United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R07-90/OM
September 1990
Superfund
Record of Decision:
Fairfield Coal Gasification, IA
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REPORT DOCUMENTATION 1" AEPOATNO. 1 ~ So A8dp1ent. Ac-.lon No.
PAGE EPA/ROD/R07-90/041
4. 1188 end ..... S. A8\)or1 0818
SUPERFUND RECORD OF DECISION 9/21/90
Fairfield Coal Gasification Plant, IA
First Remedial Action Final 4.
-
7. Author(.) 8. P8t1onnlng OrgmlDdon R8pt. No.
8. P8t1onnlng Org.lnlDdon Name and Add,... 10. ProjacllT.8klWoril Unit No.
". Contrae1(C) or Gr.n1(G) No.
(C)
(G)
1~ ~ng Organization Name .nd Addr... 13. Type 01 A8pOI'1 . Period Co.....s
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
1 S. Suppl8rnenl8ry NoI88
14. Aba..eI (Lhftt: 100 wonS.)
The 1.3-acre Fairfield Coal Gasification Plant is a former coal gas generator plant in
the town of Fairfield, Jefferson County, Iowa. Since 1917, the site has been owned by
the local power company. From 1878 to 1950, gas was generated from coal as an energy
source using various processes, each producing an array of by-products that were either
sold or disposed of onsite. Since 1937, coal tar and ammonium liquor wastes were
disposed of onsite. In 1986, site investigations by the power company found evidence of
surface contamination and contamination in the underlying ground water as a result of
leaching from buried coal tar wastes. The source of contamination was determined to be
the sediment and soil associated with a relief gas holder, a gas holder pit area, and a
tar separator. The primary contaminants o~ concern affect ing the soil, sediment, and
ground water are VOCs including benzene, toluene, and xylenes; other organics including
PAHs; and metals including arsenic, chromium, and lead.
The selected remedial action for the site includes excavating 3,800 cubic yards of
PAH-contaminated coal tar waste, soil, and sediment from the source areas and an
(See Attached Page)
17. Docum8nt AnaIyaI. .. OIIacripto..
Record of Decision - Fairfield Coal Gasification Plant, IA
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PAHs), and
metals (arsenic, chromium, lead)
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EPA/ROD/R07-90/041
Fairfield Coal Gasification Plant, IA
First Remedial Action - Final
Abstract (Continued)
.
additional undetermined quantity of soil from these site areas after separating and
decontaminating larger items, followed by offsite treatment using incineration; pumping
and treatment of an estimated 1,577,000 gallons of contaminated ground water using
filtration, polymer injection, and settling out of the sludge wastes, followed by
treatment of the supernatant using carbon adsorption with offsite discharge to a
publicly owned treatment works (POTW) or onsite use of the treated water in a nutrient
addition treatment process; disposing of the settled sludge in accordance with approved
disposal methods; treating the coal gas migration areas by enhanced bioremediation if a
pilot study proves successful; and implementing institutional controls, including ground
water and land use restrictions, and site access restrictions, such as fencing. The
estimated present worth cost for this remedial action is $5,815,000, which includes an
estimated O&M cost of $4,762,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Ground water will be treated to reduce the level of
contaminants to levels acceptable to the State, including benzene 1 ug/l (1~6 cancer
risk level), toluene 2,000 ug/l (lifetime health advisory), and xylenes 10,000 ug/l
(lifetime health advisory). Ground water will be treated to best available detection
levels. If the ground water remediation levels can not be attained, alternate
concentration levels may be established or a chemical-specific ARAR,waiver may be
invoked in an amended ROD. Cleanup levels for soil are based on risk assessment and
include total PAHs 500 ug/l, carcinogenic PAHs 100 ug/l, and benzene 241 ug/l.
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RECORD OF DECISION
"
FAIRFIELD COAL GASIFICATION SITE
'"'
FAIRFIELD, IOWA
Prepared by:
u. S. ENVIRONMENTAL PROTECTION AGENCY
REGION VII
KANSAS CITY, KANSAS
SEPTEMBER 1990
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.
DECLARATION
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Declaration for the Record of Decision
Fairfield Coal Gasification site
Fairfield, Iowa
statement Qt Basis and Purpose
This decision document presents the selected remedial action
for the Fairfield Coal Gasification site, in Fairfield, Iowa.
The selected remedy was chosen in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and the National Contingency Plan (NCP). This decision document
explains the factual and legal basis for selecting the remedy for
this site. The information supporting this remedial action
decision is contained in the administrative record for this site.
Assessment Qi the ~
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present a
current or potential threat to public health, welfare, or the
environment.
Description Q! the Selected Remedy
The
that has
aromatic
water.
principal threat at this site is buried coal tar waste
migrated off site. Volatile organics and polynuclear
hydrocarbons have leached from the tars into the ground
The major components of the selected remedy include the
following:
. The off-site incineration of the coal tar source areas and
areas of contaminated soil:
. The treatment of contaminated ground water by filtration,
polymer injection and settling, and carbon adsorption systems;
and
. The in-situ treatment of coal gas migration areas
involving the injection of nutrients into the aquifer to
stimulate biological degradation.
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Declaration 2t Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable, and it satisfies the statutory
preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as their principal element.
Institutional controls will be installed at the site to insure
that the remedy provides protection of human health and the
environment. This protection is based on health-based levels
that have been determined to be protective when met in
conjunction with institutional controls. Since these controls
will not allow for unlimited use and unrestricted exposure at the
site, a review will be performed no less often than every five
years after initiation of the selected remedial action.
1S Kay
Re ional Administrator
ited States Environmental
egion VII
Protection Agency
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FOREWORD
1.0
2.0
3.0
4.0
TABLE OF CONTENTS
INTRODUCTION
1.1
1.2
PURPOSE OF PLAN
ORGANIZATION OF PLAN
SITE BACKGROUND
2.1
2.2
2.3
SITE LOCATION AND DESCRIPTION
SITE HISTORY
NATURE AND EXTENT OF CONTAMINATION
SUMMARY OF SITE RISKS
3.1
3.2
OVERVIEW OF BASELINE RISK ASSESSMENT
REMEDIATION GOALS
SUMMARY OF ALTERNATIVES
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
NO ACTION
ISOLATE SOURCE AREAS AND SOILI
CONDUCT GROUND WATER MONITORING
CAP SOURCE AREAS AND SOILI
PUMP-CONTAIN-TREAT GROUND WATER
EXCAVATE AND INCINERATE SOURCE AREAS AND SOIL OFFSITEI
CONDUCT GROUND WATER MONITORING
EXCAVATE AND INCINERATE SOURCE AREAS AND SOIL OFFSITE/
PUMP-CONTAIN-TREAT GROUND WATER
EXCAVATE AND INCINERATE SOURCE AREAS AND SOIL OFFSITE/
PUMP-CONTAIN-TREAT GROUND WATER WITH ENHANCED
IN-SITU BIOREMEDIATION
EXCAVATE AND INCINERATE SOURCE AREAS OFFSITEI
EXCAVATE AND BIOLOGICALLY TREAT SOIL AREAS
OFFSITE/PUMP-CONTAIN-TREAT GROUND WATER
EXCAVATE AND INCINERATE SOURCE AREAS OFFSITEI
EXCAVATE AND BIOLOGICALLY TREAT SOIL AREAS
OFFSITE/PUMP-CONTAIN-TREAT GROUND WATER WITH
ENHANCED IN-SITU BIOREMEDIATION
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5.0
6.0
7.0
EVALUATION OF ALTERNATIVES
5.1
5.2
5.3
5.4
5.5
5.6
5.7
5.8
5.9
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
COMPLIANCE WITH ARARS
LONG-TERM EFFECTIVENESS AND PERMANENCE
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
SHORT-TERM EFFECTIVENESS
IMPLEMENTABILITY
COST
STATE ACCEPTANCE
COMMUNITY ACCEPTANCE
SUMMARY OF PREFERRED ALTERNATIVE
COMMUNITY PARTICIPATION
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RECORD OF DECISION
DECISION SUMMARY
1
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1.0
SITE BACKGROUND
1.1
SITE LOCATION AND DESCRIPTION
The Fairfield site is located in Fairfield, Iowa, a town of
approximately 10,000 people, in central Jefferson county. The
address of the site is 107 South Seventh Street. A map of the
vicinity and site location is shown in Figure 1.
The site occupies approximately 1.3 acres. It is bounded on
the north by Burlington Street, on the east by residential
property, on the south by an electrical substation and a salvage
operation, and on the west by Seventh Street and residential
property. The area is primarily residential with commercial
businesses to the north on Burlington Street.
The main features of the site include: three gas holders, a
gas holder pit, a relief gas holder and a gas holder base; an
operations building; a former tar separator; a former railroad
right-of-way area; and an area south of the site that was
~ormerly a ditch. These features are shown on Figure 2.
Information from the U.S. Department of the Interior and the
Iowa Department of Natural Resources (IDNR) indicate that there
are no sensitive environments within a one-mile radius of the
site. Sensitive environments would include wetlands, critical
habitats of endangered species, and national wildlife refuges.
1.2
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Coal gasification operations began at the Fairfield site in
1878. The process utilized involved the carbonization of coal in
retorts. Coke was burned beneath a retort, carbonizing the coal
and giving off gas. This gas was then purified and piped to gas
holders for future distribution. The two by-products of the
carbonization process were coke and coal tar. The coke was sold
for home heating and the tar was sold primarily for fencepost
preservation.
In 1937 the process was changed from carbonized coal to
carbureted water gas. This process involved the burning of coke
beneath an upright circular generator containing coal. Steam
which passed through the coal was captured and the gas it
contained was then purified. The by-products produced were coal
tar and ammonium liquor, both of which were disposed on-site.
Another by-product of this process was spent oxide waste from gas
purification processes which produce cyanide salts. The disposal
location of these wastes is unknown.
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In 1950 the gas system in Fairfield was converted to natural
gas. As a result, operations at the site were terminated and the
buildings were converted for use as an operations facility.
The owner of the site is Iowa Electric Light and Power
Company (IELP), who, under different corporate names, has owned
the site since 1917. IELP conducted a study in 1986 in which
contaminants were found in the soil and ground water at the site.
The United states Environmental Protection Agency (EPA) conducted
an investigation in 1987 which confirmed the presence of this
contamination on-site and also found contaminants in the drainage
ditch south of the site. IELP continued to monitor the ground
water at the site from 1986 to 1988. The site was proposed for
the National Priorities List (NPL) in June, 1988 and was placed
on the NPL in August, 1990.
IELP entered into an Administrative Order on Consent with
EPA in March, 1989 to conduct a Remedial Investigation (RI) and
Feasibility Study (FS) at the site. The purpose of the RI was to
determine the source of contamination and the nature and extent
of contamination at the site and to collect the necessary data to
determine the proper alternatives to be evaluated in the FS.
Also, as a necessary measure to retard the flow of contaminants
off site, IELP agreed to implement a ground water extraction and
treatment system. IELP contracted with B & V Waste Management to
conduct sampling at the site, which included surface and
subsurface soil, ground water, sediment, and surface water
samples, and design and implement the ground water treatment
system. IELP prepared an RI/FS Report which was reviewed by EPA.
EPA, based on the findings of the FS, prepared a Proposed Plan
which described the preferred alternative for this site.
1.3
COMMUNITY RELATIONS ACTIVITIES
The RI/FS Report and the Proposed Plan for the Fairfield
site were released to the public for comment. The public comment
period was from July 17, 1990 to August 15, 1990. These two
documents were made available to the public with the
administrative record, which is located at information
repositories maintained at the Fairfield Public Library and at
the EPA Region VII office. The notice of availability for these
documents was published in the Fairfield County Ledqer on July
17, 1990. A public meeting was held on July 26, 1990 in
Fairfield, Iowa. At this meeting, representatives from EPA, the
State of Iowa, and the Agency for Toxic Substances and Disease
Registry (ATSDR) answered questions about problems at the site
and the remedial alternatives under consideration. A summary of
comments received at this meeting and during the comment period
and EPA's response to those comments, the Responsiveness Summary,
is attached hereto as Appendix A.
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2.0
SCOPE OF RESPONSE ACTIVITIES
. .
The response activities described in this Decision Summary
address all contaminants known at the site. When implemented,
these actions will eliminate the need for future response actions
at the site. This ROD is intended to be the final ROD for the
Fairfield site.
3.0
SUMMARY OF SITE CHARACTERISTICS
3.1
CONTAMINANT CHARACTERIZATION
Coal tar waste contains polynuclear aromatic hydrocarbons
(PAHs) such as naphthalene and benzo(a)pyrene. Also produced
from coal tar wastes are volatile organic contaminants, such as
benzene, ethylbenzene, toluene and xylene, and semi-volatile
contaminants, such as 4-methylphenol, dibenzofuran, and phenol.
Metal contamination, such as barium, lead, and.mercury, and
cyanide can also be associated with coal tar wastes.
3.2
CHARACTERIZATION OF THE NATURE AND EXTENT OF CONTAMINATION
The investigation performed by IELP's contractor identified
the source of contamination and characterized the nature and
extent of contamination at the site. The discussion of these
findings are divided into four main groups: source area results,
surface and shallow subsurface results, deep subsurface results,
and ground water results.
Source Area Results
Three areas of source contamination were identified at the
site, the gas holder pit area, the tar separator, and the relief
gas holder area. These areas are former coal tar disposal or
treatment areas.~ A summary of the maximum contaminant
concentrations detected in source areas is provided in Table 1.
Surface water samples from inside the gas holder pit had
total PAH concentrations of 39,780 parts per billion (ppb), total
metals above primary drinking water standards for six compounds,
and cyanide concentration of 29,000 ppb (undetected in background
samples). A sediment sample from the gas holder pit yielded
total PAHs of 24.8', carcinogenic PAHs of 2.24', and BETX
compounds (benzene, ethyl benzene, toluene and xylene) having
total concentrations of 13.1': these were the highest sediment
values on the site (see Figure 2).
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,
A boring was drilled at the tar separator, resulting in
total PARs of 6,604 parts per million (ppm) and carcinogenic PARs
of 1,406 ppm. Two and a half feet of coal tar was observed at
the base of the tar separator.
The main source of contamination at the site, however, has
been shown to be the relief gas holder at the southwest corner of
the site. Heavy amounts of coal tar were observed in borings
taken from this area. Migration from this area has also been
documented by borings showing coal tar in dense nonaqueous-phase
liquid flows that have penetrated fractures and traveled along
the seams away from the site. The ground water results have also
shown the relief gas holder to be the main source of
contamination.
Surface and Shallow Subsurface Results
Table 2 provides a summary of the maximum contaminant
concentrations that were detected in the surface and subsurface
soils. The highest concentrations of total PAHs in surface and
shallow subsurface borings outside of the source areas were at a
location 4.5 - 5.5 feet deep northeast of the relief gas holder
(boring '22, or B-22: 187 ppm total PAHs/37.6 ppm carcinogenic
PAHs), in the vicinity of the relief gas holder, and at a depth
of 3 - 4 feet in the ditch south of this site (B-31: 191.9 ppm
total PAHS/48.7 ppm carcinogenic PAHs). These samples show
contaminant migration from the relief gas holder.
A boring from
holder base (B-26)
carcinogenic PAHs.
migrating from the
2.5 - 3.5 feet taken southeast of the gas
showed 25.1 ppm total PARs and 16.6 ppm
This indicates that contaminants are probably
gas holder base.
The results obtained for BETX compounds confirm the PAH
results. The highest concentrations were located at B-22 (332
ppm total BETX), in the ditch south of the site (B-30: 27.8 ppm
total BETX), and in the vicinity of the relief gas holder (B-14:
542 ppm total BETX and B-15: 1,413 ppm). In addition, at B-23,
lead was detected in concentrations of 170 ppm, mercury at 0.67
ppm, and cyanide at 200 ppm. These results also appear to
confirm the contaminant migration from the relief gas holder.
More investigations will be performed during the Remedial Action
(RA) to define possible contamination in the ditch south of the
site. Also, if any wastes other than those that were identified
in the RI are discovered, the disposal of these wastes will be
addressed during the RA.
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Deeo Subsurface Results
The highest concentrations of contaminants in the deep
subsurface testing were in two borings, one at a depth of 22 - 24
feet east of the relief gas holder base (B-21) and the other at
26 - 27 feet south of the relief gas holder base (B-29). B-21
had results of 312.9 ppm total PAHs, 58.7 ppm carcinogenic PAHs
and total BETX of 7,000 ppm. B-29 yielded 200.9 ppm total PAHs,
30.9 ppm carcinogenic PAHs and 473 ppm total BETX. These values
can be seen in Table 3, which summarizes the maximum
concentrations for contaminants detected in the deep subsurface.
Coal tar was observed to be migrating into subsurface
fractures during the drilling of these borings. This indicates
that the dense nonaqueous-phase liquid is migrating from the
relief gas holder at depths of approximately 22 - 27 feet.
Samples taken at lower depths show contamination, but at much
lower levels. One exception, however, is a sample taken from the
boring of a monitoring well installed southeast of the gas holder
pit (FI-7; see Figure 3), which had values of 30.2 ppm total PAHs
and 10 ppm carcinogenic PAHs at the 47.5 - 50 feet depth.
Ground Water Results
Ground water samples were collected from eleven monitoring
wells on-site and off-site, five private off-site wells, two
on-site extraction wells, and one temporary on-site monitoring
well. The analytical results of these samples show that the
relief gas holder is the primary source of ground water
contamination. Table 4 summarizes the ground water maximum
contaminant levels.
The highest PAH concentrations found in monitoring wells
were in FI-3, west of the relief gas holder; FI-7, northeast of
the relief gas holder and southeast of the gas holder pit; and
FI-9, southeast of the relief gas holder. FI-3 had total PAHs of
3396.4 ppb and total carcinogenic PAHs of 133.9 ppb. FI-7 had
total PAHs ot 2874 ppb and FI-9 had total PAHs of 5176 ppm and
carcinogenic of 108 ppb. An extraction well was installed
southeast of the site (EX-1) which was analyzed and found to
contain 3085 ppb of total PAHs. A ground water sample was also
taken from the extraction well installed in the relief gas holder
(EX-2) and a total PAH concentration of 7501 ppb was found.
The wells were analyzed for BETX compounds and similar
results were found. Well FI-3 had a total BETX concentration of
54,430 ppb, FI-7 had 6560 ppb total BETX and FI-9 had 104,000 ppb
total BETX. Ground water samples were taken from EX-1, which
contained 57,900 ppb of total BETX, and from EX-2, which
contained a total BETX value of 101,200 ppb. Many of 'the samples
exceeded EPA primary drinking water standards for BETX compounds.
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The analytical results from well FI-9 indicate the primary
ground water flow is to the southeast. This pathway will be
investigated further during the RA to define the farthest extent
of contaminated ground water. The extent of ground water
contamination will also be further defined to the west and south
of the site. Sufficient information is available from the RI,
however, to determine a proper remedy for the ground water.
Chromium and lead were detected in well FI-3 above the
primary drinking water standards. Water samples taken from the
temporary well located just north of well FI-7 (B-24 on Figure 2)
had results also above EPA drinking water standards for arsenic,
chromium, lead, and mercury. The results from this well may
indicate contaminant migration from the gas holder pit. In
addition, benzene and naphthalene were detected off site in
residential wells.
Figure 4 shows the extent of benzene contamination in the
ground water. Figure 5 indicates the plume represented by total
carcinogenic PAH contamination. The non-carcinogenic plume is
shown on Figure 6 and the contaminant plume for naphthalene is
shown on Figure 7. The private well locations are also shown on
Figure 7.
4.0
SUMMARY OF SITE RISKS
4.1
OVERVIEW OF BASELINE RISK ASSESSMENT
A baseline risk assessment is an evaluation of the potential
threat to human health and the environment in the absence of any
remedial action. It provides information to help EPA determine
whether remedial action is necessary at a site. A baseline risk
assessment was conducted for this site to determine the potential
effects on human health and the environment. In this evaluation,
both current and future land-use scenarios were evaluated.
4.2
INDICATOR COMPOUNDS
Tables 5, 6, and 7 list the compounds detected in analyses
performed on samples taken at the site. Of these, a total of 30
chemicals were identified in the Risk Assessment to be of
potential concern, 17 of which were PAHs. Toxicity information
was evaluated for all chemicals of concern, including cancer
potency factors and noncarcinogenic effects. These chemicals are
identified in Table 8 with their representative concentrations
used in calculations.
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4.3
EXPOSURE ASSESSMENT
Pathways by which humans could be exposed to the chemicals
of concern at the site were evaluated based on reasonable
assumptions about current and future land uses. The following
pathways were evaluated:
. Exposure of current residents to off-site contaminated
ground water through occasional ingestion of well water during
outside activities, ingestion of garden produce watered with
contaminated ground water, and inhalation of contaminants
volatilized during watering;
. Exposure of future workers on-site and off-site to
contaminated soil through dermal contact and ingestion;
. Exposure of future residents to off-site contaminated
ground water used as a primary potable water source.
Assumptions were made in calculating daily intake rates
under each of these exposure pathways. These assumptions are
explained in the Risk Assessment, Chapter 6 of the RI/FS Report.
"The uncertainties involved with the calculations are also listed
in the Risk Assessment. The daily intake rates are listed in
Table 9 for each pathway. Calculations are performed for
subchronic (0.5 years), chronic (10 years), and lifetime (70
years) exposure durations.
4.4 TOXICITY ASSESSMENT
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of daily exposure
levels for humans that are not likely to be without an
appreciable risk of adverse health effects. Estimated intakes of
chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans). These uncertainty factors help ensure that
the RfDs will not underestimate the potential for adverse
noncarcinogenic effects to occur. The RfDs applicable at the
Fairfield site are listed in Table 10.
Cancer potency factors or slope factors (SFs) have been
developed for estimating excess lifetime cancer risks associated
with exposure to potentially carcinogenic chemicals. SFs, which
are expressed in units of 1/(mg/kg/day), are multiplied "by the
estimated intake of a potential carcinogen, in mg/kg/day, to
8
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provide an upper-bound estimate of the excess lifetime cancer
risk associated with exposure at that intake level. The term
"upper-bound" reflects the conservative estimate of the risks
calculated from the SF. Use of this approach makes under-
estimation of the actual cancer risk highly unlikely. Cancer
slope factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied. The SFs are listed in Table 11.
4.5 RISK CHARACTERIZATION
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ), or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose. By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
A HI was calculated for each pathway evaluated. An HI of
less than 1.0 (~nity) indicates that the risks associated with
that pathway are low. An HI above 1.0 indicates that some risk
of noncarcinogenic effects exist and these risks increase
proportional to the HI value. The HI value for current off-site
residents is at unity, indicating that they are not currently at
risk, but treatment of contaminants to reduce the spread is
necessary. The future risk to off-site residents through the
ground water pathway was evaluated and the HI was calculated to
be 50, which indicates that treatment of the source, soil and
ground water is essential at this site. The HI for future
workers on-site and off-site was determined to be less than one,
indicating no significant noncarcinogenic risks.
Excess lifetime cancer risks are determined by multiplying
the intake levels with the cancer slope factors. These risks are
probabilities that are generally expressed in scientific
notation. An excess lifetime cancer risk of 1 X 10-6 indicates
that, as a plausible upper bound limit, an individual has a one
in a million chance of developed cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at a site.
The carcinogenic risks were also calculated for the
evaluated pathways at the site. The risk associated with each
pathway is summed for each r~ceptor. The carcinogenic risk to
current residents is 4 X 10-. The risk to future off-site
residents is 7 X 10-2. The risk to f~ture off-site workers at
t~e site was calculated_io be 3 X 10- and the risk to future on-
S1te workers was 5 X 10 .
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Accordingly, EPA has determined that the actual or
threatened release of hazardous substances from this site, if not
addressed by implementing the response action selected in this
ROD, may present a current or potential threat to the public
health, welfare or the environment.
4.6
REMEDIATION GOALS
Federal and state soil cleanup standards for the
contaminants of concern have not been established at this time.
Therefore, it is appropriate to determine soil cleanup levels on
a site-specific basis using the risk assessmegt's carcinogenic
risk factors. At the Fairfield site, the 10- risk level would
be protective if no institutional controls were in place. With
propei institutional controls at the site, the cleanup of soil to
a 10- risk level at this site would be protective of human
health and the environment. Based on this risk level, the clean-
up level for soil will be 500 ppm for total PAH contaminants and
100 ppm carcinogenic PAH contaminants. The 10-4 level will also
be used to determine the cleanup level for benzene in soil.
The NCP states that preliminary remediation goals are to be
set at a 10-6 excess upper bound lifetime cancer risk level as a
point of departure, b~t may bg revised to a risk level in the
acceptable range (10- to 10- ) based on consideration of
appropriate factors, including uncertainty, technical and
exposure factors.
For chronic and lifetime exposures, an assumption was
employed that all concentration values will remain constant.
This may result in some overestimation of chronic and lifetime
exposure since the volatile organic compounds, and to some extent
the PAHs, have the potential to break down and evaporate,
resulting in some reduction of risk. A technical factor for soi1
that should be considered i~ the practical limit to which soil
can be remediated. The 10- risk level for carcinogenic PAHs is
0.43 ppm. It would be technically impractical to remediate soil
to this level based on the volume of soil that would be
generated. Finally, institutional controls will be implemented
at the site, reducing the potential for exposurt. For these
reasons, cleanup of soil at the site to the 10- risk level would
be protective.
Federal and state ground water cleanup standards have been
established for some of the contaminants of concern at the site.
EPA has established the Safe Drinking Water Act National Primary
Drinking Water Standards' Maximum contaminant Levels (MCLs) as
cleanup criteria for drinking water. The Iowa Administrative
Code Chapter 133, effective August 16, 1989, .~tablished cleanup
levels for contaminated ground water in Iowa. The level to first
be considered is the EPA negligible risk level (NRL), then the
EPA lifetime health advisory level (HAL), and finally MCLs.
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,
,
For the Fairfield site, EPA believes that a clean-up level
of 1 ppb benzene, the most abundant volatile organic present in
the contaminated ground water, would be protective of human
health, based on the NRL for binzene. This level coordinates to
a protective risk level of 10- .
For carcinogenic PARs for which there are no state or
federal standards, the proposed cleanup levels will be
established using the detection limits for each specific
compound, based on the best available technology at the time of
the signing of this ROD. The goal for these cleanup levels is to
achieve a level protective of human health and the environment.
EPA believes that a level established using the current best
available detection limits will fulfill this goal. The minimum
laboratory detection limits that can be achieved under ideal
conditions fgr carcinogenic PARs coordinate to a protective risk
level of 10-. The best level that can be measured practically
during routine laboratory oPirating coniitions coordinates to a
protective risk level of 10-. The 10- risk level is considered
appropriate for this site based on the uncertainty factor
previously discussed and the technical factors associated with
the detection/quantification limits for contaminants.
The levels discussed in this section have been reviewed and
approved by ATSDR. Table 12 lists the remediation levels that
will be used for ground water remediation at this site, including
the detection limits for the carcinogenic PARs.
5.0
SUMMARY OF ALTERNATIVES
The NCP requires that certain alternatives be developed for
evaluation in the FS:
. An alternative that removes or destroys the hazardous
constituents to the maximum extent feasible and eliminates the
need for long-term monitoring and management;
. One or more additional alternatives that reduce the
toxicity, mobility, or volume of the hazardous constituents:
. One or more alternatives that involve little or no
treatment, but provide protection of human health and the
environment by containing the hazardous constituents to control
exposure to the wastes;
. One or more innovative treatment technology alternatives
if those technologies offer the potential for comparable or
superior performance or implementability, fewer adverse effects,
or lower costs than demonstrated technologies;
11
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. A limited number of remedial alternatives for ground water
that attain site-specific remediation levels within different
restoration time periods utilizing one or more different
technologies: and
. The no-action alternative.
The alternatives that were evaluated in detail in the
Feasibility study are described in this section. Eight
alternatives were determined to be appropriate for consideration
at this site. These alternatives provided a range of various
remedial options to satisfy the requirement in the NCP. The
following descriptions summarize the alternatives, including
their treatment components, implementation requirements, the
estimated time for completion and estimated costs.
5.1
NO ACTION
The NCP requires that the no-action alternative be evaluated
for every site. The no-action alternative provides a baseline
for comparing the effectiveness of other remedial options. This
alternative, alternative 1, involves no further action at the
site to prevent the migration of contaminants from the site.
There would be no costs associated with this alternative.
5.2
ISOIATE SOURCE AREAS AND SOIL/
CONDUCT GROUND WATER MONITORING
Alternative 2 would include the installation of a sheet
piling vertical barrier around the contaminated source areas of
the site. Concrete caps would also be placed over the individual
source areas. An extraction well would be used for gradient
control inside the vertical barrier to withdraw water so that
ground water would tend to flow inward. The estimated volume of
contained ground water is 1,403,000 gallons. contaminated water
removed from the extraction wells would be treated using
filtration, polymer injection and settling, and carbon
adsorption. The estimated volume of treated ground water is
526,000 gallons per year for 30 years. The treated water would
be discharged to a publicly owned treatment works facility
(POTW) .
Additional ground water monitoring wells would be installed
and sampled in conjunction with already existing monitoring wells
to confirm the effectiveness of the alternative. The site would
also be fenced to minimize access. Ground water use restrictions
would be implemented for all wells within the contaminant plume.
12
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The installation of the source area caps and barrier would
be expected to take 4 to 6 months. It is estimated that two
years of monitoring would be required to show that the ground
water plume is being contained, however long-term monitoring
would be needed. The construction costs are estimated to be
approximately $1,446,000. Continued monitoring, cap maintenance,
well installation, and ground water extraction and treatment
costs are estimated to be approximately $1,517,000 for 30 years
of operations and maintenance (O&M). This yields a present worth
of $2,963,000 for this alternative.
5.3
CAP SOURCE AREAS AND SOIL/PUMP-CONTAIN-TREAT GROUND WATER
Alternative 3 would involve capping the source areas of
contamination and installing additional extraction wells to
remove and treat the contaminated ground water thus containing
the plume of contamination. The contaminated water would be
treated using filtration, polymer injection and settling, and
carbon adsorption. The estimated volume of treated ground water
is 1,577,000 gallons per year. This water would be discharged to
a POTW.
Additional ground water monitoring wells would be installed
and sampled in conjunction with already existing monitoring wells
to confirm the effectiveness of the alternative. The site would
also be fenced to minimize acces~. Ground water use restrictions
would be implemented for all wells within the contaminant plume.
The installation of the source area caps is estimated to
take 4 to 6 months. The construction costs are estimated to be
approximately $295,000. The time estimated for well
installation, system debugging, and the establishment of the
plume containment would be 13 to 18 months. Continued
monitoring, cap maintenance, and ground water extraction and
treatment costs are estimated to be approximately $3,255,000 for
30 years of O&M. This yields a present worth of $3,550,000 for
this alternative.
5.4
EXCAVATE AND INCINERATE SOURCE AREAS AND SOIL OFFSITE/
CONDUCT GROUND WATER MONITORING
Alternative 4 would include the excavation and thermal
treatment of source areas and contaminated soil areas. The
estimated volume of the source areas to be excavated is
approximately 3800 cubic yards. The volume of soil would be
determined during the Remedial Design/Remedial Action (RA/RA)
phase. The excavated material would be incinerated in an off-
site incinerator. This alternative would also include the
temporary storage, separation, and sizing of excavated material.
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. .
A trial burn plan for the incinerator would be developed
during the RD/RA to ensure that the substantive requirements of
RCRA could be met, including the destruction of contaminants to
an efficiency of at least 99.99%.
During excavation, chemical dust suppressants and/or water
would be used to minimize dust generation. Berms would be
constructed to control surface run-on and run-off and sumps would
be used to collect rain water. All water collected at the site
would be treated using filtration, polymer injection and
settling, and carbon adsorption. This would include the water
currently observed in the gas holder pit area, which would be
discharged to a POTW.
Additional ground water monitoring wells would be installed
and sampled in conjunction with already existing monitoring wells
to confirm the effectiveness of the alternative. The site would
also be fenced to minimize access. Ground wat~r use restrictions
would be implemented for all wells within the contaminant plume.
-
The excavation and incineration is estimated to take 4 to 6
months. It is estimated that two years of monitoring would be
required to show that the ground water plume has been reduced,
however long-term monitoring would be needed. The construction,
incineration, and excavation costs are estimated to be
approximately $875,000. Continued monitoring costs are estimated
to be approximately $197,000 for 30 years of O&M. This yields a
present worth of $1,072,000 for this alternative.
5.5
EXCAVATE AND INCINERATE SOURCE AREAS AND SOIL OFFSITE/
PUMP-CONTAIN-TREAT GROUND WATER
Alternative 5 would include the excavation and incineration
of source areas and contaminated soil areas as described in
section 4.4. In addition, the ground water would be removed and
treated as described in section 4.3.
Additional ground water monitoring wells would be installed
and sampled in conjunction with already existing monitoring wells
to confirm the effectiveness of the alternative. The site would
also be fenced to minimize access. Ground water use restrictions
would be implemented for all wells within the contaminant plume.
The excavation and incineration is expected to take 4 to 6
months. The time estimated for well installation, system
debugging, and the establishment of the plume containment would
be 13 to 18 months. The construction, incineration, excavation,
and extraction well installation costs are estimated to be
approximately $904,000. Continued monitoring and ground water
extraction and treatment costs are estimated to be approximately
$3,247,000 for 30 years of O&M. This yields a present worth of
$4,151,000 for this alternative.
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5.6
EXCAVATE AND INCINERATE SOURCE AREAS AND SOIL OFFSITE/
PUMP-CONTAIN-TREAT GROUND WATER WITH ENHANCED
IN-SITU BIOREMEDIATION
Alternative 6 would include the excavation and thermal
treatment of source areas and contaminated soil areas in
combination with the ground water treatment system using
filtration, polymer injection and settling, and carbon
adsorption, as proposed in Section 4.5 and originally described
in Sections 4.3 and 4.4. This alternative would also include the
injection of nutrient-enriched ground water and engineered
biological organisms into subsurface dense nonaqueous-phase layer
areas to enhance biological degradation.
A pilot or bench-scale study would be performed to determine
the proper nutrients and the proper amounts in order to provide
the best degradation rates. The study would also determine
whether an engineered organism may provide a better degradation
rate and enhance the natural biological population.
After the study is completed, the proper nutrients would be
added to 75% of the treated ground water and reinjected into the
aquifer through an injection well. The extraction system would
pull the enhanced ground water through the dense nonaqueous-phase
layer areas and stimulate biological degradation. A single
injection well would be used during the first two years, during
which time the operating conditions, equipment design and the
overall effectiveness of the system can be evaluated and improved
upon. Soil borings would be drilled and sampled regularly to
determine contaminant characteristics, microbial populations and
nutrient levels. After the second year, two more injection wells
would be installed and operated.
Additional ground water monitoring wells would be installed
and sampled in conjunction with already existing monitoring wells
to confirm the effectiveness of the alternative. The site would
also be fenced to minimize access. Ground water use restrictions
would be implemented for all wells within the contaminant plume.
The excavation and incineration is expected to take 4 to 6
months. The time estimated for well installation, system
debugging, and the establishment of the plume containment would
be 13 to 18 months. The construction, incineration, excavation,
and extraction well installation costs are estimated to be
approximately $1,053,000. Continued monitoring and ground water
extraction and treatment costs are estimated to be approximately
$4,762,000 for 30 years of O&M. This yields a present worth of
$5,815,000 for this alternative.
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5.7
EXCAVATE AND INCINERATE SOURCE AREAS OFFSITE/
EXCAVATE AND BIOLOGICALLY TREAT SOIL AREAS
OFFSITE/PUMP-CONTAIN-TREAT GROUND WATER
Alternative 7 would involve the excavation of source areas,
which would be incinerated as described in Section 4.4. The
contaminated soil areas would be excavated and remediated in an
off-site land treatment unit. Soil areas are defined as non-coal
tar areas that contain contaminants above the 500 ppm total
PAHs/100 ppm carcinogenic PAHs level. The ground water would be
removed and treated as described in Section 4.3.
The land treatment unit would consist of a bermed area which
can be controlled to provide the proper operating conditions for
the biological treatment of the contaminated soil. A
treatability test would be performed to determine the proper
nutrients, amounts and possible engineered organisms to add for
enhanced degradation. The soil would be irrigated to control the
moisture level and the nutrients and organisms would be added and
the soil tilled weekly to provide a proper distribution. The
treatment area would be sampled monthly to determine PAH levels
and nutrient and control levels.
Additional ground water monitoring wells would be installed
and sampled in conjunction with already existing monitoring wells
to confirm the effectiveness of the alternative. The site would
also be fenced to minimize access. Ground water use restrictions
would be implemented for all wells within the contaminant plume.
The excavation and incineration of the source areas is
estimated to take 4 to 6 months. The excavation and biological
treatment of the 50il areas is estimated to take 12 to 16 months.
The time estimated for well installation, system debugging, and
the establishment of the plume containment would be 13 to 18
months. The construction, excavation, incineration, biological
treatment and extraction well installation costs are estimated to
be approximately $1,132,000. Continued monitoring and ground
water extraction and treatment costs are estimated to be
approximately $3,180,000 for 30 years of O&M. This yields a
present worth of $4,312,000 for this alternative.
5.8
EXCAVATE AND INCINERATE SOURCE AREAS OFFSITE/
EXCAVATE AND BIOLOGICALLY TREAT SOIL AREAS
OFFSITE/PUMP-CONTAIN-TREAT GROUND WATER WITH
ENHANCED IN-SITU BIOREMEDIATION
Alternative 8 would involve the excavation and incineration
of source areas and the excavation and biological remediation of
contaminated soi1 areas as proposed in Section 4.7. This
alternative would also include the ground water treatment system
16
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using filtration, polymer injection and settling, and carbon
adsorption used in conjunction with the system described in
Section 4.6 which injects nutrient-enriched ground water and
engineered biological organisms into subsurface dense nonaqueous-
phase layer areas to enhance biological degradation.
Additional ground water monitoring wells would be installed
and sampled in conjunction with already existing monitoring wells
to confirm the effectiveness of the alternative. The site would
also be fenced to minimize access. Ground water use restrictions
would be implemented for all wells within the contaminant plume.
The excavation and incineration of the source areas is
estimated to take 4 to 6 months. The excavation and biological
treatment of the soil areas is estimated to take 12 to 16 months.
The time estimated for well installation, system debugging, and
the establishment of the plume containment would be 13 to 18
months. The construction, excavation, incineration, biological
treatment and extraction well installation costs are estimated to
be approximately $1,282,000. continued monitoring and ground
water extraction and treatment costs are estimated to be
approximately $4,828,000 for 30 years of O&M. This yields a
present worth of $6,110,000 for this alternative.
6.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP has established nine criteria that are used to
evaluate remedial alternatives. These criteria serve as the
basis for conducting detailed analyses during the Feasibility
Study and subsequently are used to determine the appropriate
remedy for the site. Appendix B provides a glossary of the nine
criteria.
A detailed analysis of the remedial alternatives was
performed, consisting of an assessment of the individual
alternatives against each of the nine criteria and a comparative
analysis that focused on the relative performance of each
alternative against those criteria. As a result of this detailed
analysis, EPA has determined that alternative 6 provides the best
balance of trade-offs among the alternatives with respect to the
criteria.
When conducting the analysis, the nine criteria are
organized into three categories. The first such category is
threshold criteria. An alternative must meet the following two
requirements to be considered as a final remedy for the site:
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6.1
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy will involve the excavation and
incineration of the source areas and contaminated soil areas.
The dense nonaqueous-phase layer areas will also be addressed by
the in-situ bioremediation method and ground water will be
cleaned up by the filtration, polymer injection and settling, and
carbon adsorption systems. This will reduce exposure to
contaminated soils and ground water to protective levels and also
minimize the potential for contaminant migration.
The no-action alternative would not provide overall
protection to human health and the environment and was not
evaluated further because this threshold criteria was not met.
The alternatives involving incineration, 4 - 8, would provide the
permanent elimination of long-term residual risk. The long-term
residual risk would also be eliminated by the biological
treatment to health-based levels of the contaminated soil in
alternatives 7 and 8. Neither alternative 2 or 3 would
permanently eliminate residual risk in soil. The ground water
treatment alternatives, 3 and 5 - 8, would provide the overall
protection of human health and the environment that alternatives
2 and 4 would not.
6.2
COMPLIANCE WITH ARARS
The selected remedy will comply with all federal and state
applicable or relevant and appropriate requirements (ARARs).
Applicable requirements are those state or federal requirements
legally applicable to the release or remedial action contemplated
that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance
found at the site. If it is determined that a requirement is not
applicable, it may still be relevant and appropriate to the
circumstances of the release. Requirements are relevant and
appropriate if they address problems or situations sufficiently
similar to the circumstances of the release or remedial action
contemplated, and are well-suited to the site. Table 13 lists
the ARARs for this site.
Applicable chemical-specific requirements associated with
this remedy include the National Ambient Air Quality Standards,
promulgated under the Clean Air Act (CAA). Since the
contaminated aquifer is a present or potential source of drinking
water, the MCLs for this site are relevant and appropriate as
clean-up standards and must be met. Also identified as
applicable for this site are the requirements set forth in the
Iowa Administrative Code Chapter 133 standards discussed in
Section 3.2.
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"
The hazardous waste regulations under Subtitle C of the
Resource Conservation and Recovery Act (RCRA) may be applicable
to wastes at this site as a result of the Toxicity Characteristic
Leaching Procedure (TCLP) regulations, which become effective on
September 25, 1990. If the coal tar sludges and soils
contaminated therewith exceed the TC levels, the wastes would be
hazardous as defined by 40 CFR Part 261, and the hazardous waste
regulations would be applicable. For on-site activity, the
substantive requirements of RCRA pertinent to the remediation
with respect to treatment, storage and disposal would have to be
satisfied. For off-site activities, substantive and
administrative requirements for transportation, treatment,
storage and disposal of hazardous wastes would have to be
complied with. If the coal tar sludges and/or contaminated soils
do not exceed the TC levels, the RCRA requirements would be
considered relevant and appropriate due to the hazardous nature
of the coal tars. Accordingly, the substantive requirements of
RCRA would have to be met.
The potential applicability of the TCLP regulations does not
represent a significant change in the basic features of the
proposed remedy with respect to scope, performance or cost, as
the Proposed Plan contemplated that the selected remedy would
have to comply with the substantive requirements of the RCRA
regulations regardless of the TCLP regulations.
No location-specific ARARs were identified for
The federal action-specific ARARs that the selected
have to comply with are: all pertinent Occupational
Health Act requirements and all Hazardous Materials
Transportation Act regulations; the RCRA regulations found in 40
CFR Parts 264 and/or 266 regarding incineration; the Clean Water
Act regulations applicable to discharge to POTWs; and the CAA
requirements applicable to incinerators. The action-specific
state ARARs include the Iowa Environmental Quality Act
regulations; the Iowa Air Pollution Control Regulations, sections
22.4, 22.5, 23.1, and 23.3; and the Iowa Water Pollution Control
regulations, Sections 62.1, 62.6, 62.8, 62.9 63, 64.2 and 64.3.
Alternatives 2 and 4, which called for ground water
monitoring rather than treatment, would reduce the spread of
contaminants in ground water and provide some protection of human
health and the environment and therefore were appropriate for
consideration to this point. These alternatives, however, would
not meet the chemical-specific ARARs associated with this site.
Therefore, these two alternatives were not considered further
based on their failure to meet the threshold criteria.
the site.
remedy will
Safety and
All the other alternatives would meet the ground water
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All the other alternatives would meet the
cleanup standards previously identified (HALs,
Other chemical-specific ARARs would be met for
alternatives.
ground water
NRLs and MCLs).
all other
The action-specific ARARs would be met for all other
alternatives considered. These ARARs include all OSHA
requirements, all Hazardous Materials Transportation Act
regulations, and the RCRA requirements previously discussed.
The second category of criteria is primary balancing
criteria. The following five criteria were used to evaluate the
alternatives to determine the option that provided the best
balance of trade-offs for the final remedy for the site:
6.3
LONG-TERM EFFECTIVENESS AND PERMANENCE
The incineration of the source areas and soil and the
treatment of ground water' in alternative 6 will eliminate the
long-term risks associated with direct contact and potential
migration from these areas, thus providing a permanent solution.
The dense nonaqueous-phase layer areas will also be addressed by
this alternative. These areas will continue to leach
contaminants into the environment and the enhanced in-situ
biodegradation process will reduce contamination in these areas,
adding to the long-term effectiveness of this alternative.
The other alternatives involving incineration, 5, 7 and 8,
would eliminate the risks associated with source areas and 7 and
8 would provide a permanent remedy for contaminated soils. The
residual risk associated with contaminants in ground water above
health-based levels would be eliminated by alternatives 3, 5, 7
and 8, however long-term ground water monitoring would be
required for all these alternatives. Alternative 3 would not
permanently eliminate residual risk, requiring long-term control
measures throughout the life of the alternative.
6.4
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
The selected remedy treats the contaminant source and soil
areas and the ground water to achieve reduction of toxicity,
mobility and volume of contaminants at the site. The
incineration process provides permanent treatment, but will
generate ash as a residual. The ground water treatment is also
permanent, but will generate used filters, settled floc, and
spent activated carbon. These wastes will be disposed of in
accordance with RCRA. Incineration in accordance with RCRA will
achieve a 99.99% destruction of contaminants. The enhanced
in-situ bioremediation process will reduce the toxicity, mobility
or volume of the dense nonaqueous-phase layer areas. . This will
20
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. .
also reduce the volume of contaminated qround water that will
eventually need to be treated at the site, since these
nonaqueous-phase areas will continue to leach contaminants into
the environment and this process will treat these areas.
The other alternatives involvinq incineration, 5, 7 and 8,
would provide a reduction in the toxicity, mobility and volume,
as would the qround water treatment alternatives. Alternatives 7
and 8 would also provide for the permanent reduction of the
toxicity, mobility or volume of the contaminants in the soil
areas. Alternative 8 would provide for the reduction of
toxicity, mobility or volume of the dense nonaqueous-phase layer
areas as will alternative 6. Alternative 3 would reduce the
mobility of the contaminants, but would not provide for a
reduction of toxicity or volume of source and contaminated soil
areas.
6.5
SHORT-TERM EFFECTIVENESS
The short-term risks associated with the selected remedy
will involve the normal construction hazards associated with the
excavation of source and soil areas and with the construction and
installation of wells. Volatile emissions may also be released
durinq excavation and materials handlinq, and durinq the drilling
and samplinq of wells. This alternative involves the
transportation of wastes and would have short-term risks
associated with off-site transport.
However, any potential for exposure can be effectively
minimized or controlled by compliance with the action-specific
ARARs and by implementinq enqineerinq controls at the site, such
as restrictinq access to the site, monitorinq for volatile
emissions, and adherinq to a site-specific safety plan. In
conformance with OSHA standards, all workers will be
health-and-safety trained, wear the appropriate protective
clothinq, and participate in a medical monitorinq proqram.
The selected alternative will require 4 to 6 months to
complete the removal and treatment of source areas and
contaminated soil. The time estimated for well installation,
system debuqqinq, and the establishment of the plume containment
is 13 to 18 months. The time necessary to achieve a reduction in
contaminant levels to the health-based standards is unknown.
However, this time will be reduced by implementation of the
in-situ bioremediation system, since the coal tar miqration areas
will be left unaddressed without the process.
All other alternatives would also have minimal short-term
risks, as described above. As previously noted, compliance with
the action-specific ARARs would effectively minimize and control
the potential for exposures.
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The other alternatives utilizing incineration would also
require 4 to 6 months to complete the removal and treatment of
source areas and contaminant soil. This same amount of time
would be necessary for the construction of the cap in alternative
3. All the remaining alternatives would require 13 to 18 months
for well installation, system debugging, and the establishment of
the plume containment. The excavation and biological treatment
of the soil areas is estimated to take 12 to 16 months for
alternatives 7 and 8.
6.6
IMPLEMENTABILITY
Implementation of the selected remedy will involve
conventional construction technologies. Excavation, pumping,
decontamination, sizing, and gradient control are frequently used
technologies that have been proven to be effective. Incineration
is a proven technology for coal tar wastes. The filtration,
polymer injection and settling, and carbon adsorption systems are
frequently used processes and have shown to be effective at the
site. This process is currently being used at the site since it
was implemented as the ground water treatment process required to
contain the plume as agreed under the Administrative Order on
Consent between EPA and IELP. The enhanced in-situ
bioremediation process has not been extensively used at coal gas
sites and therefore will be implemented in a phased approach with
a pilot study.
The other alternatives involving incineration and the ground
water treatment system would have the same ease in
implementability. Capping is also a frequently used technology.
The bioremediation of the soil areas in alternatives 7 and 8 has
been previously demonstrated, but will require laboratory and
field studies to demonstrate its effectiveness under site
conditions and the rate and extent of remediation expected for
full-scale operation. This uncertainty in implementability makes
alternatives 7 and 8 less attractive than alternatives 5 or 6.
6.7
COST
The construction cost of the selected remedy is estimated to
be $904,000, plus the estimated added construction costs for the
enhanced in-situ bioremediation process, $149,000. This process
should reduce the amount of time necessary for treating the
contaminated ground water. If the process is proven to be
effective and fully implemented, the added operation and
maintenance costs are estimated to be $1,515,000, for a total
o & M cost of $4,762,000 over 30 years. The present worth cost
is $5,815,000 for 30 years. These costs are listed in Table 14.
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The range of total present worth costs for the alternatives
is $3,550,000 for alternative 3 to $6,100,000 for alternative 8.
The costs figures stated in the ROD are estimates taken from the
RI/FS prepared by IELP. The estimates prepared involve
approximations, assumptions, estimations, and engineering
judgment and may be subject to adjustment. The figures are based
on estimates of the volume of ground water and soil to be treated
and could greatly vary, depending upon the full definition of the
extent of contamination determined in the RD/RA. The figures are
also based on off-site incineration in a coal-fired utility
boiler. The estimates are significantly higher when based upon
off-site incineration at a RCRA facility. Table 15 provides a
cost sensitivity analysis for all alternatives.
The selected remedy is cost-effective because it provides
the best long-term effectiveness and permanence, a reduction in
toxicity, mobility and volume, and short-term effectiveness at
costs that are proportional to its overall effectiveness.
The third category of criteria is modifying criteria. The
following two criteria are considered when evaluating the
alternatives and are used to help determine the final remedy for
the site:
6.8
STATE ACCEPTANCE
The state of Iowa supports the remedy selected for cleanup
of contaminated source areas, soil, and ground water at the
Fairfield site.
6.9
COMMUNITY ACCEPTANCE
Community acceptance of the selected remedy was evaluated
during the public comment period. After minor modifications,
based on comments received, the remedy was selected as described
in this ROD. The comments received are contained in the
Responsiveness Summary, Appendix A.
7.0
SELECTED REMEDY
Based on the detailed analysis conducted for each of the
proposed alternatives, EPA has determined that the appropriate
remedy for the Fairfield site is the excavation and incineration
of the source areas and contaminated soil, used in combination
with a filtration, polymer injection and settling, and carbon
adsorption process to treat the contaminated ground water, with
enhanced in-situ bioremediation. This alternative provides the
best balance of the factors identified by the nine criteria. A
map showing the physical layout of the alternative is provided in
Figure 8.
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. -
The relief gas holder pit will be excavated to 20 feet, 8
feet below the water table. The tar separator will be excavated
to 12 feet. The horizontal extent of excavation will be
determined using the 500 total PAH/100 carcinogenic PAH level.
The vertical extent of excavation may also be adjusted in the
field, based on this level. Excavated material will be separated
on the separator pad, noted as the separator area in Figure 8.
All material greater than 2 inches in diameter will be shredded
in the rubble shredder area. Material less than 2 inches in
diameter will be placed on the contaminated soil storage area
pad, along with source tars, before being transported to the
incinerator. This pad will meet the substantive requirements of
RCRA. All material that cannot be reduced to a manageable size
will be steam-cleaned and sent "for disposal in accordance with
RCRA. The proper transportation requirements will be met and the
trucks will be decontaminated.
Water will be pumped from the gas holder pit and treated in
the ground water treatment system. The cap wi~l be demolished
and all debris will be sized for incineration. The walls of the
pit will be steam-cleaned and then the pit will be filled with
clean fill.
Chemical dust-suppressants and/or water will be used for
dust control during activities at the site. Volatile emissions
will be monitored during all operations. Berms will be
constructed and grading performed to control water run-on and
run- off, and sumps will collect water for treatment. Clean fill
will be added to excavated areas.
The separator pad, sizing pad, and storage pad will all be
4 inch concrete paved pads with berms. Materials will be covered
with 60-mil HPDE liners.
Monitoring wells will be installed west, south and southeast
of the site to confirm the results of the ground water modeling.
Extraction wells will be installed for the removal of ground
water and subsequent treatment. The goal of the treatment
process will be 1 ppb benzene, which corresponds to the 10-6 risk
level. The process will also meet the ground water remediation
levels listed in Table 12, ~hich includes the current detection
limits for carcinogenic PARs. If, in EPA's judgment,
implementation of the selected ground water remedy clearly
demonstrates that it will be technically impracticable to achieve
and maintain the ground water remediation levels established in
this ROD, EPA will re-evaluate those levels. For example, the
cleanup levels for ground water may be re-evaluated if it has
been demonstrated that contaminant levels have ceased to decline
over time and are remaining constant at some statistically
significant level above remediation goals. In such a case, an
24
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well-monitoring will be performed bimonthly after the remedy is
implemented. After the first year, monitoring will be performed
quarterly for 5 years, then biannually for the next thirty years,
to ensure that the remedy was successful.
Table 14 lists the capital costs for each component of the
selected remedy. The total construction costs are estimated to
be $1,053,000 and the total operations and maintenance costs are
estimated to be $4,762,000, giving a total present worth of
$5,815,000.
Changes may be made to the selected remedy during remedial
design work and the processes of construction.
8.0
STATUTORY DETERMINATIONS
The selected remedy satisfies the statutory requirements of
Section 121 of CERCLA, 42 U.S.C. 9721, as follows:
Protection 21 Human Health An9 the Environment
The selected remedy will be protective of human health and
the environment by providing for the permanent destruction of the
source and contaminated soil areas. These areas will be
excavated to a level protective of human health and the
environment that corresponds to the 10-4 risk level. Proper
institutional controls will be taken at the site, including site
fencing, ground water use restrictions and land use restrictions.
The ground water will be treated until the off-site
contaminants are be1o~ health-based standards, providing 4
protection to the 10- risk level for benzene and the 10- risk
level for carcinogenic PAHs. The enhanced in-situ bioremediation
process will address the contaminated dense nonaqueous-phase
layers in the subsurface and determine if these areas can be
effectively treated.
The selected remedy will provide maximized long-term
effectiveness and will reduce the toxicity, mobility and volume
of wastes ~o the greatest extent practicable. The selected
alternative will also have minimal short-term risks and the
proper controls will be taken to minimize these risks.
Compliance with Applicable 2X Relevant and Appropriate Reauire-
ments
The selected remedy complies with all ARARs associated with
this site. All chemical-specific ARARs will be met, including
CAA, RCRA and the Iowa Administrative Code Chapter 133, which
requires one of three standards, MCLs, HALs or NRLs. All
26
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alternate concentration level may be established and/or a
chemical-specific ARAR waiver may be invoked. Any newly
established remediation levels must be protective of human health
and the environment. The ROD will be amended or an explanation
of Significant Differences will be issued to inform the public of
the details if such actions occur.
The water will be treated using filtration, polymer
injection and settling, and carbon adsorption systems. The water
will be pumped into the operations building at a rate of 20
gallons per minute. The water will first be filtered to remove
any oil. This step may not be used if the water is determined to
be free of oil pollutants. The filtration unit will consist of
felt-lined cylinders and bag filters. The bags will be changed
as necessary. The water will then enter a clarifier where a
polymer is injected to promote settling of contaminants. The
sludge that settles out will be periodically pumped to a filter
press and then disposed of in accordance with RCRA. The
supernatant will be then treated in activated carbon vessels.
The estimated changeout per vessel is six months. The system
will be placed off of one vessel onto another during changeout so
that no contaminant gets through. The clean water will be then
discharged to the sewer for disposal in the POTW, or used in the
in-situ ground water treatment process. The whole system will be
monitored daily to control any volatilizations. The discharge
will be sampled quarterly to ensure that the water is below the
pretreatment agreement limits established by the City of
Fairfield for its POTW. If problems develop in the system such
that the pretreatment limits are not met, the system will be
evaluated and changed to meet the levels. The system will
conform to the substantive requirements that apply to tank
regulations under RCRA.
The in-situ bioremediation process will begin with a pilot
study to determine the proper types and amounts of nutrients and
possible engineered organisms to inject into the aquifer for
stimulating natural biological degradation. The nutrients,
dissolved oxygen, and organisms will be added to treated ground
water and reinjected into the aquifer using injection wells.
Injection well placement will be done through a tracer study and
ground water modeling. The system will use one well for the
first two years, during which the process will be evaluated to
determine the operating conditions and equipment design. Soil
borings will be drilled to sample the treated areas. If the
system is shown to be effective, it will be fully implemented
using two more injection wells.
The site will be fenced and ground water and land-use
restrictions will be implemented to prevent activities which
would provide contact with contaminants. Initially,
25
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action-specific ARARs, including all OSHA, RCRA, and DOT
requirements, will also be met. No location-specific ARARs were
identified at this site.
Cost-effectiveness
The overall effectiveness of the selected remedy is
proportional to its estimated cost. The soil excavation and
incineration and the ground water treatment process are necessary
to provide protection of human health and the environment. The
added cost for the pilot 'study and the enhanced in-situ
bioremediation injection well are reasonable when considering the
added protection that will be provided for human health and the
environment in addressing the contaminants. There would be a
reduction in the time needed for treatment of the aquifer,
resulting in a decreased cost.
Utilization of Permanent Solutions and Alternative Treatment
Technoloaies to the Maximum Extent Practicable
The selected remedy utilizes proven technologies in
incineration and the ground water treatment system that can be
effectively implemented. These processes provide the best
solutions in addressing the contaminants at the site. The
enhanced in-situ bioremediation process will provide treatment
for the dense nonaqueous-phase layers which would otherwise have
to be left unattended and therefore significantly add to the time
required for treating the ground water. Therefore this remedy
provides treatment technologies to the maximum extent practicable
at this site.
The selected remedy permanently destroys the contaminated
soil and source areas and treats the off-site ground water to
below health-based standards, providing for long-term
effectiveness and permanence. Alternatives 2, 3 and 4 do not
permanently eliminate risks at the site. All other alternatives
provide permanent protection.
The selected remedy provides maximum reduction of toxicity,
mobility and volume. The other alternatives involving
incineration, 4, 5, 7 and 8, also provide for the reduction of
toxicity, mobility or volume, however alternatives 2 and 4 would
not treat the contaminated ground water. Alternative 3 would not
treat the source and soil areas. Only alternative 8 and the
selected remedy address the reduction of toxicity and volume of
the dense nonaqueous-phase areas.
The short-term risks associated with the selected remedy are
minimal and will be attended to with the proper controls at the
site. The same general short-term risks apply to all
27
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alternatives, however the alternatives utilizing excavation and
transport of waste involve more short-term risks. However these
risks will be minimized through compliance with ARARs.
The selected remedy utilizes proven and implementable
technologies in excavation, incineration and ground water
treatment. The alternative portions employing caps are also
proven and implementable, but less protective. The in-situ
biological alternative portions provide added reduction in the
toxicity, mobility, and volume at a reasonable cost. The
landfarming biological alternative portions will require further
study to determine if they are fully implementable at the site.
In order to satisfy the preference for a permanent solution,
alternatives 2, 3, and 4 were eliminated. Alternatives 7 and 8
would be practicable alternatives if the volume of contaminated
soil was determined to be very large, because the biological
treatment of these soils would be cost-effective only if a large
volume was treated. Of the alternatives that remain, only
alternative 6, the selected remedy, provides the trea~ment
dense nonaqueous-phase areas, which will ultimately reduce
volume and toxicity of contaminants in these areas. This,
turn, will reduce the time necessary for treating the
contaminated ground water, making it more cost-effective than
alternative 5. For these reasons, alternative 6 provides the
best balance of trade-offs with respect to these criteria.
Preference !QL Treatment ~ ~ princioal Element
of the
the
in
The selected remedy involves treatment of the contaminated
soil and source areas by incineration. The ground water is
treated by filtration, polymer injection and settling, and carbon
adsorption. The dense nonaqueous-phase areas will also be
treated by the in-situ enhanced ground water bioremediation
process. Therefore, the statutory preference for remedies that
employ treatment as a principal element is satisfied.
9.0 DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes were made in selecting the preferred
alternative as described in the Proposed Plan.
28
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APPENDIX A
Responsiveness Summary for the Record of Decision
A.
Overview
EPA recommended a remedy which addressed the contamination
at the Fairfield site and made this remedy available to the
public for comment. All comments received from the public are
considered when EPA selects the remedy to be implemented during
the RA. This document summarizes the comments received regarding
the proposed alternative and describes how these comments were
considered and incorporated into the final selection of the
remedy at the site.
The preferred alternative that EPA recommended to the public
for implementation at the Fairfield site was the excavation and
off-site incineration of the source and contaminated soil areas.
This was proposed to be performed in conjunction with the
extraction and treatment of contaminated ground water using
filtration, polymer injection and settling, and carbon adsorption
systems and enhanced in-situ bioremediation of the coal tar
migration areas. Several questions about the site were asked at
the public meeting. The only written comments received were from
the owner and operator of the site, IELP.
B.
Background QD Community Involvement
The presence of coal tar at the site was first brought to
the attention of the community in Fairfield in May, 1985 when
newspaper accounts described the investigation performed by IELP.
The Fairfield site was also in the local newspapers in June, 1988
when the site was proposed for the NPL. In April, 1989 IELP
conducted community interviews as a part of the FS. EPA also
conducted community interviews in March, 1990, during which the
community was informed of future site activities, including the
public comment process.
EPA distributed fact sheets that provided background
information on the Fairfield site during the public meeting. The
Administrative Record, which included the RIIFS Report and the
Proposed Plan, was made available to the public at the Fairfield
Public Library and at the EPA Region VII Office in Kansas City,
Kansas in July, 1990.
The notice of availability of site-related documents and the
announcement of the public comment period and the public meeting
were published in the Fairfield County Ledaer in July, 1990. The
public comment period was held from July 17 to August 15, 1990.
29
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The public meeting was held in Fairfield on July 26, 1990. EPA,
in coordination with IDNR, the Iowa Department of Public Health,
and ATSDR, met with representatives from IELP and the public and
answered questions from the public related to the site.
'.
C.
SummarY 2t Public Comments and ~ Aaency Response
This responsiveness summary addresses the oral and written
comments received by EPA concerning the alternative preferred by
EPA which was presented in the Proposed Plan, and has now been
selected for implementation in the ROD. These comments were
submitted during the public comment period and/or the public
meeting.
A comment letter was submitted by the responsible party for
the site, IELP. This comment letter contained the only written
comments received during the public comment period. IELP's
comments are summarized as follows, with EPA's response after
each individual comment.
1. IELP comments that MCLs are relevant and appropriate at
the site, but not applicable. They base this on the fact that
ground water from the water bearing units in the site area is not
currently being used as a domestic water supply and the
hydrogeological conditions make it technically infeasible for
ground water from these units to be used as a water supply
source.
EPA's Response: EPA disagrees with IELP's statement that the
hydrogeological conditions make it technically infeasible for
ground water from these units to be used as a water supply
source. Wells in this area have been used in the past and are
currently being used for yard and garden watering purposes. A
downgradient resident could at any time place a well which would
draw ground water and use this well for a drinking water source.
EPA agrees that MCLs are relevant and appropriate as aquifer
cleanup standards on the federal level. However, the state of
Iowa has adopted the MCLs into Iowa Chapter 133, and this law is
applicable at the site.
2. IELP comments that Iowa Chapter 133 is applicable to
the cleanup of the ground water at the site, but it does not
believe that it is feasible or practical to remove all
contaminants to the Chapter 133 goals, based on the
hydrogeological conditions at the site, the physical
characteristics of the dense nonaqueous-phase liquids and the
chemical characteristics of the PARs. Specifically, IELP feels
that the 1 ppb for benzene and 0.0023 ppb for benzo(a)pyrene
cannot be practically attained. They also state that the
0.0023 ppb detection limit for benzo(a)pyrene is unattainable.
30
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. .
EPA's Response: As stated in the ROD, the performance standards
will be re-evaluated if EPA determines that it is technically
impracticable to achieve and maintain them. If the remedial
goals cannot be reached, EPA may establish an alternate
concentration level and/or invoke a chemical-specific ARAR waiver
based on technical impracticability. Any newly established level
must be protective of human health and the environment. The
Proposed Plan incorrectly stated the detection limit for
benzo(a)pyrene as 0.0023 ppb: the correct value is 0.023 ppb.
This level is attainable only under ideal, controlled laboratory
conditions. The practical detection limit for benzo(a)pyrene
that is stated as the standard to be attained in the ROD is 0.2
ppb. The remediation levels/detection limits for ground water
are listed in Table 12.
3. IELP noted a mistake in the Proposed Plgn: the
carcinoienic risk to current residents is 4 X 10- rather than
4 X 10-
EPA's Response: This correction has been noted and the ROD
reflects the change.
4. IELP comments that the FS states that the first
injection well would operate for a minimum of two years prior to
the installation of any additional injection wells. Two years
would give more time to define the microbial populations and
nutrient levels, contaminate degradation and the
effectiveness of the in-situ bioremediation.
EPA's Response: The Proposed Plan indicated that a single year
would be used to study the injection well and the effectiveness
of the in-situ bioremediation system. EPA agrees that two years
would be more beneficial than a single year for studying the
process and has reflected this change in the ROD.
5. IELP comments that filtration is not normally required,
but was used as a temporary measure to treat water pumped from
the source areas during the interim (pre-RI/FS) ground water
treatment system, required under the Administrative Order on
Consent to retard the spread of the contaminant plume.
EPA's Response: Filtration was used to remove oil from the
ground water as an initial measure of the treatment process.
stated in the ROD, this step may not be used if the water is
determined to be free of oil pollutants.
During the public meeting, the community asked questions
about the site and the remedy proposed. These questions were
fully answered during the public meeting, and a transcript of the
meeting is available in the administrative record. No. comments
were received which pertained to the selection of the proposed
remedy or other remedies.
As
31
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APPENDIX B
GLOSSARY OF EVALUATION CRITERIA
The following evaluation criteria were developed by EPA to
address CERCLA statutory requirements and technical, cost, and
institutional considerations. The evaluation criteria serve as
the basis for conducting the detailed analyses during the
Feasibility Study and for subsequently selecting an appropriate
remedial action.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Alternatives are assessed as to
adequate protection from risks above
contamination present at the site by
controlling exposures.
whether they can provide
health-based levels posed by
eliminating, reducing, or
COMPLIANCE WITH ARARS
The alternatives are assessed as to whether they attain
applicable or relevant and appropriate requirements of other
Federal and State environmental and public health laws or provide
grounds for invoking a waiver.
LONG-TERM EFFECTIVENESS AND PERMANENCE
The magnitude of risk remaining after implementation of the
alternative is evaluated. The adequacy and reliability of
controls used to manage treatment residuals or untreated wastes
that remain at the site are also assessed.
REDUCTION OF TOXICITY, MOBILITY AND VOLUME
The degree to which the alternatives employ treatment that
reduces toxicity, mobility, or volume is assessed.
SHORT-TERM EFFECTIVENESS
The alternatives are evaluated with respect to their effects
on human health and the environment during implementation of the
alternative.
IMPLEMENTABILITY
The technical and administrative feasibility of implementing
an alternative and the availability of services and materials are
evaluated.
32
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COST
Direct and indirect capital costs and operation and
maintenance costs incurred over the life of the project are
identified.
STATE ACCEPTANCE
Technical and administrative issues and concerns the state
may have regarding the alternatives are assessed.
COMMUNITY ACCEPTANCE
The issues and concerns of the public regarding the
alternatives are assessed.
33
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Table 1
Summary of Maximum Contaminant Concentrations for Source Areas
. Source Areas
Compounds Gas Holder Pit Tar Separator Relief Gas Holder
of
Concem sediment suriace water soil soil groundwater
(oom) (Deb) (POm) (oom) (oob\
Total Carcinogenic 22400 2140 1406 12.1 475
PAHs
Total PAHs 248300 39780 6604 79 7501
BETX 131000 930 6.89 1413 101200
Arsenic 8.9 61 5.2 9.8
Barium 79 1500 170 360
Cadmium 4.6 98.2 2.9 75.3
Chromium 84 72 35 11 369
lead 1900 1900 12 89 7710
Mercury 1.8 34
Selenium 16 69
Cyanide 310 29000 63 1870
Reference: BVWST.199O .
Blank spaces indicate that the analyte was undetected or detected below
the CRDL for that sample.
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Table 2
Summary o' Maximum Contaminant Concentrations 'or Surface and Shallow Subsurface Soils
locations of Soil Samples
Compounds Concentrations (oom)
o'
Concern 910 816 817 B20 B22 B23 B24 825 B26 827 B29 830 831 833
Total Carc. 0.726 228 7.184 8.968 37.6 3.22 0.847 2.609 16.56 0.043 11.83 7.915 48.7 1.924
PAHs
Total PAHs 1.26 332 9.026 15.512 187.7 4.686 1.564 6.457 25.06 0.054 24.94 30.3T 191.9 13.97
BETX 0.009 0.16 15.8 3.32 0.19 6.72 27.8 20.3 0.34
Arsenic NA NA 4 5.6 18 9.7 5.5 18 NA NA NA
Barium NA NA 180 200 250 88 320 120 250 340 NA NA NA
Cadmium NA NA 1.6 NA NA NA
Chromium NA NA 58 22 14 15 17 52 16 29 26 NA NA NA
lead NA NA 13 35 15 170 29 59 65 30 33 NA NA NA
Mercury NA NA 0.19 0.15 0.67 0.18 0.12 NA NA NA
Sefenium NA NA 1.2 1.1 1.9 NA NA NA
- -
Cyanide NA NA 9.4 29 200 44 3 1.1 5.2
Reference: BVWST,1990
Blank spaces indicate that the analyte was not detected or detected below the CROL tor that sample.
NA = Indicates that the sample was not analyzed 'or that compound.
-------
Table 3
Summary of Maximum Contaminant Concentrations for Subsurface Solis
locations of SoH Samples
Compounds Concentrations 'ppm)
of
Concern 810 821 829 830 831 833 FI2S FI30 FI7 FI8 FI-6
(backaround)
Total Carcinogenic 0.088 58.69 30.95 0.002 0.006 0.006 0.003 0.002 10 0.109
PAHs
Total PAHs 0.183 312.916 200.95 0.01 0.043 0.046 0.004 0.007 30.23 0.21~
BETX 2.7 7000 473 0.011 0.05 0.02 0.007 0.068 0.034
Arsenic 6.2 6.2 NA NA NA 6 5.1 6.8 4.6
Barium 62 57 170 NA NA NA 76 44 110
Cadmium NA NA NA 1.5
Chromium 14 18 18 NA NA NA 10 38 6.5
lead 23 22 8.2 NA NA NA 8.7 12 9.5 8.6
.Mercury NA NA NA 0.17
Selenium 1.1 NA NA NA 1.5
Cyanide -
Re'erence: BVWST. 1990
Blank spaces Indicate that the analyte was not detected or detected below the CROl for that sample.
NA = Indicates that the sample was not analyzed 'or that compound.
-------
Table 4
Summary of Maximum Contaminant Concentrations for Groundwater
We" locations
Compounds Concentrations (ugJI)
of
Concern
F12S FI2 FI3 FI30 A6. FI7 FI8 FIO AA FIC FIO AE MW2 EX1 EX2 824
T olal Cartlnoge.." 0 0 133.8 0 0 0 108 0 0 0 0 0 475 5.4
PAHs .
Total PAHs 0.12 0.24 3316.4 0.07 2874 1307.99 5176 0.03 0.11 0.81 0.14 3085 7501 369
BETIC 470 58430 6560 10110 104900 38 NA NA 57900 101200 85
Ar-* 18 NA NA NA 77
88rtum 500 580 050 420 NA NA 540 NA 2000
c.tmIum NA NA NA 75.3 56
Ctwomum 40 NA NA NA 360 120
Lead 26 18 18 41 . NA NA NA 7710 450
Mercury 022 022 NA NA NA 4.7
SelenIum NA NA 6.6 NA 8.1
Cyanide 7 18 25 NA 83 6.1 NA NA 10.0 1870 910
Reference: BVWST, 1990
. .. Background well
Blank spaces indicate that1he compound was undetected for that sample.
NI\ = Indicates that the sample was not analyzed for that compound.
-------
Chemical
Semi-Volatiles
2.4-Dim.thylphenol
2-M.thylphenol
4-Mfthylphenol
Dibenzofuran
Phenol
Volatiles
Acetone
Chloroform
Methylene Chloride
Styrene
ll1!
lenzene
Ethylbenzene
Toluene
Xylene
&
AClnaphthlnl
AClnaphthylenl
Anthraclnl
'Inzo(I)lnthrlc.ne
'tnzo(l)pyrenl
'Inzo(l)fluorlntblne
'.nzo(l.h.1)p.ryl.n.
TABl.E ,
CHEMICALS DETECTED IN SOURCE-RELATED
GROUND WATER SAMPLES
'requ.ncy of
Detection (a)
1/3
2/3
2/3
3/3
2/3
1/3
1/3
1/3
3/3
5/9
4/9
4/9
4/9
4/9
4/9
4/9
Z/9
2/9
2/9
2/9
lana' of
Ptuct10n
LhtdU. ulll
10
10
10
10
100 - 5000
34 - 2500
50 - 2500
5.0 - 8.0
5.0
5.0 - 34
5.0 - 5.000
0.02
0.02 - 0.05
0.02
0.02 - 0.'Z6
0.02 - 0.16
0.02 - 0.08
0.02 - 0.09
lana' of
Conc.ntration..
Ul11
3.900
7.0 -
19 -
7600
19000
19 - 36
30 - 6100
310
34
200
690 - 1700
710 - 73.000
430 - 1100
390 - 24000
2,000 - 6300
1.7 - sa
36 - 250
S.' - 61
26 - 29
17 - 19
11 - 12
5.0 - 7.0
continu.d-
(I) Number of lamples in whieh the chemical vas positively detected over
the n~ber of lample. Ivailable,
-------
!AJLE , (Contin~ed)
CHEM!CALS DETECTED IN SOURCE-RELATED
GROUND VA!ER SAMPLES
l.anae of l.anae of
Frequlncy of Detection Concentrations.
Chemical Deuction (a) ~imi tI. 1.1211 1.11. !l
Ilnzo(k)fl~oranthene 2/9 0.02 0.08 11-12
Chrysene 219 0.02 - 0.21 25 - 29
Dibenz(a.h)anthracene 119 0.02 - 10.0 2.5
Fl~oranthene 419 0.02 0.49 - 47
Fl~orene 419 0.02 15 - 110
Indeno(1.2.3-cd)pyrene 219 0.02 - 0.07 4.0 - 5.7
2-Methylnaphthalene 313 540 - 880
Naphthalene 619 0.02 0.003 - 4400
Phenanthrene 419 0.02 14 - 220
Pyrene 419 0.02 1.0 - 70
Me ta 1 s
Alu:Unum 5/6 200 320 - 23.000
Barium 5/6 140 - 200 140 - 920
Copper 1/6 25 - 29 27
Iron 5/6 140 640 - 14000
1.ud 2/6 6.4 - 12.0 9.8 - 41
Kaanlliwn 6/6 13000 - 49000
Hanlan..e 5/6 15 200 - 2100
Zinc 5/6 37 " - 210
Cyanide 4/7 5.0 6.1 - 25
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TABLE'
ORGANIC CHEM!CALS DETECTED IN SOURCE-RELATED SOIL SAMPLES
lanae of lange of Site
Frequency of Detection Concentrations,
Chemical Detection (a) Lhl'lts. ua/lei Ui/lei
Semi - Volu U IS
ais(2-!thylhezyl)
Phthalate 3/1. 370 - 3,900 280 - 2,1.00
2,I.-Dimethylphenol 1/1. 360 - 3,900 7,000
Dibenzofuran 2/4 370 - 3,900 900 - 15,000
2-Methylphenol 1/4 360 - 3,900 1.,700
I.-Hethylphenol 1/1. 360 - 3,900 190
Phenol 1/1. 360 - 3,900 7,100
Vola tiles
Acetone 1/26 12 22
BEn:
Benzene 16/32 5.3 - 71,000 5.0 - 1,800,000
Ethylbenzene 10/32 5.3 - 71,000 89 - 300,000
Toluene 21/32 5.3 - 71,000 6 - 2,900,000
Xylene 12/32 5.3 - 71,000 7 - 2,000,000
PAR
Acenaphthene 20/32 0.07 - 19,000 1.1 - 93,000
Acenaphthylene 25/32 0.07 - 190,000 1.2 - 660,000
Anthracene 21/32 0.07 - 19,000 3.4 - 540,000
.enzo(.).nthr.cene 26/32 0.07 - 19,000 0.86 - 280,000
aenzo(.)pyune 25/32 250.07 - 19,000 1,1 - 280,000
..nzo(b)fluor.nthene 19/32 0.07 - 19,000 1.8 - 13,000
aenzO(I,h,i)p8rylene 24/32 0.07 - 1,700 0.8 - 45,000
a8nzo(le)fluoranthene 21/32 0.07 - 19,000 1.3 - 410,000
Chryune 29/32 0.07 - 19,000 1.0 - seo,ooo
Dibenz(a,h)anthrac8ne 16/32 0.07 - 1,700 3.0 - 17,000
continuec1-
(a) N~ber of .amples in which tht chemical vas positively detectec1 over
the n~ber of ,.mples where the .nalysis VIS perfor.mec1
-------
TABLE. (Continued)
ORGANIC CHEMICALS DETECTED IN SOURCE-RELATED SOIL SAMPLES
lanae of lanae of Si te
Frequency of Detection Concentration.,
Chemical Detection LiaU tI. Ul/kl UII kR
Pluonnthene 27/32 0.07 - 19,000 0.86 - 440,000
Fluorene 23/32 0.07 - 19,000 '.7 - 560,000
IndenoCl,2,3-cd)pyrene 20/32 0.07 - 1,700 2.2- 390,000
2-Hethylnaphthalene 2/4 370 - 3,900 96 - 39,000
Ha ph thalene 25/32 0.07 - 190,000 3.2 - 830.000
Phenanthrene 26/32 0.07 - 190,000 1.1 - 1,100,000
Pyrene 27/32 0.07 - 19,000 1.2 - 930,000
-------
Chemical
He till
Aluminum
Arsenic
Barium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Mangsnese
~ercury
Nickel
Vanadium
Zinc
Cyanide
TABU: 7
COMPARISION OF CONCENTRATIONS OF METALS IN SOURCE-RELATED
SOIL SAMPLES TO RIPRESENTATIVE BACKGROUND CONCENTRATIONS
rrequlncy of
Detection
26/26
11/26
21/26
23/26
5126
24/26
26/26
26/26
26/26
26/26
3126
11/26
6/26
26/26
9/26
laDle of
Detection
L41114 tI. UR fkR
40 - 59
2.1 - 5.1
43 - 59
2.1 - 3.0
11 - 15
5.3 - 7.4
21 - 30
1.1 - 12
1,100 - 1,500
3.2 - 4.4
0.11 - 0.15
8.5 - 12
11 - 15
4.3 - 5.9
0.27 - 7.4
laDle of Sitl
Conclntration. ,
URfkR
l,S08 . 19,000
2.7 . 21
26 - 360
11 - 52
12 . 32
7.3 .
2,400
4.5 -
68
- 40,000
170
aeprellntat1ve
Jacklround 50i1
CODcentrations,
uRfh Ca)
57,000 - 90,000
7.2 - 20
200 - 1,000
50 . 100
3 - 30
10 . 70
18,000 - 51,000
15 - 50
2,300 - 10,000
70 - 2,000
0.03 - 0.260
15 . 70
70 - 150
31 . 194
HACb)
(a) aacklround concentration. of metals in loil (ran,e) are provided hire
for comparison purpoles. (Connor and Shacklette, 1975)
(b) Not available.
1,200 - 11,000
66 - 1.500
,12 - .67
11 . 64
9.2 . 53
18 - 1100
1.1 . 200
-------
TABL.E ,
SUMMARY OF EXPOSURE POINT CONCENTRATIONS
Ezpoltd Ezpolure
Po'Oulations Hec!iUD'l Chemic:al
Preltnt Offliu Ground- lariUD'l
luidenu vater Lud
(FI-A) Cyanide
len&ene
Future Offsi te
Residents
Ground
Toul PAMs
Carc:inoaenic: PAMs
Na=-~thalene
vater
(FI-3)
2,4-Dimethyl phenol
2-Methyl Naphthalene
2-Methylphenol
4-Methylphenol
Diblnzofuran
Phenol
lenl.ene
£thylbenune
Styrene
Toluene
Xylene
lariUD'l
Cyanide
Ezposure Point
Conc:entration,
111.2 11
4.2 £-1
4.1 £-2
6.1 £-3
3.8 £-2
3.8 £+0
1.1 £-1
2.1 £+0
3.9 £+0
7.3 E-1
7.6 £+0
1.9 £+1
2.5 £-2
6.1 £+0
3.4 £+l
4.3 £-1
1.5 £+0
1.4 £+1
3.1 £+0
9.5 £-1
2.5 £-2
-------
TABL£ t (Continued)
SUMMARY OF EXPOSURE POINT CONCENTRATIONS(a)
Exposure Point
Exposed Expolun Concentration. ID&/kg(b)
Pot)ulations Medium Chemical loil. mall vaUr
Futuu Offliu Soil (c ) lenzene t.!!-l
Worken !thylbenune 3.6[+0
Toluene 3.5!-1
Xylene 1.5E+1
Carcinoaenic PAHs 2.8[+1
Naphthalene 1.7£+1
Cyanide 2.9£+0
Future Onsi te Soiled) Benze'ne 4.0£+2
Workers Ethylbenzene 7.0£+1
Toluene 7.2£+2
Xylene 4.9£+2
Carcinogenic PAHs 3.3£+2
Naphthalene 1. 9£+2
Styrene 3.0[-3
Cyanide 5.2£+1
(c)
(d)
Only contaminantl of concern which ~re detected at .ach r..pective
expolure point are lilted in thil table.
Concentrationl are the'S percent upper confidence ltmit on the
arithmetic avera., of mea lured concentrationl in loil.
Sample numbers: 129-501. 129-$01~. 130-$01. 131-501. 133-501. !3~-SOl
Sample numbers: 114-501. 115-501. 118-$01. 118A-50l. 120-501.
121-501. 122-501. 122-502. 123-501. 124-501. 124-502. 125-50i.
126-501. 127-501. 127-502.
(a)
(b)
-------
TABL.E q
EXPOSURE ASSESSMENT ~ESULTS . DAILY INTAKES
AveraRe Daily Intakek
8I./kl-dn
Subchronic
Po~ulation !%~o,ure Path~v Chemical and Chronic Lifetime
-5 ,.lZ10.6
Current IDlution of ladum 1.6z10
-6 .7
I.uidlnt Iroundvaur whilt Lead 1.6sl0 7.0z10
-7 .7
watering Cyanide 2.4zl0 1.0z10
-6 .7
'.nzlnt 1.5zl0 6.5z10
-8 -9
Inhalation of Btnzene 1.1z10 4..5xlO
contaminant.
volatilized from
groundwater while
vatering
Ingestion of Cyanide -2 -3
1.b10 8.3%10
produce Irawn Benunt -lo .lo
3.3z10 1..5x10
using contaminated
,roundvatlr for
vatering
Future Insution of Toul PAMs -2 .2
3.2z10 1. 3z1 0
Resident Iroundva tlr Carclnolenic PAMs -3 .2
'.5x10 1. 3xlO
Ifa ph tha ltne 1.1x10.1 .2
4.6sl0
2.4-Di8ethylphenol 1.2x10-1 .2
4 . txl 0
2.Methyl Napthallne 2.2x10.2 .3
t.1x10
Z-Kethylphenol Z.)x10-1 -2
'.4&10
4.KetbylpheDol 5.5x10.1 .1
2.SX10
Dlbenlofuran 7.5&10.4 S.1.xlO.4
'henol 1.8&10.1 .2
7. 6sl 0
Benzene t.tx10.1 .1
, . 1xl 0
Ethylbenunt 1.0%10.2 -3
..2x10
Styrene 3.8x10-2 .2
1.hlO
Toluene 3.8z10.1 -1
1.hlO
-------
Pooula tion
Future
luident
TABLE ~ (Continued)
EXPOSURE ASSESSMENT lESULTS . DAILY INTAKES
Exoolure Pathway
Ingution of
Groundwater
Dermal Contact
in the Shower
Inhalation in
t.ht Shover
Chemical
Averaal Daily Intake.
IDJI./ka.dav
Subchronic
and Chronic Liflt~e
Xylene
Barium
Cyanide
-1
1.1z10
-2
2.8&10
-4
7.2xl0
-2
4.7&10
-2
1.1xl0
-4
3.0xl0
2.4.Di~ethylphenol 3. 2xlO-2 -2
1.hlO
2.Methylphenol 6.4&10-2 -2
2.7xlO
4-Methylphenol 1.7&10.1 .2
7. 3xlO
Phenol -2 .2
2.7xl0 1.lxlO
Benzene -1 .1
7.2xl0 3.blO
Ethylbenune -5 .6
1.8xl0 7. 7xlO
Styrene -5 .5
4.1xlO 1. 7xl 0
Toluene .4 .4
6.1xl0 2. 6xlO
Xylene -4 .5
2.0xl0 8.hlO
Barium -5 .5
4.0xl0 1.7xlO
Toul PIJI. 3.1xl0.2 -2
1. 3xl 0
Carcinogenic PAS. -4 .3
3.4x10 1.5xl0
Naphthalene 1.lZ10-1 -2
4.6&1 0
2.4-Dtmethylphtnol 1.2&10-1 -2
5.0&10
2-Ktt.hylnaphthaltne 2.2&10-2 -3
,. '&10
2-Ktthylphenol 2.2&10-1 -2
'.5&10
4-Kethylphtnol 5.4&10-1 ~1
2.3&10
Dibenzofuran 7. Sxl0-4 -4
3.1&10
Phenol 1.8xl0-1 -2
7.7&10
Benzine 9.hl0.1 -1
4.1&10
!thylbenune 9.hl0-3 -3
4.3&10
3.7&10-2 .2
Styrene 1.6x10
Toluene 3.7&10-1 .1
1.6%10
Xyllne 1.4&10-1 -2
6.1&10
-------
TAILE q (Continued)
EXPOSURE ASSESSMENT RESUlTS - DAILY INTAKES
,
,
AveraRe Daily IntaKe.
IDa/kR-dn
Subchronlc
Pooulation Exoosure Pa thwa v Chemical and Chronic Lifetime
Future Inlntion of loil -7 -8
I.n&ene 1.4xl0 6.blO
Workers offsitt -7 -7
Ithylbenune 8.3x10 3.hlO
toluene -8 -8
8.1z10 3.5xlO
Xylene -6 -6
'.5z10 1.5z10
Carcinogenic PARs -6 -6
6.4xlO 2.hlO
Naphthalene -6 -6
3.blO 1.7xlO
Cyanide -7 -7
2 . lz1 0 2.blO
Ingestion of soil Benzene . -5 -5
9 . 2zl 0 4.0xlO
onsite Ethylbenune -5 -6
1.hlO 7.0z10
Toluene -4 -5
1. 7xl 0 7.2:110
Xylene -4 -5
1.lz10 4.blO
Carcinogenic PARs -5 -5
7.hlO 3.3xlO
Naphthalene -S -S
4.4z10 1.blO
Styrene 6.9x10-10 3.0z10-10
CyanieSt -5 -6
1. 2z10 5.2z10
Dermal contact len&ene -6 -6
8.5zl0 3.hl0
with 1011 offaite Ethylbenzene -5 -5
4. b10 2.lz10
Toluene -6 -6
4.7xl0 2.0xlO
Xylene -4 -5
2.0xl0 '.6%10
Carcinogenic PAHa -4 -4
1.5z10 6.4zl0
Naphtha line 5 -5
'.2z10- S. 'dO
CyanieSe 1.6xl0-5 -6
6.7xl0
~erma1 contact .enun. 5.4z10-3 -3
2.Sz10
with loi1 onlite Itby1benune ,.4Z10.' -4
4.0dO
'ol\1ln. ,.7&10.2 -3
4.1z10
Xylen. I.Izl0., -3
2.lxl0
Carcinol.nic PAHa l.hl0.' -4
7.6%10
1.0Xl0-' -4
Naphthalene 4 .4dO
4.1zl0.' -8
Styrene 1.7dO
Cyanide -4 -4
2.h10 1.2%10
-------
TMl( I'
OIM. ClUnCAl TOIIICITY VAlU£S fOl IORCMCl!IOCrllC rrfrCf5
Sullchrontc If 0 Chrontc lro Conf IdPnc@ lro UncertaInty""
a.'ell ...'k'-9Y ...'kq-day L~,,~I Crtt 1(11 (ffed ~ Nodlfylnq fac:tors(8)
Ien.ene .fbJ P@ftdlng IllS
4-flethy''''''. ,-llete."....,(c) 5(-1 5(-2 fled I.. DK~.sed body wtgllt tlfn. 1115 ur-I.OOO for H.A.S: "'-1
MUroto.lc It)'
[,.. ,de K-2 2£-2 fled t.. II@IQht Iou. thyrotd 1115 ur-I- for H.A: "'-5
~I I f'C t s. II}'e Iln ...,..t fon
Otl_ror...
2.4-0'-1'" '.-..'
(thy '''''nne 1(.0 1(-1 Low LIver .nd .Idney tOllfe: ft, IllS ur-I.OOO 'or ".A.S: "'-1
PfM!no' 1(-1 6(-1 low I~ed f@t., body _tgM IllS ur-IOO for H.A: "'-1
..,..the ,- 4(-1 U-I(d) Ocu'.r Ind tnternal l"fOM U5£PA . 100 for H.A
1984'
Styrene 2£-1 fledf.. aed blood cen end Uwr IllS .-1.000 'or ".A.S: "'-1
~ffKts
loluene 4(-1 ](-1 fled I.. C"ntcal c_fstry. IllS . . 100 for H.A: "'-1
""tot09I(l1 plrl8den
Jly'enn 4(.0 2£.0 fled I.. Ifrperac:t tvlty. dKrMsed IllS ur.IOO for H.A: "'-1
body w 'Qht . Increased
80rtallty (8II~sJ
lIDncerc IlIOfIIIk 'MIs
18rt.. 5(-2 5(-2 fled I.. fetotoltctt,. tncrMsed IllS ar-loo for H.A: "'-1
blood pressure
lead
(I' "ert.'nty MJIII"",: .. wartltlon In ~ s@nsltl"tt,: A- Inl..t to hu88n @.trlpolltlon: 5 - e.trapollt'an fra8
subchronle to c"",,,le MRl.
(b) 110 9t..
(cJ AID based an .tlled e:resols (fnellllll", 2-.1- and 4-_thylphenol)
(d) Value currently under r~lftI by OrIIRIO Wort Group.
-------
Chndcal
TABLE II
OIAL CRITICAL TOXICITY VALUES FOR POTENTIAL CARCINOGENIC EPFECTS
Slope Factor (S,)(a)
-I
(ltJl/kR.lday)
Weight-of-Evidence
Classification
Type of Cancel'
SP Source
8enzene
2.9E-2
A
Leuke81la
IRIS 1989
4-Hethylphenol (Cl'eloll)
D
USEPA 1984b
Cyanide
D
IRIS 1989
Dlbenzofunn
2,4-Di~thylphenol
StYl'ene
D IRIS 1989
D USEPA 1984d
1.15EH(c) 82 St.-ch REAST 1989
3.0E-2(d) 82/C Lunl USEPA 1988
D IRIS 1989
D IRIS 1989
D USEPA 1989
Ethyl benzene
Phenol
Cal'cinolenic PARI
Toluene
Xylenel
"a pthalene
8al'1..
Lead
(a) Based on ad.inl.tered do.e unle.. otherwise noted.
(b) "0 oral data (r08 which SP ..y be derived.
(c) Baaed on benzo(a)pyrene. Thi. .alue is currently under review. (Use of these numbers .pproved by
USEPA (Telecon on 01/16/90 bet~en William Bunn, USEPA R~ for site end Hike HcNelly, ICAIR,
Life Syste.s).
(d) Currently under Alency review (IRIS, 1989).
-------
TABLE 12
REMEDIATION LEVELS/DETECTION LIMITS IN GROUND WATER
Contaminant
Remediation Level
(ppb)
Standard/Detection Limit
Benzene
1
Negligible Cancer Risk Level
Lifetime Health Advisory Level
Ethylbenzene
700
Toluene
2,000
Lifetime Health Advisory Level
Lifetime Health Advisory Level
Xylene
Naphthalene
10,000
20
Lifetime Health Advisory Level
Benzo(a) anthracene
0.1
practical detection limit
practical detection limit
Benzo(a)pyrene
0.2
Benzo(b)fluoranthene
Benzo(k)fluoranthene
0.2
practical detection limit
0.2
practical detection limit
practical detection limit
Chrysene
0.2
Dibenz(a,h)anthracene
0.3
practical detection limit
Indenopyrene
0.4
practical detection limit
-------
Chemicet ~ Specific !!!!!
ReGI i relllent
~ ::he.lcet-Speclflc !!!!!!
Sefe Drinking W.ter Act
(SOWA) :
N.tlonel Prl..ry
Drinking Weter Stend8rds
(MelS)
".111- Cont_I.,...t
Levels Goals (MeLGs)
Solid Weste Disposet
Act (S\II)A):
ldentlflc.tlon end
Listing of HezerdOus
Weste
cu.tlon
40 U.S.C. Sect. 300
40 C.F.R. P.rt 141
40 CFR 141. 50
141.51
40 U.S.C. Sect.
6901-6987
40 C.F.R. P.rt 261
TABLE 13
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
Description
Estebllshes heelth-bese
stend8rds for public weter
syst- (_lIi-
cont.-lnent levels).
Estebllshes drinking weter
~I Ity goels.
Defines those solid westes
""'Ich .re stbject to reg-
uletlon es hezerdOus
westes under 40 C.F.R. Perts
262-265 end Perts 124. 270
end 271).
Appllceblel
Re\event end
Approoriete
Yes
No
see COlllllent
~
The Mels for orgenlc end inorgenlc
cont_I.,...ts .re rei event end
epproprl.te for the ret8edl.tlon of ground
w.ter cont_lnetlon since the risk essesSllent
eveluetes potentiel future use of the
ground weter .s . drinking source.
No non-zero MeLG' Mere .ssocleted
with the cont.-I.,...t, present.
. ReRA requirelllents .re
eppt Icebte I f west" .re TCLP
ch.recterlstic. If not TCLP
ch.recteristic. RCRA requirelllents
ere relevent end epproprlete. end
substentive requirements wl\1 be Met.
. (see COII'IIICnt)
-------
ReQUl retnent
Cleen Afr Act:
MatlGn8t prl..ry end
Secondery AMbfent Afr
Quel fty Stendards
(MAAQA)
State Chellfcat .:. Specfffc !!!!!
lowe Envlr~tat
GuIIllty Act:
Rules for Dete...lnlng
Ctellfq) Act Ions end
Responsible Parties.
~ Action .:. Specfflc ARARs
Sotfd Waste Dfsposat
Act (SWA):
Crfterla for classfflcatfon
of Solfd Waste Dfsposat
facltltles end Practices
Hazardous Waste Menegetnent
Systems General
Cftatfon
42 U.I.C. Sect.
7401.7642
40 C.f... Part 50
lowe Code
Chapter 133
Effective 8/16/89
42 U.S.C. Sect.
6901-6987
40 C.f... Part 251
40 C.f.R. Part 260
TABLE 13 (Cont.)
ARARs
DescriPtion
Estabtlshes standards for
_lent air quat ity to
protect ptbl ic heat th and
welfare.
Estabtishes cleanup levets
for cont.ineted groundwater
and soil.
Defines .Solid Waste.
Establishes crfteria for use fn
dete...inlng which sot Id Nestes
disposat facitftles and practices
pose a reasGn8ble probability of
adverse effects on heatth and
therebv constitute prohibited
open ~.
Establishes procedUre and
criteria for modification or
revocation o~ any provision in
40 C.f.R. Par' ~60--76S.
AWl !cablel
Relevant !!!!!
ApproPriate
Yes
Yes
Yes
see conment
C.AIIIIb1t
lIMOS ..y be appt feebte to
the Falrffeld fMGP site during
remedlat act Ions.
These regutatlons are
eppt Icable to any .01 t or
,rOU1dwater cont.ineted
above 'owe action tevels.
Wa.tes at the Falrfletd .Ite are
.ot Id .,ast" end the .lte I. an open
~. Thl. pert woutd be eppt Icabte
to relledlat alternatives that Invotve
the dtsposat off-site of solid wastes as
defined In Subtltte o.
.
-------
TABLE 13 (Cont.)
ARARs
An>I Icablel
Relevant ~
R~i relllmt Citation DescrlDtlon Appropriate C(8lt1!!nt
Identification end listing 40 C.F.'. Part 261 Defines those solid wastes which see conrnent .
of Hazardous Wastes are subject to regulation as
hazardous wastes under 40 C.F.R.
Parts 262-265 and Parts 124,
240, and 271.
Stend8rds Applicable to 40 C.F.'. Part 262 Establishes standards for see conrnent .
Generators of Hazardous generators of hazardous waste.
Waste
Standards Appllcab'e to 40 C.F.R. Part 263 Establishes standards which see c~t .
Transporters of Hazardous apply to persons transporting
Waste hazardous waste within the u.s.
if the transportation requires
a -.nifest under 40 C.F.R.
Part 262.
Standards for OWnera and 40 C.F.'. Part 264 Estab'lshes .Ini.u. see COllllll!nt .
Operators of hazardous national stenderds which define
Waste treat8ent, Storeve, the acceptable .nag.-nt of
end Disposal Facilities. hazardous waste for owners and
operators of facl'ltles which
treat,store, or dispose of
hazardous waste.
40 C.F.'. Part 264
StjJpart 8 General Facility Standards lee conrnent .
40 CFR 264.14 Security
S...rt G
Closure and Post-Closure
see comnent
.
-------
ReQU I rement
Citation
St8nd8rds for Owners
end Operatora of Hazardous
Waste 'reat~t, Storage, and
Disposal facilities
(Conti~)
~rt"
~rtl
Stjjpart 0
Standards for the "BlIIIg!.....t
of Specific Hazardous Wastes
and Specific Types of
Hazardous Waste "8n8g~t
facilities
40 C.f... Part 266
Hazardous Weste Pe~it
Progr-
40 C.f.R. Part 270
Occupational Safety end
Health Act:
29 U.S.C. Sect.
651 -618
Hazardous Vaste Operatfons
end EMergency Response,
Final Rule.
29 CfR 1910.1Z0
TABLE 13 (Cont.)
ARARs
Description
Tanh
Waste Piles
Incinerators
Boiler Reguletlons
Establishes provisions
covering beslc EPA pe~ltting
requi retlltnts
Regulates worker health end
safety.
Establish training, medical
8Onitoring and workplace
regulations and standards
for all work done at
halardou~ waste sites.
Appllcablel
Relevant and
Appropriate
Yes
Yes
see connent
see connent
see connent
Yes
Yes
COIlfileflt
If TClP characterl.tlc, not applicable
bec-e westes are treated In t"a
within a 90 day tl- fr... S\AJstentlve
requi r~t8 will be _t.
If TClP characteristic, these requlr~ta
ere not applicable because wastes
are treated within a .Ingle area of
cont8ll1natlon. SlJIstentlve requir~t8
will be _to
.
Applicable If hazardous waltee ere
burned a. fuel in Industrial furnace
or boiler.
.
Under 40 C.f... Sect 300.38
requir~t. of the Act apply to all
response ectlvltles under the _CPo
These regulations are applicable
to all remedial activities conducted at
the Fairfield site.
-------
Requl rC!llll!f'lt
Clution
Clean Water Act:
33 U.S.C. Sect.
1251 - 1316
~Ient Water ouellty
Criteria Guidelines
(AWCG)
40 C.F.R. Part 131
Gu8llty Criteria for
water, 1916, 1980,
1986
latlonel Pretreat~t
Standards
40 C.F.R. Part 403
Cleen Air Act:
42 U.S.C. Sect.
1401 - 7642
latlonel ~Ient Air
Gu8llty Standards/
IESHAPSIISPS/BACT/
PSO/LAU
40 C.F.R. 60. 1 ".17,
.50 - .54, .150 " .154
.480 . .489,
40 C.F.R. 53.1 -.3]
40 C.F.R. 61.01 - .18
.50 - .112, 240 " .247
Hazardous "aterlals
Transportation Act:
49 U.S.C. Sect.
1801.1813
Hazardous "aterlals
Transportation Regulations
49 C.F.R. Parts 101,
111-171
TABLE 13 (Cont.)
ARARs
Description
Sets criteria for water
quality based on tOlliclty
to aquatic orgenisms and
h~ health.
. Sets standards to control
pollutents which pess through
or Interfere with treat~t
processes In publicly owned
treat.ent works (POTW) or which
.y cont-lnate sewage sludge.
Sets treat.ent technology
standards for e.lssions
to air frOl8:
. Incinerators
. fugitive e.isslons
Regulates transportation of
hazardous _terials.
Appl icable/
Relevant and
Appropriate
Yes
Yes
Yes
Yes
COIIIIIent
AwoeGs for PAHs and arOl88tl,s are
relevent and appropriate to all
re.edles which discharge groundwater to a
POTW or surface water.
Theae standards are applicable to
all alternatives that involve discharge to
POTW.
Theae requlr~ts are applicable
to any alternatives that Involve
e.laslone r89\llated by these atandards.
These requlr.-ents are eppllceble
to all alternatives that Involve transport of
cont.-lnated .terlals frOl8 the site.
-------
lleau I rtlllent
Cltet Ion
St.te Action .:. SDeClflc !!!!!
low. Envlroment81 Quellty
Act:
Enec:ted 19n, .s
.-ended, chapter 4558
of lowe Code
Annotated.
4558.430
lowe Air Pollution
Control Regulations
22.4 or 22.5
23.1 E.Isslons
Stendards
23.3 (4558)
Specific Cont..lnents
62.1(6)
(3) and (4)
TABLE 13 (Cont.)
ARARS
Description
The pen8llslon of IDNR's
Director II required to
chenge the use of a slt8
on the Registry of 8bendoned
or uncontrolled disposal
sites.
Establishes require.ents for
..jor stationary sources in
attainment/unclassified areas
(22.4) or nonattainBent areas
(22.5)
Establishes e.isslon Itenderds Yes
for new sources end for hazardous
air pollutants.
Establishes stenderds for
v8rious cont8lllinents.
Prohibits disch8rges to POTWs
without. pretre8tment
agreement.
Adopts the following Federal
r~guI8tions: '0 CFR Part '03
nnd '0 crR Part 125, Subpart H.
Applicable/
Relevant and
Approoriate
Yes
Yes
Yes
Yes
Yes
~
The Fairfield 81te I. en
uncontrolled welte 81te es defined by
the Act. Therefore thl. section of
the lev Is applicable.
These regul.tlons (either 22.4 or 22.5)
.re applicable to any remedial activities
taken at the site, luch 8S incineration
or eJlc.vatlon.
These regul.tlons would be
applicable to certain newlources luch
.s Inclneretorl and to ..I 51 Ions of hU8rdous
pollutantl.
These regul.tlons would apply to
reMedl.1 actions.
These prohlbltlous would apply to
any offsite dlsch8rges to a POTU.
These regulations would be applicable
to discharge from the site to a POTY.
-------
TABLE 13 (Cont.)
ARARs
R eau i rement
Citation
O~scrlDtion
lowe "et~r Pollution Control
Reguletions (continued)
62.6
Esteblish~s how IONR will 6~t
~fffuent fillitetions or
pr~tr~etment requirements
for pollutents for which th~r~
er~ no federel stenderds.
62.8 (3) end (4)
Esteblishes how IONR ..y s~t
pretreetllent requirements which
ere IIOre stringent then current
stenderds if necessery.
63 Monitoring.
Anelytlnl and
Reporting
Require8Mts
This chapter ~steblishes
requir~t for these
ectivities.
64.2(3)
Establishes siting crit~rie
thet IRJSt be c~1 ied with
when bui Iding e new weste-
weter disposal syste..
64.3 (5)
Require8Mts for Industries
thet discherge to enoth~r
disposel system.
ADDI iceble~
Rel~vent end
ADDrODriete
COlllKn~
Y~s
These regulstlons would be
eppliceble to dlscherge fr08
the site to e POT".
Yes
These requl reaents -V ~
eppl ied to eny discharges fr08 the
site to a POT". If IONR ~ It neces8ery.
Yes
Off-site dllposel options .uBt
c~ly with all portions of thll chapter.
Onelte dllposal options .utt c~ly with
the lubstantlve requlreaentl (63.3(1)
through 63.3(4».
Y~s
There regulations would epply to any
treat~t lyet.. built to rellediate the
groundwater.
. Yes
These regulations would apply to
any reaedlal option that discharged
treated weter to a POT".
10 location. IPKffic ARAII are applicable or relevent and 8ppf'oprlete to the feirffeld site (see Rl/fS chapter 8 for 80re ~taHI on aU ARARI).
-------
TABLE 1~
COQStr'UCuoo COlt Estimate - Altem&tive 6
Excavate Soil " lDciDerate Offsitel
Pump-CootaiD-Treat GTOUDd Water F.ntul~ With
IIt-SiIu BioremtJdiJboo
(1990 $)
UNrr TOTAL
m:M QUAN'TTTY UNfTS COST COST
FENCING
Chain Unk Fenct (8' High) 850 UNFT '16.00 88.000
Oa" (~. Opening) 2 EA '1,200.00 82.000
EXCAVATION 3.800 CUYD '10.00 838.000
RELOCATE GAS LINES LS IS ,000
BACKFILL 3.800 CUYC '10.00 138,000
HDPE LINER (60 mil) 30.000 SQFT 80.60 '18,000
CONCRETE STORAGE PACS W)
Contamlnaled Soil 91ora;. (85' x 65') 5.525 SQFT 12.30 '13,000
SourCI Aria Mallrial Separation (40' x 40') 1.600 SOFT 12.30 14 ,000
RubOll SIZing (55' x 40') 2.200 SOFT 12.30 IS ,000
SEPARATOR rw/2. SCREEN) 2 MONTH 88.250.00 '17.000
RUBBLE SHREAOER 2 MONTH 127.500.00 1S5.oo0
TRANSPORTATION (@)200 MILES) 22~ TRIP 8900.00 1202,000
INCINERA TlON/TREA TMENT
OFF SITE INCINERATION
Mat.rial Handling EQuip. LS 12S.000
Incinlration (fu.VHanOling) 5.850 TONS "..0 126.000
AI" Dis;>osal 5.270 TONS '7.00 137.000
WELL INSTAU.ATlON
Monitoring (. .0' DlPth) 3 EA 83.000.00 89.000
Extrac110n 2 EA ..000.00 '18.000
MW-5 Sample AnaIyIiI , EA ",0'5.00 '1 ,r#)
DECONT~INA'T1ON
ArM Construction & EQulQment Rental LS 823.000
Oo8rlUon 10 DAY 880.00 15 ,COO
washWiter DiIPOUI (5OO;pd) .0,000 GAl 80.10 ",000
-------
TABLE 1't (coat)
Ccmtructioo COlt Eatimate - AJte.mative 6
Excavate Soil ci IDciDerate Offsit.eJ
Pump
-------
TABLE 1'f Ceooc~)
o &c. M Costs aDd Present Wortb &timate - Alternative 6
Excavate Soil &c. lDciDerate OffIiteJ
Pump-CamaiD-Treat GrouDd Water J:J'lh.8~ WUb
ID-Situ BioremMi,rion
(1990 $)
rTEM
QUAHTTTY
UNrT'S
TOTAl
COST
INC1NERA 110N11'N:ATUENT
GROUNDWATER MONITORING
Slmpl' ColleCtion & Repon
Fil'll Vear (Bimontl'lly)
Vears 2-5 (Quan.rly)
Vears 6-30 (Biannually)
Slmpl. AnalysiS.
First Vear (Bimonthly)
Vears 2-5 (Quan.rly)
Vears 6-30 (Biannually)
30 MANDA V S
20 MANOA VS
10 MANDA VS
18
12
6
EA
EA
EA
GROUND WATER PUMPING (~ 3 GAUMIN)
LS
GROUND WATER TREATMENT
1,577.000
GAL
TREATED WATER ANAL VSIS
12
EA
BIOREMEDIAllON
INJECTION WEU LABOR
Vear 1
Year 2
Year 3-30
75 MANOA VS
80 MANOAYS
52 MANDAYS
ANAL VTlCAL COSTS
Drilling
MobID8mcD
D8con
Crew per C:hem
IVWST/Sit. SlIMy
SoIl Ana/yIIS
UNIT
COST
1600.00
1600.00
. 1600.00
11.015.00
11,015.00
" ,015.00
80.10
'1,015.00
MOO. 00
8100.00
8800.00
" 8.000
112.000
16,000
"8,000
"2,000
16.000
88.000 .,
"58.000 ..
"2.000 ..
~.OOO
836.000
831 .200
S EA 82.000.00 ..000
LS 82.500.00 80
S EA 1oWO.00 81,320
S DAYS 82.0.00 8720
S MANOAYS 8800.00 81,800
12 EA 81.250.00 815,000
NVT'R'ENT SYSTEM
Nutrl.nts
Maint.nanc. and UpkMP
LS 11,000 ..
LS 12.500 ..
LS 110,000 ..
OVERSIGHT AND SUPERVISION
-------
'!,
. .
TABLE 1 ~ (coot)
o &t M Costs a.od PreleDt Worth &timate - AltenJ&tive 6
Excavate Soil &t IDciDera!e Offsi~
Pump-CaamiD-Treat 0r0uDd Water """..nced With
ID-SibJ Bi~ltiQD
(1990 $)
I'T'8'
UN",
COlT
TOTAL
CCI8T
OUAHTTTY
UNn'8
EQUIPMENT REP1.ACEMENT COSTS
Year 5
Vear10
Year 15
Vllr 20
VNr2S
TOTAl. 0 & M COSTS
Pr.lnt Won"lntlr8$! Ratl @
5.~
TOTAL CONSTRUCTION COSTS(From Tabll 10-12)
838.000
838.000
'1.8.000
838.000
838.000
".762.000
'1.053.000
TOT AL PRESENT WORTH -
ALTERNATE 6
15.815.000
. Samples would be COlltC18d from MW-3. MW-c, and EX-3.
.. Annual casts
-------
TABLE II;
Cost Sensitivity Aaalysis
ALTERNATIve DISCOUNT RATE GROUNDWATER TREA n.4ENT
(Glllons per Year)
3CMI 51M1 (Base) 1 OIMI -SOIMI Base .50%
No 1 - No Action NA NA NA NA NA NA
NO 2 - c.p & Contain Sourc. ArNSl
Conduct Groundwlt.r MonltO/'ing 13,249,000 12,867,000 12,327,000 12,34 1,000 12.867,000 13.374.000
(263.000) (526.000) (789,000)
No 3 - Dewallr & c.p SoYrc. ArIUJ
Pump-Contaln- Tr..t Ground Water: 14.423,000 13.~.000 12.101,000 12.101.000 13."5.000 14.809,000
(788.500) (1.577 ,000) (2.365.500)
No 4 - Excavat. & Inclnerat. SoiV
Ground Wiler MonllO/'ing:
OffsJt. tncineration 11,077.000 11,034.000 8971,000 NA NA NA
Offslt. Incineration "4.98.5.000 $14.955.000 $14.899.000 NA NA NA
Atl RCRA Facility.
No 5 - Excavate & Incinerate Soill
Pump-COntain- Tr..t Ground Water:
Oflslte InCineration 15.145.000 14.151.000 12.759.000 12.797.000 14.151.000 15.505.000
(788.500) (1,577,000) (2.365,500)
OfISite Incineration 119.024.000 $18.030,000 $16.638.000 "6.676.000 $18.030.000 119.384.000
At a RCRA Facility. (788,500) (1.577.000) (2.365 .500)
No 6 - Excavate & InCInerate Soil/
Pump-Cc,ntain- Treat Ground Water
W,ln In-Silu Bioremedialion
Offsire InCineration $7.116.000 15,829.000 ".012,000 104.257.000 15.829.000 17.402.000
(788.500) (1,577,000) (2.365.500)
Oftsi.. Incineration 120.054.000 $18.767.000 $16.950.000 "7.195.000 $18.767.000 120.340.000
At a RCRA Facility. (788.500) <, .577 .000) (2.365.500)
No 7 - Excavall SoiVLand Farm &
Incinerall OffsitIlPump-Contlin-
Tr..t Ground Waler
Otfslt. Incineration 14,994.000 14,312.000 13.295.000 13,005 ,000 14,312.000 15.620.000
(788.500) (1,577 ,000) (2,365.500)
Offsit. Incineration .'2,817,000 112.185.000 "'.188.000 11,087,000 "2.185.000 " 3.493.000
At a RCRA Facility' (788,500) <, ,577 .000) (2,365,500)
No 8 - ExcavIII Soil/LInd Firm &
Incinerat. OffsilllPump-Contaln-
Tr..t-BiO/'emediate Ground Wat.r
Offsil. Incineration '7.398,000 86,110.000 14,290,000 14,537,000 86.110,000 17.682.000
(788.500) (1.517 .000) (2.365,500)
OtfSile Incineration $15.272.000 S13,~.000 $12.1S..ooo "2.4'1.000 S1 3.~.000 "5,556.000
AI a RCRA Facility. (788.500) (1,577.000) (2.365.500)
NA -- NOt ApphclDle
. Ottsit. Incin.ration cOSts II I RCRA Facility ar. to/' comparison only.
Off Site Incineralion at a RCRA Facility is nO! a proposed alt.rnative.
-------
TABLE 15 (coot)
Cost Sensitivity Analysis
AL. TERNATIVE SOIL & SEDIMENT VOLUME
"
(CubiC Yards)
-5~ Bue .5~
No 1 - No Action NA NA NA
No 2 - Cap & Contain Sourc. ArtUI
ConduCt GrOUndwater Monitoring NA NA NA
No 3 - Dew..t.r , Cap Sourc. Art&Sl
Pu"",-Contain- Trllt Ground Wat.r NA NA NA
No ~ - Excavat. & Incin.rat. SoiU
Ground Wat.r Monitoring:
OHSilt Incin.ration 8681.000 ".034.000 11.381.000
(1.800) (3,800) (5.100)
Oftsit. Incin.ration $1.623.000 114.955.000 122,201.000
At a RCRA Facility. (1.900) (3.800) (5.700)
No 5 - Excavate & Incinerate Soil!
Pump-Contain- Treat Ground Water:
OffSilt InCineration 13.807.000 "'.151,000 '''',~Sl2.ooo
(1 ,8(0) (3.800) (5.100)
OOsit. Incineration 110,147.000 118.030.000 825.311.000
AI I RCRA Facility. (1.800) (3,800) (5.100)
No 6 - Excavate & Incin.rat8 Soill
Pump-Contain- Treal Ground Waler
Witl'l In-Situ Bior.mtdiatlon
OOSit8 Incineration 15.500.000 15.829.000 86.158.000
(1 .900) (3.800) (5.100)
Offsit. Incineration '11.910,000 118.161,000 125.565,000
At I RCRA Facility. (1.900) (3.800) (5.700)
No 7 - ExcaV11t Soil/Una Farm &
Incin.rat. Oftsit&IPump-Contain-
Treal Ground Wat8f
OttsIt. Incinwation 83.989.000 "'.312.000 "'.620.000
(1,800) (3.800) (5.700)
Oftsltt Incin.ration '7,136.000 "2.185.000 "6.430.000
Ala RCRA Facility. (1,800) (3.800) (5.700)
No 8 - Excavil. SoIIIl.Ina Farm &
Incln.rat. OffSit&IPump.Contain-
Treat-Bior.mtdlalt Ground WIt.r
OttsItt Incln.,alion 85.114.000 .. "0,000 ..431.000
(1,800) (3.800) (5,700)
0H1it. Incineration 88.711.000 "3.884,000 "8.250.000
At a RCRA FaCility. (1.800) (3,800) (5,700)
NA -- NOt Applicabl.
. Oft,it. Inclneralion cOSts II a RCRA Facility art for comparlaon only.
Offsilt Incinll'alion al a RCRA Facility 18 nOC a propCMd alternative.
11-16
-------
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IllIG
STATE OF
I
SITE: ~,F: :.:...
10#; ~:-YIL,..t
BREAK:~
OTHER:
TERRY E. BRANSTAO. GOV£RNOR
DEPARTMENT OF NATURAL RESOURCES
LARRY J, WILSON, OIREC.OR
..
At
september 19, 1990
RECEiVED
SEP 20 1990
REME S~CTir.,~'
Mr. Craig Smith, P.E.
Superfund Branch
u.S. Environmental Protection
Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Agency
Dear Craig:
We have reviewed the draft copy of Record of Decision (ROD)
for the Fairfield site in Iowa. The selected remedy which
includes source removal and incineration of coal tar,
groundwater treatment system, and in-situ bioremediation of
tar contaminated areas complies with the State requirements.
Therefore, we concur with your declaration of the ROD for
this site.
Please feel free to call me with your questions.
Sincerely yours,
//11 ,41;) "
ll0/~ / /~~
Morris Preston, P.E.
Supervisor
Solid Waste section
WALLACE STATE OFFICE BUILDING / DES MOINES. IOWA 50319/515.281.5145
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