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Alternative 1A will significantly reduce the nobility, toxicity, and volume
of hazardous substances in the soil through treatment. The mobility of the
contaminants will be reduced significantly, such that no leachate is
expected to be produced from the vitrified material. This is a permanent
technology, the results of which are expected to last for a million years.
The toxicity of organic components will be decreased because the organics
are destroyed or changed to other forms by pyrolysis or vaporization. The
volume of the soil will be reduced by 25-30 percent because the
vitrification causes the soil mass to consolidate. Decontamination of site
structures will be carried out in accordance with the RGRA requirements and
will reduce the threat associated with these contaminated structures.
Implementation of this remedy poses some short term risks due to inhalation
of dust during soil excavation and decontamination procedures. During the
vitrification procedure, some organic compounds will volatilize. A vacuum
hood over the vitrified area will be designed to control and treat any
release of gas to the environment. There is a short term risk from the
heat generated in the process. Implementation of this alternative is
expected to take 2.8 years to complete. The equipment must be specially
designed and produced. Approximately six to twelve months will be needed
to manufacture the equipment. This will occur concurrently with the
remedial design. It is estimated that groundwater will be extracted and
treated for approximately five to ten years.
Although there have been limited performance demonstrations, it is expected
that the.vitrification will attain 99.9999% destruction and removal
efficiency (DRE). The alternative will require a trained level of
expertise to operate the power input and to oversee the movement of the
equipment.
Although no on-site permits are needed, the technical requirements of NPDES
for the surface water discharge will be met. ISV is a patented process
which requires a license.
The groundwater extraction/treatment system will reduce the mobility,
toxicity and volume of hazardous substances in the groundwater at the site.
This extraction and treatment system will result in compliance with Federal
and State ARARs. This portion of the alternative is fully protective of
puDlic health and the environment at the site.
The capital cost of this alternative is $20,837,000, the annual Operation
and Maintenance (O&M) cost is $94,800 and the present worth cost is
$21,731,000.
Alternative 1A will be fully protective of public health and the
environment.
Alternative IB
Alternative IB also uses treatment as a principal element and decreases the
mobility, toxicity and volume of the waste. This alternative will meet all
identified State and Federal ARARs. The major difference is that this
alternative is less permanent and protective than Alternative 1A since
residual soil contamination will remain. It may leach into the groundwater
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20
at levels that will exceed ARARs at some future time and thus increase the
groundwater treatment time or require additional future remedial action.
An estimated 7,125 cubic yards of soil will be vitrified on-site to
eliminate the direct contact threat and site structures will be
decontaminated and landfilled off site.
The effectiveness of this alternative is dependent on maintaining the
integrity of the cap through proper Operation and Maintenance (O&M). The
cap win reduce the rate of infiltration of groundwater through the
contaminated soils, thereby reducing the volume of leachate produced at the
site. The lifetime of a RCRA multilayer cap is finite, and the
contaminated soils will be left in place to contribute to groundwater
contamination at some future time should the cap fail. Alternative IB is
less protective than Alternative 1A based on long term protectiveness.
There are possible short term threats due to potential releases of
volatiles during the vitrification process, although the vitrification
system will be specifically designed with a hood to address the release of
volatiles.
Alternative IB requires excavation and consolidation of the wastes. This
poses a short-term threat to public health and the environment.
The elements of the groundwater extraction evaluation are the same with the
exception that groundwater will be treated over time in the upper outwash
lens, since this lens will not be vitrified. The groundwater extraction/
treatment system will meet Federal and State ARARs, uses treatment as a
principal element, and reduces the mobility, toxicity and volume of
contaminants.
The capital cost of this alternative is $6,995,000, the annual O&M cost is
$99,200, and the present worth cost is $7,930,000.
Alternative 2A
Alternative 2A uses treatment as a principal element for all contaminated
media and reduces the mobility, toxicity and volume of the waste.
Approximately 37,700 cubic yards of contaminated soil will be incinerated,
structures will be decontaminated, and groundwater will be extracted and
treated. This alternative will attain all identified Federal and State
ARARS.
Incineration is a proven technology, which will permanently destroy organic
chemicals in the soil (99.9999% DRE). However, metals are not destroyed by
incineration and will become more concentrated in the ash. Noncombustibles
and ash (potentially as much as 85 percent of the original volume) will be
classified as hazardous because the contaminated soil is classified as a
listed hazardous waste under RCRA. The delisting procedure will be
necessary to classify the wastes as non-hazardous. Incineration of 37,700
cubic yards of contaminated soil is fully protective of human health and
the environment since the ingest ion and leachability threats are
eliminated. No monitoring of the ash will be required. The expected
reliable life of this alternative is infinite.
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21
Implementation of this remedy poses some short term risks due to inhalation
of soil dust during excavation and structure decontamination. Incineration
may result in short-term low level emissions of a small fraction of the
organics in the soil feed as well as the products of incomplete combustion
(e.g., dioxins). Since there win be.3«i air pollution control system on
the incinerator to decrease emission*TSrf particulate matter, emissions of
contaminants will not exceed standards.
Implementation of this remedy is expected to take"~two years after the
equipment is obtained. Approximately six to twelve months will be needed
to obtain the equipment. This will occur concurrently with the remedial
design. The use of mobile incinerators is common and the performance of
these systems has been demonstrated. It is relatively easy to operate the
system although a trained operator will be needed.
Although no onsite permits will be required, the requirements of
incineration permits will be met. The other elements of this alternative
are the same as Alternative 1A. The capital cost of Alternative 2A is
$50,595,000, the annual O&M cost is $94,800 and the present worth cost is
$51,489,000.
Alternative 2A will be fully protective of human health and the
environment.
Alternative 2B
Alternative 2B also uses treatment.-as. a_principal element and decreases the
mobility, toxicity and volume Q^Sj^gjPJajfe "This alternative will meet all
identified State and Federal ARggiiySSwBfeor differenc
alternative is less permanent aJVPfrtdlS^e than
residual soil contamination will remain at the site tJiavCsBefifr^iPto the
groundwater at levels that may exceed ARARs at some
increase the groundwater extraction/treatment time, or requirt additional
future remedial action.
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23
Approximately 7,125 cubic yards of soil will be incinerated on-site and
structures will be decontaminated to eliminate the direct contact threat.
The effectiveness of this alternative is dependent on maintaining the
integrity of the cap through O&M, since soil contamination remains at the
site. Ihe cap will reduce the rate of infiltration of groundwater through
the contaminated soils, thereby reducing the volume of leachate produced
at the site. The lifetime of a RGRA multilayer cap is finite, and the
contaminated soil will be left in place to contribute to groundwater
contamination at some future time should the cap fail. Alternative 2B is
less protective than Alternative 2A based on long-term protectiveness.
The elements of the groundwater extraction evaluation are the same. As
the groundwater extraction/treatment system is the same as Alternative IB,
it will meet Federal and State ARARs, it uses treatment as a principal
element, and reduces mobility, toxicity and volume of contaminants.
Implementation of this remedy is expected to take 1.5 years.
The capital cost of this alternative is $12,169,000, the annual O&M cost
is $99,200, and the present worth cost is $13,104,000.
Alternative 3A
Alternative 3A does not provide treatment as the principal element for
37,700 cubic yards of contaminated soil, but does provide treatment for
structures and groundwater. Alternative 3A will meet all identified State
and Federal ARARs.
Alternative 3A is protective of public health and the environment at the
site. It eliminates the threat of migration of contaminants through
excavation and containment of all soils that have the potential to leach
into the groundwater. Alternative 3A involves excavation and containment
of soils which contribute a threat to human health via ingestion and all
soils that will pose a risk when leachate is produced. However, there
will be no reduction of toxicity or volume of the contaminants and the
reduction of mobility depends on maintaining the integrity of the off-site
disposal cell. Although this alternative eliminates the risk to human
health and the environment at the site due to contaminated soil, there is
potential for the contaminated soil to cause a problem at the off-site
facility. Alternative 3A may have significant short-term impacts on
public health and the environment due to risk involved in the excavation
and transportation of contaminated soil. Dioxin contamination may need to
be treated separately or landfilled on-site. Since this alternative
involves placement of contaminated soil, the Land Disposal Restrictions
are ARARs. Because of the uncertainties of how this restriction will be
carried out and the undefined treatment standards, this alternative may
not be implementable.
As the groundwater extraction/treatment system is the same as Alternative
1A, it will reduce the mobility, toxicity, and volume of hazardous
substances in the groundwater at the site. This extraction and treatment
system will result in compliance with Federal and State ARARs. This
portion of the alternative is fully protective of public health and the
environment at the site.
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In Section 121 of SARA, it is stated that off-site disposal without
treatment is the least preferred alternative. Also, although Alternative
3A is readily implementable from a construction standpoint, the Land
Disposal Restrictions may preclude actual implementation of this
alternative.
The capital cost of this alternative is $20,834,000, the annual O&M cost
is $95,800, and the present worth cost is $21,737,000. Although
Alternative 3A will essentially eliminate threat to human health and the
environment at the site, treatment is not used, the alternative does not
provide an adequate level of permanence and is the least preferred under
SARA. It is expected that it will take approximately one year to
implement the soil removal.
Alternative 3B
Alternative 3B does not provide treatment, does not reduce nobility,
toxicity and volume of the soil, and provides the same protection at the
site as Alternatives IB and 2B. The short and long-term risks posed by
this remedy are the same as for Alternative 3A. Since this alternative
involves placement of contaminated soil, the Land Disposal Restrictions
are ARARs. Because of the uncertainties of how this restriction will be
carried out and the undefined treatment standards, this alternative may
not be implementable. Implementation of this remedy is expected to take
about one year.
As the groundwater extraction/treatment system is the same as Alternative
IB, it will meet Federal and State ARARs, it uses treatment as a principal
element, and reduces mobility, toxicity and volume of contaminants.
The capital cost of this alternative is $6,242,000, the present worth cost
in $7,186,000, and the O&M cost is $100,200.
Alternative 4
Alternative 4 is a containment option. Alternative 4 involves containment
of 7,125 cubic yards of soil and the structures which pose a threat to
human health via ingestion at concentrations greater than the cumulative
excess lifetime cancer risk. Alternative 4 does not mitigate the
potential for release of contaminants that exceed Ml.s from the subsurface
soils into the groundwater through infiltration. Potential for additional
remedial action costs remains. Alternative 4 meets all identified State
and Federal ARARs, and minimizes the threat to public health and the
environment. It does not treat the contaminated soil. There is no
reduction in toxicity or volume of contaminated soil, and the reduction of
mobility is dependent on maintaining the effectiveness of the disposal
cell and the RCRA cap.
Although Alternative 4 is readily implementable and constructible, the
long-term threat to public health and the environment is not mitigated.
Since this alternative involves disposal, the Land Disposal Restrictions
will apply and may preclude this alternative from being implemented.
Long-term reliability of RCRA cells is unknown since the performance data
are unknown. Alternative 4 will require long-term maintenance of the
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25
disposal cell and multilayer cap. Some short term risks vail be posed by
excavation of soil and construction of the cell. Implementation of this
remedy is expected to take one year.
As the groundwater extraction/treatment system is the same as Alternative
IB, it will meet Federal and State APARs, it uses treatment as a principal
element, and reduces nobility, toxicity and volume of contaminants.
Because there is no treatment of soils to reduce the mobility, toxicity or
volume, Alternative 4 does not provide an adequate level of permanence
since the highly mobile contaminants remain at the site. The capital cost
of this alternative is $2,646,000, the annual O&M cost is $101,500 and the
present worth cost is $3,602,000.
Alternative 5
Alternative 5 is a containment option. There is no treatment for soil to
reduce the mobility, toxicity or volume of the contaminants. There is
treatment of the structures. Although mobility will be reduced because of
the reduction of infiltration of rainwater through the cap, the potential
remains for contaminants to continue to migrate should the cap fail, which
may necessitate additional remedial action costs. Groundwater will
continue to contact contaminated soil. This alternative is protective
over the short-term, assuming the cap is constructed effectively.
However, over the long term, this alternative is not protective.
Contaminated soil will remain at the site and is not treated.
Alternative 5 does not provide an adequate level of permanence since there
are highly mobile contaminants remaining at the site. Additional remedial
action costs may be incurred should the cap fail in the future. Long-term
reliability is unknown. Prevention of future exposure depends on the
effectiveness of access restrictions and aquifer use restrictions, neither
of which are enforceable.
As the groundwater extraction and treatment system is the same as
Alternative IB, it will meet Federal and State ARARs and it uses treatment
as a principal element and reduces mobility, toxicity and volume of
contaminants.
Although Alternative 5 provides some public health and environmental
protection, it is not a permanent remedy that reduces the mobility,
toxicity and volume. Hazardous substances in the soil remain in place and
win require long-term maintenance. The capital cost of this alternative
is $2,113,000, the annual O&M cost is $99,200, and the present worth cost
is $3,049,000.
Alternative 6
Alternative 6, No Action, is ineffective in preventing further contaminant
migration and does not mitigate or reduce the existing contamination at
the site. It is not protective of public health and the environment. It
win not meet Federal and State ARARs nor will it reduce the mobility,
toxicity or volume of hazardous substances in the soil or groundwater.
Hazardous substances in soil and groundwater will continue to migrate and
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will cause additional public health and environmental threats. The
alternative is not a permanent remedy. The risks that were outlined in
the public health evaluation remain.
Reconmended Remedy
The recoimended remedy for selection and implementation is Alternative 1A.
Alternatives 3A, 3B, 4, 5 and 6 clearly do not meet the preferences
mandated by SARA since they do not use treatment as a principal element of
the remedy. Alternative 6 leaves the site unchanged, which is
unacceptable from a public health standpoint. It will not meet Federal or
State APARs. Alternatives 3A, 3B, 4 and 5 merely contain the waste to
varying degrees without treatment. This is counter to the preferences
established in Section 121 (b) of SARA for implementation of remedial
action. Alternatives 1A, IB, 2A and 2B all use treatment as the principal
element of the remedy. However, Alternatives IB and 2B do not provide
treatment of the soils which can potentially and significantly contribute
to groundwater contamination should the remedial action fail. Both
alternatives require long-term maintenance of the RCRA cap to maintain the
effectiveness of the remedy. These alternatives are containment in
subsurface soil below two feet remain at the site without treatment. The
mobile contaminants in subsurface soil below two feet remain at the site
without treatment. Since the contamination that can leach into the
groundwater remains at the site, the potential for additional future
remedial action remains. The long-term protectiveness and permanence of
these alternatives are less than for Alternatives 1A and 2A. Therefore,
Alternatives IB and 2B are not recommended for implementation at the
Pristine, Inc. site.
Alternative 1A and 2A will reduce the mobility, toxicity and volume of the
contaminated media. The alternatives will meet identified Federal and
State ARARs. Both alternatives are fully protective of human health and
the environment. Each will require specialized equipment and operators,
and will require similar maintenance effort. Both are technically
feasible and implementable. However, vitrification is the lower cost
alternative. Therefore, incineration is not recommended for implementation
at the Pristine, Inc. site.
The Ohio EPA supports the selection of Alterntive 1A for the Pristine,
Inc. site. They would support only the groundwater remedial action if
another alternative is implemented. Their only reservation involves U.S.
EPA's interpretation of SARA Section 121, groundwater cleanup levels, and
how dioxin will be addressed. These matters are discussed in detail in
the responsiveness summary.
Alternative 1A is a permanent remedy requiring no maintenance of the
vitrified mass to maintain effectiveness, and little overall maintenance.
Alternative 1A is fully protective of human health and the environment,
reduces mobility, toxicity, and volume of hazardous substances at the
Pristine, Inc. site through treatment, and is a cost effective
alternative. Therefore, Alternative 1A is the recommended alternative for
the Pristine, Inc. site. Figure 9 is a depiction of the ISV process.
The Coimunity and PRPs are generally in agreement with the groundwater
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FIGURE 9
SuDOOn Trailer
Electric*! Svltt"-
««•>
x Site to oe . _ ^^_
Eitctrodt
Off-Gas
MOOO Cover
Housing
GRAPHITE
AND FRIT
STARTER
SCRUBBER SYSTEM
HEATER
CHARCOAL
FILTERS
STACK
OFF-GAS TRAILER
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27
extraction and treatment component of the alternative.
There is community concern over the short-term effects of the alternative.
Some manbers of the conramity have fully supported U.S. EPA's recommended
alternative, while the FRPs rejected vitrification and have proposed
installation of a RCRA cap with soil gas venting. The City of Reading
prefers that U.S. EPA fund a less expensive remedial action and give it
the remaining funds to build a new treatment plant. These concerns are
addressed in the Responsiveness Summary.
Alternative 1A provides a high degree of treatment of the hazardous
substances present at the site. It will be both a source control (through
remediation of soil) and a management of migration remedy (through
groundwater remediation). Therefore, the alternative will eliminate the
threat of direct contact with hazardous substances, and the future threat
of leachate production from the contaminated soil/residuals. The
groundwater plume at the site has not been fully characterized in the
lower aquifer. Although contaminated groundwater beneath the site will be
extracted (lower outwash lens and upper 25 feet of lower aquifer) to
control further contaminant migration, the extent of contamination in the
lower aquifer due to the Prestine, Inc. site is not known. There is a
potential multi-source groundwater contamination problem in the vicinity
of the site. The extent of contamination from Pristine, Inc. will be
determined by additional studies during the remedial design. This
remedial action, however, is considered the final source control remedial
action at the site.
Hazardous substances in the soil will be vitrified to permanently and
significantly reduce their toxicity, mobility and volume. The organic
compounds will be destroyed and the inorganic compounds will be
permanently encapsulated.
Because this is not a proven technology, prior to implementation of this
remedial action, bench and/or engineering pilot scale sudies will be
required to confirm the effectiveness and applicability of this .technology
to site conditions. Because of concern over the effectiveness of
vitrifying the upper outwash lens, consideration will be given, during
these bench and/or pilot studies, to whether the lens should be drained
prior to vitrification. A comprehensive program of testing and analysis
on the vitrified material will be conducted after the material cools
completely (cooling is expected to take three to five months). The
Toxicity Characteristic Leaching Procedure (TCLP) is the testing mechanism
that should be used to verify the complete treatment. If this treatment
method is found to be ineffective, this Record of Decision may need to be
reopened.
Monitoring will be conducted during the treatment process to determine if
contamination is migrating through the soil as a result of the treatment.
Consistency with Other Laws
Alternative 1A is designed to meet all applicable, or relevant and
appropriate requirements (ARARs) of Federal and State statutes. The
Federal ARARs include RCRA (40 CFR Part 260-271), OSHA (29 CFR Part 1910)
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Hie Safe Drinking Water Act (40 CFR Section 141.11 and .12) , and the Clean
Water Act (40 CFR Parts 122, 125 and 131). State ARARs include the Ohio
Revised Code (QRC) Chapters 3704, 3734, 3745, 6109 and 6111. Rules for
implementation of these requirements are contained the Ohio Administrative
Code (QAC) 3745.
The following specific ARARs will be met by Alternative 1A.
Groundwater
Three groups of Federal standards and criteria are considered to be ARARs
for groundwater at the Pristine, Inc. site; MCLs, RCRA Groundwater
Protection Standards, and Water Quality Criteria.
MCLs - Maximum Contaminant Levels established under the Safe Drinking
Water Act. These are the maxiJtnum contaminant concentrations allowed in
regulated public water supplies. These levels apply at the tap to public
water systems having at least 15 service connections or regularly serving
at
least 25 individuals. Levels are based on a chemical's toxicity,
treatability (including cost consideration), and analytical limits of
detection. MCLs are ARARs since the lower aquifer is presently being used
for drinking water and MCLs are the enforceable drinking water standard
for public water supplies. Since MCLs apply to water at its point of
distribution ( "at the tap" ) , these levels are appropriate for groundwater
at this site because wells that use the aquifer now, or residential wells
in the future, generally have minimal or no treatment. Thus, these
standards will have to be applied in the groundwater itself to ensure safe
levels at the tap.
Safe Drinking Water Act (?TVZA) - National Primary and Secondary Drinking
Water Regulations established under 40 CFR Section 141.11 and 141.12
include MCLs which are ARARs for the Pristine, Inc. site.
RCRA Groundwater Protection stapri^rrig - RCRA Groundwater Protection
Standards established under 40 CFR Section 264.94 include Background
Concentrations, Table 1 values, and Alternate Concentration Limits (ACLs).
These standards are specified in permits issued to hazardous waste
management facilities pursuant to RCRA. Pristine, Inc. had interim status
under RCRA. Therefore, these standards are ARARs. The following is a
discussion of these standards.
1. Table 1 Values - 40 CFR Section 264.94(a)(2) lists maximum
concentration limits (MCLs) for fourteen compounds. Three contaminants at
the Pristine, Inc. site exceed these listed values: arsenic, barium, and
lead. The levels are 50 ug/1 for lead, 50 ug/1 for arsenic, and 1,000
ug/1 for barium. These levels are based on the Safe Drinking Water Act
MCL, which is set at a level protective of human health and the
environment.
2. Alternate Concentration Limits (ACT-1^ - EPA may establish ACLs in
lieu of background levels or listed Table 1 values if the ACL "will not
pose a substantial present or potential hazard to human health or the
environment as long as the [ACL] is not exceeded." 40 CFR (264.94(b).
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Section 121(d)(2)(B)(ii) of CERCLA restricts the use of ACLs as cleanup
standards for on-site cleanups that assume a point of human exposure
beyond the facility's boundary. The selected remedy for the Pristine,
Inc. site does not assume a point of human exposure to contaminants
exceeding ACLs beyond the facility boundary; rather, the point of human
exposure includes the entire groundwater plume at, and migrating from, the
facility. Therefore, the restriction given at Section
121(d) (2) (B) (ii) does not apply at this site. ACLs may be used to
establish groundwater cleanup levels for the Pristine, Inc. site except
for those contaminants listed in Table 1.
When the overall health based cleanup standard of 1 x 10~6 cumulative
excess cancer risk at the plume boundary is met, by definition the
concentrations of the individual contaminants in the groundwater will not
present a threat to human health and environment. Those safe, residual
concentrations which result in an overall health based cleanup level of 1
x 10~6 cumulative excess cancer risk at the site boundary will be the
ACLs.
3. Background Levels - RCRA groundwater protection regulations
require that the concentration of a hazardous constituent must not exceed
background or the listed maximum concentration limit or the ACL. The
listed Table 1 values for barium, lead and arsenic must be met at the
site. ACLs for other contaminants will be health based levels.
Background levels are ARARs when the concentrations of contaminants in the
background exceed Table 1 values, ACLs or when the constituent has no
health-based level.
Water Quality Criteria (WCC) Established Under the Clean Water Act
Although the Clean Water Act (CWA) is not legally "applicable" to the
groundwater cleanup at the site, it is relevant and appropriate. Section
121(d)(2)(A)(ii) states that remedial actions shall attain water quality
criteria established under Section 304 or 303 of the CWA, where such goals
or criteria are relevant and appropriate under the circumstances of the
release or threatened release.
The aquifers beneath the site are current and potential sources of
drinking water. Therefore, WQC that have been adapted for drinking water
only are ARARs for the groundwater cleanup for the site.
SOIL
The contaminated soil in the magic pit area and the sediments will be
consolidated onsite. This alternative does not involve placement of soil.
The treatment method will be carried out "in situ". Therefore, 40 CFR
Part 268, the Land Disposal Restriction (LDR) does not apply. Subpart D,
treatment standards, will be considered. The relevant and appropriate
requirements of RCRA Subtitle C (Clean Closure and Landfill closure)
regulations will be met by the selected remedy. The selected remedy .
involves in-situ treatment of contaminated soil and sediment and
groundwater extraction and treatment at the site. Since in-situ treatment
will occur entirely within the area of contamination, disposal will not
occur as part of the selected remedy. Thus, RCRA closure requirements for
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30
clean closure and landfill closure are relevant and appropriate. This
allows ijrplementation of closure that meets the relevant and appropriate
requirements of RCRA clean closure/landfill closure.
A demonstration, involving groundwater or vadose zone monitoring, will be
made to ensure that the treated material and untrated residuals will not
migrate to the groundwater aquifer. A soil/vegetative cover will be
placed over the surface of the site to address any potential direct
contact threat. If the treatment method is effective to the point that
the material left in place meets the criteria for delisting or the
standards for risk-based closure, no RCRA-type cap is required. However,
if sampling demonstrates that these criteria are not met, a RCRA-type cap
may be required. It is assumed at this time that no RCRA-type cap will be
required.
Other
o Part 264.90-101. Compliance monitoring and corrective action will be
followed since hazardous waste has been released from the site.
Groundwater collection and treatnvent will occur onsite prior to
discharge. MZLs and ACLs will be used as minimum groundwater quality
requirements, except if background levels exceed these other values or no
health based ACLs, MZLs or other ARARs exist.
o Part 264.114 - All contaminated equipment, soils and structures must be
properly disposed of or decontaminated. This would include excavation
equipment, sampling equipment, and tanks.
o Part 264.116 - A survey plat indicating the location and dimensions of
the hazardous waste closure area will be submitted to the local zoning
authority, or the authority with jurisdiction over land use. The plat
will also be submitted to the U.S. EPA Regional Administrator and the
Director of the Ohio EPA.
o Part 264.14 and 264.ll7(b) and (c) - A 24-hour surveillance of the site
will be maintained during closure activities to prevent unauthorized
access. The use of the facility area must be restricted so that the
monitoring system is not disturbed.
o RCRA subchapter III, 42 U.S.C. 692l-6939b provides that U.S. EPA may
require corrective action necessary to protect human health or the
environment whenever U.S. EPA determines there has been a release of
hazardous waste from a hazardous waste management facility.
Health and Safety
o The remedial action contractor must develop and implement a health and
safety program for his workers. All onsite workers must meet the
minimum training and medical monitoring requirements outlined in 40 CFR
1980.
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Surface Water
o The treated groundwater discharged to the Mill Creek will meet the
technical requiregents of Section 402 of the CWA, the National Pollution
Discharge Elimination System (NPDES) requirements. Specific chemical
discharge limits will be developed for the groundwater treatment system
that will ensure protection of water quality and aquatic life in the
Mill Creek. Mill Creek is classified as a limited warmwater habitat.
The range of inorganic contaminants found in the groundwater and surface
water exceeds Federal acute and/or chronic water quality criteria (e.g.,
cadmium, copper, lead, mercury, and zinc). Ohio water quality standards
are also exceeded (e.g., cadmium, fluoride, lead and mercury). Ohio EPA
will determine limits on all parameters for effluent discharges from the
treatment facility based on Mill Creek's designated use and the
appropriate State Standards. Some further treatment prior to or after the
air stripper may be required. A bench scale study will be conducted to
determine the need for metals treatment.
Mr
o There are no ARARs directly derived from the Clean Air Act (CAA).
However, the risk from inhalation of contaminants from either the present
site conditions or as a result of remedial action leads U.S. EPA to take
migitative action i.e., add granular activated carbon to the air stream,
sample for radon gas or its decay products and treat the vitrified off-
gases.
Naturally occurring and accelerator produced radioactive materials (NARH)
are not covered by the Nuclear Regulatory Cormussion but by State
agencies. The Ohio Department of Health has juridiction in this case.
Ohio Revised Code
ORC Chapter 3734 provides statutory authority for the regulations of solid
and hazardous waste activities in the State of Ohio. As such, this
chapter as a whole can be applied to any remedial action as a State ARAR.
The Ohio EPA hazardous waste regulations developed on the basis of Chapter
3734 of the ORC can be found in Section 3745-50 to 3745-69 of the Ohio
Administrative Code. These regulations closely track U.S. EPA hazardous
waste regulation with few exceptions.
ORC Chapter 3704 establishes Ohio EPA's authority to regulate and control
air pollution within the State of Ohio. The rules developed and
promulgated by Ohio EPA to implement the authorities granted through this
law can be found in Sections 3745-15 to 3745-25 of the Ohio Administrative
Code.
ORC Chapter 6111 establishes Ohio EPA's authority to set water quality
standards (Section 611.04) and regulate water pollution sources. The
rules developed and implemented by Ohio EPA based on Chapter 6111 ORC are
contained in OAC Section 3745-1 through 3745-13.
-------
32
ORC Chapter 6109 establishes Ohio EFA's authority to regulate public
water supplies. The rules developed and implemented by Ohio EPA based on
Chapter 6109 are contained in OAC Sections 3746-81 to 3745-99.
The alternative will meet the technical requirements of ORC Chapter 3734
since these regulations are essentially the same as RCRA with the
exception of 3734.02(H), .05(c)(6), and 3745.53.11.
The air stripper will meet the requirements of ORC Chapter 3704. The
vitrification off-gases will also meet these requirements.
The State of Ohio, as an authorized state, manages the NFDES program
pursuant to the CWA. The technical requirements of the State NPDES
program will be followed.
All State ARARs will be met through the implementaion of Alternative 1A.
Table 9 shows the cleanup levels that will be met. (The 10~6 values are
not listed but may be used to develop the ACLs.) A cumulative list of
ARARs is contained in Chapter 5 of the FS.
Summary Discussion
Considering the various evaluation factors found in SPiRA Section 121(b)(l)
and the National Contingency Plan, Alternative 1A offers a cost-effective
solution to the contamination problem at the site. The principal threats
posed by the site are direct, contact with on and off-site soils and
ingestion of groundwater. In order to remedy these threats, Alternative
1A uses treatment as a principal element to the maximum extent
practicable. It reduces the mobility, toxicity and volume of
contaminants. In-situ vitrification of soils will eliminate the
possibility for contaminants to leach into groundwater. Groundwater
contaminants (both on- and off-site) will be removed and treated. This
alternative provides equal protection as Alternative 2A and is
approximately two times less expensive. The cost is comparable to off-
site disposal costs.
Based on the above analysis and the earlier discussions, the recommended
alternative is fully protective of public health and the environment,
cost-effective, utilizes treatment technologies to the maximum extent
practicable, and will attain all applicable, or relevant and appropriate
Federal and State requirements. According to Section 121(b)(2), an
alternative remedial action may be selected whether or not such action has•
been achieved in practice at any other facility or site that has similar
characteristics. The present worth cost of Alternative 1A is $21,731,000
and the annual O&M cost is $94,800.
-------
Table 9
ARARs
(ug/1)
M3JRCRA)
MT.
aldrin
arsenic 50
barium 1000
benzene
benzo(a)pyrene
beryllium
cadmium 10
chlorobenzene
chloroform (trihaloroethanes)
chromium 50
copper
DDT
dibutyl phthalate
1,2-dichlorobenzene
1,2-dichloroethane
1, l-dichloroethene
dieldrin
ethylbenzene
fluoride
hexachloroe thane
lead 50
mercury 2
pentachlorophenol
phenol
2,3,7,8 TCDD
tetrachloroethene
toluene
1,1,1 trichloroethane
trichloroethene
vinyl chloride
50
1000
5
10
100
50
1,000
75
5
7
4000
50
2
200
5
2
CWA
V1DC (drinking only)
0.0012
0.0031
0.0039
10
488
1,000
0.0012
0.00033
0.0011
2,400
5,200
10
1,010
3,500
(0)
0.88
15,000
2.8
-------
33
OPERATION AND MAINTENANCE
The recommended alternative requires seme annual Operation and Maintenance
(O&M) activity to ensure that groundwater will be extracted and treated to
meet ARARs. After the in-situ soil vitrification is completed, the
treatment facility built, and the extraction system constructed, several
O&M activities must be performed. Unsaturated zone monitoring must be
conducted to determine whether hazardous constituents migrate out of the
treatment zone. The vegetative cover must be maintained and be capable of
maintaining growth without extensive maintenance. A run-on and run-off
control system must be maintained. Onsite groundwater extraction and
treatment will be required for at least five years or until cleanup levels
are met in the groundwater under, and migrating from, the site. The
groundwater will be monitored. A fence around the site must be
maintained.
This remedial action start is one of the 175 sites comprising a statutory
goal for remedial action starts by October 1989. The following are the
key milestones for implementation of the remedial action in the event that
RD/RA negotiations are not successful.
Milestone Date
Approve Remedial Action (Sign ROD) December 1987
Initiate Remedial Design/Pilot Studies April 1988
Complete Remedial Design June 1989
Initiate Remedial Action (Award Contract) August 1989
Complete Remedial Action August 1991
FUTURE ACTIONS
Additional studies will be conducted to determine the extent of the
contaminant plume in the lower aquifer from the Pristine, Inc. site. It
is suspected that there is a multi source groundwater contamination
problem in the area. Because the problem is widespread, it may be
addressed under additional mechanisms such as new NPL listings, RCRA
corrective action, or Preliminary Assessment/Site Inspection (PA/SI)
activity.
The extent of remediation of the contaminated soil necessary to protect
human health and the environment has been defined based on actual
analytical results obtained during the RI and RI-2, and on modeling
conducted as part of the FS. In order to assure that an adequate cleanup
will be done at the site, confirmational testing will be done on the soil
which is vitrified as part of the bench and/or pilot scale studies.
Additionally, leachate tests may be conducted to confirm the expected
leachate production capacity of the contaminated soils. This may be
done in order to confirm these cleanup levels based on leachate production
which were defined in the FS, and the resulting volume of soil that needs
to be vitrified to meet these cleanup levels.
-------
-a:e V>.
:;/Ob/67
Iv'E RECORDS
P«I5T2NE INC.. REflDlNS. OHIO
INDEX TO DCCjltMTS REWRDIMS REMEDIAL ACTIONS
AUTHOR
BIT >SCNCLCGY, JC^I'* -OG
u.S.LP.fl.
J.5.E.P.fl.
J. S. E. P. A.
C.-2* HILL
DATE
PAGES
liO
7/SS/8S ?
i/U/83 105
5/83-4/83 76
•:?«:.;% - .:_.»£
ii?t hlu. \ ECCLJSY J ENVIRON. : 1/15/83 !50
5"C\. INC. 10/34 17
.a.E. ?.A. 10/24/64 £4
P. "YSCN 4/64-1/85 t2
r:-N' :%:. z/i/ss 60
RCj£j'.C5IC :£.-OR" I- -^IS'lNE - ClNCINNfi"
:£«tii4. :-,v*s':5A::oN REPORT ;?Pw:sfli
"."" SN CKE^VSTICN JF ;-i&£ II ;j FIELD P30GRAN
5I"E -H>x;\3 \ C'Jj-fi L'? I.NfiRlA'ICN
:K 35. -c.
7.-i5/66 i7!
iir .-iILL \ ECCLCGY i E-WISON. S/18/86 .SO
CDLQGY 4 ENVIROfffiENT INC. i/£7 60
4 .
j.S.E.P.w
4/67 ll'O
7/21/87 08
:0/26/87 12
\. a. 45
"' b
'i. fl. -6
\.t-. VA.
-------
ODHIN1STWT1VE RECORDS
PRISTINE INC., REflDING. Oh!3
INDEX TO DOCUNEVTS REGARDING REMEDIAL ACTIONS
fiLTHOR DflTE PflGES
- See 33. ,\o.7 U.S.E.P.fl. N.fl. 13
5e« B:. No.8 N.A. N.fl. 70
-------
Page No.
10/26/87
ADMINISTRATIVE RECORDS
PRISTINE, INC., READING, OHIO
INDEX TO GEKRAL CORRESPONDENCE
RE. T:'LE
DESCRIPTION
AUTHOR
DATE
PAGES
A
£
3
4
5
D
7
8
3
:o
11
\i
\l
14
15
GENERAL
CORRESPONDENCE
TRIP REPORT
GENERAL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
6ENERAL
CORRESPONDED
GE«ttL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
GENERA.
CORRESPONDENCE
GENERAL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
GENERAL
CORRESPONDENCE
DISCUSSION OF PUBLIC ICETIN6 - MARCH 6,
1385
MEETING WITH READING OFFICIALS - 8/80/86
UPDATE ON REMEDIAL INVESTIGATION TO
PAUL HANCOCK
OURSUAKT TO THE CONSENT ORDER OF 4/30/84
- SECTION 2(i)
CONFIRMATION THAT TANKS AT PRISTINE HAVE
BEEN REMOVED - 3/13/8*
CONFIRMATION OF TELEPHONE CONVERSATION
CONCERNING ADMINISTRATIVE ORDER
CONCERN OF CITY OF READING'S PLAN TQ
DEVELOP AN ADDITIONAL DRINKING VATER
tCU. ADJACENT TO PRISTINE SITE"
O.E.D.A. EVALUATION OF SURVEY CONDUCTED
ON THE CITY OF READING WATER SUPPLY
FORKAL SUWTTflL PRESENT!* THE RESULTS
OF BOTH SAMPLING EVENTS IN TABULAR
FORMAT. AND RECOMMENDATIONS FROM
U.S.E.P.A. I C.D.C. REGARDING THE SAFETY
OF yOTER CONSUMPTION
LETTER TO 'RESIDENT REAGAN, CONCERNING
•MASTEFUL SOVERMENT SPENDING AT PRISTINE
SITE, READING, OHIO
RESPONSE TO RILEY N. KIMMAN'S LETTER TO
PRESIDENT REAGAN
ICKJRANDUM: HHLTH ASSESSMENT
CLARIFICATION OF ISSUES RAISED REGARDING
THE EARLIER STUDIES ON THE RI/FS AT
PRISTINE SITE
SLWIT7AL OF STATDCNT OF UORK TO O.EPA
AND REQUEST TO RESPOND TO AN AGREEMENT
OF RI/FS
NOTIFICATION OF PROPOSED SUPERFIN)
PROJECT
MARGARET NcCUE
MARGARET NcCUE
NARY TYSON
RODGER C. FIELD
RODGER C. FIELD
RODGER XIT7
JOSEPH DUFFICY
REX BROUN
MARY TYSON
RILEY N. KINMAN
VLADAS V. ADAMKUS
STEPHEN MARSOUS
MARY TYSON
MARY TYSON
BASIL CONSTANTELOS
3/26/85
8/26/86
9/2/86
6/15/84
5/23/84
3/23/84
5/13/87
3/9/85
2/7/86
3/7/85
4/12/85
11/5/85
4/12/83
3/23/84
5/15/84
Total
47
-------
3ace NO. 3
ADMINISTRATIVE RECORDS
PRISTINE. INC.. READING. OHIO
GUIDANCE ooawEvrs LSED
~ITLE AUTHOR DflTE
ChE»r:;L. PHYSICAL AA'D BIOLOGICAL PROPERTIES OF COMPOUNDS U.S.E.P.A. 3/85
PRESENT
£R«£ST ftSScSSMEVT HftNDBOOK flT HflZflRDOUS WASTE SITES u.S.E.P.fl. 8/85
UND PUBLIC HEALTH EVALUATION "ANUAL J.S.E.P.A. ' 10/66
CN S/'F SELECTION OF R£!«EDr J. wINSTON PCRTER 12/S*/8S
ft. INTER IN GUIDANCE FGR 'a? RECORDS CF DECISION :. S.INSTCN PORTER 7/&4/B7
MANGE ON RADIAL INVESTIGATION UNDER CERCLA J.S.E.P.A • 5/85
CE 3N FEASISILTY STuCIES -JNDES CERCJ -.5. E.?.A. 4/85
I\-*uATION EXPOSURES IS THE nOȣ *3 VCLP'I.E ORGANS WKL1AN. J.B. 1385
CSN*Ar:sflN-S jF DSI.ShlNG WfER. SCI. TO'Au ENVIRONMENT
=C?.'L.S':> Wl^'iv c 2-!"lLE RADIOS Z.P *^E PRISTINE. INC. 51" CSCI. :/3;/S6
:N SND EVE:.T:VE :RDES isjie iseo
:ON ,»^ST-R ?_AN 3R:s*!v£. INC. C.N^ -ILL. ECIXCSY t EMVIROMCNT I-NC. 1333
5s:K3R3jND :-K:>E*:STRY :* SCTE ROCKS. SOILS. PLANTS AND U'.S.G.S. PROFESSIONAL OAPER 574-F \ WASHINGTON. o.c 2575
IN >E XusTEi!«LsaS UNITED STATES
JS£ jF .aS-NOR?ft. STATISTICS IN ENVIRONMENTAL NONITORIN6. COOPER, «.J. ed, CHEMISTRY IN HATES REUSE. VOL. 1 1931
-E':X"SEOUS ;€\rwTiCN OF SCHE PESTICIDES AND HERBICIDES FELDHONN. R.J.. AND WIBJCH. H. i. - TOXICOL. APPL. 1574
A 'AN. smaRflfiCOL. c:S:le:6-;3i.
::*E.T:;L :^EL;P"ENT AND RECHARGE OF BRCUNDHATER IN «ILL ;E:LCGICBL SURVEY WATER SUPPLY PAPER 1370 « :5S3
:SEZK vAL_EY. BUTLER AND HAMILTON CXNTIES, OHIO. BASED CN
ANALV5IS.
NSlrf-ER. PREs'ICE -.Ai., EN5LE-OOD CLIFFS. %€W JERSE-r. FREEZE. R.A.. AND CHERRY. J.A. 1979
EN P::A ;ND &LKD .E>D IN AREAS OF DICING GALLACHER. J.E.J.. ELUOOD. P.C., PHILLIPS. K.«., ise*
. : ARCH. DIS. >I.D. SS:40-"4 i DAVIES. P.E., AND JONES, D.T.
r ";->rc^L :\';KE5 rRC"" RELfi'ICNSHJP OF .A'E* GI'— IE5, ". E. . -ND PALI IN. r-.V. 1533
i\L'.'S»Ji:'."ijiR DISEASE. IN*. ;. F?:;E«IICL.
-------
Page No.
10/28/87
TITLE
ADMINISTRATIVE RECORDS
PRISTINE, INC., READING. OHIO
GUIDANCE DOOJICNTS USED
AUTHOR
DATE
HANDBOOK ON ATMOSPHERIC DIFFUSION. ATMOSPHERIC TJRBULENCE HANNA, S.R., BRIGGS. G.A., AND HOSKU. R.P.
AND DIFFUSION LABORATORY, NATIONAL OCEANIC S ATMOSPHERIC
ADMINISTRATION.
ASSESSMENT CF HEALTH RISK FROM EXPOSURE TO CONTAMINATED
SOIL. RISK ANALYSIS 5:269-302:
PERSONAL COMMUNICATION WITH FIRE CHIEF
«AWLEY,J.K.
"QtLYHEYER, FIRE CHIEF
INTERFACIAL REACTIONS AND THE FATE OF HEAVY TALS IN SOIL HUANG. C.P.. ELLIOT. H.A..AND ASHMEAD. R.M.
MATER SYSTEMS. J. MATES POLLJTI^ CONTROL F-D. 49:745-756
DRAFT SUPERFUKD PUBLIC HEALTH EVALUATION MANUAL PREPARED
FDR THE OFFICE OF EKER6EXCY AND RE«OIAL SES
REPORT OF THE TASK GROUP ON REFERENCE «AN.
J.S.E.P.A. !
9265.4-1 )
5tRGfl«CV -"RESS. *F* YORK - lNT£5NfiT!CW;.
•IC'WISIOf FOR RADIDL2GICAL PRDT-CTIDN liZS
i?65
1977
:965
VETESNflRY MTKlLUGY. 5tn ed.
MEAL^ :»iBLicfi':DNS CF 2.2.7.B-TF
iTCCDDl CCNTfWINATIDN OF SESIDE^IAL SCI..
SND -ESIaER."
;. TQX::DL. ENVIRON. HEAL'^ :4:47-rri - •:
:..:.. r5LK, -. . S"-R. I., A;,D r':iS.. I-.
:-
"?-:.•:--. :?e«
ROLE If SIRKRSE ^EflD IN INCREASE; fODY BLPDiN CF .-J-'u :N ESV;-:^ ",EML> ^ESPE". 7:?5-lOi - L--^. .*.„.. ;"4
INVESTIEA'IDNS INTO SOL'RCES 3? -E.-D > TnE r.WI^^EN' :F ;::d
O1LDERN.
FLUX CF GASES ACROSS THE AIR-SEA IVTESFflCE. NA'.-RE
£47:161-164
^NDBOOK CF CHEKICAL PROPERTY ESTIMATION »TrCC3:
£NVIROM€NTAL E&AVIOR OF ORGANIC CCHPOUNCS'.
.ISS. ;.S. ;ND SLS'ER. P.G.
-:C-=«--L. 3JC.< ::r:-ANY, \£« »CSK - ..,»;,N, I..;.
:375
1574
)TIC FATE PROCESS DATA FOR ORGANIC PSIC9ITY ;C-_..-i',-3. -;P£>, ».s.. i«I>. J...-!., :CK.L. ^.'.. :;.-,SG\,
PREPARED BY SRI INTERNATIONAL FOR u.5. ENVIRONMENT^ XL., 'iLi., J.. ->.0u. *.w. , Zv'ES. ;. . ^"RIJSE.
PROTECTION AGENCY, OFFICE OF W~R SESJLA'ICvS ft\D I.-., JABER, -., iND VANDt^Er.S, D.
STA^DARDS. !«N1TORIN6 AND DftT; SUPPORT D.'VISIJN, ^SHINGTC'N.
D. C, EPA CONTRACTORS 68-01-2667 SND o8-03-i981
ftGISTRY OF TOXIC EFFEC'S OF ZHE'ICAu kBrs
-------
Page No.
10/28/87
TITLE
ADMINISTRATIVE RECORDS
PRISTINE, INC., READING, OHIO
GUIDANCE DOCUMENTS USED
AUTHOR
DATE
CINCINNATI, OHIO. NATIONAL CLIMATIC DATA CENTER,
ASHEVILLE NORTH CAROLINA.
PERSONAL COMMUNICATION.
CITY OF READING, HAMILTON COUNTY, OHIO, INVENTORY REPORT
'RANSFORWATIONS OF TTTRACHLCROETHANE AND TRICHLOROETHANE
IN MICROCOSMS AND BRGUNDWATER.
CCNMERCIAL
OND WRXETINS GUIDE. K4th ed.
EXPOSURE TO LEAD BY ^E ORAL AND THE PULMONARY ROUTES OF
CHIDERN LIVIN6 IN THE VICINITY OF A PRIMARY LEAD SMELTER.
FLJO?:DE 1377. NATIONAL RESEARCH COUNCIL OF
CANADA, sRC ASSCCIS'E Xf*:"I- 3N SCIENTIFIC CRITERIA FOR
ENVIROMtNTAL DUALITY. OTTatfl. CANADA, NRCC So. :6081
RI3< SNALYSIS FDR T^DD CONTAXINATED SOIL. OFFICE OF
itA^'H AND ENV:RON"D»TAL ASSESSMENT, U.S. EPA,
rflSiI.SGTON, D.C. EPA eCiO-6-« 1-031
AIR QL'ft-ITY ftSSESSIEV W LAND DISPOSAL OF INDUSTRIAL
«ASTE£. ENVIRON. MANAGE. 6:297-305
3ERSONAL SDMWJNICA^ION, READING «ATER TREATMENT 5LAKT.
KU»US DOIS™. J>N *l'J?t ( SONS, NEW YORK
PERSONAL COMHJNICATION . LOCXLAKD WATER TREATMENT £>JNT.
•CKKBOOK OF ATMOSPHERIC DISPERSION ESTIMATES, u.s.
OEPARTI-eWT OF HEALTH, EDUCATION AND WELFARE, CINCINNATI,
OHIO.
NATIONAL ENGINEERS r^DBOOK. SECTION 4i KrDRXOBY
SOIL SURVEY OF HAMlLTuN COUNTY, OHIO. SOIL CONSERVATION
SERVICE. COLUMBUS. OHIO.
1IXINB MEISHTS, HIND SPEEDS, AND POTENTIAL FOR URBAN AIR
POLLUTION *«SOu6nCUT r^E CONTISClS UNITED STATES. OFFICE
J SIR P'OGSAMS. DIVISION OF flETESOLOSY. RESEARCH
JARX, NCRTH CAROLINA. PB-iC7l03
NEED, E.A. P-BRUARY :2, ;5e
OHIO ENVIRONMENTAL PROTECTION AGENCY (OEPA) :384
RES. TECHNOL. op56-59 FEBRUARY, ;3ft4
RAND McNALLV AND CO. 1983
ROELS, H.A., BUOCT, J.P., LAUUERYS, R.R.,
BRUAUX, P., CLAEYSTHOREAU, F., LAFONTAINE, A., 1980
AND VERDUYN, G. - ENVIRONMENTAL RES. £2:81-94
ROSE, D. AND MARIER, J.R.
SCr*UK, J... 1984
SHEN, T.J. 1982
SHORTER, D. FEBRUARY, isec
o
STEVINSON, F.J. ' 1982
SURBER, S. FEBRUARY, ::3£'
TURNER, B.D. 1970
U.S. DEPARTMENT OF AGRICULTURE 1372
U.S. D£3«RT»ENT OF AGRICULTURE AtC-UST 1362
-------
P*ge No. *
10/28/87
TITLE
ADMINISTRATIVE RECORDS
PRISTINE, INC., REPDIN6, OHIO
GUIDANCE DOCUMENTS USED
AUTHOR
DATE
AMBIENT WATER DUALITY CRITERIA FOR POLYNUCLEAR AROMATIC ' U.S. EPA
HYDROCARBONS. OFFICE OF UATER REGULATIONS AND STANDARDS,
CRITERIA AND STANDARDS DIVISION. EPA 440/5-80-069
QUALIFY ASSESSMENT: A SCREENING PROCEDURE FOR TOXIC U.S. EPA
AND CONVENTIONAL POLLUTANTS. PART 1. ENVIROM€NTAL RESEARCH
JURATORY, 37 ICE OF RESEARCH AND DEVELOPMENT.
=EDERAL REGISTER PART V, NATIONAL OIL AND HAZARDOUS
SUBSTANCES CONTINGENCY PLAN
U.S. EPA
fEALTH EFFECTS ASSESS*VT FOR LEAD. ENVIRONMENTAL CRITERIA US. EPA
AND ASSESSMENT OFFICE, CINCINNATI, OHIO EPA 540/1-86-055
NAT:GNA. PRIORIT:ES LIST. 876 CURRENT AND PROPOSES SITES
IN ORDER CF RANKING AND BY STATE.
jlIDANCE ON FEASIBLE S'JDIES UNDER CE?CLA.
-AZARMuS WAST! ENGINEERING RESEARCH LABORATORY,
CINTINNRTI, OHIO.
rEALTH ADV'ISORY FOR HAD. DRAFT. OFFICE OF DRINKING
WATER, UflSHINGTON, D.C.
CADMIUM *ALTH ADVISORY. DRAFT. OFFICE OF DRINKING
WiTER , WASHINGTON, D.C.
DRINKING WATER CRITERIA DOCUMENT FOR CADMIUM. FINAL
DR«n. CRITERIA AND STANDARDS DIVISION, OFFICE OF
DRMI«€ WATER, WASHINGTON, D.C.
3UIDELINES FOR DC HRATH RISK ASSESSMENT OF
>E.»!lCflL KUTJRES (50 FR 1170-1176).
: EAST QUADRANGLE, OHIO-HAKILTON co. 7.5 MINUTE
SERIES (TOP06RAPNIC). PHOTOREVISED 1961
DRAFT SUPERFUND EXPOSURE ASSESSMENT MANUAL. PREPARED
FOR OFFICE OF EMERGENCY AND REMEDIAL RESPONSE, U.S.,
EPA, WASHINGTON. D.C.
u.s. EPA
J.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S.G.S.
VERSAR, INC.
OCTOBER 1980
1332
JULY :6,:9fl3
1984
OCTGfiER 1984
APRIL :3fi5
SEPTEMBER 15S5
APRIL I9fl5
JANUARY 1985
1981
1986
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Page No. 7
::/06/B7
REC. TITLE
DESCRIPTION
ADMINISTRATIVE RECORDS
PRISTINE, INC., READING, OHIO
INDEX TO DUOJMENTS REGARDING PUBLIC AFFAIRS
AUTHOR
DATE PAGES
1 PUBLIC AFFAIRS U.S.EPA ORDERS SURFACE CLEAN UP BY PRI57IIC, INC.
2 PUBLIC AFFAIRS FACT SHEET: PRISTINE, INC. SITE
3 PUBLIC AFFAIRS PUBLIC (€ETIN6: READING, OHIO, AGENEDfl
4 PUBLIC AFFAIRS DISCUSSION OF PUBLIC MEETING - MARCH 6, 1985
HARY TYSON 3/20/84
U.S.E.P.A. REG. V 3/85
U.S.LP.A. REG.V 3/6/85
MARGMET McCUE 3/26/85
5 PuEtlC AFFAIRS OFFICIAL NE*S RELEASE TO BRIEF RESiDENTES ON PRISTINE, INC. SITE *WY TYSON 2/21/85
o PUBLIC AFFAIRS CCVER LETTER FOR FACT SHEET - TO PERSONS INTERESTED IN PRISTINE MARY TYSON 3/23/86
7 PUBLIC AFFAIRS FSCT ShEF: SUPERFUND PR06RAK REMEDIAL INVESTIGATION UPDATE U.S.E.P.A. 7/86
1
4
1
1
1
1
4
*** "ota; •*«
:3
-------
Pioe NO. I
10/88/87
TITL£
ADMINISTRATIVE RECORDS
PRISTINE, INC., READING, OHIO
INDEX TO T>€ PLEADINGS FILE
AUTHOR
DATE
:EMRT!€NT OF JUSTICE TRANSJIITTAL TO U.S. ATTORNEY
J. S. vs. LON6S - COMPLAINT
J.S. vs. .ONG - •€» :N SUPPORT OF IltQIflTE ORDER IN
AID CF ACCESS
(DOJ) 3/6/87
U.S. ATTORNEY - SOUTHERN 3/12/87
DISTRICT OF OHIO
U.S. ATTORNEY 5/7/87
I'.S vs. LONGS - COURT ORDER GRAFTING ACCESS
U.S. ATTORNEY
5/12/87
-------
Administrative Record Index (Continued)
CERCLA as Amended by SARA
National Oil and Hazardous Substances Contingency Plan (NCP), 40 CFR Part 300
Letter from Lee M. Thomas to Honorable James J. Florio dated May 21, 1987
Interim Guidance on Compliance with Applicable or Relevant and Appropriate
Requirements by J. Winston Porter dated July 9, 1987
Hazardous Waste Management System; Land Disposal Restrictions; Final Rule
40 CFR Part 260 et a!.. Friday, November 7, 1987
Letter from Mary Tyson to Donald Sullivan dated November 25, 1987, with
attachment
"In Situ Vitrification of Transuranic Waste: An Updated System Evaluation
and Applications Assessment". Battelle, March 1987
June 25, 1987 - Letter from Pristine Group (Jernigan) to U.S. EPA (Conway)
July 9, 1987 - Letter from Pristine Group (Sullivan) to U.S. EPA (Dufficy,
Tyson, Conway)
August 7. 1987 - Letter from Pristine PRP Group (Sullivan) to U.S. EPA (Tyson)
August 11, 1987 - Letter from U.S. EPA (Conway) to Pristine Group (Sullivan)
August 13, 1987 - Letter from U.S. EPA (Conway) to Pristine Group (Jernigan)
September 17, 1987 - Memorandum from Weston (Rae Mindock) to U.S. EPA (Tyson)
October 19, 1987 - FOIA request from Dames and Moore (Fred Erdmann) to U.S. EPA
(Robert Hartian)
October 28, 1987 - Letter from Pristine Group (Sullivan) to U.S. EPA (Conway)
November 6, 1987 - Letter from Pristine Group (Sullivan) to U.S. EPA (Conway),
with attachment
November 9, 1987 - Letter from Weston (Mindock) to Dames and Moore (Erdmann)
November 18, 1987 - FOIA response from U.S. EPA (Mary Gade) to Dames and Moore
(Erdmann)
November 24, 1987 - Letter from Pristine Group (Sullivan) to U.S. EPA
(Jenni fer Hal 1)
No/ember 25, 1987 - Letter from U.S. EPA (Tyson) to Pristine Group (Sullivan),
with attachment
December 3, 1987 - Letter from U.S. EPA (Conway) to Pristine Group (Sullivan)
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-2-
December 22, 1987 - FOIA response from U.S. EPA (Gade) to Pristine Group (Sullivan)
Public Comment Draft Feasibility Study, Pristine, Inc., November 12, 1987
Addendum to the Remedial Investigation, Pristine, Inc., December 28, 1987
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SUMMARY OF REMEDIAL ALTERNATIVE SELECnOSr
PRISTINE, INC.
READING, OHIO
SITE LOCATION AND DESCRIPTION
The Pristine, Inc. site is located in southwestern Ohio in the City of
Reading (population 12,843), a suburb of Cincinnati. The site occupies
approximately two acres in the northeast quarter of Section 33, Township 4,
Range 1 in Hamilton county, Ohio (Figure 1). The site is bordered by
residential and industrial areas (Figure 2). Cincinnati Drum Service,
directly west of the site, cleans, reclaims, and recycles steel drums.
Carstab Corporation, directly south of the site, manufactures synthetic
stabilizers and plasticizers. The irrTnediate eastern limit of the site is
bordered by Conrail Railroad right-of-way. Three hundred feet northeast of
the site, beyond the railroad, is a residential trailer park. The land to
the north is owned by the City of Reading. Eight municipal water supply
wells serving the citizens of Reading are located approximately 300 feet r
northwest of the site.
Mill Creek flows from north to south approximately 600 feet west of the
site. The creek is not used as a drinking water source or for recreational
purposes although intermittent fishing in the creek has been observed. It
discharges to the Ohio River 14 miles downstream. The average yearly
precipitation is approximately 40 inches. Approximately six inches is
accounted for by recharge to groundwater flow systems.
The Pristine, Inc. site is situated over the buried valley of the Deep
Stage Cincinnati River, a glacial-aged river fed by meltwater that eroded
several hundred feet into shale and limestone bedrock. Outwash and other
glacially derived sediments, which are about 180 feet thick in the vicinity
of the site, were subsequently deposited in this valley. The Pristine,
Inc. site is situated on a low terrace that is about ten feet higher than
the floodplain of Mill Creek, which now drains the valley. The edge of
this terrace is marked by an escarpment which coincides with the western
border of the site. The Pristine, Inc. site is not located within the 100
year flood plain, or in a wetlands area.
The site geology consists of five distinct soil units (Figure 3), fill,
upper lake sediment glacial till, lower lake sediment, and lower outwash
deposits. There are two aquifers under the site. The upper aquifer lies
within the upper lake sediments and the lower aquifer lies within the lower
outwash deposits. Within the upper lake sediments, there are three lenses
that are interconnected; the upper, middle, and lower lenses. The upper
aquifer consists of three perched water systems flowing within the lenses
in different directions moving downward through the till to the lower
aquifer (Figure 4). At the eastern edge of the site, the upper aquifer
system lies directly on top of the lower aquifer.
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oreot'KJ By CM2M MILL Novemoe' 1983
FIGURE 1
SITE LOCATION MAP
PRISTINE, INC. SITE
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Grain FacMtot
Municipal
Wa«
FMd
Municipal
Fly-Avh
Dtopoaal
TraiarParh
G v
-------
Thlcfcn««t
0-10
(»t.)
0 - 4«
10 - 48
16
•orlr>9
Cnd*d in
ThU Unit
Fill
Upper Lake Sediment (Upper Aquifer)
Upper Outwesh Lena (UOL)
Middle Outwaah Lena (MOD
Lower Outwaah Lena (LOL)
Glacial Till
Lower lake aediment
Lower outwash deposita (Lower Aquifer)
FIGURE 3
GENERALIZED COLUMN UNDER THE PRCTfJE. WC. STTE
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FIGURE 4
CONFIGURATION of UPPER AQUIFER
in RELATION to LOWER AQUIFER
PRISTINE INC. SITE
5/5
565
555
545
5J5
525
515
505
575
585
555
545
535
535
515
5O5
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FOR T>JF RFYT3RD OF DECISION
PRISTINE, INC. SITE
READING, CHIO
PURPOSE
This decision document represents the -selected remedial action for the
Pristine, Inc. site in Reading, Ohio. It was developed in accordance with
the Conprehensive 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 Contingency Plan (40 CFR Part 300).
The State of Ohio has been consulted on the selected remedy and has
indicated that a letter of concurrence is forthcoming.
The selection of remedy is based upon the Pristine, Inc. Site
Administrative Record. The attached index identifies the items which
comprise this record.
SELECM'HI
This final source control remedial action consists of the following:
Excavation and onsite consolidation of 1,725 cubic yards of sediment
and soil;
In-situ vitrification to an average depth of ten feet across the
site ;
Installation of a french drain along the eastern site boundary;
Extraction of groundwater from the lower outwash lens/ lower aquifer
using at least one extraction well;
On-site treatment of groundwater using air stripper with discharge to
Mill Creek;
Decontamination of structures followed by removal and disposal at a
solid waste landfill; and
Access and deed restrictions, and groundwater monitoring.
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DECLARAnCN
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate, and is cost-effective. As mandated by CERCIA as amended by
SARA, the remedy satisfies the preference for treatment that reduces
toxicity, mobility, or volume as a principal element. Finally, I have
determined that this remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Date
Valdas V.
Regional Administrator
U.S. EPA, Region V
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DECLARATION FOR THE RECORD OF DECISION AMENDMENT
Site Name and Location
Pristine, Inc.
Reading, Ohio
Statement of Basis and Purpose
This decision document presents the new soil component of the
Pristine, Inc. remedial action in Reading, Ohio. The Record of
Decision (ROD) is being amended for the soil component in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA) , as amended by the Super fund Amendments and
Reauthorization Act of 1986 (SARA) and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) . This decision document explains the factual and
legal basis for amending the soil component for the Pristine,
Inc. site. The remaining components of the remedy are identical
to the ROD executed on December 31, 1987.
The Ohio Environmental Protection Agency concurs wirn amending
the Pristine, Inc. ROD.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions
selected in this Record of Decision (ROD) Amendment, may present
an imminent and substantial threat to public health, welfare, or
the environment.
Description of the Revised Remedy
The overall remedy components are now as follows:
the top one foot of so it
across
and all other soils from the present ground
surface to four feet below ground surface that contain
semi -y ol a t i^e^prgafnjt^rcompounds and pest d^c ides in*
excels "6 f^ Performance Goals and rSJfeand.a1r,ds^., In tf
addition, on-sliger incinera t ion. • of sediments: and,, i..^
necessary, gU!rt«P>nwr^tfWari^C^|g«agic Pit will^occuri
The Magic Pit "is' a~ cdncrete linea pit which was used to
store and treat hazardous materials on-site. ,.,~t^^
Incinerator 'residue r&U^vbia^oiaced back on the"sit'e*?- .
'cap if it meets substantive
depth- of approximatelyi- 12 :'. f eet ^ The in-situ soil vapor
extraction system will be used to ctaMMM» the upper
-------
aquifer. The extracted groundwater will be treated at
the site using carbon adsorption;
3. Performance of an additional groundwater investigation
to delineate fully the lower aquifer contamination
associated with the Pristine site in order to design
and construct an extraction and treatment system. The
conceptual design, based on current information, calls
for the installation of a groundwater extraction weK.
to withdraw contaminated groundwater from the lower
aquifer and lower outwash lens of the upper aquifer;
4. Construction and operation of an air stripping system
>to'treat lower aquifer groundwater and a carboni:
adsorption system to treat upper aquifer groundwater;
5. Decontamination and demolition of all on-site
structures and disposal of the debris in a sanitary
landfill;
6. Construction of a fence along the western edge of the
property to restrict access;
7. Deed restriction*, and
8. Installation of a groundwater monitoring system orr\and
near the site to monitor groundwater flow and quality.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technologies to
the maximum extent practicable for this site. Treatment of the
principal threats of the site are achieved and the remedy
satisfies the statutory preference for treatment as a principal
element.
of remealar adtion to ehsuret^fS^t^^^aeay^ continues to provide
adequate protection of human health and the environment. A five
year review is necessary because this remedy will result in
hazardous substances remaining on-site above health based levels.
Valdas V. AdanOcus /? Datte
Regional Administrator
U.S. EPA, Reoion V
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Decision Summary for the Record of Decision Amendment
1. Site Background
In November 1987, U.S. EPA notified over 130 Potentially
Responsible Parties (PRPs) of their liability at Pristine,
Inc. and invited them to negotiate with U.S. EPA for the
design and construction of the final remedy. A 120-day
negotiation period was established and ended March 29, 1988
without an agreement. The remedial design was begun with
the initiation of an Interagency Agreement with the U.S.
Army Corps of Engineers (U.S.A.C.O.E.).
On March 31, 1988, the PRPs proposed the use of in-situ soil
vapor extraction technology instead of in-situ
vitrification, claiming that in-situ soil vapor extraction
would be equivalent to the performance of in-situ
vitrification. The U.S. EPA and the U.S.A.C.O.E. evaluated
the PRPs' proposal and determined that while in-situ soil
vapor extraction would address the volatile organic
compounds, it would not, however, mitigate the threats from
semi-volatile organic compounds and pesticide contamination
in the surface soils.
Upon incorporation of incineration as a means of addressing
the non-volatile contaminants and pesticides, negotiations
were reopened with the Pristine PRPs and an agreement was
reached between U.S. EPA and the Pristine PRPs in December
1988, contingent upon U.S. EPA amending the December 1987
ROD by replacing in-situ vitrification with
incineration/soil vapor extraction as the soil component of
the remedy.
2. Highlights of Community Participation
The Proposed ROD Amendment and technical review documents
have been made available to the public in the administrative
record located at the Valley Public Library, Reading, Ohio
and the Reading City Hall. The notice of availability of
these documents was published in the Cincinnati and Reading
newspapers. A public comment period on the documents was
held from November 6, 1989 to December 6, 1989. In
addition, a public meeting was held on November 30, 1989.
At this meeting, representatives from U.S. EPA answered
questions about problems at the site and the ROD Amendment
under consideration. A response to the comments received
during this period is included in the Responsiveness Summary
which is part of this ROD Amendment.
3. Description of Soil Remedy Change
The soil component of the December 1987 ROD consisted of
in-situ vitrification for the upper twelve (12) feet of soil
-------
across the site. The in-situ vitrification will be ^placed
with incineration/soil vapor extraction. See Figure : and
Figure 2 for a layout of the Pristine, Inc. Site anc i Zone
location map. The following are the major componen4 , for
the soil component of the remedy:
1. Excavation and incineration (mobile on-site thermal
treatment) of:
a) the top one (1) foot of soil across Zone A (the
volume to be incinerated will be determined by a
boundary survey);
b) sediment from the drainage ditches along the
northwest boundary of Zone A and along the
northern boundary of Cincinnati Drum Service
(existing data and additional sampling will be
used to delineate the volume of sediment to be
treated);
c) all Zone A soils that contain non-volatile
contaminants above the Performance Goals and
Standards outlined in Table 1 from a level of one
(1) foot below present grade to a level of four
(4) feet below present grade;
d) all Zone B soils that contain non-volatile
contaminants above Performance Goals and Standards
in Table 1 from present grade to a level of four
(4) feet; and
e) Magic Pit (located in Zone B) soils that contain
non-volatile contaminants above Performance Goals
and Standards in Table 1 to a level of four (4)
feet below and to a level of four (4) feet onto
the three unexposed side walls of the Magic Pit
itself.
2. The incinerator ash will be tested to determine if the
ash meets delisting criteria established under RCRA and
Ohio Solid Waste Regulations. If the delisting
criteria are met, the ash will be disposed of as a
solid waste on Zone A under the RCRA multi-media cap.
Alternative treatment/disposal methods will be
required if portions of the ash do not meet delisting
criteria; and
3. Design, construction, operation and maintenance of an
in-situ soil vapor extraction (ISVE) system, which
shall include an off-gas control system, to mitigate
VOC contamination in Zone A and Magic Pit portion of
Zone B soils. As a result of ISVE, the upper twelve
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TABLE I
PERFORMANCE GOALS AND STANDARDS
SOIL AND SEDIMENT
A. Volatile Compounds
Chemical Concentration (ug/kg)
Benzene 116
Chloroform 2,043
1,2-Dichloroethane 19
1,2-Dichloroethene 285
Tetrachloroethene 3,244
Trichloroethene 175
B. Non-volatile Compounds
Chemical Concentration (ug/kg)
Aldrin 15
DDT 487
Dieldrin 6
PAHs 14
2,3,7,8-TCDD (Dioxin) 0
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(12) feet of Zone A and the Magic Pit portion of Zone B
will be dewatered, including the upper outvash lens.
Groundwater extracted from the ISVE trenches and well
points will be treated in the Facility treatment plant
using carbon adsorption. A multi-layer cap sh'll be
installed over Zone A to minimize water infiltration
to the Zone A soils and shall meet the RCRA performance
criteria for the duration of the post closure period of
30 years. The RCRA cap will also prevent short
circuiting of air to the portion of the ISVE system to
be constructed, operated and maintained in Zone A.
4. Performance Goals and Standards
The Performance Goals and Standards that the soil/sediment
cleanup must meet are presented in Table 1. The
soil/sediment Performance Goals and Standards are based on a
cumulative 1 X 10~6 incremental lifetime cancer risk of
eleven indicator compounds examined in the RI Public Health
Evaluation.
5. Evaluation of the New Soil Remedy and the Previously
Selected Soil Remedy
The nine evaluation criteria U.S. EPA considers when
selecting a remedy and a comparative analysis between the
previously selected soil component and the new soil remedy
are listed below:
o Overall Protection of Human Health and the
Environment - Both the new recommended soil remedy
and the previously selected soil remedy provide
adequate protection of human health and the
environment by mitigating and minimizing risk
through treatment and institutional controls.
Each remedy uses treatment to the maximum extent
practicable.
o Compliance with ARARs - Both the new recommended
soil remedy and the previously selected soil
remedy would meet-all applicable or relevant and
appropriate requirements of Federal and 3tate
environmental laws.
o Long-term Effectiveness and Permanence - The new
recommended soil remedy and the previously
selected soil remedy would treat the contaminated
soil to levels which protect identified receptors.
The treatment technologies employed would be
effective in the long-term and permanent because
the contaminants of concern would be removed from
the soil and destroyed, or trapped in a solidified
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Drainage
Ditch
Runoff
Collection
Pit
o
i
pi
Conrall
Pristine Site Layout Map
-------
\ \\\\\ \\ ,
A .Mil. r*.'r-
/ \ l»l / (—
K)
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mass. Both remedies require the same degree of
long-term maintenance and monitoring as both have
cap or soil cover maintenance requirements.
Reduction of Toxicity. Mobility, or Volume - Both
the new recommended and previously selected soil
remedies provide a significant reduction in the
toxicity, mobility, or volume of soil contaminants
through the use of permanent treatment
technologies.
Short-term Effectiveness - Both the new soil
remedy and the previously selected soil remedy
present some degree of short term risks to on-site
workers and potentially to businesses and
residences near the site through potential air
emissions. The air emissions from the in-situ
soil vapor extraction/incineration technology
combination are easily controlled and monitored.
Air emissions will be funnelled to a pipe or
stack, where they would be controlled and
monitored. The air emissions from in-situ
vitrification technology are more difficult to
control because they are emitted from a large
surface area, as opposed to a stack. The new soil
remedy will take approximately seven years to
complete while the previously selected soil remedy
would take three years to complete.
Implementability - The new recommended soil remedy
component offers several advantages over the
previously selected soil remedy component in terms
of implementability. Incineration and in-situ
soil vapor extraction are proven technologies and
are easily implemented. Administrative approvals
are necessary as the trial burn, incineration
residue testing, and residue disposal program must
be approved by the U.S. EPA and the State. With
the exception of the mobile on-site incinerator,
all services and materials are readily available.
The recommended change in the soil remedy does not
cause any additional long-term maintenance or
monitoring requirements. On the other hand, the
in-situ vitrification technology is_not proyen^p.r,.
U.S. EPA plann^F^lovwnnRSrsHtu- vitrfficatioS?
another site in Ohio prior to implementing the
technology at the Pristine site. This however has
not occurred. Therefore, a full scale field test
would need to be conducted before implementation
of in-situ vitrification at Pristine. In
addition, because in-situ vitrification is still
-------
an emerging technology, the number of firms
offering the necessary services to design and
implement it is limited.
Cost - The total cost for design and construction
of the new recommended soil remedy and the
previously selected soil remedy are listed below:
New Soil Remedy $11,270,000
Previously Selected Soil Remedy $19,417,000
A cost comparison between in-situ vitrification
and incineration/soil vapor extraction is located
in Table 2.
State Acceptance - The State of Ohio concurs with
the new soil remedy.
Community Acceptance - The specific responses to
public comments are located in the Responsiveness
Summary.
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PRISTINE SOIL REMEDY COST COMPARISON
In-situ Vitrification3
In-situ Soil Vapor Extraction
Incineration
Excavation 19,000
Vitrification 10,600,000
Excavation3 33,000
Vapor Extraction13 3,000,000
Incineration0 2,433,000
RCRA Capa 447,000
Soil Sampling13 250,000
CONSTRUCTION $10,619,000
SUBTOTALS
Health & Safety 1,062,000
Contin. 10%
Bid Contin. 20% 2,124,000
Scope 2,124,000
Contin. 20%
Construction $15,929,000
Total
Legal 5% 796,000
Construction 1,593,000
Services 10%
Total $18,318,000
Implementation
Costs
Engineering
Design 6%
1,099,000
TOTAL COSTd $19,417,000
$6,163,000
616,000
1,233,000
1,233,000
$9,245,000
462,000
925,000
$10,632,000
638,000
$11,270,000
aBased on Pristine Feasibility Study costs
bU.S. EPA conservative estimate based on other sites
C3,600 yd3 top 1 ft of site + 1,125 yd3 Magic Pit + 1,000 yd3 sediments =
5,725 yd3 at $425/yd3, per FS ash delisted and placed back on-site
^Does not include O&M present worth
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PRISTINE, INC. SUPERFUflu fc!.«:TE
READING, OHIO
RESPONSIVENESS SUMMARY
Summary of Comments Received During the Public Comment Period
1. Comment: Riley Kinman, Pristine, Inc.
The No Action Alternative is the only appropriate response
for the cleaned Pristine, Inc. site under CERCLA.
U.S. EPA Response: The No Action Alternative is not
appropriate for the Pristine site. Risk levels remaining at
the site are above levels the U.S. EPA deems acceptable to
protect human health and the environment. Please see the
Pristine, Inc. public health evaluation and the previous ROD
Responsiveness Summary.
2. Comment: Riley Kinman, Pristine, Inc.
The comments provided on Dec. 3, 1987 are attached and are
still valid and are hereby made a part of this comment
document.
U.S. EPA Response: Since this ROD Amendment is an addendum
to the original ROD, your previous comments and U.S. EPA
responses are still part of the public record for the site.
3. Comment: Riley Kinman, Pristine, Inc.
We were pleased to see the U.S. EPA agreed with us, finally,
on the in-situ vitrification proposal.
U.S. EPA Response: U.S. EPA's decision to modify the soil
component of the remedy was based upon an evaluation of the
same criteria utilized in the original ROD. While the
Agency believes that the original remedy provides a good
balance among those criteria, the hew soil component
provides an even better balance of the nine criteria.
4. Comment: Riley Kinman, Pristine, Inc.
Incineration of Pristine soils may produce a large quantity
of sulfur dioxide (S02) at the site if the elemental sulfur
in the soil is caused to burn.
U.S. EPA Response: The emissions from incineration of soils
at the Pristine site will meet all National Ambient Air
Quality Standards for sulfur dioxide. U.S. EPA has
determined that these standards are protective of human
health arid the environment.
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5. Comment: Riley Kinman, Pristine, Inc.
S(>2 production at the site by this procedure would be in
violation of the Clean Air Act and Comprehensive
Environmental Response, Compensation and Liability Act of
1980.
U.S. EPA Response: Please see U.S. EPA response for Comment
4.
6. Comment: Riley Kinman, Pristine, Inc.
Demolition of buildings at the Pristine site and disposal in
a sanitary landfill does not appear consistent with the U.S.
EPA strategy for recycling and reuse to minimize disposal in
scarce sanitary landfills.
U.S. EPA Response: While the Agency is committed to the
broadest possible application of the concept of recycling,
we are limited by the space available at this site. The
successful implementation of this remedy is dependent upon
removal of all surface soils for incineration and the
necessity of having an impermeable cap to prevent short
circuiting during the vapor extraction phase. These needs
combined with the need for a staging area and water
treatment plant location preclude the relocation of the
demolition material on-site.
\
7. Comment: Riley Kinman, Pristine, Inc.
Deed restrictions do not appear appropriate for the Pristine
site.
U.S. EPA Response: Deed restrictions are necessary since
hazardous materials will remain on-site under a RCRA cap.
Deed restrictions will prohibit any activities that would
affect adversely the integrity of the cap. The cap must not
be disturbed to prevent the migration of the remaining on-
site contaminants.
8. Comment: Riley Kinman, Pristine, Inc.
It is doubtful that the remedies proposed will do anything
substantive to improve the quality of groundwater at the
site, due to the presence of other sources of pollutants at
the site that will not be addressed by these remedies.
U.S. Response: The Agency is aware of Pristine's setting
within- a regional groundwater problem. However, from the
Remedial Investigation, it is also obvious that the site is
introducing its own contaminant loading to the aquifer.
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Thus, remedial action at the Pristine site is necessary to
eliminate contaminants attributable to the Pristine site
from the regional groundwater problem. Also, should the
need arise, the Agency retains the authority to respond to
any emergency conditions, including groundwater
contamination, identified in the region.
9. Comment: The Pristine Group
The Pristine Group strongly supports the Agency's decision
to select in-situ soil vapor extraction/incineration as the
remedy for the'Pristine, Inc. facility rather than the
experimental ia-situ vitrification remedy that was
originally proposed. The vapor extraction/incineration
remedy is not only entirely consistent with the requirements
of CERCLA, but :is also more protective of the environment
because of in-situ vitrification's propensity to cause
migration of chemicals away from the site.
U.S. EPA Response: The U.S EPA agrees that the
incineration/soil vapor extraction remedy will achieve the
same cleanup standards and provide a better balance of the
nine criteria that U.S. EPA uses in selecting a remedy.
However, the statement that in-situ vitrification promotes
chemical migration of chemicals has not been proved one way
or the other. 'The U.S. EPA considers the original soil
component and the new soil component equally protective of
human health and the environment.
10. Comment: The Pristine Group
Many of the inorganic compounds and metals detected in
groundwater samples from lower aquifer wells occur naturally
(e.g., calcium, iron, magnesium, manganese, potassium,
sodium). The statement that "their presence in the
groundwater indicates groundwater quality has been
compromised" is not correct to the extent it implies that
these substances originated from the Pristine Site.
U.S. EPA Response: Due to the diverse amount of waste taken
to the Pristine, Inc. facility, the possibility exists that
calcium, iron, magnesium, manganese, potassium and sodium
were present in waste delivered and are breakdown products.
The commentor is correct that many of the above listed
compounds occur naturally and additional sampling during the
design phase will verify if they are naturally occurring.
11. Comment: The Pristine Group
The ESD states that the Pristine incinerator ash "contained
furans and dioxins." As a point of clarification, it should
be pointed out that the 2,3,7,8-TCDD congener, which is
-------
considered to be the most toxic of the dioxin and /'..ran
compounds, was not detected in the incinerator residue or
soil samples collected during the RI (with the exception of
one soil sample where the compound was also detected in the
laboratory blank sample, indicating laboratory
contamination of the sample). Further, since dioxins
exhibit a high affinity toward soil and tend to remain on or
near the surface of the soil (see Health Assessment Document
for Polychlorinated Dibenzo-p-Dioxins," EPA/600/8-84/014F,
September 1985), and since such compounds have a low
solubility in water, it is unlikely that the groundwater
would become contaminated with dioxins. No dioxin has been
detected in any prior groundwater sample at the Pristine
Site.
U.S. EPA Response: The dioxins and furans mentioned refer
to total dioxins and furans and not just 2,3,7,8 TCDD
congener. In addition, the commentor is correct that dioxin
was not detected in sampling performed in the Remedial
Investigation, but the statement "it is unlikely that
groundwater would become contaminated with dioxins" is based
upon conjecture. Additional sampling and analysis during
Remedial Design will verify the presence or absence of
dioxin.
12. Comment: The Pristine Group
The EPA states that "in-situ soil vapor extraction would
work as well as in-situ vitrification for VOCs." In fact,
the soil vapor extraction technology is the better
technology because, unlike in-situ vitrification, it does
not provide a driving force for the uncontrolled migration
of organic compounds. In this regard, the gradual heating
of the soil zone with in-situ vitrification forces the
volatile compounds to migrate away, particularly through the
more permeable soil zones. (See Battelle Pacific Northwest
Laboratory Report: "In-situ Vitrification of Transuranic
Wastes: An Updated Systems Evaluation and Applications
Assessment," March 1987.)
•
U.S. EPA Response: The U.S. EPA disagrees with the commentor
that in-situ vitrification is not as effective as in-situ
soil vapor extraction for treating volatile organic
compounds. In-situ vitrification treats volatiles, semi-
volatiles, and pesticides, in contrast to in-situ soil vapor
extraction, which only treats volatile organic compounds.
Please see U.S EPA response to Comment 9.
13. Comment: The Pristine Group
Figures 3 and 4 are conceptual only and should be described
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as such.
U.S. EPA Response: Figures 3 and 4 are included in the ROD
Amendment to give the public a general picture on how the
soil vapor extraction system operates. The Figures are not
intended to be design documents.
14. Comment:: The Pristine Group
The statement, "The new recommended site remedy would take
approximately seven years to complete while the previously
selected soil remedy would take approximately 3 years to
complete", is misleading. Overall, both remedies would take
the same length of time to complete because the lower
groundwater extraction/treatment system would be the same
for both.
Furthermore, the in-situ vitrification component has a
longer lead time for implementation than the vapor
extraction component. As originally planned, the in-situ
vitrification component was to have been tested at another
site (Greiner's Lagoon) before implementation at the
Pristine Site. However, as acknowledged in the ESD (pg 10),
that test has not been conducted. Thus, since EPA maintains
that the vitrification component must be subject to at least
a "full scale test" before being considered for use at
Pristine, the time required for completing the vitrification
component at Pristine is uncertain —and in fact is probably
much longer than that required for the soil vapor extraction
methodology. At the very least, it cannot be concluded that
the vitrification component could be completed sooner than
the vapor extraction component.
U.S. EPA Response: The commentor is correct in stating the
overall Pristine, Inc. timeframe from the original ROD to
the new site remedy is identical, since the groundwater pump
and treat has not changed. Nevertheless, on a day to day
implementation basis, the in-situ vitrification component
should require as much as 4 years less to complete than the
incineration/soil vapor extraction combination. Also, a
full scale test for in-situ vitrification at Parsons
Chemical in Michigan is near implementation.
15. Comment: J.A. Bischof, Millcreek Valley Conservancy District
On behalf of the Millcreek Valley Conservancy District we
would urge your office in carrying out any corrective action
at this site to eliminate the flow of any contaminated water
into the east branch of the Mill Creek since that drainage
may endanger the completed project and those maintaining
that facility.
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U.S. EPA Response: The remedy for the Pristine, Inc. site
will not discharge contaminants into Mill Creek. All
effluent discharged into Mill Creek from the soil vapor
extraction and groundvater pump and treat systems will meet
Federal and State discharge requirements.
16. Comment: Concerned Citizen
"The City has been informed about ineffective water wells
since 1943. It appears someone has their priorities
reversed. The article I read concerning the procrastination
of the city to do anything alarms me. Their cavalier
attitude toward the public's well being and the agencies not
pursuing the issue, to resolve a problem that defines Super
Fund imminent danger, appears contrary to the approach they
have taken toward this PRP group - 18,000,000.00?"
"The wells have been surrounded by heavy industry for years.
The thought of these so-called toxins migrating since the
government took over the site and nothing being done amazes
me! Is there a problem? Are the facts correct or
overstated regarding contaminants found on the site close to
the wells. Your studies indicate a potential problem but
not imminent. The water wells are imminent".
"Your desire to clean up the site is admirable, but myopic.
The real public danger is with the agencies's penchant, to
penalize and deceive the public, instead of working together
to encourage waste solutions. The citizens of Reading have
been deceived for years. Did they shut down Exxon or Union
Carbide for their atrocities,, or did our constitutional
currency interfere?"
"What did this small corporation do to create an expense of
18 million dollars? I cannot wait to read your response
when it is published."
U.S. EPA Response: Absent future corrective actions, the
Pristine, Inc. site does pose an imminent and substantial
endangerment to the public health and the environment. If
the site remains as is, contaminants will continue to
migrate from the site and further affect the lower aquifer
which is a source of drinking water. Risk levels calculated
for the site in its current state are above those U.S. EPA
deems acceptable to protect human health and the
environment.
Currently, the City of Reading's water supply is in
compliance with the State and Federal standards and is
subject to routine monitoring. U.S. EPA is aware that
Pristine is part of the regional groundwater problem.
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17. Comment: Pam Speers, Reading Ohio
"The question on many peoples mind concerning the
environment deals mainly with the tax payers money use in so
called "clean-up". Cleaning up the environment is good, but
to continue to push stupid issues just to soak the people
of America for money is ludicrous. How does the public
even know if superfund money was used to clean-up the site
in Reading."
"According to the article and newspaper in the library,
superfund money wts designed, but I believe a released
itemized statement showing the breakdown of monies issued
would be more appropriate. I believe the only superfund
money spent in Reading, Ohio was the issue of salaries to
the absent minded EPA people working on a dead issue. My
God people, the site has been cleaned up for years. What
else can we do? How much money is being pocketed by the
"EPA Group"? Are you on commission? You people just want
to kick a sleeping dog. There is no just reason for more
law suits and penalties against "...nase people. Maybe the EPA
should take a long look at their ~easons for continuing the
harassment. Is it personal?, Pu_.ic? , What then? Making
examples of small business versus he wonderful government
site of Fernold, plus Exxon, Chemc_ne, and Union Carbide
Corporation is hardly what the tax payers of America want.
Examples are not worth tax money. It can be used for more
responsible tasks. Get busy with "Imminent Danger" sites
and stop bleeding the people of Reading, Ohio and America."
U.S. EPA Response: Absent future corrective actions, the
Pristine, Inc. site does pose an imminent and substantial
endangerment to public health and the environment. The
responsible parties are voluntarily funding the cleanup at
the Pristine, Inc. site, so the use of Superfund monies is
not needed. In addition, monies already spent by U.S. EPA
are being reimbursed by the responsible parties. Both
considerations allow U.S. EPA to focus its limited resources
on those sites where voluntary private party actions are
impossible.
18. Comment: Concerned Citizens of Reading, Ohio
"After reviewing the Material at the Reading Library, t
appears the USEPA has forced the PRP Group into a sett ement
that is not only costly but greatly overstated, regarding
the method and amounts of contamination. The cleanup
started back in 1980, and it is now 1989, Evidently this
site has been on a priority list that the federal USEPA
uses to determine the most dangerous sites. This list
consist of firms that have put the public in imminent danger
or risk of being harmed. If the site has been in the hands
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8
of the USEPA and State for nine years, (that is longer than
the Pristine site existed), then wouldn't the USEPA be
responsible for some of the cost regarding this supposedly
"imminent dangerous" site? Is this site or should this
site even be on this priority list? According to some of
the information in the Remedial Investigation and
Feasibility Study, the site should not cost the public
$18,000,000.00 through higher prices. If the site is a
priority superfund site, you would think that the people who
have been in charge for the past nine years. At least the
owners or someone did more in one and one half years than
the USEPA has done. Who is guilty? Is this superfund
deception drawn out unreasonably to make the Agency look
good for cleaning up a site, that, according to studies and
affidavits submitted is clean."
"Does the USEPA know something that they don't want to admit
for their own selfish benefit? Is the site clean? You must
justify and substantiate the decision, forcing corporations
to pay for a site where there are various differences and
feelings regarding the studies and what should be done to
this site. These decisions greatly reflect the
constitutional freedoms of every citizen in the United
States."
"It is ironic but the publics only harm may come from its
own government and agencies. This is a problem that is
paramount, it has and will continue to have a huge adverse
effect on our economy an desire to provoke interest in the
future to eradicate environmental problems. The government
should take a different approach if there is any difference
on the method and monies needed to eliminate this problem.
Your reward would be greater felt by all if you took a more
logical approach."
"In summary, why does the government sponsored studies
indicate that $18,000,000.00 should be spent for a site that
is rated 531 out of 734, and the #2 rated site is only going
to cost $20,000,000.00? Cleanup has already taken place and
studies show that the site is clean and safe. Your efforts
are fine, but to spend $18,000,000.00 for a site, according
to your studies is clean is ludicrous."
"Thank you for reading this, concerned citizens deserve a
response. We are concerned and want corporations to pursue,
in a prudent and legal manner on ideas and methods to handle
hazardous waste safely. Pristine attempted and appears
their insight to handle future environmental problems (which
are numerous) was truncated by an unfair, nearsighted
agency."
U.S. EPA Response: The U.S. EPA does not agree with your
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statement that the Pristine, Inc. site is clean. Acceptable
risk levels of 1 additional cancer case in a million are
exceeded in both soil and groundwater at the Pristine, Inc.
site by as much as 10,000 times in a worst case scenario.
The funds to be spent to cleanup the site and past costs of
U.S. EPA will be paid by the responsible parties. The
Agency shares your concern about having only legally
reputable and competent companies in the waste disposal
industry.
The ranking of the Pristine, Inc. site on the National
Priorities List does not have a bearing on the cost of the
remedy since the nature and extent of contamination was not
determined prior to scoring the site.
20. Comment: Coalition of Reading
"After reviewing some of the articles that have been written
since the Pristine, Inc. case, we have discovered an article
that seems to depict a double standard with the USEPA, Ohio
EPA on how they handle private corporations versus city or
municipal problems. The article written in the Cincinnati
Enquirer (May 5, 1989) indicated that environmental
officials, dating back to 1943, have been trying to persuade
the city of Reading to upgrade their water system. EPA
official more recent, in the same article, indicated that
the water wells are surrounded by industrial plants. The
levels of contamination exceeds the Federal standards but
the state according to the article will not take any legal
action as long as the city is earnestly pursuing an
alternative, ignoring the ongoing and very imminent water
treatment problems. The proof is obvious, but the state is
giving them a chance even though the proof is there and has
been for years. The state knowing the treatment facility is
antiquated and not doing the job, is sad commentary from
officials who have shown some disregard to the public
health, which seems more threatened by this than the so
called migration of contaminants from a nearby site that,
according to studies, have not been proven."
"The toxins that have been identified in the lower aquifer,
originate from what direction, and do they match the toxins
found at the Pristine site? It appears, according to
studies and articles at the library, that the so called
phantom imminent danger and abandoned site criteria have
been ignored. The real issues to the citizens of reading
should be the water wells themselves and their location.
This problem is real and not based on potential and is an
imminent danger to the public health, which is what
superfund is all about."
"What an enormous amount of money and effort wasted while
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10
the real danger of having inadequate water wells still
exist. Maybe we should alert the toxins that they are
migrating from somewhere to wait until we take care of some
of the paper work. Is there a real problem? What do these
R.I. and Feasibility studies really show? The citizens will
pay again through higher cost because the government is
playing games. Any discrepancies or question marks
regarding data should be answered and justified. This site
should not cost the public and citizens of the United States
$18,000,000.00 so an agency who so far has only cleaned up
27 sites out of 1200 promote their unnecessary quest. Start
now and do something that the citizens will be proud of and
won't have to pay for."
U.S. EPA Response: To the best of the U.S. EPA's knowledge/
the water being consumed by the users of the Reading public
water supply is safe even if individual production wells are
contaminated. Should this not be the case and no
alternative exists, the U.S. EPA has the authority and
responsibility to assure that the situation is remedied.
The Superfund law was enacted with a goal of total cost
reimbursement and/or private party cleanup implementation
for each site. At the Pristine site all of the government's
past costs and the complete burden of the remedy's
implementation is being taken up by the responsible parties.
Comment: William A. Bronnin, Reading, Ohio
"How could the EPA ever ok a site like this for chemical
waste. It is located next to a creek and one hundred yards
from a residential suburb. I personally think the EPA
should be held accountable for the damage and buy all the
property around this area. The people that live in or near
the area have a higher cancer rate anywhere else in the
world."
"How could the EPA have 19.4 million dollars ok'd for
cleanup over two years ago, and not do this cleanup. What
are you waiting for."
"The second method is no good because you waited to long.
The chemicals are much deeper than 12 feet underground."
"I have lived by this waste site for 28 years. My neighbors
children tell stories of seeing the workers burying drums
under ground 15 or 20 years ago."
"The people in this area think it is hopeless to talk to
government officials. They feel and I do too, that the EPA
doesn't care about people. They just want to harass and
collect more money from tax payers."
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11
"If the EPA is not going to clean-up this mess, which was
their fault to begin with, I know they will never cleanup
the metro sewer system which has been obsolete for 25
years."
U.S. EPA Response: The Pristine, Inc. facility was a
private corporation that was poorly operated. The remedial
investigation determined the nature and extent of
contamination with the data showing that the surface
contamination has not migrated away from the site, but
groundwater has been affected by the Pristine contamination.
The responsible parties have agreed to finance the cleanup
of the site to levels which are protective of human health
and the environment. The property surrounding the Pristine,
Inc. site is not contaminated, therefore it is not required
that properties be purchased. Once the cleanup is
completed, the potential for migration of contamination
offsite will be eliminated.
The U.Sc EPA was going to fund the original remedy and try
to recover costs at a later date from the responsible
parties, but the responsible parties submitted a proposal to
cleanup and finance the site remedy if U.S. EPA changed the
soil component of the Pristine ROD. The U.S. EPA, U.S. Army
Corp of Engineers and the State of Ohio reviewed the
responsible parties' proposal and determined that the
necessary cleanup standards would be met with the new remedy
for the contaminated soil. The design for the site remedy
should begin in a few months.
Your concern that chemicals have migrated more than 12 feet
below the surface will be verified in the design phase when
we will perform additional sampling. Sampling performed
during the Remedial Investigation was the source of the 12
feet. In addition, during the Remedial Investigation,
extensive underground testing for buried metal such as drums
was performed and it was determined that buried materials
were not present at or near the site.
The Agency encourages public participation and will
periodically issue fact sheets to keep the public updated on
the progress of the cleanup at the Pristine, Inc. site. The
Agency plans to oversee an effective cleanup at the
Pristine, Inc. site that is protective of human health and
the environment.
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PRISTINE,
ONISI
MARCH 1987
JL> SITE
DH3KEE
Pages Date
100+ 3/29/88
4 7/27/88
50 8/5/88
3 8/15/88
2 8/22/88
2 8/24/88
16 12/6/89
6 12/6/89
1
30+
90+
Pitle
Petition for EPA
to Consider New
Info & Reconsider
ROD
Follow-up to
7/20/88 technical
meeting
Evaluation of
SVE at Pristine
Proposed Remedy
Offer
Author
Pristine
Group PRPs
Recipient
J. Duff icy
USEPA
Dave Ross J.Dufficy
Pristine Group USEPA
AOOE - EA USEPA
Engineering,
Science &
Technology, Inc.
Dave Ross T. Oonway
Pristine Group USEPA
Conditions for Dave Ross F. Covington
Reopening Pristine Pristine Group USEPA
Remedy Negotiations
Response to 8/22/88 Dave Ross F. Oovington
letter accepting Pristine Group USEPA
negotiation
conditions
Explanation of
Significant
Differences
Fact Sheet for
ROD Amendment
& Consent Decree
Newspaper
Advertisement
Public Meeting
Transcript
Consent Decree &
Remedial Action
Plan & Attachments
T.Alcamo
USEPA
USEPA
USEPA
USEPA
United States
Pristine PRPs
Public
Public
Reading
File
District
Court
Doc Type
Report
Letter
Report
Letter
Letter
Letter
Plan
Fact
Sheet
News Ad
Transcript
Decree
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