&EPA
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP AlRODJR05-931226
December 1992
PB94-964115 ----
Superfund
Record of Decis'ion:
MacGiliis & Gibbs/
Bell Lumber & Pole, MN
".-- -
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia I PA 19107
EP A Report Collection
Information Resourrce Center
US EP A Region S
Philad~11?hia, PA 1l91~'1
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50272-101
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R05-93/226
~
3. R8c1pIent'8 AĞ_1on No.
4.
TItI8 and Subtitle
SUPERFUND RECORD OF DECISION
MacGillis & Gibbs/Bell Lumber
Second Remedial Action
Author(8)
5.
R8por1 Date
12/31/92
& Pole, MN
Ii
7.
a.
Performing Organization Rep. No.
9.
Performing Organization Name and Address
10 Project TaaklWortc Unit No.
11. Con1ract(C) or GraJt(G) No.
te)
(G)
12. SponaĞlng Organization Name and Addr888
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report .. P8rtocI Ccw8I8CI
Agency
800/800
14.
15. Suppl8m8nlary Not.
PB94-964115
16. Abstract (Umlt: 200 words)
The MacGillis & Gibbs/Bell Lumber & Pole site, is part of a 24-acre active wood
preserving site located in New Brighton, Ramsey County, Minnesota. Land use in the
area is predominantly industrial, with a private residential area to the north and a
railroad to the west. In addition, the site overlies four ground water aquifers:, the
New Brighton surficial aquifer, the Hillside Sand Aquifer, and the bedrock aquifers. In
1918, MacGillis & Gibbs began operations as a storage yard for wood poles. In the late
1920s, onsite wood preservation operations'began, which involved dipping wood into a
PAR-based solution. In the late 1940s, the company converted its wood preservation
process to use a fuel oil and PCP solution, but discontinued this process in 1960. In
1968, the company again modified the treatment process to use a PCP oil mixture, which
resulted in a substantial increase in the volume of process wastewater. It is
suspected that the PCP-contaminated wastewater from the treatment process was
discharged directly into the disposal pit area. Prior to 1968, MacGillis & Gibbs also
placed an estimated 15,000 yd3 of treated and untreated wood, asphalt, concrete, and
PCP process waste'into the disposal pit, and covered it with clean soil to a depth of
1-2 feet. In 1970, the company began phasing out the use of PCP in its operations, and
introduced a chromated copper arsenate (CCA) pressure treating process, which is
(See Attached Page)
17. Document Analyala L Dascriptors
Record of Decision - MacGillis & Gibbs/Bell Lumber & Pole, MN
Second Remedial Action
Contaminated Media: soil, sediment, debris, surface water
Key Contaminants: organics (PARs, phenols), metals (arsenic, chromium)
b.
1d8nt11le1'8lOpan-End8d Tarms
c.
COSATI FI8J~roup
18. Availability Statement
19. Security Class (This Report)
None
3). Security Class (This Page)
None
21. No. of Pa..
44
22. PrIc8
(Sea ANSI-Z3I.18)
s.. InIItlUClioM 011 R.,,-
OPTIONAL FORM 272 (4-77)
=:'" NTJS.35)
manI of Commerce
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EPA/ROD/R05-93/226
MacGillis & Gibbs/Bell Lumber & Pole, MN
Second Remedial Action
c
Abstract (Continued)
currently being used. However, when the collected process solution was recycled back into
the CCA wood treatment system, some of this CCA solution ran off into the surrounding soil
and was transported to other areas by fork lifts. As a result of a spill of 4,000-5,000
gallons of the CCA solution near the process area, a number of investigations were
conducted by the PRP to assess the extent of contamination from wood preserving chemicals.
These studies revealed elevated levels of chromium, arsenic, and PCP in the onsite soil
and ground water. The studies further determined that the source of this contamination
was a result of various events, including run-off occurring since 1946 from the treatment
tanks area when PCP was first used; liquids discharged into the disposal pit area since
1946 that were collected by a sump underneath the treating tanks; and improper disposal of
contaminated debris in the disposal pit area. In 1987, EPA required MacGillis & Gibbs to
overpack and store 200 drums containing PCP-contaminated soil and waste. In 1988, EPA
initiated pilot studies of a soil washing system and a mobile biological ground water
treatment system designed to remove PCP and PAHs from the soil and water. A 1991 ROD
addressed abando~ed PCP process storage tanks and the LNAPL contamination plume beneath
the former PCP process areas, as OU2. This ROD addresses the contaminated soil, sediment,
debris, and waste material in the disposal pit area, as OU1. A future ROD will address
any remaining soil, debris, ground water, and surface water contamination, as OU3. The
primary contaminants of concern affecting the soil, sediment, debris, and surface water
are organics, including PAHs and phenols; and metals, including arsenic and chromium.
The selected remedial action for this site includes excavating contaminated soil,
sediment, and debris to a depth of approximately 10 feet, with dewatering of soil and the
disposal area pond; separating, rinsing, and landfilling or recycling non-burnable debris;
incinerating wood debris onsite; treating and/or disposing of residual bottom ash onsite
or offsite; treating fly ash using solidification/stabilization, then disposing of the.
solidified materia~ offsite; treating and disposing of contaminated soil onsite using soil
washing to separate sandy soil from fine-grained soil; treating contaminated fine-grained
soil onsite using bioremediation, incineration, and/or solidification/ stabilization based
on TCLP testing; backfilling the treated soil onsite in the disposal area; discharging
wastewater from soil washing, rinsing, and dewatering processes to a POTW offsite, with
onsite pre-treatment of wastewater, if necessary, using chemical precipitation, ion
exchange/ion absorption, biological treatment, reverse osmosis, or carbon adsorption;
conducting treatability tests to determine the effectiveness of each remediation process,
and final disposal alternatives for remaining residuals; and providing a contingency for
onsite incineration of contaminated soil and wood debris, if treatability studies
determine that soil washing will not meet remediation levels. The estimated total cost
for this remedial action ranges from $9,826,250 to $17,579,375.
PERFORMANCE STANDARDS OR GOALS:
Soil, sediment, and debris cleanup goals will be established during the predesign phase to
meet health-based levels. Chemical-specific soil cleanup goals also will be set so that
SDWA MCLs for ground water can be achieved. .
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MACGILLIS AND GIBBS CO. I BBLL LUMBER. POLE CO.
SOURCE CONTROL OPERABLE UNIT 1
DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
MacGillis and Gibbs Co./Bell Lumber & Pole Co. Site
New Brighton, Minnesota
Statement of Basis and purpose
This decision document presents the selected remedial actions for
the Disposal Pit Area Operable Unit (DPA-OU) on the MacGillis and
Gibbs Co. portion of the site, 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), and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).
This decision is based upon the administrative record for the
DPA-OU.
The United States Environmental Protection Agency (EPA) and the
state of Minnesota agree on the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from the
DPA-OU of the MacGillis and Gibbs Co. portion of the site, if not
addressed by implementing the response actions selected in this
Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of Remedy
The objectives of the response actions approved for the DPA-OU
are to protect public health, welfare and the environment and to
comply with applicable federal and state laws.
The MacGillis and Gibbs Co. portion of the site is separated into
three operable units, the first designated for state-lead
activities, the second two for federal-lead activities. operable
Unit 1 (DPA-OU) is defined as the waste material, debris,
contaminated soils and sediments in the disposal pit area.
Operable Unit 2 consists of abandoned pentachlorophenol (PCP)
process storage tanks and the light non-aqueous phase liquid
(LNAPL) plume beneath the former PCP process area. Operable Unit
3 consists of the soils, surface water and ground water beneath
the Site which are not included in Operable Units 1 or 2, or in a
concurrent response action being taken pursuant to a consent
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agreement between Bell Lumber & Pole and the Sta~e of Minnesota.
This remedy addresses only Operable Unit 1 (DPA-OU). The remedy
will eliminate the spread of PCP, polynuclear aromatic
hydrocarbons (PARs), chromium and arsenic into the ground water
from the disposal pit area. In addition, removal of the surface
soils will eliminate the direct contact threat to humans.
The major components of the selected remedy include:
10.
11.
l.
2 .
Fencing of the disposal area.
Excavation of soil and debris to an approximate depth
of 10 feet (or until no more debris or contaminated
soil is found) within the perimeter of the disposal
area. Excavation work will include dewatering of soils
and the disposal area pond;
Separation of non-burnable debris, wood debris, and
soils;
Rinsing and landfilling or recycling of non-burnable
debris (concrete blocks, empty barrels, metal
strapping, etc.);
Drying and incineration of wood debris;
Treatment and/or disposal of bottom ash in a landfill
or on-site.
Treatment and disposal of fly ash in a landfill;
Soil washing of contaminated soils and separation of
sandy soils from the fine-grained soils;
Treatment of contaminated fine-grained soils through
bioremediation, incineration, and/or solidification/
stabilization;
Backfilling of treated soils in the disposal area
excavation.
Discharge (and possible treatment) of soil washing
effluent, rinse water from non-burnable debris, and
water from the dewatering operation to the Publicly
Owned Treatment Works (POTW);
3.
4 .
5.
6.
7.
8.
9.
Treatability studies will be performed on the selected remedial
actions (soil washing, water pretreatment system, bioremediation,
solidification/stabilization) to determine their effectiveness.
If treatability studies for soil washing indicate that this
technology would not be effective, a contingency remedy of
incineration of all contaminated material (See Alternative 2 in
the attached ROD Decision Summary) may then be implemented.
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Statutory Determinations
~he selecced =emedy and che concingency remedy would be
proceccive of human healch and che environmenc, comply wich
federal and scace requiremencs chac are legally applicable or
relevanc and appropriace co che remedial accion, and would be
cosc-effeccive. This remedy ucilizes permanent solucions and
alcernacive c=eatment (or resource recovery) cechnologies co che
maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principle elemenc.
fa-d)'. /tIdJ'
,. Valdas v. Adamkus
~Regional Administrator
{ EPA, Region V
AI?-#tlc~ .I/. Iff 2/
Date - )
k0~.~i~~
/U- MPCA Commissioner
rz,!Zf(ffl:-
Date
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DECISION SUMMARY FOR THE RECORD OF DECISION
MACGILLIS AND GIBBS CO./BELL LUMBER & POLE CO.
SOURCE CONTROL OPERABLE UNIT
I.
SITE NAME, LOCATION, AND DESCRIPTION
The MacGillis and Gibbs Co./Bell Lumber and Pole Co. National
Priority List (NPL) Site consists of two adjacently located wood
preserving facilities. The Bell Lumber and Pole Co. facility is
located on the western portion of the Site and the MacGillis and
Gibbs Co. facility is on the eastern portion of the Site (See
Figure 1). Each of these facilities has been involved in wood
preserving activities since the 1920s, and both are still active
today. The MacGillis and Gibbs Co. facility and the Bell Lumber
and Pole Co. facility were included as one site on the NPL
because of their adjacent locations and similarities of processes
and contaminants.
The MacGillis and Gibbs Co. portion of the MacGillis & Gibbs
Co./Bell Lumber and Pole Site Co. will be referred to as "the
Site" in the remainder of this Record of Decision (ROD). However,
the MacGillis & Gibbs and Bell Lumber & Pole Co. properties are
listed on the NPL as a single site, and EPA regards them as a
single site for enforcement purposes. Similarly, the disposal pit
area which is Operable Unit 1 of the Site will be referred to as
"DPA-QU". The Site encompasses 24 acres in the SE 1/4 of Section
29, Township 30 North, Range 23 West, Ramsey County, Minnesota.
The Site is located at 440 5th Avenue NW in the city of New
Brighton. It is bounded to the east by 5th Avenue NW, to the
south by 1st Street, to the north by private residential land,
and to the west by the Minnesota Transfer Railroad and Bell
Lumber and Pole Company (Figure 1).
This ROD addresses the disposal pit area (called the Soil
Disposal Area in the Focused Feasibility Study (FFS) conducted by
Malcolm Pirnie, Inc.) in the west-central portion of the Site
(Figure 2). Elevations across the Site range from approximately
906 feet to 920 feet above mean sea level and generally slopes
toward the 'south and east. The disposal area was initially a
topographic depression subsequently filled with scrap posts and
poles, wood chips, settled solids, and spent treatment solutions
from the pentachlorophenol (PCP) process. The southwest corner
of the soil disposal area is ponded year-round. A pipeline in an
easement ownec: and operated by Williams Pipeline Company of
Tulsa, Oklahoma passes through the disposal area. The
contaminated soils in the disposal pit area are a continuing
source of contamination to the underlying ground water.
According to Twin City Testing corporation's (TCT) November 1985
Site Evaluation Report, the area geology consists primarily of
three unconsolidated stratigraphic units and two bedrock units
which underlie the Site. In descending stratigraphic order, the
unconsolidated unit includes the New Brighton Formation (silty,
fine to medium-grained sands with intermediate and laterally
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discontinuous silt and sand lenses), the Twin Cities Till
Formatio~ (silty to sandy clay till with silt and sand lenses) ,
and the Hillside Sand Unit (medium t~ coarse-grained pebbly sand
with local cobble zones). The bedrock unit includes the St.
Peter Sandstone Formation (friable sandstone with a shaley layer
near the bottom) and the Prairie du Chien Formation (dolomite
with some local sandstone). These stratigraphic units are
illustrated in Figure 3. The ground water aquifers beneath the
Site are, in descending order: the surficial aquifer, in which
the water table occurs at a depth of 10 to 20 feet below ground;
the Hillside Sand Aquifer which is separated from the surficial
aquifer by the Twin Cities Till Formation which acts as a barrier
and inhibits downward flow of ground water from the surficial
aquifer; and the bedrock aquifers, the St. Peter and Prairie du
Chien.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Portions of the following Site history are excerpted from TCT
February 17, 1987, Remedial Investigation (RI) Report, Ecology
and Environment's August 29, 1991, Focused Feasibility Study
Report, and Malcolm Pirnie, Inc.'s (Malcolm Pirnie) Focused
Feasibility Study Report, which the Minnesota Pollution Control
Agency (MPCA) approved with modifications on April 20, 1992.
This Site history section includes background infon~tion on the
MacGillis & Gibbs Co. facility and focuses specifically on the
DPA-OU, the subject of this ROD.
MacGillis and Gibbs Co. began operations in approximately 1918 as
a storage yard for wood poles, and began wood preservation
operations in the late 1920s. The wood treating process
initially involved dipping the "butt" ends of wood poles (the
section of the pole inserted into the ground) into steel dip
tanks that contained hot creosote solution. Creosote is a
coal-tar distillate composed chiefly of polynuclear aromatic
hydrocarbons (PARs). After the poles were removed from the
solution, they were drained and air dried. -The company converted
its wood preservation process in the late 1940s to a solution
that consisted of five percent PCP in a provoline 4-A fuel oil
mixture. The process was also expanded to treat the entire wood
pole with the installation of longer rectangular dip tanks that
replaced the original square-shaped butt tanks. The new ~anks
contained approximately 10 times the process treatment volumes of
previously used tanks. The creosote treatment process was
reduced to one creosote process treatment tank by about 1950, and
was discontinued prior to 1960.
In 1968, the company again modified its treatment process by
substituting a PCP/P-9 oil mixture for the solution that
consisted of PCP/provoline 4-A mixture. This substitution is
significant because the new PCP/P-9 solution was lighter than
water, thereby trapping the water extracted from the treated wood
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in the process solution, resulting in a substantial ~ncrease i~
the volume of process wastewater. The PCP/Provoline 4-A solution
used in the earlier process is denser than water; therefore most
of the water extracted during wood treatment with the
PCP/Provoline 4-A escaped as steam. It is suspected that the PCP
contaminated wastewater from the treatment process was discharged
to the disposal pit area located in the west-central portion of
the MacGillis and Gibbs facility. A discharge pipe originating
from the former PCP process area runs into the DPA-OU, and is
reported to have been used during the process operation.
Prior to 1974, MacGillis and Gibbs Co. used an undocumented
amount of process PCP waste for weed control on the property.
The remaining waste was apportioned to waste haulers who'disposed
of it in local landfills. The MPCA terminated this practice in
1974, and MacGillis and Gibbs Co. began transporting the process
waste to Illinois landfills. In 1982, 10,000 gallons of tank
cleaning wastes were transported and disposed of in Texas. The
remaining PCP and oil from processing have been removed, and the
materials are now stored in drums on the Site.
In 1970, the company began phasing out the use of PCP in its wood
preservation operations and introduced a chromated copper
arsenate (CCA) pressure treating process for the treatment ~f
both poles and lumber. This process remains in operation today at
the MacGillis and Gibbs Co. facility. According to TCT, the
current CCA solution consists of 22.4 percent chromic acid, 8.6
percent cupric oxide, 19 percent arsenic pentoxide, and 50
percent inert ingredients. No process wastewater is generated
from the CCA treatment operation. MacGillis and Gibbs Co. has
installed a concrete pad and recovery system to collect process
solution which has not been absorbed by the lumber, during the
drying process. The collected process solution is recycled back
into the CCA wood treatment system. The concrete pad, however,
does not include curbing, and some process solution does run off
the concrete pad onto the surrounding soil. Also, some lumber
still dripping with solution is stacked on the ground around the
concrete pad rather than on it, and fork lifts moving lumber on
and off the concrete pad also transport CCA solution on their
treads to other areas on the Site. The MPCAl.s Hazardous Waste
Regulatory compliance Section is working with MacGillis and Gibbs
Co. to further improve their operations.
Prior to 1968, MacGillis and Gibbs Co. placed an estimated 15,000
cubic yards of treated and untreated poles and posts, untreated
wood shavings and chips, asphalt, concrete and approximately
three cubic yards of processed PCP waste into the disposal pit
area. In 1968, the wastes were covered with 5,000 cubic ~'~rds of
clean soil to a depth of one to two feet. TCT estimated in their
1987 RI Report that approximately 30,000 cubic yards of
contaminated soils and debris are located in the disposal pit
area to a depth of about ten feet. According to TCT's 1987 RI
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Report, steel drums used to handle CCA solution may have been
buried in the southeast corner of the disposal pit area between
1970 and 1973.
The MacGillis and Gibbs Co. facility has been the subject of a
number of investigations that were initiated in 1979 after
approximately 4,000 to 5,000 gallons of CCA solution were spilled
near the process area. To determine the impact of the spill,
MacGillis and Gibbs Co. retained Soil Exploration Company (SEC)
to conduct soil borings, place monitoring wells, and collect soil
and ground water samples. Chromium and/or arsenic were detected
in three of the four wells sampled.
SERCO Laboratories, Inc. (SERCO), conducted investigations at the
MacGillis and Gibbs Co. facility in 1979 and 1981 to assess the
extent of migration of wood preserving chemicals from the
disposal pit area. Subsurface soil samples from the disposal area
contained various fill debris and indicated the presence of PCP
and other phenolic compounds. Two samples collected from shallow
borings in the disposal pit area indicated the presence of oily
material and exhibited a kerosene-like odor (SERCO 1981). The
SERCO report also stated that PCP sludge had reportedly been used
extensively for on-site weed control. Analysis of ground water
samples collected during the initial SERCO investigation
indicated the presence of PCP and other phenolic compounds, PAHs,
chromium, and arsenic in at least one monitoring well.
In 1982, SERCO installed 11 new monitoring wells to supplement
the ground water quality database and to provide additional
monitoring locations to evaluate site hydrogeology and ground
water flow patterns. A majority of the ground water samples from
these wells contained PCP at elevated concentrations. SERCO made
the following conclusions based on the results of this.
investigation (SERCO 1983) :
The disposal pit area is a local recharge area for ground
water that is located near the surface. This water flows
radially away from the disposal pit area.
The majority of contaminants detected in ground water and
soil samples taken from the Site appear to be in the
disposal pit area.
PCP and PAHs were identified in samples collected from
shallow wells west of the disposal pit area; ground water
in this area is moving in a southwesterly direction
toward County Ditch 2.
All hazardous waste sites in the state of Minnesota are ranked by
priority. The ranking is done in accordance with criteria
prescribed by the U.S. Environmental Protection Agency (EPA),
called the Hazard Ranking Score (HRS) System. After being
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scored, a siee may be included on ehe Minnesoea permanene Lise of
Priorieies (PLP) and/or included en the federal NPL. A 20re of
28.5 or more is required to be listed on ehe NPL. The MacGillis
and Gibbs Co. Site was added to ehe PLP in October 1984 with a
current ERS of 48. The EPA listed the MacGillis and Gibbs Co.
Site and the adjacent Bell Lumber and pole Co. Site as Qne site
when they were added to the NPL in September 1984 with an HRS of
48.
In 1984, Waste Reduction, Inc. (WRI), performed an evaluation of
conditions at the MacGillis and Gibbs Co. facility and prepared a
letter report for submittal to the MPCA on behalf of the
MacGillis and Gibbs Company. The report was developed in
response to MPCA's inquiries concerning the company's disposal
practices. The report also addressed the environmental impact
resulting from fill material and process waste placed in the
disposal pit area. WRI excavated a series of trenches in and
around the disposal pit area, reviewed reports from previous
investigations, and interviewed long-term MacGillis and Gibbs Co.
employees to collect information for the response report. WRI
concluded that separate fill activities occurred on the
west-central portion of the MacGillis and Gibbs Co. facility as
well as the Bell pole Co. property immediately adjacent and south
of the MacGillis and Gibbs Co. property line. The fill area
straddling these properties was reclaimed using scrap posts and
poles, wood shavings, wood chips, process waste, and clean fill.
The investigations undertaken by WRI have shown that the primary
S0urce of contaminants at the Site, other than the former PCP
process area, appears to be the materials which were deposi:ed in
the disposal pit area. WRI recommended three alternatives for
remediation of the disposal pit area (WRI 1984). The
alternatives included contaminant flushing and in-place closure;
partial excavation and off-site disposal; and complete excavation
and off-site disposal. None of these alternatives were
implemented.
In 1985, the MPCA contracted Twin City Testing (TCT) to perform
an RI at the Site. The on-site investigation for the RI was
completed in June 1986, and the RI Report was submitted in
February 1987. The purpose of the investigation was to evaluate
site hydrogeology and determine the extent of the soil and ground
water contamination in order to develop and evaluate remedial
alternatives. In the RI report, TCT concluded that, among other
things, water in the shallow aquifer below the Site flows to the
northeast; no PARs or phenolic compounds in the ground water
appear to be migrating off site; inorganic soil contamination
appears to be limited to the CCA process area; and ground water
contamination exists at a depth of up to 70 feet. Rega~ding the
disposal pit area, soil samples were collected from depths
between 22.5 and 57.0 feet. The highest concentrations of PARs
(1,092 parts per million (ppm), including both carcinogenic and
non-carcinogenic PARs) and PCP (2,700 ppm) were observed near the
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outfall of the discharge drain corning from the process area. PAR
concentrations 'n the soil were greater to the north and east of .
the disposal pit area and generally decreased with depth for both
PARs and PCP. TCT indicated that the laterally discontinuous peat
lenses w~y control vertical migration of PCP near the southern
end of the disposal pit area. Relatively high PCP concentrations
occurred throughout the debris layer and may have been attributed
to the high hydraulic conductivity associated with the debris
material. TCT identified (by appearance and odor) PCP
contaminated soils below the debris layer confined to coarser
sand and gravel lenses. TCT concluded that elevated PAR levels
may be associated with creosote placed or washed into the
disposal pit area. When creosote is mixed with water, two phases
generally develop, a lighter than water aqueous phase enriched in
phenolics, and a denser hydrocarbon phase enriched in PARs. This
may explain the elevated PAR concentrations near the base of the
debris layer.
In April 1987, PEl Associates, under subcontract to TCT,
submitted a remedial alternatives report to the MPCA. PEl
recommended three possible remedial actions: incineration,
closure of the plant as a hazardous waste site, and placing the
contaminated materials into a storage area until a means of
treatment is developed. The PEl report concluded that ground.
water treatment should be initiated and that further
investigation was required before a more detailed evaluation of
alternatives and costs could be performed.
On December 18, 1987, EPA tasked the Technical Assistance Team
(TAT) contractor to monitor MacGillis and Gibbs' Co. cleanup of
the facility. As part of the TAT oversight, 200 overpacked drums
containing PCP-contaminated soils and waste were staged either on
or adjacent to a containment pad within the PCP process area
constructed for drum storage on the MacGillis and Gibbs Co.
facility. This work was completed by June 15, 1988.
A September 1989 report on TAT activities s!:ated that soil
samples collected in the disposal pit area had a max~um PCP
concentration of 2,700 milligrams per kilogram (mg/kg) at a depth
between six and eight feet. Soil in the PCP process area had
concentrations of PCP up to 1,200 mg/kg at a depth between 4 1/2
to 6 1/2 feet. A layer of oil approximately four to six feet
thick and containing up to 32,000 mg/kg of PCP was identified
floating on the surface of the shallow aquifer in a well (TCT-3S)
at the north end of the PCP process area. A pump was installed
in this well in 1988 to recover oil. Liquids are currently being
pumped from the well at a rate of one to two gallons per minute,
and are temporarily stored in 55-gallon drums adjacent to the
well. A number of drums have been accumulated and are staged on
the concrete pad constructed for drum storage.
In 1988, Biotrol, Inc. initiated pilot tests of a soil washing
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III.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The MPCA held a public meeting in July of 1991 to present
information to the community on plans to test incineration as a
remedy for the MacGillis and Gibbs Co. facility. These tests
were performed in the fall of 1991. Incineration had been a very
sensitive community issue in previous years during investigations
and interim actions taken at these sites. Because incineration
had not been publicly proposed as a response action since 1988,
MPCA sought to ensure adequate notice of this meeting, including
mailing a fact sheet about the proposal and the meeting to the
media and approximately 2,000 households near the Site, using a
mailing list provided by the New Brighton Public Works
Department. only a handful of residents attended, and the
discussion at the meeting was markedly calm in contrast to
meetings in the late 1980s where the topics included
incineration. Residents attending did reiterate a well-known
concern that they do not want the incinerator located on the Bell
Lumber & pole portion of the site to accept wastes from offsite;
that is, the community does not want it to become a permanent
hazardous-waste incineration facility.
MPCA published the proposed Plan for the disposal pit area on
MacGillis and Gibbs portion of the site to solicit public'
comment. The proposed Plan/fact sheet was mailed out in August
1992 to interested members of the public. MPCA issued a news
release about the proposed Plan on July 30, 1992. A notice of
availability of the proposed Plan and announcement of the public
comment period were published in the Star Tribune newspaper on
July 31, 1992. The public comment period extended from August 1
through August 31, 1992.
The MPCA also held a public meeting on August 10, 1992, at 7:00
p.m. at the New Brighton City Hall to present the FFS and the
proposed plan for remediation of the disposal pit area. The
proposed Plan/Fact Sheet and the other documents comprising the
administrative record for the DPA-OU were made available at the
MPCA St. paul office at 520 Lafayette Avenue, which is the
official MPCA repository for this DPA-OU, as it is for most
metropolitan area sites. In addition, the EPA maintains an
information repository for the remaining two operable units of
the MacGillis & Gibbs Co. portion of the site at the ~rden Hills
Library.
only a handful of residents attended the August lOth meeting on
the proposed remedy for the DPA-OU. Although several in the
audience did ac~ questions for clarification, the tone of the
questions primarily indicated peoples' preference that the
overall cleanup of this site be accomplished as quickly as
possible. The mayor of New Brighton did make an offer to the
agencies during the meeting of any help the city could provide in
expediting the cleanup.
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area. Migration of contaminants from the disposal pit area into
underlyi~g groundwater is a primary source of ground water
contamination at the Site.
VI.
SUMMARY OF SITE RISKS
This section qualitatively describes the human health risks posed
by contaminants in the disposal pit area. Based on the historical
findings and on-site groundwater data, which exceed the federal
drinking water standards (maximum contaminant levels, or "MCLs"),
it is determined that remedial action is needed to address the
source of the groundwater contamination. Because this remedy is
a source control operable unit, a final baseline risk assessment
for the Site is not yet available. No quantitative risk numbers
have been calculated for exposure to Site contaminants. However,
qualitative risk information is organized and outlined below to
~emonstrate that action is necessary to stabilize the Site and
prevent the continued degradation of the groundwater. The
baseline risk assessment for the Site will be conducted later
during the final operable unit (OU #3) for the Site.
Contaminants of Concern
Both organic and inorganic contamination has been found in the
DPA-OU. The following four chemicals or chemical classes have
been identified as chemicals of concern at the DPA-OU: arsenic,
chromium, polynuclear aromatic hydrocarbons (PARs) and
pentachlorophenol (PCP). As indicated below, these chemicals of
concern have been detected in on-site groundwater wells at
concentrations above MCLs:
arsenic
chromium
PARs
PCP
Ranqe of Detections
2.0 - 310
7.0 - 5,350
0.003 - 1.80
0.028 - 96,000
(eeb)1r
MCLs (epb)
50.0
100.0
0.2
1.0
1r Source: MacGillis & Gibbs Co./Bell Lumber & Pole Co.
Focused Feasibility Study, August 1991
In. addition, PCP contamination of the soils (2,700 ppm) in the
DPA-OU is well above the 10 ppm cleanup level implemented for the
Bell Lumber and pole Co. portion of the site.
The above contaminants have been identified throughout
investigatory work done at the DPA-OU beginning in 1979. These
contaminants impact the ground water, soil and debris, sediment,
and surface waters on and near the MacGillis and Gibbs Co. DPA-
OU.
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12
and Gibbs Co. :acility. For a more complete analysis qf pocencial
healch risks presenced by the Sice, see che Minnesota Deparcmenc
of Health's 1992 Public Health Assessmenc for the MacG'illis and
Gibbs Company and Bell Lumber and Pole Co. facilicies. The MDH
documenc is scheduled to be finalized in March 1993, and will be
available shorcly thereafcer for review ac the Public Library in
Arden Hills, Minnesota and che St. Paul offices of che MPCA.
Portions of the following review of risks posed by the disposal
pit area are excerpted from the draft MDH reporc. In addition,
as part of its ongoing field invescigation at the remainder of
the Site, U.S.EPA is performing off-site soil sampling (including
road dust sampling) as well as modeling work to determine the
extent of airborne contaminat~~n. The baseline risk assessment
for the Site will be conducced during the final operable unit (OU
#3) .
Municipal drinking water supply wells, which are locaced in
deeper bedrock aquifers, are not impacted by contaminants from
the MacGillis & Gibbs Co. or the Bell Lumber & Pole Co.
facilities, and ingestion of New Brighton's municipal drinking
water does not present a human health concern.
Implementation of the selected remedy as presented by this DPA-OU
will reduce exposure to contaminated soils, sediment, and surface
water; control air emissions; and minimize or reduce contaminant
migration to the groundwater.
VII.
DESCRIP'l'ION OP AL'l'ERNA'l'IVES
The objective of the remedial action to be taken as a result of
this ROD is to reduce soil contamination in the disposal pit
area, and control the spread of contamination from the disposal
pit area into ground water. A Focused Feasibility Study (FFS)
was conducted to develop and evaluate remedial alternatives for
the DPA-OU. Remedial alternatives were assembled from applicable
remedial technology process options and we~e initially evaluated
for effectiveness, implementability and cos~. The alternatives
meeting these criteria were then evaluated and compared to the
nine criteria required by the NCP. The no action alternative
serves pr~rily as a point of comparison for other alternatives.
The five alternatives for the DPA-QU are listed below:
NOTE: A common element of all the alternatives (except
Alternative 1) is washing and landfilling or recycling of
concrete, metal, and other non-burnable debris. All alternatives
would also include dewatering of the groundwater and the surface
water in the disposal area pond, in order to excavate pond
sediments, and soils which are below the groundwater table. The
rinse water as well as the water from the dewatering operation
would be sampled to determine if treatment is needed before
discharging it to the sanitary sewer system for treatment at the
Publicly Owned Treatment Works (POTW). possible treatment options
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:3
include chemical precipitation, ion exchange/ion absorption,
reverse osmosis, carbon adsorption or biological treat~~ ,~.
An additional common element of all the alternatives (exceDt
Alternat~ve 1) is the removal and relocation of :he Williams
Pipeline Company's pipeline facility through the DPA-OU.
Information obtained by MPCA from Williams Pipeline Company in
July 1992, indicates an estimated cost of approximately $315,000
for the line relocation.
Alternative 1 - - No Action.
Under this alternative, EPA/MPCA would take no further action to
reduce contamination in the DPA-QU soils or to con~rol the spread
of contarni~ation from the DPA-OU into the groundwater.
Alternative 2 - - Incineration of all Soils and Wood Debris with
Solidification/Stabilization of Fly Ash and Off-Site Disposal at
a Permitted Landfill of Bottom Ash and Fly Ash.
Incineration of the contaminated soils from the disposal pit area
would be conducted in much the same fashion as the test-burn
conduc~ed in la~e 1991. Prior ~o being transferred to the
incinerator and burned, the contaminated soils would be
preprocessed, which would involve removing non-burnable material,
such as concrete and metal debris, and the remaining material
being screened, ground-up, and dried. The non-burnable debris
would be washed and landfilled or recycled. The incineration
would produce ash residue requiring special handling methods due
to the presence of chromium and arsenic. The ash would be sampled
to determine whether solidification/stabilization would be needed
before the ash is placed in a permitted landfill. Solidification/
stabilization is accomplished by adding a binding or stabilizing
agent to cont~nated soils which immobilizes the contaminants,
thereby rendering the contaminants nonleachable.
Alternative 3 - - Incineration of all Soils-and Wood Debris, Soil
Washing of Bottom Ash, Discharge of Effluent to the Publicly
Owned Treatment Works (POTW), and Solidification/Stabilization
and Landfilling Fly Ash.
Incineration of the contaminated soils would be the same as
described in Alternative 2, as would the solidification!
stabilization of the fly ash followed by landfilling. In this
alternative, the bottom ash produced from the combustion pDOcess
would be washed with large volumes of water, producing a final
product with reduced contamination, and wastewater containing the
majority of contaminants. The bottom ash could then be disposed
of on site, and the wastewater discharged to the POTW. However,
if contaminant concentrations in the wastewater exceed designated
pre-treatment requirements (identified in Section X of this
document), additional treatment would be necessary. These
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14
additional treatments could include chemical precipitation. ion
exchar.ge/ion a~~~rptior.. reverse ~smosis. carbon absorption.
biological treatment or other appropriate treatment. Once the
contaminant levels were reduced to meet the pre-treatment
requirem~nt, the wastewater could be discharged to the POTW.
If the contaminant levels in the washed bottom ash do not meet
the remediation levels specified in Section IX of this ROD, as
well as the Resource, Conservation and Recovery Act (RCRA) Land
Disposal Restrictions (LDR), the bottom ash will need further
treatment'through bioremediation, incineration and/or
solidification/stabilization.
~ternative 4 - - Soil Washing of Screened Soils and Incineration
of Wood Debris.
After separating logs, poles, and other burnable material for
incineration, the soil would be treated by soil washing as
described for bottom ash in Alternative 3. After being washed,
the screened sandy soils would have significantly lower
contaminant concentrations. The decontaminated soils would
continue to be washed until contaminant concentrations are within
remediation levels (identified in Section IX of this document) .
These soils would then be deposited on site. The wastewater
produced by the soil washing process would either be discharged
directly to the POTW or treated prior to discharge through
chemical precipitation, ion exchange/ion absorption, biological
treatment, reverse osmosis, carbon absorption, or some other
appropriate method. The incinerator ash would be handled as
described in Alternative 2. The fine-grained soils separated from
the sandy soil during the soil washing process would be.
remediated through either bioremediation, incineration and/or
solidification/stabilization. .
~tern&tive 5 - -
Wood Debris.
Bioremediation of Soils and Incineration of
Again, wood debris would be separated from the soil for
incineration prior to the soils being treated with
bioremediation. Incinerator ash would be handled as described in
Alternative 2. Treatability studies would be needed to assess the
effectiveness of bioremediation on the soil. Bioremediation has
been shown to be effective in treating the organic contaminants,
but not effective in treating inorganics metals. Once the soils
have been bioremediated, the question of treatment of the metals
would s~ill exist, meaning further treatment by another method.
Because of the complexities and site-specific physical
requirements needed to implement bioremediation successfully, and
the doubts about the short-ter.m and long-term reliability and
effectiveness of bioremediation and whether future additional
remedial actions would be necessary, this alternative is
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15
eliminaced from further consideration.
VIII. SUMMARY,OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternacives are evaluated using the following nine
criteria established by the EPA at 40 CFR 300.430 (e) (9) (iii):
1.
2 .
3 .
4.
Overall Protection of Human Health and the Environment;
addresses whether an alternative provides adequate
protection and describes how risks are eliminated, reduced
or controlled through treatment and engineering controls.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs); addresses whether an alternative
meet all of the ARARs, or provide grounds for invoking
waiver.
will
a
Long-term Effectiveness and Permanence; refers to the
ability of an alternative to maintain reliable protection of
human health and the environment, over time, once cleanup
objectives have been met.
Reduction of Toxicity, Mobility, or Volume; refers to the
anticipated performance of the treatment technologies an
alternative may employ.
5 .
Short-term Effectiveness; involves the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period until cleanup
objectives are achieved.
6.
ImplementabilitYi addresses the technical and administrative
feasibility of an alternativp., including the availability of
goods and services needed to implement the remedy.
7.
Costi includes capital costs, as well as operation and
maintenance costs.
8 .
Agency Acceptance; indicates whether, based on their review,
of the RI, FS and proposed Plan, the MPCA and EPA agree on
the preferred alternative. This criteria will be discussed
in the Selected Remedy section of this document.
9.
Community Acceptance; indicates the public acceptability of
a given alternative. This criterion is discuSSEd i- ~e
Responsiveness summary section of this document.
The following is an analysis of each of the alternatives against
the first seven criteria.
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16
Alternative 1 - - No Action.
The no action alternative would not be protective of human health
or the environment, would not comply with ARARs, would not
provide long-term effectiveness and permanence, and would no~
reduce the toxicity, mobility or volume of the contaminants.
Therefore, the no action alternative will not be further
evaluated.
Alternative 2 - - On-site Incineration of all Soils and Wood
Debris with Solidification/Stabilization of Fly Ash and Off-Site
Disposal at a Permitted Landfill of Bottom Ash and Fly Ash.
This alternative consists of first excavating, screening,
grinding and stockpiling soils from the disposal pit area. It is
estimated that a rotary kiln incinerator would burn the soils at
a rate of approximately four tons per hour. Given that there are
approximately 31,000 cubic yards of soil and debris to remediate
at an approximate weight of 2,900 pounds per cubic yard, 450 days
of continuous, around-the-clock operation would be required to
incinerate the soils. This period would likely be longer due to
needed periodic maintenance shut-downs. Levels of contaminants
in stack emission tests were within acceptable limits, according
to the test-burn emission sampling and analyses.
Bottom ash will contain residual chromium and arsenic
concentrations. The chromium and arsenic levels for the
test-burn bottom ash were 50 to 70 mg/kg and 40 to 60 mg/kg,
respectively. Toxic Characteristic Leaching Procedure (TCLP)
analyses of bottom ash samples indicated extract levels to be
within Land Disposal Restriction (LDR) Standards, which would
allow landfilling of the ash in a permitted Solid Waste Subtitle
D landfill. Additional TCLP testing will be performed to support
this conclusion. Because the fly ash from the test-burn exceeded
the TCLP regulatory limit for arsenic, it is likely that fly ash
from full-scale incineration will require solidification/
stabilization in order to immobilize the ch~omium and arsenic
prior to it being landfilled in a permitted Subtitle C "Hazardous
Waste" landfill. Solidification/stabilization is usually
conducted at the landfill by the operator. A small-scale
treatability study is usually required by the operator to
determine specific design parameters of the solidificcotion/
stabilization process.
1.
OVerall Protection of Human Health and the Environment
This alternat~~'e would minimize the potential for future
long-term human exposure to DPA-OU contaminants by destroying the
organic contaminants (PCP, PARs) through incineration, and
removing the inorganic contaminants (chromium and arsenic) from
the DPA-OU. Removal of contaminated soils from their current
location in the disposal pit area would also reduce migration of
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:7
contaminants to ground water and to surface water.
Short-term human exposure to contaminants may result from dust
generated d~ring excavation. screening. and grinding operations
and from air emissions during the incineration process. These
exposures can be minimized by covering soils as needed. and by
maintaining proper operation of the incinerator. periodically
monitoring air emissions, and taking mitigative measures if
needed.
Protection of human health and the environment is achieved
landfilling of both ash types in permitted landfills.
Stabilization of fly ash further aids in immobilizing
contaminants.
by the
2.
COmDliance with ARARs
Incineration of contaminated soils and landfilling of bottom ash
and fly ash, possibly after solidification/stabilization. is
consistent with RCRA guidelines for hazardous waste management.
The PCP waste at the site is classified under the RCRA program as
a "listed waste", specifically as F032 Wood Preserving Waste.
The incineration of the PCP will meet all RCRA incineration and
Clean Air Act requirements, including a Destruction Removal
Efficiency of 99.99t. The Fly Ash from the incineration process
will comply with the RCRA Land Disposal Restriction Standards
through solidification/ stabilization of the arsenic before
disposal in a Subtitle C RCRA landfill. Analyses performed to
date indicate that bottom ash should be clean enough to put in a
Subtitle D Solid Waste landfill with no further treatment. Water
from the rinsing of nonburnable debris will be tested to
determine if it meets the Metropolitan Waste Control Commission's
(MWCC) pretreatment standards required by the Clean Water Act. If
additional treatment is required to meet pretreatment standards,
possible treatment options would be as noted above.
3 .
Lona-term Effectiveness and Permanence -
This alternative can be classified as a permanent remedial
action. Organic contaminants are destroyed in the incineration
process. The inorganic contaminants, meaning the metals arsenic
and chromium cannot be destroyed, however; they can be .
immobilized. Bottom ash containing low-levels of chromium and
arsenic will be placed in a pe~tted Subtitle D landfill if
metal levels are within LDR standards. Fly ash will be
solidified/stabilized to tmmobilize arsenic and chromium pr~vr to
landfilling. While landfilling is not considered a permanent
remediation of contaminants, it is effective in isolating the
contaminants in a controlled environment, provided the landfill
is properly operated, maintained, and monitored.
During the test burn, levels of contaminants in the stack
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18
emissions were within acceptable limits, and will be monitored
during the incineration process. This alternative does not
require long-term monitoring.
4 .
Reduction of Toxicitv. Mobili:v. or Volume
Incineration destroys the organic contaminants and reduces the
volume of waste containing inorganic contaminants (chromium, and
arsenic) by concentrating them in the ash. Analyses indicates
that the bottom ash will be clean enough to landfill in a
permitted Subtitle D landfill with no further treatment. Fly ash
will require solidification/stabilization to immobilize the
metals prior to disposal. This material, once solidified/
stabilized and after passing TCLP requirements, could be disposed
of in an approved RCRA Subtitle C landfill. Mobility of
contaminants in the fly ash would be significantly reduced,
provided the permitted landfill selected is properly operated and
maintained.
s.
Short-term Effectiveness
This alternative will remove contaminated soil and debris,
thereby removing a continuing source of ground water
contamination. Incineration was shown in the test-burn on
October 31-November 1, 1991 to be extremely effective in
destroying PCP. The minimum required time to implement this
alternative is 450 days.
Dust emissions from the excavation, screening, and grinding of
soils prior to incineration may be produced-especially during dry
and windy conditions. This presents some exposure risks to
on-site workers and possibly to nearby passers-by or residents.
These risks can be limited by covering soils as needed during
preparation processes.
Additional short-term risks may be presented due to air emissions
from the incineration process. These risks-appear minimal as
indicated by the results of the test-burn. Exposure risks can be
minimized by maintaining proper operation of the incinerator,
periodically monitoring stack emissions, and "taking mitigative
measures if needed.
In addition, short-term risks may be present due to loading and
transport of the ash to an off -site permitted landfill. However',
these risks are expected to be minimal due to the limited volume
of ash that will need to be removed from the site.
6.
ImDlementabilitv
This alternative utilizes presently existing and available
technologies and equipment.
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19
7.
Cost
Costs for this alternative are highly dependent of specific
conditions, including the total volume of waste to be
incinerated, volumes of ash requiring off-site disposal, and
actual unit costs of services supplied during a competitive
bidding process. Estimating a volume of contaminated soils of
31,000 cubic yards and using estimated unit prices for
incineration, transportation, and landfill disposal, the total
cost to implement this alternative is estimated between
$15,645,000 and $38,775,000 (Table 1).
Alternative 3 - - On-site Incineration of all Soils and Wood
Debris with Soil Washing of Bottom Ash, Discharge of Effluent to
POTW, and Solidification/Stabilization and Landfilling Fly Ash.
This alternative differs from Alternative 2 in that, if the
bottom ash contains high levels of chromium and arsenic, it would
be washed in order to remove the metals. This way, the washed
bottom ash could be used as fill on site, rather than having to
be landfilled off-site as in Alternative 2.
Washing of the bottom ash would first require a treatability
study to define appropriate design parameters for this process.
Such a study would also provide information regarding the likely
'chemical characteristics of the washed bottom aSh and the
effluent. Depending on the results of the treatability study, the
process wastewater could eith~r be treated and reused in the soil
washing process or treated and discharged to the sanitary sewer.
If discharged to the sanitary sewer, treatment of the wastewater
may be required in order to meet the pretreatment discharge
criteria. Treatment could include chemical precipitation, ion
exchange/ion absorption, biological treatment, reverse osmosis,
carbon absorption, or some other appropriate treatment. The
washed ash may need to be treated further through bioremediation,
incineration and/or solidification/stabilization.
1.
OVerall Protection of Human Health and the Environment
This alternative would minimize the potential for future
long-te~ human exposure to DPA-OU contaminants by destroying the
organic contaminants (PCP, PAHs) through incineration, and
removing the inorganic contaminants
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periodically monitoring air emissions, and taking mitigative
actior.s if needed.
Landfilling fly ash after it has been solidified/stabilized in a
secure landfill provides protection of human health and the
environment. If the treatability study is successful, washing of
the bottom ash would transfer the chromium and arsenic to the
wastewater, which would be disposed of in the sewer system,
provided the contaminant levels meet the POTW pretreatment
standards. If the contaminant levels exceed the pretreatment
standards, the wastewater will first be treated before being
discharged to the sewer. Treatment could include chemical
precipitation, ion exchange/ior absorption, reverse osmosis,
carbon absorption, or some other appropriate treatment. If the
washed ash needs further treatment, bioremediation, incineration
and/or solidification/stabilization may be used.
2.
ComDliance with ARARs
Incineration of contaminated soils and landfilling of
fly ash, possibly after solidification/stabilization, is
consistent with RCRA guidelines for hazardous waste management.
The PCP waste at the site is classified under the RCRA program as
a "listed waste", specifically as F032 Wood Preserving Waste.
The incineration of the PCP will meet all RCRA incineration and
Clean Air Act requirements, including a Destruction Removal
Efficiency of 99.99%. The Fly Ash from the incineration process
will meet the RCRA "Land Ban" treatment standards by
solidification/stabilization of the arsenic before disposal in a
permitted Subtitle C RCRA landfill. The soil washing of bottom
ash should yield a product that will meet the remediation levels
shown in Section IX of this ROD, as well as RCRA LDR standards.
The bottom ash can therefore be disposed of as backfill for the
excavation in the DPA-OU. If these remediation levels are not
met, the bottom ash will need to be treated before disposal
through bioremediation, incineration and/or solidification/
stabilization.
Water from the washing of non-burnable debris, the dewatering
operation, and from the bottom. ash washing process will be tested
to determine if it meets the Metropolitan Waste Control
Commission's pretreatment criteria required by the Clean Water
Act before being discharged to the sanitary sewer system.
3.
Lona-term Effectiveness and Permanence
This alternative provides long-term effectiveness by removing
contaminants from the soil, destroying nearly all organic
contaminants, and isolating fly ash containing chromium and
arsenic in a permitted landfill after the fly ash has been
solidified/stabilized. While landfilling is not considered a
permanent destruction of contaminants, it is effective in
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,-
~solati~g co~taminants i~ a controlled environment. provided t~e
landfill is properly operated, maintained, and monitor~~. Soil
washing of the ash wil"l remove metals contamination from the
majority c: the bottom ash material. Wash water from the soil
washing ~: the bottom ash. as well as the rinse water from
nonburnable debris and water from the dewatering operation
would be treated at the POTW. This alternative is considered
reliable in meeting the specified remediation c~iteria.
4 .
Reduction of Toxicitv. Mobilitv. or Volume
Incineration would destroy the organic contaminants (PCP, PAHs),
and reduce the volume of waste containing inorganic contaminants
(chromium and arsenic) by concentrating them in the ash. The
toxicity, mobility and volume of contaminants in the bottom ash
will be reduced by the soil washing process. The contaminated
wastewater from the soil washing process, if it meets
pretreatment standards, would then be discharged and treated at
the POTW, prior to its discharge to the Mississippi River.
Fly ash would require solidification/stabilization to immobilize
the metals prior to disposal. This material, once solidified/
stabilized and after passing TCLP requirements, could be disposed
of in a permitted RCRA Subtitle C landfill. Mobility of
contaminants in the solidified/stabilized fly ash is
significantly reduced, provided the secure landfill selected is
properly operated and maintained.
5 .
Short-term Effectiveness
This alternative would remove contaminated soil and debris,
thereby removing a continuing source of ground water
contamination. Incineration was shown in the test-burn on
October 31-November 1, 1991 to be extremely effective in
destroying PCP. The minimum required time to implement this
alternative is 450 days.
Dust emissions from the excavation, screening, and grinding of
soils prior to incineration may be produced, especially during
dry and windy conditions. This presents some exposure risks to
on-site workers and possibly to nearby passers-by or residents.
These risks will be limited by covering soils as needed during
preparation processes.
Additional short-term risks may be presented by air emissions
from " the incineration process. These risks appear minimal as
indicated by the results of the test-burn. Exposure risks will
be minimized by maintaining proper operation of the in~inerator,
periodically monitoring stack emissions, and taking mitigative
measures if needed.
In addition, short-term risks may be present due to loading and
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:2
transport of the ash to an off-site permitted landfill. However,
these risks ar~ ~xpected to be mi~irnal due to the limited volume
of ash that will need to be removed from the site.
6.
ImDl~mentabilitv
This alternative utilizes presently existing and available
technologies and equipment. Several vendors are available for
the soil washing process of the bottom ash to provide a
competitive bid. In addition, should this alternative require
additional equipment and specialists, these items should be
available without significant delay. A treatability study would
be required to determine the effectiveness of a soil washing
process to remove metals from the bottom ash, process design
parameters, and effluent characteristics. The equipment and
handling processes needed for this alternative are well-tested
under similar conditions.
7.
~
Should the treatability study indicate that the bottom ash cannot
be disposed of on site due to excessive levels of chromium and/or
arsenic, or that the wastewater effluent will require treatment,
it is likely that the increased cost from these items will render
this alternative not competitive with the others being
considered. The estimated total cost of this alternative is
between $22,561,000 and $63,361,000, assuming additional
treatment of the bottom ash after soil washing (Table 2). This
does not include the cost of possible treatment of the wastewater
before di$charge to the POTW.
~ternative 4 - - Soil Washing of Screened Soils and On-site
Incineration of Wood Debris.
This alternative differs from Alternative 3 in that only the wood
debris would be incinerated on-site, rathe~ than both the soils
and wood debris. The fly ash would be dispased of off-site in a
permitted RCRA Subtitle C Hazardous Waste landfill. Excavation
and screening would be required to separate non-burnable debris
and burnable debris before the soil washing treatment could be
implemented. All contaminated soils would be washed. Soil
washing will remove contaminants from the sandy soils and
concentrate them in the fine grained soils. Prior to initiating
the soil washing, treatability studies would be conducted to
determine the contaminant levels in washed soil and the most
appropriate method for treating the process wastewater effluent
and the contaminated fine grained soils.
It is anticipated that the fine grained soils may be treated
through bioremediation, incineration, and/or solidification/
stabilization before being disposed of in a landfill.
Bioremediation is potentially more feasible in treating the fines
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:han it would be for treating all 0: :he soils as discussed :n
Alternat~ve 5. The fine grained SQils from the soil washing
process will be treated in a slurry phase process rather than a
solid phase as in Alternative 5. Again, bioremediation cannot
treat the metals still contained in the fines, however; the
slurry phase may allow the dissolution of the metals from the
soil particles. If the inorganic (metal) concentrations remain
above acceptable levels after the slurry phase bioremediation, a
solidification/stabilization process could be evaluated to bind
the metals prior to disposal. The solidification process would
only be required for 5000 tons of the fine soils as opposed to
33,500 tons of soil in Alternative 5.
Depending upon the results of the treatability study, the process
water could either be treated and reused in the soil washing
process or treated and discharged to the sanitary sewer. If
discharged to the sanitary sewer, treatment of the wastewater may
be required in order to meet pretreatment discharge criteria.
Treatment could include chemical precipitation, ion exchange/ion
absorption, biological treatment, reverse osmosis, carbon
absorption, or some other appropriate treatment. Bottom ash
would be disposed of in a permitted Subtitle D Solid Waste
Landfill as in Alternative 2 .
1.
Overall Protection of Human Health and the Environment
This alternative minimizes the potential for future long-term
human exposure to contaminated soil by removing the contaminants
from the soil. The removal of contaminants from the soil will
also result in a reduction in migration of the contaminants to
the ground water and surface water.
As in Alternatives 2 and 3, short-term human exposure may result
from dust generated during excavation, screening, and grinding
operations, and from air emissions during the incineration
process. These exposures can be minimized by covering soils as
needed, and maintaining proper operations of the incinerator,
periodically monitoring air emissions, and taking mitigative
action, if needed.
The inorganic contaminants remaining in the bottom ash and fly
ash will be placed in a secure landfill, thus reducing potential
for human exposure. Solidification/stabilization, if implemented
as a further treatment of the ash, would further immobilize the
inorganic contaminants.
Washing of the contaminated soil would transfer contaminants into
the wastewater and fine-grained soils. The wastewater may be
disposed of in the sewer system, provided the contaminant levels
meet POTW pretreatment. standards. If contaminant levels are too
high, the wastewater will first be treated before being
discharged to the sewer. Treatment could include chemical
-------
24
precipitation, ion exchange/ion absorption, ~everse osmosis,
carbon ab~orption, biological trea~ment, or some other
appropriate treatment. The fine-grained soil may be treated
:hrough bioremediation, incineration, and/or solidification/
stabilization.
2 .
ComDliance with ARARs
Based on information available from other similar sites, soil
washing will reduce contaminant levels to meet remediation levels
described in Section IX of this ROD, as well as RCRA Land
Disposal Restriction (LDR) standards. Water from the washing of
non-burnable debris, the dewatering operation and from the soil
washing process will be tested to deter.mine if it meets the
Metropolitan Waste Control commission's pretreatment standards
required by the Clean Water Act before being discharged to the
sanitary sewer system. Incineration of the wood debris will be
done in accordance with applicable RCRA. incineration and Clean
Air Act requirements. As in the case of Alternative 2, disposal
of fly ash and bottom ash will be conducted in accordance with
RCRA LDR standards.
3 .
Long-term Effectiveness and Permanence
This alternative provides long-term effectiveness by removing "the
contaminants from the soil. Incineration of burnable debris will
destroy organic contaminants. Soil washing transfers the
contamination from the sandy soils to the wash effluent and the
fine-grained soils. 50il washing techniques have achieved over
90 percent reduction efficiency for organics, and between 50 and
80 percent reduction efficiency for metals. If the washed soils
meet the health based remediation levels specified in Section IX
of this ROD, they will be placed on-site. The wastewater, if it
meets POTW pretreatment standards would then be discharged to the
sewer system, where it would be treated by the Metropolitan Waste
control. Commission's treatment works prior .to discharge to the
Mississippi River.
While landfilling of ash and possibly the soil fines is not
considered permanent remediation of contaminants, it is effective
in isolating contaminants in a controlled environment, provided
the landfill is properly operated, maintained and monitored.
This alternative should not require future additional remedial
action.
4.
Reduction
of Toxicity. Mobilitv. or Volume
Incineration destroys the organic contaminant (PCP, PAHs), and
reduces the volume of waste containing inorganic contaminants
(chromium and arsenic) by concentrating them in the ash. Bottom
ash and fly ash will be disposed of in a permitted off-site
landfill. Because of the amount of inorganic contaminants, the
-------
2S
fly ash may require solidification/stabilization 'prior ta
disposal in the landfill. Additio~al ~esting will be conducted to
confirm the accuracy of current testing which indicate that
bottom ash ~ould be disposed of in a solid waste landfill with no
further treatment. Mobility of contaminants in the ash is
significantly reduced, provided the secure landfill selected is
properly operated and maintained.
Soil washing will reduce the volume, mobility and toxicity of the
treated soil. The contamination from the soil washing process
will be concentrated in the fine grained soils and the effluent
wastewater. The effluent wastewater, if it meets pretreatment
standards, would then be discharged and treated at the POTW,
prior to its discharge to the Mississippi River. The fine grained
soils may then be treated by bioremediation, incineration, and/or
solidification/stabilization, further reducing toxicity, mobility
and volume of contaminants.
S .
Short-term Effectiveness
This alternative would remove contaminated soil and debris,
thereby removing a continuing source of ground water
contamination. Incineration was shown in the test-burn on
October 31-November 1, 1991 to be extremely effective in
destroying PCP.
The excavation and screening of soils and debris may produce dust
emissions, especially during dry and windy conditions. This
presents some exposure risks to on-site workers and possibly to
nearby passers-by or residents. These risks will be limited
by covering soils as needed during preparation processes.
Additional short-term risks may be presented due to air emissions
from the incineration process. These risks appear minimal as
indicated by the results of the test-burn. Exposure risks can be
minimized by maintaining proper operation of the incinerator,
periodically monitoring stack emissions, and taking mitigative
measures if needed.
In addition, short-term risks may be present due to loading and
transport of the ash to an off-site permitted landfill. However,
these risks are expected to be minimal due to the limited volume
of ash that will need to be removed from the site.
6.
ImDlementability
This alternative should be readily implementable provided there
are positive results of the treatability studies. CUrrently,
several soil washing vendors are available to provide
competitive bids. If this alternative requires additional
equipment and specialists, these should be available without
significant delay. 80il washing has been successfully used at
-------
26
other sites in treating contaminants similar to those found on
:his DP~_- OU.
7.
C:ost
This alternative carries an estimated total cost of between
$9,826,250 and $17,579,375, assuming additional treatment of the
fine-grained soils (Table 3). This figure does not include the
cost of possible treatment of the wastewater before discharge to
the POTW.
IX.
SELECTED REMEDY
The MPCA's/U.S. EPA's preferred alternative is Alternative 4 - -
On-site Incineration of burnable debris and soil washing of
contaminated soils. This alternative will require several steps
to implement, and would include:
10.
11.
1.
2.
Fencing of the disposal area.
Excavation to an approximate depth of 10 feet (or until
no more contaminated debris or soil is found, whichever
is more extensive) within the perimeter of the disposal
area. Excavation work will include dewatering of soils
and the disposal area pond;
Separation of non-burnable debris, wood debris, and
soils;
Rinsing and landfilling or recycling of non-burnable
debris (concrete blocks, empty barrels, metal
strapping, etc.);
Drying and incineration of wood debris;
Treatment and/or disposal of bottom ash in a landfill
or on-site;
Treatment and disposal of fly ash in a landfill;
Soil washing of contaminated soils which will separate
sandy soils from the fine-grained soils;
Treatment of contaminated fine-gr.ained soils through
bioremediation, incineration,. and,tor solidification/
stabilization;
Backfilling of treated soils in the disposal area.
Discharge (and possible pretreatment) of soil washing
effluent, rinse water from non-burnable debris, and
water from the dewatering operation to the PO'n7;
3.
4.
5.
6.
7.
8.
9.
Several treatability studies will also be required to determine
the effectiveness of each remediation process, and final disposal
alternatives for remaining residuals:
1.
Testing of the water used to wash the non-burnable
debris as well as the water used in the dewatering
operation, will be required to determine if treatment
is needed prior to disposal to the sanitary sewer
system. Possible.water treatments include chemical
-------
. 0
27
2 .
precipitation, ion exchange/ion absorption. reverse
osmosis, carbon absorpt:on. biological treatment, or
some other appropriate method.
It is believed that the wood debris will contain the
majority of the CCA in the excavated material. The
.incineration process will destroy the organic
contaminants in the wood, but the metal contaminants,
which cannot be destroyed, will remain in the ash after
incineration. TCLP testing of the bottom ash and "fly"
ash from the incineration of wood debris will be
required to determine if solidification/stabilization
is needed before the ash is placed in a secure
landfill. Testing of the bottom ash will also be
performed to determine whether the health based
remediation levels discussed below can be attained. If
so, the bottom ash should be able to be disposed of on-
site.
Testing of the water used in the soil washing process
will be required to determine if the water can be
treated and reused in the process or if treatment is
needed prior to disposal to the sanitary sewer system
(possible water treatments include those listed in item
1 above) .
The sandy soils will be separated from the fine-grained
soils during the washing process. It is believed that
the sandy soils will be free from contamination after
the washing process and could be placed back on site.
It is believed that the fine-grained soils will hold
most of the soil contamination after the washing
process and will require treatment by bioremediaiton,
incineration, and/or solidification/stabilization.
TCLP testing of the fine-grained soils will be required
to determine if Land Disposal Requirement standards
would require sOlidification/stabilization prior to
landfilling.
3.
4.
s.
The exact design of these cleanup actions will be determined
during the design phase. The remedial actions will be tested on
a pilot- or bench-scale before final implementation. If
treatability studies indicate the remedial actions will not meet
the remediation levels discussed below, the MPCA/U.S.EPA prefers,
as a contingency remedy, incineration of the contaminated soils,
as well as the wood debris, as described in Section VII of this
document under Alternative 2. It should be noted, however, that
additional evaluation of alternatives may be undertaken by the
Agencies at that t~e, because of the cost differential between
soil washing and incinerati~n of soils. Both the preferred
alternative and the fall-back alternative meet the first ~ight of
the nine evaluation criteria used to determine the
appropriateness of remediation options. The ninth criteria,
.Community Acceptance, is addressed in Section X of this document.
-------
" .
28
Remediation Levels
The cleanup or remediation levels for the disposal pit area were
developed to provide protection to residents and workers who may
be exposured to contaminated soils. These levels were also
developed for protectiveness of groundwater beneath the Site.
Residential exposure to the contaminated soils assumes ingestion
of the soils by both adults and children. Occupational exposure
assumes exposure to the soils through ingestion as well as
inhalation. Direct exposure to contaminated soils is assumed to
occur in the upper two feet of soil.
The remediation level for soils is based on a risk level of 10 E-
5 for excess lifetime cancer risk, meaning if 100,000 people were
exposed to these soil contamination levels every day for 24 hours
(8 hours a day for occupational) for 70 years (24 years
occupational), we would expect one additional case of cancer that
would not otherwise occur resulting from the exposure. This
remediation level applies to the carcinogens or probable
carcinogens found at the site which are arsenic, the eight
carcinogenic PARs, and pentachlorophenol.
The soil remediation level will also provide a hazard index ratio
of less than 1 for noncarcinogenic effects of contaminants at the
site. For noncarcinogens, risk is determined by calculating the
hazard index which is a ratio of estimated exposure to the'
accepted daily intake. A hazard index greater than 1 indicates
that adverse effects may be possible while a value less than ~
means that adverse effects would not be expected.
The contaminated soils in the disposal pit area below the upper 2
feet shall also be remediated to a level that will be protective
of groundwater. The soil remediation levels shall be established
at a level that will not leach contaminants to the groundwater
and create groundwater contamination in exceedance of the Maximum
Contaminant Levels of the Safe Drinking Water Act and/or the
Recommended Allowable Limits established by the Minnesota
Department of Health. Methods for the calculation of these
remediation levels are contained in the U.S.EPA guidance
"Determining Soil Response Action Levels Based on Potential
Contaminant Migration to Ground Water: A Compendium of
Examples., October 1989.
Actual concentrations of contaminants to meet the remediation
levels discussed above shall be determined during the predesign
phase.
x.
STA'1'tJ'l'OllY DBTBRKINATIOHS
The selected remedy must satisfy the requirements of Section 121
of CERCLA, which are:
-------
29
- Protection of human health and the environment;
- compliance with ARARs;
- Be cost effective;
- Utilize permanent solutions and alternative treatment
te=hnologies or resource recovery technologies to the
maximum extent practicable; and
- Satisfy the preference for treatment as a principal
element, or justify not meeting the preference.
1.
Protection of Human Health and the Environment
The selected remedy provides overall protection of human health
and the environment by removing a primary source of ground water
contamination from the DPA-QU. Excavating and treating the
contaminated material in the disposal pit area will also remove a
potential health hazard to MacGillis and Gibbs Co. workers and
area residents, especially children, who may trespass on the DPA-
QU.
2.
Co~liance with ARARs
The selected alternative will meet all applicable, relevant and
appropriate requirements (ARARs) under federal law, or more
stringent state laws. Because the remedial actions the MPCA will
undertake on this Site relate only to the debris, soils and
sediments and surface water at the MacGillis & Gibbs Co. disposal
pit area operable unit (DPA-OU), and not the ground water at the
Site, only ARARs relating to remediation and disposal of the
debris, soils, sediments, and surface water are addressed herein.
1.
Resource conservation and Recovery Act (RCRA)
a.
Chemical Specific
- RCRA Definition and Identification of Hazardous Waste
(40 CFR 261.31); Minnesota Hazardous Waste Rule
7045.0020 - 7045.0135 (4) (f) (Minnesota Equivalent
Regulation)
- RCRA Toxicity characteristic rule regarding classification
for soils and sediments containing arsenic, chromium and
PCP (40 CFR 261.24)
b.
Location specific
- Location standards for hazardous waste treatment units (40
CFR 264.18)
- Wetlands protection; floodplain management (40 CFR 6.302,
Appendix A)
-------
30
c.
Action Specific
- Standards applicable to generators of hazardous waste (40
CFR 262); Minnesota Hazardous Waste Rule 7045.0211-
7045.0304 (Minnesota Equivalent Regulation)
- Standards applicable to transporters of hazardous waste,
(if residual metals in incinerator ash require placement
in Subtitle C landfill (40 CFR Part 263)
- Standards applicable to operators of hazardous waste
treatment facilities (40 CFR part 264); Minnesota
Hazardous Waste Rules 7045.0552-7045.0642 (Minnesota
Equivalent Regulation)
- RCRA Land Disposal Restrictions (40 CFR 268)
- Metals Emissions from Boilers and Industrial Furnaces (40
CFR 266.106)
- Hydrogen Chloride (HC1) Emissions from Boilers and
Industrial Furnaces ( 40 CFR 266.107)
2.
Clean Water Act (CWA)
-Discharge to Publicly Owned Treatment Works (POTW)
Part 403)
( 4 0 CFR
3 .
Clean Air Act (CAA)
- National Ambient Air Quality Standards (40 CFR Part SO)
In addition, while not an ARAR, Section 121 (d) (3) of CERCLA
requires that any hazardous waste removed from the site for off-
site disposal must be disposed of in a landfill meeting the
requirements of EPA's "Off-Site Policy", OSWER Directive 9834.11
(November 13, 1987).
3 .
Cost Effectiveness
The remedial costs for the selected remedy are approximately $10
million to $17 million dollars. This is the most cost effective
of the three remedies that could meet the cleanup criteria set
for the DPA-OU. The contingency alternative, incineration of all
wood debr~s and soils, is substantially more costly at $15
million to $38 million dollars. The more expensive contingency
alternative would be implemented only if pilot tests of the
remedial actions in the selected alternative are not able to meet
the criteria established for the DPA-OU. Because of the cost
differential, the Agencies may elect to conduct further
evaluation of alternatives if treatability studies show the
selected alternative is not effective.
-------
Do.
31
4. Utilization of Permanent Solutions and Alternative
Technoloq:es or Resource Recoverv rechnoloqies to the Maximum
Extent possible.
The selected alternative, incorporating both incineration and
soil washing, plus possible further treatments based on results
of treatability studies, utilizes alternative technologies to the
maximum extent currently possible at the DPA-OU. Incineration
will provide permanent destruction of organic contaminants in the
wood debris. Although metals will not be destroyed and will
remain in the ash following incineration, solidification/
stabilization of the ash is expected to permanently immobilize
metal contamination. Soil washing will remove contaminants from
the majority of the contaminated soils and residuals will be
further treated, as necessary
5 .
Satisfaction of the Preference for Treatment as a PrinciDal
Element
The preferred alternative provides several different treatments
as principal elements in the remediation, including incineration,
soil-washing, possible wastewater treatment, and possible
solidification/stabilization as a further treatment.
Documentation of Significant Changes from the Proposed Plan
The Proposed Plan was released for public comment on August 1,
1992. The Proposed Plan indicated that as part of the preferred
alternative, wood debris would be burned in the incinerator on
the Bell Lumber & Pole Co. property. However, the Federal
ACquisition Regulations require that this on-site incineration
work be competitively bid with the contract being awarded to the
lowest responsive, responsible bidder. U.S.EPA/MPCA will
advertise the incineration work fer competitive bidding at the
Remedial Action phase of the site.
It was stated at the public meeting for the-Proposed Plan that
the preferred remedy would not include the disposal pond located
in the disposal area. In order to excavate the sediments and also
some of the soils in the disposal area, it will be necessary to
dewater the groundwater as well as the surface water in the
disposal pond. It has been determined that this will provide the
easiest access for removal of the sediments and result in the
most environmentally sound method for removal of the sediments.
The dewatering is a construction activity that would be common to
each of the alternatives which were considered, and t~er£:;=~
'does not change the Agencies' determination of the selected
, alternative. The estimated costs of the dewatering, inCluding
treatment, would be approximately $85,000 to $150,000 depending
on the degree of treatment that will be required.
Since the Proposed Plan was presented to the public, the cost
-------
1 d"
32
estimates of all the alternatives were updated primarily to
reflect ar- increased volume of soL. to be remediated than had
been reflected in the FFS. The cost range for the selected
alternative (Alternative 4) was revised from $9,928,250 -
$12,928,250 to a range of $9,826,250 - $17,579,375. The cost for
Alternative 4 was also revised to include the treatment of the
fine grained soils resulting from the soil washing process. This
update of costs is not considered by the Agencies to be
significant and thus will not alter the Agencies' decision to
choose Alternative 4 as the Selected Alternative.
The cost range for Alternative 2 has also increased from
$10,662,500 - $25,842,500 to $15,645,000 - $38,775,000. This is
an increase of approximately SO % for both the upper and lower
limits of the cost range. Alternative 2 is the Agencies' choice,
at this time, as the contingency remedy, if treatability studies
indicate that Alternative 4 will not be effective. As previously
noted, the Agencies may want to reevaluate the use of Alternative
2 at that time because of the potential cost differential in the
two alternatives. It is expected that increased site information
will be available after the treatability studies are performed
which will provide a more accurate estimate of costs for
Alternative 2 should there be a need to implement an alternative
remedy.
The cost range for Alternative 3 has also increased from
$16,025,000 - 34,025,000 to $22,561,000 - 63,361,000. The cost
for Alternative 3 was revised to include the treatment of the
soils resulting from the soil washing process.
-------
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-------
8th Ave. tlW
DISPOSAL PIT AREA
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-------
FIGURE 3
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WITH LOCAL L.ENSES OF SAND AND GRAVEL
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ABSENT AT PORTIONS OF THE SITE
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AND CLAYS. RESTRICTED TO BEDROCK V ALLEYS
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-------
\J
.
TABLE 1
ESTIMATED COSTS
AL~A11VE2
ACTMTY I QUANTn'Y (eat.) I UNIT cosr I con
E:.c:aV81ion. screcnincand grmUins oi 10.000 cy S,40/ey $4.%00.000
saiil
I S2.SQ.8SO/ey
i 1DQac:rauaa of sails 30.000 cy S7.soG.OOO .
I ~oa.ooo
I
I
I
. Tr~uon (truck) of ocmcm ash 38.000 toes S60/ton S2.280.ooo .
Tr~1JGn (ni1rcad) of boLtom $40/tOD $1..520.000
ash
Disposal of bonom un \38.000 tons I S20/tnn(') . $760.000 .
SW/ton(') $.5.130.000
Transporwaon (U'\Jdt) of fly LVI 1.500 tODl S60/ton S9Q,OOO
S'tOhil;,aUan and dispOsai of fly ash 1.500 tons S1.0oo/ton(' SUoo.ooo
Steam wuh AoMarubie debril $1'.000
ESTrMATED TOTAL COST SU.645,OOO .
$3&.175.000
t!szaI:
C) Subtide D wdfill. Special (non-hazardous) Wllste
C, Subdde D LaDcI1iD. 1nduauw W... .
(') £"cimauxi 500 lba/drum. S250/dnnn. S5OO/t,OOO 1\)$
-------
6.0
iJ
Q
TABLE 2
ESTIMATED COSTS
ALTERNATIVE: 3
~
ACTIVITY
QUANTITY (est.) I
UNIT C~I
COST
~
Excavation. screening & 30.000 ey Sl401ey S4.200,000
grinding of so11s
Inc1neration of s011s 30.000 ey S250-8501ey $7.500,000-
S25.500,000
Soil. washing of bottom ash 38,000 tons S 6 5 I ton ( 1) $2.470.000
Treatment of soil washing 38,000 tons Sl72/ton (3) $6,536,000-
residual $772 Iton ('-) $29,336,000
Discharge of effluent to POTW 50,000 gallons SO.35 per $18 (neg-
1,000 ligible
gallons
On-site disposal of treated 38,000 tons $5/ton $190,000
bottom ash
Transportation of fly ash 1,500 tons $60/ton $90,000
Stablization and disposal of 1,500 tons 1,QOO/ton(Z) $1,500,000
fly ash
Steam wash non-burnable $75,000
debris
ESTIMATED TOTAL COST $22,561,000.
63,361,000
Notes:
(,) Based on document EPA/540/AS-91/003, February 1992
Report
(Z) Estimated
(3) Treatment
('-) Treatment
(Application Analysis
500 lbs/drum, $250/drum, $500/1,000 lbs
using bioremediation and solidificat~on
using incineration and solidification
-------
TABLE 3
::ST~TED COSTS
ALTERNATIV'E 4
~
QUANTITY (est.) I
:-"NIT COST I
'::OST
~
:'CTIVITY
Excavat 1. on , screenJ.ng & 30,000 r::y S140/r::y $4,200,000
qrJ.ndinc:r of sOJ.ls
Inc:1.neracion of wood & 7,500r::y(1) S250-850/r::y Sl,875,OOO-
burnable debris other than $6.375,000
sOJ.ls
SOJ.l washing of screened 33,750 tons (2) S65/ton $2,193,750
sOJ.ls
Treatmenc of soil washing 5,000 tons Sl72/ton (7) $ 860,000-
fines S772/ton(8) $3,860,000
On-sJ.te disposal of washed 33,750 tons S3.34/ton $112,500
sOJ.ls
Discharge of effluent to POTW 50,000 gallons SO.35 per $18 (neg-
1,000 ligible)
c:rallons
TranSDorCation of flY ash 375 tons $60/ton $22,500
Stablization and disposal of 375 tons l,OOO/ton(3) $375,000
fly ash
Transporcation (truck) of 1,875 tons (,,) $60/ton $112,500-
bottom ash $40/ton $75,000
Transportation (railroad) of
boctom ash
Disposal of bottom ash 1,875 tons (,,) $20/ton (5) $37,500-
$135/ton (6) $253,125
Steam wash non-burnable $75,000
debris
ESTI~TED TOTAL COST $9,826,250-
- $17,579,375
Notes:
(,) Estimated as 25 percent of total volume
(2) 22,500 cy at an assumed density of 3,000 lbs/cy
(3) Estimated SOOlbS/drum, $2S0/drum, $500/1,000 Ibs
(,,) Estimaced as 25 percent of incinerator influenc material,
2,000 Ibs/cy
(5) Subtitle D Landfill, Special (non-hazardous) waste
(6) Subtitle D Landfill, Industrial Waste
(7) Treatmenc using bioremediation and solidification
(8) Treatment using incineration and solidification
1,875 r::y assume
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U
MacGillis & Gibbs / Bell Lumber & Pole Co. Site
New Brighto~, Minnesota
Responsiveness Summary For aUl Record of Decision
Introduction
The Minnesota Pollution Control Agency (MPCA) undertook a
Remedial Investigati'Jn/Feasibility Study (RI/FS) to determine the
nature and extent of contamination at the disposal area on the
MacGillis & Gibbs portion of the site and to develop appropriate
remedial actions for cleanup of this area of the Site. MPCA
issued a Proposed Plan that recommended an alternative for an
interim remedial action at the MacGillis & Gibbs disposal area
portion of the Site. The interim action alternative is intended
to remove a source area on the site that is continuing to spread
contamination into soils and groundwater beneath the Site.
Additional investigation will be concurrently performed with this
interim action in order to determine a final Site remedy.
MPCA issued a notice of the Proposed Plan's availability and a
public comment period, which were published in the Star Tribune
newspaper on July 30, 1992. A thirty-one day public comment
period was conducted from August 1 to August 31, 1992 to allow
interested citizens to comment on MPCA's Proposed Plan. On
August 10, 1992, MPCA presented its Proposed Plan at a public
meeting. The purpose of this Responsiveness summary is to
document the fact that no comments were received during the
public comment period.
The Responsiveness summary is divided into the following
sections:
I. Resoonsiveness Snmmarv overview. This section briefly
outlines the proposed remedial alternatives as presented in the
proposed Plan, including the recommended alternative.
II. Snmmarv of Public Comments Received-Du.rina the public
Comment Period and MPCA Resoonses.
I.
Responsiveness summary overview
On AUgust 1, 1992, MPCA submitted the Focused Feasibilit~ Study
and the proposed Plan for the MacGillis & Gibbs disposa: ~=ea on
the site to the public for review and comment. The interim
remedial action alternatives described methods for removing a
source area of contamination on the site, specifically,
contaminated soils, sediments and debris in a low-lying,
partially ponded area formerly used for disposal. MPCA's
proposed Plan described five remedial action alternatives that
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would remediate this source area and initiate restoration of the
aquifer. The proposed interim re~edial action alternatives
(IRAAs) included the following:
IRAA 1 -
No Action
IRAA 2 - washing, and landfilling or recycling, of nonburnable
debris: incineration of soils and wood debris;
solidification/stabilization of fly ash; off-site disposal of
bottom ash and fly ash.
IRAA 3 - Washing, and landfilling or recycling, of nonburnable
debris; incineration of soils and wood debris, soil washing of
bottom ash: discharge of effluent to POTWi
solidification/stabilization and off-site disposal of fly ash.
IRAA 4 - Washing, and landfilling or recycling, of nonburnable
debris: incineration of wood debris, treatment of bottom ash and
fly ash: on-site disposal of ash (or off-site disposal,
contingent on TCLP testing): washing of soils: discharge of
effluent to POTW: treatment of fine-grained soils through
bioremediation, incineration or solidification/stabilization: on-
site disposal of treated soils.
IRAA 5 - washing, and landfilling or recycling, of nonburnable
debris; incineration of wood debris; bioremediation of soils.
After careful consideration of the RI and FS, MPCA recommended
IRAA 4 as the preferred alternative.
II. Summary of Comments Received During the PUblic Comment
Period
No comments were received at the public hearing on August 10,
1992, and no written comments were received during the proposed
Plan comment period.
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U.S. DEPARTMENT OF COMMERCE
Natlona' Technical 'nrormatlon Service
S,.r'"gIl8Id. VB. 22 In t
AN EOUAl OPPORTUNITY EMPLOYER
OHICIAl nUSINESS
flflllo'ty ror flrlveto Use, S300
POSTAGE AND FEES PAID
U.9. DEPARTMENT OF COMMERCE
COM-2 t t
FIRST CLASS
[I)
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