United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-90/124
August 1990
Superfund
Record of Decision:
Sangamo/Crab Orchard
NWR (USDOI), IL
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. 30272-101
REPORT DOCUMENTATION T 1. REPORT NO. I 2. 3. Recipient"o Acceaaion No.
PAGE EPA/ROD/R05-90/124
4. Tille and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 09/29/90
Sangamo/Crab Orchard NWR (USDOI), IL
Second Remedial Action 6.
7. Author(a) 8. Perfonning OrganiZ8tion Repl No'
8. P8rfonnlng Or8alnization Name and Add..... 10. ProjectITaaklWork Unit No.
11. Contract(C) or Gnnt(G) No.
(C)
(G)
12. ~orIng Organiz8llon Name and Addre.. 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplem8ntary Notaa
18. Abatrac1 (Urnit: 200 worda)
The Sangamo/Crab Orchard NWR (USDOI) site, in the Crab Orchard National Wildlife Refuge,
is near Carterville, Illinois. Within the re fuge, lakes and adjacent wetlands support
recreational activities on the western portion of the refuge, while the eastern portion
is used for manufacturing purposes. The Department of Defense (DOD), the original
administrator of the refuge, leased portions of the refuge to munitions and explosives
manufacturers who continue to operate onsite. In 1947, DOD transferred the
administration of the refuge to the Department of the Interior (DO I). DOI also leased
portions of the refuge to manufacturers of PCB transformers and capacitors, automobile
pa rt s, fiberglass boats, plated metal parts, and jet engine starters. Solid wastes
generated from these industrial activities were disposed of in onsite landfills while
other liquid wastes may have been discharged into nearby surface waters and
impoundments. EPA has divided the site into four operable units. The first operable
unit, documented in a March 1990 Record of Decision (ROD), addressed the
metal-contaminated areas. The second operable unit is documented in this ROD and
focuses on the PCB-contaminated soil and sediment in four sites including the Job Corps
Landfill (site 17), an inactive I-acre landfill containing 1,400 cubic yards of
(See Attached Page)
17. Documant Analyala L Deacrlplora
Record of Decision - Sangamo/Crab Orchard NWR (USDOI), IL
Second Remedial Action
Contaminated Media: soil, sediment
Key Contaminants: organics (PCBs), metals (lead)
b. IdentifieralOpen-EncIed Terma
c. CooA 11 Reid/Group I
18. Avallabllty Statement 18. Secwlty Cia.. (Thla Report) 21. No. of pagea
None 100
20. Security Cia.. (Thia Pege) 22. Price
Nt"lno::>
272 (4-77)
(See ANSl-Z38.18)
See Inetructlone on Re v.-
(Formeriy NTlS-35)
Department of Convnerce
'-
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EPA/ROD/R05-90/124
Sangamo/Crab Orchard NWR (USDOI), IL
Second Remedial Action
Abstract (Continued)
contaminated material; the Water Tower Landfill (site 28), an inactive I-acre landfill
containing 100 cubic yards of contaminated material; the Area 9 Landfill (site 32), an
inactive 2.5-acre landfill; and the Area 9 Building Complex (site 33), where contaminated
runoff from an industrial building complex discharges into two drainage ditches. The
Area 9 Landfill and Building Complex together contain 36,000 cubic yards of contaminated
material. Two additional operable units will be addressed in a future ROD. The primary
contaminants of concern affecting soil and sediment are organics including PCBs and
metals including lead.
The selected remedial action for this site includes excavation and treatment of
PCB-contaminated soil and sediment using incineration or in-situ vitrification (ISV), if
appropriate, and stabilization/fixation of incineration residues and non-incinerated,
metal-contaminated soil and sediment, followed by onsite disposal in a RCRA-permitted
landfill; backfilling, capping, and closure of excavated areas and areas where
contamination is below the excavation criteria; environmental monitoring including ground
water, surface water, and leachate monitoring; and implementation of institutional
controls including land use and transfer restrictions. ISV, an innovative treatment
technology, will substitute for incineration if a successful demonstration of the
technology is made. The estimated present worth cost for this remedial action is
$25,000,000, which includes an annual O&M cost of $379,701 for 30 years. If ISV is used,
the estimated present worth cost of this remedial action will be $17,080,215, whic~
includes an annual O&M cost of $201,800.
PERFORMANCE STANDARDS OR GOALS: Soil and sediment contaminated above the established
remediation goals will be excavated and treated. Soil remediation goals include PCBs 1
mg/kg for the top 12 inches of surficial soil, PCBs 25 mg/kg for soil below 12 inches,
and lead 450 mg/kg. Sediment remediation goals include PCBs 0.5 mg/kg. Soil and
sediment remediation goals are based on the risk assessment, a 10-6 excess cancer risk
level, and an HI=l.
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JB::IARATIQ{ R:R 'IBE RIbHJ OF IB::IsIQ{
~ CR:HARD NATIaiAL wnm;TFE !
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stabilizatiorvfixation of residues fran in::ineration an::l non-
in::inerated soil an::l sediment contaminated with metals (if
determined to be RCRA hazardous because of their metals
leadlability), to renier them non-hazardous;
on-site disposal of non-RCRA hazardous stabilized/fixed material
an::l untreated residues exc::E!E!din; the clean up targets in a
lan::lfill meetin:;J the requirements of RCRA SUbtitle D an::l 35
Illnois Administrative Code Part 807;
Backfillin:;J, placement of low-peDneability caps an::l closure of
areas where contamination is below the excavation criteria or fram
where contaminated soil an::l sediment have been excavated;
Envirorunental lOOni torin:;J an::l maintenance durin:;J an::l after remedial
construction to ensure the effectiveness of the remedial action.
DECI.ARATION
'!he selected remedy is protective of human health an::l the envirornnent,
attains Federal an::l State requirements that are legally awlicable or
relevant an::l appropriate for this remedial action, is cost-effective
an::l consistent with ac::hievin:;J a permanent remedy. '!his teIuedy
satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, ndJility or volume as a prin::iPal element an::l
utilizes permanent solutions an::l alternative treatment (or resource
recovery) technologies to the maxiJmJm extent practicable for this site.
Because this remedy will result in hazardous substances remainin:;J on-
site al:xJve health-based levels, a review will be conducted within five
years after cc.mmencement of remedial action to ensure that the L~I~
continues to provide adequate protection of human health ani the
environment.
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IB:ISIaf ~ - R:B ARFAS
~ (R]mRD NATICtU\L wrrrn.TFE ~
~, II.LIK>IS
I.
SI'lE 1W4E, IDCATIaf AND IE;CRIPl'Iaf
Sarga1rO Electric D.Irrp / Crab Orchard National Wildlife Refuge
Carterville, Illinois
'!he Crab Orchard National Wildlife Refuge (the Refuge) site lies near
Marion, Carterville and CartxmJale, Illinois, primarily within Williamson
County, ~ into Jackson, Union and Jolmson Counties in southern
Illinois (See Figure 1 in AJ;:pen:tix A). '!he Refuge consists of
approximately 43,000 acres of IIU.lltiple-use land. '!he land is used as a
wildlife refuge, and also for recreational, agricultural and in::lustrial
purposes.
'!he 'NeStern en:! of the Refuge arourrl. Crab orchard Lake is used for
recreational purposes while the eastern en:! is used for manufactur:i1q
facilities. ~s to the eastern portion is closed to the public,
except for limited access to workers at the in::lustrial sites and
restricted access to hlU1ters. '!he study sites which were the focus of
the Remedial Investigation (Rr) and Feasibility Study (FS) are located in
the eastern, closed portion of the Refuge (See Figure 2 in AJ;:pen:tix A).
'!here are twelve lakes, in=l\dirg crab Orchard Lake located within the
Refuge. Crab Orchard Lake supports a large population of sports fish and
is used as a drinki.ng water source for the Refuge and neamy Marion
Federal Penitentiary. Wetlands are foun:l in sane areas adjacent to the
lakes. Wildlife on the Refuqe i.n:lude many game and ~ species.
'!he Refuge has habitat suitable for one errlan;Jered species, the Irrliana
bat, and defInitely houses, another, with two active bald eagle nests.
n. SI'lE HIS'n:'Rl AND ~ ACl'IVI'l'I:ES
'!he Crab Orchard National Wildlife Refuge is owned by the U.5.
govermoent and is currently administered by the u.s. Fish and Wildlife
Service (ms) a bureau of the Department of the Interior (ooI). '!be
Refuge was previously administered by the Department of Defense (rOD).
D.1rin;J the OOD administration portions of the Refuge 'N'ere leased to
in::lustrial tenants, primarily for the pu:pose of I1I.D'1itions and explosives
manufacturin;J. In 1947, the OOD transferred the Refuge to the ooI.
several other in::lustries m:JVed onto the site to occupy mi.ldin;Js fonnerly
used by the wartime in::lustries. '!be production of explosives c:onti.nued
to be the pri.n:ipal irx1ust:ry on the Refuge. other in::lustries i.n:luded
the manufacturin;J of PCB transfonners and capacitors, au:t.ald:>ile parts,
fiberglass boats, corrugated boxes, plated metal parts, tape, flares and
jet elXJine starters. Manufacturin;J, primarily m.mitions, continues at
the site.
cn~e.ss, in passin;J the law that created the Crab Orchard National
Wildlife Refuge, mardated a oontir1ui.n;J imustrial presence on Refuge
prc:p!rty . Can~p:ess required that the lands nust be used in a manner
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consistent with the needs of in:lustJ:y, as VJell as those of agriculture,
recreation, ani wildlife conservation. 'Ihe accompanyi.rqlegislative
history inlicates that Con;ress viewed the irdustrial developnent of the
Crab Orchard National Wildlife Refuge as central to the viability of the
Refuge.
Disposal activities at the site apparently :in:luded d1..mpi.rq of waste
material in unused areas of the site, ani lanifilli.rq of waste materials
in unlined lanifills which were covered with earth. other disposal might
have :in:luded discharge of liquid material to surface water bodies ani
:i:rrpJurrjment. 'Ihe types of materials disposed of at the Refuge reflect
the broad ran;Je of substances used in the various in::iu~..trial ani Refuge
activities. '!here are no good estiInates of the total volume of disposed
material.
'Ihe site was proposed for the National Priorities List (NFL) in 1984 ani
finalized on the NFL in July 1987. '!he relative roles ani
responsibilities of other Federal Agencies ani the United States
Envirarmantal Protection Agen::y (U.S. EPA) at Federal Facilities like
Crab Orchard National Wildlife Refuge are prescribed in Section 120 of
the Calprehensive Environmental Response C:q:Jensation ani Liability Act
(CERCIA), as amen::Ied, ani Executive order Nlm1ber 12580. OOI is
responsible for remedial action ani c:x:rrpliance with CERCIA. '!he u.s. EPA
is responsible for provic:lirg assistance ani oversight to OOI for actions
at the site taken pursuant to CERCIA. In addition, u.s. EPA, after
consultation with OOI, is responsible for final remedy selection at the
Site.
In addition to the roles ani responsibilities of the OOI am u.s. EPA at
the Refuge d;~]Ssed above, OOD may have sane responsibility for sane of
the hazarda1s substances at the Site, in aocordanoe with Section 107 of
CERCIA ani unier the Defense Environmental Restoration Program. Various
other private parties may have responsibility for the hazarda1s
substances at the Refuge in aocordanoe with Section 107 of CERCIA.
In February 1986, the U.S. EPA ani FWS entered into a Federal Facility
Initial O:I1pliance Agreement, which required the perfonnance of a
Remedial Investigatiat ani Feasibility Study (RIfFS). '!be FWS, in
conjun::tion with 5anJaIoo Westa1, Inc., a potentially respousible party
(PRP) at the site, began an RIfFS at the Refuge in May 1986. In August
1988, an RI Report was finalized ani made available to the p.1blic. In
Al¥;JUst 1989, the FS Report an:! Plqceed plans for the first two qJerable
units (the Metals Areas ani the PCB Areas) were made available to the
public. Q1 March 30, 1990, a Record of Decision (R:>D) selectin;J the
final ~~ for the Metals Areas cparable unit was signed by u.s. EPA,
with the conc::urJ:'eJ'r of OOI. '!be U.S. EPA served as the 5UR)Orti.rg
agen::y durin;J the RIfFS, ani was lead Agercy for the develcpoent of the
pr'qX)Sed plans ani the Metals Areas R:>D ani this R:>D. '!be Illinois
Environmental Protection Aqercy (IEPA) served as a supporti.rg agen::y for
the FS, pr'qX)Sed plans ani this R:>D.
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A draft rnteragerx:y 1!greenent (rAG), pursuant to CERCIA section
120(e) (2) is a.1rl"e11t1y bei.n;J developed between U.S. EPA, 001, OOD am
IEPA. '!he Department of the ArItrf, (Dl\) may participate in the rAG.
Negotiations on this rAG were started in August 1989, am are expected to
delineate Jtqercy roles am responsibilities for future activities am
will stip.1l.ate schedules for canpletion of the remedial action specified
in this R:>D am remedial action for other operable units.
In July 1989, 001 iSSl~ letters to ~r6xiJnately sixty in:tividuals am
entities p.IrSUant to CERCIA Section 104 (e), to request information
relati.n;J to the identification, nature am quantity of materials treated,
stored or disposed of at the Refuge, or transported to the Refuge: the
nature or extent of any releases or threatened releases of a hazardous
substance at the Refuge: am information relati.n;J to the recipient's
ability to pay for a cleanup. 001 am U.S. EPA are jointly reviewi.n;J the
responses to these letters to detennine whether any of the respon::lents -
\tt'all.d be considered PRPs at the site. Special notice letters have not
been issued to any PRPs at the site to date.
III. CI:IMJNI'lY RE[ATICH; IIIS'R:RY
Public participation requirements urder CERCIA Sections 113 (k) (2) (B) am
117 were satisfied durin; the RIfFS process. u.s. EPA has been
pri1narily responsible for corrlucti.n;J the c::crnrmmity relations program for
this Site, with the assistance of FWS. 'Ihe followi.n;J pmlic
participation activities were corrlucted duri.n;J the RIfFS:
Establishment of Administrative Record repositories at the Southern
Illinois university's MJrris LibraIy in cartx:>n:3ale, Illioois am at
U.s. EPA, Region V Office in Orlcago, Illinois.
Establishment of aa:titional information repositories at Marion
Carnegie Public Library in Marion, Illinois: crab orchard National
Wildlife Refuge Headquarters in Ca.rterville, Illinois; am Marion
Federal Penitentiazy in Marion, Illinois.
Develq:ment of a maili.n;J list of interested citizens, organizations,
news media, am elected officials in local, Camty, state am
federal govemment. Periodic mailin;Js of Fact Sheets am other
information to all perscn; or entities 00 the maili.n;J list.
Periodic news releases ~i.n;J various on-site activities am
results of investigations.
A Fact Sheet in luJUst 1988, explai.nin; the results of the ~j al
investigation. '!he Remedial Investigation Report was also released
at this time.
Paid newspaper advertisements ~i.n;J the RI pmlic meeti.n;J am
the FS am prc:pJSed plan availability sessions am pmlic hearin;Js.
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A p.1blicmeetin;J in August 1988, to meet conCerned citizens and
n;!::t"'.'I)SS the results of the remedial investigation. ~roximately
100 people atten:led the meetin;J.
A Fact Sheet in Januazy 1989, explainin;J the Feasibility Study and
p~ plan process, d;~1SSin;J remedial technologies under
consideration, and arunmcin;J a tentative schedule.
A Fact Sheet in August 1989, explainin;J u. S. EPA' s preferred
alternatives for two operable units at the site, and d;!::t"'.'Il$-Sin;J the
availability of the FS and p~ plans for those operable units.
'lhis Fact Sheet also outlined the other remedial alternatives,
aI'U1CA.D'1CE!d the p.1blic ccmnent period and solicited cx:mnent on the
alternatives .
An availability session in August 1989, to infoDnally answer
citizens' questions aba.1t the FS and p~ plans. Q,lestions were
answered by representatives of u.s. EPA, FWS and IEPA.
A p.1blic hearin;J on August 30, 1989, on the p~ plans and the
FS. Camnents were taken on the record. ~roximately 140 people
atten:led. Presentations were made, and questions were answered by
representatives of u.s. EPA, FWS and IEPA.
A p.1blic cx:mnent period of thirty days was originally planned,
ronnin;J fran August 18, 1989, to September 16, 1989. '!he public
cx:mnent period was anncunoed in the p~ plan for the qJerable
unit, in the Fact Sheet of August 1989, and through paid newspaper
advertisements in the Salthem Illinoisan and the Marion Drily
Rep.Jblic. Based on cxmnent taken at the p.1blic hearin;J on August
30, 1989, and letters received, the cx:mnent period for this qJerable
unit was exten::led three times, lU'1til December 1, 1990, for a total
ccmnent period of 105 days. '!he extensions were anrxJl.1OOeCl by
letters to the iniividuals and graJpS on the mailin;J list, at public
meetin;Js and by press releases.
A seoon:l p.1blic hearin;J on Oct:d;)er 3, 1989, ~ifically on the
prcposed plan and ]:'F!!mAdial alternatives for the PCB Areas qJerable
unit. Additia1al p.1blic ocmnent was taken on the record.
Presentations were made, and questions were answered by
representatives of u.s. EPA.
A Responsiveness SUrrmary addressin;J cxmnents and questions received
durin;J the p.1blic ~11t period on the RI,IFS and p~ plan is
inc1\Xled with this Record of Decision as the third section.
'lhis decision d/XI-nt presents the selected remedial action for the PCB
Areas qJerable unit at the Crab Orchard Na:tional Wildlife Refuge
Sl1perf'uni site, in cartezville, Illinois, chosen in acx:ordan::x! with
CERCIA, as aIneR:1ed by SARA and the National Contin;Jerx.y Plan. '!he
decision for this operable unit at the site is based on the
Administrative Record.
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IV. SCDH: AND IDIE OF OPmAmE UNIT
'!he first step in the RI prcx::ess Was a review .of available Refl..¥;Je files
ani old analytical results to target "study sites" to be investigated in
depth. 'Ihirty-three study sites were investigated duriIg the RI, with
seven of these carried into the FS for evaluation of remedial
al ternati ves.
As with many SUperfund Sites, the problems at the Refl..¥;Je are carplex.
'Ihe results of the investigations of the study sites in:iicated that the
Refl..¥;Je consists of several geograIi1ically distilct areas with markedly
different characteristics. '1hese irx:lude differences in the
contaminants, in the parties responsible for the contamination, ani in
the remedial actions ani schedules that wculd be appropriate.
O:msequently, the Aqe:rcy decided to address these areas in:iividually as
"~le units" of an overall site remedy. '!he followiIg four ~le
units have been created:
PCB Areas - those areas contaminated with PCBs, TNhich may also
be contaminated with other materials, such as lead ani cadmium,
includiIg study sites 17, 28, 32 ani 33.
Metals Areas - those areas priJnarily contaminated with heavy
metals, irx:lu:ti.ng study sites 15, 22 ani 29;
Explosive/ z.tmitions Areas (fomerly designated as "OOD Areas")
- those areas thought to be contaminated with chemicals fran
explosive or rmmitions manufacturiIg, includiIg study sites 3,
4, 5 and 19; ani
Miscellaneous Areas - those areas that are thc::u1ht to require
no further work or that will need further investigation,
lOOnitorin:J or ma~, irx:ludiIg sites 7, 7A, 8, 9, 10, 11,
llA, 12, 13, 14, 16, 18, 20, 21, 24, 25, 26, 27, 30, 31, 34,
and 35.
t1n:ler the National COntin:Jency Plan, response actions may be corxlucted in
cpmWle units, provided such units are consistent with achievin:J a
pemanent remedy. Further, iIrplementation of cpmWle units shcW.d begin
before selection of a final remedial action for the Site "when early
actions are necessary or awropriate to achieve significant risk
reduction quickly, when phased analysis and response is necessary or
appropriate given the size or carplexity of the site, or to expedite the
carpletion of total site cleanup" [40 CFR 300.430(a) (1) (ii)]. 'lbese
oorW.tions are satisfied in this case. First, the prop:lSEd cpmWle
units are consistent with achieviIg a pennanent l.~ at the site sime
they will, in fact, provide pennanent remedies for the designated areas.
Secc:ni, p~irg by cpmWle units is sensible in this case because the
nature of the problems in the different areas requires a phased awroach
given the size ani cx:nplexity of the site and the fact that the
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btplementation of remedies for the operable units will ~te site
cleanup ani the reduction of risks from the operable units. .
'!his Record of Decision addresses the PCB Areas opeI'able unit. '!he four
study sites cxuprisin;J this operable unit are: the Jab Corps I.an:ifill
(site 17) i the Water Tower I.an:ifill (site 28) i the Area 9 I.an:ifill (site
32) i ani the Area 9 a.rl1~ carplex (site 33) (See Figure 2 in AR?eniix
A) . '!he re:lIeuy selected will ad:iress the principal threats of soil ani
-nbnent contamination at all four sites canprisin;J the operable unit
am will mitigate future surface water ani grourdwater contamination.
'!he Ieli.eJy for the PCB Areas operable unit is the secorxi of at least four
operable units planned at the site. '!he PCB Areas operable unit fits
into the overall site strategy by addressin;J the principal threats fran
the four sites contaminatai with PCBs. (Lead is a co-contaminant at three
of these sites). '!he waste materials will be treatai to destroy the
FCBs, ani the metal-bearin;J residue will be contained on-site. since the
PCB Areas pose sane of the na;t significant risks currently identified at
the Refuge, remedial action for those areas should be initiatai as
quickly as possible.
Each of the other operable units is on a separate schedule. '!he
schedule for each operable unit will be established in an upc:x:min:;J
revised Interagency Agreement aI'lX:)l'q the u.s. EPA, OOI, OOD ani IEPA,
which is expected to be canpletai in September 1990. Depen:iirg on
acktitional information, other operable units may be creatai or oanbined,
as CiR;)ropriate.
A Proposed Plan for the Metals Areas operable unit was released by u.s.
EPA at the same time (August 1989) as the Proposed Plan for the PCB Areas
operable unit. '!he Proposed Plan ani required !AJblication of notice
occurred concurrently for the PCB Areas am Metals Areas operable units.
Because of public corx::em aba1t the incineration c::arp:ment of the
preferred alternative, the !AJblic ccmnent period for the PCB Areas was
exten::led three times for a total of one hun:ired am five (105) days of
!AJblic ccmnent. A final lClllcUY selection for the Metals Areas operable
unit was made on March 30, 1990.
v.
srm ~cs
'lhe RIfFS was cxn1ucted to identify the types, quantities am locatia1S
of oantaminants at the site ani to develcp ways of solvirq the problems
they present. Because of the size of the Site, the first step in the RI
process was a reviSri of available Refuge files ani old analytical results
to target "stuiy sites" to be investigatai in depth. '!he nature ani
extent of actual or potential contamination relatai to the stuiy sites
was determined by a series of field investigations, incluclin;:
geqi1ysical surveys;
surface soil scmplin;J i
exploratory test pit i11sta1lation an:i sanplin;Ji
installation an:i sanplirq of grourdwater mnitorirq wells;
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surface water sanplin;; am
sediment sanplin;J.
soil am ~;mP.nt sanplin;J in the fa.lr areas catprisin;J the PCB Areas
~le unit in:licate the non-unifom p~ of PCBs ani lead, ani the
less consistent presel'O! of other organic ani inorganic contaminants.
'!he fa.lr areas are all located in the portion of the Refuge where visitor
aca!SS is restricted, so human exp::sure to the contaminants is sporadic
ani occasional. HoINever, the areas are wooded ani it is likely that
wildlife are currently ~ to the contaminants.
'!he Jci;) Corps I.an:1fill site (study site 17) is catprised of an
~roximately one-acre larxlfill adjacent to a man-made pord which has
been drained since. the catpletion of the RI in 1988 (see Figures 3, 4 ani
5 in ~ A). Aerial ~ in:licate that the area was used
Oller an extended period for dunpin;J, ani became inactive sanetime prior
to 1960. '!he pord was created in the mid-1960's by danmin;J a drainageway
leadin:J to crab 0rd1ard lake. Soil sanples fran the lanifill am
sediment sanples fran the Jci;) Corps Porn in:licate the p~ of PCBs,
lead am cadmium, with other organic ani inorganic contaminants of less
concern fooni in the soil, sediments, pord water am gram:iwater. '!here
are an esti1nated 1400 cubic yards of soil am sediment contaminated with
PCBs. ~roximately 620 cubic yards of this material are thcught to be
c::o-contami.nated with metals.
'n1e Water TcMer lanifill (stLxly site 28) consists of an open field which
gradually slopes to the oortheast. '!be slopirg oortheast face is
heavily overgrown an::l slc:pes dawn to a wocxied area. '!he fill area is
~roximately one acre, located oorth of the Water Tower (see Figures 6
am 7 in ~ A). Aerial ~ .in:licate that the area was used
:inteJ:mittently Oller an extemed period for durrpirg, am ~mP inactive
sanetime prior to 1971. Dcwn-slope drainage areas were also investigated.
soil sanplin;J at the Water Tower I.an:1fill shawed sane localizej spots
with PCB am lead. contamination pri1narily below the surface. An
esti1nated 1000 a.tbic yards of soil are contaminated with lead. am K:Bs.
Other inorganic am organic oontaminatiat fooni in soil am gram:iwater
at this study site will be addressed durin;J confinoation sanplin;, or as
part of remedial activities.
Area 9 is a manufacturirg site at the Refuge. '!he Area 9 I.an:1fill (study
site 32) is located abaIt 100 yards scuth of crab 0rd1ard lake am 100
yards east of the Area 9 adldin;J Catplex (study site 33). '!he 1arxlfill
is approximately 2.5 acres with an esti1nated depth of 6 to 10 feet (see
Figures 8 am 9 in ~ A). 'Ihe lanifill was reportedly uSed fran
the 19508 \D1ti1 1964, am durirg the active life of the lanifill a
variety of imustrial wastes were burned, c::atpacted in a swale am
ocvered. RLmoff fran the 1anifill can drain into an intermittent creek
am into crab 0rd1ard lake. '!he Area 9 a.1i.1dirg O:Irplex (see Figures 9
am 10) has been oocupiej by several :in:iustrial tenants, ircl\.¥iin}
5argaItD westal, Inc. fran 1946 to 1962. It is currently oocupiej by
Olin, Cozporatiat, am aooees to sane areas has been closed. '!he
contaminatiat in the b.1i1din;J CCII'plex priIDarily centered arc:urd two
7
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tuilctin;r-;, numbers 1-1-2 ani 1-1-23, ani in tv.'O drainage ditches which
receive I'\JlX)ff fran the tuildin;J canplex. ARJraximately 36,000 cubic
yards of soil ani sediments in Area 9 are contaminated primarily with
PCBs. Of these, awraximately 2000 cubic yards are co-contaminated with
lead. In addition, soil, sediment ani groun:;lwater at this study site
sha,wed sane other inorganic ani organic contamination of less ooncern.
VI. ~ OF SITE RISRS
'Ibis Record of Decision addresses the PCB Areas operable mrlt. 'n1e RI
Report irx:luded a risk as.~t to define the actual or potential
threat that the Site-related contaminants pose to human health an:J,Ior the
envirornnent. Since the Site is a National Wildlife Refuge, particular
attention was paid to the potential iItpact on wildlife.
'!he ooI, as tIustee for Refuge lards ani for fish ani wildlife at those
lards, 1m.lSt ensure that remedies adequately protect ani restore those
tIustee :resources. Coin; so, in many cases, requires staniards nDre
strin;ent than or different fran those that may apply primarily for human
health reasons for sane contaminants. In praoulgatin; the regulations
for Natural Resource D:unage Assessment (43 em Part 11; Type B
Regulations, Final Rule, 51 FR 27673-27753, August 1, 1986) ooI addressed
the difference in staniards for natural resource damage assessment ani
remediation for human health p.1rpOSes. 'n1e tIustee can only agree to a
covenant not to sue urder Section 122 (j) of CERCIA if a PRP agrees to
un:3e.rtake awropriate actions neoessary to protect ani restore natural
:resources damaged by actual or threatened releases of hazardous
substances.
D:unage assessment ani restoratiat are carrie:i aJt for the pn:pose of
-------
assessment. '!here are J'X) starnards for wildlife exposure ani wildlife
contaminant residues, so risk assessments ¥.'ere used ani exposures
cx:trpared to toxicity information on other species.
'!he results of the risk as!:'oosment con:lucted as part of the RI fcx::us on
the contaminants which pose the highest risks of exposure to humans ani
the envi.roranent, even though other contaminants (posirg lesser risks) may
have been fOUJ'Xi at the site. OVerall, the risk assessment indicates that
the followirg problems present the greatest threat to human health ani,lor
the environment fran the four study sites that c:arprise the PCB Areas
cperable 1.D1i t:
SUrface soils at the Jab COrps I.an:lfill, the Area 9
I.an:lfill ani the Area 9 arildin;J Cclrplex to both humans
ani wildlife;
SUbsurface soils at all four study sites, especially to
l:Jurrc:Mirg wildlife;
Sed.iJnents at the Jab COrps I.an:lfill ani Area 9 to
wildlife directly ani to humans through focxi chain
accumulation; ani
Exposures of small ani l:Jurrc:Mirg wildlife to contaminated
air at all four study sites.
Alt.ho.xJh contaminants ~. fOJrrl in other media (gI'01.D'rlwa.ter am surface
water) at the study sites cc:.rtpris~ this operable 1.D1it, the risk
assessment does mt indicate that these contaminants currently pose a
threat to human health ani,lor the environment. However, potential future
gI'01.D'rlwa.ter contaminatiat is of great cxn::ern because the aquifer is
potentially usable ani may disc:haJ:ge to a sensitive ecosystem, for
exarrple, a ~ani. Also, the potential that ruooff will adversely
iIrpact surface water is of cxn::ern partiallarly because Crab orchard Lake
is used as a drinkin;J water sam::e. '!he areas CXI1pris~ the PCB Areas
cperable 1.D1it are within the portiat of the Refuge where human aooess is
currently restricted. Hcwever, if the restrictiat were relaxed in the
future, the risks to humans cxW.d be higher \mless ~; al actim has
been taken. It is infeasible to restrict all wildlife aooess to
contaminated areas.
A Sl1111DarY of the risk assoo~rrt: fran the RI Report for each of the sites
CXltprisin) the FCB Areas cperable unit follows:
A.
SITE 17: JOB CDRPS IANDFIIL AND laID
1.
Contaminant Identificatiat
sanplirg was done at the soil, sediment, gI'01.D'rlwa.ter, pon:i
water an:i fish fran the pon:i. Results indicated that the soil
an:i sediment contained PCBs at 0.08 to 50,000 milligrams per
kilogram (Dg/kg), lead in a ran;Je of fran less than 6 to 17,414
9
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nq,/kg, ani cadmium in a ranqe of fran less than 1. to 57 nq/kg.
Sane of the contaminated soil is hazardous by the Resa1roe
Conservation ani Recovexy Act (RCRA) characteristic test for
lead1able metals (EP Toxicity) . '!he pond water contained R::8s
at 0.032 to 0.058 micrc:AJlams per liter (ug,tL), which ex~s
the Ani>ient Water Quality criteria (1U'Q:) for freshwater
aquatic life am human health. '!he grc:JlU'¥:1 water contained R::8s
ran:J~ fran 0.01 to 15 ug,tL, with these sanples, exoeedi.rq the
1U'Q: for freshwater aquatic life ani human health ani bIo
sanples exoeedi.rq the proposed Maxinum Contaminant Level (MCL)
of 0.5 ug,tL. In addition, limited groun::iwater sanples
contained chloroform at 12 ug,tL, which ex~s the 1U'Q: for
human health, pentachlorq:X1enol at 19 ug,tL which ex~ the
1U'Q: for. freshwater aquatic life, lead at 55 ug/L, which
exceeds the MCL, ani c:hranium at 74 ani 139 ug,tL, which ex~s
the MCL.
2.
ExDOsure Assessment
'!he exposure assessment coniucted as part of the RI corx:lu:ied
that several media could be iI!pacted by the contaminants at
this site, an:i that there were several potential exposure
routes for contamination. Mean an:i worst case levels of PCB
contamination in soil were used to corxiuct the risk assessment.
Also, upper bcAm:i estimates of soil contamination with lead an:i
N-nitrosodimethylamine were used to estimate risk. Cadmium was
~9~9Ssed qualitatively.
'!he proximity of the pond ani vegetative caver on the lan:lfill
make the site an attractive demin:J habitat. Exposure was
quantified for deer, mallard ducks, ral:bit, m::use, mink, heron
an:i otter. Exposure of wildlife to contaminants waIld occur
through ~estian, inhalation, an:i ahsoIption through the skin
or gills. Animals on the site ~d be exposed to contaminants
through irgestion of soil, sediment an:i water as \/ell as
through consunption of contaminants that bioaCCUllD.1late (PCBs
an:i cadmium) in vegetation an:i prey. Groani.rq an:i inhalation
of contaminated dust an:i vapor also expose animals (especially
b.1rrowin;J animals) to oontaminants in ~;lIIP1'1t or soil. Dezmal
or percpera.tlar ahsoIption is a primary exposure route for
aquatic organisms sum as fish an:i macroinvertebrat.es, an:i is
also an exposure ra.tte for animals that maintain skin contact
with ocntaminated soil or sediment. calculations for the
inhalation route inclu:ied factors relat~ to active (one
boor/day) an:i inactive periods.
Althcu3h acx::ess to humans is restricted, the exposure
assessment indicates that there is the potential for occasional
recreational users to be exposed via inhalation or in;Jestion of
the contaminants, an:i through potential food d1ain
acnmu1atim. '!be exposure asSC3SC!!ft011t assumed limited human
aooess of three visits per year for foor hours per visit. It
10
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was also assumed that a htnnan might inadvertently consume 100
JIg of contaminated soil or sedi1rent per visit by in3'estion.
(Irqe:stion of soil is a. staroard pathway for eJ
-------
4. . Risk O1aracterization
usin; a unit risk factor of 7.7 (Irg/kqlday) -1 for human
exposure to PCBs, the W'1rel'nediated site shc:IINs a potential
in::reased cancer risk of 1.1 x 10-3. Usirg a cxmparison to
estimated cancer risk, the human exposure to N-nitrosocli-
methylamine wcW.d result in an excess cancer risk of 2 x 10-7.
'Ibis risk wcW.d be additive with the risk fran PCB exposure,
resultirg in a current risk exceeclirg u.s. EPA's guidelines for
"acceptable risk". 'Ibis assessment is based on very limited
human exposure, as n; ~JSsed above, ani represents current risk
fran the W'1rel'nediated site. If future use ~""e to allow
greater access to the Site, the risk fran the \n'1re.mediated site
wcW.d be greater. '!he qualitative ~c;SOOsmi?nt con:1ucted for
cadmium ccn::ludes that chronic human exposure to cadmium-
CXJnta:minated soil shc:W.d be investigated quantitatively. '!he
risk characterization irrlicates that no chronic or acute
systemic health effects to humans wcW.d result fran exposure to
the lead contamination at the site unier current access
limitations.
since the Refuge was established to protect wildlife, the risk
aSE'oosment also considered risk to wildlife as a pri1naJ:y factor
in the selection of the leluedy. Small mammals are use::l in
assessments for small CXJnta:minated areas because these mammals
are frequently at greatest risk, ani their small hane ran;e ani
available toxicity information reduces ~inties in the
resultant ass~sment.
'!he risk d1aracterization for wildlife oarpared estimated
exposures to PCBs for deer, mallaIds, ra1::bits, mice, mink,
heron ani otter to data fran laboratory tests. '!he conclusion
is that the fish-eatin; species may be the DWJSt affected, am
that the \n'1re.mediated site may present c:orx::ems for
reproductive am teratogenic effects, possible overt lethality,
am other systemic toxicity in vertebrate species. It is
reasonable to a5SJ- that predators am amivores c:xW.d be at
great risk, thraJgh OOI1S1.mption of organisms with
bioat"Y"l1JTlluated levels. A small animal, such as a m:JUSe or
ra1::bit, will cxmsume a proportionally very high anomt of PCBs
whi.d1 cxW.d have adverse effects on the aniJDal. In ad::lition,
bJrrowirx] animals pat:entia1.ly rea!ive levels of exposure to
PCBs, lead, am N-nitrosodimethylamine which c:xW.d result in a
variety of adverse effects, m::lOOirg carcinogenic respoILge,
reproductive inprlrment, am other inpacts.
B.
SITE 28: WATER 'D:MER IANDFILL
1.
contaminant Identification
!b;t of the information d1aracterizin; the waste at this site
is a result of the test pit sanplin; done for the RI. 'lhere
12
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"
was no evidence of contail1e.rs or containerized. wastes in the
investigation. '!be surface soil of the site generally ~
to be free of oontamination. However, subsurface soil was
famd to be oontaminated at sane locations. Results in:ii.cated
that soil is oontaminated with PCBs (fran less than 0.01 to
8,900 my'kg) am lead (fran 13 to 4,300 ng,Ikg) . Inorganic
~ of in c::on::entrations of less corx::em than lead ~
also detected in sane soil samples. '!be lead levels are
t.haJght to be high ena.tgh that the soil woold be considered
RCRA hazarclc:us waste for the d1aracteristic of EP Toxicity.
unfiltered groon:iwater samples exceeded the MCI.s for iron (fran
425 to 94,600 u;JjL) am ~ (fran 357 to 2780 u;JjL) ;
l'1c:7w1ever, the MCI.s for iron am man;JaI1eSe are sec::ormry MCI.s,
based on odor or taste. One unfiltered groon:iwater sample also
contained du'anium (165 u;JjL) am lead (76 u;JjL) in ex~;>I~ -
of their MCI.s, D.1t the dissolved metal c::on::entrations ~
bela« these stan::1ards ( dissolved levels may be more
representative of contaminant It'OVement than total unfiltered
levels) .
2.
Exoosure Assessment
'!be ~ assessrtelt con:iucted as part of the RI concluded
that, in general, iJtpact on environmental CXI!'pOJ1eJ'1ts is limited
where the contaminants are famd at depth. However, exposures
ca.1ld result if J::mTowin;J manmals dug dens or raceways in the
fill material, or if the site experienced erosion or other
d.ist:umanoe .
3.
Toxicitv Assessment
'!be toxicity of PCBs am lead are ni~1S'S=ed in paragrapt A.2
abave.
4.
Risk Characterization
Quantitative risk ~c:::mpJ'1t was oot oarpleted for this stu:ly
site due to the limited rcutes of current~. since the
~ a~"'csC!lN:01"Jt concluded that the wastes are famd only at
depth in isolated patches, there is currently no potential
route by Wich human receptors may be exposed. SCIDe
uncertainties Wich ~ oot addressed woold be the future use
of the lam am the resultant fate am transport of
oantaminated groon:iwater.
'!he risk asS'OO'C!IN:01"Jt c:xn=luded that ~ to humans am
surface-dwellin;J wildlife was likely to be miniJDal because
clean soil provides a barrier to oantamination iran Sl1bsurface
soil. However, aJ'1i1Mls ~ into the fill material woold
be exposed to lead am PCBs am ca.1ld receive potential levels
of ~ Wich ca.1ld result in a variety of adverse effects,
13
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inc1udi.n;J carcimgenic response, reproductive .i.npairment am
other iItpacts.
c.
SITE 32: ARFA 9 lANDF'IIL
1.
contaminant Identification
Analysis of soil on the surface am at depth in this landfill
am in soil sanples ~dient of the landfill inticate that
lead (fran 11 to 20,500 ngJkg) am R:Bs (fran less than 0.5 to
88,000 ngJkg) 'NeI'e foun:i. Further analysis of the soil was
corxiucted to asf!~c; the presence of chlorinated clibenzo-p-
dioxin (00) am clibenzofuran (OF) isaners. 'lbese ~ are
typically foun:i as co-contaminants where R:Bs are manufactured.
In this case, they may be elevated beyon:! expected levels clue .
to uncontrolled 00m:in:J of PCB products. Soil analysis showed
elevated levels in sane sanples of tetrachloroOF (fran 0.14 to
26.3 miCt~Lams per kilogram (ugJkg», pentachloroOF (0.34
ugJkg) am octachlorooo (fran 0.6 to 20.6 ugJkg). Sediment
sanples taken fran the drainage channel up am down stream of
the landfill showed contamination with R:Bs (fran less than 0.5
to 11 ngJkg) am lead (fran 11 to 29 ngJkg). R:Bs were also
foun:i in lake sediment sanples (fran less than 0.5 to 4.09
ngJkg). '!he gra.n:iwater contained R:Bs in sane ~ls above the
ambient water quality criteria for human health (fran less than
0.005 to 0.044 uq/L). In addition, d1rani.um was foun:i in one
unfiltered saItple above the r«::L (92 tr;J/L). However, the
dissolved level in this sanple was below the r«::L (1.2 uq/L) am
dissolved levels may be mre representative of contaminant
m:wement than total levels.
2.
ExDosure Assessment
'!he exposure ~t con:luct:ed as part of the RI concluded
that several media CCA.1ld be iItpacted by the contaminants at
this site, am that there 'NeI'e several potential transport
ro.rt:es. 'lhe viable exposure rootes for. humans evaluated in the
risk ass~c::mAJ1t inc1me air, surface water (inc1udi.n;J the
bioacx::unulatia'1 of contaminants in edible fish tissl1~) am
direct oontact. A mean level of PCB contamination in soil of
3,200 Dg/kq was used to oc:niuct the risk assessment. In
addition, a representative inteJ:mediate oonoentration of 4,000
m;Vkg for lead was used in the assessment.
Altha1gh .................. to humans is restricted, the exposure
ass~~ in:licates that there is the potential for occasional
recreational users to be eJq)OSed via irIhalation or injestion of
the contaminants, am t.hrcu;Jh potential food d1ain
a001llll]1 atial. '!be exposure asscsc::mA..1'1t 8~~UMd limited human
a~'" of three visits per year for four ha.1rs per visit. It
was also "ssl1~ that a human might inadvertently consume 100
JIg of contaminated soil or sediment per visit by in3'estion.
14
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(In:;Jestion of soil is a starmrd pathway for exposure in humans
am wildlife risk assessments.) Inhalation exposure \ro'O.lld be
~.lLIIlly assumed for FWS personnel on worksites or for
in::idental visitors to the contaminated sites.
'!he presence of contaminants in surface soils am ~i ~nts
indicates that direct contact by wildlife ca.1ld result in
exposure thra.1gh in;}estion of the soil, sediment or water, am
thra.1gh potential OOl1SUII'ption of contaminated vegetatiat am
prey because potential food chain exposure is particularly
likely with PCBs; thra.1gh inhalation, especially by 1:m'rc:Min;}
animals; am thra.1gh direct exposure of aquatic organisms or
in;}estion of water, sediments am organisms associated with
surface water as the contaminants migrate toward Crab Orchard
lake. To ag-9SS potential wildlife exposure, an assurrption of
one boor of active 1:m'rc:Min;} per day was ~ighted with a
restin;} exposure estimate in::ludi.rq breathin:J, feedi.n; am
groc:mirg activities.
3.
Toxicitv Assessment
'!be toxicity of PCBs am lead are r1i~JSSed in paragra(:h A.2
above.
Polychlorinated d.ibenzo-p-dioxiI1s am d.ibenzofurans are of
ccn:x:u:n because two members of these classes, 2,3,7,8 -
tetrachloro 00 and 2,3,7,8 - tetrachloro DF, are highly toxic
with acute am chronic ~ am produce a rn.nnber of chronic
disorders in::lu1in;J :iJnnunotoxicity, teratogenicity,
reproductive toxicity am suspected human carcinogenicity.
AlthaJgh other isaners are also toxic, reIOOVal or additiat of
chlorine atans decreases toxicity, as does substitutiat to
other }X)Sitions.
4.
Risk Characterization
Us~ estimates of exposure to lead, an c:xxasional visitor to
the contaminated area ca.1ld be exposed to 8.7 ug,/kg/visit.
'lhi.s is below a chronic, no-effect level of 0.32 nq,/J
-------
unremecliated site shows a potential increased canoe.r risk of
7 x 10-4. 'Ibis ~'"'~~sment is based on very lbnited hmnan
exposure, as di !C:l""I1ssed .above, ani represents o..u:rent risk fran
the unremecliated site. If future use 'Nere to allC7.i greater
access to the Site, the risk to humans fran the unremectiated
Site \VW.ld be greater. Additionally, a variety of human
exposure scenarios for PCB-contaminated fish fran Crab orchard
lake result in a ran]e of potential increased carrer risk as
high as 2 x 10-3 (see Table 1).
Significant wildlife exposure is likely. 'n1e risk
characterization for wildlife c:x:mpared estimated chronic PCB
exposures for mallard ducks, rabbits ani mice to U.S. EPA
chronic no-effect levels based on rat studies. 'n1e conclusion
is that the fish-eatin;J species may be the na;t affected, ani
that the unremecliated site may present risks for behavioral,
ilmunological ani other systemic toxicity in vertebrate
species. It is reasonable to assume that predators ani
annivores could be at great risk, t.hra.1gh COJ1SUlti'tion of
organisms with bioacamulated levels. A small animal, sudl as
a DOJSe or rabbit, will consume a prcportional1y very high
level of PCBs whidl could have adverse effects on the animal.
In addition, Wrrowin;J animals ani other terrestrial wildlife
receive potential levels of exposure to lead whidl could result
in a variety of adverse effects, includin; behavioral,
reproductive iDpainnent, ani other iDpacts. 'n1e corx::lusion is
that the unremectiated site waild pose a risk to wildlife of
chronic, toxic effects fran lead.
D.
SITE 33: ARFA 9 BJIIDING cx:MPI.EX
1.
CQntaminant Identification
Analysis of soil within this blildin;J OCIIplex :in:ticates that
contamination primarily centered ara.tn:l two blildin;Js, numbers
1-1-2 ani 1-1-23, ani in two drainage ditd1es whidl receive
runoff iran the b.1i1din;J CXlrplex. Soil in the b.1i1din;J
CXlrplex ani -d~nt in the drainage ditd1es 'Nere contaminated
with PCBs (iran less than 1 to 120,000 Dg/J
-------
criteria for human health (fran 0.006 to 0.144 uq/L). .
O1ranium was foond in bIo unfiltered sanples above the !a..
(fran 50 an:! 113 u;J,IL).. However, the dissolved levels in these
sanples TNere below the MCL ( 1 an:! 1.3 u;J,IL, respectively) an:!
dissolved levels may be mJre representative of contaminant
movement than total levels. In addition, tridlloroethene was
foond in one well above the ambient water quality criteria for
protection of human health (906 u;J,IL).
2.
Exoosure Assessment
'!he exposure assessment corrlucted as part of the RI concluded
that several media cn.lid be inpacted by the contaminants at
this site, an:! that there TNere currently three :fu:octianal
transport rootes for human exposure iI¥=1u:iin; groun:iwater,
surface water an:! direct contact. However, because there are
no current users of groun:iwater am because of the relatively
low mbility of the contaminants, the risk assessment C01'X:luded
that the groun:iwater exposure route is not currently
:fu:octional. '!he assessment further concluded that the air
route of exposure was non-:fu:octional because of the
restrictions to enployees only. Levels of PCB contamination in
soil of 5,000 ng,/kg an:! in sediments of 200 ng,/kg TNere used to
con:iuct the risk assessment. Acces.s to humans is restricted at
the builc:tirg ocnplex to enployees, therefore the exposure
assessment only considered inadvertent ~ to ~;TnPrrt:s
in the drainage ditd1es down:3radient of the buildirq. A
further a""<:,O"'qnent shccl.d be done to consider potential
(iI¥=1u:iin; inadvertent) ~ to errployees at the build.in;J,
as well as future use scenarios.
'!he p~ of contaminants in surface soils an:! ~;TnP.J1ts
irxticates that direct contact by wildlife cn.lid result in
exposure ~ ~on of the soil, sediment or water, ani
~ potential CXI1SU1Tption of contaminated vegetatioo an:!
prey because potential fcxxi d1ai.n exposure is partio.1larly
likely with PCBs; an:! ~ inhalatioo, especially by
l:::urrcwin:} animals. However, the exposure as~~~ CXI1Cluded
that due to the imustrial nature an:! restricted access to the
site, the diversity an:! abm:3aooe of wildlife wcW.d be less
than at other areas of the Refuge. To as~$S potential
wildlife exposure, an assuuptioo of one hour of active
l:::urrcwin:} per day was weighted with a restil'g exposure estimate
inc1\XlinJ breathirg, feedin;J an:! groc:mi.n;J activities.
3.
Toxicitv Assessment
'!he toxicity of PCBs is t'I;cnlSc;;ed in paragraPt A.3 above.
'!he toxicity of polyd1lorinated d.i}:)enzodiaxins an:!
d.i}:)enzofurans is t'I;cnlSsed in paragntp1 C.3 above.
17
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4.
Risk O1aracterization
usin;J estimates of exposure to PCBs in ditch sediment only, an
occasional visitor to the contaminated area cculd be exposed
to 0.29 ug/kg,Ivisit. '1hi.s is below acute or sub-acute
threshold criteria, therefore the \mI"e1Dediated Area 9 a.1i.l~
CCltplex site WQJ1d not result in exposure to PCBs that WQJ1d
result in systemic toxic effects. Cntp:Ired to the estimate of
exposure of 11 ug/kg/visit at the Jd:> Cozps Pon:i, this exposure
to the unremedi.ated site shows a potential in:rea.sed carx:er
risk of 3 x 10-5. '1hi.s assessment is based an extremely
lilnited hmnan exposure, as ni~ above, an:! represents
current risk asD~seO only for the relatively low levels of PCB
contamination outside the ferred area. '!he risk within the
ferred areas WQJ1d be substantially higher. If future use were
to allow greater access to the site, the risk fran the
unremedi.ated site ~d be greater. A further risk
d1aracterizatian shalld include a quantitative assessment of
the risk fran the polyd1lorinated DO an:! DF isane.rs.
'!he risk d1aracterization for wildlife cx:It'pared estimated
d1roni.c PCB ~ for rabbits an:! mice to u.s. EPA d1roni.c
no-effect levels based on rat studies. '!he conclusion is that
the unremedi.ated site may present ooncems for behavioral,
:inm.mological an:! other systemic toxicities in vertebrate
species. It is reasonable to assume that predators an:!
annivores cculd be at great risk, tl'u:"cu3h OO1'1SUltption of
organisms with bioacx::urrulated levels. A small animal, such as
a m:JUSe or rabbit, will consume a prcp>rtionally very high
ano.mt of PCBs which cculd have adverse effects on the
intividual.
\
While potential adverse iJrpacts were identified, the RI did not ~SlJre
~ actual, current iJrpacts on wildlife. Res""""rch done by the FWS has
inticated the potential for adverse iJrpacts on wildlife above the Site-
specific cleanup criteria established by the FWS. '!here is on-
-------
address the threats arx:1/or potential threats identified at the stuj:y
sites within the operable \.D1it. '!he ms am Sargan¥:) Weston, Inc.
screened the list of alternatives. based on their effectiveness (Le.
protection of human health arx:1/or the environment, reliability),
iJrplementability (Le. technical feasibility, CCltpI.ian::e with identified
State an::l Federal regulations) an::l relative costs (i. e . capital,
operation an::l maint:enan::Je) .
In the Prop:sed Plan, eight remedial technologies, which \¥ere canbined
into thirty-fcm' (34) alternatives in the FS, \¥ere described. 'n1e
alternatives presented in the FS ran;Jed fran containment of the waste in
place to treatment to the maxiJrum extent possible. Varic:us canbinations
of the eight remedial technologies outlined belOlii \¥ere considered for one
or nDre of the fcm' stuj:y sites CCIIprisin;J the PCB Areas operable \.D1it.
Several of the thirty-fcm' alternatives presented in the FS i11coqx>rate
two or nDre of these technologies in the alternative. Finally, sane of
these eight technologies ~ incorporated into "consolidated remedial
alternatives" which are \.D1ique because they are the only alternatives to
address all of the stuj:y sites together. Public ocmnent was solicited
on the four "consolidated remedial alternatives" which \¥ere presented in
the Prop:sed Plan, on the thirty fcm' alternatives di~1SSed ~ the FS,
am on the eight technologies which \¥ere canbined to create the varic:us
alternatives.
BelOlii is a brief description of the eight remedial technologies which
\¥ere incx>qx>rated in the RI/FS into remedial alternatives; am the fcm'
"consolidated remedial alternatives," as well as the "no action
alternative" presented in the Prop:sed Plan:
A.
a:m'AINMENl' REMEDIAL TEaiNOLOGIES
i. Imustrial Lardfill - Contaminated soils am ~i~
woold be excavated am placed in an iniustrial lan:ifill. 'Ihi.s
"imustrial lan:ifill" would be a solid waste lan:ifill as
regulated by SUbtitle D of RCRA am 35 Illinois Administrative
Code Part 807. 'n1e lan:ifill would be c::onstzucted, at a minimJm,
with a sin;Jle c:x:arpacted soil liner am drainage layer. After
placement of the oa1taminated soil am ~i1llP.rrt:, the lan:ifill
would be covered with a cap c::onstzucted of c::x:arpacted soil, a
drainage layer, gravel, soil fill am topsoil. Upcn cxmpletion,
the lan:ifill would be vegetated. Groordwater am leachate
nadtorin;J, am routine mai.nt:er1aooe would be elements of the
lcnrtem requirements. Variations ioolu:ie oonstroctioo of the
industrial lan:ifill either on-site or off-site.
ii. TSC'A Lardfill - '!he Toxic ~ Control Act (TSC'A)
regulates certain activities involvin;J PCB oontaminatioo. A'TSCA
I.an:1fill is ooe that meets the design criteria required by this
law. PCB-ocntaminated soils am ~i1llPJ'1ts would be excavated am
placed in a TSC'A lan:ifill. 'n1e lan:ifill would be c::onstzucted of
a c::x:arpacted soil liner, a drainage layer, a synthetic membrane
liner, am a seocn:1 drainage layer. After planPmPJ1t of the
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ccntaminated material, the 'lSCA larxifill \VOUld be qavered with a
cap oonstructed of cx:upacted soil, a synthetic membrane, a
drainage layer, gravel, soil fill, and topsoil. Upon oarpletion,
the 'lSCA larxifill \VOUld be vegetated. GraIrrlwater and leachate
m::mitorirg, and rootine maint:enarx::e \VOUld be elements of the
lorq-te:nn requirements. Variations incl\Xie oonstructi.on of the
'lSCA larxifill either on-site or off-site.
iii. 'lSCA Cap - PCB-contaminated soils and sediments \VOUld be
left in place and covered with a low penneability TSCA cap. '!he
cap \VOUld be oonstructed of cx:upacted soil, a synthetic membrane,
a drainage layer, gravel, soil fill and topsoil. Prior to
oonstruction of the cap, sediments \VOUld be dewatered and all~
to chy, and the contaminated area \VOUld be sloped and graded to
provide drainage and a good constIUction surface. GraIrrlwater
m::mitorirg and routine maintenance \VOUld be part of the lon:;J-te:nn
requirements.
iv. Slurry Wall - Certain remedial alternatives whidl involve
the oonstruction of a 'lSCA cap also require the oonstruction of a
slurry wall for more c:mplete containment. A slurry wall is a
vertical barrier aram:l the contaminated area. '!he slurry wall
is typically oonstructed of a cement or bentonite mixture with a
very low penneability. '!he slurry wall acts as a barrier to the
m::we.ment of ccntaminated ~ter. 'l11is containment system is
coupled with ~ter extraction ~ls to ~e the
ccntaminated ~ter for treatment. '!his technology is
considered to provide additional safeguards against potential
future ~ter ccntamination if waste is left in place. '!he
risk assessment did mt imicate that ccntaminated ~ter
currently poses a risk. A slurry wall is considered in
alternative 3C for the Water Tower landfill (Section 5 of the FS)
and alternatives 2E and 3B for Area 9 (section 7 of the FS).
However, since slurry wall technology is mt feasible for all of
the PCB-contaminated sites, it was mt ;irxx)zporated into art:I of
the consolidated alternatives presented in the Plq)osed Plan.
v. IDW Pemeability Cap - Areas ~ ccntamination is. below
the excavatiat criteria, or fran where ccntaminated soil and
RM;1nE'nt have been excavated \VOUld be closed and covered with a
low penneability cap. '!he cap wa.tld be oonstructed of oarpacted
soil, a drainage layer, soil fill am topsoil. Rart:.ine
maintenance of the cover, as ~l as ~ter 1OOl'1i.torirg would
be part of the lon:;J-te:rm q>eration and maintenance requirements.
B.
TRFA'IMEN1' REMEDIAL TEaiNOIDGIES
vi. Incineration,l'D1emal Destruction - Contaminated soils and
RM;1IIPJ'1ts wa.tld be excavated and treated by incineratiay thema1
destruction in a TSCA c::arpliant incinerator. High ~.ratures
wa.tld permanently destroy the PCBs and other organic c:tJemicals.
Arrj metal contamination wa.tld mt be destroyed by incineratiay
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thermal destruction, bIt would be captured in the ash residue.
If the ash is detennined to be urxxmtaminated with the
constituents of concem, it would be replaced in the excavated
areas. If the ash is contaminated it waild be contained in an
iIX:lustrial lan:lfill (remedial techoology i). '!he inci11erator/
therlna1 treatment unit waild be either on-site or off-site.
DJr:in;J operation, air pollution control -~ would be used to
prevent contamination fran be:in;J released to the air.
vii. Stabilization/Fixation - Contaminated soils and ~ i mPJ'lts
and contaminated inci11erator ash waild be treated with bon:lin;J
agents whidl fix contaminants within the stabilized waste. '!his
tmatment makes the contaminants mre resistant to lea.dlirq.
Cement-based and li.me-based stabilization p~"'-es are oc::.moonl.y
used for fixation of metals and have also been used for treatment
of PCB wastes. 'lhe stabilized material waild be contained in an
in::lustrial lardfill (remedial techoology i) or a TSCA lardfill
(remedial technology ii).
viii. In situ Vitrification (ISV) - Vitrification is a fixation
process whidl would seal the contaminated soils and ~ i ~J'lts in
a glass or synthetic silicate mineral material. An electric
current generates high t:e.rrperatures whidl pyrolyzes organic
chemicals, such as I:cBs and encapsIJl.ates inorganic ~,
such as metals. '!he contaminated materials waild be treated in
place and covered with clean soil. '!his technology waild be
considered innovative treatment for the contaminated materia1.
In situ vitrification is considered in alternative lC for the
Water Tower landfill (Section 5 of the FS) and alternatives 1C
and 2C for Area 9 (section 7 of the FS). However, since this
technology is not feasible for all of the PC&-contaminated
material withaIt excavation and consolidation of soil and
sediment fran qeograprically clisti.nct stu:ly sites, it was not
.in:x:>zporated into any of the consolidated alternatives below.
C.
CDNSO~ REMEDIAL AIlI'ERNATIVES
'!he FS presents several consolidated remedial alternatives whidl
incozporate the abcNe ~ i;:l J technologies to adlieve a c1eam.tp
for AlJ. of the stu:ly sites oarpris:in;J the PCB Areas _cpmmle
unit. '!be advantages to a oonsolidated l.ewerJy are that the
c1eanJp can progl.~ DDre quickly and efficiently and that sane
ocsts can be saved.
In reviewin3' the PCB Areas operable unit Prcposed Plan, the
pmlic was asked to consider the oonsolidated ~ial
alternatives, and site specific I"PI'IAiial alternatives di~1Ssed
in the FS, as well as other possible c::x:mi>inations of the eight
remedial technologies listed above. 'lhese consolidated
alternatives are dic:nlSsed in Section 8 of the FS. '!he
consolidated alternatives also include saoe actions whidl affect
the Metals Areas operable unit, whidl were addressed in the Mard1
21
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()
1990 RJD for those areas. In outliniIg the consoli~ted
alternatives below, only the actions which effect the PCB Areas
cparable mrit are di ~l$~.
Consolidated Alternative 1
Fstimated Total Remedial Cost: $25,195,035 present worth
Fstimated Time to Inplement: 2.5 to 5 years
Consolidated Alte:rnative 1 includes the followin;J oc:rrqxments:
Excavation of Soil and Sediment - Contaminated soil and sediment
walid be excavated usin;J conventional equipnent. '!he excavated
material walid be moved to a storage area on-site, where it walid
be stored \mtil it was treated or disposed.
Incineration - Soils and sediments which are contaminated with
PCBs, but with 00 excessive metal contamination walid be
incinerated on-site, as described in remedial technology vi.
Non-contaminated incinerator ash walid be backfilled in the
excavated areas.
Stabilization,/Fixation - Soils, sediments and incinerator
residues which are contaminated with both PCBs and metals walid
be treated by stabilization;fixation, as descri.bec1 in ~ial
technology vii.
TSCA I..an:ifill - Materials which are treated by
stabilization,lfixation walid be disposed of in an on-site TSCA
landfill, as descri.bec1 in remedial technology ii. '!his
alternative proposro usin;J an existin;J five-million gallon
COIJC1.~te tank new on the Site, whidl ~d be retrofitted to meet
the required design st.arnards.
TSCA Cap - In Area 9, sane contaminated soil walid be left in
place. '!his area walid be covered with a TSCA cap, as descri.bec1
in remedial technology iii.
IJ:N Pe.z:meability caps - Soils and sediments which do not eoroeed
the cleamJp st.arnards at eadl of the four study sites walid be
covered in place with a low penneability cap, as described in
~ia1 tedmology v.
COnsolidated Alternative 2
Fstimated Total PEmedial Cost: $6,156,161 present werth
Fstimated Time to Inplement: 2 years
OJnsolidated Altemative 2 includes the followin;J oarp:ments:
Excavation of Soil and Sediment - Same as descri.bec1 in
OJnsolidated Altemative 1.
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stabilization/Fixation - Soils an:! sediments whien 'are
contaminated with high levels of FCBs (greater than 1000 parts
per million, or 0.1 percent) an:! heavy metals would be treated by
stabilization/fixation, as described in remedial t..ed'lrx>logy vii.
TSCA I.an::lfills - 'I\1o TSCA I.an::lfills, as described in remedial
t..ed'lrx>logy ii, would be constructed on-site. '!he first would
involve retrofitting' an existing' cxn::rete tank to meet the design
stan::3ards. '!his lan:ifill would be used to contain the majority
of the wastes treated by stabilization/fixation. '!he secorxi
would be newly constructecl near Area 9 an:! would contain all
treated waste that did not fit in the first lan:ifill an:!
W'1treated contaminated soil an:! sediment.
TSCA cap - Same as described in Consolidated AlteJ:native 1.
law PeJ:meability caps - same as described in Consolidated
AlteJ:native 1.
Cbnsolidated AlteJ:native 3
Esti1na.ted Total Remedial cost: $8,910,700 present worth
Estimated Time to Inplement: 2.5 to 3 years
Consolidated AlteJ:native 3 includes the follC1ili.n;J cx:mponents:
Excavation of Soil an:! secliment - same as described in
Consolidated AlteJ:native 1.
Iocineration - Soils ani sediments whidl are contaminated with
"nan-soJ:b:d PCBs" would be incinerated on-site, as described in
remedial t..ed'lrx>logy vi. Non-soJ:bed PCBs are these which are not
d1emi.cally bcu'n to the soil or ~;1IIPnt, an:! whim may be mI'e
available to nx:we. Non-sorDed PCBs are estimated to be foon:l in
soils or ~;1IIPJ1ts with contamination higher than 5000 parts per
millioo (or 0.5 percent). Before incinerating' the soils an:!
~;1IIPJ1ts, tests would be CCIIpleted to detennine the precise
levels at whim PCBs are sorDed, an:! thus, whim soils an:!
c:u:wH1IIP11ts walld require incineratia1. Na1-ccntaminated
incinerator residue might be backfilled in the excavated areas.
stabilizatiay'Fixatioo - Soils an:! ~;1IIPnts whim are
contaminated with high levels of PCBs (greater than 1000 parts
per millim, or 0.1 percent), whim have not been incinerated,
(an:! whim are oo-oontaminated with netals) woold be treated by
stabilizatiavfixatim, as described in ~al t..ed'lrx>logy vii.
TSCA I.an::lfills - Same as described in consolidated AlteJ:native 2.
TSCA Caps - Same as described in Consolidated AlteJ:native 1.
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c;
IDN Permeability Caps - Same as descr:ilied in Consolidated
Alternative 1.
Consolidated Alternative 4
Estimated Total Remedial Cost: $23,858,330 present werth
Estimated Time to Inplement: 2 years
Consolidated Alternative 4 includes the followin;J ccrnponents:
Excavation of Soil am Sedi1nent - Same as descr:ilied in
Consolidated Alternative 1.
Stabilization/Fixation - Soils am secliJnents which are
cont.ami.nated with "free PCBs" (am co-contaminated with metals) -
\¥OU1d be treated an-site by stabilization/fixation, as describe
in remedial technology vii. As descr:ilied in consolidated
alternative 3, free (or non-soIDed) PCBs are those which are mt
chemically ba.1rxi to the soil or sediment.
Off-site 'ISCA I.an:lfill - Both treated am \D1treated cont.ami.nated
soils am secliJnents \¥OU1d be taken off the Refuge am disposed of
in a 'ISCA larxlfill, as descr:ilied in remedial technology ii.
'ISCA Cap - Same as descr:ilied in Consolidated Alternative 1.
IDN Permeability C!ps - Same as descr:ilied in Consolidated
Alternative 1.
D.
NO AerIal RE1-tEDIAL AUI'ERNATIVES
Estimated Total Remedial Cost: $657,724
Estimated Time to I1rplement: less than 1 year
'!he National Cc.ntin;JeIx:y Plan (NCP) which contains the ocdified
regulations of the SUperfurrl pJ:cxp:am, requires that the "no
actiem" alternative be c:xn;idered at every site. un1er this
alternative, actiCl'l at arrj of the oontaminated areas is generally
limited to marl.torin;J of site oc:n:titions. All wastes, rootes of
contaminant migratiem, am 10R3-tem human am envi.roraDenta1
exposure pathways will remain~. '!his alternative ~d
net reduce the threats an:! potential threats to human health
and/or the envircnment identified at the site.
VIII .
'JBB ~~ lBtED'i
'!he Selected Remedy, as outlined below, will pennanently ~iate the
four study sites oarprisin;J the FCB Areas qJerable unit. 'Ihe Selected
Remedy is divided into three major ccrnponents: 1) treatment, 2)
Oa1tainment, am 3) general operatioo am maintenance. However, the
Selected Remedy allows for the treatment am containment ccrnponents to be
m:xtified based em a strirgent dem::mstration of the perfOJ:11lal'O! of an
24
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alternative treatJrent technology, in situ vitrification or .ISV. Unless
otheJ:wise specified, the tam "selected Remedy" when used in this
doc::mnent refers to the use of in situ vitrification only if a SI~sful
ciertonstration of the technology is made.
'!be selected Remedy will address the pr:in:::ipal threats to human health
am the envirorunent that currently exist at the foor stu:iy sites
c:::atprisirq the operable unit, am will prevent future threats am
envirorunental degradation. '!be treatment p~"'es selected for the
contaminated soil am sediment constitute treatment to the maxiJ1I..nn extent
practicable. contairunent of arrj metal-bearirq waste or treatment residue
will allow safe lorg-tam control of this material. '!be labor am
equipnent neoe'5-c:;ary to iJtplement the selected Remedy are, or will be
de100nstrated to be, currently available. Specific details on variaJS
aspects of the selected Remedy follow.
A.
MAJOR a::MFONENI'S OF SErECI'ED REMEDY
'!be selected Remedy for PCB Areas operable unit at the Crab Orchard
National Wildlife Refu;Je is an alternative which was not specifically
cutlined in the FS, bIt which :in:::ludes the Preferred Alternative in the
Prc::pJsed Plan am is a canbination of technologies identified in the FS.
'!be selected Remedy allows for the m:xiification of the selected
treatment am oontairunent ~ by substitutirq an alternative,
innovative treatment technology, in situ vitrification, for
:in:::ineration, based on the de1oonstration wtlined in Section 3 below.
If this c:ie.m:)nstratia1 is not satisfactorily c:::arpleted as described, the
1:e1(1edy as outlined in Section 1 below will be inplemented. '!be selected
Remedy, if :in:::ineratia1 is used as the treatment technology, will take an
estimated 3 to 5 years to inplement. If ISV technology is inplemented in
the selected Remedy, iIrplementation will require an estimated two years.
1. Selected Remedy (with incineration)
Excavation of Soil am ~imP-'1t - Soil am ~imP-'1t which is
contaminated aOOve the remediation goals presented in Sectia1 B
below, will be excavated usin;J conventional equipnent. '!be
excavated material will be m::IVed to a storage area on-site, where it
will be stored until it is treated or n;~. Design of the
project will require methods to prevent contaminated ~i.tnP.nt fran
m::IVln} into surface water am nethods to minimize dust. Design will
also :in:::1uje consideratiCl1S to ensure CClIpliaroe with awlicable or
relevant am ~riate requirements (ARARs), listed below in
Secticn X. B. '!he excavated material will be sanpled to determine
whether it is hazardoos as defined by RCRA, am hazarda1s am non-
hazardcus material will be stored separately.
Incineratiav'lhermal Destroction - All excavated soil am ~;mPnt
which is cantaminated with PCBs in exoess of the PCB ~iatia1
goals will be treated by :in:::ineratiav theImal destJ:ucticm. '!he
:in:::inerator will be a teDp>rcu:y, JldJile unit br<:U3ht oo-Site for the
duration of the project. After CClIpletion of the :in:::ineraticn of
25
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the PCB-contam:inated soil ani sediment, the in::ineratQr will be
decontaminated ani renDVed fran the site. Prior to full operation,
a trial tmn of the in::inerator will be used to establish the
operatin;J ccn:litions, ani on-goin;J :aonitorin;J of the unit will be
perfonned to establish that the remediation goals ani in::inerator
perfonnance stamards are bein;J met. Non-contaminated in::inerator
residue will be backfilled in the excavated areas.
Stabilization; Fixation - Soils, ~i1l1P.nts ani aIrj in::inerator
residue which is considered RCRA hazardoos because of the
characteristic to leach metals (EP Toxicity or Toxicity
Characteristic Leachin;J Procedure ('IcrP), whid1ever is the ~roved
regulatory test at the time of the remedial action) will be treated
by stabilization; fixation. Stabilization; fixation is a treatment
process where contaminated soils ani sediments will be treated with
bon:ii.rxJ agents which fix contaminants within the stabilized waste.
'!his treatment makes the contaminants m:lre resistant to leachin;J.
Cement-based ani lime-based stabilization processes are ~lIua.A1ly
used for fixation of metals. DJrin;J the remedial design process,
~ropriate mixtures of treatment materials will be evaluated to
assess their ability to iImd:>ilize the contaminants at the site ani
to effectively rerxler the material non-hazarda.1s ani the na;t
effective mixture(s) will be chosen. Also, a treatment quality
assuran:e plan will be developed to document the perfonnance of the
full scale treatment process.
IIxiustrial I.an:lfill - Excavated treated waste ani untreated non-
hazarda.1s materials which exceed the remediation goals will be
disposed of in an on-Site in::1ustrial larxifill. '!his "in::1ustrial
larxifill" will be a solid waste larxifill as regulated by SUbtitle D
of RCRA ani 35 IAC Part 807. '!he larxifill will be constrocted, at a
mi.nim..nn, with a sin;Jle c:arpacted soil liner an:i drainage layer.
After placement of the contaminated soil ani ~i1l1PJ1t, the larxifill
will be covered with a cap constrocted, at a mininum, of cx:rrpacted
soil, a drainage layer, a barrier to prevent bur.rowin;J animals, soil
fill an:i tq:Isoil. '!he final design will be determined by site-
specific c:haracteristics, the object bein;J to provide adequate
oonta.inment of the waste material. '!he final locatiat of the on-
site larxifill will be determined by investigations (inc1\Jdin]
hydrogeologic) oc:nmcted duri.n;J the remedial design phase to
establish aooeptable sitirq d1aracteristic:s. Upon CXltpletiat, the
lardfill will be cavered am vegetated. GraJRiwater am leachate
mcnitarin;J, an:i routine maintenance will be part of the lag teJ:m
requirements.
Backfill Excavation - Clean soil will be placed in the areas where
contaminated material had been rem:JVed.
I.lN PeJ:1Deability caps - Areas where contamination is belai the
excavation criteria, or iran where contaminated soil an:i ~i1l1PJ1t
have been excavated \oiI'CA1ld be closed an:i covered with lai
pemeability caps. '!he caps \oiI'CA1ld be constrocted of oc:mpacted soil,
26
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a drainage layer, soil fill am topsoil. RaItine mai.ntenarioe of the
caver wcW.d be part of the lorg-tenn requirements.
Monitori.n:1 ani Maintenance - '!he on-site lan:ifill am excavated
areas will require JOOnitori.n:1 of groun:iwater ani surface water.
Lorg-tem maintenance will be required for the lan:ifill am the low
penr&UJility caps.
Institutional Controls - '!he Refuge is currently \.m:ier the
management of the ooI, ani acx::ess restrictions are in place. '!he
Interagerx:y Agreement which is required by Section 120 of CERCIA am
which is expected to be c:arpleted by september 30, 1990, will
in;x)rporate lam use am transfer restrictions to be inp::sed at the
site.
'!he carp:ments of this Selected Remedy are corceptual, an:;! are based on
specific remediation goals, perfonnance standards ani ARARs. As a
result of the remedial design an:;! const.IUction processes, sane m:in:>r
c::harges may be made to the design features outlined above.
2. Selected Remedy (with Alternative Treatment Ted1noloav. ISV)
Excavation aOO;or Consolidation of soil an:;! Sediment - COntaminated
soil am sediment will be consolidated in one of the existi.n:1 areas
of contamination (IOOSt likely Area 9). COntaminated soil an:;!
sediment fran geograp1ically distinct study sites will be excavated
usin;J conventional equipnent am consolidated into the selected
area. Design of the project will require methcds to prevent
contaminated ~j~.nt fran 1I¥JVi.n:1 into surface water an:;! methods to
minimize dust. Design will also ensure CXIl'pliarna with ARARs.
In situ vitrification - Vitrification wcW.d be used to treat all
contaminated soil am ~;--J'1t which had been consolidated into a
sin;Jle area of contamination. No separatioo of soil am !l:AiiTnPJ'1t
contaminated with heavy metals will occur. '!he process wcW.d use
electrodes to generate an electric current ~ blocks of the
contaminated material to create a glass or synthetic silicate
mineral material. '!he electric current W'OOld generate high
telIperatures which will pyrolyze the PCBs am other ozganic
d1emicals. '!be inoJ:gan.ic ~, such as lead will be
eooapsulated in the glassy matrix. '!he area of contaminatioo which
is selected to be the site of oonsolidatioo of the waste will be
detemined by site specific characteristics, the pu:pose bei.n:1 to
provide adequate oantai.nment of the waste material an:;! to minimize
inpacts 00 artj sensitive ecosystem. '!he final locatioo of the
vitrified site will be detemined by investigations c:xniucted duri.n:1
the ~;;., design P1ase to establish acceptable sitin;
characteristics.
Backfill Excavatioo ;.. Clean soil will be placed in the areas where
contaminated material had been relIXJVed.
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IDtI Pemeability Caps - Both the vitrified area ani other areas
where contamination is belCM the excavation threshold criteria, or
fran where contaminated soil. ani secllirent have been excavated, ~d
be closed ani covered with lCM pe.nneability caps. '!he caps walld be
constructed of cx:rrpacted soil, a drainage layer, soil fill am
topsoil. Ra.1tine maintenance of the cover would be part of the
lorg-tenn requirements.
Monitor:in;J ani Ma.intenance - '!he vitrified area ani excavated areas
will require trcni tor:in;J of groun::lwater ani surfaoa water. I.an;J-tenn
ma.int.enarDa will be required for the lCM pe.nneability caps.
Institutional Controls - '!he Refuge is currently unier the
management of the OOI, ani access restrictions are in plaoa. '!he
Interagerx:y Agreement whidl is required by Section 120 of CERCIA ani
whidl is expected to be CCltpleted by September 30, 1990~ will
incorporate lani use ani transfer restrictions to be :i1tp)SE!d at the
site.
'!he CCI't'pOnents of the Selected Remedy us:in;J this Alternative Treatment
Technology, are COJ~Wal, ani are based on specific remediation goals,
perfo~ stamards ani ARARs. As a result of the remedial design ani
constn1ction processes, sane minor dlan;Jes may be made to the design
features ootlined above. '!he Alternative Treatment Technology will only
be inplemented as part of the Selected Remedy if oartain dem:.mstrations
ani COJ'Xtitions, as ootlined in Section 3 belCM, are met.
3. Deroonstration to AllCM Alternative Treatment Technoloav to be
Imclemented as Part of the selected Remedy
In order for the Alternative Treatment Technology ootlined in Section 2
to be iItp1emented rather than the Selected Remedy in Section 1, oertain
COJ'Xtitions ani denr:Jnstrations IIIJSt be met, ani approved by U.S. EPA. '!he
cx:rrp:ments of the dEm:mstration are ootlined belCM.
a. within the negotiation period (not to exceed 120 days) pJrSUal1t
to Section 122(e) of CERCIA ani follCM:in;J the issuance of a special
natioa letter relatilq to the perfo~ of remedial design ani
~ial action for the PCB Areas Operable Unit at the Refuge, the
pat:entially respcI1Sible party (PRP) in receipt of such special
natioe letter 1IIJSt infOIm the U.S. EPA in writilq as to whether it
inten::)s to perfcmn the treatability test for the Altemative
Treatment Technology (ISV).
b. '!be party respC4lSible for inplementin;J the Selected Remedy,
(OOI, or other parties in aexx>rdance with the Interagerx:y Agreement
due to be signed at or before September 30, 1990 or with the Consent
Decree coverin) the remedial design ani remedial action for the PCB
Areas Operable Unit, if any) if they so wish to perfOIm the
dEm:mstratiat of the Alternative Treatment Technology described
above, IIIJSt sutmit to U. S. EPA a workplan for the perfo:rmanoe of
treatability testin;J for the vitrification process within 180 days
28
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of the date on Wich u. s. EPA iSSl1~ special notice letters to a:rrJ
mPs relatirq to the perfOJ::1Ilal'X:e of remedial design an:i ~; ~l
action on the PCB Areas Operable Unit at the Refuge.
c. Upon ~ by u.s. EPA of the treatability testiIg workplan,
the responsible party(ies) 1IUSt CCtlplete the work required within
the schedule specified in the workplan.
d. If a treatability testiIg workplan is not su1:mitted within the
time period specified in b., above, or if u.s. EPA does not awrcve
the treatability testiIg work plan, the Selected Remedy as CJ.ltlined
in Section VIII.A.l., above, JDJSt be iItplement.ed.
e. If a treatability testiIg workplan is iItplemented, the party
responsible for iItple.mentiIg the Selected Remedy must su1:mit to
u.s. EPA, on or before the date that treatability testin;J results
are due, a dem:mstration that there is a ccmnercial ven::30r (or
ven::30rs), of the vitrification process that is able an:i available to
inple.ment the work on the scale am within the schedule required.
If no such ven::30rs are available, then the Selected Remedy as
CJ.ltlined in Secticn 1, above, JDJSt be iItplemented.
f. If a treatability testiIg workplan is inplemented, the results of
the perfOJ::1Ilal'X:e evaluaticn for the vitrification process will be
as~oosed by U. S. EPA. All of the followiIg perfOJ::1Ilal'X:e st:arnards
mJSt be deroonstrated (am the con::1itions above m.1St be met), in
order for u.s. EPA to fini that the Alternative Treatment
Tedmology (ISV) may be iJtplemented rather than the iR::ineraticn
technology as CJ.ltlined in the Selected Remedy:
(1) A carprehensive evaluation of the destruction of PCBs am
oo-oontaminant dioxins am furans by the vitrification process
JIL1St be made. Vitrification mJSt be able to match or exoeed the
destructicn am rem::MU efficien=y of 99.9999 , for the PCBs am
organic oo-oontaminant.;
(2) Vitrificaticn mJSt be able to meet or exoeed the 1 milligram
per kilogram dry soil ~j~tion goal for PCBs as required in
Sectioo B below;
(3) A oarprehensive evaluation of vitrificaticn's ability to
imDcbilize metals Wich are RCRA hazardous waste constituents
1II.1St be made. vitrification mJSt be shown to ren:ier l1CI1-
hazarda.1s all material Wich is hazardous because of the
characteristic to leach metals as 1DE'aSJJre by the 'laP test;
(4) I.ead1ability testiIg results for the vitrified waste mJSt be
CXJIi:)ined with hydrogeologic 100delliIg to dena1strate that l'D1e of
the grouniwater cleanup stardards required in Section B below,
will be exoeeded at the point of CCIlpliance (Wicb would be the
vertical plane thra.J;Jh the ck:Iwn;p:adient bcJurnaxy of the area of
ocntamina.ticn to be vitrified);
29
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(5) Treatability testin:] results, canbined with awropriate
IOOdelin:], nust denDnstrate that the surface water remediation
goals required in Section B below, will be met;
(6) A CXIIprehensive evaluation of the air emissions fran the
vitrification process must be made. Vitrification must be shown
to meet or exceed the air emission standards required in Section
X.B below; and
(7) '!he treatability testin:] results must dem:mstrate that
vitrification will meet the requirements of 40 CFR 761.60(e)
pertainin;J to Perfo~ of treatment alternatives to
i.rx::ineration umer TSCA.
g. If u. S. EPA fims that arrj of the Perfo~ staroards set forth
in (e), alJove, caJ'IlXJt be dem::mstrated, or that arrj other contition
listed above in Section VIILA.3 has not been met, then the selected
Remedy, as outlined in Section 1, above, must be inplemerrted. If
u.s. EPA fims that all of the Perfo~ standards set forth in
(e), above, can be dem::mstrated and that all the other contitions
listed alJove have been met, u.s. EPA will sen:i a notice in writin:]
to that effect to the party responsible for inplementin:] the
selected Remedy. within 30 days of receipt of sud1 notioe, the
party :responsible for inplementin:] the selected Remedy DL1St infonn
u.s. EPA in writin:] as to whether it will inplement the Alternative
Treatment Technology (ISV) or the i.rx::ineration technology as
outlined in the selected Remedy.
REMEDIATION GOAIS
B.
Remediation goals have been established for the study sites oatprisin:]
the PCB Areas ~le unit. '!he goals are based on the risk asg~sment
Performed in the RI Report, Wich evaluates potential risk to human
health and the envira1ment. '!be goals ~ then further refined to
reflect ooI' s specific ocncems and statuto%)' marx3ates for the protection
of fish and wildlife at the Refu;Je, and u.s. EPA's regiooal and natiooal
policies in establishirg remediation goals. FUrther refinement of the
remediation goals, particularly with respect to sufficient clean soil
caver to prevent translocatiCl1 of cxnt:am.inants by J::mrc7.rin;J animals, may
be necessary as a result of aatitia1al risk assoosment evaluatia1S. '!he
remediatioo goals for the study sites in the PCB Areas ~le unit are
iHcn1Ssed briefly below. Since, under the selected Alternative, saue
~ will remain at the Refu;Je in an cm-site landfill, the
effectiveness of the remedial actioo will have to be re-evaluated at
least evezy five years. Similarly, umer the Alternative Treatment
Technology, saue oontaminants will remain :iJmx:lbilized in the treated area
of oantaminatioo, so a five-year review, plrSU8l1t to Section 121(c) of
CERC::[A will be neoeB9MY..
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1. SOIL AND SEDIMENI' REMEDIATION GOAIS
OJntaminated soil am sediment at all of the stu::1y sites
c::arprisin;J the c:perable unit will be remediated to the followin;J
specific levels: lead to 450 milligrams (Irq) per kilogram (kg)
dry soil (1 Irq per kg is equivalent to 1 part per million):
cadmium to 10 Irq per kg dry soil: PCBs in the top foot (u
ind1es) of soil to 1 Irq per kg dry soil: PCBs in soil below one
foot depth to 25 Irq per kg dry soil: am PCBs in sediments to 0.5
Irq per kg dry ~i mP1'1ts. It is believed that a remedial action
which meets these criteria will address all of the other
contaminants at the sites. HC7.NeVer, the risk fran all of the
d1emical contaminants present above naturally ocx::urrin;J
backgroon:i levels established for the site in the soil am
sediment shall not exceed an excess cancer risk of one in one
million (10-6) am shall not exoeed coooentrations detennined to
produce any non-canoer chronic health effects.
In addition to bein;J treated to levels protective of wildlife am
of human health by direct contact, the PCB- am lead-contaminated
soils am sediments shall be treated to a level that is
protective of the gram:iwater. '!he soil remediation goals shall
be established at levels that will not allow leadli.n:J to the
gram:iwater am create gram:iwater contamination in exceedanoe of
the gram:iwater remediation goals established in Para~ 2
below. '!he method for calc:ulatin;J the soil renatiation goals
shall be ~roved by U. S. EPA. Methcrls for the develcpnent of
soil remediation goals can be fourxl in IlDet:ezminin:J Soil Response
Action Levels Based on Potential contaminant Migration to
Grourrlwater: A Carpen:tium of ExaIrples" (EPA, 0ctdJer, 1989).
'!he method DUSt be oc:rcpatible with the site soil CXIl'ditions am
contaminants.
2..~ REMEDIATION GOAIS
'!he gram:iwater at each of the stu::1y sites will be m:mitored
durin;J am after construction of the remedial action. '!he
m:mitorin;J results will be evaluated to assure that after
oatpletiat of the ~;"tia1 of the contaminated soils am
~;mP11ts, the risk fran All of the contaminants in the
gram:iwater (~!CDJred at the sooroe of contamination) above
naturally cxx::urrin:J backgroon:i levels shall not exceed any exoess
human health risk or any stardard. If, at any time, gram:iwater
at any of the ~iated stu::1y sites exceeds a 10-6 amulative
life-time cancer risk, or M:Is for carcinogens, whichever is m::>re
strin:Jent: am M::ts, maximJm contaminant level goals (laGs), or
a hazard in:Ex of 1.0, whichever is mre strin;Jent, for ncn-
carcioogens, aa:titiooal ~ial work as detennined by U.S. EPA,
shall be performed. '!he risk assessment shall follow procedures
established in the ''Risk Ass~~1'1t Guidarn! for SUperf'urn
Volume I R.mIan Health Evaluation Manual" (IW:;S) (EPA/540/1-
89/002) or any amendments thereof.
31
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3. SURFACE WATER REMEDIATION GOAI.S
'!he surface water of the Job Corps Porxi will be naritored dur~
am after constJ:uction of the remedial action, if CiR'ropriate.
Sin::e this pan:! was created by daInrnin;J a creek, it is likely that
there will be no water in the pord dur~ active remediation, am
no decision has been made whether this pord will continue to
exist after remediation. Arrj surface water at this site will be
DDnitored am the results will be evaluated to assure that after
canpletion of the remedial action of the contaminated soils am
secliments, the amulative risk fran all of the contaminants in
surface water above naturally cxx:urr~ backgrounj levels
established for the site 11DJSt not exceed an excess can::er risk
of one in one million (10-6) am I'IL1St not exceed any l'101'1-Ca1'X:e
chronic health effects. In addition, after the remedial action
is canplete, the water in the Job Corps pan:! nust show no
degradation am 11DJSt meet all chemical-specific ARARs
established for this site (see Section X.B. below).
'!he surface water at Area 9 will also be DDnitored dur~ am
after construction of the remedial action. '!he results will be
evaluated to assure that after canpletion of the remedial action
for the contaminated soils am secliments, the CUIm.1lative risk
fran all of the contaminants in surface water above naturally
cxx:urr~ backgrounj levels established for the site shall not
exceed an ~s cancer risk of one in one million (10-6) am
shall not exceed ai1y l'101'1-Ca1'X:e chronic health effects. In
addition, after consb:uction of the remedial action; the water
in the Area 9 Dnbayment of Crab C>rd1ard Iake nust show no
degradation am nust meet all chemical-specific CiR'licable or
relevant and CiR'ropriate regulations (ARARs) established for this
site.
c.
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1. Selected Alternative
a. Direct ~nital Costs .
'!he direct caPital cost estimates irx:lude site preparation,
excavation, treatment, placement, landfill constJ:uction, Cl:Ner
construction, backfilliIq of excavated areas, verification
sanpliIq, constJ:uction health and safety, and installation of
fenciIq and naritoriIq wells. '!he breakdown for each study site
follows:
site 17: 1390 OJbic yards
site 28: 1000 OJbic yards
sites 32 and 33: 36,000 OJbic yards
b. IOOirect CaDital Costs
$1,073,877
$752,375
$14,908,820
'!he intirect capital cost estimates irx:lude a contiIqency
allowance of 25 percent, en;JineeriIq fees of 15 percent, and
legal fees of 5 percent of the direct capital costs. '!he
breakdown for each study site follows:
site 17:
site 28:
Sites 32 and 33:
$483,245
$338,569
$6,708,968
c. Oceration and Maintenance Costs
Operation and maintenance cost estimates irx:lu:le site
maint:enarxJe and inspection, sanpliIq and analysis, and a reserve
fun:i and i.nsurame. '!he breakdown for annual costs for
operation and maintenance for each study site follows:
Site 17:
site 28:
Sites 32 and 33:
$34,978
$28,047
$316,676
d. Tot'~' Present Value Cost
'!he total present value cost estimate irx:1\Xles all of the costs
listed above for each of the sites, and estimates an operation
and ma.int:enara! pericxl of thirty years with a five percent
interest rate. '!he total present \1IOrth cost estimate for the
selected alternative is approximately $25,000,000.
2. Altemative Treatment Tec:hnolOQy
'!he costs for the Altemative Treatment Tec:hnology are taken iran
the costs for Alternative 1C iran 01apter 7 of the FS. '1hese
costs represent the costs for vitrificatioo of the Area 9
ccntamination. Vitrification costs ~ net estimated for each
of the study sites. Since Area 9 is expected to oontr.ib.tte aver
33
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95% of the mass of contaminated soil am ~,. the costs
listed here are expected to be reasonable estimates. Ha¥ever, '.
the cost of the Alternative Treatment Technology may be higher
because there will be costs related to excavation am handlin;1 of
contaminated materials fran other study sites. Also site-
specific soil characteristics can affect the cost estimates.
a. Direct capital Costs
'!he direct capital cost estimates irx:lude site preparation,
treatment by vitrification, cover construction, verification
scmplin;1, construction health am safety, am installation of
fencin;1 am naritorin1 wells.
'!he cost estimate is $9,240,000.
b. Irrlirect capital Costs
'!he in:lirect capital cost estimates irx:lude a contin1ency
all0wan::2 of 25 percent, ergineerin1 fees of 15 percent, am
legal fees of 5 percent of the direct capital costs.
'!he cost estimate is $4, 338 , 045.
c. Oceration am Maintenance Costs
Operation am maintenance cost estimates irx:lude site
maintename am inspection, scmplin;1 am analysis, am a reserve
funj am i.nsuraR:::e.
'!he estimate for annual costs is $201,800.
d. Total Present Value Cost
'!he total present value cost estimate irx:ludes all of the costs
listed above for each of the sites, am estimates an operation
am maintenance period of thirty years with a five percent
interest rate. '!he total present ~ cOst estimate for the
selected J:eweaJy is $17,080,215.
IX. StHmRI OF mE
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types of treatment utilized, the volumes of soil arP ~i~11t to
be treated, and ultiJDate disposal lcx::ation. Eadl of the
Consolidated Alternatives. proposes to leave levels of PCBs above
the remediation goals in the deep soils of Area 9 8.1i.ldin;J
CCIIplex, and to contain them in place. '!his containment is oot
as pennanent as treatment, and the effectiveness will depen:i on
the lorq-term qJeration and maintenance and i11stitutional
controls. Eadl of the four Consolidated Alternatives includes
treatment by stabilization; fixation for sane of the PCB-
oontaminated waste. '!be lorq-term effectiveness and ~
of this treatment has oot been proven for PCBs. Consolidated
Alternatives 1 and 3 utilize irx:ineration to permanently destroy
PCBs, however, neither alternative proposes to use irx:ineration
on all of the material oontaminated with PCBs.
For all of the alternatives, the lorq-term risks asscx::iated with
e>cposure to and migration of the remainin;J wastes and treatment
residues will be reduced (by varyi.n:J deg]:ees) by ensuri.n:J
qJeration and maintenance of the landfills, maintenance of the
caps/CXJVerS, grcmxiwater mnitori.n:J and mnitori.n:J of
drainageways and Crab ord1ani Lake.
Reducticn of Tax:icity, It::i>ility, or Volume. '!he Selected Remedy
will reduce toxicity, nd:Iil ity , and volume to the maximJm extent
for PCBs and other organic chemicals. By permanently destroyi.n:J
these ~, the volume of the hazardous materials is reduced
am toxicity am m;bility are eliminated. '!he nmility of the
metals is reduced by stabilizatian; fixation an:! containment, or
by vitrification. Altha.1gh stabilization; fixation in::reases the
volume of the treated material, it does oot increase the mass of
the hazardoos CXIIpOI'1el1ts. Vitrification wa.tld reduce the volume
of the oontaminated soil, bIt wa.tld oot effect the mass of the
hazardoos metal ex JI'I-:>nents.
All of the COnsolidated Alternatives in:1me varyi.n:J deg]:eeG of
treatment by stabilizatiay fixation. '!his treatment wa.tld
reduce the m:bility of the treated contaminants, whidl wa.tld
include both PCBs and metals. stabilization; fixation wa.tld oot
reduce toxicity or volume of the contaminants. Because they
incinerate portiCl1S of the oontaminated material, Consolidated
Alternatives 1 and 3 wa.tld reduce toxicity, m:bility, and volume
of saoe PCBs by pennanent destructia1 of lesser anomts of the
CXI1taminatia'1. Na1e of the ather alternatives wa.tld reduce
tad.city, m:bility or volume to the degree of the Selected
Remedy .
Sbart-'tel:m Effectiveness. All of the alternatives umer
consideration coold present a ~t to workers and the
environment duri.n:J the constructiay inplementation P1ase of the
~i ~ 1 actia'1 because of the potential for dust generation or
the mavement of oontaminated t=Ar1;~-'1ts in surface water. '!he
36
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the Selected Remedy usin;J in situ vitrification has been ~ted as
set forth above in Section VIII .A. 3, the Selected Remedy provides the
best balance aIIDn;J the nine criteria that u.s. EPA uses to evaluate
al ternati ves. '!his section provides a SUlt1I1IaZy of the c:arrparati ve
analysis of the alternatives for the PCB Areas operable unit.
0Yerall Prat:.ectiat. Each alternative, with the exception of the
no-action alternative, would provide adequate protection of
human health and the envirornnent for those sites specifically
addressed. Protection would result by eliminatin;J, reducin;J, or
controllin;J risk through treatment, eD;Jineerin;J controls, or
institutional controls. However, those alternatives which
address only one or tW'O of the four study sites c:arrprisin;J the
PCB Areas operable unit eliminate, reduce or control risk only
for those study sites addressed, and not the whole operable unit.
In order to meet the threshold criterion of protectiveness, the
Alternatives which address only one or tW'O of the study sites
would have to be canbined to provide overall protection for the
operable unit. '!he Selected Remedy addresses the principal
threats to p.1blic health and the environment for all of the study
sites by treatment to the maxiImJm extent practicable of
contaminated soil and sediment and conta:iranent of the residues.
Q:mp1iance with ARARs. All alternatives wuld meet all
~licable or relevant and awropriate requirements of Federal
and State enviroranenta1 laws. Potential ARARs for each
alternative are extensively di~1Ssed in the FS report. '!he
ARARs for the Selected Remedy are presented in Section X.B,
below .
1.a'xJ-teI:m Effectiveness am Pe1:IIBneme. '!he Selected Remedy
would provide the greatest lag-tam effectiveness and
~. Both treatment tedmologies in the Selected Remedy
involve excavaticm and/or rerooval or consolidation of
approximately 36,000 cubic yards of PCB-contaminated soil and
sediment, of which approximately 3,620 cubic yards are estimated
to be co-oontaminated with metals. Treatment will provide that
all of the organic ~ will be pezmanently destroyed, for
the maxinum lorg-tam effectiveness. Of the 3,620 cubic yards of
metal-oontam:inated material, approximately 1,250 cubic yards is
thaught to be RCRA-hazardous. '!he hazarda.1s irorqanic metals
will be treated by stabilization; fixation or by vitrification to
remer the material ncn-hazardaJs, with secure containment of the
residues and the ncn-hazardaJs metal-bearin;J material to provide
the ma>riml1l11 l~-tem effectiveness and ~ for the metal
contaminaticm. CDrt:aminated soil and sediment constitutes the
principal threat fran this operable unit. '!he Selected Remedy
also addresses the threat fran surface water and groun:iwater by
reDlJVin:J the material that ocu1.d contaminate the water.
'!he alternatives develqei in the FS and the Consolidated
Alternatives differ in whether treatment will be utilized, the
35
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utilization of variws protective neasures will m:iI)i.mi.ze these
threats.
Consolidated Al ternati ves 2 a.n:i 4 a.n:i the Selected Remedy usiIq
ISV weW.d take the least anomt of time to inplement
(~rox.ima.tely 2 years), Consolidated Alternative 3 WQ11d take
slightly lOn;Jer (CiR>rox.ima.tely 2 to 3 years), a.n:i Consolidated
Al ternati ve 1 a.n:i the Selected Remedy usiIq :in::ineration weW.d
take the IOOSt time to inplement ( CiR>roximately 3 to 5 years).
'l11e difference in time is priInarily based on the availability of
:in::ineration,/ thermal destruction equipnent. '!he availability of
in situ vitrification equipnent is also questionable. Protective
measures weW.d be used for the entire time the action is
ocx::urrin;J .
IDplementability. All Consolidated Alternatives a.n:i the
Selected Remedy (using incineration) use stan::iard, reliable
technologies whidl are feasible for inplementation. '!he
availability of a nd::>ile :in::inerator is a potential difficulty
whidl could affect the inplementability of the Selected Remedy
an:! Consolidated Alternatives 1 an:! 3. However, this equipnent
is currently available. '!he availability of a cxmnercial
vitrification process that could meet the remediation goals an:!
perfonnance standards for the site is a concern. However, this
issue is one whidl nust be addressed before the Alternative
Treatment 'l'ec:hoology (ISV) could be inplementa:l.
Q)st. For the Selected Remedy (usiIq :in::ineration a.n:i usiIq
ISV), an:! eadl Consolidata:l Alternative, the total remedial costs
(capital plus cperation an:! ma:int:enarre) in present net worth
are:
Selected Remedy (:in::ineration)
Selected Remedy (ISV)
Consolidata:l Alternative 1
consolidata:l Alternative 2
consolidata:l Alternative 3
consolidata:l Alternative 4
$25,000,000
17,080,215#
25,195,035*
*
6,156,161
*
8,910,700
*
23,858,330
# As previoosly explained, the costs for the Alternative
Treatment Technology (ISV) are taken fran the costs for
Alternative lC fraD 01apter 7 of the FS. 'lhese costs represent
the costs for vitrification of the Area 9 contamination. Sines
Area 9 is expected to contr:ib.rt:e aver 95% of the mass of
oc:ntaminata:l soil an:! -n;mP1'1ts, the ocst listed here is a
reasonable estimate, bIt may be greater.
* Facn of the consolidata:l alternatives :in::ludes sane costs for
~iation of the Metals Areas operable unit. '!he costs listed
above weW.d be approximately 5 to 15 percent less for only the
PCB Areas operable unit.
37
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~ u; L 1qeB:::y AcxEptance. '!he ooI, the o.Irrent owner of the
site, corx:urred on the proposed plan for the PCB Areas Operable
Unit. At this time, the Department has not c::onc..1rred on the
final selected l=laly.
'!he State of Illinois concurs with the treatment c:x:qx:>nent for
contaminated soils an:! sediments in the selected l~l.eJy (see
~C).
Chmll1rrlty AcxEptance. A thi.rty~y pJblic ccrnment period
was originally scheduled to run fran August 18, 1989, to
September 16, 1989. Based on concems expressed at the pJblic
hearin;J on August 30, 1989, an:! in letters to the U.S. EPA, the
cxmnent period was extended three times \mtil December 1, 1989.
'!his alla.Ned for a total pJblic caument period of 105 days. In
addition, a second pJblic hearin;J was held on October 3, 1989,
when additional cxmnent was taken.
A number of ccrnmentors presented oral ccmnents at one or both of
the pJblic hearin;Js. Numerous written cauments relatin;J to the
PCB Areas operable unit were also received durin;J the. official
pJblic c:xmnent period, incl\Xlin;J letters fran organizations an:!
political entities. '!he ccmnents related to the SUperfun:i
dec:isionmak:ing process am;or the technical merits of the
alternative preferred in the Proposed Plan. Canmentors foo1ssed
especially on the incineration CuI~leIlt of the preferred
alternative. Additionally, cq:proximately 700-800 signatures were
sutmitted on petitions qp:sin;J incineration. '!he c:x:amnents
received have been SUlTltliU'ized an:! addressed in the Responsiveness
SUrmIary portion of this ROD.
'!he cc:mnents received durin;J the pJb1ic cxmnent period are one
measure of the CXItIII.Url.ty's aoceptance of U.S. EPA's proposed
Selected Remedy. '!he vast majority of cc:mnents sul:mitted on the
PCB Areas Proposed Plan either c:gxJSed the incineration
treatment process or expressed concern with the safety of its
in'plementation. M:Ist ccmnentors that c:gxJSed incineration stated
that there was a clear need for remediation of the contaminated
areas, bJt that they were ooncen1ed with the "safety" of an
incinerator. Alag with the vocal qp:sition to the incineratioo
treatment, theJ:e was extensive a:n:m1'1 expressed that the pmlic
needs to be involved in the iJrplementatioo of the leme..ly. As
expressed in the Responsiveness SUlmIary portion of this ROD, U.S.
EPA sUUlqly SlJR)Orts the active involvement of the trirmnUty in
the 0CI1tinued SUperfun:i activities at the site.
Another measure of CXI11tI.U1ity aoceptance is the organization of
diverse elements of the oamunity into the Crab Orchard Response
Team (CDRr). '!his groop organized as a response to concerns fran
many sectors of the oamunity an:! is h::>tYwni1'¥j involved as a focal
point to express oontinued camunity concems. '!he ccmnents
38
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received fran CDRI' are iIx:ludec1 as official documents in the
Adm:ini.strati ve Record.
In oorv::lusion, the canmunity near the Refuge has expressed
CJRXISition to the iIx:ineration CCIIp)nel1t of the Selected Rene:ly,
or is concerned that the inplementation of the iIx:ineration
process mJSt ensure the safety of the local canmunities. In
addition, the canmunity is generally dissatisfied with the
SUpe.rfuni decisionmakin;J process, am :in::ti viduals am graJpS feel
that they need far more invol ve.ment in orH;JO~ activities.
In surranazy, at this time the Selected Remedy represents the best balaooe
amorq the alternatives of the evaluation criteria used to evaluate
remedies. '!he Selected Remedy ~izes lorq-term effectiveness am
pennanera! am reduction of toxicity, nd::>ility am volume. '!he Selected
Remedy is safe am provides short-term effectiveness, am is
iltplementable. '!he dem:n1stration to allow an Al teJ:native Treatment
Technology (ISV) is an attelrpt to keep the same balaooe of the evaluation
criteria, am at the same time to address canmunity concerns.
x.
S':IMUlt:RY 1EDHUNAT.ICH;
A.
mmxJ.'J.ON OF HUMAN HEAIllH AND '!HE E:NVIR:>NMENl'
'!he Selected Remedy (usirq iIx:ineration or, if snooessfully
de.nonstrated, in situ vitrification) is protective of hmnan health am
the environment for the foor stmy sites CClTtprisirq the ~ Areas
operable unit. Also, the Selected Remedy is consistent with the mission
of the Refuge, which is to provide a safe am protective settirq for
wildlife. '!he Selectec1 Remedy provides adequate protection by a
combination of treatment of contaminated soil am secllinent by
iIx:ineration to destroy the organic cont:aminants, stabilization,! fixation
of the RCRA characteristic metal-bearirq material to renjer it non-
haZardalS, the eR3ineered control of an a1-Site solid waste larxifill for
the treated am untreated contaminated residues, am institutional
controls by cantirn.rln;J to restrict pmlic acress, particularly to the
constroct:ed landfill.
'!he Alternative Treatment 'l'ec::hoology (ISV) wa.Ild provide the same degree
of protectiveness by desb:uction of the organic material am
i1nrrd::>ilizatim of the metal-bearirq material by in situ vitrification,
the eR3ineered oontrol of a low-permeability cap over the treated
residues, am institutional controls. '!he remedial alternatives,
inclu:lirq a1-Site larxifills, ~ develqe1 with the umerstan:lin;J that
the site wa.Ild 0CI1tinue to be a wildlife refuge, with restricted pmlic
acress in order to protect the wildlife. An interagerx::y agreement will
require ooI to maintain the m-site landfill am to inpose acress
restrictions for the larxifill, if the lam use ~ to d1an;Je in the
future.
'!he remediation goals for the stmy sites CXI'Iprisirq the cparable unit
have been established so that hmnan exposure levels will be reduced for
39
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the sum of all CX1I1taminants to no greater than a 10-6 ~ cancer risk
level. In addition, the non-carcinogenic hazard in:tices for the sum of
all oontaminants shall be less than one. Also, chemical-specific
remediation goals have been established by the FW3 which are believed to
be protective of wildlife at this site. '!he remediation goals
established in this document are consistent with OOI's conc::ems ani
statutory manjates. IIrplementation of the selected remedy will BJt pose
unacceptable short-term risks ani will BJt cause cross-media inpacts.
'!he selected Remedy would remediate the fOOl" study sites that c::arprise
the operable mrit so that future access restrictions to those areas would
BJt be ~ed (althc:u;h the vitrified masses may require limited
restrictions) . Because the selected Remedy will leave oontaminants at
the site in either an on-site larxifill or in the vitrified area of
contamination, CERCIA Section 121(c) requires that the IeloeJy be reviet¥ed
at least every five years to ensure that it continues to be protective to
p.Jblic health ani the environment.
B.
o::MPL.IANCE WI'IH APPLICABIE OR REIEVANl' AND APPROPRIATE
REXXJIRE1.1ENIS
'!he selected Ie&~ will ccrrply with all Federal am any II¥:)re stringent
State ARARs. '!he major ARARs that will be attained by the CCIt1p01'1e11ts of
the selected Remedy are listed belOil. '!he list of ARARs belOil is
i.nterv::1ed to be c:::atprehensive, hcJINever, iltplementation of the ARARs will
be detennined, ani identification of ARARs may require further
refinement, during remedial design am remedial action.
1. SUrface Water Disd'1arqe
Clean Water Act
- If pc:ni or stream water fran site 17 or stream or ditch water
fran Area 9 (sites 32 ani 33) DIJSt be discharged to a surface
water body. during site preparation, the discharge shall meet the
effluent stamards ani prohibitions ani water. quality st.armrds
established Ul'D!r Sections 301, 302, 303, 307, 318 ani 405 of the
Clean Water Act (40 CFR 122.41 ani 122.44).
2. Excavation of Soil ani Sediment
RescNroe CD1servatiat ani RiecxM!ry Act, SUbtitle C
- Excavated material which is ~ hazardous will be han:U.ed ani
stored in aocordanoe with the substantive technical st.armrds
CSR>licable to generators of hazarda.1s waste am for owners ani
c.perators of hazarda.1s waste storage facilities (40 CFR 262.34;
am 264, SUbparts B, C, I, J, am L).
- Excavated material which is ~ ha.zarda1s will be han:U.ed ani
stored in aocordanoe with the lani disposal restrictions (40 CFR
268).
40
-------
- '!he excavation activities, when cx::trpleted shall meet the
closure performance stan:3ards for clean closure (40 CFR 264,
sutpart G) for the specific hazarooos waste constituents.
- '!he excavation an:l storage activities 1IIJSt also meet any m::>re
strin;Jent State -of Illimis equivalent previsions (35 IAC Part
724 design requirements).
Tcadc SUbst:ames Cl..IUu! Act
- Excavated material which oontail'ls PCBs at concentrations
greater than 50 parts per million will be han:iled an:l stored in
ac:oordame with the requirements of 40 CFR 761.65.
Clean Air Act
- DJrin;J excavation the national ambient air quality stan:3ards
(~) for particulate matter an:l lead shall not be exceeded
(40 CFR 50.6 an:l 50.12).
3. Incineration of Soil an:l SediJnent
Tcadc SUbstances Cl..luul Act
- All contaminated soil an:l sediment that oontail'ls PCBs above the
mMdiation goal shall be disposed of in ac:oordaroa with the
disposal requirements of 40 CFR 761.60(a) (4) (i) an:l (d).
- '!he design an:l cperation of the on-site 100bile incinerator will
meet the suDstantive tedmical requirements of the TSCA
incineration regulations (40 CFR 761.70).
Resource Cl..6e1. vatim am Recc:IYery Act, SUbtitle C
- '!he design an:l cperation of the on-site 100bile incinerator will
meet the substantive tedmical requirements of the RCRA, SUbtitle
C incineration regulatia1S (40 CFR 264, sutpart 0).
- '!he incinerator ash will be analyzed to detemi.ne if it is a
RCRA characteristic waste in ac:oordame with 40 CFR 262.11.
- Incinerator ash wch is RCRA hazarda.1s will be han:lled ani
stored in aOCOJ:danoe with the substantive tedmical stan:3ards
cq:.plicable to generators of hazarda.1s waste an:l for owners an:l
cperators of hazarda.1s waste storage facilities (40 CFR 262.34;
an:l 264, ~ B, C, I, J, an:l L).
- Incinerator ash which is RCRA hazarda.1s will be han:lled an:l
stored in ac:xmdarxJe with the lan:l dispasa1 restrict.ia1S (40 CFR
268) .
41
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Clean.Air Act
- ~in; incineration the. national ambient air quality stan.::Iards
(NMOS) for particulate matter am lead shall not be ~ed
(40 CFR 50.6 am 50.12).
4. vitrification
Taxi.c SUbstances Q...LLul Act
- All contaminated soil am sediment that contains PCBs a!x:Jve the
remediation goal shall be disposed of in acx::o~ with the
substantive tedmical disposal requirements of 40 CFR 761. 60 (d)
am (e).
- '!be design am operation of the on-site vitrification unit will
meet the substantive technical perfonnance stan.::Iards of the TSCA
incineration regulations (40 CFR 761. 70) .
ResaJrce Cb1servat.ia'1 ani RecaYezy Act, SUbtitle C
- '!be design am operation of the on-site vitrification unit will
meet the substantive tedmical requirements of the RCRA, SUbtitle
C miscellaneous unit regulations (40 CFR 264, SU!::part X).
- RCRA d1aracteristic waste may only be consolidated in a non-
oontiguous area of. contamination if the substantive tedmical
requirements of 40 CFR 264.301(b) am 268.6 have been met.
- If the final rolemaJd.n;r specifies a specific treatment
technology for metal-beariIg d1aracteristic waste, the
substantive tedmical requirements of 40 CFR 268.42(b) will be
met, if required.
Clean Air Act
- ~in; treatment the NMOS for particulate matter an:l lead
shall not be ~ (40 em 50.6 am 50.12).
5. ~~hilization/ Fixation
Rescm:ce CD1se1:vatim ani Rscc:wety Act, SUbtitle C
- ~ hazardous material will be treated by this process to
renjer it ncn-hazarda.1s. '!be treatment shall be in aocorc:1aJ'v=e
with arrj praIL1lgated treatment st.anjards for waste web is EP
Toxic for cadmium am;or lead (40 em 268 for 0006 anj/or 0008
waste) .
- Treatment shall be in units designed to meet the substantive
tedmical requirements for either containers, tanks, waste piles
or m;~'laneous units (40 em 264, SUI:p!rts I, J, L or X).
42
-------
- Treatment \.mits must n-eet any ncre str:irqent regulatory design
stan:1ards of the state of. Illinois (35 IAC Part 724).
Clean Air Act
- D.1riIg treatment the ~ for particulate matter ard lead
shall not be exceeded (40 CFR 50.6 ard 50.12).
6. DiSPOSal or Decx:mtamination of Eauianent
ResaIroe Ca1sel:vatim and ReaJVery Act, SUbtitle C
- D.1r:irq remediation ard closure all equipnent, structures ard
soils that are used on/with ~ hazardous materials must be
properly decontaminated or disPosed of (40 CFR 264.114).
- Decontamination of equiprent structures ard soils that are
used oll/with RCRA hazardous materials must Ireet any ncre
str:irqent regulatory decontamination or diSPOSal stanjards of
the state of Illinois (35 IAC Part 724).
Taxic SUbstarD:!s (h,LLul Act
- D.1riIg remediation ard closure all equipnent, structures ard
soils that are used on;with TSC'A regulated PCB-ocntaminated soil
am sediment DIJSt he properly dec:ontaminated (40 CFR 761.79) .
7. IOOustrial Iarxlfill or CaPS
Solid Waste Di~ Act as aIIIelD!d by ICRA SUbtitle D
- '!he design ard operation of the on-site solid waste disposal
cell or the cap aver the vitrified area of contamination will
n-eet the substantive technical requirements of the RCRA, SUbtitle
D guidelines for the lard disposal of solid waste (40 em 241,
SUbpart B).
- Si.r¥::e all of the RCRA hazardaJs material will be rerrlered non-
hazardaJs prior to placement in the 1ardfil1, the requirements
of the land di~ regulations of 40 em 268 do not apply, nor
are they relevant or appropriate.
- '!he design and qJeration of the 1ardfil1 will meet any more
stringent tedmical regulations of the state of Illinois (35 IAC
Part 807).
43
-------
8. Backfill Excavation
Clean Air Act
- J:)Jrin;J backfillin;J activities the NAAQS for particulate matter
shall mt be exceeded (40 CFR 50.6).
9. Monitorina an:i Maintenance
Resa1roe CD1servaticn am Recavezy Act, SUbtitle C
- Groun:lwater nonitorin;J for the remediate:i study sites shall be
in acx:ordance with the grourdwater nonitorin;J requirements of
RCRA (40 CFR 264, SUbpart F) . .
Solid Waste Di.~l Act as amen:Jed by RCRA SUbtitle D
- Groun:lwater an:i leachate nonitorin;J for the on-site lan:ifill
shall be in acx:ordance with the RCRA SUbtitle D, solid waste
lan:ifill requirements (40 CFR 241.204) .
- Grourrlwater am leachate m:>nitorin;J for the on-site lan:ifill
will meet any nore strin;Jent technical regulations of the State
of Illinois (35 IAC Part 807).
10. Personnel Protection
Oocupaticmal Safety am Health Act (CERA)
- J:)Jrin;J all remedial activities the requirements of the
Occupational Safety an:i Health Act for the tra:inin;J am safety
of workers will be abseJ:ved (29 CFR 1910.120 and 1926, SUbparts
C, D, E, am P).
11. Remediation Goals
crab 0r:t:baJ:d &1ab1in;J Legislaticn (16 U.S.C. 666f am 9)
Nat.i.cna1 Wildlife RefuJe Administ:raticn Act (16 U.S.C. 668d:i)
Eagle Prat.ect:.im Act of 1940 (16 U.S.C. 6688)
Migratmy Bird Treaty Act of 1918 (16 U.S.C. 703-7U), as amended
- '1he chemical specific remediation goals which have been
established for the study sites oarprisin;J the PCB Areas, am
any others that will be established for this cparable mdt will
be consistent with the statutory requirements cite:i above.
For iIrplementatiCl1 of the Selected Remedy, u.s. EPA, 001 am IEPA have
agreed to consider a I'nJIIt)er of procedures as guidalre. 'lhese in:::1ude,
but are mt limited to: u.s. EPA's Risk Assessment Guidalre for
44
-------
SUperfUnd: u.s. EPA's SUperfUnd Remedial Design ani Remedial Action
Guidance: U. S. EPA' s RCRA Technical Enforcenent Guidance Dx:ument: U. S.
EPA's prcposed M:L for ~: any prcposed revisions to U. S. EPA' s design
stan::1ards for RCRA SUbtitle D lanifills, which are available before
remedial design: the State of Illinois waste Management Facilities
Design criteria: ani State of Illinois Mcnitorin:J Well Construction ani
Installation criteria.
c.
cnsT EF'F'ECI'IVENES
'!he Selected Remedy for this operable unit appears to be cost-
effective. '!he costs are reasonable for the overall effectiveness of the
chosen remedy. Other Alternatives which were less costly provided less
lorg-te:rm effectiveness ani pennanence: less reduction of toxicity,
m:lbility or volume: or less ilrplementability.
D.
UTILIZATION OF PERofANENI' SOIIJI'IONS AND AI.:I'ERNATIVE TRFA'lMENI'
TEOiNQr.cx:;IES 'ro '!HE MAXIMUM IDcr'ENI' PRACrICABlE
'!he Selected Remedy for the PCB Areas operable unit utilizes permanent
solutions ani treatment technologies to the maxilIum extent practicable.
'!he evaluation of the five primary balancin:J criteria is d;~1ssed in
Part IX., above. '!be analysis of the criteria supports the Selected
Alternative ani the Alternative Treatment Technolcgy, as providin;J the
best balance am::I'J::J the develqm Alternatives. '!he analysis of the
criteria dem:mstra.tes that the selected Remedy utilizes permanent
solutions to the maxiJrum extent practicable. '!he Selected Remedy was
chosen as the final J:'PI'III"Idial action for the PCB Areas cperable unit
because it provides the greatest lorg-tenn effectiveness ani pennanence
ani reduction of toxicity, m:lbility ani volume through treatment.
'!he Alternative Treatment Technolcgy (ISV) is included to allow the
party (ies) respoJ !Sible for the iIrplementation of the remedy to
demonstrate that vitrification, an alternative treatment technolcgy, is
as effective as incineration, which is a proven technolcgy for PCB
contamination. If the dena1stration allowed in Part VIII.A.3 in:licates
that the required treatment ani perfonuanoe st:amards can be met by
vitrification, then the treatment oarponent of the Selected Remedy may
inclme this Alternative Treatment Technolcgy.
E.
M
-------
residue which. is hazardous because of the characteristic tQ leaCh metals
be treated by stabilizatiorV fixation or vitrification to ren:ler the
material non-hazardous am to reduce nd:>ility of the contaminants.
Incineration am stabilizatiorV fixation treatment technologies have been
c:lenDnstrated to be extremely effective for soil am sediment cont:am.inated
with PCBs am metals respectively. Vitrification has not been fully
c:lenDnstrated for the principal contaminants, but is a pranisin;
al temati ve treatment technology.
XI. ~Qi OF SIaaFIawr QWQS
A.
ORIGINAL !-'1<.ta"1:J<.KW ALTERNATIVE
'!he Proposed Plan for the PCB Areas operable unit was made available to
the p..1blic on August 18, 1989. '!he preferred altemative identified in
the Proposed Plan was a consolidated remedial al temati ve which included
the followin; c:arp:ments:
Excavation of Soil am Sediment - Contaminated soil am sediment
~d be excavated usin; conventional equipnent. '!he excavated
material ~d be DDVed to a storage area on-site, where it would
be stored until it was treated or disposed.
Incineration/ 'lbennal DestJ:uction - All excavated soil am sediment
which is contaminated with PCBs ~d be treated by incineration/
thermal destruction. Non-contaminated incinerator residue ~d be
backfilled in the excavated areas.
Stabilization/Fixation - Residues fran incineration/ thermal
destruction, am non-incinerated soil am sediment which contain
metals at levels which are hazardous because of the characteristic
for lead1able metals, as defined by RCRA, ~d be treated by
stabilization/fixation.
In:lustrial lanjfill - Contaminated residues fran incineration/
thermal destruction am materials treated by stabilization/ fixation
~d be disposed of in an on-site iniustrial lan:lfill, meetin:] at a
mininum, the 8R>licable or relevant am 8R>rcpriate requirements of
SUbtitle D of ~ am 35 IAC Part 807.
IDw Pemeability Caps - Areas where contamination is below the
excavatiCl'1 criteria, or £ran wi1ere contaminated soil am ~;~rtt
have been excavated ~d be closed am covered with a low
per:meability cap. 'lhe cap ~d be oonstJ:ucted of CCIIpacted soil, a
ci:rcUnage layer, soil fill am topsoil. Ra1tine maintenance of the
oover ~d be part of the lcn;r teIm requirements.
Backfill Excavation - Clean soil ~d be placed in the areas where
contaminated material had been J:'EmJVed.
M:mitorin:j am Maintenance - GroI.Jmwater am surface water
nadtorin:j would be oon:iuct:ed aroorn the on-site lan:lfill am
46
-------
excavated areas.
also be required.
Inspection am maintenance of the larrlfill would
B.
DESCRIPI'ION OF SIGNIFIC'ANI' aiANGES
'!he only significant chan;Je which has been made to the selected Remedy
fran the Preferred Al temative n i ,,=<,1SSE!d in the Proposed Plan for the FCB
Areas operable tmit is that the remedy selected in this Record of
Decision allows a de1rcnstration to select an Alternative Treatment
Technology, if specific criteria can be met. '!his chan;Je would allow the
party (ies) responsible for the inplementation of the remedy to perform a
treatability study to de1rcnstrate that in situ vitrification, an
innovative technology for R:B-contaminated soil am sediment, will meet
specific requirements. '!he selected Remedy is the same as the Preferred
Alternative in the Proposed Plan unless the Alternative Treatment
Technology is utilized. '!he Alternative Treatment Technology am the
denr>nstration required in order to inplement it are c1i,,=<,1SSed extensively
in sections VIII.A.2 am 3, respectively.
c.
REASON FOR 0iANGES
On March 8, 1990, the National Contin;Jency Plan (NCP) was revised. '!he
revised NCP is the regulatory framework for the inplementation of CERCIA.
'!he revised NCP continues to enp,asize treatment of contaminated material
as a principal element of SUperfun:i remedies. In addition, the revised
NCP provides for the utilization of innovative or alternative treatment
technologies, where ~ropriate. u.s. EPA, in selectin:J final remedies
for sites or operable tmits, ImJSt balan::::e a mnnber of statutory ma.mates.
'Ihese mardates are ni~'J1S'5€d in Part X. above. '!he revised NCP provides
guidance in the ~lication of the statutory determinations for 1:emedy
selection.
u. S. EPA is considerin;J usin;J the innovative technology described because
it offers the potential for c:x:I1paI'able or superior treatment perfo:rmarv;,e
or inplementability, fe.'er or lesser adverse inpacts than other available
approaches, or lower costs for similar levels of perfo:rmarv;,e than
denxmstrated technologies.
For the FCB Areas operable tmit at the Refuge, u.s. EPA believes that
treatment of the principal threats is required. F\1rther, u.s. EPA
believes that the selected Remedy will aocarplish this goal, will meet
all of the statutm:y mardates, am will provide the best balan::::e aIIDR1
the len~ evaluatiCl'1 criteria. However, in order to ~.LLA1ate the
revised NCP's enpmsis CI'1 innovative technology, am to try to respon:l to
oc:um.mity concern, an Alternative Treatment Technology (ISV) has been
in=l\xled in the selected Remedy. '!his alternative treatment may only be
iJlplemented if a deDDh:sudtion suooessfully shows that the innovative
treatment can meet the remediation goals for the PCB Areas operable tmit.
-------
CRAB ORCHARD NATIONAL WILDLIFE REFUGE
PCB AREAS OPERABLE UNIT ROD
APPENDIX A
FIGURES
-------
. u- ~ ._. -"'--- -~_._.. _._--
_..~ '---'.--- ..- .-
/- -. I
' . Jackson Coun,y
De Soto
~
':)
.
Williamson County
Herrin
...
\t)
I
Cartervil1e
.....
It)
Energy !!
!
Q)
-
c
-
Carbondale
Marion
Cedar LDJce
I
Boskydel1 I
I
I
Giant City I
Stat. Park :.~)'
I.\\~,
e'::,; ,
Unle GfGSsy . "", ,
~L
I
Makanda I
I
I
I
Fern. Clyffe
Statl Park
Crab Orchard
Site
\
~. ,
..~ ,....... oil.. ~ af.¥' i
.
Rockford 8
Chicago
.
Peoria
Illinois
.
Springfield
Nal te
Figure 1
Site Area Map
Crab Orchard Site
Williamson County, Illinois
J I Refuge Boundary
t ~ ~ . ~ ~ . ~ . ~ Closed Site Area
t ----1 Surface Water
, .. . II:.""" t, :. .
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FIGURE 3
N
!
CRAB ORCHARD
NATIONAL WLDLIFE
REfUGE
SITE 17
FEASIBILITY STUDY
~
PROIIOSEO REMEDIATIOH
I'lZJ - ,.,. (SOILI UO"" PO
PROPOSED REMEDIATION
J::=?:"*=I - IlEA (SBIIIIENTltaO....
$ - GAOUIINIATER MONI1ORIN
. W£LL
ICALE IN FEET
.
109'
"200
.
Gi ~Ii-
-------
FIGURE
"4
SITE 17
SAMPLING LOCATIONS
PHASE II
N-
17-1488
.,8lCJJ
17... 8 8 m:J2J
11-1188
..8tm
17-4'8". '0.0.701
."Im
11-418mJ
.. SHALLOW WELL
.. DDP WELL
SCALI III P8ET
---
- --
o II 10
pce CONCENTIIATION
SOIL ~ S.EDIMENT, .../kl WET WEIGHT
E3 ..,". SUllPACI
'".cou
o W8LL 0It WAT'IR."II:
. NLD DUPUCAft
In aB1~JEN&~ER~
-------
5
.-
I-
t:J
CI
f\lit
~
~l ."
\~
Ii<
-
SCALE
620' O'
r~----"""
620'
.
SITE 17
17- JOB CORPS LANDFILL
~I-LAKE a STREAM
17-10 JUNE 18, 1981
. - MONITORING WEL.L LOCA TION a
IDENTIFICATION.
420.16 -GROUND WATER ELEVA TION
420-- -GROUND WATER CONTOUR
~ jIIIIIW",,,,.-., - ----
-------
~:. - , I .t,1-
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XUl. J
/ ,,'-
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,
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CRAB ORCHARD NATIONAL WILDLIFE REFUGE
PCBS AREAS OPERABLE UNIT ROD
APPENDIX B
TABLE
-------
TABLE 1
CRAB QRC;/IAAD LAKE
ESTIMATED RISK 10 HUMANS
DUE TO CONSUMPTION OF FISH TISSUE
ASSUHPTI ONS:
- 100 % of fish diet is captured at Crab Orchard lake.
- Consumption of Crab. Orchard fish continues over a 7O-year lifetime,
or during a 10-year or 5-year period.
- Undetected values are calculated as one half the analytical detection
limit (0.2 mg/kg for RI data).
- Cancer unit risk factor of 7.7 (mgjkg/day)-1 for Aroclor 1260 (*)
- East~est division denoted by Yolf Creek (200 fishable acres
on eastern area, 7000 fishable acres total for lake.)
SCENARIO
AVERAGE PCB
CONCENTRA TI 01/
(lng/kg w)
--------------------------------
(1)
------ ------
I. Average Fishennan
(6.5 g fish per day or 10-20 meals per year)
a) 95% .Yest BasslS% East Bass
b) 100% Yest Catfish/Bullhead
c) 95% ~est /5% East Catfish
d) Creel Census (4)
e) National Average (5,#)
f) National Average (6,#)
.0.34
0.32
0.61
0.30
1976-1979 0.29
1980.1981 0.18
0.20
0.08
0.51
II. Sports Fisherman
(30 g fish per day or 50-100 meals per year)
a) 95% ~est BasS/5% East Bass
b) 100% Yest Catfish/Bullhead
c) 95% ~est /5% East Catfish
d) Creel Census (4)
e) National Average (5,#)
.f) National Average (6,#)
0.34
0.32
. 0.61
0.30
1976.1979 0.29
1980-1981 0.18
0.20
0.08
0.51
NOTES & REFERENCES:
<------ RISK lEVELS+------>
(2)
7O.year 10-year 5-year
lifetime Exposure Exposure
---------
--------
--------
2.5E-04
2.3E-04
4.3E-04
1."7E-04
2.1E-04
1.3E-04
3.5E-05
3.3E-05
6.1E-05
2.4E-05
3.0E-05
1.8£-05
1.8£-05
1.6E-05
3.0E-05
1.2E-05
1.5E-05
9.2E-06
1.2E-03
1.1E-03
2.0E-03
7.8E-04
9.6E-04
5.9£-04
1.6E-04
1.5E-04
2.8£-04
1.1E-04
1.4E-04
8.5E-05
8.3E-05
7.4E-05
1.4E-04
5.6E-05
6.8E.05
4.2E-05
(1) Averages are calculated ass~ing fish without detected PCB residues contain
such residues at one half the analytical detection limit.
(2) Averages are calculated ass~ing fish without detected PCB residues are free of such residues.
(3) Derived using a 1976 Creel Census survey and average concentrations In fish species
detected In the RI and In monitoring studies conducted by the State of Illinois (see Section 2.7).
Based on the Creel Census data, the relative catch per boat expedition It Crab Orchard lake is
comprised of roughly, 35% bass, 31% bluegill sunfish, 14% catfish, 12% crappie and 8X bullhead.
(4) ATSDR (November. 1987). Draft Toxicological Profile on PCBs.
(5) SChmidt. CJ et al. (1985). National. Pesticide Monitoring Program.
Arch. Environ. Cont... Toxicol.; 14:225-60.
(#) Fillet residues calculated as one thir~ reported whole body residue.
C*) The potency factor of 7.7 (mg/kg/day) is based on studies using Aroclor 1260;
only Aroclor 1254 residues were detected at Crab Orchard lake. Available data neither
demonstrate nor preclude the carcinogenicity of Aroclor 1254.
(+) Additive risks due to PCB/TCDF residues in fish 81ght be obtained by adding 15
percent to risk level noted for PCBs.
-------
CRAB ORCHARD NATIONAL WILDLIFE REFUGE
PCBS AREAS OPERABLE UNIT ROD
APPENDIX C
SUPPORT AGENCY CONCURRENCE
-------
~
Illinois Environmental Protection Agency
P. O. Box 19276. Springfield. IL 62794-9276
IEPA Record of Decision Declaration for the PCB Operable Unit
at the Crab Orchard Natlonal Wlldl1fe Refuge
NPL Slte near r~ar1on. 1111no1s
With the exception of the specified landfill design. the selected remedy is
protective of human health and the environment. attains Federal and State
requirements that are applicable or relevant and appropriate for this remedial
action. and is cost-effective. This remedy satisfies the statutory preference
for remedies that employ treatment that reduces toxicity. mobility. or volume
as a principal element and utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on site.
U.S. EPA is expected to conduct a review no less than five years after
commencement of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
The adequacy of the U.S. EPA landfill design continues to be an outstanding
issue with the State of Illinois and becomes the primary issue for complete
concurrence at this time. Based on this infonnation. the IEPA selectively
concurs with the decision the U.S. EPA has made in selecting this remedy.
Date
717/90
Bern~~ p /~-/
Di rector
Illinois Environmental Protection Agency
BPK:SD:sap/2534n.60
-------
~IVENESS ~ FUR 'lEE REXXIku OF IH::ISICfi
aw3 ORCIARD NATI~ WTTnT:n<'E REFU;E
PCB AREAS OPmABIE UNIT
I.
~IVENESS S(MmRY ~
'!he united states Environmental Protection Aqercy (U.s. EPA) held a
public cxmnent pericxi fram August 18, 1989, through December 1, 1989, for
interested parties to cxmnent on the Proposed Plan for remediating
contamination problems at the FCB Areas operable unit of the Crab Orchard
National wildlife Refuge SUperfund site near carteJ:ville, Illinois.
Comments were also taken on any docmnents in the administrative rE!CX)rd,
includi.rg the Remedial Investigation/Feasibility Study (RIfFS). '!he
required p.Jblic hearing on August 30, 1989, focused on the results of the
FS an:l u.s. EPA's preferred remedial alternative (Proposed Plan).
Comments were taken on both the Metals Areas am FCB Areas operable units
at the hearing on August 30, 1989. A secon::1 p.Jblic hearing was held on
October 3, 1989, to take additional cxmnents on the remedial alten1atives
for the FCB Areas operable unit. '!he p.Jblic cxmnent pericxi was held in
ac:oordance with Section 117 of CERCIA.
'!he p.Jblic comment. period for the FCB Areas operable unit was initiated
col'1O.lrrel1tly with the comment. pericxi for the Metals Areas operable unit.
'!he cxmnent pericxi for the Metals Areas was closed earlier (on September
23, 1989) am a Record of IRcision was issuErl for the Metals Areas
operable unit on March 30, 1990. since the hearin;J held on August 30,
1989, covered both operable units am since the preferred alternative for
each operable unit shared sane similar c:::arp:>nents, na;t of the comments
received for the Metals Areas operable unit also apply to the FCB Areas
operable unit. 'Ihe exception is those ccmnents that address specific
procedural aspects of the Metals Areas operable unit. '!he Record of
Decision for the Metals Areas operable unit which was signed by u.s. EPA
on March 30, 1990, included a Responsiveness summary which respomed to
all ccmnents which were raised regard.in;J that operable unit. '!he Metals
Areas Responsiveness summary is hereby inco:rporated by reference into
this Responsiveness summary.
'!he puzpose of this responsiveness SlUtI'OaZY is to document the U. S. EPA' s
arx:l the u.s. Deparbnent of Interior's (ooI) responses to cxmnents
received durin3 the p.Jblic cx:mnent pericxi. 'n1ese ccmnents were
considered prior to selection of the final remedy for the FCB Areas
operable unit at the Crab Orchard National Wildlife Refuge SUperfund
site, which is detailed in the Record of Decision (ROD).
II. ~ Cti CDMJNl'1Y INVCll1EMENI'
'!he ooI, in conjunction with u.s. EPA, is responsible for comuctin3 the
canm.mity relations program for this site. A cammuni.ty relations program
was established by ooI for the Refuge in June 1987. It established a
process for a bIo-way flCM of project infonnation between local
officials, concerned citizens, the media am ooI. '!he program was
updated in July 1988, at the time of the completion of the RI, to broaden
-------
u.s. EPA's role in community relations activities. Four information
repositories were established in the local area: at the'Marion Federal
Penitentiary, the Marion Carnegie Public Library, the crab orchard
National Wildlife Refuge Headquarters an:i the .Morris Library at Southern
Illinois University in Carbordale. several different press releases an:i
fact sheets were issued to announce field activities an:i the fin:lin;r-; of
the RI an:i FS. A public meetin; on the fin:lin;r-; of the RI was held in
Carterville in August 1988. Camnunity relations activities are
SlJI'lUTarized in the ROD, if additional information is desired.
III. :RJBLIC HEAR1R;S
'!he required public hearin; on the Proposed Plans for the Metals Areas
an:i PCB Areas operable units was held on August 30, 1989, fran 7:00 p.m.
to 10:30 p.m., at the John A. Logan College in Carterville, Illinois.
Approximately 140 persons att.en:ied, includin;J the U.S. Con;ressman for
the clistrict, several local or federal officials or their
representatives , representatives of sare CCIl'I'pCU1ies or in:iustries that
have been tenants at the Refuge, an:i members of the press (television,
radio an:i newspapers) .
A secon::l public hearin; to di5O.JSS only the PCB Areas operable unit was
held on October 3, 1989, fran 7:00 p.m. to 11:00 p.m., at the Student
Center at SOUthern Illinois University in Carbordale, Illinois.
AR:>roximately 95 persons att.en:ied. Additional public cc:mnent was taken
at this hearin;.
IV. S(HW« OF SIQaFICANl' ~ 1
-------
A.
Canments on the SUDerfunj Prcx::ess
Ccmnent 1:
Nlnneroos commenters felt that the infonnation in the repositories was too
lergthy ani technical, ani that ltDre review time was required.
Response 1:
'!be National contin;;ency Plan (NCP) which was effective at the time of
public notice of the Proposed Plan required that the Feasibility Study
(FS) be available for public ccmnent for not less than twenty one days
(40 ern 300.67(d)). Because of concern that twenty-one days was not
sufficient time to review ani canment on the FS, the original canunent
period for this operable unit was thirty days. Based on concern
expressed at the public hearin:J on August 30, 1989, the p.1b1ic canunent
period was ext:.er¥ied for an additional thirty days. Based on additional
cxmnents that were received in writin;;, the public cxmnent period was
ext:.er¥ied a total of three times, makin:;J a total ocmnent period of one-
hun:1red ani five days. While the infonnation in the administrative
record is technical in nature, it is no ltDre technical than that
ordinarily generated for similar sites ani u.s. EPA believes that the
unusually lergthy camment period provided sufficient time for review ani
ccmnent on the proposed remedy.
CaImnent 2:
Same cxmnenters felt that it was difficult to locate infonnation on
IOObile i1x:ineration.
Response 2:
'!his ocmnent was raised early in the p.Jblic ocmnent period. In response
to this concern, additional material on ndJile i1x:ineration was sent to
the infonnation repositories. '!be material i1x:luded u.S. EPA reports and
journal articles which included additional references.
camnent 3:
One ccmnenter stated that there was a lot of CCIIII\'I.U1i.ty qp:sition to the
proposed ren.edy, but that the SUperfun:l p.Jblic ocmnent process is
structured to make it seem othezwise.
Response 3:
'!he NCP establishes a regulatoI)' framework for the inplementation of
CERCIA. As rH!::l"'!IJSSed in Response 1, the NCP inc1uies previsions for the
minim.nn requirements for p.Jblic participation. Anx:n:J these requirements
was that the Feasibility Study (FS) be available for p.Jblic ocmnent for
not less than twenty-one days (40 ern 300.67 (d) ). As was stated in
Response 1, the original c::crtment period for this operable unit was lon;Jer
3
-------
than the mini.nu.1m requirement, an::i three additional extensio~ to the
camment pericxi were granted based on public ccmnent. '!he total camment
pericxi for this operable unit was, one hun:ired an::i five (105) days. '!his
ccmnent pericxi is far lorqer than nonnal, an::i was allowed in response to
specific ccarmmity concems.
Canment 4:
sane ccmnenters expressed the opinion that the final remedy had been
decided an::i that the public ccmnents would not have arrj influence on the
final remedy selection.
Response 4.:
All public ccmnent which was received durin; the ccmnent pericxi was
seriously considered prior to the final decision on a remedial action.
Just because one inlividual camment, or a ntmIber of camnents may not have
chan;Jed the final decision, does not mean that the process is a "token
gesture". Canments received expressed a diversity of opinion about what
action is needed to clean up the site, an::i not all opinions CXJUld be
satisfied by arrj one decision. Also, c:cmm.mity acceptance is only one of
nine criteria used to evaluate remedial alternatives, an::i ltU.lSt be weighed
against the other criteria. In addition to the criteria of CCII'I1I'IU.U1ity
acceptance, u. S. EPA is required to meet a ntmIber of statutory ma:rx:3ates
in the selection of the final 1.~1.eJy. '!be balance between the decision
criteria (includirx3' c:cmm.mity acceptance), an::i the assessment of the
statutory ma:rx:3ates are di ~1Ssed in Sections IX. an::i X., respectively, of
the Decision 5l.munary of the Record of Decision.
u.s. EPA believes that the ROD reflects a direct influence by public
camment on the decision makin;J process. Opposition to the use of
incineration technology at Crab Orchard contributed to u. S. EPA' s
decision to include in the roD, a provision for a den¥:n1stration of
in situ vitrification (ISV) as an alternative treatment tectmology that
meets the perfonnance staroards of incineration.
Canment 5:
one ccmnenter expressed concern about the other operable units at the
Refuge, specifically the "000 Areas", an::i worxiered whether they might be
"swept 1.D"der the rug".
Response 5:
'!be operable mrl.ts are each at a separate schedule for CXIIpletion of
remedial work. Section 120 of CERCI.A requires OOI, the current owner of
the Site, to enter into an interagency agreement (~) with U.S. EPA
before September 30, 1990. Olrrently, OOI, U.S. EPA an::i the Illinois
Environmental Protection kJerr:y ("IEPA") are negotiatirg the interagerr:y
a~~. '!he Department of the Arrr¥ may participate in the~. '!he
operable unit, formerly referred to as "000 Areas", is new referred to as
"M.mitionsjExplosives Manufacturirg Areas", am a specific schedule for
4
-------
\YOrk at this operable unit is bein:J developed for the interagency
agreement. '!his schedule will require the initiation arxi completion of a
rerredial investigation of areas that may have been contaminated as a
result of munitions or explosives production. If contamination is fourd
at levels of concern, options to clean up the operable unit will be
developed. '!he interagency ag1:eement arxi rerredial \YOrk done on the
operable unit will all be subject to p.Jblic revierw arxi cx:rnment.
Comment 6:
One cx:rnmenter questioned whether the characterization of the operable
unit as the "PCB Areas" masks potential problerrs with the metal ex>-
contamination.
Response 6:
'!he creation of separate operable units was discussed extensively in the
Responsiveness SUmrrary to the Record of Decision for the Metals Areas
(which is incorporated by reference here). '!he characterization of the
operable units at the site is not i.nten:ied to be misleacli.rg, arxi the
titles of the operable units s:iJtply characterize the major contaminants
within each unit. '!his does not mean that other contaminants may not be
present, as is the case of the PCB Areas operable unit, where lead
contamination has always been acknowledged arxi n;~1S-c;a:i, arxi is
addressed in this ROD.
camnent 7:
one cx:rnmenter stated that there have been problems in the past with other
SUperfun:1 sites when remedies have been selected because the U.S. EPA
will not give 100% guaranties of safety.
Response 7:
U. S. EPA has made the detennination that the risk fran the unremediated
site is of sufficient magnitude that there is an actual or potential
risk to human health or the erwirorunent. On:e the; site has been shown to
produce a risk, varioos remedies to address the risk are evaluated. '!he
projected result of each of these remedies must be a reduction of the
risk to fall within a rarge of "acceptable risk" (as defined by CERCIA
arxi the NCP), D.1t no one can give a 100% guarantee that the u~llledy will
entail no risk. However, each of the remedies will result in less risk
than wculd be present \¥ere no action taken at the site.
camnent 8:
A ferw cx:mnenters expressed the opinion that the government, or President
Bush himself, is behird an effort to p.lSh incineration.
5
-------
Reslx>nse 8:
Co~ has directed U. 5. EPA to. meet certain statutory II1aOOates for
remedy selections at SUperfun:l sites. 'Ihese II1aOOates include the
preference for treatment as a principal element of the rell~ arxi the
utilization of pennanent solutions arxi alternative treatment
tec:lmologies to the maxiJm.nn extent practicable. 'Ihe goverrunent has not,
on a national basis, ~ifically selected any one treatment method.
Incineration is considered a tec:lmology that can be used in many
cira.nnstances to meet these II1aOOates because it has been dem:>nstrated
to treat arxi permanently destroy organic contaminants.
Comment 9:
A few cx:mnenters were concerned that there are no checks arxi balances on
EPA.
Response 9:
CERCIA provides that U.5. EPA ImJSt consult with support agencies durin:3'
the lell.aLly selection process. '!he support agencies for this tell~
selection are the 001 arxi Illinois EPA (IEPA). Each of these agencies
has had opportunities to ccrnment on the remedy selection for the PCB
Areas. CERCIA also requires that p.1blic cx:mnent be taken arxi considered
before the final remedy is chosen. SUperfun:l remedies ImJSt c::cmply with
all Applicable or Relevantarxi Appropriate Requirements (ARARs), which
ensures that programmatic arxi legal requirements are met for every
lel(ledy. Finally, Section 310 of CERCIA has provisions to allow citizen
suits to be brought against the goven-anent. 'Ihese procedures arxi
statutory obligations provide a variety of "checks arxi balances" on the
remedial action selection ani iltplementation at SUperfun:l sites.
O:mnent 10:
One ccmnenter stated that the p.1blic wants an "unbiased" opinion fran
saneone other than U.S. EPA. '!hey supported the creation of a local task
. force to look into the process an:l activities at the Site.
Response 10:
krJ member of the pJblic, inc1udirg scientists am technicians, may
ccmment on u.s. EPA's pr'q)OSE!d remedial action. In addition, the p.1blic
may solicit irp1t an:l cx:mnent fran anyone they feel will be ''unbiased''.
U. S. EPA SUR>Orts the idea of a local task force that can be involved in
the SUperfun:i activities throughout the entire process. U.s. EPA has a
t:ed1nical ass~ grant (TAG) program which allows cxmm.mity groups to
receive grant money to hire their own t:ed1nical consultants. A local
group, the Crab Orchard Response Team (ney. If
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work with any groups an::l/or in::lividuals that want to be involved in any
of the upc:x:I'I1in:J SUperfun:i activities at the Refuge.
Carmnent 11:
Carmnenters asked why the conpmy (ies) responsible for the contamination
are not payiIg for the cleanup.
Response 11:
S~ the Crab 0rd1ard National Wildlife Refuge is owned by the Federal
govemnent, particular legal starx1ards of CERCIA apply. Section
120(e) (1) of CERCIA states that "...the deparbnent, agency, or
instrurrentality which owns or operates sud1 facility shall, in
consultation with the Administrator an:i appropriate State authorities,
ccmnenoe a remedial investigation an:i feasibility study for such
facility." u.s. EPA wculd therefore consider that the requirement to
con::luct the RI/FS is strictly ool's. Notl1irg in CERCIA prevents 001 fran
enteriIg into an ag1:eellent with another party for that party to assist
001 with its obligation. In this case, Sa.n:;aloo Weston, Inc., a CCIt1pCU1y
that produced electrical equipnent at the Refuge, an:i 001 entered into an
Wepen:lent, volun~ agreement to perfom the RI/FS. Both 001 an:i
~ Weston, Inc. have contributed to the costs of the work which has
been done to date at the site.
Co~ has directed u.s. EPA on the broader issue of how to work with
private parties that may ~ve been responsible for contamination at
SUperfun:i sites. Con;}ress has established provisions in CERCIA that
allow private parties to do work at SUperfun:i sites (Sections 106 an::l 122
of CERCIA) while u.s. EPA retains the oversight responsibility to ensure
that the work is done correctly (.in=lucling any an:i all additional work
u.s. EPA determines to be necessazy). Under CERcrA Sections 120(e) (6),
106 an::l 122 U.S. EPA has the authority to allow or require Sa.n:;aloo
Weston, Inc. or other potentially responsible parties to perfom an:3;or
pay for remedial action activities at the Refuge.
Comment 12:
Sane ccmnenters wanted to knew We has the burden of proof if a suit is
brought against u.s. EPA by Illinois or citizens. '!hey felt that the
burden of proof shoold be on U. S. EPA to prove that the operation of the
1:elOedy inplementation is safe.
Response 12:
Citizens, .in=ludiIg the State, may briIg an action against U.s. EPA umer
CERCIA Section 310, 42 U.5.C. ~9659, allegin;J that a rem:JVa1. or remedial
action taken umer CERCIA Section 104 or secured umer CERcrA Section 106
was in violation of one or Jm)re of the nc:I'Hiiscretionary provisions of
CERcrA. HoINever, umer CERCIA Sectioo 113 (h), 42 U.5.C. ~9613 (h), no
such citizen challenge to a removal or remedial action may occur prior to
CCIIpletion of the leItledy. In addition, umer CERcrA Section 113 (j), 42
7
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u.s.c. ~9613(j), judicial review of arrj issues conc::erni.rq the adequacy of
the response action taken, incl~ issues of short-term effectiveness
aOO safety, shall be limited to the administrative record, aOO the ccmt
will uphold u.s. EPA's decision in selecti.n;r the response action unless
the objecti.n;r party can dem::>nstrate, on the administrative record, that
the decision was arbitrary aOO capricious or otherwise not in accordance
with law. .
Camrent 13:
Sane ccmnenters pointed out that the Toxic SUbstances Control Act
("'!SCA"), is U.S.C. ~2601 et seq., allows for alternative treatment
n-ethods to be used rather than incineration aOO one c:x:mute1ter read
several excerpts of the TSeA regulations into the record.
Response 13:
u. s. EPA is aware of the TSeA regulations, aOO has considered TSeA in the
ARAR process. TSeA does allow for alternative treatment n-ethods to be
used. '!he regulations of 40 em 761.60(e) allow u.s. EPA to consider a
alternative treatment if the alternative treatment meets the perfonnance
equivalent to an incinerator as required by 40 em 761. 70 (i.e., equal
desb:uction of PCBs) aOO will not present "...an unreasonable risk of
injury to health or the envirornnent. II '!he alternative treatment
technology dem::>nstration of in situ vitrification provided in the ROD is
based upon the '!SCA ARAR for the allowance of alternatives to
incineration. Section X. B of the Decision SUmmary portion of this ROD
includes a discussion of the TSeA regulations that will be n-et by the
Selected Remedy for the PCB Areas Operable unit.
Ccmment 14:
A few ccmnenters demarxied fonnal written responses to their camments
before the. ern of the p.1blic ccmnent period.
Response 14:
Section 117 of CERCIA requires the u. S. EPA to allow an q;:portunity to
ccmnent on the Proposed Plan for remedial action. Section 117 (b)
requires that the final plan (the ROD) "... be acx::arpanied by ... a
response to eadl of the significant cxmnents, criticisms, ani new data
suJ::mitted in written or oral presentations...." '!his ROD is the final
plan for the PCB Areas at the Refuge. '!he u.s. EPA is mardated to
provide its fcmnal respoJlSes to ccmnents as part of the ROD, thus, they
were not provided before the ern of the ccmnent period.
CCmnent 15:
One camnenter asked aba1t other similar SUperf\m:l sites where
incineration was not d10sen as the :t:E!\.eJy, aOO asked for infonration em
why incineration was not d1osen.
8
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Response 15:
A number of SUperfun:i sites have soil arxl/or sediment contaminated with
PCBs, a.n:l frequently with other hazardous subst:.arres. AU. S. EPA
document dated September 22, 1989, titled Draft Guidance on selectin;J
Remedies for SUDerfund Sites with PCB-contamination cH!::nJSSeS a number of
similar sites, the remedies that have been selected for these sites, an:i
the rationale for the remedy selection. For 50% of similar sites with
PCB-oontaminated soil a.n:l sediment, incineration was the selected remedy.
For the majority of sites where incineration was not selected, the high
cost of incineration was a priInazy consideration to ~rt another
remedy. For additional details, copies of this doo..nnent have been sent
to the information rep:sitories.
Camnent 16:
Same canmenters worrlered wy the parties i..nvol ved in the development of
the RI an:i FS could have different interpretations of the information an:i
different recommenjations about a suitable remedy. Specifically, people
questioned wy O'Brien & Gere ~ineers had recammerrled stabilization
treatment rather than incineration.
Response 16:
O'Brien & Gere Er¥1ineers, the consultants that prcxiuced the RI am F5
reports, were retained by San;Jam Weston, ~., a cc:rrpmy that produced
PCB-1aden electrical equipnent at the Refuge. SarxJamo Weston, Inc. had
hired O'Brien & Gere to do the RI/FS work as part of a cexJPerative
a9l~lIent with the Fish am Wildlife SeIvice. In its review of the F5,
u.s. EPA requested ~ of O'Brien & Gere's r~lIu.enjation for re.l(1edy
selection, because the FS shoold be limited to a CCIt'IpCilQ.tive assessment
of eadl of the remedial alternatives against the nine remedy selection
criteria. O'Brien & Gere am San;Jam Weston, ~., as members of the
public, are entitlEd to express their cx:mnents regardin;J u.s. EPA's
preferred le.lllerJy. '!hey are not entitled to select the le.luedy for the
site. '!hey have ~rted stabilization treatment rather than
incineration based on a different interpretation than u.s. EPA of the
balancin; criteria, prilnarily, the cost criteria.
Camnent 17:
One CX'It'IIt'enter stated that u.s. EPA is not meetin; its mardates fran
cor~ess in the selection of remedies for SUperfun:i sites. Specifically,
U. S. EPA is not selectin;J permanent remedies, is not wei9hin;J protection
of health mre heavily than cost, am is not payin;J eno.Igh attention to
CCIt1ItI.mi ty i11p.rt:.
Response 17:
U.S. EPA has met its statutory manjates in the selection of this reluedy
for the PCB Areas ~le \mit. 'lbere is an extensive d;c:rl1ssion of hew
9
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this L~U~ meets these manjates in section X. of the Decision SUnunary
portion of the ROD.
Camnent 18:
one camnenter felt that the p.Jblic should be fully infonned ani then
allowed to vote on the selected remedial action.
Response 18:
section 121 of CERCIA di !':l"'.!JSSeS the selection of remedies for SUperfun:l
sites. Con;ress has directed that the President select remedial actions
for sites after evaluatjn;J numerous specific issues. '!he President, in
canyjn;J out his Con;ressional man:iate, has delegated the authority for
remedy selection to u. s. EPA. CERCIA further specifies the provisions
for p.Jblic involvement in Sections 113 (k) ani 117. 'Ihese provisions
allow for public inplt, but do not allow the public to select remedies by
votjn;J or other processes.
Camnent 19:
Several camrnenters W'Ol'Xiered why the preferred alternative identified in
the Proposed Plan was not one whid1 was outlined in the FS.
Response 19:
Although not presented as a oonsolidated alternative, the preferred
alternative identified in the Proposed Plan was outlined in the FS as
alternatives 3-lB, 5-lB ani 7-lB. For ead1 of the study sites to be
remediated, the preferred alternative was fully screened against the
leb.:Uy selection criteria in ead1 of the relevant chapters of the FS.
Camnent 20:
one camnenter stated that information was not available at the
information repository at Marion Federal Penitentiary.
Response 20:
U.s. EPA's Ccmmmity Relations Coordinator d1ecked the information
repository at Marion Federal Penitentiary am foun:i that the documents
are available thra.1gh the prison library am are up to date.
B.
General Cc:mnents ani Questions About the site
Camnent 21:
People questioned haw safe the Refuge is for humans such as d1ildren ani
pregnant wate1, whether wildlife is erDan;Jered, am whether the fish in
Crab ord1ard lake are safe to eat. To one extreme, one ccmnenter felt
that no one is currently at risk fran the PCB-c:ontamination in the
groorxl.
10
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Response 21:
5ecllinent, water aId fish samples were taken from crab orchard lake as
part of the Remedial Investigation, aId the analysis of these samples was
used to support the risk assessment that evaluated the safety of the
site. In general, the risk assessment in:ticated that Crab orchard lake,
outside of the Area 9 Embayment, is safe for recreational activities such
as swi.nu'ni.rg aId boatin;J, aId the water is safe for human co1'1SlIItption.
'!here is a fishin; advisory on the lake which was placed by the IEPA,
Illinois Department of Public Health aId Illinois Department of
COnservation. '!he advisory was placed because sane fish showed elevated
levels of contamination. u.s. EPA :recc:mnerx:'is that people canply with the
fishin:;J advisory. '!he risk assessment in the RI in:ticates that high
levels of fish COl'1Slmption may pose an elevated risk to in:tividuals. '!he
assumption that no one is at risk fran the PCB-contamination at the site
is not supported by the risk assessment. '!he unremediated study sites
pose POtential excess risk to both human health aId wildlife.
Camnent 22:
Sane cxmrenters pointed out that the contaminants have been at the Refuge
for decades, aId asked how l~ the material remains hazardous.
Response 22:
EG3s am lead are the major contaminants of concem at this operable
unit. Lead is a naturally occurring element which is not destroyed in
the envirornrent. PCBs are very chemically stable umer a variety of
comitions, ani are exceptionally persistent in the envirornrent.
Camnent 23:
One camnenter asked why EPA did not take action at the site sooner, if
they knew about the contamination prOOlem.
Response 23:
In proposin;J the crab Orchard National Wildlife Refuge for irx:lusion a1
the National Priorities List (NPL), u.s. EPA evaluated exi.stin:.J site
infonnation ani made the detennination that a release or substantial
threat of a release of hazarda.1s suDstances had occurred or ~d oocur
that ~d endan:]er h\.Dnan health or the environment. However, because of
the limited aooes9 of humans to the contaminated areas an::i the efforts of
OOI to further reduce exposure by issuin;J warnirr;Js aId fish advisories,
U. s. EPA determined that emergency respallSe action was not warranted.
'!he Fish an::i Wildlife setvice (FWS) an::i u.s. EPA began action in 1986,
prior to final listin;J of this site on the NPL, by initiatin;J the RI/FS
that provides the basis for this info:z:med decision on ~rq>riate
remectial action.
11
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Camrent 24:
One ccmrrenter stated that the time frame to clean up the entire site
could be 20 to 30 years, rather than the 2.5 to 5 years di~sed in the
Proposed Plan because there are areas at the Refuge that have not been
investigated.
Response 24:
Because of the size of the Refuge am the number of potential areas at
the Refuge that may have been adversely ilTpacted by irxhJst.rial activities
at the Site, it is true that the entire SUpe.rfun:i process is e>q)eCted to
be len;Jthy. In order to streamline the process, problems which are
apparently related have been grouped into operable units, am each of
these operable units will be on irrlepen:1ent, but possibly concurrent,
schedules to c::x:.Irplete the necessary remedial action. '!he schedules will -
reflect available information about the magnitude of the threat to human
health or the envirorunent, am will prioritize the units accordin:;Jly.
The schedules for each operable unit are beirq finalized in the
interagency agreement which is e>q)eCted to be signed by September 30,
1990 (see the Response to Camnent 5). '!he 2.5- to 5-year schedule is an
estimate for the inplementation of the Selected Remedy for this operable
unit usirq incineration ted1nology.
Camment 25:
One commenter ~ressed concern with the concept of a "walk away site",
if taxies will be left buried in the grcum.
Response 25:
The object of the selected :teiuesly is to minilnize the areas at the Refuge
that will require lon;J-tenn mnitorirq am maintenance, am to
permanently destroy those ~ that can be treated. The area where
the metals will be managed as residuals will require lon;J-tenn mnitori.n;J
am maintenance, am property management (includirq lam use
restrictions) as lon;J as the contaminated residuals remain at the Site.
'!he areas where remediation is cx.rrplete am where no contaminants are
left above the remediation goals will require m future DDnitori.n;J or
lam use restrictions.
Camnent 26:
Several c~ ~Ial~ tters ~ressed conc::ern about the effects of incineration
technology on the CXI1III.D'l.ity in general. Specific concerns ~ raised
about property value reduction, damage to tourism am an adverse effects
on enrollment at Scut:hem Illinois University (SIU).
Response 26:
'!he inpact of remEldial alteJ:natives on local OC1'11ItImities is evaluated
through the criteria of short-tenn effectiveness, lon;J-tenn effectiveness
12
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am pemanenc:e. '!he design of the Selected Remedy will pI'eYent adverse
short-t:e.nn ilrpacts to the area, such as air emissions, potential dust
generation or surface water run-off, by usin;J erqineerin;J methods to
prevent these fran oa::urrin;J. '!he ilrpact of the selected remedy on
tourism or SIU enrollment is difficult to assess quantitatively.
However, the evaluation of short-t:e.nn effectiveness in the FS irxlicates
that the ilrpact fran incineration will be no greater than the ilrpact fran
the other alternatives, am is likely to be 11U.1ch less than the adverse
effects on tourism (or SIU enrollment) that have occurred because of the
existin;J contamination problem at the Refuge. Refuge figures irxlicate
that annual mnnbers of visitors to the Refuge declined fran 1,200,000 to
800,000 because the p..1blic is aware of existin;J contamination problems.
Clearly, pennanently eliminatin;J these problems can only irrprove tourism
am decrease adverse ilrpacts on the nearby c::c::It11'D.JI ty .
Canment 27:
Serre commenters expressed concerns that exposure to toxic campou.rrls can
take place through various pathways which will be influenced by the
transport process am the receptor organisms.
Response 27:
u.S. EPA agrees that contamination of several media can result in
exposure of different organisms through various pathways. To address
this c::on:em fully, the risk assessment process includes a c::orti'rehensive
evaluation of the exposures of various sensitive receptors to a variety
of potential exposure scenarios.
Canment 28:
One commenter was concerned that the remedy for the site does not take
the contaminants out of the sediments in crab Orchard Lake or out of the
fish in the lake.
Respouse 28:
'!he remedy selected in this R)[) does specify a remediation goal for
contami.nated secllitwants in crab Orchard Lake, am renKJVa.l of secllitwants
which contain concentrations of contaminants above this goal are
required. '1he 1aueJy does not propose arrf remedial actions specific to
the fish pop.1lation of the lake. Hc7.Never, ~i1llPJ1t cleanup targets have
been established to protect wildlife, ani have been set to minimize
bioaocunulation of PCBs into fish tissue. '!he renKJVa.l of the sources of
contamination (soils ani secllitwants) sha.1ld allow the levels of PCBs in
fish tissue to drop in the future.
Ccmnent 29:
Several canmenters felt that the cost of the izx:ineration alternative is
far too high, especially oonsiderin;J the questions aba1t its safety.
13
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Response 29:
Cost is only one of the nine criteria which are considered before a
remedy is selected. Although incineration appears to be lOOre costly than
other al ternati ves, implementation of incineration provides a better
balance of lOl'XJ-tenn effectiveness, permanence am reduction of
toxicity, IrCbility am volume than any of the other alternatives. ISV
may also provide this balance of the de.m:mstration set forth in section
VIII-A.3 of the Decision SUrrInaJ:y is successful.
c.
Comments on the Safety of Incineration
COmment 30:
Numerous comrnenters felt that incineration is not a safe or proven
technology am that incineration's "track record" is too short.
Commenters said implementation of incineration does not fulfill the
overall criteria of protection of public health am the environment.
concem was e>q;>ressed over the lack of an evaluation of the potential
adverse impacts of incineration on wildlife, plants am terrestrial
ecosystems .
Response 30:
Incineration technology has been in use since CCI'CIIt1.D'li.ties first began
burni.lXJ refuse. '!he technology has evolved am become refined as the
waste in:lustry developed its use for ctisposil'XJ of hazardous wastes, aItOl'XJ
them, PCBs. Numerous applications of incineration technology urxier the
Toxic SUbstances Control Act (TSCA), which regulates the harxilil'XJ am
disposal of PCB-contaminated wastes, have resulted in U. s. EPA' s
determination that, when operated subject to strict controls am
perfonnance st:.aroards, incineration represents the best derronstrated
technology available to dispose of PCBs in the concentrations fOlD'Xi at
the Crab Orchard site. Contrary to the ~ over a lack of evaluation
of adverse impacts to wildlife, plants am associated ecosystems, the
risk characterization am e>cposure assessments con:iucted duril'XJ the RI/FS
scecificall v address those impacts am establish remediation goals which
will mitigate them.
COmment 31:
Numera.1s cxmnent:ers expressed cxn:mn with potential air emissions fran
the incinerator. A gra.1p of cxmnents involved the fact that all
incinerators, regardless of the stan:mrds required, ~d pennit an
"allC74lleCi" am:JlU1t of emissions for various contaminants, specifically:
metals (particularly lead), dioxins ani furans, inhalable particles or
CXItpJl.1n:is that may contr:ih.rt:e to acid rain, global waJ:1IIin:J or depletion
of the ozone. In addition, ocmnenters e>q;>ressed doubt in EPA's methods
ani ability to IOOdel ani subsequently measure the cmnmts of emissions
am their potential impacts on hlmlan health am the environment.
Concerns were also e>q;>ressed aba1t the adverse impacts of malfunctions of
the incineration process.
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Response 31:
It is generally true that incinerators, regaJ:dless of the air pollution
control devices attached, will produce same air emissions. '!be expected
byproducts of canbustion are water vapor ani cartx:m dioxide, which would
not cause harm to nearby humans or wildlife. For campoun::is other than
water ani cartx:m dioxide, strict emissions st.anJards must be met ani the
incinerator will be designed to achieve those st.anJards. '!he first step
to minimize emissions is to design the incinerator to assure the ItDSt
c::x::Itplete canbustion of organic material possible by choosirq optinnJrn
parameters for 1) the retention time of the waste in the combustion
chambers, 2) the highest temperature necessary for complete combustion of
the waste ani 3) ample mixi.n;J of the waste to be canbusta:l ani the heated
oanbustion gasses. '!his design will minimize emissions of dioxins,
furans, unburned FCBs as well as pollutants which have been associated
with global warmi.I'g ani depletion of the ozone layer.
'!be secon:l line of defense to meet the emission st.an::Iards involves a
specially designed air pollution control system. Typically, such a
system incorporates several control devices, usually in a series, which
sequentially rerrcve pollutants. When pollutants like heavy metals, ani
organics, sum as dioxins ani furans, are entrained on particles of
uncambustecl material, physical methods such as baghouses, venturi
separators ani electrostatic precipitators are employed. For rerrcvirq
pollutants that occur as gasses, sum as vaporized metals, organic fumes
an:i acid fumes (sulfur an:i nitrogen oxides), devices sum as wet
scrubbers ani camon strippers can be used.
Once the appropriate incinerator design ani pollution control system are
mosen, multiple mnitorirq systens an:i safety controls are added. A
trial burn of a low concentration waste is comucted to determine the
settirgs ani adjustments that provide for day-to-day operation which
meets the strirqent performance stan:1ards. Malfunctions of aIrf of the
incinerator processes or pollution control equiprent trigger autanatic
shutdown controls on the incinerator until the malfunction is located ani
repaired. As di~.1Ssed in the ROD, ancillary systens are added to the
incinerator lD1it to prevent fugitive emissions fran the incinerator or
fran material hamlirq.
In:;inerator designs and their control systens chosen by u. S. EPA are
typically oonse.rvative or "aver-designed", so that emissions st.an::Iards
are met within a large margin of safety. Likewise, the predictive
dispersion models used are equally oonse.rvative so that incinerators will
be sited and operated such that inpacts to human health and the
environment will be negligible, if measurable at all.
Canment 32:
Sane cxmnenters asksi questions al:n1t the fuel used to fire the
incinerator. Concerns were raised aver the potential emissions fran
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the fuel. One canment.er felt the energy costs wculd be extremely high
an::i another asked if there was any connection to a proposed waste
blen:iirg plant.
Response 32:
'!he control of emissions generated fran the fuel wculd be addressed in
the iI¥::inerator design an::i pollution control systems di !'::l"'IJSSed above.
Natural gas, a "clean .bumin;J" fuel, will likely be used to maintain the
high t.enperatures needed for CCI1'plete FCB canbustion. Energy costs do
make iI¥::ineration cx:rrparatively IrOre costly than non-treatment
technologies, however, the result of iI¥::ineration is pennanent
destruction of PCBs, as opposed to merely conta~ the highly toxic
c::arrpoun:is with a non-treatment remedy. '!he Selected Remedy usin;
incineration technology or in situ vitrification, is not related to a
proposed waste blen:iirg plant. .
Cc:amnent 33:
Several ccmnenters referred to the Liquid Waste Disposal (lWD)
iI¥::inerator in Calvert City, Kentucky as evidence that incinerators are
unsafe. '!he ccmnenters expressed concerns that the lWD incinerator has
released millions of poun:1s of carcinogens to the air which have
adversely iIrpacted agriculture, the SllrI"OUI'Xtin envirorunent an::i have
caused canc:m- an::i other il~ in the local pcp1l.ation.
Response 33:
'!he lWD incinerator facility in Calvert City is an "interim status"
facility un:ier Resource ConseJ:vation an::i Recovery Act (RCRA), which means
it is not now operatin;J un:ier a hazardcus waste permit. '!he State of
Kentucky is respoIlSible for i.ssuirq that permit an::i for il1p::sinq strict
requirements for the proper operation of the facility. However, the
decision has proved extremely controversial an::i the State has been unable
to CCI1'plete finalization of the permit. In the meantime, the facility
operates un:ier con::titions develqped durin:] a trial burn at the facility;
con::titions which will ultiJDately be iIrpJsed in the final permit. '!he
. in::inerators (there are bwo interim status in::inerators at the facility)
are not allowed to burn PCBs in excess of 50 ppn, which would require
additional restrictions un:ier TSCA.
Concerns that IHD is responsible for adverse envirorunental inpacts am. is
the cause of cancer an::i other illnesses in the local population are
unfaD'Xied am possibly inaccurate. '!he Calvert City area is one of heavy
irxiustry, particularly known for its several chemical manufacturin:]
facilities. SUch chemical facilities have often been associated with
increased levels of illness in the SllrI"OUI'Xtin pcp1l.ation. However, no
epidemiological infomation has been deve1qped which can directly link
specific illnesses with the lWD in::inerator. In short, where people have
lived in heavily imustrialized areas am been exposed for decadE>s to
rrW.tiple enviromnenta1 pollutants, it is ittpossible to differentiate the
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sources or the causes of various illr1essE>s in the popllation. What this
means for the crab Orchard site is diso1SS€d in the next response.
Canment 34:
Several ccmnenters stated that comnu.mities with operatin;J irx::inerators
have excess cases of cancer an:l other health effects. '!hey expressed
cxn::em that there have been no lOn;J-tem health studies on such
canmuni. ties.
Response 34:
As ni ="-'JSSed in Response 33, sane heavily in:iust.rialized areas have been
known to be areas of elevated incidences of cancers an:l other illnesses,
as compared to the incidence of those same cancers an:l illnesses in
popllations in non-in:iustrialized areas. SUch in:iustrialized areas may
contain steel mills, chemical factories an:l fossil-fuel power plants, in
addition to the incinerators in question. M.1ltiple sources operatin:]
aver several decades make it impossible to pin any particular increase
in illness on a specific source. Where incinerators operate in non-
in:iust.rialized areas like the Refuge, such health studies cannot separate
out those il~f'es that may cx::cur due to (or be exacerbated by) an
in:ii vidual's activities, such as Sl'OC)kin;J or diet.
'!he remediation goals selected for the crab orchard site are inten:ied to
reduce the risk fran ~ to the PCBs rt:M in place on the Refuge to
approximately 1 x 10-6, or one in one million. '!his means that in a
hypothetical popllation of one million people who are continually
exposEd to the PCB residuals left at the site (Le. Job Corps Iardfill
an:i Pon:i) each day for a lifetime of 70 years, only one has an additional
chance of contractin:] cancer specifically due to the exp:JSUre. '!his
shcW.d be balanced against the current health risk at the site of 1.1 x
10-3, or one in 1000 people, usin;J the same exp:JSUre scenario. U.S. EPA
has deliberately chosen these very consezvative levels (1 x 10-6) for
human health protection, which will be virtually umneasurable against
the average lifetime cancer risk of one in every four people.
Ccmnent 35:
one canmenter cited a study by the EPA scien=e Advisory Board dated April
1985, Inhalation Pathwav Risk Assessment of Hazardous waste Incineration
Facilities. '!bey stated that this study concluded .irx:ineration is not
necessarily a safe process, an:i asked hc:7.i EPA can new state at this site
that .irx:ineration is a safe process.
Response 35:
'!he above referenced report identified safety problems with .irx:inerators
operated prior to 1985. Reports such as this have resulted in the
awlication of more strin:]ent stan:Jards for .irx:inerator units which have
been subsequently selected by U.s. EPA for the .irx:ineration of hazardc:us
waste. As ni c:t"'IJSsed in carment 7, U.S. EPA cannot guarantee 100%
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"safety" of any l:ell~. However, incinerators can be opera~ safely so
as to reduce the risk of PCB-contamination at the site to within a I"an;e
of "acceptable risk" as opposed to the unacceptable risks associated with
tak:in; no action at the site. .
Camnent 36:
One cx:mnenter stated that the operation of an incinerator may not be safe
because the incinerator operators are "sleazy", that they have no reason
to operate well, arx:l are m:>re interested in profit than safety.
Response 36:
In choosirg contractors to operate incinerators, U.S. EPA carefully
screens out contractors who cannot shCM that they will operate the
incinerator safely arx:l within the law. Once chosen, the operator faces
civil arx:l criminal penalties should the operator operate the incinerator
in violation of perfonnance staOOards.
Camnent 37:
One c:xmnenter wanted to know' which incinerator operators U. S. EPA has
used or approved in the past.
Response 37:
Many incineration contractors have operated unier the various auspices
of U.S. EPA programs inclucli.rg SUperfurx1, ~, '!SCA arx:l unier pennits
issued pursuant to the CAA; however, U.S. EPA does not officially en:iorse
or (without fonnal p~) denoonce incinerator operators. SaTe
large incinerator contractors which are operatirg or have operated in
Region v include westi.n;house-Hazte, Olemical waste Management, Weston
arx:l Ogden Envirorunenta1. .
Camnent 38:
Sane cx:mnenters expressed con::erns that the trial bum only provides a
snapshot, arx:l does not inticate actual evezyday operatirg cornitions.
Response 38:
On the contrary, a trial b.1m is designed to specifically identify the
I"an;e of "everydaY" operatirg cornitions aItside of which the incinerator
will not be pemitted to operate. .
Camrent 39:
One canmente.r questioned why groups such as Greenpeace, the citizens
Clearin:Jhouse for Hazardous Waste, the National Toxic Canpaign Against
IIx:ineration, arx:l many local groups woold cwose incineration if it is
safe.
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{}
Response 39:
u. S. EPA cannot speak for or represent the opinions of these groups, but
generally such groups oppose incineration not as an "unsafe" technology
but as a technology that poses too many unacx::eptable risks to be widely
applied in dealirg with our national waste disposal problem. '!hey may
feel the canparative risks fran incineration to the risks of other
technologies favor the developnent of other technologies. In d100sirg a
remedy for crab Orchard, ~er, u.s. EPA is znakirq a decision on the
canparative risks of incineration, which permanently destroys R::Bs,
versus the risk of leavirg concentrations of R::Bs on the site that may
threaten human health am the environment.
Camnent 40:
one c::anmenter e>q:>ressed concern with the potential safety hazard fran the
location of the incinerator (am its stack) in the vicinity of the county
airport.
Response 40:
'!he stacks of m::Ibile incinerators are generally not tall enough «100
feet) to pose a P'1ysical darger to neamy aviation. HCMeVer, the
possible iIrpact of arrj water vapor plmne will be considered when
d100sirg a site for the incinerator.
Camnent 41:
sane camnenters expressed COI'rernS with the location of the incinerator
in an area of seismic activity, am the potential adverse effects on the
incinerator that coold oocur.
Response 41:
Areas of known am. frequent seismic activity will be avoided when
d100sirg the incinerator site. safety systems will be designed into the
incinerator to accamt for various natural disasters, inc1uctin;J seismic
activity.
t:nnmP.J1t 42:
sane ccmnenters stated that they felt incineration was the best relle~1y
for the PCB-ocntami.nation.
Response 42:
u.s. EPA agrees that incineration is the best ten.edy for the PCB-
contamination at the Refu;e, am, therefore, U.s. EPA has selected
incineration as the ~el1e1y for this operable mdt. '!he basis for the
selectioo of incineration is n; ~lssed in the Decisioo Slmmary portion of
the RID. However, because vitrificatioo may be able to be deua1strated
to attain the same perfonnarre starmrds as incineration, it may be
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i1rplemented if a treatability study denonstrates that the ~ can
be met.
..,.
D.
Comments am ouest ions on the Safetv of other Remedial canconents
Canment 43:
One ccmnenter asked how cx:>ntaminated dust which could potentially be
generated durin;J excavation of cx:>ntaminated soil am sediment will be
controlled.
Response 43:
As explained in the ROD, procedures for dust cx:>ntrol durin;J material
han:llin;J will be required in the design of the selected remedy.
u. S. EPA is aware that excavation of contaminated soil am sediment has
the potential to create cross-media iIrpacts, such as releases of dust to
the air or ron-off to surface water. Safeguards are established as a
part of the remedial design to prevent these potential adverse iIrpacts.
Specific design features will address dust suppression am ron-off
control. Typical dust suppression measures for earthwork include wettin;J
of the material am certain han:llin;J techniques. '!he design will also
include methods to control dust emissions fran the stabilization!
. fixation treatment process. In addition to the en;ineerin;J controls to
prevent releases of oontaminants, the remedial design will incluie
mnitorin;J requirements to ensure that the control processes are workin;J
am a contin;Jerx:y plan on how to address am cx:>rrect arrj malfunction that
could damage the environment.
C:mnent 44:
Sane commenters questioned how the deteI:mi.nation would be made that the
incinerator ash is "clean" before it is replaced into the excavated
areas.
Response 44:
Irx::inerator ash whim meets all of the cleanup targets am ARARs
n; Ql"'I1SSed in the Decision SUn1nary portion of the ROD would be cx:>nsidered
clean. '!he ash walld be tested in accordance with an awroved sanplin;J
am analysis plan to establish whether the stamards had been met. Ash
that does mt meet the cleanup targets will be solidified in an
imustrial lan:lfill.
<'aTInE>.nt 45:
One camoenter questia1ed whether the incineration of soil am sediment
oo-oontaminated with metals will inc:::rease the potential for the metals to
leam.
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e.
Response 45:
'!be metal contamination may be less m:bile because of its association
with certain soils such as clay. InciIle.ration should not affect this
relationship. However, the selected remedy requires that ash be
IrOnitored for the m:bility of the metals, ani all of the soil ani ash
with m:bile metals (EP Toxicity or'Icr.P) will be treated in order to
ren:ier the metals less m:bile.
a:mnent 46:
One camnenter felt that the requirements for the lonJ-term mnitori.n;J of
the on-site lan:lfil1 \¥ere too vague, especially as to how lonJ the
IrOni torm; would ex>ntinue.
Response 46:
Monitorm; of the 1an:lfil1 would be required for the life of the
1an:lfil1. CERCIA requires a review at least every five years to ensure
the continued safety of CXIt1pleted remedies when hazardous substa.rw::es are
left on-site. SiIre the metal waste constituents will be treated ani
left at the Refuge, the integrity of the 1an:lfil1 will be m:m.itored to
~rt the evaluation.
a:mnent 47:
sane camnenters expressed corx:em that 1an:lfil1s will ultimately leak ani
contaminate the groordwater.
Response 47:
'!be prcblems of potentiallea){1D; fran the 1an:lfil1 are addressed in two
ways. First, the lanifill is designed with a lead1ate collection system.
'!his system is IrOnitored ra.rt:iI1e1y to see if any lead1ate is generated by
the 1anifil1, an:! if so, whether it contains hazardous substa.rw::es. '!be
secxn:l method to assoos potential groordwater contamination is the
requirement for ra.rt:ine groordwater m:m.itorm; arami the lanifill.
'lbese m:m.itor:in:;J ass---rt,s allow early detection of any releases fran
the lanifill, so that oonective action can be taken.
a:mnent 48:
A 11\.1IIi:)er of o.....-11ters cg>osed the location of the lanifill cn-site, an:!
expressed a prefereooe that the material be m:wed off-site.
Response 48:
Because metal contamination can be treated b.1t not pennanently destroyed,
the ~ial alternatives evaluated in the FS all inclu:ied a oarponent of
lonJ-term oonta:irunent (except the no action alternative). '!he FS Report
includes an ass~~.nt of both on-site ani off-site lanifills, with or
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without treatment of the material prior to disposal. ~ alternatives of
on-site versus off-site larxifilling were canpared against the nine
criteria used to evaluate potential remedies, am were also evaluated
against the goals am mission of the 001 for lorq-teI:m Refuge management.
'!he c:x:rrp:irative assessment of the larxifill locations in:licates that an
on-site larxifill is preferred. '!he Agencies believe that it is easier to
ensure the lorg-teI:m effectiveness am pe.nnanence of an on-site larxifill
for the treated material through aggressive lorg-teI:m operation,
mnitoring am maintenarre. DispJsal of the treated material in an off-
site lanifill may allow the material to be mixed with other waste Wich
might adversely affect the treatment process am increase the ItDbility of
the contaminants. In addition, the costs of disposing of the material in
an off-site lanifill are significantly higher without providirg any
additional benefit.
-./
CERCIA Section 12l(b) states that "'Ihe off-site transport am disposal of
hazardous substances or contaminated materials. .. should be the least
favored al temati ve remedial action...." IEPA has assessed the capacity
of cx:amnercial lanifills in the state of Illinois am this assessment
in:licates that capacity is limited. In addition, 001 believes that an
on-site lanifill is consistent with its mission am obligations for the
Refuge. Because the Agencies believe that an on-site larxifill is safe
am provides the best balance of the remedy selection criteria, an on-
site lanifill has been selected as the disposal camponent of the selected
leiueJy.
CaTIment 49:
Several ccmnenters expressed the opinion that a RrnA design for the
lanifill c:::arp:ment of the 1=1-=Jy is lOOre suitable than a solid waste
lanifill design. '!hey felt that a RrnA larxifill would be lOOre protective
in the lorg run.
Response 49:
A solid waste lardfill was selected because the regulato%)' requirements
for lanifill design are based on the type of waste to be nj~. A
RrnA lardfill is required for the disposal of hazardous waste, as
defined in 40 CFR 261.3. since the material to be disposed here will not
be a hazardCAJs waste When it is disposed, a RrnA lardfill design will not
be selected as an ARAR. HCM!ver, as part of the remedial design process,
various landfill designs will be evaluated to see Wich design provides
the ~ containment of the waste. '!he final lardfill design will
be based an technical requirements, am will meet, at a minimum, the
legal design requirements.
Camnent 50:
Several ocmnenters questioned whether a water tank at the Refuge could be
safely retrofitted to dispose of hazardous waste residues.
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v.
v
Response 50:
'!here is a five-million~lon concrete'tank on the Refuge which was
constructed as a water reservoir in 1942. Based on an initial
en;ineerin;J review of the as-built drawin;Js of the tank, it appears to be
technically feasible that the tank could be retrofitted to meet the
design requirements of the selected lan:lfill. However, before this could
be chosen as the final lan:lfill site, an as.~t 'NOUld be made as part
of the design process to establish whether the current corrlition ani
settin;J of the tank would meet all of the ARARs. '!he exact location of
the on-site lan:lfill was not identified in the FS, although several
locations were proposed. '!he Refuge is a large area and there are
several potential locations that would meet the requirements of an on-
site lan:lfill. '!he RI Report provides an initial hydrogeologic
assessrent of many of the study sites. '!his data can be extrapolated to
irrlicate good can:lidate areas for further investigation durin;J the design
~ of the remediation. '!he remedial design will include further
investigations of the IIDSt suitable areas, includin;J the water tank,
before the final location is selected. '!he final location will be the
one which is the IIDSt appropriate ani least disruptive to the Refuge of
those that meet all of the legal requirements ani st:an:3ards discussed in
this ROD.
. E.
Canrnents ani ouest ions Reaardina other Remedial AI ternatives
camnent 51:
In CXI'I11't'el"1in;J on the remedial al ternati ves, numerous oc:munenters expressed
opinions on whether a It::ll-=U¥ for the PCB-contaInil1ated material needs to
be selected ard iJtplemented mI, or whether a remedy oould wait until
sane time in the future.
'!he ran;Je of opinions on this issue is expressed belCM:
a. Sane canmenters felt that the PCB-contamination requires
i.nmediate action, especially siIx::e PCB-contamination has been foun:i in
the fish of Crab orchaJ:d Lake.
b. Sane canmenters felt that, given the questions regardin;J the
safety of incineratia1, it is better to wait ani do ~ at this
time.
c. Sane canmenters felt that siIx::e the waste has been sittin;J at
the site for a lcn;r time, it would be better to cap (Le., a TSCA cap or
a plastic sheetirq caver) the material rDfI, ani wait to evaluate future
technologies.
d. Sane canmenters felt that siJDa alternative technology is bein;J
devel~, the remedy selection sha.11d wait.
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-logies have not been fully
effective at han:Uirg the types am c::orx=entrations of contaminants foun:i
at the Refuge.
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(l
.
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v
CCmnent 53:
One cxmnenter suggested that a two-phase process to hanfie the R:B-
contamination might be m:>re acceptable. '!he first phase would be
separation of the PCBs fran the soil, which would eliminate the :immediate
risk to the env:irormlent. '!he sec:on:l phase would be incineration of the
separated PCBs utilizirq newer incineration technology such as the plasrra
torch.
Response 53:
Although innovative separation technolCXJies are currently beirq
investigated, m proven technology exists for tilysical separation of PCBs
fran a soil substrate. 'Ihermal treabnents such as incineration usirq a
plasrra torch achieve the objectives of both proposed "phases" above.
However, plasrra torch technology has mt been adequately developed to be
irx:luded in consideration of alternatives for the Crab Orchard site.
Canment 54:
Sane c:x:rranenters expressed a preference for containment of the waste as
the selected remedy. One c:x:rranenter suggested the construction of an
earthquake-proof builc:tirr;J to store the waste.
Response 54:
Response #51 explains that CERCIA requires that U. S. EPA must select a
rehledy which is pe.nnanent ani will reduce the toxicity, mbility or
volume of contaminant to the maximum extent practicable. storage, even
in an earthquake-proof builc:tirr;J, is mt a viable alternative because it
does mt fulfill either of these goals. Storage is particularly
unacceptable when ccnpared with technolCXJies such as incineration, whidl
permanently destroys PCBs.
a:mnent 55:
A ferN cx:mnenters had questions an:l camnents aba1t polyethylene glycolate
dechlorination treatment processes (~~lly known as APEX; or !lecules (like PCBs) or to
detoxify them to fom ather ~ that are considered less haImful
an:l envhoumeld;ally safer. 'Ihese treatment processes are currently beirq
investigated by U.s. EPA, D.1t are mt developed eno..tgh to be considered
for full-scale use for Sl.1perfurxl sites for, aIOO1'g ather thiIqs, the
followirq reasons:
1.
2.
Water can adversely affect the rate of reaction.
Reaction byproduct:s are currently mt well umerstood an:l may
be Dn"e toxic than the contaminants be~ treated.
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'!he need to deliver, mix an:i heat the reagent (wh;lch is
expensive an:i non-recoverable when used in situ) an:i the soil
may limit the applicability of the technology.
CCmnent 56:
"
3.
One ccmnenter asked why a specific annmt of the contaminated material
(up to 10,000 cubic yards) CXJUld not be given to a number of treatment
ven:iors to allow them. to derocmstrate their aNn systems. One c:xmnenter
suggested that innovative technologies such as the use of ultra.soun:i,
light an:i ozone, or technologies usin; electron donors be used to
destroy the PCBs.
Response 56:
u.s. EPA maintains infonnation on technologies suitable for the
treatment of various types of hazardous wastes. Amon; the infonnation
which is available an:i updated on a regular basis are reports on
treatment technologies in use, treatability studies an:i reports on
develcpin; innovative technologies. In as'SeSsin; the treatment
technologies available for the PCB an:i lead bearin; waste fran the PCB
Areas c:perable unit, these sources tNere consulted. COnsidercition of the
cq:.plicability of a technology includes an evaluation of whether the
technology has been de,m:)nstrated to be effective, whether the process is
available at full scale, whether it has potential adverse effects on the
co-oontaminants, an:i legal restrictions on what type of treatment may be
used. Although the abave-JreJ'1tioned technologies may one day score highly
un:ler such an evaluation, they are not viable for selection at this time.
A Site-specific lemedy is not the place to allow a number of different
treatment ven:lors to try to de,m:)nstrate that their processes may be
effective. A major problem with this proposal is that an successful
system may make the situation at the site worse.
Camnent 57:
One cxmnenter, a vendor of waste treatment processes, submitted
infonnation Pertainin; to two treatment processes that felt would
adequately remediate the site. '!he processes are: the ABSKO process
whid1 is said to be an organic reduction process whid1 rem:wes d1lorine
iran hydrocaJ:bons ani produces a synthetic fuel; ani the BioVersal
process which is said to reroove hydrocaJ:bons fran soil. '!he cxmnenter
requested a semple of material to run tests to dena1strate the two
processes .
Response 57:
'!he data sutmitted to S\g)Ort the prooess;es raise serious questions an:i
cance.ms. First, the pzooesses were used on oils, bIt there is no data
specific to PCBs. Secon:l, the processes were said to leave approximately
200 parts per million (ppn) of residue, which far exceeds the acceptable
cleanup target for the Refuge. 'lhircl, the ABSI
-------
u
'\._-"
')
produce a synthetic fuel which is not characterized am may. be hazardous
or toxic. 'Ibis fuel would require subsequent treatment or disposal which
cannot be evaluated since its makeup is unknown.
Canment 58:
Sane cx::rnrrenters expressed a preference for stabilizatio1Vfixation
treatment of the PCB-corrt:aminated material because it is cheaper am
~ to be safer am effective.
Response 58:
Stabilization/fixation was evaluated as a technology am incorporated
into the Consolidated Alternatives in the FS am Proposed Plan. It is
also incorporated into the Selected Remedy to address soils arxi sediments
contaminated with heavy metals (approx. 3,600 cubic yards) arxi
i.n=inerator residue, as appropriate. Although stabilizatio1Vfixation
appears to be cheaper than i.n=ineration arxi may have fewer short-term
risks than those attrilJuted to i.n=ineration, stabilizatio1Vfixation does
net provide treatment of PCBs to reduce their JOCIbility, toxicity or
volume to the degree that i.n=ineration does. When CXJTpared tt;> the
Selected Remedy, stabilization/fixation fails to fulfill the CERCIA
statutory man::late for treatment of the pri.n=iPal threats at a site am
the man::late for pennanent remedies where possible.
Canment 59:
One camnenter questioned whether the hazardous materials could be
recovered am recycled.
Response 59:
Recovery technologies are net available for the contaminants faJl"d at the
st1.Xiy sites cxmprisin;J the PCB Areas operable lD'1it. Technologies sud1
as those used in minin;J have net been awlied to hazardous waste an:! have
net been shown to achieve the cleanup targets required. Soil washin;J is
one technology which has potential to be used on metal contamination.
'Ibis prcx::ess extracts contaminants fran the soil usin;J a liquid medium as
a washin;J solution. '!his technology will reduce the volume of
contaminated soil an:! increase the correntration of the contaminants in
the residual. '!he potential theoretically exists that the metal
oontaminants could be oonoentrated to the point where res::overy was
feasible. 1fc1.'ever, there are several reasons wily this technology was
net considered for the metal co-contamination at the Refuge. '!he
reasons i.n=1ude: 1) the ptooess is not ~1"Cially available for soils
contaminated with metals: 2) the prcx::ess works best on coarser soils,
wilile the soils at the Refu;Je ten:! to consist of fine particles (silts
an:! clays), so the feasibility of the treatment is questionable: 3) lead
contamination poses problems for the process because lead is not
chemically associated with arry partio.1lar fraction of the soil an:!
therefore there are diffio.1lties in washin;J it: 4) the cadmium, chrani.um
an:! lead react differently to chemical an:! y;:ilysical ocn:1i.tions so that a
27
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was.hin1 solution suitable for all of them would be difficul~ to specify;
arxi 5) concentratin:;J the metal cx>ntamination fran the soil arxi sediment
at the Refuge might make the conc::entrations high encR.1gh to ren:ier the
:iJmd:>ilization treatment less effective. .
Canment 60:
'!he Shawnee Group of the Sierra Club recommen:Jed a remedial alternative
that would include incineration of only those materials that are not co-
cx>ntaminated with metals, treatment by stabilization/fixation of toxic
incinerator ash arxi ra1-incinerated soils, arxi lan:1fillin:;J of the residue
preferably in an above-grcuni lan:1fill (othezwise in a TSCA lan:1fill) .
'Ihi.s :r'eu..al1L1.en:iation was made with caveats that certain assurances arxi
i11plementation requirements (rH ="IJSSed elsewhere in this Responsiveness
SUnu'nary) would be met.
Response 60:
'!he remedial alternative proposed virtually mirrors the Selected Remedy
d10sen by u.S. EPA arxi described in the IDD. '!he one exception to the
Club's proposal is the inclusion of an Alternative Treatment Technology,
ISV, to replace the incineration arxi stabilization/fixation c::cmponents of
the Remedy. 'Ihi.s Alternative Technology will only be used, however,
after a dem:>nstration that ISV successfully meets the remediation goals
arxi perfonnance stan:1ards established for the Selected Remedy.
'!he assurances sought by the Club include strin:;Jent naritorin:;J arxi
malfunction controls for the incineration (di="l1SS€d in Response #31) as
W'e1.l as testirg of the ash for hazardous characteristics arxi proper
larxifillirg arxi closure for residuals which remain on-site. Steps to
provide those assurances are di="IJSsed in this IDD.
F.
Canments arxi Questions Re.aardim ImDlementation of the Remedv
Carment 61:
SaDe cx::mnenters felt that if incineration is used, there should be
Wepement sb..W.es and oversight to naritor the perfonnance of the
incinerator, arxi that the public should have input into all of the
naritorirg plans and data.
Response 61:
As 1IL1d1 as possible, U.S. EPA will allCM interested parties to oon:iuct
Wepement sb..W.es and 1Ia1.itorirg of the inplementation of the Remedy.
As di="llSsed in Response #10, U.S. EPA reccrrmems the TN:; process as a
fo:rom. for adrlevirg the input desired in the plannirg arxi i11plementation
of the Selected Remedy.
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c'
v
Ccmnent 62:
Camnenters again raised questions regardin;J specifics of incinerator
design an:! c:pna.tion. Exanples include: Specifically where will the
unit be located? What type an:! JOOdel will it be? What will the
technical an:! operational specifications of the unit be? Others made
:reu...llllermtions as to con:titions to be met as a pre-requisite to
operation. SUch recatII'I1el)jations included: havin} emergency procedures
in place against operational failures, havin} IOOnitorin} schedules an:!
testin} methods specifie:i, an:! Pericxlic mnitorin} to ensure performance
stan:1ards are bein} met.
Response 62:
several of these conoems were ni~JSsed in Response #31 as well as in
the ROD itself, however, IOOSt of these concerns canJ'XJt be addressed
until the design ~ of the remedial action begins. A general
nic:t"'l1S-5ion of the incinerator an:! its control/safety systems is given in
response #31. However, the actual design an:! specifications will be
developed by an eJCperienced incinerator design contractor. orx:e designed
an:! b1i1t, the incinerator operatin} con:titions will be detennined after
an actual "trial tmn" is c::orducted. A ran;Je of operatin} parameters
will be established for lc:n;-tenn operation, such as 1) the feed rate of
waste, 2) the arrnmt of fuel ~E'd to maintain rrwnl-I.Jstion an:! 3)
threshold levels for shutdown of the in=inerator in malfuJ'ction
situations. '!he methods ani schedules for effluent an:i emission testirg,
will also be established after the trial tmn. As n;~lS-S€d earlier,
irp.lt fran ccmnunity interest groups is encourage:i durin} the design an:!
inplementation process an:! U.S. EPA will place the appropriate
infonnation in repositories for acx:ess to all interested parties.
Canment 63:
one caumenter stated that scru1::bars (pollution control devices) produce
sludge an:! questioned wimt wculd be clone with the sludge.
Response 63:
Because the ci:>jective of the scrubber is to ret'IDYe heavy metals an:!
organic fumes, the scruJ:i)er sludge walld probably be detenni.ned to be
RCRA hazarda.1s, thus, the sl\Dje walld be treated with stabilization;
fixation to ren::1er it nonhazardc:AJs an:! lan:ifille:i in the on-site
in:1ustrial lamfill. .
Ccmnent 64:
Several cx:mnenters ~ conoem that ~ an in=inerator was brcu;ht
to the site, other waste material fran off-site walld be brought in an:!
the in=inerator walld be left ronninJ full-time.
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"
Response 64:
'l1le Selected Renvsdy will be designed an::i iIrplemented only for the
hazarc:1oos substances fami on the Refuge. Although an on-site SUperfund
iR::inerator does not require an ~tin; permit, it 1IL1St meet the
substantive requirements of '!'SCA an::i RCRA. In order to acx::ept other
wastes fran off-site, U.S. EPA \¥al1d need to obtain a RCRA permit for
cxmnercial operation of a hazardous waste iR::inerator. Since U. S. EPA
has no sud1 permit, an::i will not be applyin; for one, the incinerator
will be prciribit.ed fran acx::eptin; any wastes fran off-site.
Ccmnent 65:
Ccmnenters questioned whether wastes fran other cperable units at the
RefUJe \¥al1d be carrlidates for treatment in the iR::inerator.
Response 65:
:rn:ineration may prove to be a feasible technology to deal with wastes
fran future cperable units, for exanple, destruction of any ordnance
material fami in the explosive/munitions areas. Hc7.vever, the
iR::inerator design necessary for destruction of PCBs may not necessarily
be awropriate for ordnance destruction. At this time, it is not prodent
to tty to develq> a "dual-design" iR::inerator on the speculation that the
iR::inerator miaht be used for other cperable units.
Ccmnent 66:
One caumenter had specific questions an::i conceJ:nS regarciirg CXI'!'pOne11ts of
the l:e1uerJy other than the iR::inerator. 'these include:
a.
How will the lan:ifill be constJ:ucted?
b. What type of cap will be constructed, an::i haw will it be
narl. tored an::i maintained?
c.
Will furx3s be available for maintenance of the cap?
Response 66:
'!he perf~ standards am requirements for the lardfill design are
di~1ssed in Section VIII.A.l. of the ROD, haMever, specific design
parameters sud1 as sitirxJ an::i cap specifications will be refined in the
~i.al design process. '!he ncnitorin:J ani maintenance of the cap will
be c:xn:tucted by the party inplementin:J the ROD (Le., 001 or potentially
responsible parties (PRPs», who will be requirEd to maintain adequate
furx3s for lan;J-te!:m ~tiCX1 an::i maintenance of the cap.
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"
. Weston. Inc.
Ccmnent 67:
5an:]aDD Weston, Inc. repeated the cxmnents that they made for the Metals
Areas operable unit regarclin;J the creation of separate operable units.
'!hey provided their cxmnents on the Metals Areas as an attad1ment to the
cxmnents on the K:B Areas. In general, San;aloo ccmment.ed that they
0RXJSErl u. S. EPA' s decision to treat the Metals ani K:B Areas as separate
operable units.
Response 67:
U.S. EPA reiterates its response to San;aloo's original cxmnents regarclin;
the creation of operable units. U.S. EPA st.arrls by its decision to
create the bIo separate operable units fran the study sites rH!CU"J1C!~ in
the FS (at least bIo 11¥)re operable units have been developed, pertainiIq
to the ''m.mitions areas" ani ''misoellaneous areas." Moreover, since the
ROD for the Metals Areas was signed by U.S. EPA, the National CJntin;Jerx:y
Plan (NCP) has been revised (Federal Register Vol. 55, No. 46, March 8,
1990, effective date April 9, 1990). '!he rew NCP states in 40 CFR
300.430(a) (ii) that operable units generally shalld be used ''when early
actions are neoessary or appropriate to achieve significant risk
reduction quickly, when ~ analysis ani response is necessary or
awrq>riate given the size or c::arplexity of the site, or to expedite the
c:x::IIpletion of total site cleanup." '!he stip.tlatian is that "Operable
units... should not be inconsistent with nor preclude iJrplementation of
the expected final rebledy. II '!he creation of separate Metals ani K:B
Areas operable units clearly meets these requirements am management
prin:::iples.
o,mw:.nt 68:
San;aloo Weston, Inc. ocmnented that the potential risks fran the sites
CCltprisin;J the K:B Areas do not warrant the "extreme" b:wl:~ly. 5an;fcmJ
Weston, Inc. stated that "... the desire for 'penuanenoe' does not alone
justify selecticm of the mst extreme am costly treatment r~
available. . . . II '!hey state that costly treatment technologies shcW.d be
reserved for highly mbile or highly toxic wastes that cannot be reliably
controlled thrtuJh other means. San;aloo Weston, Inc. believes that
alternatives other than oarplete in:::ineraticm fully satisfy CERC[A
criteria an:! goals an:! states that "San;aloo believes that EPA did not
adequately balance the statutory criteria in develq>in;J its in:::ineration
remedy. n
Response 68:
'!he Decision SU1II11ary of the ROD am the a~~in;J Admini.strative
Record doC'~1'1t in great detail how U. S. EPA awlied the risk aC!~essment
am remedy selection process to choose the Selected Remedy. U.S. EPA
believes that the CERC[A criteria am goals were awliecl consistent with
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"'
the National Contin:;Jerx::y Plan (as required) an::l disagree$ that the risks
at Crab orchard do not suwort the choice of incineration or ISV. 'Ihese
tedmologies were d10sen not out of a "desire" for permanence, bIt in
re::.-pa1Se to a clear statutory manjate fran Con;p:-ess. '!be JId:>ility an::l
toxicity of sud1 contaminants as heavy metals an::l PCBs, particularly at
the levels foun:l at Crab orchard, clearly warrant reliable control
technologies, as 5an;aIoo has stated. In::ineration an::l
stabilization/fixation technologies have been repeatedly dem:nstrated to
provide that reliability, or permanence, at full-scale operation. Other
alternatives, incltriin;J the least-costly alternative of in-place
contai.ranent preferred by 5an:;Ja.m:>, are not pennanent solutions an::l
cc::rrpared to the Selected Remedy, leave unacceptable risks of exposure at
the Refuge.
Ccmnent 69:
5an;aIoo Weston, In::. is concerned that the cleanup targets for the PCB
Areas are overly stringent, inawropriate or unfoun::ied in light of the
risk assessment in the RI/FS. Specific COl"Dm1S with the cleanup
stamards follow:
a. 5an;aIooWeston, In::. felt that the threshold criteria above
whid1 excavated soil an::l sediment would be treated an::l below whid1
the materials \tJOUld be disposed of without treatment was not clear
in the P1:qxJsed Plan. '!bey felt that an awroad1 consistent with
RCRA an::l other laws \tJOUld be to treat by stabilization/ fixation
only the excavated material that exhibits the characteristic of
Extraction Procedure (EP) Toxicity when tested in ac::x::ordarx:e with
u. S. EPA protocols.
b. 5an;aIoo Weston, In::. objects to the blanket ~lication of a
cleanup criteria for soil and sediment of 1 x 10 excess carrer
risk. '!be reasons for their objection follow:
(1) '!bey state that the c::x:II'pJl1rd-specific cleanup targets as
developed in the RI/FS prepared for 5an;aIoo by O'Brien and Cere
are sufficient because they ~ devel~ to protect against
the patential risks of the substances identified in the RI/FS,
and that '''!here is no need to specify a cleanup criterion in
the R)[) for other substances that have not been d.isoc:JVered ..."
(2) 'lhey are CXI'O!I'nE!d that u.s. EPA failed to assure that
calcu1atia1S of CUIII.llative risk \tJOUld be based on "realistic
am site specific exposure scenarios rather than on potentially
i.naRrcPriate general assunptions."
(3) F\1rther, they believe that "'Ihe 10-6 risk level should not
be a rigid requirement, bIt at npst a goal to be considered",
am that the R)[) shauld provide for the cleanup gQal to be
stipulated as an EOroeSS risk ran;Je of 10-4 to 10-7.
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~
D3 is-c;11E!d by Region V in the past, an:i is ocnsistent
33
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with criteria established at other sites where nultipl~ c:oritam.inants
are present. ResJ;x>nses to san;ano Weston, In::.'s specific cc.mnents
follow:
<1
(1) 'lhe cx:ttp::Il1ni-specific cleanup targets, as developed in the
RI/FS, the Prcposed Plan ani this ROD, 'Nere developed to
protect against the potential risks of the target ~
identified in the RI/FS, incluc1.irg the risks to e>eposed
wildlife for the specific c:atpJUJ'Xis addressed. HoINever, the
target c:atpJUJ'Xis were refined without estimatin;J the risk fran
other c:atpJUJ'Xis that were foun::l at the study sites. 'lhe risk
assessne1t assumed that many of these other c:atpJUJ'Xis 'WOUld be
addressed by the remediation for specific chemicals. HoINever,
u.s. EPA must assure that this occurs ani the 10-6 excess risk
level is the criterion against which this will be ass-x-9?d.
CERCI.A requires that hazardous substances that "have not been
discovered" must also be addressed if they are foun::l at the
site.
(2) U.S. EPA's policy in assessin;J risk fran SUperfun:1 sites
is that the assessment be based on a reasonable, \\IOrst case
risk assessne1t. 'lherefore, in estimatin;J the residual risk
iran the remediated areas, the calculations of risk to
establish whether the cleanup target has been met will be based
on "realistic ani site specific exposure scenarios rather than
on potentially inawropriate general assurcptions." 'lhe final
assessne1t for the remediated areas will follow the U. S. EPA
guidance on performirq risk assessments. .
(3) 'lhe revised NCP allows for consideration of cleanup
targets within an excess risk rarge of 10-4 to 10-6. However,
U. S. EPA Region v has determined that 10-6 provides an
awropriate stardard of protectiveness as a cleanup target,
based on the Regional Mministrator's decision on acceptable
risk management practices. 'there is no evidence that the 10-6
exoess cancer risk cleanup target for the PCB Areas qJerable
mri.t is in oanflict with the statuto~ mamates of CERCIA.
Also, the risk assessne1t in the RI SlJRX)rts that these levels
are attainable for the study sites to be addressed. 'therefore,
this risk level will be retained as the cleanup level for the
soil am ~imP-'1t in this qmable mri.t.
c. In the preanble to the revised NCP, U.S. EPA's approach to
gran:lwater ~iation is di ~. 'Ihe preamble states '''!be goal
of EPA's SUperfun:1 awroach is to return usable gro.m:l waters to
their beneficial uses within a timeframe that is reasonable given
the particular ci.rc::umstances of the site." 'Ihe gran:lwater at the
Refu;Je is a usable resource ani contr.ib.rt:es flow to a mri.que
envirannent. '!be RI Report iniicated that there was gran:lwater
contaminatioo associated with the PCB Areas qJerable mri.t, b.1t did
not r1nt-oI-J1t risks fran the gran:lwater. U.S. EPA believes that
the rem::JVal of sooroes of contamination will control arrj potential
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Q
G
""..,')
t."
gra.m:lwater problems. However, if m:mitoriIq activities duriIq an:i
after ~ir\tion :in:ii.cate that there is potential 'riSk fran the
gra.m:lwater, additional remediation activities will be considered.
s:m:e a remedy other than source control was not selected for
gra.m:lwater, the 10-6 exc€'SS cancer risk target level rtic:n1s~ in
the Proposed Plan and selected in this ROD will not neoec:C!arily be a
cleanup level, bIt will trigger a review of con:litions at the sites.
Lan;Jua.ge has been added to the Decision S\.1n1miny portion of the ROD
to clarify this. In addition to the excess cancer risk staroard to
trigger a review of the gra.m:lwater con:titions at the study sites,
there are staroards for non-cancer chronic health effects. 'Ihese
stan:iards have also been clarified in this ROD.
Specific camnents are addressed belCM:
(1) Grc:AJr'dwater is an enviroranental media that has been
iItpacted by the past disposal activities at the study sites
catprisiIq the PCB Areas operable unit. Because gra.m:lwater
is a valuable resau:ce, U.S. EPA's goal is to maintain the
beneficial uses of gra.m:lwater. In addition, the gra.m:lwater
at sane of the study sites c:iischarqes to crab Orchard rake and
potential c:iischarqe of contaminants to the rake is a con:::ern.
As rti =--ussed above, since the risk fran the sites should be
addressed by the rEmJVal. of contaminant saJrCeS, the staroards
specified in the ROD are not cleanup stan::Iards, but stan::Iards
to evaluate how effective source control has been. If the
stan:iards specified in the ROD are ~M, the gra.m:lwater
situation will be evaluated to detenn:ine if further remedial
action is ~=uy.
(2) As stated, the stan::Iards specified in this ROO for
gra.m:lwater are not cleanup stan:iards, bIt triggers for further
review am evaluation of gra.m:lwater con:litians. 'n1erefore,
the RI/FS did not analyze the iIrpacts of usiIq them as
cleanup stan::Iards for gra.m:lwater. Sargan¥:) Weston's con:::ern
~ ~ific levels that are belCM the method
detection limits for such ~ is one whid1 is easily
addressed in the remedial design~. ~ia1 design am
~ial action will require a workplan that specifies, ~
other thin;Is, the constituents to be DDnitored for gra.m:lwater
am the quality ~ required. 'Ihe risk as«;ooC!lN:O'1t is
most likely to i1'K::lu:3e constituents that have actually been
detected in a.cxx»:danoe with the at;:proved Quality ~
Project Plan.
(3) As rtic:n1S~ in paragra.IXt b(2) above, the risk asCJ'oosment
calculations for gra.m:lwater will reflect realistic and site-
specific exposure scenarios, in accordance with U.S. EPA
guidaooe.
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