United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-90/132
March 1990
Superfund
Record of Decision
Pristine, OH
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50273-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-90/132
9. Recipient1* Acceaalon No.
4. Tide end Subtl»«
SUPERFUND RECORD OF DECISION
Pristine, OH
First Remedial Action (Amendment)
5. Report Date
3/30/90
- Final
7. Author)*)
8. Performing Organization R«pt No.
». Performing Organization Harm ind Addre**
10. Profect/TaekWork Unit No.
11. Contract(C) or Grvtt(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Addrau
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type ol Report i Period Covered
800/000
IS. Supplementary Noiaa
18. Abalraet (Limit: 200 word*)
The 2-acre Pristine site is in Reading, Hamilton County, Ohio. The site is bordered by
industrial and residential areas, including a trailer park three hundred feet northeast
of the site. Eight municipal supply wells serving the citizens of Reading are located
approximately 300 feet northwest of the site. Prior to 1974, this site was used for the
manufacture of sulfuric acid. Subsequently, Pristine began liquid waste disposal
operations at the site, and in 1977, obtained a permit to operate an onsite liquid waste
incinerator. An onsite concrete lined pit (the magic pit) was used to store and treat
hazardous materials during liquid waste disposal operations. In 1979, State
investigations identified as many as 8,000 to 10,000 drums and several thousand gallons
of liquid wastes onsite. Types of waste included acids, solvents, pesticides, and PCBs.
Over 90 hazardous compounds were detected onsite in the soil, ground water, surface
water, sediment, and debris as a result of past disposal activities. In 1981, the State
ordered all onsite disposal operations to cease. From 1980 to 1983, EPA and Pristine
removed onsite wastes including paint and solvent sludge, solvents, pesticides,
organics, PCB-contaminated soil, and incinerator ash. During 1984, the PRPs removed
contaminated soiT and waste as a means to address the immediate site hazards. A 1987
(See Attached Page)
17. Document Anelysi* a. Descriptor*
Record of Decision - Pristine, OH
First Remedial Action (Amendment) - Final
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (benzene, PCE, TCE, xylenes), other organics (dioxin,
pesticides), metals (arsenic, chromium, lead), other inorganics
b. MenMera/Open-Ended T<
c. COSATI Reid/Group
It. Aveflabllty Statement
1*. Security CUa* (Thl* Report)
None
20. Security da** (Thi* Page)
None
21. No. of Peg**
24
22. Price
(See ANSI-n8.1l)
See InttrucHcra on
UfllUNAL FUHM ZfZ (*-f r)
(Formerly NT1S-15)
Department of Commerce
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EPA/ROD/R05-90/132
Pristine, OH
First Remedial Action (Amendment) - Final
Abstract (Continued)
Record of Decision (ROD) documents the selection of in-situ vitrification of the upper 12
feet of soil across the site. This ROD amends the soil component remedy of the 1987 ROD
from in-situ vitrification to incineration and soil vapor extraction. The primary
contaminants of concern affecting the soil, sediment, dabris, and ground water are VOCs
including benzene, PCE, TCE, and xylenes; other organics including dioxin and pesticides
such as DDT; metals including lead, chromium, and arsenic; and other inorganics.
The selected amended remedial action for this site includes excavating and incinerating
the top one foot of contaminated soil from across the site (a total of 3,598 cubic yards)
and 1,799 cubic yards of contaminated soil to a depth of four feet in areas that contain
semi-volatile organic compounds and pesticides in excess of performance goals;
incinerating 600 cubic yards of contaminated sediment and 1,125 cubic yards of
contaminated soil surrounding the magic pit; testing the residual ash and placing the ash
onsite if it meets standards for delisting; performing in-situ soil vapor extraction with
an off-gas control system to extract VOCs from onsite soil to a depth of 12 feet;
dewatering the upper aquifer, and onsite treatment of the extracted ground water using
carbon adsorption; capping the soil with a RCRA multi-layer cap; pumping and treatment of
ground water from the lower and upper aquifer and lower outwash lens of the upper aquifer
using air stripping and carbon adsorption; decontaminating and demolishing all onsite
structures and disposing of the debris offsite; monitoring ground water; and implementing
institutional controls including deed restrictions, and site access restrictions such as
fencing. The estimated present worth cost for this remedial action is $13,500,000, which
includes an OSM cost of $6,000,000.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific goals for soil/sediment were based on
a cumulative 10~6 incremental lifetime cancer risk of eleven indicator compounds
including aldrin 15 ug/kg, benzene 116 ug/kg, chloroform 2,043 mg/kg, DDT 487 ug/kg,
1,2-DCA 19 ug/kg, 1,1-DCE 285 ug/kg, dieldrin 6 ug/kg, PAHs 14 ug/kg, dioxin 0 ug/kg, PCE
3,244 ug/kg, and TCE 175 ug/kg.
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DECLARATION FOR THE RECORD OF DECISION AMENDMENT
Site Name and Location
Pristine, Inc.
Reading, Ohio
Statement of Basis and Purpose
This decision document presents the new soil component of the
Pristine, Inc. remedial action in Reading, Ohio. The Record of
Decision (ROD) is being amended for the soil component in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision document explains the factual and
legal basis for amending the soil component for the Pristine,
Inc. site. The remaining components of the remedy are identical
to the ROD executed on December 31, 1987.
The Ohio Environmental Protection Agency concurs with amending
the Pristine, Inc. ROD.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions
selected in this Record of Decision (ROD) Amendment, may present
an imminent and substantial threat to public health, welfare, or
the environment.
Description of the Revised Remedy
The overall remedy components are now as follows:
1. On-site incineration of the top one foot of soil across
the site and all other soils from the present ground
surface to four feet below ground surface that contain
semi-volatile organic compounds and pesticides in
excess of Performance Goals and Standards. In
addition, on-site incineration of sediments and, if
necessary, soils surrounding the Magic Pit will occur.
The Magic Pit is a concrete lined pit which was used to
store and treat hazardous materials on-site.
Incinerator residue will be placed back on the"site
under the RCRA multi-media cap if it meets substantive
RCRA delisting criteria;
2. In-situ soil vapor extraction of on-site soils to a
depth of approximately 12 feet. The in-situ soil vapor
extraction system will be used to dewater the upper
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aquifer. The extracted groundwater will be treated at
the site using carbon adsorption;
3. Performance of an additional groundwater investigation
to delineate fully the lower aquifer contamination
associated with the Pristine site in order to design
and construct an extraction and treatment system. The
conceptual design, based on current information, calls
for the installation of a groundwater extraction well
to withdraw contaminated groundwater from the lower
aquifer and lower outwash lens of the upper aquifer;
4. Construction and operation of an air stripping system
to treat lower aquifer groundwater and a carbon
adsorption system to treat upper aquifer groundwater;
5. Decontamination and demolition of all on-site
structures and disposal of the debris in a sanitary
landfill;
6. Construction of a fence along the western edge of the
property to restrict access;
7. Deed restriction; and
8. Installation of a groundwater monitoring system on and
near the site to monitor groundwater flow and quality.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technologies to
the maximum extent practicable for this site. Treatment of the
principal threats of the site are achieved and the remedy
satisfies the statutory preference for treatment as a principal
element.
A review will be conducted within five years after commencement
of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment. A five
year review is necessary because this remedy will result in
hazardous substances remaining on-site above health based levels.
Valdas V. AdanOcus fi Datfe
Regional Administrator
U.S. EPA, Region V
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Decision Summary for the Record of Decision Amendment
1. Site Background
In November 1987, U.S. EPA notified over 130 Potentially
Responsible Parties (PRPs) of their liability at Pristine,
Inc. and invited them to negotiate with U.S. EPA for the
design and construction of the final remedy. A 120-day
negotiation period was established and ended March 29, 1988
without an agreement. The remedial design was begun with
the initiation of an Interagency Agreement with the U.S.
Army Corps of Engineers (U.S.A.C.O.E.).
On March 31, 1988, the PRPs proposed the use of in-situ soil
vapor extraction technology instead of in-situ
vitrification, claiming that in-situ soil vapor extraction
would be equivalent to the performance of in-situ
vitrification. The U.S. EPA and the U.S.A.C.O.E. evaluated
the PRPs' proposal and determined that while in-situ soil
vapor extraction would address the volatile organic
compounds, it would not, however, mitigate the threats from
semi-volatile organic compounds and pesticide contamination
in the surface soils.
Upon incorporation of incineration as a means of addressing
the non-volatile contaminants and pesticides, negotiations
were reopened with the Pristine PRPs and an agreement was
reached between U.S. EPA and the Pristine PRPs in December
1988, contingent upon U.S. EPA amending the December 1987
ROD by replacing in-situ vitrification with
incineration/soil vapor extraction as the soil component of
the remedy.
2. Highlights of Community Participation
The Proposed ROD Amendment and technical review documents
have been made available to the public in the administrative
record located at the Valley Public Library, Reading, Ohio
and the Reading City Hall. The notice of availability of
these documents was published in the Cincinnati and Reading
newspapers. A public comment period on the documents was
held from November 6, 1989 to December 6, 1989. In
addition, a public meeting was held on November 30, 1989.
At this meeting, representatives from U.S. EPA answered
questions about problems at the site and the ROD Amendment
under consideration. A response to the comments received
during this period is included in the Responsiveness Summary
which is part of this ROD Amendment.
3. Description of Soil Remedy Chance
The soil component of the December 1987 ROD consisted of
in-situ vitrification for the upper twelve (12) feet of soil
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across the site. The in-situ vitrification will be replaced
with incineration/soil vapor extraction. See Figure 1 and
Figure 2 for a layout of the Pristine, Inc. Site and a Zone
location map. The following are the major components for
the soil component of the remedy:
1. Excavation and incineration (mobile on-site thermal
treatment) of:
a) the top one (1) foot of soil across Zone A (the
volume to be incinerated will be determined by a
boundary survey);
b) sediment from the drainage ditches along the
northwest boundary of Zone A and along the
northern boundary of Cincinnati Drum Service
(existing data and additional sampling will be
used to delineate the volume of sediment to be
treated);
c) all Zone A soils that contain non-volatile
contaminants above the Performance Goals and
Standards outlined in Table 1 from a level of one
(1) foot below present grade to a level of four
(4) feet below present grade;
d) all Zone B soils that contain non-volatile
contaminants above Performance Goals and Standards
in Table 1 from present grade to a level of four
(4) feet; and
e) Magic Pit (located in Zone B) soils that contain
non-volatile contaminants above Performance Goals
and Standards in Table 1 to a level of four (4)
feet below and to a level of four (4) feet onto
the three unexposed side walls of the Magic Pit
itself.
2. The incinerator ash will be tested to determine if the
ash meets del1sting criteria established under RCRA and
Ohio Solid Waste Regulations. If the delisting
criteria are met, the ash will be disposed of as a
solid waste on Zone A under the RCRA multi-media cap.
Alternative treatment/disposal methods will be
required if portions of the ash do not meet delisting
criteria; and
3. Design, construction, operation and maintenance of an
in-situ soil vapor extraction (ISVE) system, which
shall include an off-gas control system, to mitigate
VOC contamination in Zone A and Magic Pit portion of
Zone B soils. As a result of ISVE, the upper twelve
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Drainage
Ditch
o
m
Conrail
Pristine Site Layout Map
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Cincinnati Drum
Service, Inc.
Municipal
Fly-Aoh
Dlipocoi
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(12) feet of Zone A and the Magic Pit portion of Zone B
will be dewatered, including the upper outvash lens.
Groundwater extracted from the ISVE trenches and well
points will be treated in the Facility treatment plant
using carbon-adsorption. A multi-layer cap shall be
installed over Zone A to minimize water infiltration
to the Zone A soils and shall meet the RCRA performance
criteria for the duration of the post closure period of
30 years. The RCRA cap will also prevent short
circuiting of air to the portion of the ISVE system to
be constructed, operated and maintained in Zone A.
4. Performance Goals and Standards
The Performance Goals and Standards that the soil/sediment
cleanup must meet are presented in Table 1. The
soil/sediment Performance Goals and Standards are based on a
cumulative 1 X 10~6 incremental lifetime cancer risk of
eleven indicator compounds examined in the RI Public Health
Evaluation.
5. Evaluation of the New Soil Remedy and the Previously
Selected Soil Remedy
The nine evaluation criteria U.S. EPA considers when
selecting a remedy and a comparative analysis between the
previously selected soil component and the new soil remedy
are listed below:
o Overall Protection of Human Health and the
Environment - Both the new recommended soil remedy
and the previously selected soil remedy provide
adequate protection of human health and the
environment by mitigating and minimizing risk
through treatment and institutional controls.
Each remedy uses treatment to the maximum extent
practicable.
o Compliance with ARARs - Both the new recommended
soil remedy and the previously selected soil
remedy would meet all applicable or relevant and
appropriate requirements of Federal and State
environmental laws.
o Long-term Effectiveness and Permanence - The new
recommended soil remedy and the previously
selected soil remedy would treat the contaminated
soil to levels which protect identified receptors.
The treatment technologies employed would be
effective in the long-term and permanent because
the contaminants of concern would be removed from
the soil and destroyed, or trapped in a solidified
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TABLE I
PERFORMANCE GOALS AND STANDARDS
SOIL AND SEDIMENT
A. Volatile Compounds
Chemical Concentration (ug/kg)
Benzene 116
Chloroform 2,043
1,2-Oichloroethane 19
1,2-Dichloroethene 285
Tetrachloroethene 3,244
Trichloroethene 175
B. Non-volatile Compounds
Chemical Concentration (ug/kg)
Aldrln 15
DOT x 487
Dieldrin 6
PAHs 14
2,3,7,8-TCDO (Dloxin) 0
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mass. Both remedies require the same degree of
long-term maintenance and monitoring as both have
cap or soil cover maintenance requirements.
Reduction of Toxicity. Mobility, or Volume - Both
the new recommended and previously selected soil
remedies provide a significant reduction in the
toxicity, mobility, or volume of soil contaminants
through the use of permanent treatment
technologies.
Short-term Effectiveness - Both the new soil
remedy and the previously selected soil remedy
present some degree of short term risks to on-site
workers and potentially to businesses and
residences near the site through potential air
emissions. The air emissions from the in-situ
soil vapor extraction/incineration technology
combination are easily controlled and monitored.
Air emissions will be funnelled to a pipe or
stack, where they would be controlled and
monitored. The air emissions from in-situ
vitrification technology are more difficult to
control because they are emitted from a large
surface area, as opposed to a stack. The new soil
remedy will take approximately seven years to
complete while the previously selected soil remedy
would take three years to complete.
Impleroentability - The new recommended soil remedy
component offers several advantages over the
previously selected soil remedy component in terms
of implementability. Incineration and in-situ
soil vapor extraction are proven technologies and
are easily implemented. Administrative approvals
are necessary as the trial burn, incineration
residue testing, and residue disposal program must
be approved by the U.S. EPA and the State. With
the exception of the mobile on-site incinerator,
all services and materials are readily available.
The recommended change in the soil remedy does not
cause any additional long-term maintenance or
monitoring requirements. On the other hand, the
in-situ vitrification technology is not proven or
fully tested. As stated in the December 1987 ROD,
U.S. EPA planned to use in-situ vitrification at
another site in Ohio prior to implementing the
technology at the Pristine site. This however has
not occurred. Therefore, a full scale field test
would need to be conducted before implementation
of in-situ vitrification at Pristine. In
addition, because in-situ vitrification is still
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an emerging technology, the number of firms
offering the necessary services to design and
implement it is limited.
Cost - The total cost for design and construction
of the new recommended soil remedy and the
previously selected soil remedy are listed below:
New Soil Remedy $11,270,000
Previously Selected Soil Remedy $19,417,000
A cost comparison between in-situ vitrification
and incineration/soil vapor extraction is located
in Table 2.
State Acceptance - The State of Ohio concurs with
the new soil remedy.
Community Acceptance - The specific responses to
public comments are located in the Responsiveness
Summary.
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PRISTINE SOIL REMEDY COST COMPARISON
In-situ Vitrification3
In-situ Soil Vapor Extraction
Incineration
Excavation 19,000
Vitrification 10,600,000
Excavation3 33,000
Vapor Extraction13 3,000,000
Incineration0 2,433,000
RCRA Capa 447,000
Soil Sampling6 250,000
CONSTRUCTION $10,619,000
SUBTOTALS
Health & Safety 1,062,000
Contin. 10%
Bid Contin. 20% 2,124,000
Scope 2,124,000
Contin. 20%
Construction $15,929,000
Total
Legal 5% 796,000
Construction 1,593,000
Services 10%
Total $18,318,000
Implementation
Costs
Engineering 1,099,000
Design 6%
TOTAL COST<1 $19,417,000
$6,163,000
616,000
1,233,000
1,233,000
$9,245,000
462,000
925,000
$10,632,000
638,000
$11,270,000
aBased on Pristine Feasibility Study costs
^U.S. EPA conservative estimate based on other sites
C3,600 yd3 top 1 ft of site + 1,125 yd3 Magic Pit * 1,000 yd3 sediments
5,725 yd3 at $425/yd3, per FS ash delisted and placed back on-site
not include O&M present worth
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PRISTINE, INC. SUPERFUWu SATE
READING, OHIO
RESPONSIVENESS SUMMARY
Summary of Comments Received Purina the Public Comment Period
1. Comment: Riley Kimnan, Pristine, Inc.
The No Action Alternative is the only appropriate response
for the cleaned Pristine, Inc. site under CERCLA.
U.S. EPA Response: The No Action Alternative is not
appropriate for the Pristine site. Risk levels remaining at
the site are above levels the U.S. EPA deems acceptable to
protect human health and the environment. Please see the
Pristine, Inc. public health evaluation and the previous ROD
Responsiveness Summary.
2. Comment: Riley Kinman, Pristine, Inc.
The comments provided on Dec. 3, 1987 are attached and are
still valid and are hereby made a part of this comment
document.
U.S. EPA Response: Since this ROD Amendment is an addendum
to the original ROD, your previous comments and U.S. EPA
responses are still part of the public record for the site.
3. Comment: Riley Kinman, Pristine, Inc.
We were pleased to see the U.S. EPA agreed with us, finally,
on the in-situ vitrification proposal.
U.S. EPA Response: U.S. EPA's decision to modify the soil
component of the remedy was based upon an evaluation of the
same criteria utilized in the original ROD. While the
Agency believes that the original remedy provides a good
balance among those criteria, the hew soil component
provides an even better balance of the nine criteria.
4. Comment: Riley Kinman, Pristine, Inc.
Incineration of Pristine soils may produce a large quantity
of sulfur dioxide (SO2) at the site if the elemental sulfur
in the soil is caused to burn.
U.S. EPA Response: The emissions from incineration of soils
at the Pristine site will meet all National Ambient Air
Quality Standards for sulfur dioxide. U.S. EPA has
determined that these standards are protective of human
health and the environment.
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5. Comment: Riley Kinman, Pristine, Inc.
SC>2 production at the site by this procedure would be in
violation of the Clean Air Act and Comprehensive
Environmental Response, Compensation and Liability Act of
1980.
U.S. EPA Response: Please see U.S. EPA response for Comment
4.
6. Comment: Riley Kinman, Pristine, Inc.
Demolition of buildings at the Pristine site and disposal in
a sanitary landfill does not appear consistent with the U.S.
EPA strategy for recycling and reuse to minimize disposal in
scarce sanitary landfills.
U.S. EPA Response: While the Agency is committed to the
broadest possible application of the concept of recycling,
we are limited by the space available at this site. The
successful implementation of this remedy is dependent upon
removal of all surface soils for incineration and the
necessity of having an impermeable cap to prevent short
circuiting during the vapor extraction phase. These needs
combined with the need for a staging area and water
treatment plant location preclude the relocation of the
demolition material on-site.
7. Comment: Riley Kinman, Pristine, Inc.
Deed restrictions do not appear appropriate for the Pristine
site.
U.S. EPA Response: Deed restrictions are necessary since
hazardous materials will remain on-site under a RCRA cap.
Deed restrictions will prohibit any activities that would
affect adversely the integrity of the cap. The cap must not
be disturbed to prevent the migration of the remaining on-
sita contaminants.
8. Comment: Riley Kinman, Pristine, Inc.
It is doubtful that the remedies proposed will do anything
substantive to improve the quality of groundwater at the
site, due to the presence of other sources of pollutants at
the site that will not be addressed by these remedies.
U.S. Response: The Agency is aware of Pristine/s.setting
within a regional groundwater problem. However, from the
Remedial Investigation, it is also obvious that the site is
introducing its own contaminant loading to the aquifer.
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Thus, remedial action at the Pristine site is necessary to
eliminate contaminants attributable to the Pristine site
from the regional groundwater problem. Also, should the
need arise, the Agency retains the authority to respond to
any emergency conditions, including groundwater
contamination, identified in the region.
9. Comment: The Pristine Group
The Pristine Group strongly supports the Agency's decision
to select in-situ soil vapor extraction/incineration as the
remedy for the Pristine, Inc. facility rather than the
experimental in-situ vitrification remedy that was
originally proposed. The vapor extraction/incineration
remedy is not only entirely consistent with the requirements
of CERCLA, but is also more protective of the environment
because of in-situ vitrification's propensity to cause
migration of chemicals away from the site.
U.S. EPA Response: The U.S EPA agrees that the
incineration/soil vapor extraction remedy will achieve the
same cleanup standards and provide a better balance of the
nine criteria that U.S. EPA uses in selecting a remedy.
However, the statement that in-situ vitrification promotes
chemical migration of chemicals has not been proved one way
or the other. The U.S. EPA considers the original soil
component and the new soil component equally protective of
human health and the environment.
10. Comment: The Pristine Group
Many of the inorganic compounds and metals detected in
groundwater samples from lower aquifer wells occur naturally
(e.g., calcium, iron, magnesium, manganese, potassium,
sodium). The statement that "their presence in the
groundwater indicates groundwater quality has been
compromised" is not correct to the extent it implies that
these substances originated from the Pristine Site.
U.S. EPA Response: Due to the diverse amount of waste taken
to the Pristine, Inc. facility, the possibility exists that
calcium, iron, magnesium, manganese, potassium and sodium
were present in waste delivered and are breakdown products.
The commentor is correct that many of the above listed
compounds occur naturally and additional sampling during the
design phase will verify if they are naturally occurring.
11. Comment: The Pristine Group
The ESD states that the Pristine incinerator ash "contained
furans and dioxins." As a point of clarification, it should
be pointed out that the 2,3,7,8-TCOD congener, which is
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considered to be the most toxic of the dioxin and /'..ran
compounds, was not detected in the incinerator residue or
soil samples collected during the RI (with the exception of
one soil sample where the compound was also detected in the
laboratory blank sample, indicating laboratory
contamination of the sample). Further, since dioxins
exhibit a high affinity toward soil and tend to remain on or
near the surface of the soil (see Health Assessment Document
for Polychlorinated Dibenzo-p-Dioxins," EPA/600/8-84/014F,
September 1985) , and since such compounds have a low
solubility in water, it is unlikely that the groundwater
would become contaminated with dioxins. No dioxin has been
detected in any prior groundwater sample at the Pristine
Site.
U.S. EPA Response: The dioxins and furans mentioned refer
to total dioxins and furans and not just 2,3,7,8 TCDD
congener. In addition, the commentor is correct that dioxin
was not detected in sampling performed in the Remedial
Investigation, but the statement "it is unlikely that
groundwater would become contaminated with dioxins" is based
upon conjecture. Additional sampling and analysis during
Remedial Design will verify the presence or absence of
dioxin.
12. Comment: The Pristine Group
The EPA states that "in-situ soil vapor extraction would
work as well as in-situ vitrification for VOCs." In fact,
the soil vapor extraction technology is the better
technology because, unlike in-situ vitrification, it does
not provide a driving force for the uncontrolled migration
of organic compounds. In this regard, the gradual heating
of the soil zone with in-situ vitrification forces the
volatile compounds to migrate away, particularly through the
more permeable soil zones. (See Battelle Pacific Northwest
Laboratory Report: "In-situ Vitrification of Transuranic
Wastes: An Updated Systems Evaluation and Applications
Assessment,11 March 1987.)
•
U.S. EPA Response: The U.S. EPA disagrees with the commentor
that in-situ vitrification is not as effective as in-situ
soil vapor extraction for treating volatile organic
compounds. In-situ vitrification treats volatiles, semi-
volatiles, and pesticides, in contrast to in-situ soil vapor
extraction, which only treats volatile organic compounds.
Please see U.S EPA response to Comment 9.
13. Comment: The Pristine Group
Figures 3 and 4 are conceptual only and should be described
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as such.
U.S. EPA Response: Figures 3 and 4 are included in the ROD
Amendment to give the public a general picture on how the
soil vapor extraction system operates. The Figures are not
intended to be design documents.
14. Comment: The Pristine Group
The statement, "The new recommended site remedy would take
approximately seven years to complete while the previously
selected soil remedy would take approximately 3 years to
complete", is misleading. Overall, both remedies would take
the same length of time to complete because the lower
groundwater extraction/treatment system would be the same
for both.
Furthermore, the in-situ vitrification component has a
longer lead time for implementation than the vapor
extraction component. As originally planned, the in-situ
vitrification component was to have been tested at another
site (Greiner's Lagoon) before implementation at the
Pristine Site. However, as acknowledged in the ESD (pg 10),
that test has not been conducted. Thus, since EPA maintains
that the vitrification component must be subject to at least
a "full scale test" before being considered for use at
Pristine, the time required for completing the vitrification
component at Pristine is uncertain —and in fact is probably
much longer than that required for the soil vapor extraction
methodology. At the very least, it cannot be concluded that
the vitrification component could be completed sooner than
the \vapor extraction component.
U.S. EPA Response: The commentor is correct in stating the
overall Pristine, Inc. timeframe from the original ROD-to
the new site remedy is identical, since the groundwater pump
and treat has not changed. Nevertheless, on a day to day
implementation basis, the in-situ vitrification component
should require as much as 4 years less to complete than the
incineration/soil vapor extraction combination. Also, a
full scale test for in-situ vitrification at Parsons
Chemical in Michigan is near implementation.
15. Comment: J.A. Bischof, Millcreek Valley Conservancy District
On behalf of the Millcreek Valley Conservancy District we
would urge your office in carrying out any corrective action
at this site to eliminate the flow of any contaminated water
into the east branch of the Mill Creek since that drainage
may endanger the completed project and those maintaining
that facility.
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U.S. EPA Response: The remedy for the Pristine, Inc. site
will not discharge contaminants into Mill Creek. All
effluent discharged into Mill Creek from the soil vapor
extraction and groundwater pump and treat systems will meet
Federal and State discharge requirements.
16. Comment: Concerned Citizen
"The City has been informed about ineffective water wells
since 1943. It appears someone has their priorities
reversed. The article I read concerning the procrastination
of the city to do anything alarms me. Their cavalier
attitude toward the public's well being and the agencies not
pursuing the issue, to resolve a problem that defines Super
Fund imminent danger, appears contrary to the approach they
have taken toward this PRP group - 18,000,000.00?"
"The wells have been surrounded by heavy industry for years.
The thought of these so-called toxins migrating since the
government took over the site and nothing being done amazes
me! Is there a problem? Are the facts correct or
overstated regarding contaminants found on the site close to
the wells. Your studies indicate a potential problem but
not imminent. The water wells are imminent11.
"Your desire to clean up the site is admirable, but myopic.
The real public danger is with the agencies's penchant, to
penalize and deceive the public, instead of working together
to encourage waste solutions. The citizens of Reading have
been deceived for years. Did they shut down Exxon or Union
Carbide for their atrocities,, or did our constitutional
currency interfere?"
"What did this small corporation do to create an expense of
18 million dollars? I cannot wait to read your response
when it is published."
U.S. EPA Response: Absent future corrective actions, the
Pristine, Inc. site does pose an imminent and substantial
endangerment to the public health and the environment. If
the site remains as is, contaminants will continue to
migrate from the site and further affect the lower aquifer
which is a source of drinking water. Risk levels calculated
for the site in its current state are above those U.S. EPA
deems acceptable to protect human health and the
environment.
Currently, the City of Reading's water supply is in
compliance with the State and Federal standards and is
subject to routine monitoring. U.S. EPA is aware that
Pristine is part of the regional groundwater problem.
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17. Comment: Pan Speers, Reading Ohio
"The question on many peoples mind concerning the
environment deals mainly with the tax payers money use in so
called "clean-up". Cleaning up the environment is good, but
to continue to push stupid issues just to soak the people
of America for money is ludicrous. How does the public
even know if superfund money was used to clean-up the site
in Reading."
"According to the article and newspaper in the library,
superfund money was designed, but I believe a released
itemized statement showing the breakdown of monies issued
would be more appropriate. I believe the only superfund
money spent in Reading, Ohio was the issue of salaries to
the absent minded EPA people working on a dead issue. My
God people, the site has been cleaned up for years. What
else can we do? How much money is being pocketed by the
"EPA Group"? Are you on commission? You people just want
to kick a sleeping dog. There is no just reason for more
law suits and penalties against these people. Maybe the EPA
should take a long look at their reasons for continuing the
harassment. Is it personal?, Public? , What then? Making
examples of small business versus the wonderful government
site of Fernold, plus Exxon, Chemdyne, and Union Carbide
Corporation is hardly what the tax payers of America want.
Examples are not worth tax money. It can be used for more
responsible tasks. Get busy with "Imminent Danger" sites
and stop bleeding the people of Reading, Ohio and America."
U.S. EPA Response: Absent future corrective actions, the
Pristine, Inc. site does pose an imminent and substantial
endangerment to public health and the environment. The
responsible parties are voluntarily funding the cleanup at
the Pristine, Inc. site, so the use of Superfund monies is
not needed. In addition, monies already spent by U.S. EPA
are being reimbursed by the responsible parties. Both
considerations allow U.S. EPA to focus its limited resources
on those sites where voluntary private party actions are
impossible.
18. Comment: Concerned Citizens of Reading, Ohio
"After reviewing the Material at the Reading Library, it
appears the USEPA has forced the PRP Group into a settlement
that is not only costly but greatly overstated, regarding
the method and amounts of contamination. The cleanup
started back in 1980, and it is now 1989, Evidently this
site has been on a priority list that the federal USEPA
uses to determine the most dangerous sites. This list
consist of firms that have put the public in imminent danger
or risk of being harmed. If the site has been in the hands
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8
of the USEPA and State for nine years, (that is longer than
the Pristine site existed), then wouldn't the USEPA be
responsible for some of the cost regarding this supposedly
"imminent dangerous" site? Is this site or should this
site even be on this priority list? According to some of
the information in the Remedial Investigation and
Feasibility Study, the site should not cost the public
$18,000,000.00 through higher prices. If the site is a
priority superfund site, you would think that the people who
have been in charge for the past nine years. At least the
owners or someone did more in one and one half years than
the USEPA has done. Who is guilty? Is this superfund
deception drawn out unreasonably to make the Agency look
good for cleaning up a site, that, according to studies and
affidavits submitted is clean."
"Does the USEPA know something that they don't want to admit
for their own selfish benefit? Is the site clean? You must
justify and substantiate the decision, forcing corporations
to pay for a site where there are various differences and
feelings regarding the studies and what should be done to
this site. These decisions greatly reflect the
constitutional freedoms of every citizen in the United
States."
"It is ironic but the publics only harm may come from its
own government and agencies. This is a problem that is
paramount, it has and will continue to have a huge adverse
effect on our economy an desire to provoke interest in the
future to eradicate environmental problems. The government
should take a different approach if there is any difference
on the method and monies needed to eliminate this problem.
Your reward would be greater felt by all if you took a more
logical approach."
"In summary, why does the government sponsored studies
indicate that $18,000,000.00 should be spent for a site that
is rated 531 out of 734, and the 12 rated site is only going
to cost $20,000,000.00? Cleanup has already taken place and
studies show that the site is clean and safe. Your efforts
are fine, but to spend $18,000,000.00 for a site, according
to your studies is clean is ludicrous."
"Thank you for reading this, concerned citizens deserve a
response. We are concerned and want corporations to pursue,
in a prudent and legal manner on ideas and methods to handle
hazardous waste safely. Pristine attempted and appears
their insight to handle future environmental problems (which
are numerous) was truncated by an unfair, nearsighted
agency."
U.S. EPA Response: The U.S. EPA does not agree with your
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statement that the Pristine, Inc. site is clean. Acceptable
risk levels of 1 additional cancer case in a million are
exceeded in both soil and groundwater at the Pristine, inc.
site by as much as 10,000 times in a worst case scenario.
The funds to be spent to cleanup the site and past costs of
U.S. EPA will be paid by the responsible parties. The
Agency shares your concern about having only legally
reputable and competent companies in the waste disposal
industry.
The ranking of the Pristine, Inc. site on the National
Priorities List does not have a bearing on the cost of the
remedy since the nature and extent of contamination was not
determined prior to scoring the site.
20. Comment: Coalition of Reading
"After reviewing some of the articles that have been written
since the Pristine, Inc. case, we have discovered an article
that seems to depict a double standard with the USEPA, Ohio
EPA on how they handle private corporations versus city or
municipal problems. The article written in the Cincinnati
Enquirer (May 5, 1989) indicated that environmental
officials, dating back to 1943, have been trying to persuade
the city of Reading to upgrade their water system. EPA
official more recent, in the same article, indicated that
the water wells are surrounded by industrial plants. The
levels of contamination exceeds the Federal standards but
the state according to the article will not take any legal
action as long as the city is earnestly pursuing an
alternative, ignoring the ongoing and very imminent water
treatment problems. The proof is obvious, but the state is
giving them a chance even though the proof is there and has
been for years. The state knowing the treatment facility is
antiquated and not doing the job, is sad commentary from
officials who have shown some disregard to the public
health, which seems more threatened by this than the so
called migration of contaminants from a nearby site that,
according to studies, have not been proven."
"The toxins that have been identified in the lower aquifer,
originate from what direction, and do they match the toxins
found at the Pristine site? It appears, according to
studies and articles at the library, that the so called
phantom imminent danger and abandoned site criteria have
been ignored. The real issues to the citizens of reading
should be the water wells themselves and their location.
This problem is real and not based on potential and is an
imminent danger to the public health, which is what
superfund is all about."
"What an enormous amount of money and effort wasted while
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10
the real danger of having inadequate water wells still
exist. Maybe we should alert the toxins that they are
migrating from somewhere to wait until we take care of some
of the paper work. Is there a real problem? What do these
R.I. and Feasibility studies really show? The citizens will
pay again through higher cost because the government is
playing games. Any discrepancies or question marks
regarding data should be answered and justified. This site
should not cost the public and citizens of the United States
$18,000,000.00 so an agency who so far has only cleaned up
27 sites out of 1200 promote their unnecessary quest. Start
now and do something that the citizens will be proud of and
won't have to pay for."
U.S. EPA Response: To the best of the U.S. EPA's knowledge,
the water being consumed by the users of the Reading public
water supply is safe even if individual production wells are
contaminated. Should this not be the case and no
alternative exists, the U.S. EPA has the authority and
responsibility to assure that the situation is remedied.
The Superfund law was enacted with a goal of total cost
reimbursement and/or private party cleanup implementation
for each site. At the Pristine site all of the government's
past costs and the complete burden of the remedy's
implementation is being taken up by the responsible parties.
Comment: William A. Bronnin, Reading, Ohio
"How could the EPA ever ok a site like this for chemical
waste. It is located next to a creek and one hundred yards
from a residential suburb. I personally think the EPA
should be held accountable for the damage and buy all the
property around this area. The people that live in or near
the area have a higher cancer rate anywhere else in the
world."
"How could the EPA have 19.4 million dollars ok'd for
cleanup over two years ago, and not do this cleanup. What
are you waiting for."
"The second method is no good because you waited to long.
The chemicals are much deeper than 12 feet underground."
"I have lived by this waste site for 28 years. My neighbors
children tell stories of seeing the workers burying drums
under ground 15 or 20 years ago."
"The people in this area think it is hopeless to talk to
government officials. They feel and I do too, that the EPA
doesn't care about people. They just want to harass and
collect more money from tax payers."
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11
"If the EPA is not going to clean-up this mess, which was
their fault to begin with, I know they will never cleanup
the metro sewer system which has been obsolete for 25
years."
U.S. EPA Response: The Pristine, Inc. facility was a
private corporation that was poorly operated. The remedial
investigation determined the nature and extent of
contamination with the data showing that the surface
contamination has not migrated away from the site, but
groundwater has been affected by the Pristine contamination.
The responsible parties have agreed to finance the cleanup
of the site to levels which are protective of human health
and the environment. The property surrounding the Pristine,
Inc. site is not contaminated, therefore it is not required
that properties be purchased. Once the cleanup is
completed, the potential for migration of contamination
offsite will be eliminated.
The U.S. EPA was going to fund the original remedy and try
to recover costs at a later date from the responsible
parties, but the responsible parties submitted a proposal to
cleanup and finance the site remedy if U.S. EPA changed the
soil component of the Pristine ROD. The U.S. EPA, U.S. Army
Corp of Engineers and the State of Ohio reviewed the
responsible parties' proposal and determined that the
necessary cleanup standards would be met with the new remedy
for the contaminated soil. The design for the site remedy
should begin in a few months.
Your concern that chemicals have migrated more than 12 feet
below the surface will be verified in the design phase when
we will perform additional sampling. Sampling performed
during the Remedial Investigation was the source of the 12
feet. In addition, during the Remedial Investigation,
extensive underground testing for buried metal such as drums
was performed and it was determined that buried materials
were not present at or near the site.
The Agency encourages public participation and will
periodically issue fact sheets to keep the public updated on
the progress of the cleanup at the Pristine, Inc. site. The
Agency plans to oversee an effective cleanup at the
Pristine, Inc. site that is protective of human health and
the environment.
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4 7/27/88
50 8/5/88
3 8/15/88
2 8/22/88
2 8/24/88
16 12/6/89
6 12/6/89
30*
90*
PRISTINE,
ONIS'E
MARCH 1387
-AJ SITE
OTOKIE
Pages Date Title
100* 3/29/88
Petition for EPA
to Consider New
Info & Reconsider
ROD
Follow-up to
7/20/88 technical
meeting
Evaluation of
SVE at Pristine
Pristine
Group PRPs
Recipient
J.Dofficy
USEPA
Dave Ross J.Dufficy
Pristine Group USEPA
ACOE - EA USEPA
Engineering,
Science &
Technology, Inc.
Proposed Remedy Dave Ross T. Conway
Offer Pristine Group USEPA
Conditions for Dave Ross F. Covington
Reopening Pristine Pristine Group USEPA
Remedy Negotiations
Response to 8/22/88 Dave Ross F. Ccvington
letter accepting Pristine Group USEPA
negotiation
conditions
Doc Type
Report
Letter
Report
Letter
Letter
Letter
Explanation of
Significant
Differences
Fact Sheet for
ROD AffwujbnHnt'i
& Consent Decree
Newspaper
Advertisement
Public Meeting
Transcript
Consent Decree &
Remedial Action
T.Alcamo
USEPA
USEPA
USEPA
USEPA
united States
Pristine PRPs
Public
Public
Reading
File
District
Court
Plan
Fact
Sheet '
News Ad
Transcript
Decree
Plan & Attachments
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