United States
Environments) Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROOROS-90/139
September 1990
SEPA
Superfund
Record of Decision
St. Louis River, MN
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50272-101
REPORT DOCUMENTATION 11. AEPOATNO. I L
PAGE EPA/ROD/R05-90/139
S. A8cIpI8nI'. Ac-.Ion No.
4. TlII8 8ftd SubtIU8
SUPERFUND RECORD OF DECISION
St. Louis River, MN
First Remedial Action
7. AulMt(.)
L A8part D...
09/28/90
..
.. l'WfonNng Org8lliDtion A8pI. No.
II. 1'Wf0000000na OrQ8lNullon NIIm8 8ftd AddN88
10. JIroI8ctIT88lu'Worli UnlI No.
11. ConlrllCt(C) or Qt8nI(Q) No.
(C)
(Q)
12. Spon80Mg Org8lliDion N8nw 8ftd AddN88
U.S. Environmental Prot~ction
401 M Street, S.W.
Washington, D.C. 20460
IS. Typ8 of A8port . P8rtocI Co".,8d
Agency
800/000
14.
15. SUppl8mM18ry No..
18. Ab8tr.cl (Urn/I: 2IID word8)
The 230-acre St. Louis River site (also known as the St~ Louis River/Interlake Duluth
Tar site) is on the north bank of the St. Louis River in Duluth, Minnesota, with
portions of the site within the 100-year floodplain. The bank of the river consists
of a series of inlets and peninsulas, including the Stryker Embayment and the boat
slip inlets. This site is the former location of several pig iron and coking plants,
as well as separate tar and chemical companies, which used byproducts from the plants.
The chemical companies closed in the 1940s, and the pig iron coking plants closed
during the 1960s. Tar seeps are present onsite in several locations, including the
embayment and boat slip areas where tar producers had disposed of tars directly onto
the ground. Soil and underlying ground water are contaminated with high levels of
PAHs as a result of past onsite disposal activities. Chemicals released from the
sediments are the source of a thick layer of tar-like material in portions of the
embayment and boat slip areas. This Record of Decision (ROD) addresses Operable Unit
1 (OUl), the remediation of the onsite tar seeps, which are a potential source of
ground water and surface water contamination. A future ROD will include a
(See Attached Page)
17. DocuIMnl Analy818 .. DHcrIptor.
Record of Decision - St. Louis River, MN
First Remedial Action
Contaminated Medium: soil
Key Contaminants: organics (PAHs)
b. IdendlieraJOpen-EncI8d T8ft'II.
c. COSA TI R8IcIIGtoup
18. Availability 8"-1
111. S8cI81ty Ct... (TN. Report)
None
20. S8cUItty Ctaa8 (Th18 Page)
None
Z 1. NO. 01 ..agea
56
22. PrIce
I
(See ANSI Z311.'8)
SH 'MITUCII- on"'-
_,-11-.-..
(4-77)
(Formarty NTlS-35)
Departmant o' Commerce
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EPA/ROD/ROS-90/139
St. Louis River, MN
First Remedial Action
Abstract (Continued)
treatability study to address the contamination of the soil, sediment, qround water and
surface water at the site (OU2). The primary contaminants of concern affectinq the
soil are orqanics includinq PARs.
The selected remedial action for this site includes excavatinq 300-2300 cubic yards of
visible tar seeps with offsite disposal to a power plant or a similar facility for use
as recyclable fuel, and landfillinq the tar and ash residues off site. This ROD
provides a continqency for incineration of up to 10% of the materials at a RCRA
incinerator if the power plant will not accept the contaminated soil/tar mixture. The
estimated present worth cost for this remedial action ranqes from $700,000 to
$2,700,000, dependinq on the extent of excavation required. There are no O&M costs
associated with this remedial action.
PERFORMANCE STANDARDS OR GOALS: No chemical-specific qoals are. provided; however, this
remedial action will reduce the current excess lifetime cancer risk for qround water to'
acceptable levels and prevent miqration of contaminants to surface and qround water.
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REXXIm OF IE:ISICN
SITE NAME AND IDCATICN
St. Louis River/Interlake/D..1luth Tar Site
D..1luth, Minnesota
STATEMENl' OF B\SIS AND RJRREE
'!his decision document presents the selected source control remedial action
for the St. L6Uis River/Interlake/D..1luth Tar Site in D..1luth, Minnesota, chosen
in accordance with the Comprehensive Enviromnental Response, Carpensation, arxl
Liability Act of 1980 (CERCIA), as arnerx:led by the SU:perfun:1 Arnen:!ments arxl -
Reauthorization Act of 1986 (SARA), and, to the extent practicable, the
National oil arxl Hazardous SUbstances Pollution Contingency Plan (NCP). '!be
decision is based on the Administrative Record for the St. Louis
River/Interlake/D..1luth Tar site. '!he attached in:lex identifies the items
which c::orrprise the administrative record upon which the selection of the
remedial action is based. ~
'!he state of Minnesota has been consulted and concurs with the selected
remedial action.
ASSESSMENI' OF '!HE SITE
---
Actual or threatened releases of hazardous substances from this site, if not
addressed by ilrplementing the source control remedial action selected in this
Record of Decision, may present an imminent and substantial errlangennent to
the public health, welfare, or the environment.
" .
DESaUPI'ICN OF '!HE SEI.D:TED REMEDY
'!his operable unit is the first of two that are planned for this site. '!he
first operable unit is a source control operable unit. It addresses tcr seeps
present on the site. '!he function of this operable unit is to rem:rve t~ .
tars, which are a potential source of ground water and surface water
contamination, and to reduce the risks to hurrans and wildlife associated \.,ith
exposure to the contaminated tar materials. While the remedy does address one
of the principal threats at the site, the secooo operable unit will involve
continued investigation and a treatability study of the other contaminated
media on the site, follC1.Ved by remediation. .
'!he major a:mponents of the selected remedy include:
- Excavation of the tar; and
- B.m1ing the tar for energy recovery at an acceptable utility c::x:mpany,
s~l blast furnace, or other suitable facility.
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- 2 -
,
~~(R;
a:nsistent with CERCIA am, to the extent practicable, the NCP, 40 C.F.R.
Part 300, the selected so..IrOe cx:ntrol remedial actioo is protective of human
health am the envircrJment, CCltplies with Federal am State requi.renents that
are legally awlicable or relevant am awropriate to the ~i"J actia1, am
.is cost~ffective. '!he h:u.edy utilizes .pemanent. solutioos am alteJ:native
treatment t.ec:hrx>loqies am resource retXNerj t.ec:hrx>loqies to the may;,rl1",
extent practicable, am satisfies the statutozy preference for remedies that
E!q)loy treatment that re:h1oes toxicity, DCbUity, or volume as a principal
element. Because this c:perable lD'1it lSlOOy addresses only part of the
cxntamination present m-site, am hazardcus subst.a.ooes will remain m-site .
aJ::x:we health~<=Ar1 levels, the five year review will awly to this actia1, if
. are rot reduced to heal th-based levels as a result of the secorrl
e lD'1i t . al actia1. .
-
9/2crho.
tate; I I
!
,
tor
~~~
t Gerald L. Wille, ioner
Minnesota Pollution Ox1trol Agercy
-
:.--
9-2' -.90
tate
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I.
II.
III.
'IV.
v.
VI.
VII.
VIII.
IX.
x.
SUlflARY OF REMEDIAL AIlI'ERNATIVE ~(fi
- st. I.a.rls River/InterlakejD..1luth Tar site
D.1luth, Minnesota
TABIE OF a:Nl'ENl'S
SITE NAME, IDC'ATI0JIl AND DFSCRIPI'ION.................. 1
SITE HISIORY AND ENFORCEMENT ACI'IVITIES.............. 2
COMMUNITY ~ONS HISTORY.......................... 3
SOOPE ~ roIE OF OPERABLE UNIT OR RESroNSE ACI'ION... 4
SUMMARY OF SITE
~CI'E:RIS'rIc:s. . . . . . . . . . . .'. . . . . . . . .. 5
..
SUMMARY OF SITE
RISI
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.,
- Stntunal:y of Remedial Alternative Selection
st. Louis River/Interlake/D.1luth Tar Site
Operable Unit 1
D.1luth, Minnesota
I.
Site Nane. Location am DescriDtian
'!he St. Louis River/Interlake/D.1luth Tar (SIRIDI') site is loc:ated in IW.utb,
Minnesota. '!he site lies on the north bank of the st. Louis River,
approximately four river miles from Lake SUperior. '!he site i.rx:ludes
approximately 230 acres of lam and river/embayment area. (see Figures 1 am
2.) .
" ,
, f" .
'!he SIRIDI' site :is bounded on the north by the aJrllngton Northern Railroad
right-of-way. A peninsula at the base of 54th Avenue constitutes the 'eastern
portion of the site, am the st. Louis River defines the southern ~. -
StJ:yker Embayment, a river embayment of approxbnately 35 acres, is on the
western boundaIy of the site. Another peninsula, located south of 59th
Avenue, is also part of the site. '!his peninsula is kr10wn as the Hallett
Peninsula. '!he tip of the Hallett Peninsula is actually part of SUperior, I
Wisconsin. However, this area is not being ~ated as part of this .
operable unit. f
;;::.:.
'!he site is zoned for manufacturing use. However, residences are lcx::ated west
of the site on the 63rd Avenue Peninsula, and to the north of the railroad
tracks. 1\pproxbnately 800 persons live within one mile of the site. '!here is
a walking trail along the western bank of the embayment, am some residents .
have been known to swim and fish in the embayment, despite repeatedwarn..i.rgs
not to do so. "No swimming" and "No fishing" signs have been posted. A
canpground, a school, am a school playfield are located within one mile of
the site boundaries.
'!he two peninsulas that are included in the SIRIDI' site ,consist largely of
fill material. (See Figure 2.) The topography of the site is uneven, am
slopes slightly away from the st. Louis River. Portions of the site are
lcx::ated within the 100 year floodplain.
'!he contamination at the site is found as tar seeping at the grourrl surface;
tar deposits within the fill material; solid wastes such as coal arrl coke
particles, ash, slag, and clinker; and slicks of oily wastes. Contaminants
are foun:l in ground water on a lcx::alized basis, at ground surface, within
both the native soil and the fill, in floating slicks on surface water, am in
river embayment sediments. .
'!his Record of Decision focuses on the tar seeps am associated tar
contamination only. Tar seeps are present at the following lcx::ations:
Figure 3.)
(see
o
In the central portion of the Hallett Peninsula immediately south of
the Hallett Dx:k Company office;
On the Hallett Peninsula near the northwest corner of the Hallett
o
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L
.~.. Jx : ~..- _.,;1;;-
. ".' I'
. ....
, " . ", l
-~::':'a::.::.: -""~:'~-:':"'-..-~"~ =--.) -----------'\;
,,:':': ' ~ . " r-: . .' , . .
..~~. ~" ilU. . \ " .
....,.1 . ~
, '~ ", iiI ~
. . .... " &) " S " , )" ..l .~. .
. .- . , "':7 "')' ". ,.... "..-,
..-' ~' ~, ' 'X' ?)l'..~'~
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~ESTIMTED~ .r
2000 r..l HARDENED TAR
\\
TAR
SEEP
o
500
1000
1500
,..,--------~
---_._----
SCALE
.~
TAR
SEEP
~
-
" t
N
LEGEND
~ POSSIBLE EXTENT
of SOIL
CONTA/\INATION
. TAR SEEP
FEASIBILITY STUDY - SLRIDT SITE
POTENTIAL AREAS FOR TAR REMEDIAL ACTIONS
FIGURE
..-..... ---... .
I,
I.
!
I
!
i
i.
! '
.2
. ,
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~
~
....
RADIO
ANIDfNAS
n
u
...
'i
u
BURUNCTON NOR1HERN RR
...
en
~
1&1
:J
Z
~
-<
'0
..
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co
STRYKER
EMBAYMENT
"i'~'~~i!~i--"II~i.!I!';~11[~i~j
o
ST. LOUIS RIVER
.-- ..-...,
~
~
FEASIBILITY STUDY - SLRIDT'SITE
lOCATION OF FORMER INDUSTRIAL OPERATIONS
0-
.#_-
LEGEND
'"
A. DUlllTH TAR AND CHEMICAL
B. INTERlAKE IRON
C. 54TH AVENUE PENINSlIL' F1lL AREA
D. ZENITH FURNACE COMPANY
E. AMERICAN (DOMINION) TAR AND
CHEMICAL
F. MW12 CONTAMINATED SOILS AREA
PENINSULA BOUNDARIES
1909 0
1939 CJ
1973 [J
---
FIGURE
3
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2
o
Boat Slip:
On the Hallett Peninsula at the southeastern edge of IW.uth Auto
Wreck:irg arrl exten:i:iJ1g into the northern portion of A. KeI!p fisheries
(Junction of Areas E and A): and
o
At the south erxi of the 54th Avenue Peninsula, at the 48-inch o.Itfall
pipe. .
Soil, sediJnent, qroun:l water, and surface water contamination will be
addressed in a future operable unit. GI'OUl"rl water fran the site is not
currently used as a source of drinking water.
~ :
II.
site HiStorv arrl Enforoenent Activitv
~
'!he SIRIDI' site is the former location of pig iron and coking plantS and
separate tar and chemical corrpanies. '!he tar and chemical carrpanies used the
tar byproducts of the iron corrpanies' coking operatioru;; to make other
products, including tar paper and shingles. '!he tar ~ chemical cxmpanies
closed in the 1940's, and the most recent pig iron plant has not operated i
since the 1960's. ~ !
'!he tar seeps are a result of past disposal activities on-site. '!he seep I
located near the Hallett office and the seep near the head erxi of the boat
slip are in areas where tar producers once disposed of tars directly on the .
qroun:l. '!he seep at the erxi of the 54th Avenue Peninsula is located at a
point where a pipe discharged wastes to the St. Louis River. '!he seep near
D.l1uth Auto Wrecking is located where a tar storage tank is believed to have
stood.
-
Soil on-site is contaminated in areas where the iron arrl tar facilities were
located, and near where tar seeps cx:::cur. GI'OUl"rl water is contaminated. beneath
surface "hot spots", where contaminated soil or tar seeps are located.
Sediments are contaminated with a thick layer of tar-like material in porti::>ns
of the embayment im:i boat slip. A tar blanket cx:::curs at the erxi of the 48-
inch outfall pipe heneath the st. Louis River. oil slicks frequently occur on
surface water in the embayment and boat slip. '!hese slicks seem to be caused .
by the release of cnemicals from the sediments.
'!he Minnesota Pollutic.:1 Centrol Ageri':'j (MPCA) learned of the site when a local
resident reported oil risir(3 to the surface of StIyker Embayment.
MPCA staff then inspected t}",e site in July and November 1981. '!he U.S.
Enviroronental Protection Agency (U. S. EPA) corrlucted a prel:inUnazy assessment
of the site on FebIUaIY 16, 1983, and a site investigation on May 27, 1983.
In 1983, the U.S. EPA consolidated the SIRIIJr site arx1 the St. I.a1is
RiverjU.S. Steel site and added them to the National Priorities List (NFL) as
one site-the st. Louis River Site. Although the two sites are listed as ~
on the NPL, they are being investigated arx1 will be addresse::l separately.
'!his is because they are separated by a distance of four river miles, and
because U.S. Steel is corrlucting the cleanup at the U.S. Steel site.
Because no Potentially Responsible Party (PRP) was fourrl who was willin;J to
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3
-
Ul"X3.ertake the site investigation an:1 cleanup of the SIRIIJ1' site, the MPCA an:1
U. s. EPA executed an agreement in April 1986 for the MPCA to cxmduct a
Remedial Investigation (RI) using money from the Federal SUperf\.1rd. 'n1e
investigation was delayed because the furrling mechanism for the Federal
SUperf\.1rd expired in October 1985 and was not reauthorized by Corgress \.D'1til a
year later. '!he MPCA began the RI in the surmrer of 1987. 'I\oJo ~ of .
investigation were con1ucted, and the RI report, which discusses these .two
phases, was reviewed an:1 approved by both MPCA and u.s. EPA in February 1990.
'!he RI Report was placed in the infonnation repository at the D.1luth Public
Library for public review. A public meetirg to di~ the results of the RI
was held on March 27, 1990.
A site-wide feasibility study was started: hCMever, it became apparent that
treatability studies on the soils and sediments were necessary due to the
large volumes of contaminated media and the potentially high costs associated
with remediation. since the tars could be addressed at the present tine, ari:i
due to a strong desire to begin cleanup on-site, it was decided to separate
out the tar seeps operable unit. A Focused Feasibility stUdy (FFS) for this
source control operable unit was c:orrpleted in July 1990. '!he FFS report, as
well as the Proposed Plan, were made available to . the p.lblic on July 28, 199p.
A p..1blic meeting to discuss the alternatives was"held on August 15, 1990. !
U.S. EPA acx::epted verbal comments at the meetirg, and written comments throL1f
August 26, 1990. .
.--
MPCA is responsible for conducting the search for Potentially Responsible
Parties (PRPs). '!his report is scheduled for c:orrpletion by SepteIrher, 1990.
One ~ PRP, the Interlake Iron ColTpany, was sent letters requestirg their
involvement in the cleanup process on February 11, 1985 and August 30, 1985.
'!hey declined then, but have recently sought to have input into the FFS;
Interlake has commented on the FFS report. Interlake has also con1ucted a
search for other PRPs. '!his search report will be incorporated into the
report prepared by MPCA. .
Special notice letters have not yet been issued to PRPs. MR:'.A will issue
Requests for Response Action (RFRAs) to PRPs in the near future.
III.
Canml.mitv Relations History
'!he st. IDuis RiverjInterlakejDJluth Tar site has generated a great deal of
public interest. SUperfund activi.ties at the site have also received
attention from local organizations, pu\:>lic officials, and the media.
Community relations have largely been t.andled by MR:'.A. A public meetirg was
held in July of 1988, and numerous fact sheets have been published to keep the
public infonned of site activities. On March 27, 1990, a meetirg was held
with a local group knCMn as the Technical Advisory Committee, an:1 later that
day, a p.;1blic meeting was conducted to discuss the results of the RI. On July
28, 1990,. after cor.pletion of the Operable Unit FFS for the tar seeps, the FFS
and Proposed Plan were placed in the Infonnation Repository located at the
D.1luth Public Library. On that day, a notice of their availability was
published in the D..1luth News Tribune. '!he RI Report and the Administrative
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\J
4
Record were also made available for public review at the librazy. '!be
Administrative Record is also available for review at the u.s. EPA Regional
Office in Olicago, Illinois.
To encourage public participation in the remedy selection process, U. S. EPA
set a 30-day public comment. pericx:l from July 28, 1990, through August 26,
1990, durin;J which comments on the Proposed Plan would be accepted. A p.1blic
meetin;J was held in D..1luth on August 15, 1990, to n;~s the Proposed Plan,
accept vemal comments on it, arrl to answer questions.
Interested parties provided comments on the altematives which were presented
in the Proposed Plan arrl the FFS. '!be ~ for the SIRIDI' site described
herein was selected after a detailed review of all public comments received.
'!be attached ReSponsiveness SUrranaJ:y addresses comments received.
'!his decision document presents the selected remedial action for the SIRIDI'
site in D..1luth, Minnesota, chosen in accordance with CERCIA as aIreIrled by SARA
arrl, to the extent practicable, the National Contingency Plan. '!be decision
for this site is based on the Administrative Record.
-
IV. SCXJce an::} Role of Operable Unit or ~ Action !
'!be problems at the SIRIDI' site are corrplex. As a result, EPA has divided ~
work into two components called operable units (oos). '!bese are as follows:
o 00 One:
.;;::::. 0 00 'IWo:
Tar Seeps; am
Contamination present on the remaining portions of the
site.
'!be first 00 addresses tar seeps at the SIRIDI' site. '!bese seeps are a
principal threat at the site because of the potential for direct contact with
the tars by humans am wildlife. '!be tars also are likely to iIrpact groun::l
water and surface water quality. C1emicals that volatilize from the tars also
pose a potential threat of inhalation exposure to people who go near the
seeps. '!be cleanup objectives for this 00 are to prev~t exposure to tars, to
prevent migration of contaminants to surface water an:i gI'OUJ'Xi water, am to
prevent exposure of non-human animals to the tars through cleanup arx:3,Ior
containment of the tar seeps.
'!be secorrl 00 will address contamination of soil, sediments, g1'OUrx:l water, arx:l
surface water on the remaining portions of the site. 'Ihreats ~;sociated with
these contaminated media are as follows: .
Soil
- direct contact, inhalation, am ingestion exposures:
Sediments
- direct contact exposure;
SUrface Water - direct contact and ingestion exposure: arxi
Grourrl Water.
- a potential threat only, as drinking water is supplied by
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5
the public water system, am there is little chance that the
site groun.1 water will be consumed in the future. '!he site
consists largely of fill material am is partially within a
floodplain; both of these factors make well develc:pnent on-
site unlikely.
Ingestion of contaminated fish is also a potential threat.
In order to minimize these threats before remedial action can be taken,
certain measures have been employed. "No swimrn.irq" am "No fish.in:J" signs
have been posted on-site. A fish consurrption advisory is in effect. Fences
are also present on-site to minimize trespassin;J.
,.. j'"
i
Although the abOve-mentioned media were studied in the RI alon:J with the tar
seeps, many questions remain as to the most effective way to remediate these.
site problems. Prel:i1ninaxy estimates of remediation C05t$ for the remain:ler
of the site have been as high as $100,000,000. Because of this potentially
high cost, the large areas that need to be remediated, am the uncertainties
associated with various treatment technologies, the agencies are delayirq
their decision as to hCM to clean up the rernain:ler of the site until further
information can be gathered. ,.. !
Treatability studies are being planned for the contaminated soils and ,
sedi!nents on-site. SUrface water contamination is expected to be corrected
once secllinent contamination problems are addressed. General grourrl water
quality will likely iIrprove in those areas where it is contaminated after
action has been taken to clean up the contaminated soil am tar seep areas
present on the surface.
V. SUmma1:v of site O1aracteristics
---
C1ernical contamination at the SlRIIJI' site consists predominantly of
. polynuclear aromatic hydrocarbons (PARs). Metals have also been detected on-
site at lCM levels. '!he follCMing eight cheJTlicals or cheJTlical classes were
identified during' the RI as the site-wide indicator cc:mpourrls:
o arsenic
o beryllium
o bis(2-ethylhexyl)phthalate or DEHP
o cadmium
o chromium
o lead
o mercury
o carcinogenic PARs (as benzo [a] pyrene)
'!he cc:mpourrls were selected based on frequency of detection, contaminant-
specific information on environmental transport and fate, am toxicity. Table
1 presents a 5UITU'I"IarY of the contaminant concentrations detected in
the tar seep saITples during the RI. Metals concentrations have not been
toxicologically significant in tar seep saITples collected durin;J the RI. '!be
main contaminants of concern for the tars are carcinogenic PARs, or cPARs.
CPAH..c;, a subset of the larger group of cheJTlicals knCMn as PARs, are kriown to
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-J .
6
cause can:.:
therefore.
co~t~ .
. .."1Z0 [a] pyrene is the nost carcinogenic of the cPAHs;
~tency factor is used for all cPAHs, so that the m:st
_-isk estimates can be made.
'!he contamination at' the SIRIDI' site is founj as tar seepin:] at the grcurx:i
surface; tar deposits within the fill material; solid wastes suc:h as coal an::l
coke particles, ash, slag, am clinker; an::l slicks of oily wastes.
Contaminants are fourd in groun:i water on a localized basis, at gram:l
surface, within both the native soil an::l the fill, in floatin:] slicks on
surface water, am in river embayment am boat slip sedl1rents. 'Ibis decision
dcx:ument focuses only on the tar seeps am asscx:iated tar contamination.
'!he tars are an-orphous black residues from the coking process ani other
irrlustrial activities. '!he tar materials are characterized by high
concentrations of PAH ccmpourrls. Total PAH concentrations in the tars ran;Je
fram 1,650 to 107,200 ng/kg, with the average Concentration bein:] 28,200 --
ng/kg. CPAH concentrations in the tars range from 298 to 20,900 ngjkg. '!he
average cPAH concentration is 5500 ng/kg. '!he total vol\mle of tars is
estimated to range from 500 cubic yards to 2300 cubic~. '!he ran;Je is
large due to uncertainty regarding the depth of the tar seeps.
~
. ~
Areas for potential tar remediation are shown in Figure 3. A tar seep is
located at the junction of the southeastern boun::iaIy of Area E am the
northeastern bour-daxy of Area A on the Hallett Peninsula. '!he estimated
volume of tar ranges from 400 to 2000 cubic yards; the tar ext.erds to a depth
of 2 to 10 feet. '!he tars are located in an area where a tar storage tank is
believed to have stood. '!hey caver about 5400 square feet. Concentrations of
total PAHs in this seep exceed 1000 ng!kg and total cPAHs are equal to 250
Irg/kg .
Area D on t':e Hallett Peninsula also contains a tar seep that exterrls between
2 to 10 feet below the surface. An . estimated 14 to 70 cubic yards of tars are
present, although recently gathered information indicates that a larger volume
of tars may be undiscovered in the subsurface area. Field work to confinn
this information has not been done. The tars are contained in a
roughly square area of about 190 square feet. Concentrations of total PAHs
exceed 100,000 ng/kg and total cPAHs are equal to 20,900 Irg/k;'.
A third area of tany material is located in Area B northwest of the Hallett
Boat Slip. An estimated 20 to 40 cubic yards of tar are contamiJ1ated with
PAHs in excess of 1000 ng!kg and total cPAHs equal to 300 ng/kg. '!he tars are
present to a depth of 1 to 2 feet, and are believed to be the result of past
tar disposal. '!his area is about 540 square feet in size.
'!he southern tip of the 54th Avenue Peninsula, where the 48-inch outfall pipe
meets the st. Louis River, contains an esti.mated 40 to 200 cubic yards of
softened tars over an area of about 1100 square feet. '!hese wastes exten:i 5
feet or m:>re in depth an::l analysis shows total cPAHs equal to 700 ngjkg.
Another esti.mated 25 cubic yards of tars may be present in sludges alorg the
bottom of the 48-inch concrete pipe. .
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7
'!he follCMing potential human exposure pathways to site contamination in the
tars an:l adjacent tar contamiriated soils have been identified:
o
Contact with tar an:l tar contaminated soils on-site by enployees
an:l trespassers;
o
Inhalation of contaminated dusts by errployees an:l trespassers:
Exposure to volatile corrpounds by remediation workers, Hallett Dx:k
Cc:mpany errployees, an:l other site errployees during tar waste re:noval:
an:l
o
o
Ingestion of tars.
Exposure to volatile organic compound emissions at tilnes other than tar
renoval is also possible, although real-time monitorirg for total VOCs did nOt
detect any emissions during RI activities.
Wildlife could also Corne into contact with the tar seePs. Tars nay migrate
into surface water due to erosion. Tar seeps could be located in contact with
grouOO water. . ~ i
f
VI. S\.Irmncuv of site Risks
DJring the FFS conducted on the tar seeps operable unit, an analysis was
corducted to estinate the health problems that could result if the tar seeps
at the SIRIDI' site were not remeciiated. '!his analysis is comrronly referred to
as a risk assessment. In conducting this assessment, the focus was on the
health effects that could result from direct exposure to the contaminants as a
result of the tar corning into contact with the skin. HCMever, :inhalation of
volatile organic chemicals present in the tars, and inhalation of tar
contaminated dust, as well as irgestion of tars, are other possible exposure.
routes .
.. .
'!hose people most'likely to corne into contact with the tars are on-site
workers an:l trespassers. The risk analysis focused on cPAHs as the najor
contaminant of concern. CPAHs are a class of semi -volatile organic carrpolJnis
which are KnCMn to cause cancer in humans and/or laboratory animals, an:l thus
are classified as carcin(x;Jens.
Scmplirg of the tars at the site determined that the concentration of total
PAHs in the tars ranges from 1,650 to 107,200 trg/kg, with the average
concentration beirg 28,200 trg/kg. The cPAH concentrations in the tars I'an3e
from 298 to 20,900 trg/kg. '!he average cPAH concentration is 5500 ng,/kg.
By usirg the average cPAH concentration (5500 trg/kg), an excess lifet~
cancer risk of 9x10-2 was calculated based upon a lifetime inc:jastion exposure
scenario; '!his means that if no cleanup action is taken, there is
approximately an additional one in ten chance of contractirg cancer as a
resul t of irgestion exposure to the contaminated tars. '!his estinate was
developed by taking into account various conservative asSUI'!'ptions about the
likelihood of a person being exposed to the tars. '!his risk calculation
-------
~
8
-
assumed a 70 kg adult in;Jests 0.1 g of tar per day, daily for 70 years, with
5500 ng/kg as the average cPAH roncentration, and the toxicity of all cPAHs
beirq the same as that of benzo[a]pyrene. '!his type of risk calOl1.ation is
ronseIVative and mayover-estimate the actual risk if other ac:.c:~nni'ltians were
to be made.
U. s. EPA and MR::A have determined that by ren'OVin;J contaminated tars fran the
site and treatirq them, significant canoer risks associated with oantactinJ
the tars (either derrnal1y, or through irqestion or .inhalation) can be
minimized quickly. Migration of contaminants to ground water and. surface
water fran the tar seeps will also be prevented. In addition, wildlife will
be kept fran contactirq the tars. Actual or threatened releases of hazardaJs
substances fran the seeps, if not addressed, may present an imminent and
substantial errlargerment to p..1b1ic health, welfare, or the environment.
VII. DescriDtic:n of Alternatives
'!he alternatives analyzed for the tar seep operable unit are presented below.
'!hese are numbered to rorresporrl with the rn.nnbers in the FFS Report. '!he
aiternatives for the tar seep cleanup are the fo11owirq:"
~
o Alternative 1:
No Action
,
o Alternative 2:
Contairanent
o Alternative 3A:
Use as a Recyc1ab1eja.u:nab1e Waste Fuel
o Alternative 3B:
Incineration
-
o Alternative 3C:
Reuse for Pavement Production
Cost breakdCMnS for these alternatives are shown in Tables 2 through 6.
Alternative 1:
NO ACrION
Capital cost: $0
Annual Operations arrl Maintenance (O&M) Costs: $0
30-Year Present Worth (iW): $0
Estimated Irnple:mentation TiJnefrarne: None
'!he SUperfund program requires that a "no action" alternative be evaluated at
every site to establish a baseline for cc:mparison. Urrler this alten1ative,
U. s. EPA would take no further action at the site to prevent exposure to the
tar seeps. . .
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9
Alternative 2:
roNl'AINMENI'
Capital Cost: $300,000
Annual O&M Costs: $30,000
3D-Year Present Wo:r1:h: $600,000
Estimated Inplementation TiIreframe:
3 Months
'n1e contaminated tar ~d be left in place ard capped. since the tar is
similar to Resource Conservation ard Recovery Act (RCRA) K087 listed waste,
RCRA is relevant ard appropriate to action taken at this site. 'n1e cap must
therefore meet"'RCRA design stan.1ards. 'lWo different cap designs are developed
for the tar seep areas. Tars in trafficked areas would be c:overe:1 with a
39.5-inch thick cap with a top layer of asphalt for protection. Tars in ~
trafficked areas would have a total thickness of up to 8 feet to control
infiltration am prevent frost damage. One tar seep is located in the St.
Louis River floodplain. Executive Order 11988 prohibits cappin;J sud1 wastes
within a floodplain. Capping this seep is therefore not acceptable. RcRA
I.arxi Disposal Restrictions (IDRs or "lard ban") would preclude relocatirg
these tars to other seep areas without treatment:
-
!
I
Alternative 3A:
USE AS A RECYCIABIE/EURNABIE WASTE FUEL
Capital Cost: $700,000 to $2,700,000
Annual O&M Costs: $0
30-Year Present Wo:r1:h: $700,000 to $2,700,000
Estimated IIrplementation Tirnefrarne: Up to 1 year
All tar seeps (500-2300 cubic yards) would be excavated until no further tar
contamination is visible. '!he tar would be transported ard burned as
recyclable waste fuel at a coal-fired PJWer plant, sud1 as the No:r1:hem States
J?a.ler facility in'Minneapolis, in a steel blast furnace, in a cement kiln, or
in a similar facility. U.s. EPA will approve the final destination of the
tar, to ensure that the facility is acceptable for use. '!he bLu::n.irq process
would destroy the cPAHs in the tar, while allCMing the benefit of energy
recavery from the high BIU values present in the tar. DJring excavation of
the tars, the last tar rem::wed may become mixed with soil. '!he PJWer plant
will not accept contaminated soil, so this option includes a contingency for
bLu::n.irq up to 10% of the materials at a RCRA incinerator. Residues fran
bLu::n.irq tar as a recyclable waste fuel are larrlfilled in a proper manner alon;r
with ash fran the PJWer plant, blast furnace, or cement kiln. '!he facility
chosen for bLu::n.irq Im.lSt be equipped with the appropriate equipment, maintain
stack emission starrlards, and meet regulations. '!his alternative canplies
with 4C ern 261.6(a) (J) (vii) whid1 states that K087 wastes may be burned for
energy recavery. Volume 50, Federal Register, Number 230, Pages 49164 am
49170-49171, November 29, 1985, also discusses using the waste as a fuel, ard
can be referenced for further infonnation.
-------
... - . -'
10
Alternative 3B:
rncrnERATION
Capital Cost: $1,400,000 to $16,000,000
Annual O&M Costs: $0
30-Year Present Worth: $1,400,000 to $16,000,000
Estimated Inplementation Timeframe: Up to 6 years
All contami.nated tars would be excavated am destroyed in a thermal
destruction mdt. If the volUIre of tar excavated was toward the 1011 end of
the estimated volUIre (500 cubic yards), the tars would be incinerated off-
site. If the volume was tOward the high end (2300 cubic yards), the tars
would be incinerated on-site. U.S. EPA would appravethe incinerator facility
chosen. In either case, incineration would destroy cPAHs. Metals may. remain
in the ash, which would be disposed of, after any treatInent necessary in order
to meet the IDRs, in a RCRA COl'l'pliant larx:ifil1. '!he scrubber water would also
require proper disposal. If incineration were done off-site, the residuals
would be disposed of by the incinerator operator, also in COl'l'pliance with
RCRA. '!he incinerator used would COl'l'ply with all technical starrlards for i
incinerators, which include having stack scrobbe:is am other recavery !
trechani.sms to ensure that \.D1treated hazardous substances are not released irf:o
the envirornnent. .
Alternative 3C:
:REUSE FOR PAvrnENr PROIXJCI'ION
Capital Cost: $1,100,000 to $3,300,000
Annual O&M Cost: $0
30-Year Present Worth: $1,100,000 to $3,300,000
Estimated Inplementation Timeframe: 6 months to 1 year
Tars would be excavated am reused in pavement production facilities. CPAHs
would not be destroyed, but would be bourx:l within the pavement matrix am
stabilized. Metal am cPAH concentrations would be diluted by the process.
Permits for this process would need to be obtained. Air emissions would
likely be high, thus requirin;J a waiver of state of Minnesota air quality
regulations an:j RCRA requirements to make i1T1plementation of this alternative
possible. '!he final product would have to pass RCRA 'I'oxici ty O'laracteristic
Leaching Procedure ('IcrP) testing procedures am meet treatment starrlards for
1<087 listed wastes before bein;J placed on the grourrl, or a waiver of these
requirements would have to be issued.
.<..."
VIII. SUImary of the ChTn:Irative Analysis of Alte.rnatives
'!he Focused Feasil:i1ity Study for the tar seep operable mdt examined five
remedial alternatives in detail, am evaluated them accordin;J tot.echnical
feasibility, envirormental protectiveness, am public health protectiveness.
'!he alternatives were evaluated accordin;J to the folla...rin;J nine criteria,
which are used by the U. S. EPA to provide the rationale for the selection of
the chosen remedial action for a site.
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11
o OVerall Prot.eCtion of Human Health arrl the Envi.rorment addresses ~ther or
not a L~lIeJy provides adequate protection am describes ha« risks posed
thrc:ugh each pathway are eliminated, reduced, or controlled thrc:ugh
treatment, erqineerin; controls, or institutional controls.
o Cc:rIi>liance with ARARs addresses wnether or not a lell.edy will meet all of
the applicable or relevant am appropriate requirements of other Federal
am State environmental statutes arrl;or provide grounds for invakiJ'q a
waiver .
o Lon:;J-tenn effectiveness am pennanenoe refers to the magnitude of residual .
risk am the ability of a remedy to maintain reliable protection of human
health am the environment over time once cleanup goals have been met.
i.
o Reduction of toy.icity, nobility, or volume thrc:ugh treatment is the .
anticipated perfonranoe of the treatment technologies that may be errployed
in a remedy. .
o Short-term effectiveness refers to the speed with which the remedy achieves
protection, as well as the remedy's potential to create adverse iIrpacts ~
human health am the environment durin:;J the cdfu;truction am iIrplementati~
periOd. . .
o I1tplementability is the technical am administrative feasibility of a
remedy, inclucli.rg the availability of materials am se1:Vioes needed to
iIrplement the chosen solution.
o COst includes. capital am operation am maintenance costs.
o state Aoceptance in:licates wnether, based on its review of the JU:/FS,
Proposed Plan, an:1 draft roD, the state COno.1rS with, op{X)SeS, or hps.no
comment on the preferred alternative. .
o Camrmm.i.ty Aoceptance is assessed based on a review of the p.mlic camments
received on the JU:/FS report an:1 the Proposed Plan.. Fornal camments
received are addressed in the attached Responsiveness SUnu'nary.
Ead1 of the alternatives was evaluated usin:;J these nine criteria. '!he
regulatory basis for these criteria comes from the National oil am Hazardous
SUbsta.'1CeS Pollution Contingency Plan am Section 121 of CERCIA (Cleanup
Starrlards). Section 121(b) (1) states that, "Remedial actions in which
treatment wt.ich pernanently am significantly reduces the volurre, toxicity or
nobility of the hazardous substances, pollutants, am contaminants is a
principal element, are to be preferred over remedial actions not involvin:;J
such treatment. '!he off-site transport am disposal of hazardoos substances
or contaminant materials without such treatment should be the least favored
alternative remedial action \'~ere practicable treatment t.ed1nologies are
available. " Section 121 of CERCIA also requires that the selected remedy be
protective of human health am the environment, be cost-effective, am use
permanent solutions an:1 alternative treatment technologies or resource
recavery technologies to the naxi.mum extent practicable.
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12
Each alternative is cx:mpared to the nine criteria in the followin:;J section.
Table 7 presents a brief ovezview of the alternatives arrl how they oarpare to
the nine criteria.
OVerall Protection
Alternatives 2, 3A, arrl 3B would provide adequate protection of human health
arrl the envirornnent by e1iminatirg, reducirg, or controllirg risk thraJgh
treatment an:vor ergineerirg controls. Alternatives 3A arrl 3B wa.tld remove
the tars fran the site arrl treat the cPAHs in them. 'Ibis wa.tld reduce the
risks associated with direct contact, arrl minimize migration of c:xmtaminaticm
to grc>1.mi arrl surface water.
~ f'"
Alternative 2 woUld reduce contact risks arrl migration of contaminants to
surface water. HCMever, wastes in contact with grc>1.mi water wa.tld remain in.-
place.
Alternative 3C would stabilize the cPAHs, but contact with them would still be
possible. I.eachi.rg of contaminants fran the pavement might also ooc:Ur. Air
emissions durirg pavement production would likely present a risk to human I;
health arrl the environment. ' ".
,
Alternative 1, "no action", is not protective of human health arrl the
envi.rornnent. '!herefore, it not considered further in this analysis as an
option for this site.
Compliance with ARARS
~
Alternatives 3A arrl 3B would neet their respective applicable or relevant arrl
appropriate requirements of Federal arrl State envirornnental laws.' Alternative
3A is supported by 40 em 261.6(a) (3) (vii) \¥hich grants exenptions for the
treatment of RCRA listed waste K087, allCMirg it to be burned for ererqy
recovery or as a fuel in a steel blast furnace. '!his is. further described in
Volume 50 of the Federal Register, Number 230, Pages 49164 arrl 4917C>-49171,
dated November 29,' 1985. In Alternative 3A, residual ash would be disposed of
in a proper ITI3l"U1er. Alternative 2 would neet RCRA stan1ards for cap design. .
HCMever, buildi.rq a cap in a floodplain must CXIT1ply with Executive order 11988
(Flocx1plain Management, May 24, 1977). Relocatin;J tars fran the flocx1plain to
ot.her areas of t.he site am then capping would likely be considered placement
tm.!er RrnA arrl would trigger the IDRs. Alternative 3B would neet RCRA arrl
both sti.,te arrl Federal air arrl water pollution stan1ards for the operation ot:
incinera'~rs, arrl for disposal of ash arrl scrubber water. Alternative 3C .
would likely require a waiver of Minnesota air regulations due to high air
emissions durirg pavement processirg. '!he final pavement product in
Alternative 3C would have to pass RCRA TCIP arrl meet treatment stan1ards for
K087. Based upon contaminant concentrations in the tars, it is unlikely that
RCRA treatment standards oould be achieved.
Table 8 presents the ARARs that apply to the alternatives considered at the
SIRIDI' site in 100re detail.
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13
Lena-term Effectiveness and Pernanence
Alternative 3A and Alternative 3B would destroy the cPAHs in the contaminated
tars. '!be lo~-term risks of exposure to the tars would be greatly
eliminated. '!be alternatives would prevent migration of contaminants in the
tar to groon1 and surface water. '!be residual ash prcduced by off-si te
treatment would be managed by the EPA approved facility (blast furnace,
utility carpany, or off-site incinerator) where the tars were b.u:ned. If the
tars were b.1rned in an on-site incinerator as in Alternative 3B, the ash would
be treated as 1'1eCE'SSary and disposed of in a RCRA c::arpliant \mit to prevent
the possibiliq of human contact. SCrubber water would also be disposed of
properly. ~ ;,"
Alternative 2 would reduce contact e>qx>sure risks that presently exist.
Migration of contaminants to surface water would also be reduced. F\1ture
seepage of water through the tars would be decreased, but wastes would remain
in contact with groun1 water. Wastes that are not treated constitute a '
principal threat that would remain at the site and would pose potential lo~-
term risks of exposure. Lerq-term maintenance and noni torirg of the cap would
be required to assure the cap remains effective. ~ !
Alternative 3C would bim cPAHs within a pavexrent matrix, reduc~ their
nd:>ility. However, exposure to the contaminants \\1Otll.d not be totally
eliminated. '!be pavexrent prcrluced may crack, allowirg possible leachin;J of
contaminants to the groun1 water. '!be pavexrent would also need to be disposed
of when it ~~~ to be functional.
::::-:
Reduction of Toxicitv. Mobilitv. or Volume of the Contaminants throucth
Treatment
Alternative 3A and Alternative 3B would involve treatment of a principal
contaminant, the cPAHs. '!be cPAHs would be destroyed by burni.rxJ the tars as'
recyclable waste fuel or by incinerating them. Toxicity, nobility, and volume
of cPAH contaminants would be reduced. Metals may remain in the residual
ashes; the ashes will be treated, if necessary, and disposed of properly to
minimize the nobility an:! the toxicity of the Iretals.
Alternative 1C may reduce the mobility of the cPAHs, but the contaminants
would not be dest-'l'"QYed. Ne~.ther the voltnne nor the toxicity of the
contaminants would be reduced. Alternative 2 does not involve any treatment;
toxicity and voltnne of contaminan...s are not reduced, though nobility may be
reduced.
," ,
Short-tenn Effectiveness
Al ternati ve 3A would treat the tar seeps and reducx. the possibilj ry of' direct
human contact with the contaminants in the least anount of tiIre c:xmpared with
other alternatives, except possibly Alternative 2 (i.e., cappirg).
Alternatives 3A, 3B and 3C that inclu~e excavation could pose same short-term
risks of exposure due to air emissions of cPNls or VOCs durirg the excavation
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14
process. '!hese risks are e>cpect:ej to be minimal. Alternatives 3A, 3B an:! 3C
involve transportation of contaminants off-si te an:} could present a short-
tenn risk of exposure to the oc:rnmunity due tq the possibility of
transportation acx:idents.
D.1e to the potential shortage of off-site incinerator capacity or potential
unavailability of an on-site incinerator, Alternative 3B would likely require
st.ockpiling of contaminated tars on-site. 'Ibis could pose a short-term risk .
of exposure via direct contact or volatile organic COItpJU1"d emissions !ran the
tars.
Risks of contact exposure would be greater for Alternative 3B than those un:3er
Alterative 3A,";which would allow for nore rapid destruction of the
contaminants. under both alternatives, there are some risks of exposure to
air emissions fran the treatment facilities.
Al ternati ve 3C would result in the greatest arrount of contaminant. emissions to
the air. Waivers of air regulations would likely be required. Contact with
contaminants in the pavement product would still be posSible. '!he need to
obtain peDni ts for this process may cause delays. .
.
.-
!
,
Alternative 3A has ffM associated administrative difficulties that could delay
iItplementation. '!he remedy has been used sucx:essfully to address similar .
problems at other swlar facilities. Skilled workers needed to perfonn the
remedy are readily available. SUitable facilities for burning the tars as a
recyclable waste fuel are in existence. No lo~-tenn nonitoring would be
required for the preferred alternative, while Alternative 2 would require sum
nonitor~ of the remedy's integrity. Alternative 2 would also be
administratively difficult to iItplement due to tars beirq located within a
floodplain. '!here is uncertainty about the availability of adequate capacity
to burn the tars in an incinerator for Alternative 3B. 'Ibis could lead to
lo~ delays before iItplementation of Alternative 3B. Alterna~ive 3C is likely
not iItplementable because the pavement produced would have to pass 'laP an:!
meet treatment starrlards for K087. A waiver of Minnesota state air
regulations would lL{ely be requind during pavement production. Delays could.
be encountered when attenpting to olJtain permits to iItplement this
alternative.
IrnPlementabili ty
Cost
'!he present-worth cost ICm3e Qf the alternatives is as follows:
o Alternative 3A is $700,000-$2,700,000.
o '!he lowest cost alternative is Alternative 2 at $600,000.
o '!he highest cost alternative is Alternative 3B at $1,400,000-$16,000,000.
o Alternative 3C has a present-worth cost of $1,100,000 to $3,300,000. .
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15
State Acceptance -
'Ihe State of Minnesota OOncw:'S with and supports Alternative 3A.
CommLmi tv Ac:x=eptance
'!he O::Inrro..mity accepts the selected alternative, Alternative 3A, based upon
p.1blic canment received. 'Ihe specific comments received and u.s. EPA's
responses are outlined in the attached Responsiveness SUrmnaJ:y.
IX. '!be Selected Rr:m:dv
'!he selected alternative for cleanup of the tar seeps operable unit at the St.
Louis River/Interlake/I:Uluth Tar site is Alternative 3A - Use as a
Recvclable/B.1.mable waste Fuel. Based on current information, this
alternative would appear to provide the best balance of trade-offs am::n:j the.-
alternatives with respect to the nine criteria that EPA uses to evaluate
alternatives. Alternative 3A would achieve substantial risk reduction thro.1gh
treatJrent of a princiPal threat at the .St. Louis River/Interlake/D..1luth Tar
site. Alternative 3A achieves this risk reduction quickly and at a reasonab:~e
cost. 'Ibis alternative also addresses the three temedial action objectives I
for the site-prevention of human exposure to tars via inhalation, in]esti~.t
or clixect oontact routes; prevention of oontaminant migration to surface watE!r
and grourxi water; and prevention of wildlife exposure to tars.
'!he costs for c:arrponents of the selected telliedy are presented in Table 3. '!he
estimated cost range is $700,000 to $2,700,000.
"...
x. statutoIV Detenninations SlmIImv
1. Protection of Human Health and the Environment
'Ibis selected remedy provides for overall protection of human health and the
environment, by treatIrent of oontaminated tars present on-site. '!he tars will
be burned as a recyclablejbumable waste fuel. Carcinogenic PAHs will be
destroyed in the process. Tars will be prevent-..ed from oontributirg to future
oontamination of grourrl and sur.:ace water. HlLrans and wildlife will no lon;er .
be able to oontact the tar.
Any short-term risks associated with excavation of oontaminated materials
(dust generation) will be minimized by the use of good oonstruction practices.
Air rronitorirg will be oorrlucted to as~s possible expc.:!Sure durin] reredi.al
action.
o
2. OJnplianoe with ARARs
'!he selected remedy will attain Federal and state applicable or relevant an:i
appropriate requireIrents as described in Section VIII of this Record of
Decision. ARARs oonsidered for this site are listed in Table 8. '!he Federal
ARARs that apply to this remedy are as follows:
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. - .
,"
16
. '
o 40 ern Part 261.6 (a) (3) (vii) regardin;J listed waste K087
o 40 ern Part 261 regardin;J 'laP arrl characteristic arrl listed hazardous
waste definitions
o 40 ern Part 262 regardin;Joff-site disposal of wastes in a ~ lan:1fill
o 40 ern Part 263 regardin;J transport of wastes off-site
o 40 ern Part 264 regardin;J facility standards
o 40 ern Parts. ~62 arrl 264. regardin;J incinerator standards
o 40 ern Part 268 regardin;J the I.an:i Disposal Restrictions (may awly to the-
selected remedy if there are metals in the residual ash)
o Clean Air Act, Air Pollution Prevention arrl Control, 42 U.S.C., U7401 to
7642
o 40 ern Part 50 oonoe.rniIq National Ambient Air -Quality Standards !
o 40 ern Part 60, Subpart E oonoe.rniIq New Source Perfonnanoe Standards for I
Incinerators
o Federal Water Pollution Control Act, 33 U.S.C. U1251 to 1387 regardin;J
treatment of scrubber water
-
o 33 U.S.C. ~1342, Section 402, NPDES, arrl 40 ern Parts 122-125 regardin;J
treatment of scrubber water
a 33 U.S.C. !i1317, Section 307, Pretreatment Standards, arrl 40 ern Part 403
regardin;J treatment of scrubber water
3. Cost-Effectiveness
'!he selected remedy provides overall cost-eifectiveness. !he cost is
reasonable for the treatment obtained in comparison to the other alternatives.
'!he selected rerredy can be iIrplemented at a cost that is pot:£3.ntially far less
than incineration of the tars, the next best alternative.
4. Utilization of Permanent Solutions and Alternative Treatment Teamologies
or Resource Recovery Technologies to the Maximum E>ct:.E:!nt Practicable
'!be selected Iellcly provides' the best balance with respect to the nine
evaluation criteria as described in Section VIII of this Record of Decision.
Treatment is utilized to the maximum extent practicable by burning tars foa..m:1
on-site as a recyclablejbumable waste fuel. 'Ibis alternative is a penranent
solution which destroys the cPAHs in the tars, the tar oontaminants which pose
the greatest risk to human health and the envirornnent. '!be selected
alternative is also preferre::i because it allows for beneficial reuse of the
tars, taking advantage of their high BIU value.
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17
'!his alternative reduces toxicity, mobility or volUl'Ce of contaminants through
tre.atJrent. It can be ~lemented in a relatively short ti1re arrl with little
i1rpact on tbe local cxmnunity. It is readily ~lementable, arrl can be done
. for a reasonable cost. 'Ihe state concurs with arrl supports tbe selected
remedy. '!he alternative was presented in tbe Proposed Plan arrl subjected to
~lic ccmrent. Based on ccmrents received, tbe Ccmmmity accepts tbe
selected l:eluedy.
5. Preference for Treatment as a Principal Element
'Ihe selected remedy eliminates a principal threat at tbe site (threat of
direct contact'; 'injestion an:Vor inhalation exposure to tbe tars) by tbe use
of tre.atJrent, tlU-ough use of the tars as a recyclablejburnable waste fuel. A
future operable unit will address other threats present at tbe SlRIDl' site. -,
~
,
-
-------
CCIIT'OOund
VOLATILES:
Benzene
Toluene
Ethylbenzene
Styrene
Total Xylenes
SEMI-VOLATILES:
2-Methylphenol
4-Methylphenol
2,4-0;methylphenol
. Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
O;benzofuran
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)Anthracene
Chrysene
Benzo (b)
Fluroanthene
Benzo (It)
F luoranthene
Benzo(a)Pyrene
Indeno (1,2,3-cd)
pyrene
O;benzo (a, h)
Anthracene
Benzo(gh;)Perylene
TOTAL PANs:
TOTAL cPAHs:
INORGANICS:
Alun;run
Arsenic
Bariun
Beryl! hili
Cal ci \III
Chrom;un
Copper
Iron
Leecl
Magnesiun
Manganese
Mercury
Vaneclh.lll
Zinc
Cyanide
Phenolic.
BTU Ana lyses
BTU/lb
TABLE 1
SLRIDT FEASIBLITY STUDY
TAR SEEP OPERABLE UNIT
,~ONTAMINANTS PRESENT IN TAR SAMPLES
Concentration (or Range)
(1IIQ/ka)
Average Concentration
(ma/!ta)
12 oJ
48 oJ
3.6 oJ
17 oJ
78 oJ
,.,. ,
"
76 oJ
160 oJ
77 oJ
200 - 38,000
2300 oJ
170 . 13,000
290 oJ
1400 oJ
88 - 8000
260 - 12,000
80 - 3700
170 . 6200
120 - 5400
42 . 2700
71 . 2900
9600
4600
2100
3600
1000
2000
~ 1500 !
800
800 f
500
800
700
900
600
900
28,200
5,500
;.
32 . 1300
16 . 2800
37 . 2500
24 . 3200
21 - 1600
14- 4100
1,650 - 107,200
298 - 20,900
7400
4.7
93
1.1 oJ
29,500
11
30 E
14,100
39
1580 E
28lo0
0_43
19 E
118
18
195
2100 - 16,200
10,500
Notes:
E - Analysis did not pass GA/GC requirements
oJ . Indicltes an estimated value
0871-04-8
J
-------
TABLE 2
SLRIDT FEASIBILITY STUDY
TAR SEEP OPERABLE UNIT
CAPPING CONCEPTUAL DESIGN PARAMETERS
CaDital
CaD SYStem:
Vegetative for Areas A & E'
Asphalt for Areas B & 6';
Quanti tv
Iln.11
Unit S
Cost
Relocate Outfall Area
0.5 Icre $200,000 $100,000
0.5 . acre $165,000 $80,000
200 cy SZ5 S5.000
Subtotal: S185,OOO
S45,OOO ,
~ !
$30,000 f
~
Total:2 .
S300,OOO
Engineering and Permits (25%)
Administration (15%)
Contingencies (251.)
~ , Cost estimates are based on similar designs done for other Minnesota sites.
2 Does not include repair and maintenance costs. All numbers have been rounded
and may not add up.
. .
-------
- .. -.
.TABLE 3
~LRIDT FEASIBILITY STUDY
TAR SEEP OPERABLE UNIT
REQUIREMENTS 1 PARAMETERS FOR TAR DISPOSAL
AS A RECYCLABLE/BURNABLE WASTE FUEL
CaDita' Ouantity Unit Jln.iLL Cost
Excavation 500 - 2300 cubic yards S25 $13,000 to
S58,OOO
,
,
Backfill of Excavation 500 - 2300 cubic yards S5 S2,500 to
. $12,000
Work Area Prep/ 1 $10,000 $10,000
Decontamination Pad
loadingfTransportation 30 - 150 end-dump load S900 ,S27,000 to
~ S140,OOO
Burning/Tipping Fees 450 . 2100 cubic yards $500 $225,000 to ,
SI,050,OOO
50i1 Mixture Incineration 50. 200 cubic yards $ 1, 600 $80,000 to
. $320,000
-
Restoration 1 $50,000 $50,000
Subtota1 $410,000 to SI,600,000
Engineering and Permits (25%) $100,000 to $400,000
Administration (15%) $60,000 to $2~O,OOO
Contingencies (25%) $100,000 to $400,000
Total $700,000 to 12,700,000
-------
- .' ~ .
TABLE 4
- SLRIDT FEASIBILITY STUDY
TAR SEEP OPERABLE UNIT
OFF-SITE INCINERATION
CONCEPTUAL DESIGN
Item Quanti tv Unit Unit S
Pre-design Studies 1 eich S50,OOO
"
Excavation '" , 500 cubic yards S25
;
Transportation 43 BO-pac!, loads $2,200
Incineration/Disposal 3400 30-gallon packs S200
Backfill/Restoration 500 cubic yards S10
~
'Subtotal
Jineering and Permits (2St)
kdministration (15r.)
Contingencies (25%)
~
Total
,"
Cost
$50,000
$13,000
, $95,000
$680,000
$5,000
$840,000
$210.000
$140,000
$210,000
$1,400,000
-------
. .'. -'
..,' .' -.
..
TABLE 5
SlRIDT FEASIBILITY STUDY
TAR SEEP OPERABLE UNIT
REQUIREMENTS' PARAMETERS FOR TAR TREATMENT
BY ON~SITE INCINERATION
CaD11!J ~ Unit Unit $ Cost
Excavation 2,300 cubic yards $25 $60,000
Backfill of Excavat ion,.. 2,300 cubic yards $5 $10,000
, ~
Incineration - Fixed Costs 1 $8,000,000
Incineration - Variabl e 2,300 cubic yards $400 S900,000
Costs
Restoration J $50,000 $50,000
~
~
Subtotal $9,000,000
Annual ODerations/Maintenance
Labor 5,400 hour $25 S140,000
-;;::;.. 1 ,800 hour $40 $ 70,000
Monitoring 1,800 hour $40 $ 70,000
Ash & Waste Disposal 1,400 cubic yards $50 $ 70,000
Maintenance 1 S100,000. $100,000
,
Subtota 1 $ 450,000
~.
~ S 9,500,000
Engi~eering and Permits (ZS~) $2,400,000
Admin:stration (15%) $1,400,000
Contingencies (2S~) $2,400,000
Total 11 6.000,900
HOTE: Fixed costs include mobilization/demobilization. set-up, construction of
staging areas, and burn tests prior to processing. -
-------
. ,..-..
TABLE 6
SLRIDT FEASIBILITY STUDY
- TAR SEEP OPERABLE UNIT
REQUIREMENTS' PARAMETERS FOR TAR PROCESSING
BY ON-SITE COLO MIX PAVEMENT FACILITY
C8D1.1!J
Pre-Design Studies
~
1
Unit
each
Excavation
':, .500 - 2~00
cubic yards
Backfill of Excavation
500 - 2300
cubic yards
Work Area Prep/Storage
Pad
1
'Mobilization Setup/
Demobilization
Material s/
,'rocess i ng/Fi na 1
Blacktop
g,OOO - 40,000
tons
~'
,.' Restoration
1
Subtotal
Engineering and Permits (25~)
Administration (15~)
Contingencies !25%)
Total
Unit S Cost
S50,OOO S50,OOO
S50 S26,000 to
$120,000
S5 S2,500 to
S12,OOO
$10,000 . S10,OOO
~..
$150,000 S150,OOO
S40 S360,000 to
$1,600,~00
f
$50,000
$50,000
~6S0,000 ~2,OOO,000
$160,000 to $500,000
S100,000 to S300,000
S160,000 to $500,000
~~,ooo to $3,300,000
-------
EVllultlon Crlterll
Over.II Protection of Humen
Heelth end the Envlrorment
compll.nee with ARAR.
Long-Te... Effectiveness
Recb:tton of Toxicity,
Mobility, or Volume
Short-Te... Effectlvenes.
I~Iementability
Cost: Clpitel
AnrAJ8 I OUt
30-Jelr Present Uorth
Stlte Acceptlne.
Community Acceptenee
0811-04-8
1 - No Action
Not Protective
lneonsletent with RCRA
Not .ff~'I'--
Not applfceble
lot eppllceble
lot eppllceble
10
10
SO
,
\,
-
TABLE 7
SLIIDT FEASIBILITY STUDY
TAR SEEP OPERABLE IIIIT
COMPARATIVE ANAL'SIS AMONG ALTERNATIVES
2 - Contllnnent
Protective of humin hellth
Compile. with .11 .ten-
dlrds. However, tlr. cln
not ,be upped In . ftood
pl.ln, end relocetlon trig-
ger. lend ben reguletlons.
Likely effective with long-
te... ..Intenenee.
Not eppllceble. MIY re-
duce mobll I ty by preventl ng
Inflltretlon of water
through cont..lnent..
"'nl..1 rl.k to workere end
the fd»tfc.
Mlterlel. end equipment .re
.vatteble.
1300,000
1 30,000
1600,000
3A - lecycleble/Burneble
"este Fuel
Protective
Compile. with ell current
.tend8rda
Effective. lesl-I. .re
I.ndfilled by tre.tMent
f.cH Ity.
Orgenlc compounds .re
de.troyed. May reduce
IIIobH Ity of lnorg_'c. by
..negement of resl_I..
Air relee... Ilbly ciJr-
Ing excavation. Poten-
tl.I for pj)llc exposure
during trensportetlon.
CUrrently I"Ietnentebie.
1100,000 to 12,100,000
o
1100,000 to 12,100,000
Concurs, accepts
Accepts
...... --'" I
...-- _. --- .-...
38 - lnelneretlon
Protective
Compll~~ with ell .tend8rdt
,- ...
Effective, but re.l-i.
requl re long- te... ...,.gement
by lendU" Ing.
Orgenlc cOft1)OU1d8 .r. des-
troyed. M.y reduce 8Gbility
of Inorganic. by 8I8Nge8ent
of reslduel..
Air rei e.... IIt.ty during
exc.v.tlon end tr..t.,.t.
Potentl.1 .Ienlflcent rl.k.
to on-.lte worker..
I.Iementebl., but .~fflc
equlfD8l't MY be wwV8H-
Bbl. .t the tl.. of re.edl-
.1 letlon.
11,400,000 to 116,000,000
o
11,400,000 to 116,000,000
3C - leuse for Pevement
Likely Protect Iv.
lequlre. w.lver of
Mlnnesote Rule. esph.1t
flcility ~ul.tlons end
ICRA euldetlne8.
Lnely .ffectlve .t
binding cont..lnant..
However, peYe8ent wi It
eventual t y ce... to be
functional.
, ,
.
"81 reduce
8Gbft Ity of orgenlc end
Inorganic c~.
Air rele.ses tlltety ciJr-
Ing exc.v.tlon end ..-
ph.1t proc...lng.
lequlres e.tentlve pre'
design testing. Pro-
ce..lng 88y not be I..
plement.ble due to .Ir
peMilt end ..terl.I.
h.ndt I n, con-
.Icteratlons, and ICRA
AlAR..
11,100,000 to 13,300,000
o
11,100,000 to 13,300,000
-------
Table 8
ARARs
SIRIDl' site
Tar Seeps Operable unit
. 0 RCRA, as amerxied b'j HSWA, 42 U.S.C. ~~ 6901 to 6992 K
o 40 ern Part 261 ~ characteristic an:! listed haza.Idoos waste
definitions an:! RCRA Toxicity O1aracteristic I.ead'UnJ Prcx~~\1re ('Ia.P)
o 40 ern Part 262 ~ off-site disposal of wastes in a RCRA lardfill
o 40 ern Part 263 ~ transport of wastes off-site to a RCRA lardfill
o 40 ern Part,,2,64 ~ general facility starrlards
o 40 ern Parts 262 an:! 264 ~ incinerator starrlards
o 40 ern Part 266 an:! SUbpart C an:! SUbparts A-N of 40 ern 264, 265,. an:! 270
~ recyclable materials used in a manner constitutirg disposal
o 40 ern Part 261.6(a) (3) (vii) ~ listed waste K087
,
o 40 ern Part 268 ~ the I.an::l Disposal Restrictions
!
,
o 40 CFR Part 264 nqarc:lj.Iq ~ cap design starrlards
o Executive order 11988 an:! 40 ern Part 6, Apperxlix A, which regulate
remedial action inplementation in floodplains
;:::-
o
Clean Air Act, Air Pollution Prevention am Control, 42 U.S.C. n 7401 to
7642
o National Ambient Air Quality Starrlards 40 CFR Part 50
o New Source Performance Starrlards for Incinerators, 40 ern Part 60, Subpart
E
o Minnesota Rules 7005.2000 through 7005.2040, Minnesota state air
~ations regardirq a..q>halt plant emissions controls, operations, air
monitorirg an:! reportirg regulations
o Federal Water Pollution Control Act, 33 U.S.C. ~U251 to 1387 regardi.rq
treatment of scrubber water
o 33 U.S.C. ~1342, Section 402, NPDES, an:! 40 ern Parts U2-U5 regardi.rq
treatment of scrubber water
o 33 U.S.C. ~1317, Section 307, Pretreatment Starrlards, an:! 40 CFP Part 403
.. regardi.rq treatment of scrubber water
-------
St. I.a1is RiverfInterlakejIW.uth Tar site
IW.uth, Minnesota
~le Unit 1
Respa~iveness Slmm:ny
INIR:XDCrIOO
'!he United States Environmental Protection Agercy (U. s. EPA) and the
Minnesota Pollution COntrol Agency (MPCA) entered into a COoperative
Agreement in April 1986 to urrlertake a Remedial Investigation and
Feasibility Study (RI/FS) for the St. Louis River/InterlakejIW.uth Tar
(SIRID!') Superfurx:i site. '!he required RI report was cxmpleted in January
1990 and a Foq.1SErl Feasibility Study (FFS) report rega.rdin;J tar seeps \tJhi.d1
occur on the site was cxmpleted in July 1990. In the RI, the nature and
extent of contamination on-site was investigated, and alternatives for
appropriate remedial action at the SIRID!' site were developed and eValuated ~
in the FFS. A Proposed Plan was then written by EPA \tJhi.c::h identified the
recarnmerxled alternative. 'lhroughout this process, public meetirgs have
been held near the site so that u.S. EPA and MPCA could" be available to
discuss the RI/FS and Proposed Plan with the public and answer their .
questions. u.s. EPA offered a 30 day public comr;Ient period on the Proposed i
Plan and FFS from July 28, 1990 to August 26, 1990. At a public meetirg ,.
held on August 15, 1990 in D.1luth, U.S. EPA presented its Proposed Plan for
the SIRID!' site. "
~
'!he purpose of this Responsiveness StmmIaIy is to docurrent the comments
received during the public comment period, and u.s. EPA's" responses to the
comments. All of the comments summarized in this document were considered
prior to u.s. EPA's final decision embodied in the Record of Decision for
the site. "
'!he Responsiveness summary is divided into the following sections:
I. Responsiveness SUrnmarv OVerview: '!his section briefly outlines the
proposed remedial alternatives as presented in the Proposed Plan,
including the recarnmerxled alternative.
II. Background on Communi tv Invol Ve1TIl'IDt: '!his section provides a brief
history of community interest and cornrm.mity relations activities
con1ucted for the SIRID!' site.
III. SUrnmarv of Public Comments Received D.1rl.J1Cl the Public Comment Period
and u.s. EPA's Responses. Both oral and written comments are ,
summarized, and followed by u.s. EPA's responses to those OCIt1I'nel1ts.
I.
Responsiveness SUrnmarv overview
On July 28, 1990, U.S. EPA made the Focused Feasibility Study (FFS)
report dated July 1990, and U.S. EPA's Proposed Plan for the SIRID!'
site, also dated July 1990, available to the public for review and
comment. '!he al ternati ves for the remedial action presented in these
documents describe methods for cleaning up the tar seeps that are
-------
2
present on-tite. U.S. EPA's Proposed Plan described five (5)
alternatives for remedial action at the site. '!be proposed rerre:lia1
al ternati ves were as follows:
Alten1ative 1 - No action - No further action would be taken at
the site to remediate the tar seeps.
Alten1ative 2 - capping - '!be tar seeps would be left in place
an:i covered with an iInpenreable cap.
Alten1ative 3A - Use as a recyclablejbumable waste fuel - '!he
tar seeps would be excavated an:i the tars bw:ned for eneJ:9Y
recovery off-site, at either a utility cx:rrpany, steel blast
furnace,.. or other similar facility.
Alternative 3B - Incineration - '!be tar seeps wa.tld be excavated
and the tars burned in either an on-site or off-site incinerator,
depen::ling on the volume of tar fouro..
Alten1ative 3C - Reuse of TarS in Pavem=nt - '!be tar seeps waild
be excavated an:i the tars reused in a paverrent product.
After careful evaluation of the RI an:i FFS for the SIRIDl' site, the U.S.
EPA selected Altexnative 3A as its preferred alternative in the Proposed
Plan.
'!be following parties submitted fomal written comments durirg the p.Jblic
canment period:
....-
1. William J. Andersen
Citizen - SUperior, wisconsin
2. Grant L. Johnson
Senior Vice President/General Ca.msel
'!be. Interlake Corporation
Nurrerous parties provided verbal comments during the p.Jblic hearirg
portion of the August 15, 1990 Proposed Plan public meeting. '!bose parties
included:
1. William Spehar
2. Joe stifold .
3. Allan GtnTmert.
4. William Arrlel'sen
5. Jerome Bosidl
6. Tim I..elan:i
II. Backgra.md on Community Involvement
'!be Minnesota Pollution Control Agency (MPCA) leamed of the site when a
local resident reported oil rising to the surface of St%yker Embayment,
apparently from the slow release of oil fre:.:! the sedi1nents. "Oil slicks"
are a camrcon occurrence on the embayment.
MPCA staff inspected the site in July and NoveJnber 1981. '!be U.S. EPA
corrlucted a preliminary assessment of the site on February 16, 1983, arxi a
site investigation on May 27, 1983. In 1983, the U.S. EPA consolidated the
-------
3
SIRIDI' site am the St. Louis River/U.S. steel site am added the1n to the
National Priorities List (NFL) as one site-the st. Louis River site.
Although the two sites are listed as one on the NFL, they are beirg
investigated am will be addressed separately.
Because no Potentially Responsible Party (ffiP) was fOLU'Xi who was willirg to
urrlertake the SlRIDI' site investigation am cleanup, the MPCA am u.s. EPA
executed an acp:ee:lLent in April 1986 for the MPCA to conduct a ~ial
Investigation (RI) usirg IIDney fran the Federal Superfurxi. '!he
investigation was delayed because the fun::li.rq mechanism for the Federal
Superfurxi expired in OCtober 1985 am was not reauthorized by a:m;ress
until a year later. '!he MPCA began the RI in the summer of 1987. 'IW
Ji1ases of investigation were conducted, am the RI report, which n;~ses
these two phaseS, was reviewed am approved by both MPCA am U. S. EPA in
February 1990. '!he RIReport was then placed in theinfonnation repository
at the n.1l.uth Public Library for public review. .
A site-wide feasibility study was started; however, it becaIre apparent that
treatability studies on the soils am sediments were necessary due to the
large volumes of contaminated media and the potentially high costs
associated with remediation. since the tars cou1d be addressed at the ;
present time, am due to a strong desire to begin cleanup on-site, it was !
decided to separate out the tar seeps operable unit. A Focused Feasibility f
Study (FFS) describing several cleanup alternatives for this operable unit .
was c:x:mpleted in July 1990.
p"'.
'!he St. Louis RiverjInterlakejn.1l.uth Tar site has generated a great deal of
public interest. SUperfurrl activities at the site have also received
attention from local organizations, public officials, and the Iredia.
Conmmity relations have largely been handled by HPCA. MPCA prepared a
ComrmJnity Relations Plan (CRP) in June 1987 for the site. '!he CRP outlined
a commLD'1ity relations strategy to apply to the SlRIDI' site. A p..1blic
m=eting was held in July of 1988, and numerous fact sheets have been
published to keep'the public infoI1nErl of site activities. on March 27,
1990, a meeting was held with a local group known as the Technical Advisory
Committee arrl, later that day, with the general public, tc discuss the
results of thl' RI. on July 28, 1990, after conpletion of the Operable unit
FFS for the tar seeps, the FFS am Proposed Plan, which describes EPA's
preferred cleanu:.> alternative, were placed in the Information Repository
located at the n.1l.uth Public Library. on that day, a notice of th~ir
availability was published in the n.1l.uth News Tribune. '!he Administrative
Record has also been w.ide available for public review at the librarj.
To encourage public participation in the remedy selection process, u.s. EPA
set a 30-day romnent period from July 28, 1990, through August 26, 1990,
during which comments on the Proposed Plan am FFS WOl,1d be accepted. A
public m=eting was held on August 15, 1990, to diso.JSs the Proposed Plan,
accept verbal comments on it, am to answer questions. U. S. EPA accepted
verbal romnents at the meeting, and written romnents through August 26,
1990. Specific responses to romnents are presented in Section III of this
Responsiveness Stnmnary.
-------
4
III. SUmmaJ:v of Comments Received D-lri.nq the P..1blic Comment Period
and U. s. EPA' s Response to Comments
O:muTIents raised during the St. Louis River/InterlakejI).l1uth Tar site
Proposed Plan public camment period are summarized below. O:mnents
are organized ard paraphrased in order to effectively summarize am
respord to them in this document. '!be reader is referred to the
" actual camments ard the transcript of the public meeting (formal
c:x.mnents start on page 49) in the Administrative Record.
I. Comments Received from the P..1blic D-lri.nq the AUQUSt 15. 1990 Piooosed
Plan P..1blia Heari.nq
I. A. Comment
-"
Mr. William Spehar ard Mr. Joe stifold, citizens of J:W.uth, ead1
made comments regarding the Engineer's Realty De1oolition Iardfill
located in Ga1:y-New J:W.uth. Both expressed disappointment that the
MPCA would not provide any information regarding the facility.
,
!
f
I.A. Response
'!he Engineer's Realty De:rrolition Landfill could not be di~
because the Minnesota Attorney General's office has closed
the MPC,A's files on the larntill perxiinJ possible civil legal
action. '!be MPCA issued a news release on September 14, 1990
stating that the MPCA citizens board will role on closing the
lardfill 'at a meeting to be held on September 25, 1990. '!be
lardfill is not a SUperfund site ard is not connected in any
way to the st. Louis River/Interlake/J:W.uth Tar SUperfund site.
I. B. Comment
Mr. Allan Gurnrrert, D..1luth citizen, cammented that he felt the
MPCA ard EPA were doing "a great job." He also expressed hope
that all agencie!: involved with environmental issues in the ~.a
would coordinate '::heir efforts ard their furdi.ng to produce
"greater overall impact and a better end result".
I. B. Response
'!be agencies thank Mr. GuIr.mert for his support of their efforts.
MPCA ard EPA have communicated with the u.s. ArmY CotpS of
Engineers, the City of J:W.uth, and the Wisconsin Deparb'nent of
Natural Resources regarding activities taking place on ard near
the site. '!be site is also a part of a Remedial Action P~.:m
(RAP). RAPs deal with Areas of Concern (ACe) on ard near.the
Great Lakes. When ccmplete, the RAP report will be submitted to
the International Joint Commission, which deals with Great lakes
area cleanups in the United states and Canada. While furdi.ng
for each of the agencies mentioned is separate ard distinct,
-------
5
every effort will be made to ensure that the ~rk each agen=y
does will be coordinate::i with the others in order to benefit the
area as a whole. RAP coordinators are especially active in
wcrkinJ toward this en:i.
I. C. Comment.
Bill Arrlersen, citizen of SUperior, Wisconsin, oanmented that the
am:::Illnt of cx:m1merCial activity occurring on the site shoold be
reduced because such acti vi ty may be stirring up dust into the air.
He suggested that we consider closing the facilities until the site
is cleaned up.
; t.'
I. C. Resoonse i
'!he am:::Illnt of dust generate::i by active facilities has not yet
been thoroughly defined. '!his will be investigate::i further in the
secorrl operable unit. As such, there are no grourrls for closing
the facilities. '!he current operable unit deals only with the
tar seeps present on-site.
~
!
,
I. D. Comment
....--=
Jerane Basich, citizen of D..1luth, oommente::i that he is disappointe::i
about the quality of the investigation am the length of time
the investigation has taken. He does not believe that the agencies
have determined the extent of the contamination. He feels he could
conduct an investigation "checkinJ every cubic foot of the site
using only four or five men". He feels the agencies should "get
going" .
I. D. Resoonse
'!he agencies recognize Mr. Basich's frustration. '!he SUperfun:i
process is 'very complicate::i, am the time between site discovery,
investigation, am cleanup often spans several years. '!his site
is very large, and it has tG.ken time to detenni.ne the extent of
contamination a.n:l to detennine how best to clean it up. While
Mr. Basich does not feel that the extent of contamination has
been defined, the agencies feel it has. '!he volume of material
has not been precisely detennined, b'lt the areal extent of
contamination is known. '!he volume cf tar cannot be precisely
determined until the tar is excavated. '!he agencies are workinJ .
diligently to begin treatability studies on the sediments am soils
so that the best remedy for the rest of the site can be selected.
'!he tars will be excavate::i and treate::i within the next year.
I. E. Comment
Tim Leland, D..1luth citizen, comrnente::i that he wants the embayment
cleaned up in the very near future. He lives by the river, am .
enjoys using am fishing it. New homes are being . built in the
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6
area, arrl- a waterfront trail has been built next to the embayment.
Signs were put up warning people not to swiIn or fish am people
are bej,n;J scared away. Enough testj,n;J has been done. '!be
embayment is a small, m:mageable area that could easily be closed
off, purrped out, arrl cleaned up. He wants action to be taken soon.
I. E. ResPonse
'!he agencies are also interested in havj,n;J the embayment cleaned
up. Plans for a bioremediation treatability study to be c:x::arpleted
next sprj,n;J/summer on sorre of the embayment sediments are in the
works. SUch a test is necessary to detennine if this method can
effectiV~ly destroy the tars present in the embayment sa:timents. If
the test 'works, biorernediation will be used to clean up all of the
contaminated sedilnents. While the embayment could be closed off, -
the cleanup would still be very difficult arrl quite expensive. '!he -
Agencies are taJc:inJ steps to involve the parties responsible for the .
contamination in the cleanup process arrl to hav~ them pay for the
actions taken.
II. Written Comments Received D..1ring the Publ ic ~t Period arrl U. S.
EPA's Response to Comments
!
,
II. A. Comment
::.--
Mr. William J. Arrlersen of SUperior, wisconsin submitted written
comments at the public meetj,n;J held on August 15, 1990 in D..1luth,
Minnesota, am submitted additional written comments by mail. His
oamments were as follows. Comment 1 deals with information submitted at
the public meetj,n;J. Comments 2 through 5 were provided by mail in a
letter dated August 25, 1990.
1. At the public meetj,n;J, Mr. Andersen submitted two letters regarcti.nJ
harbor and channel modifications and dredgj,n;J operations in the area
near the site., One letter, dated March 5, 1981 and addressed to C.H.
GrWy of the Hallett Dx:k Corrpany by Alden E. LiIrl, discusses
consolidation of businesses operatj,n;J on hm:bor frontage to increase
efficiency, lessen the need for dredging, Lnprove fish and wildlife
habitat, and enhance recreational activities in the harbor and river
area. '!he other letter, dated August 16, 1983, deals .with the u.S. Arrrry
Corps of Engineers' (U.S. ACE) plan to dredge the river am deposit the
sedi1nents in the SUperior, Wisconsin Municipal Fore...c1:. '!he adequacy of
the storage facility was questioned. Also, it was noted that dredgj,n;J
could interfere with spawnj,n;J activities of fish in the area. 'Ibis
letter was written by William Andersen and addressed to the u.S. ACE.
- .
2. r.fi:'. Arrlersen requested an extension of the public comment period in
order to hold another public hearj,n;J in SUperior, Wisconsin, because it
was not previously Jma...1n that a portion of the site was located in
SUperior. -
3. He requested that the site boundaries be extended to include the tar
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7
blanket ext.erni.ng into the open waters of the St. Louis River am
additional oontaminated sediments which othawise wcW.d be dredged
durin:J the proposed D.1luth - SUperior Harbor Olannel Modification
Project.
4. He asked that if incineration were the remedial alternative chosen, that
the effluent starrlards be clearly identified in advance am that
mnitorin:J by a public agency be required to assure cc:mplianoe with
those starrlards.
5. He stated that it was not his intention to delay this iItportant project.
He requested that the EPA direct the MPCA am wmR to immediately take
steps to ~ze the flow of tars into the St. Louis River.
II. A. Response
~
~
1. 'Ihe U. S. EPA' s Proposed Plan for cleaning up the tar seeps at the SIRIUl'
site will not have an :impact on the acti vi ties mentioned in the letters
Mr. Arrlersen provided. With regard to the first letter, the Office of
. Superfund has no authority to iltplement oonsolidation of 1an:i use. As
to the seoorrl letter, the EPA an:i MPCA have ~ infonned of U ~ S. ACE
plans for dredging the river near the SIRIDr site as part of the
"Harbor an:i 01anne1 Modifications: D.1luth - SUperior Harbor,
Minnesota arrl Wisconsin" Project. Both agencies have comrrented on the
plan. It is their hope that the harbor arrl channel project will be
coordinated with the St. I.Duis River RAP, an:i that the enviromnental
inpacts of the dredge project will be fully assessed.' 'Ihe dredge plan
called for the sediments to be deposited on the SIRIDr site itself, on
Erie Pier, or in the SUperior Forest facility. ().Jr comments objected
to the proposal for diSPOSal on the SIRIDr site, an:i requested further
information regarding the suitability of the Erie Pier an:i SUperior
facilities. Future activities at the SIRIDr site nay involve dredging:
at that time, spawning runs will be taken into oonsideration to minimize
the :impact on the fish population as much as possible.
2. A letter was sent to Mr. Arrlersen on September 7, 1990 that denied the
request for the extension and explained the reasons fc.'r it. However,
the letter was returned. . '!he reasons for denial are llste:l bela.r:
!
,
o Mr. Arrlersen stated that it was not previously known that part of the
site is in SUperior, Wisconsin. However, EPA and MPCA did indeed know
that was the case. 'Ihe Wisconsin Deparbnent of Natural Resources (wrNR) .
also is aware of the cirCLm1Stances and has advised the MPCA to oorrluct
the necessary actions at the site. wa-m has asked only that they be
kept infonned of site activities. Accordingly, the WI:NR is on the site
nailing list arrl is aware of the proposed remedy. .
o 'Ihe ~rtion of the site that is presently beirq addressed is not in
SUperior. When action is taken on those parts of the site that are
oonsidered to be in Wisconsin, further wa-m input will be sought.
o It is not practical to hold two public meetings on the same site.
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8
.
Interested citizens from SUperior may atterxi the meetirgs held in
D..1l uth .
o The request was not submitted in a timely manner. A request for an
extension must be submitted in the first half of the public camment
period. The request was post:marked on the last day of the public
comment period.
3. 'Ihe site bc:>urdaries do include the tar blanket that exterrls into the St.
Louis River. '!he site cannot, however, be exteIrled to include all other
contaminated se:llinent that may be dredged durin:] the proposed D..1luth -
SUperior HaJ:bor O1annel Modification Project. '!hat project will be
reviewed bY the Environmental Review Branch of the u.s. EPA in Region 5,
but is not regulated urder the SUperf'urd program. '!here is also a
Remedial Action Plan (RAP) which deals with pollution in the St. Louis
River System. Dre1ging of contaminated se:llinents in the boat slip,
Stryker Embayment, and off the eIrl of the 54th Avenue Peninsula may be
corrlucted as part of the SIRIDI' site cleanup. .
-
:-
4. Incineration is not the chosen remedy. '!he tar will be excavated am ;
used as a recyclablejburnable waste fuel. '!he facility at which the I
tar is burned must be acceptable to EPA am MPCA am meet applicable,
emissions standards. SUch facilities are subject to mnitoring by state
agencies to ensure conpliance with emissions regulations. '!he next
phase of the SIRIIJI' site project is remedial design. In this phase,
facilities will be evaluated arrl MPCA arrl EPA will make a deteImination
as to their suitability for burning the tar.
5. The agencies recognize that Mr. Andersen does not inteIrl to delay the
project, and appreciate his concern arrl his input. EPA am MPCA are
working to minimize further contamination of the St. Louis River, am to
clean up the remainder of the site as soon as possible.. WtNR is kept
infonned of site activities, as mentioned previously. '!he agencies
would like to clarify that tars are not presently flowing into the
river. '!here is a possibility that erosion is dispersing some tar
particles from tar seeps into the river; also, tars are present in the
river sediments. Tars are not, however, presently being dischaz\;Jed into
the st. IDuis River.
II. B. Corronent
Grant L. Johnson, Senior Vice President and General Counsel for the
Interlake Corporation, submitted a letter, as well as comments on the
FFS am the Proposed Plan that were prepared by Interlake's consultin:]
firm, International Technology Corporation (IT). '!he Interlake
Corporation is a Potentially Responsible Party (PRP) for the
contamination present at the SlRIIJI' site. '!he following camments were
made.
General Corronents
1.
Interlake and IT have based their comments on the asSUI'!'ption that the
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9
extent of tar seep contamination is as est.iJnated in the studies
urdertaken to date. Should excavation of the material reveal that the
anount of tar is substantially greater than previously estimated, an::!
that remedial action costs are substantially greater, the :te.medy
selection process should be revisited.
2. Interlake supports the approach of divid.in;J the site into "operable"
units for purposes of identifyin;J the persons potentially responsible
for urdert:aki.rg remedial action or for payin;J the costs of remedial
action. For exarrple, same tar seeps are on property fonnerly owne::l by
the Interlake Corporation, while one is on property fonrerly owne::l by
a tar ccmpany. '!he embaynent was contaminated by activities ergaged in
by the t,ap: oarrpanies, an:i not by Interlake. A distinction should be
made between the Interlake portion of the site arxl thOse portions of
the site that are the responsibility of the tar c::dIrpani.es arxl their
successors .
3. Interlake did not undertake the RIIFS when asked to do so in 1985
because at that t:i1ne, the agencies were conoerned only with the
embaynent, arrl Interlake was not responsible for contamination of the
embayment. Although Interlake sold tar to tl!e tar c::dIrpani.es on-site,
Interlake did not "arrange for treatment or disposal" with those
c::dIrpani.es an:i thus was not liable for contamination of the embayment.
'!be MPCA project manager agreed with this intapretation of SUperf\.1m
statutes .
...-
4. Responsibility for site contamination could not be ascertained until
conpletion of the RI. '!be RI expanded the areas of concern to areas
fonrerly owned arrl operated by Interlake. Since then, the Interlake
Corporation has cooperated with the agencies in attenptin;J to develop
appropriate remedies. Interlake also conducted a PRP search arxl
provided a copy of the report to MPCA.
Technical Comments on the Focused Feasibility Study
5. '!be FFS states on page 2-1 that certain Applicable or Relevant an::!
Appropriate Requirements (ARARs) ~ to tar seeps, arxl later says
. that these requirements are relevant and appropriate, but not
applicable. IT believes these regulations are at most, relevant arrl
appropriate. 'Ibis distinction is most :iJTportant for cap designs arxl
ult.iJnate disposal of soil incinerated on-site.
.' .
6. ?age 2-2 arxl 2-3, Section 2.2.1 and 2.2.2. Each of these sections
indicate that metals including arsenic, beryllium, chromium, lead arrl
mercw:y are contaminants of interest identified for tars. 'lhese
statements are not supported by Appendix A nor the data collected in
the Remedial Investigation. As is indicated in the Proposed Plan for
the site, it should be clearly stated in the FFS that the only
constituents of concern for the tar seeps are the polynuclear aranatic
hydrocarbons (PAHs).
7. Page 3-1, Section 3.1.2.
IT believes that the wastes present at the
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10
site are PreQami.naI1tly not K087 wastes. '!here are nuITerOUS technical
differences between the coal tar that predaminates t.hrougl"loot the site
arrl the RCRA-listed K087 wastes. IT has previously enumerated these
differences in a letter to MPCA dated June 13, 1990. IT believes that
once excavated, the coal tar may be identified as characteristically
hazardous ~ virtue of its benzene content but it should not be
categorized as the listed K087 waste.
8.
Page 3-1, Section 3.1.2 appears to conclude that if an ARAR is relevant
. arrl appropriate, its standards must be met. '!his is incorrect. Where
RCRA regulations are considered relevant arrl appropriate, their design
standards should represent a point of departure for identifyirg an
appropria~,site-~c reIredy at the SUperfund site. Even if the
listed K087 RCRA s were relevant arrl appropriate, that
conclusion alone does not result in the need for an 8 foot thick cap.
Clearly the remedial objectives, the limited areal nature of the seeps -.
arrl the present uses of the site dictate the need fo~ a thinner cap.
'!his alternative should be modified to reflect a thinner cap that is
ITOre consistent with site-specific conditions.
Page 4-7, Section 4.2.4.1. '!his section, de$Cribirg the on-site ;
incineration alternative, states that "ash from on-site incineration !
will be landfilled off-site. II IT believes this assunption is erroneous,
am not consistent with the site-specific corm.tions. As denonstrated .
in Apperdix A arrl as verified in EPA's Proposed Plan for the site, the
sole constituents of concern for the tar seep material are PAHs. If
the on-site .incineration equipment meets the RCRA starrlard for
destnlction efficiency, the resulting soil/ash will clearly meet the
risk-based value of less than eight ppm total carcinogenic PAHs. since
the starrlards for the listed K087 waste are not applicable, but are
only relevant and appropriate, the criteria for on-site replacement of
the treated soil should revert to the health-risk value of eight .PIE.
Applying this approach, the treated soil could be placed back at its
point of origin or elsewhere on the site. It is wholly inappropriate
to conclude that after COITplete on-site decontamination of soil, it
must also be transported off-site for RCRA disposal. IT recammerrls
tl.at this alternative be modified to facilitate on-site placement of
tr.~ted soil should it meet the cleanup objective of eight ppn.
10. Table. 2-1. '!he criteria in this table should be modified to accurately
reflect the criteria standard in the National Contingency Plan. '!his
standard allows a 10-4 to 10-6 range of incremental cancer risk exposure.
9.
11.
Figure 3-1. '!he type of cap envisioned to oover the. tar seeps in areas A
arrl E should be revised to reflect a ITOre ITOdest thickness consistent with
the objective of preventing infiltration, direct contact, arrl erosion of
the tar material.
12.
section 4.0, Paragraph 2 of Apperrlix A contains a typl-yLaphical error.
Use of the oral potency factor may lead to an overestiJnate of risk
potential for skin cancer, not an underestiJnate.
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~.
11
Section 4.1 of Appen:lix A. 'Ibe Report concludes that the 1'maxiJmJ:m
contaminant level" found at the site in the tar seeps for arsenic is 4.7
ppm. SUd1 a conclusion is not factually based in the RI. '!be reported
value is less than half of the Contract Required Detection Limit for this
constituent am the spike recoveries on the QC sanples were not within
control limits. 'Ibe value is suspect am therefore ina~ropriate for use
in risk assessrrent. '!his appen:iix should clearly conclude that PAHs are
the sole group of constituents of concern for the tar seep operable unit.
Comments Recfardina U. s. EPA' s Prooosed Plan
13.
14.
Page 4, First paragraph. IT Corporation does not COno.Jr with the .
estimated .potential range in cost for remediation of the site. Altha.tgh
potential costs for remediation of SUperfund sites typically range Oller
several orders of magnitude during initial studies, IT has seen no
information (including previous draft FS's) that leads us to believe the--
potential costs approad1 $100,000,000. Even as an upper bourxi, it is
OIlerstated am poorly estimated.
Page 6, First paragraph. IT continues to disagree with u.s. EPA regardin;J
the application of regulations governing K081. wastes as relevant am ;
applicable standards for the coal tars found at the site. Although the!
tars are similar to K087 wastes, EPA had the opportunity to list coal ~
as K087 wastes when initially writing the regulation. EPA elected to .
narrow the range to coal tar decanter sludges. Consequently, at this time
it is inappropriate to ~ the definition to include coal tars in
general. Additional arguments against the use of K087 regulations as
relevant and appropriate were presented in letters to Mr. Cliff 'lWaroski
of MPCA fram IT Corporation dated June 13 am July 13, 1990.
15.
16.
Page 7, Alternative 3C. '!his paragraph indicates that metals are a
constituent of concern in the tar seep materials arrl that these metals
would be diluted by the process.' 'Ibe record should clearly state that
metals are not a constituent of concern for the tar seep areas.
17.
Page 9, IlCOIrpliance with ARARs". 'Ibis paragraph states that relocating
tars fram th.~ floc:dplain. would constitute pla~t under RCRA am would
trigger land Disposal Restrictions (!DR). As an ARAR, EPA should
indicate its authority to exeJTpt RrnA IDR for "placement" of soil an:!
debris fram SUpo..rfund sites. 'Ibis exemption could facilitate the
excavation, treatment and placement of tar seep material at the site.
Page 9, "long-Term Effectiveness and Permanence". '!be first paragraph
under this heading is internally inconsistent. It states that Alternative
3B would destroy the cPAHs in the contaminated tars am that the long-tenn
risk of exposure to the tars would be eliminated. However, it goes on to
conclude that after this complete destruction of the risk, the ash would
be treated as necessary and disposed of in a RCRA c::anpliant unit to
prevent the possibility of human contact. As stated in our comments on
the Final Feasibility study, IT believes there is no need to renove the
treated soil/ash if the on-site incinerator treats the tany material to
a concentration below eight pprn--the threshold of concern calculated in
.,,:-"
18.
f
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12
Appen:lix A of the Final Feasibility Study. '!he National Contin;Jency Plan
allows for placement of incinerated soil/ash back on a Superfun:i site when
the risk has been adequately reduced or eliminated.
II. B. Resoonse
Response to General Comments
1. 'Ihe costs presented may vary by up to 50% greater or 30% less than
originally estimated. If the costs are out of this ran;]e, the agencies
may elect to reconsider the remedy selected am to reevaluate its cost-
effectiveness. If a different remedy is selected, an ~lanation of
Significant ,Differences dOCLm'leI1t will be prepared am presented for p.1blic
c::amment. "
2.
'!he agencies divide sites into operable units when it makes sense to do -
so am aids the cleanup process. '!he agencies have not yet determined if
the rest of the. site will be broken out into separate operable units, or
hC'M such a breakdCMn would be done. Formal detenninations of liability
have not yet been made.
;:::..
: i
3. '!he agencies have not yet made fomal detenninations of liability. It "
should be noted that there are differences between the Minnesota .
Environmental Response and Liability Act (MERIA), Minnesota's Superfun:i
law, am the COmprehensive Environmental Response, COmpensation, am
Liability Act (CERCIA), the Federal Superfun:i law. MPCA is not
responsible for interpreting CERCIA. While ideally, each responsible
party will pay for its fair share of the cleanup, there are provisions
urder CERCIA for joint and several liability.
4. rrhe agencies recognize the cooperation shCMn recently by the Interlake
Corporation, and appreciate their efforts in corrlucting a PRP search.
Response to Technical Comments on the Focused Feasibilitv Study
. .
5. '!he regulations are rel~vant and appropriate to the cleanup. Relevant am
appropriate requirement...:; mean those cleanup standards which address
problems or situations sufficiently similar to those encountered at the
CERCIA site such that their use is well-suited to the particular site.
Once a requirement is detel"T!\ine1 to be relevant and 'appropriate, it must
be cx:mplied with as if it were c.pplicable. '!he detennination of relevant
and appropriate relies on profes~~ional judgment, considering environmental
and technical factors at. the site. '!he cap designs presented are relevant
am appropriate for the cont:ami.riation fcurd on-site. Incinerated soil is
discussed in the response to Comment 9. Please note that neither cappirg
nor incineration was selected as the remedy for the tar seeps.
6. '!he metals were named as contaminants of concern for the tar .seeps in the
FFS. rrhe Proposed Plan, while naming several contaminants of concern,
states that the major contaminants of concern for the tar seeps -are the
carcinogenic Polynuclear Aromatic Hydrocart>ons (cPAHs). '!he cPAHs are
driving the cleanup. '!he EPA is concerned that metals may concentrate in
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13
the ash which results fram burning of the tars, am will ensure that the
ash is disposed of properly.
;,.--
7. '!he wastes at this site have been identified in both the RI am FFS as
coal tars fram coking operations. 'Ibe wastes were deposited prior to the
effective date of RCRA. Also, although the waste at this site is known to
have been generated fram coking operations, it is not clear if this waste
meets the definition of K087, decanter tank tar sludge fran c::okin:J
operations. '!he waste is, nonetheless, sufficiently similar to K087 for
RCRA to be relevant am appropriate.
S. Once a requirement is determined to be relevant am appropriate, it mJSt
be COIt'plied .with as if it were applicable. Relevant am appropriate
design starrlards have been considered for the site remedy. '!he cap
discussed in the FFS am Proposed Plan is described as bein;J 1m. to eight-
feet thick. 'Ibis thickness could vary, but the cap must be iInpenneable,-
am allow for frost protection. 'IWo types of caps are described in the
documents which vary depending upon the land use in the area where the tar
seep is located. Please note that capping was not the remedy selected for
the site. - . ;
~ I
. ~ . .
9. 'Ibe main constituents of concern for the tar seeps are cPAHs. However, I
there was concern durin;J development of the incineration alternative.
regarding whether the metals that are present in the tars ~d
concentrate in the ash. After incineration, the ash would be tested. If
metals were present in the ash at high levels (above - Best [)em:)nstrated
Available Technology, or BDAT levels), they would be treated and disp:>sed
of off-site in a RCRA COIt'pliant landfill because it would not be feasible
to build a RCRA unit on-site. If all contaminants in the ash were below
levels of concern, the agencies would consider other methods of disposal.
Please note that incineration was not chosen as the remedy for the tar
seeps operable unit. Also, note that relevant am appropriate .
requirements must be complied with as if they were applicable.
10.
'Ibe table states the following remedial action objective: "[p]revent
significant inpact to human health due to skin contact and inhalation
exposures. " '!he criteria for this obj ecti ve concerns concentrations of
PARs present in the tars which correspond to a lifetime incremental
cancer risk via contact exposure of greater than 10-6 (one in one
million) . 'Ibis table is correct. 10- 6 is the "point of departure", the
risk level above which remedial action can ~ taken.
See Response #8. 'Ibe cap is described as bein;J 1m to 8 feet thick. 'Ibe
cap would be designed to prevent infiltration, clirect contact, am erosion
of tar material, as well as provide frost protection. caPPinJ was not
chosen as the remedy for the tar seeps.
12. After checking with Malcolm Pirnie, Inc., the authors of the :FFS, it was
determined that there was not a typographical error made. Use of the oral
potency factor may lead to an underestimate of risk potential for skin
cancer. .
11.
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14
13. Review of the data has irrlicated that it is acceptable for use. '!he Risk
Assessment stated that a level of 1 n-g/kg Arsenic was associated with a 1
in 1 million (lxlO-6) excess cancer risk. for workers. '!he maxi1m.nn level
of arsenic foUJ"d. in tar seeps was 4.7 n-gLkg. In ccmparison, a level of 8
n-g/kg of cPAHs was associated with a 10-6 excess cancer risk. '!he
maximum level of cPAHs foUJ"d was 20,900 n-g/kg. CPAHs are the main
contaminants of concern, arrl are driving the cleanup.
Response to Comments ReQardinq U. S. EPA' s Prooosed Plan
14. '!be costs were calculated based on tables prepared for the site-wide draft
feasibility study report, which has not yet been ccmpleted. COsts
included remediation of sediments, soils, surface water, arrl groun:1 water.
'!be potential for the site-wide remedy to cost $100,000,000 does exist.
'!be actual cost may not be that high, deperxling on the remedy chosen.
;::;
See Response #7. K087 is defined as "decanter tank tar sludge fram cokin;J
operations". '!be tar at the SIRIDI' site is silnilar to K087. RrnA is
relevant arrl appropriate.
16. '!he main contaminants of concern in the tar m the cPAHs. Same rretals I
are present in the tar at low levels. i
17. EPA did state that relocatil'lg tars that are located in the floodplain to
other areas of the site without treating them first would constitute
placement. '!be EPA can obtain a variance or waiver fram the ~ IL'R for
placement of soil arrl debris originating from SUperf'urxi sites. Hawever,
the EPA does not believe that the tar can be considered either soil or
debris. Even if such a variance or waiver was obtained, capping would not
be the preferred remedy.
15.
18. While cPAHs would be destroyed by incineration, incinerator ash could
possibly contain higher concentrations of rretals than the tar itself. '!he
ash would have to meet BOAT standards for the rretals present. If it did
not, it would 'have to be treated arrl larrlfilled in a ~ ccmpliant unit.
If the ash were to meet health-based arrl BD.lcr' standards, the agencies may
::onsider other disposal methods. Incineration was not chosen as the .
remedy for the tar seeps.
III. Re."\3ininq Concerns
'!he follCJtJing concerns were noted during the question curl answer portion
of the P\ililic meeting.
A. How will the waste be transported?
B. will existing businesses on the site be r..:wed?
c. Will the whole area be cleaned up, or just certain parts of the site?
D. Why does the cleanup process take so long?
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15
.
E. Why isn't bioremediation being used on the tars?
F. Who will pay for the cleanup?
G. Will the enpayment be cleaned up?
H. Will other debris (glass, metal, etc.) be renx:wed from the embayment
during cleanup?
I. Where will the ash be disposed of? Will it be lan:lfilled in n.1l.uth?
J. Where will the tar be burned?
". ,
K. Will river dredging near the site as part of the channel nolificatian
project increase the rate at which contaminants fran the sediJrents an-site
will be transported into the st. lDuis River? ".
III. Responses to Rernaininq Concerns
A.
'!he waste would most likely be transported by tanker truck. DJ..'t"llg the ;
Remedial resign phase, issues such as this are investigated, and the be!t
way to transport the waste will be determined. '!he waste walld be ,
manifested to ensure it ends up at the facility EPA has chosen to treat .
it. A paper trail will follCM the waste.
B. '!he businesses will not have to be moved. Access to contaminated areas of
their property will have to be obtained to allCM for cleanup. '!he areas "
will be mom tored to ensure that the businesses do not further contaminate
the portions of the site addressed under this remedial action. .
....-
c.
'!he portions of the site that shCM contamination above health-based levels
will be subject to cleanup. Contamination is not present on all 230 acres
of the site.
D. '!he SUperfund 'Process is verj corrplicated and often takes several years to
corrplete. once a site is discovered it must be thoroughly investigated to
determine the type and extent of contamination. Often, the voltnne of '
contaminated media can only be estimated. Studies must ~1en be done to
detenrine the best way to clean up the contaminants present.. Many
technologies u.~ are corrplex and take a long ti1ne to i1Tplen:ent. Legal
issues often arise 4-.hat can slow the process dCMJ1. Fundirg shortages can
also cause delays.
E. '!he contaminants in the tars are too highly concentrated for bioremedi-
ation of the tars to be viable. A national team of experts, the EPA's
STAR!' team, evaluated this option and did not think it would work on the
tap;. Biorernediation is, however, being considered for use on both soils
and sediJrents as part of the future operable unit.
F. '!he MPCA is in the process of contacting parties believed to have caused
the contamination at the SIRIDI' site. MPCA will take enforcement actions
against such Potentially Responsible Parties (PRPs) to force them to pay
-------
16
for, an:i perhaps conduct, the cleanup. If such efforts are not
sucx::essful, the SUperfund will be used to pay for the clearrop, an:i PRPs
will later be sued for recoIIery of cleanup costs.
G. '!he MPCA an:i EPA feel strongly that the embayrrent should be cleaned up.
CX1r pri.rnaJ:y goal is protection of htm\a11 health an:i the enviroranent. '!he
agencies will conduct further studies to detennine how best to clean up
the embayrrent.
Debris in the embayrrent will a1lrost undoubtedly have to be :rem::wed in
order.to proceed with any cleanup alternative.
H.
I. '!he agencfes have not yet determined the exact location for ash disposal.
SUch details will be worked out in Remedial Design. '!he disposal
facilities will have to be acceptable toEPA an:i MPCA. '!he.ash will have
to be treatErl in a proper manner. None of the facilities that have been'
considered for treabnent of the tar are located in D.lluth. Ash would 1rOSt
likely be disposed of near the location of the facility where the tar was
burned.
~
. -
J. '!he agencies have not yet detennined the exa~ location of the trea~
facility. utility companies including the Northern states Power (NS~) i-
facility in Minneapolis, and two Minnesota Power facilities, one in Gran1
Rapids, am the other in Aurora-Hoyt lakes, have been considered. (One
resident recommended that Minnesota Power an:i Light be utilized.) Blast
FUmaces would likely be locatErl out of state. '!he regulatoI}' agencies
will make the final decision on the treabnent facility in the Remedial
Design ~.
K. '!he channel modification project has been in the works for a number of
years. A date for dredging has not yet been set. '!here is a chance that
site contamination could be removed before the larger dredging project
takes place. If the channel modification project does occur first, the
o.J.rrent of the river near the site might be increased. Contaminants in
the "tar blanket" off the 54th Peninsula Avenue may be affected by this.
ContaminatErl sediments in the boat slip and embayment are recessed fran
the river, however, and would not likely be affected.
-------
,'I . ".
9C
ADkI.lsrRArIVI RICORD I.DEI
usrp}, Rt.tdlal Action SuptrfuDd Eitt
St. Loois RiverlIDterlatt-Dulotb rar , Cbe.ica!/US Steel
Dulutb, «iDDelota
1!TRAkf FAGrS DArr
rHLl
AurHOR
R!CIPm'~
DOCOkur rrPl
DOCJUIfW
2 00100100 Lttttr iro. tbt USEPA CODstaDtelos, USEPA lritau, IDterlake CorulpoDdeDce
offerlDg PRPs tbe IroD
oppertuDity to
voluctarily ,
UD dutde a 'Ruedi al
IDvestigatioDlfeasibility
Stady
5 85108/30 Letter offering IDterlate CODstaote]os. OSEPA Erihu. IDter late CorrespoDdeDce 2
1::, tbe tfp:rtutity to Irc.
roluttarily perfor. tbe
~ort rtquired to abate ~
'Df rele.se or tbre.teDed ~
release of hazardous
substaDCU
85/10/0J Letter fro. IDterlake Porcelli. IDterlate Iron Oats. USEn CorrespondeDce 3
Iret
lndicatJDg tbat tbey are
~ilIJDg to uDdertate aDY
"nHessary and
appropriate
actioDs" , bo~e;er tbey
are uncertai. of ~bf
tbey are considered a
PRP and ~by tbe ~jte
bas beet llsted on
tbe National Prioritles
Llst
2 86/0J1J6 Lttter actDo~ledgjng CcnstaDtelos, USIPA Percell I. Interlake CorrfspcD~eoce
recelpt of 10-1-85 I rer
letter, asSU.iDg tbe
pcsltioL tbat aD RIlfS
is DtCeSsary aDd tbat
ttl~ Ittter dees net
relt.se tbe FRP trel
anf poteotial llabllitf
ier tbe costs of
puiellHg
tbese 5tudJts
86101'21 Let!er approvlDg «PCA's ...kat. usrn Cbll~:er.~~~. KFCA C~r:~~~~:~~~:f ('
ctttr to cODdu:t aD P.l
4 87106100 Supertund Progra. fact «PCA 'a:: ~bttt f
-------
~ r~. 2
JJ/50
ADlIlIsrRArIVE "CO~D I'D'!
US'P! Itltdial ActioD Saptrtand sitt
5:. LOU1S RirtrlIDttrlakt-Dalutb rar , CbtllcallUS St~tl
Dulatb, liDDtSota
'HE.'lW!E PAGES DArE rIfLE AurBOR RECIfIENT DOCUlllr ffPl DOCiOIlEEF.
Sbut for tbe St. l:(jH
RirtrIIDt~rlakt-Dulutb
rar ,itt
87 87109l0J litld 'ottS trol tbt Sparks, laicol PirDie Bielke. IICA BaDdrrittea 'otes 7
IDttllakt II
85103106 Itlo . Agt}da Ittl Lutsar. IPCA IPCA It,ouDdDl 8
CODtrol Sbtet tor 3.26.~5
.ettiDg re: fbt request
tor approral ot a
RtSpoDSt Ordtr by CODStat
Ifitb US Sttel
89 /J 2/00 I~IO rt: IPCA IPCA Itioraadul 9
Ptr.aatat List of , !
Prioritits dts:ribiag
,itt coaditioas, .tatt ,
assjgDed tc .ite aDd
actioas to bt takt~ at
tbt Iattrlatt sitt
89/1 2/00 It.c rt: IPCA Ptr.aatat KPCA 'ticraadul JO
;;;= List ot Priorities
dtscribiag sitt
c~aditi ca!. " ,
statt assiga~~ t~ sitt
aad actioDS te bt tatte
at tbt
U. S. SW l' site'
5: 85103126 R~sp:ose Order bf Coestot IIPCA PltadlogslOrdtrs JJ
ia tbe .atttr cf: US
Swl
i~ Dulutb. IU befou tbt
KPC}, Ifitb attacb.tet!
87106/16 KPCA lers Rtltast: IfPCA Puss Rtlust 12
°Sup~:fued lar~5tlgatioe
of
'or.~r rtst Dulatt
Io~u!trJal SJtt tc EtglCO
"
83102116 Rtport: Prtli'J~arr Ptrte:blao. , , ' USEPA l~p~rtsIStadiu J3
A55~S5.~ot of SJte
! 4 ~!'~S.':7 Slte Iaspe:tl:C ~ep:rt lartbelc.tr.' , E OSHA F.e;:rt5IStodlt5 14
!:~ ~fl02.':E RI rart PlaG- S::pe of Kalce. Firtlt , Assoc. KFCA RepUt5IStudJts 15
-------
, I~.
Jl/'D
3
iE ,'TRAIIE PAGES DArE
?
H8 87103105
iff 87103121
13 81106100
ADK1.1SfRAf1VI RICORD I.Dll
USIPJ. Rtltdial Aeti~c SuptrtuDd sitt ,
St. Louis Rirtll1Dttrlakt-Dulutb far' CbtlieallUS Stttl
Dulutb. lliDDtSota
fIrU
AUfBDR
RBCIPIUf
fork
R1 rort 'laa
IlPCA
puality Assuraaet Projtet fPCA
Plu
, .
,. .'
COlluaity Rtl,tioas Plaa IlPCA
tor tbt R1 at tbt St.
Louis Rirtrl1attrlakt-
Dulutb far' Cbtlical
sitt
~
DOCUlfllf frPr
~OC/lul!m
Rtport.IStadi tJ 16
Rtport.IStadits 17
RtportslStaditJ J8
.'
-------
. ., -'
'~ II~.
H/90
ADMIIISrRArIf' R'CORD I'D'I - UPDAf' ,J
sr. LOUIS R1r'R/1.f'RLAll/DOLurB fAR SIr,
DULUfH, 11l"sorA
'HE IlRAKE PACES DATE fIfLE AUrBOR RlCIPIIJr DOCOK'Jr rfPI .DOC'UMEn
4 B"OBm LtttH H: St. Loui, L. Btilte D. Sieber" USfPA Corrupoadeace
Rirer/1ottrlake/Dolutb IPCA
far Pba,e II field rork
.
.- .
..
8~/0~/J1 Lttttr HI L. hilte K. fanz, lalcol. Corrupoodeace
St. £oui, Rirer! IPCA 1 i rai t --
loterlake/Dalotb rar
Site R~uod 1
Cr~uod Wattr Sa.plJng
2 ~O/OllO~ LtttH rt: G. Fullord G. lobtnoa, Corrupcadtnct I
St. Loui, Rirer! KPCA lDttrldt
10terlake/Dulutb rAr ,
Sitt, DulDcb, lfJ
J ~O/04l1J Letter re: Iottrlakt C. Kicbael C. ',aro,ti, IPCA Corrupoodeoct
Fta,ibllity Study Kalcol. PiIDU
- Cbapter J
13 ~0I06/J3 Letttr rt: C~..tot, oa f. Colttllo, IrC C. ',aro.ti, IPCA Corrt,poodtoce
Gr~uod rater aad far Step
Ope ubl e Uo it.
4 ~0/06/H Ltt tH Rt I C. licbael, I,f C. ',aro.tJ, IfPCA Corre,pC'adeace
frtatability Study «alco18 PirDie
r~rk Plao 1aterlatt
Sitt
6 '0/07/13 LeetH HI K. Costello C. f'arC',ki, IPCA Corrupood!Dce
COlltot, cn fu Ire
SHP Dratt
fea,ibility Study
J ~O/07m LeetH rt: T.C. Irjha C. '"ro,tJ,IPCA Corrt!pC'od!oct
lHtiog t'a K'r 14, J990, T.G. Irik,o , A"C'c.
di'cu,~iog tecboologr
(It di!p~,iog ot ct'al
tar io Bla,t Tura,ce,
~0/08130 LtttH rtl R. IUHr, '.f. L. Btth, US"A Corrupoodeoct
fta,ibility Study IPeA
~ppro'al and Fropc~ed
Plao ccocurreoct
( B7/06/00 Suptrfuod progra. KPCA Tact Sbett
Tact Sbttt St. Lt'uis/
Iattrl,tt Dulutb far
~jtt
-------
--_.. -. - -..-.
... - ~.-
-.- -.. - - - ---.- -
.- ------
- _.__.. ---- - ---
-.--- -- - .-.-
,~ /10. 3
'h/~O
AD~I'ISfRAfIrl "CORD I'DI' . DPDArl II
Sf. LOOIS RIVIRIIRflRLAIIIDOLOfB fAR SIfl
DOLOfR, II"'SOfA
~F.E: lVKE PACIS DArE fIfLE ADfSOR RlCIPIUf DOCDUIr rFFE DOCRUIIPU
trposurt to coostitutots
co cr otar St. Loui~
Rirtr/lottrJaktlDulutb
far Sitt
87/06116 ~ IPCA PrtH RtItaH
'tll! rtltast. rt:
Suptr!und In't~tigatico
of tor.tr rtst tulutb
IDdu~trJal Sitt tc btgio
8~/C7nl Rtv~ rtlta~t rt: IIPCA Peu. RtIuH
KFCA Start, litld rork
fttk of Junt 26 at ~
IottrlaktlDulutb f.r
SupHtund S1tt
2 90102114 KtV~ rtltast rtl IIPCA Prus Rtltast
Public .tttiog ,tt to
discu~s i07tstigatioo
;.;:; rtsult, 00 St. Louis
Rirtr/lnttrlakt Ironl
Dulutb far Suptrfuod
Sitt
'0102120 Itrs RtltaSt rt: l.Caclsco, 'tsidtot,lo,iroo.~ot Prtss Rtltast
Datt cbaog~d t~r tbt IIPCA . lilt
Public IItttiog rc tht
Iottrlakt Suptrfuod
Site
2 50102120 Lttttr rtl «.Culloo Rt,idtot,forirco.tot Frts, fitItast
Datt cbanptd fcr tbt IIFCA .li.t
Fublic Ktttiog CD tbt
Iottrlakt Soptrfund
Site
'0108/00 Lttttr rt: cotict DSlPA PetH R~lt!H
of Fublic Kttting
'0108100 'tVS Itltast rt: PrtS! leluH
Fublic .tttlog .od
Fublic CO.ltot Ptriod
rtgardiog St. Lrui~
RirtrllnttrlaktlDulutb
far Suptrfuod Sltt
Dulutb. ~I
134 87111/00 fbaH 1 Sitt lIalc01l Pinit «tCA RtportiStudit~
Invtstipatico Draft
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.'
No. 2
6/90
ADKIRISfRAfIVr RECORD I.Dll - UPDAfr 11
Sf. LrUIS RIVERIIRfrRLAXIIDULUfR r.R SIfl
DULUfH, «I..rsorA
EIFRAKE PAGES DAfE fIfLE AUfHOR REC11lur DOCUIIINf rrF~ ~CC/il'l!fH
88106100 . Sup~rfund Pcogra. «PCA lact S6ttt
'ut Sbttt . St. L(luis
Ri'~cIIcttrlaktIDulutb
far SIt~
I'
I' "
2 B~/O~/OO Tact Sb!tt frr «PCA lact Sbtt t
St. Loui~ Rirtrl
Ict!rlaktlPulutb
far Sitt
f ~OIO~/OO Fact Sbttt on tbt «PCA lact Sbttt
P.t.!dJal In't~tl~ati(lc
of tbt St. L~uis Rirtrl ~
~
IcttrlattlPulutb far Sitt
. ~OI0710~ St. Loui~ P.iVtrl asrPA lact Sbttt
Inttrla~tlDulutb far
Sup!rtur.d Sitt fropostd
Flac 'act Sbut
~OIOSIH lI!ttic~ DottS tro. tbt P. eacgialosi e. fraroski, «peA «tttiog 'ottS
liar 24tb projtct .ttticg Kalcol. PirDit
btld ic St. Paul
3 ~010612Z KtlC rt: fhe legally R. SczneJdi r. rtcOty, aSrPA Kt.oracdu.
a~c~ptablt .ttb('d~ for
d~sposlng of ceal tar
~CI07/J2 IltiO ct: J. f!tiua D. Sitbtrs, aSrPA Kuoraodul
St. l(lui~ Rirtrl USlFA
IDterlJktlDLlutb
far Sitt 'ocu~td
'tasibilitr StJdr
ba~ betn rtvitrtd
by 5C51 for IP.A~s
1 ~010810~ St. LOUIS RiVtCl D. Sitbtrs, USrPA OttidaJ lile Kt.orandu.
IDttrla~tlDulutt
far Site frittlog~
(lC Pr~posed Plae
~OIOJm Letter It: Cr..tot~ 00 K. Costtllo, IrC G. JOhSOD, Ia ttr 1 att Otber
C'ptrablt Units Corp
...
16 ~OIOJI2I L!ttec r!: rocu'td II. COHtlJo, 1.1. G.JobDsoD,IDttrJakt Otbtr
Risk AS't~s.tDt tbat IrC Corp.
defict$ p('~totial
rjsk~ ass(lciattd ritb
-------
- ." ~ .
-,
Q" IIr. 4
t J6/~0
ADK1~ISfRAflfl RICORD I.DII . OPDAfl 11
$f. LOOIS .IVI'lllfl.LAIIIDOLOfP. fA~ ~lfl
DOLUfH, KI..,SOfA
rH51FRAKE FAGE~ DAfr rIrU AGfSOR RECIFIUf DOCO«Uf HPE DCleNU/!EEF
'tport . St. L~uis .irtrl
InttrlaktlDDlutb rar Sitt
JH BUJ]/OO Pba~t II .1 rork Kalcoll Pirnit KPeA 'tportlStuditS
Plan I~r . St. lrui~
Ri'trllnt~rl.ktIDulutb
far SiCt
2J~ 88/J 2/00 ApptDdict$ Volu.t I KaIco18 Pirnit KTCA RtportlStuditS
Fb3St II C~alitr
A!!Ur3nrt Preftct Plan
t~r -St. L.~ui~ Rirtrl
IDttrl~~tIDulutb far Sit~
~ !
US U/J 2100 Apptodicts Vola.t II Kaleoll Pimit «PCA 'tport/StudiU '
Pba~t II paalitr
A$suranct Prejtct Plao
for. St. Loui! ,irtrl
IDttrlaktlDulutb rar
::-::= $itt
~8 88/12100 PbaSt II pualitr «alcoll Pimit KPCA RtportlStudit~
A$suraoct fr~1tct
Plan Irr . St. Leuis
F,jrtrl]nttrlaktIDulutb
rar Sitt
EC B910~127 H!altb A!$tS$.tot U.S. Public Htaltb 'tport/Stadi tS
for H. Leui~ 'i'HI Strrict
U.S. St~tl, St. L~ujs
F.irtrll~ttrI.ktIDul.tb
Tar Dulutb, IIH
243 ~O 10 lICO fioal 'tport Kal:oll 'iroit KPCA RtportlStudiu
't.tdial Inrtstig.tion
Volult I
J54 90101100 Tinal '!port K.lcoll 'irait KPCA '!portlStuditS
Ft.tdi.l !nrt$tig'tica
Volu.t 11 Apptndict$
JO 9010~tJ6 LHtfr rt: C. Iddr e. lficbatl,«alco18 Rtp~rtlStudi t $
H. L~UH Pirtrl KreA Pi ra It
Int~rJ.ktlflulutb
far Sitt Rr.tdlal
]nr!$tI9'tJ~n Rtp~rt
Apprer.l - ,~ rorl
Flao Attachd
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19~ "" 5
1/16190
ADKIJISTRATIVI RICORD IIDII . UPDATI II
~T, LOUIS RIVIFIIlfIFLAlrIDULU~H rAR SIrl
DULUTH, KIJ',SOfA
'CREIIF.ANE 'AGE~ DATE rIfLE AUTHOR RICH IUT DOCUI/Uf ffFE DOWJHEH
126 ~~ I~J 111 ~tdi.tnt Sur'tf/Pr~gra. K. Costtllo, Irc G.J~br.s~o. Iottrlakt RtportlStudlts
and Rt~alts at tbt St. Corp
L~uj~ Rjrtr/IottrJaktl
ruJutb rar Sitt
,.
9f ~C/0610C rralt Rtport lfaIcoh ,jlcit e. rvau!ki, «peA Rtport/StudlH
rta~ibiljtf Study
tor far SttpS Optrablt
['oit ~t. LC'uj! Rjrtrl
ID!~rJ,t~/Duluth .f,r
Sitt
H ~0I01/00 rio,J R~port K,lcoh 'lroit KFCA, USIfA Rtport/Studlt!
It,sjbjljtr Study. ,
lor Tar SttP! Optrablt
Unit St. Louis Rirtl/
Int~rI,ttlDulutb far
SHt
....- 15 ~OI01m fropcsd ,Iao USIPA R~portlStudjts
~t. Lcai~ Rjrtrl
10ttrlaktiDoloth Tar .' ..
~upHfoDd Sitt
Dulotb. /IN
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