after the site was discovered and during critical periods
such as mudslides and flooding.. Between July and October 1982, a planned removal action
removed 302,000 gallons of waste oil, solidified 205,000 gallons of sludge and treated
and released 430,000 gallons of contaminated water. An August 1984 Record of Decision
addressed the incineration of contaminated water, oil above 50 ppm, PCB and oil below 5D
ppm PCB. Currently bulk waste material including 6,000 gallons of oil, 60,000 gallons
of waste water and 705,000 gallons of sludge are still present at the site. The primary
contaminants of concern affecting the soil include: PCBs, PAHs, VOCs and metals
(primarily lead). .
(See Attached Sheet)
7. KIY WOADS AND DOCUMINT ANAL.YSIS
~ DISCRIPTORS b.IDENTIFIERs/opeN eNDED TERMS c. CDSATI Field/Group
Record of Decision
Laskin/Poplar Oil, OH
Second Remedial Action
Contaminated Media: soil
Key contaminants: lead, PAHs, PCBs, VOCs,
metals
" DISTAIIUTIDN STATEMENT 11. SECURITY CLASS /TIIU R~porrl 21. NO. OF PAGES
None 36
I 20. seCURITY CL.ASS (Ttlis POPI 22. PAICe
tJt'\no
IPA ,- 2220-1 (R... .-77)
-"aVIOUI aOITION II 0810"'aTa
-------
EPA/ROD/R05-87/053
Laskin/Poplar Oil, 08
Second Remedial Actio~
16.
ABSTRACT (continued)
The selected remedial alternative includes: construction of a fence around
contaminated portions of the site and the onsite incinerator; onsite incineration of
oils, sludges and highly contaminated soils; offsite treatment of all waste waters,
decontamination water and scrubber water; offsite disposal of all incinerator ash;
dismantling and offsite disposal of all tanks; crushing and incineration of cinder block
walls of the pits; and backfilling and grading of all excavated areas. The estimated
present worth of the recommended alternative is *8.5 million with no O&M required.
-------
RECORD. OF DECISION
Remedial Alternative Selection
Source Removal Operable Unit
SITE: Laskin/Poplar Oil - Ashtabula, Ohio
PURPOSE:
This decision document represents the selected remedial' action for the operable
unit for the Laskin/Poplar Oil site. It was developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), a~d to the extent practicable, the National Contingency Plan of
1985 (NCP) (49 CFR Part 300).
The State of Ohio' has concurred on the selected remedy, as stated in the attached
Letter of Concurrence.
BASIS:
- .
;
. .
The selection of remedy is based upon the Laskin/Poplar Oil site Administrat~ve
Record. The attached index identifies the items which comprise this record.
DESCRIPTION OF SELECTED REMEDY:
The selected remedy consists of the following' major components:
- construction of a fence around the contaminated portions of the site and
the on-site incinerator;
- on-site incineration of oils, sludges, and highly contaminated soils;
- off-site treatment of all wastewater, decontamination water, and scrubber
waterj
- off-site disposal of all incinerator ash;
- dismantling and off-site disposal of all tanks;
D
- crushing and incineration of the cinder block walls of the pits;
- backfilling and/or grading of all excavated areas to preclude ponding.
DECLARATION:
Consistent with CERCLA, as amended by SARA, and the NCP, I have detenmined that
the remedy described above is a cost-effective interim remedy. This action °is
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protective of human health and the environment, attains Federal and State
applicable or relevant and appropriate requirements, and is cost-effective.
This option will not require any long-term operation and maintenance activities.
This remedy satisfies the preference for treatment that reduces toxicity,
mobility, or volume as a principal element. Finally, it is determined that the
remedy utilizes permanent solutions and alternative treatment technologies to
the maximum extent practicable.
. .
The United States Environmental Protection Agency (U.S. EPA) is continuing its
campresensive Remedial Investigation/Feasibility Study (RI/FS) for the
La'ski n/Popl ar Oi 1 site. Phase II of the RI is schedul ed to begi n during the
1st Quarter of Fiscal Year 1988 and will further characterize the site, major
migration pathways, and extent of dioxin contamination. The U.S. EPA is planning
to complete the remaining tasks of the RI/FS by late 1988. This will include
the identification and evaluation of potential final remedial actions. If
additional remedial actions are determined to be necessary, a Record of pecision
will be prepared for approval of the future remedial actions.
Date
p fi
sl!ftlWJ~ ac /- If/ll
Valdas V. Ad . us
Regional Adm" istrator
United Stat Envi ronmental
Agency, Regi on V .
Protection
,"
-------
.. '" .._... .. .,,~~
8\818 of Ohio ~,..._......... PwotectJon Agenc:r
P.O. 80)( 1049, 1800 WaterMark Dr.
Columbus, Ohio 43266-0149
Richard F. Celeste
Governor
September 28, 1987
n~CE'VED
Mr. Valdas V. Adamkus
Regional Administrator
u.s. EPA, Region V
230 South Dearborn Street
Chicago 111ino~s 60604
o C 1 (\ , 1987
, ~ C:"'.\ RE(;\ON 5
L ,,'.. M,I.Jt.,,"lstIlAtOR
o'~~~.. ....~ 1..- '..1'.
Dear Mr. Adamkus:
After review of the Phased Feasibility Study for Source Material Removal. for
the Laskin/Poplar 0'1 Superfund site and the draft Record of Decision fop; this
remedial action, Ohio EPA concurs w1th the proposed remed'al alternat1vea
Th1s alternat1ve includes: ~
- construct10n of a fence around the contam1nated port10ns of the s1te'
and the on-sHe 'nc1nerator; .
- on-s1te 'nc'nerat10n of 011s,.sludges and .source 501151;
. I
I
- off-site treatment of all wastewaters, decontam1nated water, and
scrubber water;
- off-s1te d1sposal of all 1nc1nerator ash;
- d1smantl1ng and off-s1te d1sposal of all tanks;
- crushing and 1nc1nerat10n of the c1nder block walls of the p1ts;
- and backfilling and grading of all excavated areas.
Est1mated cost of $8.5 m11110n.
u
. .
Oh10 EPA will assure payment of 10 per centum of the remed1al act10n. There
15 no operation and maintenance required for th1s act10n.
Richard l. Shank, Ph.D.
01rector
O. WHD
cc: RF
RA
FREEMAN v
RLS/RHIl z
cc: David Strayer, CAS,DSHWM
Radney Beals, NEDO
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
LASKIN/POPLAR OIL SITE
SOURCE REMOVAL OPERABLE UNIT
SITE LOCATION AND DESCRIPTION
The Laskin/Poplar Oil site is located west of the village of Jefferson in
Ashtabula County, Ohio. The site occupies approximately 9 acres. The
general site location is shown in Figure 1.
The site is bounded on the north by Cemetery Creek, on the south and east
by the Ashtabula Fairgrounds, and to the west by wooded areas. A map of
the site is shown in Figure 2. The following facilities and structures
are located on site:
The residence of Mr. Alvin Laskin, property owner;
- A boiler house, four boilers, and a stack;
- Several greenhouses;
- Thirty-four tanks;
- Four pits; .
- A retention pond, a freshwater pond, and two treatment
. ponds; and.
- Miscellaneous sheds and buildings.
;
. .
~
SITE HISTORY
A greenhouse operation started at the Laskin/Poplar oil site approximately
80 years ago. Boilers were installed approximately 30 years ago to heat
the greenhouses. During the 1960's, tanks were installed to hold waste oil
to fire the boilers. The oils were not analyzed. prior to acceptance, and
oil containing PCBls and other hazardous constituents were accepted.
When the greenhouse business deteriorated, the owner began collecting,
reselling, and disposing of waste oils. These activities included oiling
roads in Ashtabula County. Through a series of legal actions, the company
was placed into receivership. All on-site business activities relating to
oil have stopped.
Remedial activities began in December, 1980 and the site is presently
involved in a comprehensive federal-lead Remedial Investigation/Feasibility
Study (RI/FS) which will be completed in 1988. . This action is an operable
unit to address the source material onsite. It will be consistent with the
. final remedy to the greatest extent practic~ble.
-------
ii~
i' ""',.
;/'
I
lJ
-, I
I
.
- . !
,,~ "OAO.':" . ' I
". '. .I--~.-. - ..1'.- ~..:..~'
t
1000 0 1000 2000 3000 .xIO
- - -
1 5 0
- - - - -
I NILE
5000
6COO
7000 'EET
I IULO~ETER
CONTOUR INTERVAL 10 FEET
DATUM 1$ MEAN SEA LEVEL,
c:J
FIGURE 1
LOCATION MAP
LASKIN/POPLAR Ol~
QUADRANGLE LOCATION
-2-
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,---,-,
, J
\ ""
,--....
IACKFILLED POND
.~
D
a
GREENHOUSES
.\ (
- .,
;
- .
..
FIGURE 2
SITE MAP
LASKIN/POPLAR Oil
-3-
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Several emergency actions have taken place at the site since the U.S.EPA
first became involved. During 1982, Superfund planned removal operations
removed 302,000 gallons of waste oil, "treated and released 430,000 gallons
of contaminated water and solidified 205,000 gallons of sludge. In
1985-86, the potential responsible parties (PRp.s) removed approximately
250,000 gallons of oil and wastewater from the site. All of the pits
hav~ been covered.
CURRENT SITE STATUS
Phase I of the remedial investigation (RI), which characterized the
Laskin/Poplar Oil site and identified potential pathways for chemical
migration, has been completed. Field work for Phase II of the RI is
scheduled for lQFY88 and will provide detailed information on groundwater,
soil, and dioxin contamination. The ROD for the overall site is expected
some time in 1988. "
Data collected during the Phase I of the RI and by the PRPs has shown
that further action is required at the site. Of immediate concern is the
bulk waste .material still present at the site and the potential risk to
public health, welfare, and the environment the waste material presents.
The waste present on the site
include the following:
- Approximately 6000 gallons of oil
- Approximately 60,000 gallons,of wastewater
- Approximately 705,000 gallons of sludge
;
..
A more detailed breakdown of the waste volumes is given in the Appendix
of the phased feasibility study.
The types of contaminants present in the wastes include polychlorinated
biphenyls (PCBs), polynuclear aromatic hydrocarbons (PAHs), and volatile
organic compounds (VOCs). The levels of contaminants found in the waste
material are summarized in Table 1. The soils immediately surrounding
the pits are expected to have contaminant levels commensurate with those
found in the sludges and oils. Lower levels of contaminants are found in
the borings surrounding the pits. Soils which are visibly contaminated
will be considered "source" soi15 and will be included in this source
removal operable uni~.
RISK TO RECEPTORS VIA PATHWAYS
There is a continuing potential for a release of the contaminated liquids
and sludges to the environment. A release could occur through fire,
natural deterioration of the tanks and their fittings, seepage through
the sides and unlined bottoms of the" pits, and accidental or deliberate
acts. A release from any of these routes would have the potential to
contaminate surface water, groundwater, and soil.
-4-
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TABLE 1
ANALYSIS OF WASTES
Ranges of Contaminants
Oils Wastewaters Sludges
METALS (ppm)
Aluminum 0.04-4.87 28-14,600
Antimony 0.0-0.2 0.0-13
Arseni c 0.0-0.75 0.0-16
Barium 2.0-34 0.021-0.7 6.1-1.270
Chromium 0.0-8.5 0.0-0.074 10-3,420
Copper 0.0-13 0.0-0.224 - 25-598
Iron 25-295 0.227-74.9 28-4,720
Lead 30-543 0.004-0.62 69-12,400
Magnesium <20 0.08-47.2 0.0-9,040
Manganese 1.9-8.4 0.014-7.22 0.0-375
Mercury 0.0-0.24 0.0-0.0003 0.0-18
Nickel 0.0-0.291 0.0-82
Zinc 9.0-290 0.267-15.9 18-5,060
Cyani de 0.0-0.03 0.0-5 .' .
~
. PCBs (ppm)
Aroclor 1221 0'.0-0.054
Aroclor 1242 10-22 0.0-0.024 0.0-94
and/or 1016
Aroclor 1254 41-144 41-0.15 0.0-170 .
Aroclor 1260' 0..0-12
VOLITILE ORGANICS (ppm)
Methylene Chloride 0.0-2.4 0.0-3,800
Acetone 0.25-46 0.0-97,000
1,1-Dichloroethene 0.0-1.7
1,1-Dichloroethane 0.0-0.12 0.0-5.3
Chloroform 0.0-1.2 0.0-5,100
1,2-Dichloroethane 0.0-0.36 0.0-6,400
2-Butanone 0.0-18 0.0-19,000
1,1,1-Trichloroethane 0.0-0.27 0.0-21,000
Trichloroethene 0.0-0.04 0.0-1,200
Benzene 0.0-0.46 0.0-280
4-Methyl-2-Pentanone {J.0-3.8 0.0-7,400
Tetrachloroethene 0.0-0.01 0.0-750
Toluene 0.0-7.4 22-76,000
Chlorobenzene 0.0-2
Ethy 1 benzene 0.0-14 14-44,000
Total. Xylenes 0.0-3.4 . 49-140,000
Vinal Acetate 0.0-10
-5-
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TABLE 1
(cont.)
ANALYSIS OF WASTES
Ranges of Contaminants
Wastewaters Sludges
BASE/NEUTRALS (ppm)
1,3-0ichlorobenzene
1,2-0ichlorobenzene
Nitrobenzene '
rsophorone
1,2,3-Trichlorobenzene
Naphthalene
2-Methylnaphthalene
Acenaphthalene
Acenaphthene
Oibenzofuran
Fluorene
4-Nitroani 1 i ne
n-Nitrosodiphenylamine
Phenanthrene
Anthracene
, di-n-Butyl Phthalate
Fluoranthene '
Py rene
Butylbenzylphthalate
Benzo (A) Anthracene
bis(2-ethylhexyl) Phthalate
Chrysene
Oi-N-Octyl Phthalate
Benzo (8) Fluoranthene
Benzo (A) Pyrene
Indeno(I,2,3-c,d) Pyrene
Benzo (g,h,i) Pyrene
0.0-120
0.0-62
0.0-2.2
0.0-17 0.0~15,000
0.0-130
1.3-15 0.0-34,000
0.45-45 96-5,800
0.0-6.5 0.0-1,000
0.11- 34 50-6,600
0.25-30 0.0-3,600
0.0-30 0.0-5,000 ;
, .
0.0-5 ~
0.0-26 0'.0-1,600
0.62-97 , 0.0-12,000
0.14-17 ' 0.0-9,000
000-2.7 0.0-62
0.22-30 0.0-5,300
0.18-35' 0.0-5,200
0.0-0.033 0.0-290
0.0-8.5 0.0-1,400
0.0-8.5 0.0-370
0.0-51 0.0-1,500
0.0-1,000
0.0-6.2 0.0-95
0.0-0.44
0.0-330
0.0-350
ACID EXTRACTABLES (ppm)
Phenol
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
4-Chloro-3-Methylphenol
107-53
0.0..34
0.0-9.5
0.0-16
0.0-34,000
0.0-8,500
0.0-22,000
0.0-2,700
0.0-140
-6-
-------
The route of greatest concern is seepage from the sides of the pits and
the unlined bottoms of the pits. Seepage from the pits would have the
potential of contaminating groundwater and soil. Groundwater samples
taken by EPA contractors and soil samples taken from around the pits
indicate releases have already occurred. The soils immediately sur-
rounding the pits are expected to contain contaminants at levels similar
to ~hose found in the sludges and oils in which they are in contact.
The continued presence of these waste materials would allow more seepage
to occur.
There is a potential for fire at the site. The wastes in Pit 2 have a
flash point of only 80-85 F, and much of the oils and sludges have high
BTU values. A fire, started by whatever means, could create a contami-
nated smoke plume and could release contaminated materials to the site
and surrounding"area.
Based on surface topography, contaminants released on site have the
potential of being carried into Cemetery Creek. Cemetery Creek empties
into the Grand River which supplies the drinking water for approximately
25,000 people in Ashtabula County.
.~
~
PCBs
PCBs are absorbed through the lungs, the gastrointestinal tract, the
intact$kin, and (in experimentally exposed. animals) the eyes. After
absorption,' PCBs circulate through .the body in the blood and accumulate
in the liver, adrenal glands, and skin. .
The most significant concerns from PCBs are the chronic effects which are
manifested over prolonged, but not necessarily continuous, exposure to
low levels. Many of the toxic effects in mammals have been noted at
extremely low levels of exposure, in several species at dietary levels of
only 1.0 to 2.5 ppm or less. The toxic effects of PCBs in humans have
been reported both as a result of occupational exposures and in the
general population. PCBs have been shown to be carcinogenic in rats and
mice, and there is evidence that it might cause stomach and liver cancer
in humans. The Office of Health and Environmental Assessment (OHEA) of
the U.S.EPA developed health advisories for PCBs in soil. The OHEA asses-
sment concluded that a PCB level of 1 to 6 ppm in soil in a residential/
. commercial area would be associated with a lx~0-5 level of oncogenic
risk.
The levels of PCBs in the oils are above 50 ppm in every sample taken and
are as high 170 ppm. The levels in the sludges are generally greater.
than 20 ppm and are found as high as 238 ppm. The levels of PCBs found
in the borings nearest to the pits, approximately 4 to 6 feet, are below
3 ppm:
-7-
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METALS
Lead is the metal of primary concern found in the waste material. The ,"
" main routes of exposure for lead are inhalation and ingestion.. The
Centers for Disease Control (CDC) have stated that soil and dust levels of
greater than 500-1000 ppm appear to be responsible for blood levels in
children increasing above background levels. The major health effects
associated with lead concern damage to the hematopoietic and neurological
system. Lead can cause renal dysfunction, and is known to be teratogenic
to animals. There is evidence that young children are more sensitive to
the toxic effects of lead than are adults.
The levels of lead in the oils range from 30-543 ppm. The level of lead
in the sludges range from 69-12,400 ppm.
POLYNUCLEAR AROMATIC HYDROCARBONS (PAHs)
A number of PAHs were identified in the base/neutral analysis for the
sludges. As a group, PAHs are persistent in the environment. Some PAHs
are carcinogenic and mutagenic. Materials such as tars and oils, known
to contain PAHs, have been shown to be carcinogenic to humans: According
to the regional spokesperson for the Agency for Toxic Substances and
Disease Registry (ATSDR), CDC considers total average PAH levels of up to
100 ppm in residential 'areas and 1000 ppm in comercia1 areas acceptable.
The levels of total PAHs in the S'ludges range from 428 ppm to over 82,000
ppm.
" .
;
. .
'"
VOLATILE ORGANIC COMPOUNDS (VOCs)
No health based standards for VOCs in soil currently exist. However,
some of the VOCs found at the site are considered toxic or are carcinogens.
A number of the VOCs in the sludges can be found at levels greater than
10,000 ppm. The level of VOCs in the closest soil. borings to the pits
can be found at greater than 1 ppm.
ENFORCEMENT HISTORY
State actions at the Laskin/Poplar Oil site include a complaint filed in
. the Ashtabula County Court of Common Pleas in'Apri1 1979' for air and
water pollution violations. The owner/operator was found liable by the
court and ordered to cleanup the site. The owner/operator was found in
contempt of cou rt on several occas ions and a receiver was appoi nted for
the business by the Ashtabula County Court of Common Pleas court on December
22, 1980. The owner/operator entered into a consent decree with the Federal
Government on January 21, 1981. The consent decree required the
owner/operator to cleanup the site, halt discharge of contaminated water
to Cemetary Creek, and abide by TSCA PCB rules.
-8-
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After several emergency fund-financed removals between 1980 and 1983, a
unilateral Administrative Order (AO) was issued to four PRPs in August
1984. This AO required the removal and incineration of the bulk of the
contaminated oil and treatment of the contaminated water t.hat was con-
tained in the pits and tanks on site. This order was complied with
during the winter of 1985-86.
, .
A second unilateral AO, to eight PRPs, was issued in July 1986. This
order, which originally required the removal and incineration of the'
remaining sludge, was amended in September, 1986. The amended AO required
the development of a workp1an to remove and incinerate the sludge and to
samp1 e the soil s around the in ground pits. This workplan was submitted
in March 1987.
Additionally, while these administrative enforcement activities were
taking place, the U.S.EPA was pursuing a cost recovery action to recover
the monies spent on the emergency actions. The first complaint was filed
in June 1984. Amended complaints were filed in December 1984, July 1985,
and October 1986. Currently there are eleven defendents in this action
including the owner/operator, the operating company (Poplar Oil Co.), a
finance company, and eight corporations which generated wastes sent to
the site. These defendents have sued an additional 600 third parties,
have settled with approximately 30, and have since dismissed another 30
for lack of evidence. Settlement discussions on this action are on-going.
COMMUNITY RELATIONS HISTORY
- .
;
~
U.S.EPA's community relations acti'vities at the Laskin/Poplar Oil site
date back to 1981, when the agency conducted emergency actions to prevent
oil from leaching .off the site. Between July and November, 1982, U.S.EPA
conducted a removal at the site which resulted in the elimination of the
site's most imminent hazards. A Community Relations Plan (CRP) was
prepared and implemented during that time.
The public comment period for this operable unit stated on August 10,
1987 and went through September 11, 1987. On August 18, 1987, a public
availability session was held at the Jefferson Courthouse, giving area
residents an opportunity to meet and talk with staff about site activi-
ties. On August 26, U.S.EPA held a public meeting to accept comments on
the feasibility study for the source material removal operable unit.
Health issues hav~ and continue to be a major source of concern for the
citizens. Concerns center around the pathways of possible exposure to
contaminants during the period of the site's operation. These include
exposure to the burning of PCB contaminated oil, the road spreading of
the oil, and the presence of dioxin. Questions and.comments posed by the
community and the PRPs are included in the attached responsivness summary.
-9-
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ALTERNATIVES EVALUATION
The major objective of the phased feasibility study (PFS) is to evaluate
remedial alternatives for the removal of source material from the Laskin/
Poplar Oil site. Source material includes the sludges, oils, and waste-
waters as well as highly contaminated soils. The clean-up approach estab-
lished for this operable unit was developed to address. the materials
which may serve as a source for further site contamination and is not
meant to serve as the final remediation level for the site. All attempts
have been made to keep the actions of this operable unit consistent with
the final remedy to the extent it can be anticipated.
The remedy selected will ~e consistent with the goals and intent of the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA) and the National Oil and Hazardous Substances Con-
tingency Plan (NCP) (40 CFR Part 300 et. seq., 47 Federal Register 31180,
July 16, 1982).
An environmental assessment presented in Chapter 2 of the PFS determined
that source control measures are needed at the site. A list of approp-
riate remedial response.technologies was identified. Each technology was
screened based on its technical feasibility and implementability. The
following technologies were considered appropriate technologies:
;
. .
~
Oils/Sludges/Soils
- O~-site containment
- Off-site containment
- On-site land treatment
- . On-site incineration
- Off-site incineration
- On-site incineration/
Off-site containment
Wastewaters
- On-site treatment
- Off-site treatment
Tanks
- Dismantling/Off-site
disposal
Technologies which 'were eliminated from further consideration include
on-sit~ containment, on-site land treatment, and on-site wastewater
treatment. The on-site containment option encompased the placement of
the source soils and the waste from the tanks and pits into an on-site
waste disposal unit. This option was not considered implementable due to
the impending November 8, 1988 deadline imposed by the Land Disposal
Restrictions. The Land Disposal Restrictions prohibit the land disposal
of all wastes included on the California List and solvent wastes from
-10-
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catagories FOOI-FOOS. The design, construction, disposal, and closure
would all need to be finished prior to the November 8, 1988 deadline.
Land treatment was not considered technically feasible for the treatment
of the levels of PCBs and halogenated organics found in the waste mate-
ria1s~ On-site wastewater treatment was not considered technically
feasible, based on the volumes expected and the difficulty in achieving
discharge requirements due to the wide variety of organics compounds and
levels of lead found in the waste. The wastewaters would be more suited
for treatment at a comercia1 wastewater facility.
Remedial action alternatives were developed from the remaining technol-
ogies. These alternatives were then compared on cost effectivness,
protectiveness to the pUblic and the environment~ and compliance with the
requirements aryd intent of SARA. A comparative evaluation of the altern-
atives is shown in Table 2.
Alternative 1
Under this alternative, no remedial action would be taken at the
site. The threat to public health and the environment, as described
earlier and in the FS, wou1u remain.
Alternative 2
;
, .
..
Alternative 2 consists of solidifying all of the liquid wastes and
.. placing all .0' the source material in a licensed TSCA or RCRA
facility as appropriate. All tanks would be dismantled and taken
off-site. The pit area would be backfilled with on site soils and
graded to preclude ponding.
No long term maintenance or monitoring at the Laskin/Poplar Oil site
would be required under this alternative. However, the waste would
not be treated prior to 1andfi1ling at the licensed facility. The
long term dependability of any landfill is unknown. The cost esti-
mate for Alternative 2 is $4.2 million.
Alternative 3
Alternative 3 combines on-site incineration of the oils, sludges,
and source soils with off-site treatment of the wastewaters, decon-
tamination water, and scrubber water. the incinerator ash and
dismantled tanks would be disposed in an off-site RCRA licensed
facility. If tests indicated that the ash could be delisted, the
ash could be sent to a sanitary 1anfi11. The excavated pit area
would be backfilled with onsite soils and graded to preclude ponding.
This option would not require any long term maintenance or monitoring
at the site. All source mater;a1 would be treated to the greatest
extent practicable. The cost estimate for alternative 3 is $8.5
mi 111 on .
-11-
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ORDER OF MAG'UJUII[
COSTS
nCHIUCAl CRITERIA.
felSlbllltl
18p1 e.entibl I It 1
I
....
I\J
I
PUBL IC HEAL TN ANO
ENVIRONMENT
callEMIA
UTEIT Of
PE IlHAtI: IT
TREATMENT USAG(
No Action
10
Not Appllcibl.
Not AppllCibl.
- Potentl.1 for chellc.1
.'gr.tlon II~ell
- No tre.t.ent II Involved
Tible 2
ALTERNATIVES EVALUATION SlINRY MATRII
Of'-Ilte Cont.lnaent
14.199,805
.
. Altern.tlves C~r-
~1.lll .v.llible
. L.nd Dllpos.1 Reltrlctlon
de~llne 11/8/88
. W'ltes not tre.ted
Long-tenl depend.bliltl
of l.nd"11 unknOMn
- No tre.t..nt II Involved
Thll II the le'lt f.vored
option under SARA
On-lite Inciner.tlon
18,490.865
. Altern.tlve II C08-
..reI. I 1, .v.ll.ble
.
. All "Itel pe,..n-
ent 1, tr..ted
. Tre.went II used to
the gre.test e.tent
priCtlClble
r ... .....
O'f-slte Inclner.tlon
112.141.355
t Altern.tlve Is CQ888r-
cl.ll, .v.II'ble
t
. All ..stel tre.ted
pe,..nentl, tre.ted
. Tre.t.ent Is Uled to the
gre.telt ,.tent posllble
On-lIte Inclner.tlon
O'f-slte Cont,'nment
15.J24,418
. Altern.t I ves COl8ler-
clall, ".II.ble
.
. Over h.I' the w.stes
untreated
Long-ten. dependiblllt,
0' I.ndfill unknown
. Less th.n h.l, 0' the
w.ste Is tre.ted.
L.nd',lllng wIthout
tre.tMent Is the le.st
'.vored under SARA.
-------
Alternative 4
Alternative 4 utilizes off-site incineration for all oils, sludges,
and highly contaminated soils. All wastewaters and decontamination
water would be treated at an off-site treatment facility. The tanks
would be demolished and disposed of at a licensed facility off-site.
The excavated areas would be backfilled with on-site soils and
graded to preclude ponding.
This option would not require any long term maintenance or monitoring
at the site. All source'materia1 would be treated to the greatest
extent practicable. The cost estimate for Alternative 4 is $12.2
mi 11 i on .
Alternative 5
Alternative 5 includes on-site incineration of all oils and sludges
as well as soi ls"with greater than 25 ppm PCBs or 500 ppm total
halogenated organics. The remainder of soil excavated from the tank
and pit areas would be 1andfi11ed off-site at a RCRA licensed hazar-
dous waste facility along with all dismantled tanks. All waste-
waters, decontamination water, and scrubber water would be treated
at an off-site treatment facility. The excavated areas would be
backfilled with oo-site soils and graded to preclude ponding.
This alternative would not require any long term maintenance or
monitoring at the site. The most highly contaminated source material
.wou1d be permanently treated. However, the soils that would be
landfi11ed, which comprise roughly one half of the source material,
would not be treated. The off-site disposal of waste without treat-
ment is the least favored option under SARA. The cost of Alternative
5 is $5.8 million.
.
. .
'"
With the exception of no action (Alternative 1), all of the alternatives
would effectively and permanently minimize the danger to the public
health and the environment at the site area through the removal of the
contaminated material.
'"
The use of an off-site landfill (Alternative 2 and 5) is conventional,
easy to implement, and transfers the operation and maintenance to the
. owner/operator of the landfill. The most sig~ificant disadvantage of
this option is that it does not treat the contaminants, so there is no
reduction in toxicity, volume, or mobility. It also may be difficult to
maintain the long term integrity of hazardous waste landfills as required
by the U.S.EPA's off-site policy. The off-site disposal of contaminated
materials without treatment is the least preferred option under SARA.
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The off-site incineration of the source materia)s (Alternative 4) offers
the advantage of permanently destroying the contaminants in the waste
material and the soils. It is a proven technology that transfers opera-
tion and maintenance to the owner/ operator of the incinerator facility.
One the'most significant disadvantage of this alternative is implemen-
tability. The material must be packaged in small fiber drums for trans-
por-tation. The facilities available have commitments to their regular
clients which control when and at what rates the source material can be
taken care of. In.addition, a number of off-site hazardous waste
incinerators have shown a reluctance to'accept the waste material due to
the high levels of 1ead found in some of the sludges. Tramsportation of
the waste to an off-site facility increases both the cost of this
alternative and the risks posed to the public by movement of contaminated
materials on the highways.
As with off-site incineration, on-site~ineration (Alternative 3 and 5)
would uti1i~e a proven technology to permanently destroy the contaminants
in the source material. The advantages of this alternative are that the
packaging requirements necessary for off-site incineration would be
avoided, and all material could be processed in one year or less once the
incinerator begins operation. This alternative also meets the goal of
SARA of implementing a remedial action which incorporates treatment
rather than land disposal where practicable. .
;
. .
~
A comparison of the alternatives on the basis of protectivness of public
health and the environment shows that on-site and off-site incineration
p.rovide a h-igh'leve1 of protection. Alternatives which use a high degree
of 1andfi11ing provide an equal level of protection in the short run.
The long run dependability of landfills, however, are unknown. There
would be no beneficial impacts associated with the no action alternative.
Any detrimental environmental effects associated with the waste and soil
removal operations would essentially be the same for each alternative
except the no action alternative. These short term negative impacts
could be minimized using proper construction methods.
The State of Ohio and the U.S.EPA expressed preference for remedial
actions that would provide destruction of hazardous constituents in lieu
of transporting untreated wastes to a RCRA approved location. Section
121(b)(1) of SARA states "Remedia1 actions in which treatment which
. 'permanent1y and significantly reduces the volume, toxicity or mobility of
the hazardous substances, pollutants, and contaminants is a principal
element, are to be preferred over remedial actions not involving such
treatment. The offsite transport and disposal of hazardous substances or
contamin~ted materials without such treatment should be the least favored
alternative remedial action where practicable treatment technologies are
avai1ab1e.". .
-14-
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Thus, th~ U.S.EPA emphasizes the need to consider tr~atment, recyc1;-ng
and reuse before off-site land disposal of hazardous substances from
CERCLA sites is used. In addition, Section 300.68(h)(1) of the NCP
provides that remedial alternatives should not be eliminated on the basis
of cost alone. Therefore, other long term benifits should be analyzed
when comparing alternatives.
Environmental benifits which would accrue as a result of selecting an
incineration option over a land disposal option are:
1)
permanent destruction of the PCBs, PAHs, VOCs, and other organics
found in the source material,
2) .e1imination of the risk of release of hazardous substances to
the environment and reduction of the health risk associated with
this exposure, and
3)
elimination of the need for governmental authorities to perform
the environmental monitoring at the site would be necessary if the
wastes were left on site or relocated to another site.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
;
~
The technical aspects of the remedial alternative inp1eme~ted at the
Laskin/Poplar Oil site will be consistent with all federal and state
applicable or re1avent and appropriate requirements (ARARs). Other
environmental laws which may be considered ARARs to the remedial alter-
natives evaluated are the Resource Conservation and Recovery Act (RCRA),
the Toxic Substance Control Act (TSCA), the Clean Air Act. Chapters
3704 and 3734 of the Ohio Revised Code (ORC), and Section 3745-15, 17,
and 18 and 21 as well as Section 3745 - 50 through 3754 - 69 of the Ohio
Administrative Code.
The specific provisions of RCRA which may serve as ARARs for the alter-
native chosen include the thermal destruction requirements (40 CFR Subpart
P, Section 265.370 through 265.383), the incinerator requirements
(40 CFR Subpart 0, Section 265.340 through 265.369). These provisions.
list the proceedures and requirements which must be complied with during
the thermal destruction of the waste material. These reqirements are
also included in OAC rules 3745-57-40 to 3745-57-99 and OAC rule 3745-50-62.
The off-site wastewater treatment requirements (40 CFR Parts 262 and 263)
could also be considered an ARAR.
The selected remedy involves placement and treatment of soils and debris
wastes. Placement of wastes or treated residuals is prohibited under
RCRA Land Disposal Restrictions (LOR) unless certain treatment standards
are met. LOR standards have not been published for soil and d.ebris
wastes, but when published, the standards may be applicable or relevant
and appropriate. Despite the absence of specific treatment standards,
the treatment method employed as part of this remedial action s~tisfies
the statutory requirement to, "...substantially diminish the toxicity of
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the waste or substantially reduce the likelihood of migration of hazardous
constituents from the waste so that short-term a~d long-term threats to
human health and the environment are minimized.1I [sec. 3004 (m) H.S.W.A.J
Emissions from the incinerator would be covered under the Clean Air Act,
ORC Chapter 3704, and OAC Sections 3745-15, 17, 18, and 21. Off-site trans-
portation of hazardous waste is covered under OAC 3745-53-11. This
requires the transporters of hazardous waste to register with the Public
Utilities Commission of Ohio and to obtain Ohio transporter registration
numbers. These requirements will be met during the remedial action.
ARARs will only be waived under the conditions set forth in Section
121(d)(4) of SARA. This action is considered an interim measure. There-
fore,no final cleanup levels have been determined. The final cleanup
. levels will be determined at the completion of the overall site RI/FS.
RECOMMENDED ALTERNATIVE
It is recommended that Alternative 3 be selected. This alternative
consists of the following:
Construction of a fence around the contaminated portions of the
site and the on-site incinerator
;
~
- On-site incineration of oils, sludges, and IIsourcell soils
- Off-site treatment of all wastewaters, decontamination water, and
scrubber water
- Off-site disposal of all incinerator ash
- Dismantling and off-site disposal of all tanks
- Crushing and incineration of the cinder block walls of the pits
- Backfilling and/or grading of all excavated areas to preclude ponding
Based on the comparison of alternatives, the recommended alternative is
fully protective of public health and the environment, cost effective,
utilizes treatment technology to the maximum extent practicable, and will
meet all applicable, or relevant and appropriate federal and state
requirements. It has an estimated cost of $8.5 million.
DESCRIPTION OF RECOMMENDED ALTERNATIVE
At the inception of the remedial action, the site would be fenced to
reduce access to the contamination on site and the equipment used for the
remedial action.. Site access would only be granted on an as needed
basis.
On-site mobile incinerators are a proven and available technology. Based
on vendor information, both infrared and rotary kiln mobile incinerators
-16-
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would be capable of achieving the 99.9999% destruction efficiencies
required for PCB wastes. Both units have air scrubber systems capable of
effectively removing air emission constituents to the levels needed to
meet all federal and state ARARs. Air emission levels would be specified
during the remedial design process. The attainment of these levels would
be requi red.
The soils could be used to condition the sludges to aid in material
handling. The oils found on site could be used as a supplemental fuel
source for the sludges 'and soils. The cinder block walls of the pits
would be 'crushed and combined with the oils, sludges, and soils to be
burned. . .
All ash generated during the incineration process would be tested to
determine the appropriate method of off-site disposal. If the test
results indicate that the ash should be classified as a hazardous waste,
it woul~ sent off-site to a RCRA licensed landfill for disposal. The
transportation of the ash would be conducted by a company experienced in
hazardous waste handling. The company would be required to have all
necessary permits, manifests, and insurance. If the ash can be delisted,
it could be sent to a sanitary landfill.
Off-site wastewater treatment is technically feasible and has been used
for earlier wastewater removed from the site. All decontamination water
and scrubber water would be disposed of in a similar fasion. An experi-
enced hazardous waste hauler would be used to transport the waters.
;
~
After all waste has been removed from the tanks, the tanks wiil .be dis-
mantled for transportation and disposal at an off-site RCRA facility.
The exact method of dismantling could include flame, hydraulic, or other
technique that could be safely carried out on site. The choice of demo-
lition method will be made during remedial design activities, or during
the removal operation, based on site conditions.
,\
All areas which have been excavated will be backfilled with on-site soils
and/or graded to preclude ponding. Site runoff from the area will be
directed to the existing retention pond.
The'source removal is intended solely as an interim measure. The cleanup
levels used will not necessarily be the final remediation level for the
site. The final levels will be determined during the overall site RIfFS.
All attempts have been made to keep the rem~diation efforts associated
with this operable unit consistent with the final remedy to the extent
that it can be anticipated.
The intent of this operable unit is to remove the the source material
still present on the Laskin/Poplar Oil site. To be consistent with the
intent, the operable unit must deal with the soils which have become
significantly contaminated due to the bulk movement of the oils and sludges.
Therefore, the soils surronding the pits and in the tank area will be
-17-
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removed until the remaining soils are visibly clean. The remaining soils
will be sampled and analyzed for the full hazardous substance list prior
to backfilling and grading. This will aid in the overall site cleanup.
The following is a cost estimate for the recommended alternative.
Site preparation,
mobilization, demo-
bilization and
penniting
Conditioning and
incineration of
wastes and soils
Transportation of
4340 tons of ash
to the landfill
Di sposal cost for
4340 tons of ash
Transportation and
disposal of scrubber
and decon. wat~r
Tank cutting and
decontamination
Transportation of 245
tons of dismantled
tanks
Landfill costs
for 245 tons
Pi t backfi 11i ng
and gradi ng
Indirect costs
including engineering
services and
contingencies
Total
OPERATION AND MAINTENANCE
$1,500,000
$4,377 ,500
$244,125
$651,000
$350,200
$200,000
$ 13,785
$ 36,750
$ 10,000
$1,107,505
$8,490,865
@ $500/ton
20 tonsil oad
300 miles
@ $3.75/mi.
4340 tons
@ $l50/ton
875,500'gal.
@ $0.40/gal
;
- .
...
20 tons/load
300 miles
@ $3.75/mi.
245 tons
@ $1S0/ton
15% Of all .
costs
The preferred alternative will require operation and maintenance costs
associated with the start-up (including the trial burn) and the operation
-18-
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of the mobile incinerator. These costs would be limited to the period of
time when the 'incinerator would be operating, which has been estimated to
be approximately one year and is included in the cost estimate. There is
no long term operation or maintenance associated with this alternative.
No long term monitoring will be required.
SCHEDULE
The following schedule of activities povides projected milestones for the
work to be performed at the Laskin/Poplar Oil site.
Approve Remedial Action (ROD)
Design Award (Notice to Proceed)
September 1987
January 1988
Design Completion
April 1988
July 1988
Award Contract
Begin Remedial Action
Complete Remedial Action
September 1988
September 1989
. .
~
FUTURE ACTIONS
A work plan was completed in August 1987 for Phase II of the RI for the
site. A ROD for the overall site cleanup is scheduled for September
1988. The overall site RI/FS will deal with groundwater, dioxin, and
overall 50i1 contamination. .
';
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LASKIN/POPLAR OIL SITE
JEFFERSON OHIO
RESPONSIVENESS SUMMARY
. .
The United States Environmental Protection Agency (U.S. EPA) recently held a
public comment period from August 10, 1987 to September 11, 1987 for interested
parties to comment on U.S. EPA's August 1987 Phased Feasibility Study (PFS) and
Proposed Plan for a source removal operable unit at the Laskin/Poplar Oil site.
At the time of the pUblic comment period, U.S. EPA had announced its recommended
alternative for the removal of the source material.
The purpose of this responsiveness summary is to document U.S. EPA's responses
to comments received during the public comment period. All of t~e comments
summarized in this document will be factored into U.S. EPA's final decision.
Since the purpose of this comment period was to receive comments specifically
related to the PFS, comments related to the overall Remedial Investigation/
Feasibility Study (RI/FS) or the Superfund program as a whole will be addressed
at a later time. A number of comments were received well after the closing '.;
date of the public comment period. U.S. EPA has not responded to those comme~tsp
except to the extent that many of the same comments were made in timely
submissions.
This responsiveness summary is ~ivided into the following sections:
I.
Responsiveness Summary Overview - This section briefly outlines the
proposed remedial alternatives as presented in the PFS including the
recommended alternative.
II.
Summar of Public Comments and U.S. EPA Res onses - This section
summarlzes ot wrltten an ora comments recelved from the community
and the local officials and the U.S. EPA's responses. The comments are
organized by subject area.
II I.
Summar of Potential Res onsib1e Part PRP Comments and U.S. EPA
Responses - lS sectlon summarlzes bot wrltten comments recelved
from the PRPs and the U.S. EPA responses. The comments are organized
by subject area.
.,
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I.
n
RESPONSIVENESS SUMMARY OVERVIEW
A.
Proposed Alternatives and Recommended Alternative
The PFS identifies and evaluates alternate source
alternatives range from no action to 'complete and
The a1ternatves were screened and evaluated based
feasibility, imp1ementabi1ity.
control options. The'
permanent treatment.
on their technical
Five alternatives passed the initial screening and were compared in
detail. The five alternate included:
1.
No action;
2. Off-site Containment;
3. On-site Incineration;
4. Off-site Incineration;
5. . On-site Incineration/Off-site Containment.
, .
'"
These five alternatives were then subjected to a detailed evaluation of
their effectiveness, compliance with the Superfund Amendments and
Reauthorization Act, and cost effectiveness. The U.S. EPA's recommended
alternative is the on-site incineration of all source material on the
site. Groundwater, soil, and dioxin contamination will be covered in
the overall RIfFS for the site. '
B.
Public Comments on the Remedial Alternatives
Public comments were received from the Village of Jefferson trustees,
the Ohio Environmental Council, and citizens of Jefferson.
C.
PRP Comments on the Remedial Alternatives
The following entities submitted comments on behalf of the PRPs:
. .
Baker & Hostetler, Counsellors at Law, on behalf of
Browning-Ferris Industries of Ohio, Inc., General Motors Corporation;
TRW Inc., Rockwell International "corporation; Koppers Company, Inc.,
and Be-Kan, Inc.
Squire, Sanders, & Dempsey, Counsellors at Law, on behalf of
Ashland Oil, Inc., Cleveland Electric Illuminating Company,
Consolidated Rail Corporation, White Consolidated Industries,
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II.
She 11 Oi 1 Company, Mobil Oil Company, Sun Refi ni ng and Market i ng
, Company, Inc.. Matlack, Inc., Anchor Motor Freight, Inc. and
E1isKim, Inc. -
Freedman, Levy, Kroll & Simonds, Counsellors at Law on behalf of
Perfection Corporation.
Keystone Environmental Resources, Inc on behalf of Be-Kan,I"c.,
Browning-Ferris Industries of Ohio, Inc., General Motors Company,
Koppers Company, Inc., Rockwell International, Inc., and TRW, Inc.
SUMMARY OF PUBLIC COMMENTS AND U.S. EPA RESPONSES
This responsiveness summary addresses both oral and written comments
received by U.S. EPA concening the Phased Feasibility Study (PFS) for
the Laskin/Poplar Oil site. The comment period was held from.
August 10, 1987, to September 11, 1987. A public meeting was held on
August 26, 1987, at the Ashtabula County Courthouse, as an oppurtunity
for the public and other interested parties to present oral and written
comments to the U.S. EPA. These comments are recorded in a transcrtpt
of the meeting which is available at the Information Repositories in ~
Ashtabula and Jefferson, Ohio, and the U.S. EPA Region V office in
Chicago. The written and oral comments are summarized and organized
into the following categories: .
A) The remedial alternative;
B) Additional site work; and
C) General.
A.
Remedial Alternative
- A number of the comments received from the village trustees and the
community supported the U.S. EPA's recommendation of an on-site mobile
i nci nerator.
U.S. EPA's Response:
The U.S. EPA is pleased that the community and local officials support
. the recommended alternative.
- A number of the comments expressed a concern regarding site security
and access.
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o
u.s. EPA's Response:
Areas of the site which are known to be contaminated are currently
enclosed in a property fence. As an initial step of this proposed
remedial action a chain link fence will be constructed. The exact
extent of the fencing will be determined once initial sample results
are received from the Phase II RI for the overall site and the incinerator
location is chosen. Site access during the remedial action will be on
an as needed basis only.
- One comrnentor wanted to know what equipment would be removed.
u.S. EPA Response:
This remedial action will result in the removal of the tanks and pits.
At the end of the action, the mobile incinerator will be removed. The
boiler stack, boilers, and other site. features will be dealt with in
the overall RIfFS.
B.
Additional Site Work
~
- One comment or was concerned that dioxin was not mentioned in the PFS.
u.S. -EPA Response:
Dioxin is not present in the areas covered by this action and s6was
not mentioned. Dioxin contamination is being considered in the
overall site RIfFS.
C.
General
- A number of commentors stated that local contractors should be used
as much as possible.
U.S. EPA Response:
. .
If the work is to be performed by the U.S.EPA, selection of the con-
tractors will be in accordance with applicable federal regulations.
Therefore, bids will be solicited in a manner which will allow all
qualified contractors capable of performing the work to bid on the
project. Out of town contractors often rely on local contractors for
many of the tasks. Information on becoming involved in CERCLA actions
was given to Michael Wheeler of the Ashtabula County Disaster Ser-
vices.
"
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II I.
.,
- A commentor felt that the public should be kept informed of EPA's
schedule of activities.
u.s. EPA Response:
The U.S. EPA agrees. The community relations department has made a
commitment to keeep the public abreast of U.S. EPA actions.
SUMMARY OF PRP COMMENTS AND U.S. EPA RESPONSES
This responsiveness summary addresses the written comments submitted by
or on behalf of the PRPs. The comment period was held from August 10,
1987~ to September 11, 1987. A copy of the comments submitted are
available in the Information Repositories in Ashtabula and Jefferson,
Ohio and the U.S. EPA Region V Office in Chicago. The comments are
organized into the following categories: A) EPA Authority, B) Remedial
Alternatives, C) Time Limits, D) Funding, and E) General. The U.S. EPA
responses are provided for each comment, or set of like comments.
.
, A. '
EPA Authority
Commentors felt the U.S. EPA' lacks the authority to.perform the
remedial action. The ~pecific comments are listed below.
...
Comment:
- The U.S. EPA lacks authority to perform the Phased Feasibility Study
and to take the proposed remedial action, due to the 1 year, $2 million
limits set forth in Section 104 of CERCLA.
u.S. EPA's Response:
The 1 year, $2 million limits set forth in section 104 of CERCLA apply
to emergency response action, not to remedial actions. The Phased
Feasibility Study and the subsequent remedial action are not being
performed under the emergency response authority, but under the
remedial authority.
Comment.:
- Under the Superfund Act, U.S. EPA may only perform remedial actions
at the Laskin/Poplar Oil site if that action is necessary as a result
of a release or threatened release of hazardous substances from the
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site.
Section 101(14) of Superfund states:
liThe term [hazardous substance] does not include petroleum,
including crude oil or any fraction thereof which is not otherwise.
specifically listed or designated as a hazardous substance under
subparagraphs (A) through (F) of this paragraph, and the term does
not include natural gas, natural gas liquids, 1iquified natural
gas, or synthetic gas usable for fuel (or mixutures of natural gas
and such synthetic gas).11
The issue is also discussed in the U.S. EPA General Counsel Memorandum,
July 31, 1987. The PRPs feel the oil excusion implies the oil part of
the waste material cannot be dealt with in the operable unit.
U.S. EPA Response:
The July' 31, 1987 General Counsel discussion of the CERCLA Petroleum
Exclusion set forth in Sections 101(14) and 104 (a)(2), referred to by
the commentor, specifically states on pg. 8:
. .
.. However, it was clear that the omission of oil coverage was ~.;
intended to include spills of oil only, and there was no intent ~
exclude from the bill mixtures of oil and hazardous substances."
The memorandum-continued on pg. 10:
-
.. In fact,one of the petroleum-hazardous substances ~ixtures most
often mentioned during the debates was that of PCB contaminated oil
which is a type of contamination arguably resulting from the
IInormal usell of the oil in transformers. Accordingly, an
interpretation of the petroleum exclusion which includes as
IIpetro1eum" hazardous substances added during use of the petroleum
would not be consistent with Congressional intent."
The situation at the site c1ear}y falls within the authority of Super-
fund. The oils on site are mixed with a variety of volatile organic
compounds, PCBs, and metals, and creosote wastes which are all listed
. as hazardous substances under Superfund. Creosote wastes, which are
derivatives of wood and coal tars, not petroleum products, are a source
of polynuclear aromatic hydrocarbons (PAHs), which are also classified
as hazardous substances.
B. . Remedi a 1 A 1 t ernat ives
A number of comments were received questioning the U.S. EPA's choice of
cleanup levels. These comments dealt with the reasoning behind the
U.S.EPA's choice of cleanup levels and the consistency of the cleanup
levels with the final remedy. Based on these comments, the U.S.EPA has
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:.
reconsidered the chosen cleanup levels. Based on the intent of the
operable unit, to remove the source material found on site, and the
desire to be consistent with the overall site remedy, the U.S.EPA has
modified its cleanup level. The new cleanup level will require the
removal of soils from around the pits and in the tank area until the
remaining soils are visibly clean. This cleanup level is consistent
with the intent of the operable unit and minimizes the likelihood
that soils will be removed past the levels which will be determined'
in the overall site RIfFS. The specific comments made on behalf of
the PRPs are discussed below.
Comment:
- The 5 pp~ PCB cleanup level is inconsistent with the "National TSCA
Policy". The national policy should govern the cleanup level at CERClA
sites. .There is no reference to "Regional Policy" in Section 121 of
CERClA.
u.s. EPA's Response:
.
~
As mentioned earlier, the U.S. EPA will not be using the 5 ppm PCB
action level for this operable unit. The soil shall be removed until
it is visibly clean. Therefore, the issue is moot.
The regional policy approach, however, is fully consistent. with and.
supported in the National TSCA Policy referenced. The national policy
states in 40 CFR Part 761, pg. 10689:
IITherefore, spill s whi ch occurred before the e'ffect i ve date of
this policy are to be decontaminated to requirements established
at the discretion of EPA, usually through its regional offices."
Just as importantly, the TSCA policy does not supercede CERCLA policy.
The TSCA rule specifically states on pg. 10690:
I' However, other statutes requi re the agency to consi der different
or alternative factors in determining appropriate corrective
actions.1I
The policy continues:
" Thus, cleanups under other statutes, such as RCRA corrective
actions or remedial or emergency response actions under SARA, may
result in different outcomes."
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Comment:
- The draft is totally lacking in any explanation of why the Region.
is assuming that Laskin site must be considered a "residential area".
Why can this not be considered a "restricted area", where National
Policy a110ws much higher levels?
U.S. EPAls Response:
The site is considered a residential area for three reasons. First the
site owner/operator has his residence on the property. Second, National
Policy defines residential/commercial areas as areas where people live
or reside or where people work in other than manufacturing or farming
industries. It aho specifically includes playgrounds and parks.
Areas which are less than .1 km from a residential/commercial area are
considered"as such even where access is restricted. Immediately across
the street from the.Laskin property is the Ashtabula County Fairgrounds
and a set of softball fields. On the property itself there is a
freshwater pond which people fish. Third, under current zoning, the -
property can be developed residential.
;
~
Comment:
- Why has the Region not considered the idea of covering the area with
10 inches of clean.soil, which would allow for higher levels even in
residential areas?
U.S. EPAls Response:
The use of a 10 inch soil cover was not considered by the Region because
the operable unit is only an interim remedy. Since contaminated soils
will remain onsite, the possibility exists for the clean soil to become
contaminated or to be mixed with contaminated s011 if further soil
remediation is required. This could result in a larger volume of soil
requiring further remediation and would not be cost effective. Also,
the addition of soil would. not do anything to prevent further contami-
nation of the groundwater.
Comment:
- Soil removal should be left until overall site cleanup levels are
established. This is necessary to assure that the remedial action is
cost effective and consistent with the rest of the site.
;,
U.S. EPA Response:
As documented in the endangerment assessment included in the feasibility
study, the sludges and oils contain hazardous substances at levels above
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current health based standards.
It is the U.S. EPA's feeling, 'due to the fact that the pit bottoms are
unlined, that the oils and sludges in the pits have been in direct
contact with some soils. These soils are saturated with the contaminants
and therefore can be considered source material. Leaving these soils
on site would not be appropriate in terms of protectiveness to public
health and the environment, would not be consistent with the intent of
the remedial action, and would significantly increase the chances that a
mobile incinerator would need to be returned to the site. This remobil-
ization would be costly.
We understand the PRPs concern regarding unnecessary work during this
remedial action and have reviewed the cleanup criteria to be used.
Based on this review, the U.S. EPA has chosen a cleanup approach which it
feels is consistent with the intention of removing the source material,
protective of public health and will minimize the chance of removing
material beyond final cleanup levels.
The chosen cleanup level requires that all soils around the pits and tn
the tank area which are visibly contaminated will be removed. The ta~t
that the soils are visibly contaminated indicates that bulk movement of
the source material has occurred. It would not be reasonable to leave
these soils until the completion of the final RIfFS.
The commentors also felt t~at the Land Disposal Regulations had been
misinterpreted. They felt that they would not apply to the conditions
at the site. The comments are presented below:
Comment:
- Leache concentrations based on the Toxicity Characteristic Leaching
Procedure (TCLP) should be used in determining whether or not land
disposal restrictions apply. This is based on the land ban "correction"
notice of June 4, 1987. The PFS bases its conclusions on actual waste
concentrations.
U.S. EPA's Response:
Use of leachate concentrations based ~n the TCL~ was implicitly stated in
the November 7, 1986 Land Disposal Restrictions and later explicitly
stated in the the June 4, 1987 corrections. The leachate concentrations
only apply to the solvent wastes F001-FOOS which the PFS states some
of the wastes could be considered. The levels in the sludges are such
that the U.S. EPA feels they would have leachate concentrations above the'
limit. The levels are presented below.
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Maximum
Concentration Found
Contaminant
Allowable Leach
Mehy1ene Chloride
Acetone
1,1,1-Trich10roethane
Trich10roethene
Tetrach10roethene
Toluene
Xy1 ene
Ethy1benzene
3,800 ppm
97,000 ppm
21,000 ppm
1,200 ppm
750 ppm
76,000 ppm
140,000 ppm
44,000 ppm
. .86 ppm
.59 ppm
.41 ppm
.091 ppm
.05 ppm
.33 ppm
.15 ppm
.053 ppm
In addition, liquid, PCB containing wastes are covered under the
California List when they are contained in wastes which are listed as
hazardous under 40 CFR Part 261, or if the mixture exhibits one or more
of the characteristics of hazardous waste identified in that Part.
PCBs are banned from land disposal if the total waste concentration
(not an extract or filtrate) exceeds 50 ppm PCBs.
Wastes containing halogenated organic compounds (HOCs) are subject t~;
the California List prohibitions if the waste is listed as a hazardou~
waste under 40 CFR Part 261, or exhibits one or more characteristics of
hazardous waste identified in that Part. The land disposal prohibition
applies to hazardous wastes containing HOCs in total concentrations
greater than ~OO mg/1 (liquids) or 100 mg/kg (non-liquids). This is .
based on total waste concentration (not an extract or filtrate).
Comment:
- Is the Regions interpretation that the land ban would be triggered at
the Laskin/Poplar Oil site consistent with Headquarters policy?
u.s. EPA Response:
The current interpretation in Headquarters regarding what triggers the
Land Disposal Restrictions 1s that when the wastes are removed from
their present location for treatment or disposal the Land Disposal
Restrictions are triggered. On-site containment of the wastes would
require the removal of the liquids and sludges f.or solidification, thus
triggering the restrictions.
Based on the Land Disposal Restriction, certain treatment standards
must be met. The treatment standards for liquid PCB wastes, with
greater than 50 ppm PCBs~ specifies thermal destruction. The treatment
standard for Halogenated Organic Compound (HOC) wastes, with greater
the 1000 ppm HOCs, specifies incineration.
The applicability of the Land Disposal Restrictions is seperate from
the" placement issue which triggers the Minimum Technology Requirements
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for a disposal unit. These requirements are triggered when an existing
unit is expanded or a new unit is created. Under Headquarters policy,
the definition of what is a unit can be expanded when the contamination
is not centered in "hot spots" but is more general and uniform across a
large site. This is not the case at the Laskin/Poplar Oil Site. The
source material areas are distinct units. Therefore, the combination
of all of the wastes into one containment area would trigger the Minimum
Technology Requirements, which include a double liner and a double
leachate collection system.
Comment:
- Based on the soils data collected in fulfillment of the consent order,
PCB and HOC concentrations do not exceed land based limits.
U.S. EPA's 'Response:
It is correct that the soil samples taken from four to six feet from
the pits had levels below the Land Disposal Restritions limit. In
addition, Land Disposal Restriction standards have not been promulgat~d
for soil and debris wastes at this time. When these standards are -.:
published, they may be considered applicable or relevent and appropri!teo
Some of the sludges, however, exceed the land Disposal Restriction.
This means some form of treatment is required for these materials. The
soils immedi~tely surrounding these sludges are be1ieved'to contain
similar contaminant 'levels. The U.S. EPA, therefore, believes it is
prudent amd reasonable to treat these soils.
The commentors felt that the whole concept of an operable unit was not
supported for this, site. Their reasons are as follows:
Comment:
- Both the U.S. EPA and private parties have taken emergency actions
that were necessary to remove the most imminent hazardous wastes at the
site. There is no authority under the Superfund Act for the agency to
fractionalize response actions at a site in a manner that is wasteful,
duplicative and inefficient.
U.S. EPA's Response:
v
The U.S. EPA would like to clarify the difference between emergency
actions and remedial actions. The emergency actions were taken to
to prevent imminent threats to public health and the environment.
Remedial actions are used in removing threats to public health and the
environment 'which do not require immediate action. This does not mean
that the remedial actions can and should be put off for long periods
of time, but that the risk is not considered imminent and does 'not
justify emergency response action.
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The source removal operable unit falls under the remedial action
category. While there is no immenent risk that requires emergency
action, enough information exists to show that releases of contaminants
from the pits could and most likely have occurred. It would be
inappropriate for the U.S. EPA not to proceed with the operable unit
based on the contaminents known to be present and the threat of a
release of the contaminants. This approach is consistent with 40 CFR
300.68 (c) of the National Contingency Plan.
Conment :
- The agency cannot support its proposed Remedial Action with an
i ncomp l.ete r; sk assesment.
U.S. EPA's'Response:
It is the U.S. EPA's policy that source control operable units do not
require a quantitative risk assessment. As stated in the Guidance o~
Feasibility Studies Under CERCLA, U.S. EPA, June 1985:
;
, .
II At sites where only source control remedial measures are being~
evaluated, a qualitative assessment of the potential public health
th reats in the absence ,of remedi a 1 act i on will genera lly be
conducted. .,
The U.s. E-PA continues to believe a source removal, operation at the
site is prudent.
The U.S. EPA's authority to break the site into operable units, such
as 'this source removal, is clearly stated in the National Contingency
Plan 40 CFR Part 300.68 (c).
II Response actions may be separated into operable units consistent
with achieving a permanent remedy. These operable units may
include removal actions pursuant to 9300.65(b) or remedial actions
involving source controls, and/or management of migration.
,
The U.S. EPA feels that the operable unit is an efficient and practical
method of dealing with complex sites such as the Laskin/Poplar Oil site.
The commentors had comments regarding the permitting of on-site
incinerators at CERCLA site. These connents are listed below.
Conment:
- The Phased Feasibility Study needs to reflect that additional testing
(test burn) of the incineration unit will be required to confirm the
use of this technology for site remediation.
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G
"
u.s. EPA's Response:
A test burn for the mobile incineration will be conducted prior to the
incineration of any'hazardous waste. The test burn will need to document
the 99.9999% performance standard is achieved.
Comment:
- The issue of whether or not an on-site mobile incinerator may legally
operate on a CERCLA cleanup site without a RCRA permit in any state
other than Illinois has not been resolved. The resolution depends on
the interpreatation of sections 118(i) a~d (2)(e) of CERCLA as amended
by SARA.
U.S.EPA's Response:
Section 118(i) does not apply to the alternatives chosen. Section 118
was apparently incorporated into SARA in recognition of the fact that
the State of Illinois has aggressively pursued its own program for
on-site incineration, and has aquired its own mobile incinerator. -;
Section 121 (e)'s general tenor is to insure that the often 1engthy_.;
permitting process for on-site remedies, that ordinarily would require
such permits, not delay the start of remediation. By requiring that
such operations nevertheless must meet applicable or relevant and
appropriate requirements of law, Congress has ensured that human
health and environmental protection is~ues, otherwise covered by
permi tt i ng, wi 11 be addressed. " "
The" remai nder of the comments on the remedi ala 1 ternat i ve covered a
variety of topics and &re presented below:
Coment :
- The high lead content of selected sludges makes off-site incineration
an impractical and costly alternative.
U.S. EPA's Response:
"
Off-site incineration was determined to be the most expensive option.
The U.S. EPA agrees that high lead c~ntent of s9me of the sludge could
result in additional costs, and has recomended on-site incineration
as the selected remedy.
Comment:
- For all alternatives, consideration needs to be given to air ~missions
from material handling during the on-site remedial activities.
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u.s. EPA's Response:
All of the options have the possibli1ity of air emissions during material
handling. Actions, such as conditioning the waste in the pits, will be
taken minimize any air releases. Air monitoring will be used to assure
that dir releases are kept at an acceptable level.
Comment:
- Air quality monitoring and air pollution controls should be added to
the cost estimates.
u.s. EPA's Response:
Air ~ollution control systems are part of the incinerator units and are
included in the cost estimates. The cost of monitoring during the test
burn and the continuous monitoring of the incinerator during the clean-
up is also included. Air quality monitoring would need to be used for
each alternative that involved moving or conditioning the waste. Thi~
cost would be similar for each alternative and therefore would not ef~
feet their relative costs. .~
Comment:
- On pages 68-71, landfill co~t~ were listed as $3.75/ton, but should
be $150/ton.
u.s. EPA's R~ponse:
The U.S. EPA agrees that the wrong price/ton was given. However, the
total dollar amount given is correct and the overall estimates do not
change.
Comment:
- On page 71 disposal costs for 6,435 tons of 5011 and ash are $965,250
at $150/ton. The cost of off-site wastewater treatment is $140,000
based on 350,000 gal and $.40/ga1. The line item for oil was omitted
($15,000, 30 tons, $150/ton).
U.S. EPA's Response:
~
The cost breakdown did accidentally merge information from the disposal
of soils and ash with information from the disposal of wastewater. The
commentor is correct that disposal cost for soils and ash should be
$140,000. Oil was included in the 3500 tons of high level waste to be
incinerated. The final cost should be $5,714,418 as opposed to
$5,724~418.
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lJ
Comment:
- U.S. EPA has improperly rejected certain remedial alternatives and
.failed to consider others. The U.S. EPA has failed to perform a com-
plete evaluation of all reasonable alternatives. For example:
a. Could the ash be disposed of on-site?
b. Could the ash be chemically fixated and disposed of on-site?
c. Could the low level source soils be disposed of on-site?'
d. Could soil washing be used?
e. How quickly could an on-site disposal unit be constructed?
U.S. EPA's Response:
The U.S. EPA has met its requirements of comparing remedial actions
ranging from no action through complete destruction. Some options -
were ruled out prior to the Phased Feasibility Study because they were
known to be inappropriate or infeasible. The U.S. EPA and Ohio EPA.;
have chosen what they consider a reasonable and appropriate solutio~
It was determined that an on-site disposal un.it for the source removal
could not be constructed, filled, and closed by November 1988 based on
prior experience with past CERCLA remedial actions. The idea of
replacing the clean ash back on site was rejected based on the fear it
could be recontaminated, resulting in the extra cost of remediating the
material twice. The same would be true for fixating the ash or soils
and placing them back on site.
Comment:
- The option to landfill soils and non-pumpab1e sludge in Pit 4 should
remain open based on the potential difficulty to incinerate these
materials given low BTU values. The PCB and HOC concentrations are
below land ban limits.
l\
U.s. EPA's Response:
While supplemental fuel will need to' be added,"the U.S. EPA expects no
difficulty in incinerating the soils and non-pumpable sludge in Pit 4.
Soi1s are routinely incinerated in PCB cleanups. The PAHs and VOCs are
also effectively treated by incineration. The issue is not the com-
bustibility of the soil but the destructability of the hazardous con-
stituents present.
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Conrnent :
- Given the high ash content (80%), a large volume will remain after
incineration which would be 1andfi11ed off site as a hazardous waste.
The cost for 1andfi11ing the unpumpab1e sludge in Pit #4 and the soils
is approximately $2.5 million less than incinerating these materials
combined with 1andfi11ing the ash.
U.S. EPA's Response:
The U.S. EPA agrees that the estimated cost difference between the two
options is approximately $2.5 million. The complete incineration option
was chosen over a combination of 1andfi11ing and incineration for two
reasons~ The first reason was that the total incineration option was
considered ~ore protective of public health and the environment. The
long-term dependability of any landfill is unknown. This has been
supported by the difficulty of current facilities in meeting the U.S.
EPA's Off-site Policy. The second reason was the goal of SARA to use
permanent treatment technologies to the greatest extent practicable. -
With the mobile incinerator on site, it is clearly practicable to treat
the additional material. .,:
~
While the current estimated difference between these two options is
$2.5 million, the actual difference could be much lower. This is tr~e
for two reasons. The first reason is that the soils which are in con-
tact with the cinder block walls and unlined bottoms 'of the pits are
believed to have contaminant levels similar to the sludges and oil and
therefore would need to be incinerated under either option. The second
reason is that much of the ash may pass the necessary tests which would
enable it to be disposed of in a sanitary landfill.
Conrnent:
- Considering the quantity of ash generated, the volume reduction from
incineration is not significant.
u.s. EPA's Response:
The goal of SARA is to reduce toxicity, mobility, or volume. By
incinerating the soils and non-pumpable sludge i~ ~t 4, toxicity is
reduced significantly and volume is decreased by approximately 20%.
MObility is also addressed by eliminating the majority of the
hazardous constituents and the most mobile constituents.
Conunents:
- What ARARs were considered in weighing various alternatives.
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"
u.s. EPA's Response:
The ARARs ~onsidered in weighing the various alternatives included the
Resource Conservation and Reclamation Act (RCRA), the Toxic Substances
Control Act (TSCA), the Clean Water Act (CWA), the Clean Air Act (CAA),
Chapters 3704, 3734, of the Ohio Revised Code (ORC) Section 3745-15, 17,
18, and 21 as well as 50 through 69 OAC dealing with air and water
contamination and Chapter 3745-31 of the ORC dealing with untertaking 'a
solid waste disposal facility.
C.
Time Limits
The commentors expressed concern regarding the length of the public
commen~ period and the time period for producing a good faith offer.
The specifi,c comments are dealt with below:
Comment:
- No notice of the draft FS was received prior to the PRP notice lett,r
dated August 18, 1987 and postmarked August 21, 1987. EPA's failure.to
allow adequate, reasonable, and meaningful opportunities in which to ~
comment is contrary to public participation provisions.
U.S. EPA's Response:
The public comment period must last a minimum of 21 days as specified
under the National Contingency Plan. A 21-day comment period for the
site was established from August 10, 1987 to August 31, 1987 by the
placing of an announcement in the local paper on August 4, 1987. In
addition to this announcement, the special notice letters were sent
to the PRPs.
Requests were made by various PRPs for an extension of the comment
period. An extension was granted by U.S. EPA to September 11, 1987.
This allowed 21 days from the actual mailing of the notice letters and
32 days overall.
Also, this action is one in a series of activities that have been taken
related to this site. The PRPs have been aware that a PFS was in
preparation and that their own study,. undertaken in response to an EPA
, Administrative Order, would in part be the basis for the the PFS. The
U.S. EPA feels adequate time was provided for review of and comment on
the PFS.
Comment:
- The Agency did not provide complete copies of the study with the
notice of letters. Only selected excerpts were sent.
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u.s. EPA's Response:
Complete copies of the report were sent out to the members of the
steering commitee which had been established by the PRPs in existing
litigation on past costs. In addition, complete copies of, the PFS
were placed in the Information Repositories located in Jefferson and
Ashtabula, Ohio, and at the U.S. EPA Region V office, located in Chicago,
11. It would not have been feasible to provide complete copies of the
report to each of the more than 300 PRPs involved with the site who
received special notices.
Corranent:
- At th-e PRP meeting on September 4 in Cleveland, EPA announced that
the deadline for good faith proposals to perform the next phase of work
would end on October 23, 1987. Becasuse the EPA will not announce its
final decision until the end of the September, after considering pUblic
comment, there is an objection to the triggering of the 60-day dead1i~e
under the CERCLA Section 122 "special notice" procedures. ..
.
U.S.EPA's Response:
. .
~
The U.S. EPA is currently developing guidance on the timing of the.
issuance of "Special Notice" letters. While there are'severa1 possible
approaches, the present procedure being followed is to initiate the 60
day moratorium/period of negotiation concurrent with the public comment
period and Record of Decision 'review and approval process. The advantage
of this approach is the oppurtunity it provides PRPs to get involved in
the alternative evaluation process through the submission of formal
cOlTlllents.
D.
Funding
Convnent :
- PRP liability for cost incurred should be allocated in accordance
with the degree to which parties contributed substances to which EPA
may legally respond under CERCLA not on volume of oil disposed of. .
U.S. EPA's Response:
The question of liability is not a factor in the choice of remediation
action and will not be dealt with in this responsiveness summary.
. Comment:
- Section 104 of the Superfund Act requires that States assume a share
of the costs of Remedial activity. The PFS does not indicate whether
or not this requirement has been satisfied.
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D
u.s. EPA's Response:
The issue of State share was not discussed in the PFS because it had no
bearing on the feasibility or effectiveness of the alternatives.
The State is responsible for 10% of the remedial actions capital cost
and 10% of the first years operation and maintenence (O&M). All
subsequent O&M would be funded by the state. The State of Ohio concurs
with the U.S. EPA's choice of source removal and will fund its cost
share.
E.
General
Comm~nt:
- The maps on pages 6 and 31 should have the pits numbered in increasing
order from right to left.
U.S. EPA's Response:
.. :.4
;
The pits should be numbered in increasing order from right to left.:
L
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