United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-88/084
September 1988
SEPA
Superfund
Record of Decision
Republic Steel Quarry, OH
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'0272. 101
REPORT DOCUMENTATION /1. 'REPORT NO. /2. 3. Recipient's Accession No.
PAGE EPA/ROD/R05-88/084
4. Title and Subtitle 5. Report Oate
SUPERFUND RECORD OF DECISION 09/30/88
Republic Steel Quarry, OH 6.
First Remedial Action - Final
-- -
Author(s) 8. Performing Organization Rept. No.
9. Performing Organization Name and Address 10. Project/Task/Work Unit No.
- - ----- ---I
11. ContractlC) Or GrantCG) No.
CC) I
CG) I
12. Sponsoring Organization Name and Address -- -------------- - ..1
U.S. Environmental Protection Agency 13. T,.. .1 R...rt & Po,;" c.,.... ]
401 M Street, S. W. 800/000
Washington, D.C. 20460 1~ I
15. Supplementary Notes .~
16. Absg8ct ~Llmit:t!~. worm 1 Quarry site is located in the City of Elyria in Lorain County,
T e epu 10 ee
Ohio, southwest of Cleveland. The site is situated between West River Road and the West
Branch of, the Black River, directly west across the river from Franklin School. The
site consists of a four-acre quarry containing water surrounded by seven acres of
fenced-in property. Elyria surrounds the site, with a populat ion of approximately
58,000. Prior to 1950, the site operated as a sandstone quarry. From 1950 to 1972, I
approximately 200,000 gallons of waste pickle liquor (acid wastes used in steel
,nocessing) were discharged to a ditch located on the east side of the steel plant,
which flowed north into the quarry. From 1972 to 1975 the ditch was used for disposing
of rlnse water from plckllng operatlons. The dltch was dammed ln 1976 and after thls
time sulfuric acid used to pickle the steel reportedly was disposed of directly into the
quarry. Heavy metals were detected in ground water downgradient from the quarry during
a site investigation conducted by EPA in 1983. Further study identified low levels of
numerous contaminants in the ground water. Sediments and surface water within the
quarry contain VOCs and metals. Approximately 100 yd3 of surface soil from the
discharge ditch are contaminated with VOCs and metals. The primary contaminants of
concern affecting surface water, sediments, and soil are VOCs including toluene, and
(See Attached Sheet)
u
17.~c~t ~'t8'~~c!-sq,~Ptors
Republic Steel Quarry, OH
First Remedial Action - Final
Contaminated Media: soil
Key Contaminants: VOCs, metals
---
ent lers/ pen. Ended Terms
c. COSATI Field/Group
'v.ilability Statement 19. Security Class (This Report) 21. No. 0' Pages
None 35
-.----- --
20. Security Class (This Page) 22. Price
None
b Id
lfi
o
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FOR". 272 (4-77)
(Formerly NTIS-35)
Oepartment 0' Commerce
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EPA/ROD/R05-88/084
Republic Steel Quarry, OR
'irst Remedial Action - Final
16.
ABSTRACT (continued)
metals including chromium and lead.
The selected remedial action for this site includes: excavation and offsite disposal
in a RCRA landfill of approximately 100 yd3 of contaminated. surface soil from the
pickle liquor discharge ditch and from along the southern end of the quarry;
implementation of a five-year monitoring plan including a fish species survey and fish
tissue bioassay to ensure absence of contaminants; and ground water monitoring. The
estimated present worth cost for this remedial action is $63,200. O&M costs were not
provided.
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/0
IE::U\RATIn the Rep.Iblic Steel Quarry Site
Administrative Record. The attached index identifies' the items which
comprise this record.
~CN
This final remedial action consists of the following:
Excavation of approximately 100' cubic yards of contaminated soil
that are located (l) in the ditch previously used to discharge
pickle liquor to .the quarry' and (2) along the southern end of the
quarry ;
DisFOsing excavated. soil according to RCRA regulations.
Because low levels of hazardous substances will reIPain on site, the five
year facility review will apply to this action. SF;ecific tasks
reccmnended as part of this mni toring process are.:
Conducting a fish ~ies survey and fish tissue bioassay to assure
the absence of contaminants. The survey will identify fish species
present in the quarry. Fish tissue samples will be collected from
each species.
Resampling grotmdwater to assure the concentrations of any
contaminants are at acceptable risk levels.
IE::U\RATICN
The selected renedy is protective of ht.nTIaIl health and the environment ~
attains Federal and State requirements that are applicable or relevant and
appropriate, and is cost-effective. Due to the limited scope of this
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remedy, the statutory preference for treatment will not be met. The small
volume and levels of contamination present in the soils do not make
treatment a cost-effective alternative. Finally, I have determined that
this remedy utilizes permanent solutions to the maximum extent practicable.
g/3-0/gZ .
Date
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SUfwM\RY OF REJ.1EDIAL AL~ SELECl'Irn
RERJBLIC S'DR. ~ SI'JE
ELYRIA. ana
SITE JW:::KGEUJND
Site Location and DescriPtion
TIle Republic Steel Quarry site is located in the City of Elyria, Ohio which
is southwest of Cleveland in Lorain COlll1ty (see Figure 1). TIle site is
located between West River Road and the West Branch of the Black River,
directly west across the river from Franklin SChool (see Figure 2). TIle site
. may be found on the Grafton USGS quadrangle map in Township 5 North, Range 17
West.
TIle site consists of a four-acre quarry containing water and seven acres of
fenced land surrounding the quarry (see Figure 3). Water in the quarry has
been measured at depths up to 62 ft. TIle sides of the quarry are nearly
vertical and rise to an average of about 25 ft. above the quarry water
surface elevation. Quarry walls are COIT1IX>sed of Berea Sandstone at and below
present water level and to varying heights alx>ve the present water level.
Quarry walls alx>ve the sandstone are COIT1IX>sed of vertically stacked, large
sandstone blocks.
Site Phvsioqraphv
Lorain COlll1ty, in which the Republic Steel Quarry site is located, is on the
eastern fringe of the till plain area of the Great Central Lowlands. TIle .
top:>graphy is generally flat to gently rolling. TIle surface slopes gently
from a high elevation in the southern part of the COlll1ty to a low elevation
at Lake Erie. Exceptions to the nearly flat toJ.:X)graphy are gorges of the
Black River near Elyria and the site. TIlese gorges eX!X)se the underlying
bedrock. .
Vegetation imnediately adjacent to the quarry perimeter is rrostly grass and
small brush; however, larger trees are found around the site and along the
river. Vegetation is fairly dense over rrost of the site.
Porolation
TIle Republic. Steel Quarry site is located in the west side of the City of
Elyria, which has a pJpulation of approxinately 58, OOQ. TIle economy of the
city is sllppJrted primarily by rrore than 150 small, light industries. The
neighborhOOd around the site is largely residential.
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ERIE
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LTV
STE::L. PLANT
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C:TY CF EL.YRIA
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Site Historv
The Republic Steel OJarry' site was operated as a sandstone quarry' during an
unknown period of time prior to 1950 when the quarry began to be used for
pickle li~r diSFQsal. Pickle liquor is an acid. used to dissolve oxides
present in mill scale that forms on steel during the hot rolling process.
Republic Steel reportedly discharged approxinately 200,000 gallons of pickle
liquor into the quarry each year frc:m 1950 to 1972.. Waste pickle liquor was
re:fX)rtedly p.Imped. through an a.J:ove-ground pipe to a ditch, located on the
east side of the plant, which flow'eQ. north into the quarry. From. 1972 to
1975, the ditch was still used to direct rinse water from. steel pickling
operations into the quarry. In 1976, the pickle liquor discharge ditch was
darrTred about 100 feet south of the site fence. L'IV's records indicate that
sulfuric acid was used to pickle the steel and was diS:fOsed in the quarry.
In 1981, Republic Steel COrpJration notified EPA of its past dis:fX)sal
activities to comply with Section 103(c) of CERcrA.. In respJnse to Republic
Steel's notification, the U.S.. EPA. Field Inv"'eStigation Team (FIT) contractor
performed. a site investigation for EPA in. late 1983 and installed. three
rom toring wells. N)' organic contamination was detected at the site;
. however , heavy metals such as chromium, arsenic, lead, cadmium, magnesium,
aluminum, and iron were detected. in the groundwater at higher levels in the
dOwn-gradie."1t rronitoring w"ell than in the up-gradient wells. The site was
evdJ.uated. using the Hazard Ranking System (HRS) and proFOsed to be included
in Upjate II of the National Priorities List (NPL).. The site was listed on
the NPL on O:tober 16, 1984.
o
At the request of LTV Steel, IT COrpJration (IT) conducted an investigation
of the site in NOvember 1984 that included. sampling and chemical analysis of
quarry 'Nater samples and EJ?l:..-installed roni toring wells. This inv"eStigation
conc lOOed. that EPA.' s score should be recomputed based on el.;i.dence obtained in
their investigation. AccQrding to IT, tJ1e re--ccm;;:uted score would not be
hiC;h enough for the site to be inCluded cn -:"'1e NPL. On Decenber 13, 1984,
L~'" Steel sutmitted a letter to £FA. sc:atir..g ~'1eir objection to the. quarry's
inclusion on the NPL. IncluJect with t.he let.ter was a copy of IT's re:fX)rt as
slJF.p:)rting evidence. The letter st.ated tha1:. the-results of IT's studY
concluded that the quarry had virtually returned to its original natural
corm tion.
£.p.~ re'lie,'iBd the IT data and concluded that original HRS score for t11e
Republic Steel ~i~as correctly calculated, and that the site srDuld
r-erain on the NPL Upjate II list. On January 8, 1986, EPA. sutmi ttOO a
lett.er to t..i1e State of Ohio Clearing House for rev-ietJ. under tl1e State
Intergovenunental Re'lieTtJ Process. In this letter, U.S. £FA. prop)sed a
~.1/-FS :or the Republic Steel Quarry.
On nay 9 I 1986, Ohio £FA revie..,red the Statement Of WJrk for the RIfFS and
ir~ca~~j G~eir willingness to support and assist the program in a letter to
U.S. £?A, Region v.
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Enforcement Activities
Before commencing Remedial Investigation activities, in April of 1986,
U. S. EPA offered the opp:>rttmi ty to conduct the work to the two p:>tentially
resp:msible parties; L'IV Steel, fonner owner of the site and the City of
Elyria, present owner' of the site. Because the parties disagreed over the
necessi ty for listing the site on the NPL, L'IV and the City of Elyria would
not agree to conduct the Rerredial Investigation under the Agencies'
ov"ersight. U.S. £PA, therefore, corx:lucted ~e RI in cooperation with Ohio
EPA..
COpies of the Prop:>sed Plan for the Republic Steel Quarry site were sent to
the public in£onnation repository on septeniber 1, 1988 and the PRPs were
informed that U.S. EPA intended to conduct a remedial action at the site.
~ial NOtice Letters will be sent, which will establish a sixty (60) day
ITDratoritml to provide opporttmity for the PRPs to suJ::rnit a good faith
prop:>sal to carry out'the Remedial ~ion (RA).
CXJ.MJNITY REU\TIrt and the
Prop:>sed Plan.
The City of Elyria has shown a high level of interest in the site because the
city is a PRP~ Major concerns of the city include:
o
City officials have concluded fram private studies
that the site has returned to natural conditions
and that it should not have been listed on the NPL.
City officials do not believe they should be held
liable to pay for remedial actions conducted by
U. S. EPA because they plrchased the property in
good faith fran L'IV Corp:>ration.
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Concerns of the Izaak Walton League include:
The nature of contamination in the quarry pit.
The environmental impact of contaminants from
the site upon the Black River.
Potential health impacts on the cOITll1Lmity.
The future use of the site area. IWL rnenbers
would like to see the site cleaned up so that
it is avai lable for public use.
Residents living near the site did not consider the possible contamination to
be a pressing issue, according to the city cOt.n1Cilman representing the 5th
"ward. .
SITE ~Z7\TICN
Remedial Investigation field work was initiated Jlme, 1987 and was completed
during M:irch, 1988. This section surrmarizes the results of the various work
tasks completed. Samples of surface water, sediments, surface soils and
ground water were collected and analyzed to estimate the types and extent of
contamination due to the site.
. surface Water
Surface water samples were collected from the quarry and Black River
adjacent to the site on two occasions in Jlme 1987 and M:irch 1988. 'During
the Jlme 1987 sampling, 19 quarry and 6 river samples were obtained and
analyzed for a complete range of organic and inorganic chenicals. A second
sampling, performed during M:irch 1988, collected water from approximately the
same locations originally sampled but the samples were analyzed only for
seni-volatile organic chenicals.
Quarry surface water sample analyses were conpared to up;jradient ground water
sample analyses to determine site related contamination. The upgradient
ground water data was chosen as the best background information available
because the quarry surface waters are situated below the water table in the
same water bearing lmit. No organic chenicals were identified in the quarry
waters as being potentially site related. Several inorganic chenicals were
identified as bEiing potentially site related. These chenicals include
barium, calcium, iron, magnesium, manganese, nickel, vanadium and zinc.
Table 1 lists concentrations of site related chenicals of concern.
The downstream Black River samples were compared to upstream river sanples
and quarry samples to estimate if the site was affecting river water quality.
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The results of this c~ison indicated that the site was not adversely
impacting the overall quality of the Black River water. One analysis for
zinc, in the mixing zone below the quarry outlet, showed an elevated
concentration. This is discussed m:Jre tl1oroughly in the endangerment
assessment section.
'D\BLE 1
CCN:ENl'RATICNS OF rnEMICALS OF CCN:ERN IN QUARRy SURThCE WATER
AT 'lEE REPUBLIC SI'EEL SITE
REPUBLIC SI'EEL QUARRY RI
Mean Maximum Frequency
Concentration Concentration of
C1.enical (ug/l) (ug/l) Detection
Barium 46 113 19/19
calcium 56,700 315,000 19/19
Iron 3,070 1,600,000 19/19
Magnesium 23,600 88,900 19/19
Manganese 940 25,700 11/19
Nickel NA 86 5/19
Vanadium 4.4 60 8/19
Zinc 37 12/19
u
NA - The mean concentration is below the detection level and is considered
as a nondetect.
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Sediments
sediment samples fran the quarry and the Black Ri~,..er were collected in June
1987 and analyzed for organic and. inorganic chenicals. Eight samples' of
quarry sediments and four samples of Black River sediments were collected.
The nature and extent of contamination evaluation for sedi:rrents was per-fomed'
in two phases' to detennine if the quarry sediments were contaminated and to
estim3.te if the quarry had adversely irnpactoo'the quality' of Black River
sediments. .
. Fran these analyses the Agercy concluded that sediIrents wi thin the quarry
are contaminated "lith volatile and seni-volatile organic and inorganic
chenicals. Table 2 presents concentrations of chemicals of concern
identified in the sooiment samples. Volatile organic Comp:)unds were
detected only in the deep quarry sediment samples (greater than 35 ft.)
while seni-volatile organics and inorganics were detected. in both deep and
shallow sarrples. 'Ihe concentrations of the inorganic and senivolatile
contaminants of the sediments obtained from deeper p::>rtion of the quarry w'ere
greater than the shallow sediment concentrations but p::>se no :imninent threat,
however, because the sediments are not believed to mix into the quarry
waters. Mixing probably does' not occur because measurements of water
characteristics in the quarry showed that water does not circulate with
enough force to stir up the sediments. The quarry is also protected by
trees, which reduce wind action on the quarry water. Concentrations of
contaminants in the shallow sediments were detenninoo to pose no irnninent
health risk. .
Further, carparison of downstream Black Riv-er' sedirrents to upstream river an::1
quarry sediments was performed to estim3.te if the site is adversely impacting
Black River sediments. The analyses indictErl that no p::>tentially site
related organic or inorganic chemicals were detected in the sediments
. downstream. The site is not affecting sediments in the Black River.
surface SOils
Eight surface soil samples were collected in Jillle 1987. TWo samples were
collected from background locations while six samples' were collected in an
effort to identify p::>tential site contamination. Analyses performed on .
surface soi Is obtained from areas of the site that were periodically
iI11.Irdated by quarry welter or that were exp)sed to waste discharges in the
p3St detectErl contaminants above background concentrations. Contaminants
detected included volatile and semi -volatile organic and inorganic chemicals
at low concentrations. Concentrations of chenicals of concern in these soi Is
are shown in Table 3. Seni -volati Ie and inorganic chenicals were also
detected in a sample of the steel yard soils that are sliding into the
quarry .
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TABLE 2
CCN::ENl'RATICNS OF cmMICALS OF CCN:ERN IN SEDIMENI'
"NJ: 'lEE REPUBLIC STEEL SITE
REPUBLIC STEEL QUARRY RI
Mean Maxi1m.Im Frequency
Concentration Concentration of
O1emical (ug!kg) (ug!kg) Detection
Butylbenzylphthalate 2,600 73,000 2/7
Di-n-octylphthalate 2,500 6,250 3/7
Diethylphthalate 3,730 56,000 4/7
Toluene 30 370 2/7
Methylene O1loride NA 25 2/7
Acetone 93 1,135 4/7
Tetrachloroethane 5 38 2/7
Ethylbenzene 3.5 .28 1/7
2-Butanone 37 360 4/7
ncFNA 8,430 33,200 6/7
cFNA 3,000 16,900 4/7
Pentachlorophenol 8,830 25,000 2/7
Copper 58,000 300,000 6/7
Mercury 400 730 2/7
o
Tin 10,000 108,000 3/7
Diethy1phtalate 4,200 54,000 3/7
Di-n-butylphthalate 2,160 31,000 3/7
bis(2-ethylhexy1)
phthalate 4,000 68,000 2/7
NA -= The mean concentration is below the detection level and is considered
as a nondetect.
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'mBLE 3
~CNS OF OiEMICALS OF CCN:ERN IN SOn.
AT '!HE REPUBLIC STEEL SITE
REPUBLIC STEEL QUARRY RI
Clanical
Mean
Concentration
(ug/kg)
Maximlm
Concentration
(ug/kg)
Frequency
of
Detection
Methylene Clloride 15 33 2/4
Acetone 37 150 2/4
2-Butanone NR 78 1/4
ncR-JA 3,210 5,080 3/4
cR-JA NA 1,800 3/4
Copper 85,000 94,000 3/4
Mercury NA 340 2/4
bis(2-ethylhexyl)
phthalate NR 7,800 1/4
Di-n-butylphthalate NA 2,400 2/4
Di-n-octylphthalate NA 1,900 1/4
Clromiurn 32,000 178,000 3/4
Manganese 842,000 5,990,000 4/4
NR = Not relevant. Only 1 sample contained detectable concentrations;
therefore a geometric mean was not calculated. .
NA = TIle mean value was below detection.
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'mBLE: 4
CON:ENrRATIrns OF CHEMICALS OF CCN:ERN m GROONI:WATER
AT 'mE REPUBLIC STEEL, SITE
REPUBLIC STEEL QUARRY RI
Mean Maxim.nn Frequency
Concentration COncentration of
Chenical (ugjL) (ugjL> I::etection
Lead NR 19 1/5
Nickel NA 131 3/5
Zinc 43 106 5/5
Pentachlorophenol NR 5a 1/5
Phenol NR lob 1/5
Eari um 64 114 5/5
Beryllium 1 2.1 3/5
Chranium 8.4 20 3/5
Co~r 11 28 2/5
Manganese 1,490 11,600 5/5
Nickel 117 131 4/5
Silver NR 4.1 1/5
Vanadium 29 57 4/5
Methylene Q1J.oride 7 140 2/5
Acetone 8 55 1/5
NA. = The mea!1 concent:::-ation is below the detection limit.
NR = !'Tor. :::-:levant. Only 1 sample contained. detected concentrations;
t1:e:::-sfore, a geometric mean was not calculated.
a. =:-:e --::.=.":: :.s est:..rrated in the date base ai1d is o,.e half the detection
, ..:....,.....:-
..:.. -..i.. 1.- - .
b 'The .::s-:.ec::.on limit of Ple.-r,.ol is 10 ug/L.
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Groundwater
Eight DOni toring wells were installed at or near the Republic Steel Quarry
site. All of these wells were sampled in August 1987 and two wells were
resampled and analyzed for organics in March 1988.
Volatile and semi-volatile organic and inorganic contaminants were detected
in grOlmdwater samples down-gradient from the quarry. Table 4 gives
concentrations of chemicals of concern identified in the ground water.
Volatile and semi-volatile organics were detected only at low concentrations
in nonitoring wells adjacent to the site. 'TIlese contaminants were not
detected in the DOni toring well across the Black River east of the site.
Inorganic chemicals .were detected in all down-gradient wells adjacent to the
site and in the well across the Black River (nontoring well B-8). A direct
connection to site related contamination cannot be made to the inorganics
.detected in DOni toring well B-8.
Dmnqernen:t Assessne1t
The p:>tential risks to human health attributed to chemicals present at the
RepJblic Steel Quarry site were evaluated under a number of exp:>sure
scenarios. Potential pathways of exp:>sure to chemicals originating at the
si te under both current-use and hYIX>thetical future-use cOnditions were
examined. Tables 5 and 6 sumnarize :p::>tential pathways of exp:>sure under
current-use and future-use conditions, respectively. Complete pathways were
then evaluated in regard to carcinogenic and non-carcinogenic risks :p::>sed to
pJblic health.
For :p::>tential carcinogens, excess lifetime cancer risks are obtained by
ITUJ.ltiplying the daily intake of the contaminant under consideration by its
cancer :p::>tency factor. A risk level of 10-6 represents an upper bound
probability that one excess cancer case in 1,000,000 individuals might result
from exp:>sure to the :p::>tential carcinogen, and is used as a bench mark by
regulatory agencies. Potential risks for non-carcinogens are presented as
the ratio of the chronic daily intake exp:>sure to the reference dose
(CDI:RfD). 'TIle sum of all of the ratios of chemicals under consideration is
called the hazard index. 'TIle hazard index is uSeful as a reference :p::>int for
gauging the :p::>tential effects of envirornnental exp:>sure to complex mixtures.
In general, hazard indices which are less than one are not likely to be
associated with any health risks, and are therefore less likely to be of
regulatory concern than hazard indices greater than one.
- .
Table 7 surrmarizes :p::>tential risks associated with the site. under C'.lrrent-
use conditions, the only exp:>sure scenario resulting in a greater than 10-6
risk is the ffi3Xirnum case for ingestion of fish. However, this risk is
primari ly due to the :p::>ssible uptake by the fish of carcinogenic FNi\s fOlmd
in the quarry sediment. This was conservatively estimated using a sediment
to fish tissue m:xiel. Table 8 lists available ARARs used in the Endangerment
Assessment. Fish metabolize PNA to some extent, further reducing the dose
concentration. Additionally, this ffi3Ximum exp:>sure scenario results in a
-------
-11-
hazard index greater than the one because the estimated chronic daily intake
for mercury is greater than avai lable criteria for protection against
noncarcinogenic effects. However, mercury was only detected in 2 out of 7
sediment samples and this risk is based on IrOdeling the concentration of
mercury fram the sediment to fish tissue using very conservative assumptions.
COmbined risks to trespassers, assuming the same person would be expJsed to
soil through direct contact and incidental ingestion, quarry water through
swimning, and fish through ingestion were estimated.
As indicated in Table 7, the combined upper-bound excess lifetime cancer
risks are 3 x 10-8 to 4 x 10-6 under average and maxirmlrn ~sure conditions
respectively. '!he combined current-use hazard index is less than one under
the average exp:>sure scenarios and greater than one under the maxirmlrn
exp:>sure scenarios.
Evaluation of the exp:>sure scenarios under future-use conditions resulted in
an upper-bound excess cancer risk greater than 10-6. Maxirmlrn expJsure to
future residents would occur through direct contact and incidental ingestion
of soil, and ingestion of groundwater. Consequently, the combined IX'tential
residential risk exceeds 10-6 (see Table 7). It should be noted that the
risk derived from the ingestion of ground water is being driven by a one time
detection of methylene chloride in one downgradient oonitoring well. Resam-
pling the well did not detect methylene chloride, which is a COITmJn
laboratory contaminant. 'Iherefore, the presence of methylene chloride is
questionable. 'Ihe need for confinnatory sampling is indicated. Contaminated
soils were limited to a small area in the pickle liquor discharge ditch and
the adjacent ramp-like feature which is periodically inundated with quarry
water.
In evaluating the combined noncarcinogenic future risk, the hazard index is
greater than one under the maximum exp:>sure scenarios. However, none of
the noncarcinogenic chemiCals in groundwater have chronic daily intakes that
exceed available criteria. In addition, each of the chemicals of I;X:>tential
concern with the highest CDI:RfD ratios have different end I;X:>ints of
toxici ty. '!herefore, i111pacts fram ingestion of noncarcinogenic chemicals are
not expected.
Wi th respect to I;X:>tential ilT1pa.cts on aquatic life in the quarry, of the 12
chemicals with acute Ambient Water Quality Criteria (AW;X:) values ,only
copper exceeds the acute criteria (see table 9). Trichloroethene, nickel,
toluene, ncPNA, mercury, pentachlorophenol, and the phthalates are all below
the acute level. . One Black River surface water sample collected in the .
mixing zone beneath the quarry outlet indicated levels of zinc which 9XCeeded
the Nl1:X acute criteria. 'Ihere nay be some acute effects in the small mixing
zone beneath the quarry outlet. However, downstream zinc concentrations were
virtually identical to upstream zinc concentrations, therefore it is felt the
quarry is not affecting the overall quality of the Black River.
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TABLE 5
EXPOSURE TO CONTAMINANTS ORIGINATING AT THE REPUBLIC STEEL QUARRY
UNDER CURRENT-USE CONDITIONS
REPUBLIC STEEL QUARRY
POTENTIAL PATlH,/AYS OF
14ed i um
Potential Routes of
Exposllre
Potential Receptors
Soil (surface)
Trespassers
Pathway Complete?
Dermal absorption,
incidental ingestion
Air
Inhalation of volatile
organics and/or fugitive
dust
Trespassers, nearby
residents
Surface ~/ater/
Sediment
Dermal absorption,
incidental ingestion
Trespassers swimning
in quarry
Uptake by fish with
subsequent inge~tion by .
humans
Trespassers fishing
in quarry
People fishing in
nearby surface water
bodi es,
Ground~'/ater
Ingestion. inhalation.
dermal absorpti on
Local residents
Yes. However. the majority
of the site is densely veg-
egetated.
No. Dense vegetation cover
prohibits soils from becom-
ing airborne.
Yes. Trespassers have been
observed swimming in the
quarry. Quarry depth pre-
cludes exposure to
sediment.
Yes. Large fish were
observed in the quarry.
No. No site related
contaminants have been
detected in Black River
downgradient of the quarry.
No. Groundwater is not
currently being used for
a potable supply in the
vie in i ty 0 f the site.
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. c
c .
-13-
POTENTIAL PATlI~IAYS or
TABLE 6 .
EXPOSlmr TO CONTAMINANTS ORIGINATING AT THE REPUBLIC
IHIDER FUTURE-USE CONDITIONS
REPUULIC STEEL QUARRY
STEEL QUARRY
Nedium
Potential l~out:(~S of
Exposul'e
Potential Receptors
Pathway Compl ete?
Soil (surface) Oe nlla 1 absorption, Future users of the si te Yes.
(res i dents)
Groundwater Ingestion, inhalation. Future use rs of the site Yes.
dermal absorption
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-14-
'U\BLE 7
StJM1l\Ry OF ro.I'ENI'IAL RISKS ASSOClATED WI'IH '!HE REPUBLIC STEEL QUARRy
REPUBLIC STEEL QUARRy RI
N::>ncarcinogenic .
Total Cancer Risks Hazard Index
Ex1;x:>sure SCenario Average Maximum Average Maximum
current-Use (Trespassers)
Direct Contact with SOil 2xlO-8 4xlO-7 <1 <1
Swilrming in the Quarry lxlO-10 4xlO-10 <1 <1
Const.mpt.ion of Fish 9xlO-9 4xlO-6 <1 >1
Combined Risk to Trespassers 3xlO-8 4xlO-6 <1 >1
Future-Use
Park Patron -
Direct Contact with SOil 4xlO-8 lxlO-6 <1 <1
Residential Use -
Direct Contact with SOil 3XIO-7 2xlO-5 <1 <1
Ingestion of Ground Water 2xlO-6 3XIO-5 <1 >1
Combined Residential Risk 2xlO-6 5xlO-5 <1 >1
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'D\BLE 8
CXJ.1PARISCN OF QUARRy ~CE WATER CCN:ENI'RATICNS AT 'IHE REPUBLIC STEEL SITE
WI'IH NM;:f::, 'IDXICITY VALUES
REPUBLIC STEEL QUARRy RI
Federal Water
Concentration in Quality Criteria
SUrface Water (ug/L) for CoIlSUITption
(ug/L) of Fish
Chemical Average MaxiIm..Im
Nickel NA 86 100
Vanadium 4.4 60
Barium 46 113
Manganese 9,210 75,700 100 ug/l
ncFNAa 0.00014 0.00060
cFNAa 0.000050 0.00058 0.031
PentachlorOphenola 0.0028 0.0059
Acetonea 3.4 42
Tetrachloroethanea 0.0026 0.011
Ethylbenzenea 0.00029 0.00024 3,280
2-Butanonea 1.0 8.0
bis(2-ethylhexyl)
phthalatea .0042 0.061
coppera 18 96
Mercurya 0.44 0.81 0.146
Methylene Chloridea NR 0.28
Butylbenzylphthalatea . 0.014 0.405
Di-n-butYlphthalatea 0.0012 0.017
Toluenea 0.009 0.11 424,000
NR = r-bt relevant.
Chanical was detected at only 1 location.
NA = NOt applicable.
'TIle mean value was below detection.
a = calCUlated concentration
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-16-
'I7\BLE 9
CC'fo1PARISCN OF SURThCE WATER CCN:ENrnATICNS NJ: '!HE REPUBLIC SI'EEL SITE
WI'IH ~ 'lDXICITY VALUES
REPUBLIC STEEL QUARRY RI
Federal Water
Quality Criteria
Concentrations in Water
(ug/L)
State Water
Quality Criteria
Aquatic Life
(ug/L)
Maximum O1ronic Acute
O1emical
Average
Maximum
Average
Tetrachloroethene 0.0013 0.011
EthyllJenzene 0.00029 0.0025
2-Butanone 1.0 8.0
ncPNA 0.00014 0.00060
cPNA 0.000050 0.00058
Copper 18 96
Mercury 0.44 0.81
Pentachlorophenol 0.015 0.043
Acetone 3.4 42
Methylene 0110ride u: 0.28
bis(2-ethylhexyl)
phthalate 0.0042 0.061
Diethylphthalate 40 87
Magnesium 23,600 67,500
Nickel NA 86
Vanadium 4.4 60
Calcium 56,700 315,000
Methylene 0110ride NA 0.28
Tin
Bari um 46 113
Manganese 940 25,700
Butylbenzyphthalate 0.014 0.405
Di-n-buty1phtha1ate 0.0012 0.017
Di-n-octylphalate 0.0053 0.0047
Toluene 0.009 0.11
32,000 (LOEL)
620a 2,300a
14b
0.2
1
2.2
12
0.012
13
341
160
-
18
2.4
20
3c
3c
940c
940c
1,400
3c
3c
3c
940c
940C
940c
17,50ob
u: = Not calculated
NA = The mean value was below detection
a For naphthalene
b Hardness dependent parameter
c As phtalate esters. Insufficient data to develop criteria.
Value presenta at the lowest observed effect level.
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Ten of the chemicals have chronic ~ values (Table 9). Of these, quarry
surface water concentrations are below chronic ~ for noncarcinogenic FNAs,
trichloroethene, butybenzylphthalate, di -n-butylphthalate, di -n-octylphthalate ,
and pentachlorophenol. Copper, mercury and diethylphthalate were chemicals
that exceeded the ~.
It should be noted that risks p:>sed by these chemcals except barium, vanadium,
manganese and nickel were calculated using the Sediment/water partitioning ITOdel.
'!he ITOdel is conservative and chemical concentrations in the water are not
expected to be as large as those predicated by the ITOdel.
EVALUATICN AND DISCUSSICN
'!he Remedial Investigation (RI) of the Republic Steel Quarry site is complete and
shows that current site cOnditions p:>se a limited risk to public health. Under
section 300.68(e) (3) of the National Contingency Plan, the U.S. EPA
has the authority to ITOdify an investigation if, after assessing a m.unber of
factors related to the degree of envirornnental impact, the Agency concludes that
ITOdifications are appropriate. In this case, the RI has documented that the
greatest risk due to current use is to trespassers who consume fish caught in the
quarry. Slight future-use risks could be present to people who live on the site
and drink the grotmdwater and come in contact with the surface soils. At present
the site is fenced and no exposure routes for off-site contamination exist.
After careful consideration of the findings of the RI rep:>rt and the limited
health risks p:>sed by the site, the Agency has conducted the fOllowing assessment
of alternatives, technologies, and remedies. The current-use pathway evaluated
was indirect exposure to quarry sediments through ingestion of fish which could
be caught by trespassers. Future-use pathways considered included ingestion and
dennal adsorption of contaminated soils and ingestion of grolmdwater by future
residents on the site.
The sole indirect route for exposure to contaminated quarry bottom sediments
under current-use scenarios is via ingestion of fish. The risk to public health
associated with the fish was conservatively estimated using a Sediment/surface
water exp:>sure ITOdel. Viable resp:>nse actions considered included:
u
l.
2.
No action:
Access Restrictions
The botmdaries of the site are currently fenced and no trespassing signs are
p:>sted. The City of Elyria is currently rraintaining the fence.
Contaminated soil was identified by sampling in the fonner pickle liquor
diSCharge ditch and the ramp-like feature adjacent to the west of the ditch
(see figure 3). Field observations estimated soi 1 depth to average 0.5 foot
throughout this area. Approximately 100 cubic yards of contaminated soil are
estimated to be present. Four resp:>nse actions were considered to address the
on-site surface soil contamination:
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-18-
l.
2.
3.
4.
NO Action
Access Restrictions
Containment
Removal with either off-site Disposal or off-site Treatment
(incineration) .
'Ihe first two alternatives did not meet the CERCI:A Section 12l(b) cleanup goal of
a pennanent solution and were dropped from further consideration. Cost estimates
were obtained on remaining alternatives including capping of the soils and
removal of the one hundred (100) cubic yards of contaminated soils and either
off-site disp:>sal or incineration. 'Ihe cost estimates were as follows:
Capping contaminated soils with clean soils: $62,500
Excavation of soils: $50,000
TransFOrt and DisFOsal of soils in a RCRA landfill:
TransFOrt and Incineration of soils: $229,700
$13,200
'!he risk calculated for the ingestion of groundwater under the future-use
scenario was derived primarily from one groundwater sample which indicated the
presence of methylene chloride. Methylene chloride is a cOITlrOn laroratory
contaminant. It's presence was not confinned in the second round of groundwater
Sampling. '!he Agency believes that the presence of methylene chloride in the one
sample was an anomaly. Because the groundwater is not currently being used as
drinking water down-gradient fonn the quarry, no remedial technologies to add1
groundwater contamination were considered. M:mitoring is strongly recomnended,
however, to determine if future remedial actions will be warranted. .
SUrrmarv of cOlTlPa.rative analysis of alternatives
Alternatives assembled to address the quarry sediments and surface soils were
evaluated based on the following nine criteria:
Overall protection of hurran health and the environment;
Compliance with all federal and state applicable or relevant
and appropriate requirenents (ARARs);
Reduction of toxicity, ITDbility or volt.nne;
Short tenn effectiveness;
Long tenn effectiveness;
Implementability;
Cost;
Cornm.mi ty acceptance; and
State acceptance.
A summary of the relative perfonnance of the alternatives with resPect to each of
the arove nine criteria is provided in this section.
All proFOsed resFOnse actions would be protective of public health. 'TI1e no -
action alternative would, however, leave the site with acceptable (10-4 to 10-
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-19-
risks. Access restrictions, fencing the site and p)sting "no trespassing" signs,
have not proven totally effective as trespassers have been observed on site.
Applicable or relevant and appropriate requirements considered included Ambient
Water' Quality Criteria (AWU:) for aquatic organisms and for consumption of fish,
Resource Conservation and. Recovery Act (RCRA) requirements for off-site disp:>sal
of contaminated soi Is and water quality standardsjARARs for grOtmd water.
One Black River surface water' sample collected in the mixing zone beneath the
quarry outlet exceeded the. ~ acute' criteria for zinc. Because downstream
zinc concentrations were v"irtually identiCal to upstream zin: concentrations, it
is felt that any potential adverse impact on the Black Riv"er is limited.
The maxi1m1m nickel concentration detected is very close to the w::x: concentration
or 100 ug/L for consumption of fish. Concentrations of manganese an:l mercury in
the quarry surface water exceeded Federal Ambient Water Quality Criteria for
const.m1ption of fish (see Table 8). The mercury concentration was calculated
using a conservati ve water/sediment partioning Irodel. A fish tissue bioassay is
needed to determine contaminant levels which are present in quarry fish.
Potential ARARs which have been identified for grourxi water are present in Table
10. Concentrations of chemicals of p)tential concern at the site are generally
below the Water Quality Criteria. N::> private drinking water wells are identified
downgradient of the site. Future-use considerations will. warrant continued
m:mi toring . .
The land disp)sal restrictions under 40 CFR part 268 were determined to be an
applicable requirement to the selected remedy because the primary source of
contamination of the ditch sediments was fran waste pickle liquor. Waste pickle
liquor is identified asRCRA waste K062. UrX:ler the first third rule promulgated
on August 8, 1988, pickle liquor waste must meet sp:!Cific Best Demonstrated
Available Technology (BDAT') treatment levels for chromium an::l lead prior to land
disp)Sal. The BDAT levels prOImllgated in the first third rule (non waste
waters) are 0.094 IT9/1 & 0.37 rrg/l ('ICLP extract) for chromium and lead
respectively. Due to the low levels of chranium and lead. contamination in the
soils at the RepubUc Steel Quarry site, it is believed that treat:Irent will not
be required to meet these &F\T lev'"els. However, prior to offsi te diSFOsal, 'ICLP
tests will be performed on the soils to determine their compliance. In the event
that testing reveals that the soils do not meet the TCLP BrnT levels for chromium.
or lead, EPA will select an appropriate treatment technology to ensure compliance
with the Larxl DiSFQsal Restrictions.
. .
The criteria dealing with the reduction of toxicity, rrobility or V''Olume for
contaminants only considers reductions due to treat.rcent. Off-site incineration
of the 100 cubic yards of surface soils was considered as an alternative.
A treatment technology to address the quarry sediments was not considered. because
disturbing the sediments and mixing them into quarry waters through excavation
would create a greater pJtential threat to human health than the sed.irrEnts
currently p)se.
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-20-
TABLE 10
CQVIPARISCN OF GROUNEWATER CCNCENI'RATICN NJ}
'!HE REPUBLIC STEEL SITE WI'IH ARARs
REPUBLIC STEEL QUARRY RI
O1enical
Concentration in
Ground Water
(ugjL) .
Average
Maximum
Ohio
Federal
Barium
Beryllium
Manganese
O1romium
Copper
Lead
Nickel
Zinc
Pentachlorophenol
Phenol
Altnninum
Calcium
Cobalt
Silver
Vanadium
Methylene O1loride
Acetone
64
1
1,490
8.4
11
NR
117
51
NR
NR
2,600
190,000
NR
NR
29
7
8
114
2.1
11,600
. 20
28
19
131
106
1,000 M:I.,c
0(3.9 ng/l)d
50 M:I.,c
50 M:Lc
15. 4 ~a
5,000 w:;c
(organoleptic)
3,500 w:;ca
5
10
11,600
348,000
18
4.1 .
57
140
55
50 w:;ca
NR = Not relevant.
O1enical was detected at only 1 location.
These adjusted criteria, for drinking water investigation only, were
derived from p.Iblished EPA ambient water quality criteria (45 FR
79318-79379, Nov611ber 28, 1980) for combinoo fish and drinking water
ingestion and for fish ingestion alone. The adjusted values are not
official EPA ambient water quality criteria, but may be appropriate for
SUperfund sites with contaminated groundwater.
a
o
Cri teria designated as organoleptic are based on taste and odor effects, not
human health effects. Health-base water quality criteria is not available
for this chemical.
b
c
M:I., = Maximum Contaminant Level for drinking water standards.
d
Water QtElity Criteria (WQC); concentrations in parentheses correspond to
midpoint of risk range for potential carcinogens.
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-21-
All alternatives considered to address the on-site surface soil contamination,
with the exception of alternative 1 (no action) are effective in the short tenn.
The access restrictions do not provide as high a degree of effectiveness because
trespassers have been observed on-site. As stated above disturbance of the
quarry sediments would likely result in short-tenn adverse effects to the
environment as well.
SOil contamination alternatives 3 and 4 (containment or reroval) provide the
highest degree of long tenn effectiveness. Neither alternatives 1 (no action)
or 2 (access restrictions) provide long tenn health protection because of
continued trespassing on site. The containment (capping alternative) would
require operation and maintenance to provide continued long tenn effectiveness.
The irnplementability of each alternative is based on the technical feasibility,
admdnistrative feasibility and the availability of services and materials for the
alternative. All of the alternatives are techniCally feasible. They all
involve technologies which have been used regularly in the past and have a
daronstrated perfonnance record. The services and materials required for each
alternative are readily available.
There are no costs associated with the no action alternatives. The access
restriction alternative would present minimal costs as the site is already
fenced. The capping option has a present worth cost of $62,500, which includes
operation and maintenance. Excavation of the soils and disp:>sal in a RCRA
landfill has a total present worth cost of $63,200. Excavating the soils and
off-site incineration has a total present worth cost of $279,700. The
incineration option is not felt to offer significant increases in protectiveness
to plblic health and the environment, short tenn effectiveness or long tenn
effectiveness, over raroval and disp:>sal, for the additional cost.
Limi ted conrnents have been received to date from the cOITlTU..IIli ty regarding the
various alternatives considered. In a meeting with Elyria city officials (the
City is a PRP) the mayor and cOlll1Cil indicated that off-site disp:>sal would be
the favored alternative. The public meeting for the prop:>sed plan was tX)Orly
attended.
The State of Ohio, through the Ohio EPA, has been actively involved in the RI
process for the Rep.Iblic Steel Quarry site and concurs with the U.S. EPA's
selected action.
SELErJE) N:TIrn
Based on available data and analysis conducted to date, the U.S. EPA selects the
raroval and off-site disp:>sal of the surface soils as the most appropriate
solution for meeting the goals of renediation of the Replblic Steel Quarry site.
The characteristics of the selected alternative that are considered most
irnp)rtant are:
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-22-
Removing approximately 100 cubic yards of contaminate:1 soil that
are located in (1) the ditch previously used to discharge pickle
liquor to the quarry and (2) along the southern end of the quarry;
Di5p)sing excavated soil according to RrnA regulations.
"A renedial tectmOlogy alternative is not reconrnended by the EPA to address the
contaminated quarry sediments. This was detennined because disturbing the
sediments anl mixing them, into quarry waters through excavation would create a
greater J;XJtential threat to htnnan health than the Se:1irnents presently :p:>se.
The quarry is- currently fenced and no trespassing signs are :p:>sted, but these
access restrictions have not been totally effective. Access to the sediments
is also restrict.ed as they are covered by over 35 feet of water.
Also, since low levels of contamination have been detected in other on-site
. media, this site shall be subject to rronitoring under' the five year review
process, in accordarce with section 121 (c) of CERCIA (Superfund). The p.lI1X)se of
this rronitoring, which will be conducted by (J.S. EPA, is to assure through
sarrpling that ingestion of fish and ingestion of grmmdwater :p:>se no unacceptable
health risk. Specific tasks recoourended as part of this rronitoring process are:
COnducting a fish species survey and fish tissue bioassay to
assure the absence of contaminants. The survey will include
identifying species in the quarry and sampHng each fish species.
Resampling groundwater- to assure the concentrations of any
contaminants are at acceptable risk levels.
Data from fish tissue' bioassays shall be presented to the Ohio Dep:3.rtlnent of
Public HeaJ.th to detennine if a fishing advisory is warrante:1 for the RepJblic
Steel Quarry. These sampHng activities shall be conducted by U.S. EPA in the
Fall of 1988.
sr1\'J:.UImY D~CNS
The U.S. EPA and OEPA believe that this rerredY will satisfy the statutory
requirements of providing protection of hurran health and the environment,
attaining applicable or relevant and appropriate requirements of other
en,,"i.ronmental statutes and will be cost-effective. The small volume and limited
levels of contamination present in the soil at the site do not warrant the use of
resource recovery technologies or alternative treatment technologies.
o
Protection of Human Health and the Envirornrent
The selected action provides adequate protection of htnnan health and the
en,,"i.ronment by preventing expJsure and accidental ingestion of contaminated
surface soils. Additionally, further' U.S. EPA coru:luL"ted monitoring will assure
that fish in the quarry and the downgradient grOlmdwater do not J;X)se a human
health threat.
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. .
-23-
Attairnnent of APPHcable or Relevant and APPropriate Reouirenents
Although no ARARs are available for surface soils and quarry sediments, because
the surface soils p:>se a slight future-use, health-based risk, their rerovd.l and
diSpJsal is warranted'in this case. Disp:>sal of the soils will follow Resource
Conservation and Recovery' kt. (40 CFR section 268.41) procedures. Ambient Water
Quality Criteria (AW:C) for aquatic organisms have been exceeded by the site in
its present condition. The need for fish species survey and tissue bioassay is
indicated. Ground water is not currently used as drinking ~ter downgradient of
the site.
Cost-Effectiveness
This alternative affords a high degree of overall effectiveness by eliminating
the IroSt accessible pathway of exp:>sure. '!he present worth cost of this action
is $63,200. This compares with the $279,700 required for off-site incineration
of the soils. u.s. EPA believes the costs of the selected renedy are
proIX>rtionate to the overall effectiveness it affords.
Utilization of pemanent Solutions and Alternative Treatment Technoloqies or
Resource Recoverv TechnolOsure to
contaminated soil~ is readily implemented, and is cost effective.
Preference for Treatment as a PrinciPal Element
Due to the limited scope of this remedy, the statutory preference for treatment
will not be met. '!he small volume and levels of contamination
present in the soils do not make treatment a cost-effective alternative.
SChedule
c
The following are the key mile stones for implementation of the rerredial action
in the event that RD/RA negotiations are not successful.
Approve Rerredial Action (execute Rill)
Fish survey and tissue bioassay
Initial Rerredial Design (for limited soil rem:>val)
Complete Remedial r:esign
Ini tiate Remedial kt.ion (Award Contract for
limited so i I rem:>val)
September 1988
Fall 1988
January 1989
March 1989
June 1989
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.
HtRII:SLlC' SDn. CUl\RRY SI'.IE
ELYRIA, CHID
~ smH\RY
The United States Environmental Protection Agency (U.S. EPA) recently held
a plblic ccmnent pariod, Septanber 2 - 5eptenber 23, 1988, for interested
parties to cornnent on the U.S~ EPA's August 26, 1988 Renedial .
Investigation (RI) RepJrt an:l ProJ;Osed Plan for the renedial action for
the Replblic Steel Quarry site. At. the beginning of the pJ,blic comnent
period, the U.S. EPA. announced its recomnended alternative for the
RepJblic Steel Quarry site.
The purpose of this resp:msiveness SlmrnaIY is to document U.S. EPA's
resp)nses to corrments received during the pJblic ccmnent pariod. All of
the conmen.ts s1.IIT1T1aIized in this document were considered by (r.s. EPA. in
its final decision.
This resIX>nsi veness S1.IITlT1i3IY is di vi.ded into the following sections:
I.
RESPONSIVENESS ~::",{.JMv'V>,RY OVERVIEW - This section briefly
outlines' the proFOsed ranedial alternative evaluated in
the PrOFOsed Plan, including the recornnended alternative.
II.
SUM\'1!\RY OF COM1ENI'S ON 'mE RI REroRI' AND PROPC6ED PLAN - This
section sLmrnarizes both written and oral conments received
from interested parties.
I.
RE:3PCN3IVEmE5S SlJl'vH\RY OVERVIEW
A.
Recomnended Alternative
The findings of the RI reFQrt showed that the site FOsed limited,
health risks. After careful' consideration of the findings the
Agency conducted an assessment of altenlatives, technOlogies' and
remedies and presented this assessment in the prop)sed p~an. The
altenlatives were evaluated based on the nine criteria detailed
in the pr0p)sed plan.
The major components of U.S., EPA's selected ranedy for the
Rep.lblic Steel Quarry are as follows:
Reroving approximately 100 cubic yards of contaminated soi 1
that are located (1) in the ditch previ.ously used to diSCharge
pickle liquor to the quarry and (2) along the southern end of
the quarry;
Disp:>sing excavated soil according to RCRA regulations.
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-2':'"
Also, since low levels of contamination have been detected in
other on-site media, this site shall be subject to ITDni toring
under the five year review process, in accordance with section
121 (c) of CERCIA. (Superfund). SF€Cific tasks reccmnended as
p:irt of this ITDnitoring include:
COnducting a fish species' surv"ey and fish tissue bioassay to
assure the absence of contaminants. The survey will include
identifying SF€Cies in the quarry and. sampling each fish
. species.
Resampling groundwater to assure the concentrations of any
contaminants are at acceptable risk levelS.
B. Public comments on the Prop::>sed Plan
Fornal written comments on the Replblic Steel' Quarry Proposed Plan
were sul:mi tted by two grOUFG; L'IV Steel Corporation and the City
of ElyriaA NJ oral conrnents were received during the public
meeting which was held on September 15, 1988 in Elyria, Ohio.
II.
SlMoI\RY OF aM1ENI'S rn 'DIE PRCJR:5ED' PUW
The fOllowing section slII111larized written' and oral comments received
from interested parties. Many of the conrnents were edited for
clari ty or when multiple parties make a similar comnent.
Conment:
EPA erroneously characterizes that discharges of rinse water to the
Black River have contiIUled since 1976. '!he LTV Steel Corp. plant
discontinued pickling operations in 1976 and has never discharged
rinse water directly into the Black River.
u.S. EPA's RESR:NSE:
After investigating this claim, the U.S., EPA agrees that the I1IV
Steel plant has not continued to discharge rinse water from pickling
operations to the Black River. The ditch nmv' functions as a drain
for fast water from plant roads and P3Iking lots. Drain waters are
ITDni tored in accordance with EPA regulations. An errata to the HI
report, \.Jhich includes this error, will be mailed to the Replblic
Steel Quarry Infornation repository.
v
CCJvlV1ENI' :
As long as the site maintains a restricted entry status, additional
testing on the fish p::>pllation is not necessary.
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U.S. EPA's RESFCNSE:
The U.S. EPA maintains that fish tissue studies at the site are
necessary. Results fran the Republic Steel RI rep:>rt indicate that
fish in the quarry may fX)se a risk to p.Jblic health. This
determination is based on conservati v"'e rrodeling of uptake of sediment
contamination by fish as opposed'to actual fish tissue data. Fish
tissue analyses were not performed as a task un:ier the RI because it
was felt that rrodeling would, be sufficient to evaluate whether the
fish p:>sed a health risk. The RI, however, indicated rrore risk tl1an
was expected and indicated that fish tissue bioassays are warranted.
Access restrictions, such as the existing site fence, were considered
and p.lt out for public comnent (see the Republic Steel Quarry site
Proposed Plan). The existing site access restrictions have not
proven totally effective, as indicated by numerous rep:>rts of
trespassers fishing and swimming at the site. City officials have
indicated that the city cannot afford to rronitor the site on a full
time basis. For these reasons, access restrictions w-ere not
identified as being as protective of hurren health and as permanent of
a solution as other identified alternatives. .
Finally, the U.s. EPA. is required by law (CERCIA section l2l(c)) to
perfonn a five-year review on sites at which hazardous substances are
left on site. The RepJblic Steel Quarry site falls into this
category.
c:c:MVlENI' :
If U. S. EPA perfonns additional groundwater monitoring for organic
consti tuents, proper laboratory CJA/OC procedures' should be followed.
U. S. EPA's RESFCNSE:
"
The U.S. EPA strives to maintain high Quality Assurance/Quality
Control (QA/OC) procedures throughout all inv-estigations.
Laboratories which the U.S. EPA uses to perform analyses' undergo a
very stringent validation process to assure quality data is
generated. The U.S. EPA will follow proper laboratory QlVe::!:-
procedures during any sarrpling to be conducted at the Republic Steel
Quarry site.
ccr-1\'lENI' :
The additiOnal grOlmdwater sampling is not necessary.
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. ~
-4':""
U. S. EPA 's COM1ENI'S:
The Agency believes that the additional groundwater sarrpling is very
necessary to assure the absence of methylene chloride in the
downgradient grotmdwateL The concentration of methylene chloride
detected in the first groundwater sampling rourxj is driving the
entire cancer risk for ingestion of grotmdwater under the future-use
scenario. If the detection of methylene chloride proves' to be a
laboratory artifact, cancer risk :p:>sed by the groundwa.ter will be
decreased to acceptabJe risk levels.
CC'M'tlENI' :
It was recorrmeooed that the srrall aIrount of soil suggested to be
excav<3.ted be allowed to rerrain as long as entry on the site rerrains
restricted.
U.S. EPA's RESKNSE:
As has been stated previously I access restrictions presently in place
at the site have not been totally effective. 'TIle access restriction
alternative was presented in the ProJ;Osed Plan for the Republic Steel
Quarry site. The soil raroval and off-site dis:p:>sal alternative was
selected over the access restriction alternative because it is mJre
protective of plblic health and is a IrOre pemanent, long-tenn
solution which can be implemented for a reasonable cost. Removal of
the contaminated soils will eliminate one exp:>sure pathway at the
si te which wOuld have required future IrOni toring .
CCM\'lENI' :
The U. S. . EPA should provide the City of Elyria with the option of
using its own personnel and equitment to effect the soil raroval.
U.S. EPA's RESKNSE:
[,
The U. S. . EPA will offer the opp:>rtuni ty for Potentially Responsible
Parties (PRP's) to conduct the soil raroval at the Replblic Steel
Quarry site. 'TIle removal will be conducted according to U.S. EPA
regulations and guidelines with U. S . EPA oversight.
CCM'vlENI' :
U.S. EPA's investigation of the quarry is an overreaction to a site
that does not belong on the N3.tional Priorities List.
U.S. EPA's RESKNSE:
A substantial am:nmt of hazardous waste was disposed of in the
Republic Steel Quarry site. 'The health risks :p:>sed by the site were
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o
o
-5-
evaluated using standard field procedures, strict interpretations of
the Hazardous Ranking Systen (fIRS) scoring regulations and quality
assured/quality controlled data. Once a site has been placed on the
National Priorities List (NPL), the u.s. EPA is required by law to
fully investigate p:>tential health risks p:>sed by every aspect of the
si te. TIle RepJblic Steel Quarry Remedial Investigation Rep:>rt
documents that contamination related to disp:>sal practices at the
site is present in quarry sediments, grOtmdwater and surface soils.
The rep:>rt also documents that the site contamination p:>ses only a
limited health risk. TIle limited health risks in no way suppJrt the
claim that the site should not have been placed on the NPL in the
first place.
I
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AIii';!NISTRATlVE RECORD INDEX
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~cetJng of ~J9!86.
Res~onse to uSEP~ l~~.er of
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HDi1lt.i 51 ~A11'~E RECORO INDEX
RE.c.u8LIC S"I:::::L 11t.:Ai~RY
EL'(Rl~. 8:-118
AUTH!J.1
Lee E.
Lal'scrr-t.TV Steel Co.
LarW2rICe
blatnlcK-0eOt.of jU5t1C~
J~ne Luo~cn-uSEPA
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Sum~ary of C(~roent; a~o
Hespons2 re: Re~ucl:c S~Eel
Quarry N~L S~Jrlng anc
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10~olE t~at autnor
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11 841~2/12
TIT,-~
Re5ccnaen~s ~Gtlon to
C'JYtS!Jlldate.
n~:~~~aeYtt's ~otlon To Deter
Conslder~tlon Qf Pe~ltlon
FOt' R:",. :~I: i II ~l'1e case of
C'tV
LJi :';;~cr.:g:'1t,:;n, ~lSC(;r;Slrl v.
Unlteo Sca:es ~,86-: /f';2. u.3.
Ct or HuO.~ D.C.C.r., as
~':"nSIJ ll~;~elJ.
B'r12T fClr ~:esC(;rlc2r:t
(1 II
~~;lle~~e co l:S:l~; of
Re:u~~lc Steel QUarry
Ijtl !ne ~~~i~; l(i ~;-:e ':a:2
of CIty of St0~gntGn~
Wlsc~nSl~ v. USE~H:
; ao-l~92. U.S.Ct.
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AL7.lNlSTFiH"jlVE RECORD rND~X
Rt~UBL:C STE~L QUARKY
ELYKIH, uHlU
HuTI-:CR
US~PA ana the Dept. of JU5tlce
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