United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R07-93/065
September 1993
SEPA Superfund
Record of Decision
McGraw Edison, IA
-------
4.
50272-101
REPORT DOCUMENTATION ,1. REPORTNO. .
PAGE EPA/ROD/R07-93/065
TIlle and Subtitle
SUPERFUND RECORD OF DECISION
McGraw Edison, IA
First Remedial Action - Final
Awhor(a)
:t
3. RecIpi8nt'a Ace_Ion No.
5.
Report D8t8
09/24/93
&.
7.
8.
P8rformlng Organization Rept. No.
9.
P8rformlng Organization Name and Add,..
10 Proj8c:t TaklWork Unit No.
11. Contract(C) or Granl(G) No.
(C)
(G)
12. Spon8aring Organization Name and Add,..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Raport & PwIocI Cov8f'8d
Agency
800/800
14.
15. SuppIemeIUry NeII-
PB94-964310
1&.. AbetI'8Ct (Umlt: 200 word8)
The 13-acre McGraw Edison site is a former manufacturing facility located in
Centerville, Appanoose County, Iowa. Land use in the area is predominantly residential
and industrial, with the upper and lower Centerville reservoirs locat~d approximately
one mile southwest of the site. Surface water exiting the site to the southwest
even~ually drains into the Centerville reservoirs; while surface water exiting to the
northeast flows eastward toward Hickory Creek and the Chariton River, which is located
approximately 3 miles from the site. From 1965 to 1978, McGraw Edison manufactured
toasters and toaster ovens in a 194,800-square foot building that housed the onsite
manufacturing operations. The manufacturing operations included nickel and chromium
plating processes, which generated wastes including plating solids and rinse water.
The rinse water associated with the plating operations was treated in an onsite
wastewater treatment facility, while the plating solids were discharged to drying beds
located on the west side of the wastewater treatment facility. In addition, TCE was
used to clean the plating equipment in the manufacturing building and was stored in a
5,OOO-gallon above-ground storage tank located in the manufacturing area. The improper
'disposal of plating sludge and spills of TCE from the storage tank are the primary
(See Attached Page)
17. DocumenI Analysis L Descriptors
Record of Decision - McGraw Edison, IA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, TCE,
,(arsenic, chromium,
toluene, xylenes), other organics (PAHs), met~ls
lead)
b.
1d8nl1fie1'8lOpen-End8d Terms
Co
COSA71 Fi8WGroup
18. Availability Statement
19. Security CIaa (This Report)
None
:II. Security CIaa (This P9)
None
21. No. of Page.
98
22. Price
(See ANSI-ZH.18)
S.1n8t1ucti0n8 OIl "-
OPTIONAL FORM 272 (4-77)
=:rty NTlS-35)
men! of Con'!-
-------
EPA/ROD/R07-93/065
McGraw Edison, IA
First Remedial Action - Final
Abstract (Continued)
sources of contamination at the site. In 1986, State investigations identified hazardous
substances at the facility including two cinder-block lined lagoons containing chrome
plating sludge, a large tank of TCE, and drums containing caustic substances. Subsequent
EPA investigations indicated the presence of elevated levels of several heavy metals,
including chromium and arsenic, in the lagoon sludge; as well as VOCs, including TCE, in
soil, ground water, and surface water onsite. In 1988, EPA required Cooper Industries and
the previous owner to remove the plating solids from the drying beds. VOCs were found to
have contaminated an offsite residential well on an adjacent property, and the residents
using this well were provided with a permanent alternate water supply. In 1989, Cooper
Industries performed a removal action at the site which included removing the sludge from
the lagoons, removing plumbing and equipment from th~manufacturing building and the water
treatment building, decontaminating equipment and the interior concrete floor surfaces,
removing soil contaminated with metals from the north of the manufacturing building, and
backfilling excavated areas with clean soil. During the removal, additional plating
sludge was found in the soil to the north of the manufacturing building, in the subsurface
soil along the northern property line, and in the former disposal pits. In addition, two
product vaults were found that contained liquids contaminated with chromium and nickel.
In 1990, a second removal action was performed to address liquid wastes and soil
contamination. During 1991 and 1992, approximately 1,720 tons of contaminated soil were
excavated and transported for offsite disposal, and approximately 34,850 gallons of
liquids were sent to a recycling facility. This ROD addresses a final remedy for the
potential threats posed by the contaminated media at the site. The primary contaminants
of concern affecting the soil and ground water are VOCs, including benzene, TCE, toluene,
and xylenes; other organics, including PARs; and metals, including arsenic, chromium, and
lead.
Th~ selected final remedial action for this site includes "installing and utilizing_a soil
vapor extraction system to remove VOCs from the soil in the source area; venting extracted
vapor to ambient air with or without treatment using either carbon adsorption or catalytic
oxidation; constructing an asphalt cap "over the source area; providing for a contingent
remedy to excavate soil, with onsite treatment using low temperature thermal desorption,
if treatability testing indicates that the selected remedy is not feasible; extracting and
treating ground water onsite, using ultraviolet oxidation; discharging treated water to
either an off site POTW or to onsite surface water; providing for a contingent remedy to
extract VOCs, using granular activated carbon, if treatability testing indicates that the
selected remedy is not feasible; and monitoring ground water annually to evaluate the
e~fectiveness of the treatment system. The estimated present worth cost for this remedial
action is $5,300,000. The estimated present worth cost for the contingent remedies ranges
from $7,350,000 to $11,950,000.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil cleanup goals are based on protecting the quality
ground water, and include TCE 200 ug/kg. Chemical-specific ground water
based on SDWA MCLs, and include TCE 5 ug/l.
of the underlying
cleanup goals are
-------
RECORD OF DECISION
MCGRAW-EDISON FACILITY
CENTERVILLE, IOWA
Prepared by:
u.s. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 1993
-------
RECORD OF DECISION
DECLARATION
SITE NAME AND LOCATION
McGraw-Edison Facility
centerville,Iowa
STATEMENT AND PURPOSE
This decision document presents the selected remedial action
for the McGraw-Edison Facility, located in Centerville, Iowa.
This decision was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), 42 U.S.C. 9601 et seq. as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the
extent practicable the National Contingency Plan (NCP), 40 CFR
Part 300 (1990). The Regional Administrator has been delegated
the authority to approve this Record of Decision.
STATEMENT OF BASIS
This aecision is based on the administrative record compiled
for the Site which was developed in accordance with Section
113(k) of CERCLA, 42 U.S.C. 9613 (k). The Administrative Record
is available for public review at the centerville Public Library
located at 115 South Drake, Centerville, Iowa and at the
Environmental Protection Agency (EPA) Regional Office located at
726 Minnesota Avenue, Kansas city, Kansas.
ASSESSMENT OF THE SITE
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), present a current or
potential threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Site is a comprehensive approach
for the complete remediation of the principal threats posed by
the Site. This approach will address trichloroethene (TCE)
contamination of the subsurface soils and ground water.
The major components of the selected remedy include:
-------
Soil Contamination
Construct an asphalt cap over the soils where TCE
contamination has been detected at depth;
Install soil vents and air inlet wells to improve the
circulation of air through the subsurface soils;
Connect the soil vents and air inlet wells to a vacuum
system to remove the TCE-contaminated vapors from the
subsurface soils; and
Monitor the effectiveness of the system.
Ground Water Contamination
Install extraction wells in the contaminated ground water
zones;
Extract the ground water;
Treat the ground water using ultraviolet catalyzed oxidation
technology;
Discharge the treated water to the surface or to the
publicly owned treatment works (POTW); and
Monitor semi-annually the effectiveness of the ground water
treatment system.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are applicable or relevant and appropriate (ARARs) to this
remedial action, and is cost effective. The remedy satisfies the
statutory preference for remedies that employ treatment and
reduce the toxicity, mobility, or volume as a principal element
and utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable.
This remedy will result in hazardous substances remaining
on-site above health-based levels until the ground water cleanup
is achieved. A review will be conducted within five years after
commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
/foill/am W. Rice Date/ /
Acting Regional Administrator
IT.S. EPA, Region VII
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RECORD OF DECISION
DECISION SUMMARY
MCGRAW-EDISON FACILITY
CENTERVILLE, IOWA
Prepared by:
u.S. Environmental Protection Aqency
Reqion VII
Kansas City, Kansas
September 1993
-------
MCGRAW-EDXSON FACXLXTY
RECORD OF DECXSXON
DECXSXON SUMMARY
TABLE OF CONTENTS
PAGE
1.0 SITE NAME, LOCATION AND DESCRIPTION
...................
1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES ...............
1
2.1 site History
... ...................... II... .............
1
2.2 site Investigations...................................
6
2.3 Enforcement Activities ................................ 13
2.4 National Priorities List Status ....................... 15
3.0 COMMUNITY PARTICIPATION. ........ ..... ................. 15
4.0 SCOPE AND ROLE OF RESPONSE ACTION ..................... 16
5.0 $ITE CHARACTERISTICS SUMMARY.......................... 16
6.0 SU11MARY OF SITE RISKS................................. 17
7.0 REMEDIAL GOALS
........................................ 37
8.0' DESCRIPTION OF ALTERNATIVES... . . . . . . . . . . . . . . . . . . . . . . .. 37
8.1 Ground Water Remedial Alternatives .................... 39
8.1.1
No Action Alternative (GW-l) ....................... 39
8.1. 2
Limited Action Alternative (GW-2) .................. 39
8.1.3
Granular Activated Carbon Treatment ................ 41
8.1.4
Ultraviolet Catalyzed oxidation Treatment .......... 41
'8.1.5
Air Stripper Treatment ............................. 44
8.1.6
Chemically Enhanced Solubilization with
Air Stripper Treatment ............................. 44
8.2 Soil Remedial Alter~atives ............................ 46
8.2.1
No Action................... . . . . . . . . . . . . . . . . . . . . . .. 46
8.2.2
Limi ted Action...... '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 46 '
-------
TABLE OF CONTENTS (continued)
PAGE
8.2.3
In-situ Treatment
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 48
8.2.4
Excavation and Disposal
Off-site ................... 48
8.2.5
Excavation and Disposal On-site
. . . . . . . . . . . . . . . . . . .. 52
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ....... 52
9.1 Overall Protection of Human Health
and the Environment............................... 55
9.2 Compliance with ARARs ................................. 56
9.3 Long-Term Effectiveness............................... 56
9.4 Reduction of Toxicity, Mobility or Volume ............. 57
9.5 Short-Term Effectiveness .............................. 58
9.6 Implementabil i ty ...................................... 58
9 . 7 Cost.................................................'. 59
9.8 State_Acceptance ...................................... 60
9.9 Community Acceptance.................................. 60
10.0 THE SELECTED REMEDY...................... ~ . . . . . . . . . . .. 60
10.1 Ground Water
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 62
10.2 Soils................................................. 63
11.0 STATUTORY DETERMINATIONS.............................. 64
12.0 DOCUMENTATION OF SIGNIFICANT CHANGES .................. 64
13.0 GLOSSARY.............................................. 65
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FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
LIST OF FIGURES
PAGE
SITE VICINITY MAP
........ .............. ..................
2
TOPOGRAPHIC RELIEF
MAP [[[
3
APPROXIMATE EXTENT OF MCGRAW-EDISON SITE .........
4
MANUFACTURING BUILDING ...........................
5
DIRECTION OF SURFACE WATER FLOW..................
7
MONITORING WELL LOCATIONS
...... ...... ... ...........
9
APPROXIMATE EXTENT OF VOC SOIL CONTAMINATION ..... 11
CROSS-SECTION OF INDICATED SUBSURFACE FEATURES.... 12
VOC CONTAMINANT PLUME IN GROUND WATER
.. .. .. . .. .. .. .. .. .. .... 14
FIGURE 10 GRANULAR ACTIVATEC CARBON TREATMENT SCHEMATIC..... 42
...........43
FIGURE 11 PROCESS DIAGRAM UV OXIDATION TREATMENT
FIGURE 12 PROCESS DIAGRAM AIR STRIPPER TREATMENT
...........45
FIGURE 13 SCHEMATIC FOR CES TREATMENT ...................... 47
FIGURE 14 SOIL VENT SYSTEM - IDEALIZED CROSS-SECTION ....... 49
-------
TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLE 5
TABLE, 6
TABLE 7
TABLE 8
TABLE 9
TABLE 10
TABLE 11
TABLE 12
TABLE 13
TABLE 14
TABLE 15
TABLE 16
LIST OF TABLES
PAGE
SUMMARY OF NONCARCINOGENIC RISKS FOR
ADULT TRESPASSERS................................. 20
SUMMARY OF CARCINOGENIC RISKS FOR.
ADULT TRESPASSERS................................ 21
SUMMARY OF NONCARCINOGENIC RISKS FOR
CHILD TRESPASSERS................................ 22
SUMMARY OF CARCINOGENIC RISKS FOR
CHILD TRESPASSERS................................ 23
SUMMARY OF NONCARCINOGENIC RISKS FOR
ADULT OFF-SITE RESIDENTS ......................... 24
SUMMARY OF CARCINOGENIC RISKS FOR
ADULT OFF-SITE RESIDENTS ......................... 25
SUMMARY OF NONCARCINOGENIC RISKS FOR
CHILD OFF-SITE RESIDENTS......................... 26
SUMMARY OF CARCINOGENIC RISKS FOR
CHILD OFF-SITE RESIDENTS................. ... . . . . .. 27
SUMMARY OF NONCARCINOGENIC RISKS FOR
ON -S ITE ADULT WORKERS............................ 28
SUMMARY OF CARCINOGENIC RISKS FOR
ON-SITE ADULT WORKERS.. . . . . . . . . . . . . . . . . . . . . . . . . .. 29
SUMMARY OF NONCARCINOGENIC RISKS FOR
CONSTRUCTION WORKERS....... . . . . . . . . . . . . . . . . . . . . .. 30
SUMMARY OF CARCINOGENIC RISKS FOR
CONSTRUCTION WORKERS............................. 31
SUMMARY OF NONCARCINOGENIC RISKS FOR
FUTURE ON-SITE ADULT RESIDENTS ................... 32
SUMMARY OF CARCINOGENIC RISKS FOR
FUTURE ON-SITE ADULT RESIDENTS ................... 33
SUMMARY OF NONCARCINOGENIC RISKS FOR
FUTURE ON-SITE CHILD RESIDENTS ................... 34
SUMMARY OF CARCINOGENIC RISKS FOR
FUTURE ON-SITE CHILD RESIDENTS......... .'......... 35
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TABLE 17
TABLE 18
TABLE 19
LIST OF TABLES (continued)
SUMMARY OF PREDICTED BLOOD LEAD LEVELS
FROM EXPOSURE TO LEAD IN SITE MEDIA ............. 36
SUMMARY - EVALUATION OF GROUND WATER ALTERNATIVES
WITH RESPECT TO NINE CRITERIA ................... 53
SUMMARY - EVALUATION OF SOIL ALTERNATIVES
WITH RESPECT TO NINE CRITERIA ................... 54
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RECORD OF DECISION
DECISION SUMMARY
1.0
SITE NAME. LOCATION. AND DESCRIPTION
The McGraw-Edison facility is located on a 13 acre tract
adjacent to Iowa Highway 5 in a residential/industrial area on
the southern edge of Centerville, Iowa. The MCGfaw-Edison (McGE)
Site is located approximately 1.5 miles southeast of downtown
Centerville in an industrial park (see Figure 1). Centerville is
located in south-central Iowa in an area of gently rolling hills.
The topographic relief across the site is approximately 7 feet,
as indicated in Figure 2. It is an industrial and agricultural
center. Access to Centerville is provided by highway and railway
systems.
The McGraw-Edison facility is located within the SW 1/4 of
the SW 1/4 of Section 6, Township 68 North, Range 17 West, in
Appanoose County, Iowa. The McGE Site refers to and includes all
properties to which ground water contaminated with
trichloroethene (TCE) has migrated. The approximate extent of
the McGE Site, based on available information, is presented as
Figure 3.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1
site History
McGraw-Edison manufactured toasters and toaster ovens at the
Site from 1965 to 1978. The manufacturing operations included
nickel and chromium plating processes. Rinse water associated
with the plating operations was treated in the on-site wastewater
treatment plant. The manufacturing areas were housed in a
structure containing 194,800 square feet of floor space (see
Figure 4). The manufacturing building contained concrete-lined,
below-grade pipe chases, and a 5,000 gallon above-ground solvent
storage tank. The pipe chases were located in the metal plating
area and were used to collect plating liquid and return it to the
process vaults or the wastewater treatment building. The
solvent, trichloroethene (TCE), was used in the manufacturing
building to clean the metal plating equipment. The treated
wastewater was discharged to the Centerville sanitary sewer
system. The plating solids were discharged to drying beds
located on the west side of the wastewater treatment building.
McGraw Edison Company sold the facility to Peabody
International Corporation in 1980. Peabody rented the facility
to a party who used the facility for storage of grain and
finished goods. Cooper Industries, Inc. purchased the stock of
the McGraw-Edison Company' in 1985, and the McGraw-Edison Company
became a wholly owned subsidiary of Cooper Industries. In 1990,
Cooper Industries bought the facility from Peabody International.
1
-------
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MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE 2 - TOPOGRAPHIC
RELIEF MAP
-------
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MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE 3 - APPROXIMATE EXTENT
OF MCGRAW-EDISON SITE
-------
.-- ..-...-.. .~.. .
10 10._------
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~ 13E\J=R,VEWI\Y
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MCGRAW-EDISON FACILITY
RECORD OF DECISION
fIGURE 4 - MANUFACTURING
BUILDING
-------
The McGE site is situated on a local topographic high area.
Drainage features discharge Site storm water to drainage ditches
located near the northeast and southwest property corners.
Surface water exiting the site from the northeast corner flows
eastward toward Hickory Creek and the Chariton River (approximate
distance of 3 miles); surface water leaving the Site through the
southwest culvert eventually flows into the upper and lower
centerville reservoirs (approximate distance of 1 mile), see
Figure 5.
2.2
site Investiaations
The Iowa Department of Natural Resources (IDNR) performed an
assessment of the McGE Site during June 1986. IDNR identified
certain hazardous substances located at the facility, including
two cinder-block lined lagoons containing chrome plating sludges,
a large tank containing trichloroethylene (TCE) , and drums con-
taining sodium hydroxide and sulfuric acid. The Environmental
Protection Agency (EPA) conducted sampling at the site during
January 1987. The analytical data from that sampling indicated
that the lagoon sludges contained elevated concentrations of
several heavy metals, including chromium, arsenic, nickel and
cobalt. These four metals were also detected, at elevated
concentrations, in on-site sediments. The toxicity character-
istic of a water sample from the cinder block walls of the lagoon
was analyzed using the Extraction Procedures Toxicity Test (EP
Tox). The results indicated an EP Toxicity of 40 microgram per
liter (ug/l) for chromium. According to the Resource
Conservation and Recovery Act (RCRA) , an EP Toxicity or a
Toxicity Characteristic Leaching Procedure (TCLP) test value
greater than 5 ug/l for chromium is a characteristic toxic waste.
On-site surface water samples indicated elevated concentrations
of cobalt, nickel and chromium. At the time the analysis was
performed, EP Toxicity was the only method of evaluating the
leaching potential of a substance.
Cooper Industries and Peabody International entered into an
Administrative Order on Consent (AOC) with EPA on October 3,
1988. The AOC specified that Cooper Industries and Peabody
International were to conduct a site investigation and to remove
the plating solids from the drying beds. Data from this
investigation indicated that metal concentrations in the sludge
lagoons, the east drainageway and the south drum storage area
were significantly higher than uncontaminated background
concentrations at several locations. Volatile organic compounds
(VOCs) were detected in surface water and soil samples obtained
along the southern property perimeter. Ground water monitoring
wells were installed and sampled. High concentrations of TCE,
1,2-dichloroethane and 1,2-dichloroethene were detected in
subsurface soils while drilling and installing monitoring wells
adjacent to the south side of the building. Monitoring wells
MW-2 and MW-3A had concentrations of TCE and 1,2-dichloroethene
6
-------
.......
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SCAL( IU'
MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE 5 - DIRECTION OF
SURFACE WATER FLOW
-------
which exceeded drinking water standards.
locations are presented as Figure 6.
Monitoring well
A removal action was performed by Cooper Industries and
Peabody International during May to July 1989. Activities
performed during this removal action included: removal of the
sludges from the lagoons, pipe chases (interior and exterior of
the manufacturing building), clarifier, and water treatment
tanks: stabilization of the lagoon sludges: removal of the
clarifier structure; decontamination and removal of the equipment
in the water treatment building: removal of soils contaminated
with metals north of the manufacturing building: decontamination
of the interior concrete floor surfaces (this activity was not
successfully completed during this action): and backfilling
excavated areas with clean soil. During the removal action,
additional plating sludge was found below the surface soils north
of the .manufacturing building. Plating sludges were encountered
in former disposal pits and in the subsurface soils at the
northern property line.
While attempting to decontaminate the manufacturing building
floor, two product vaults and one diesel oil tank were discovered
beneath the floor. Samples of the product tanks were collected
and analyzed. Both vaults contained liquids with elevated
concentrations of chromium and nickel.
In addition to the investigation and removal action, ground
water-samples from an adjacent residence were collected at the
request of the property owner. The analytical data from these
samples indicated that the ground water in the residential well
was contaminated with TCE at concentrations of 360 parts per
billion (ppb). (The maximum contaminant level (MCL) for TCE in
drinking water is 5 ppb.) The water in the residential well was
being consumed by the residents, who were furnished with an
alternate water supply during the fall of 1988. Cooper
Industries furnished a permanent alternate water supply to the
residents during the winter of 1988 by providing their house with
a connection to the Public Water Supply.
Cooper Industries entered into a second AOC with EPA on
September 21, 1990. This AOC required that Cooper Industries
perform a second removal action and conduct a remedial
investigation and feasibility study (RIfFS) for the ground water
contamination which EPA designated an "operable unit" or a
segregable portion of the remedial work. The second removal
ac~ion (Phase II) was performed between October 1991 and May
1992. This removal action addressed the soil contamination and
liquid wastes which remained after the first removal action.
Approximately 1,720 tons of contaminated soil were excavated and
transported for off-site. disposal. Approximately 34,850 gallons
of liquids were removed from the site. These liquids were sent
to a recycling facility.
8
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MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE 6
LOCATIONS
- MONITORING WELL
-------
-
The results of these investigations and response actions are
provided in more detail in the Phase I and Phase II Soil Operable
Unit Removal reports which can be found in the Administrative
Record.
Cooper Industries conducted a remedial investigation (RI)
pursuant to an Administrative Order on Consent issued by EPA.
The field activities were conducted between October 1991 and July
1992. The RI field work was divided into three (3) segments:
soil investigation; ground water investigation and surface water
and sediment.
1. Soil -- The field work performed to investigate on-site
soils included a soil gas survey, borehole drilling and
subsurface soil sampling, geophysical testing and surface soil
sampling. Samples of the gas contained within the soil pore
spaces was collected and analyzed during the soil gas survey.
The survey indicated that the soils near the southeast building
corner and south of the building were contaminated with VOCs,
particularly TCE, to a depth of 35 feet. The borings advanced
into the subsurface soils were used to obtain samples. These
samples were analyzed to identify contaminant concentrations, if
present. VOC contamination of the surface and subsurface soils
was generally limited to a 200-foot radius around the TCE storage
area and an area along the storm water culvert. The approximate
extent of VOC contamination in soils is presented as Figure 7.
In addition to the information gathered concerning the
contaminant concentrations, the soil investigation provided
valuable information regarding the subsurface stratigraphy.
Based on the information gathered during the RI, it appears that
there are three distinct till units present below the site. The
till units are separated by distinct sand layers. A glacial
meltwater channel is present and is incised into the two lower
till units. A cross-section of subsurface features, interpreted
from RI information, is presented as Figure 8. The sand layers
or units and the meltwater channel contain water. Residential
wells surveyed as part of the RI, are for the most part completed
at a depth of approximately 45 feet below ground surface.
Bedrock was encountered at a depth of approximately 120 feet.
2. Ground Water -- Monitoring wells were constructed such
that water samples from each of the sand layers and from the
interface of the bedrock and till (basal drift) could be
collected. The analytical data from the collected samples
indicates that the upper and intermediate sands are contaminated
with TCE south and east of the manufacturing building. The TCE
contaminant plume has migrated off of the McGE property. The TCE
concentrations are generally in the part per billion range. The
extent of ground water contamination southeast of the McGE
facility was not determined during the RI. Additional work to
10
-------
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MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE. 7- APPROXIMATE EXTENT
VOC SOIL CONTAMINATION
-------
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MCGRAW-EDISON FACILITY
RECORD OF DECISION
i(L
..
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FIGURE 8 CROSS-SECTION OF
INDICATED SUBSURFACE. FEATURES
-------
define the limits of the TCE contaminant plume within the ground
water is still being performed and will be completed during the
remedial design. The approximate extent of the TCE contdminant
plume in the ground water, based on available information, is
presented as Figure 9.
Inorganic contaminants (chromium, beryllium, cadmium and
nickel) were detected in ground water samples collected after
initial monitoring well development. With subsequent sampling
activities, the concentrations of these inorganics decreased.
During May 1993, Cooper Industries performed a limited ground
water sampling activity. The purpose of this activity was to
collect ground water samples with little or no suspended solids.
This activity was performed because it was suspected that the
elevated concentrations of metals detected in the ground water
samples may not have been representative of actual levels. This
was due to the presence of sediments or soil particles contained
in the ground water samples. These elemental compounds (metals),
which were detected at elevated concentrations in the ground
water, commonly occur as a natural component in soil. The
analytical data from these samples indicated that the
concentrations of the inorganic contaminants of concern were
below the maximum contaminant levels (MCLs). In some instances
the inorganic concentrations were below the detection limit.
Based on this information, EPA has determined that the early
detection of the inorganic contaminants was caused by the
presence of excessive amounts of soil particles and was not
representa~ive of ground water conditions.
3. Surface Water -- Surface water and sediment samples were
collected from drainage features in the vicinity of the Site.
Chromium and nickel were detected in all sediment and surface
water samples. The concentrations of nickel in sediment were
typically less than 500 parts per million (ppm). Chromium
concentrations in sediment were generally less than 100 ppm.
Surface water samples indicated the presence of chromium, nickel
and TCE. The surface water samples containing TCE were collected
from the southwest corner of the property and along the east
drainage ditch of Iowa Highway 5 south of the site. The TCE
concentrations in these surface water samples were slightly above
the MCL (detected concentrations ranged from 5 to 12 micrograms
per liter (ugjl)).
2.3
Enforcement Activities
Cooper Industries and Peabody International Company entered
into an Administrative Order on Consent with EPA pursuant to
CERCLA 9106 on October 3, 1988. The terms of this order required
Cooper Industries and Peabody International Company to perform a
site characterization st~tly to identify the areas of
contamination and to perform removal activities to remove the
plating wastes from the storage lagoons.
13
-------
.....
.t-
r=,::-T 'H' .... . ... "\'" !~tj~ ' ... ... ':. ~~~-!.
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CONT A~A TION IN UPPEn AND
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PW-4
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wCIOI '.u -rn +
MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE 9 - VOC CONTAMINANT
PLUME IN GROUND WATER
-------
Cooper Industries entered into a second CERCLA 9106
Administrative Order on Consent with EPA on September 19, 1990.
The terms of this order required that a second removal ac~ion be
performed to remove all soils, sediments and structural materials
that had inorganic (metals) contaminant concentrations above the
specified action levels and to perform a remedial investigation
and feasibility study of the TCE contaminant plume in the ground
water.
2.4
National Priorities List Status
The McGraw-Edison facility has not been proposed for listing
on the National Priorities List (NPL).
3.0
COMMUNITY PARTICIPATION
Representatives of EPA and the Iowa Department of Natural
Resources (IONR) met with representatives of the community and
Appanoose County on July 22, 1987. The purpose of the meeting
was to answer questions regarding the "Superfund process" and
liability of property owners.
EPA and the Iowa Department of Health held Availability
Session meetings with adjacent property owners and other
interested citizens in Centerville, Iowa on March 27, 1991. The
purpose of these meetings was to discuss the Site conditions and
the health risks that the Site represented to the general public.
The Administrative Record Addendum for the RI/FS was placed
in the Drake Public Library on August 11, 1993. A public
meeting was held in Centerville on September 24, 1991 to inform
the public of the initiation of remedial investigation activities
at the site and to provide details of those activities. Fact
sheets, identifying significant Site activities, were mailed to
everyone on the Site mailing list (which included local media,
officials and PRPs) during November 1990, March 1991, September
1991, and August 1993.
The remedial investigation (RI) and feasibility study (FS)
reports and the Proposed Plan for the McGraw-Edison facility were
released to the public on August 10, 1993. These three documents
were included in the addendum to the administrative record which
is located in the EPA Record Center, Region VII and at the Drake
Public Library in Centerville. Notice of the availability of
these documents was published in the Dailv Ioweaian on August 10,
1993. A public comment period was held from August 10 to
September 9, 1993. A public hearing was held in Centerville,
Iowa on August 18, 1993. At this meeting, representatives from
the EPA, the Iowa Department of Health (IDOH), and the Agency for
Toxic Substances and Disease Registry (ATSDR) were available to
answer questions about the Site and the remedial alternatives
under consideration. EPA's response to the comments received
15
-------
during this comment period is embodied in the Responsiveness
Summary.
4.0
SCOPE AND ROLE OF RESPONSE ACTION
The remedial action to be performed at the McGraw-Edison
facility has two components: one to address the contaminated
soils: and the second to address the ground water contamination.
The contaminated soils pose a threat, current or potential, to
the environment due to continued leaching of the TCE from the
soils into the underlying ground water (The TCE contained in the
soils will continue to act as a ground water contamination source
if not addressed.) The contaminated ground water poses a threat,
current or potential, to human health or the environment because
of current or future ingestion of drinking water from wells that
contain contaminants above health-based concentrations. The
purpose of the response actions is to prevent and/or minimize
current or future exposure to the contaminated soils and ground
water. These actions are expected to be the final response
actions for the McGraw-Edison facility.
5.0
SITE CHARACTERISTICS SUMMARY
Past storage, disposal and handling practices at the Site
have resulted in contamination of the soils, sediments, surface
water and ground water. The primary sources of contamination
were the handling and disposal of the plating sludges and the
accidental spills from the TCE storage tank.
Twelve contaminants of concern were detected in the ground
water at the Site during the investigations. These contaminants
include: Benzene: 2-Butanone: Carbon Disulfide: Chloroform:
Chloromethane: 1,2-Dichloroethene (total): 4-Methyl-2Pentanone:
Trichloroethene (TCE): Toluene: Chromium: Lead: and Nickel. six
of these contaminants (benzene, chloroform, chloromethane, TCE,
Lead and Nickel) are classified as potential human carcinogens.
Nineteen contaminants of concern were detected in the soils
at the Site during the investigations. These contaminants
include: Toluene: Trichloroethene: Xylenes (total): Benzoic
Acid: Benzo(a) anthracene: Benzo(a)pyrene: Benzo(b)fluoranthene:
Benzo(k)fluoranthene: Chrysene: Fluoranthene: Fluorene:
Indeno(1,2,3-cd)pyrene: Naphthalene: pyrene: Cadmium: Chromium:
Lead: Nickel: and Cyanide. Ten of these contaminants (TCE, lead,
nickel, benzo(a) anthracene, benzo(a)pyrene, benzo(b)fluoranthene,
benzo(k)fluoranthene, chrysene, indenO(1,2,3-cd)pyrene and
cadmium) are classified as potential human carcinogens. The
majority of these contaminants were detected in one small area of
the site and do not represent site-wide conditions. The removal
actions performed during i989 and 1991 excavated and disposed of
surface soils contaminated with chromium and nickel above action-
specific concentrations. These removal actions resulted in the
16
-------
health risks associated with the Site surface soils to be within
the acceptable range. The contaminants located within the
subsurface soils, especially TCE, will continue to migrate
downward toward the ground water. If not addressed, this source
of ground water contamination could continue for hundreds of
years. It is estimated that the subsurface soils contaminated
with TCE are confined to an area 300 feet in diameter and up to
30 feet deep.
Eleven contaminants of concern were detected in the surface
water at the Site during the investigations. These contaminants
include: 1,2-Dichloroethene (total): Trichloroethene: Benzoic
Acid: Antimony: Arsenic: Barium: Chromium: Lead: Nickel: Silver:
. and Vanadium. Four of these contaminants (TCE, lead, nickel and
arsenic) are potential human carcinogens. The surface water that
exits the site flows to the west toward the centerville
reservoirs or to the northeast toward the Chariton River.
Four contaminants of concern were detected in the sediments
at the Site. These contaminants include: Toluene: Barium:
Chromium (trivalent): and Nickel. These contaminated sediments
could migrate off-site in the drainage features.
6.0
SUMMARY OF SITE RISKS
A Baseline Risk Assessment of the McGE site was performed by
Cooper Industries to assess the risks posed to human health and
the environment by the Site. The purpose of the of a baseline
Endangerment Assessment is to identify potential health risks
posed by the chemicals of concern (COCs) present in the soil,
ground water, surface water and sediments at a site under current
and further land uses assuming current (baseline) site
conditions. The compounds of concern and the media in which they
were detected are presented in tabular form below.
Detected Compounds
Environmental Media
Xylenes (total)
Ground water
Ground water
Ground water
Ground water
Ground water
Ground water,
Ground water
Ground water,
Ground water,
Ground water,
Sediment
Ground water,
Ground water,
Sediment
Soil
Surface water
Benzene
2-Butanone
Carbon Disulfide
Chloroform
Chloromethane
1,2-Dichloroethene
4-Methyl-2-Pentanone
Trichloroethene
Toluene
Chromium
Surface water, Soil
Soil, Sediment
Surface water, Soil,
Lead
Nickel
Surface water, Soil
Surface water, Soil,
17
-------
Detected Comcounds
Environmental Media
Benzoic Acid
Benzo(a) anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
Naphthalene
pyrene
Cadmium
Cyanide
Antimony
Arsenic
Barium
Silver
Vanadium
Sur:ace
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Surface
Surface
Surface
Surface
Surface
water, Soil
water
water
water,
water
water
Sediment
The Baseline Risk Assessment evaluated both current and
future exposure situations. For purposes of the Baseline Risk
Assessment, it was assumed that no remedial action would be
performed at the site in order to conservatively evaluate the
possible future risks posed by the contamination. The following
pathways (routes) of exposure were evaluated: ingestion of
contaminated ground water, surface water, soils or sediments:
inhalation of contaminated surface soil particles entrained in
air, volatilized chemicals from soil to air, or volatilized
chemicals from ground water: and dermal (skin) contact with
contaminated ground water, surface water, soil or sediments.
Incremental lifetime cancer risks and a measure of the
potential of noncarcinogenic adverse health effects were
estimated for each population in each exposure scenarios. For
carcinogenic compounds, risks were estimated by multiplying the
estimated exposure dose by the cancer potency factor of each
contaminant. The product of these two values is an estimate of
the incremental cancer risk.
For noncarcinogenic compounds, a Hazard Index (HI) value was
calculated. This value is a ratio between the estimated exposure
dose and the reference dose (RfD) which represents the amount of
'toxicant that is unlikely to cause adverse health effects.
Generally, if the HI is less than one, the predicted exposure
dose is not expected to cause harmful noncarcinogenic human
health effects. If the HI were to exceed one, the potential for
adverse noncarcinogenic human health effects increases as the HI
increases.
18
-------
Due to the potential additive effects of ingestion,
inhalation and dermal contact to contaminants via different
pathways, exposure routes were identified: ingestion of surface
soils: dermal (skin) contact with surface soils: inhalation of
surface soil particles in air: inhalation of volatilized
chemicals from soil to air; ingestion of ground water; inhalation
of volatilized chemicals in ground water; dermal contact with
ground water: ingestion of surface water; dermal contact with
surface water; ingestion of sediments: and dermal contact with
sediments. These routes of exposure were evaluated for both
children and adults. Specifically these exposure routes are:
1) current and future trespassers, both adults and children:
2) current off-site residential populations for both adults and
children; 3) future occ~pational (Site workers): 4) future
construction workers; and 5) future on-site residential
populations, both adults and children. The scenarios evaluating
off-site workers, off-site residents and trespassers were
evaluated for current and future uses of the Site. The risks
posed by the contamination at the Site are summarized in Tables 1
to 16.
The risks posed by lead contamination are especially severe
to susceptible populations, such as children 6 months to 7 years
old. Because of the hazard posed by lead, EPA has developed
special methods to analyze the risk potential. These methods
evaluate the amount of lead that is available to children from
all sources and then calculates the probable lead concentration
in the child's blood. If the lead concentration is less than 10
micrograms per deciliter (ug/dL), the likelihood of adverse
effects due to exposure to lead is minimal. The risks posed to
children who are or might be current off-site residents,
trespassers at the Site, and future on-site residents are
summarized in Table 17.
The Baseline Risk Assessment indicates that the McGE site
currently presents an unacceptable risk to human health and the
environment. The principal threat from the site is from exposure
to the TCE-contaminated ground water. The assessment was
performed using U. S. EPA's recommendations for "reasonable
maximum exposure" (RME) which is used to conservatively estimate
the highest current and future exposure that can be reasonably
expected to occur and "reasonable average exposure" (RAE) which
provides an estimate which is potentially lower than the RME.
19
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TABLE 1 -- SUMMARY OF EXPOSURE RISKS FOR ADULT TRESPASSERS
AT THE MCGRAW-EDISON SITE
Hazard Index -- Current and Future Exposure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Reasonable Average
Exposure (RAE)
Incidental Ingestion of Soils
0.0009
0.000007
Dennal Contact with Soils
0.0004
0.00002
Inhalation of Volatilized
Soil Chemicals
0.000001
0.000001
Inhalation of Entrained
Soil Particles
0.000001
0.000001
Incidental Ingestion of Surface
Water
0.008
0.002
Dennal Contact with Surface
Water
0.002
0.0003
Incidental Ingestion of
SedimentS
0.0004
0.000003
Dermal Contact with SedimentS
0.0003
0.00001
All Pathways Combined
0.012
0.002
20
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TABLE 2 -- SUMMARY OF EXPOSURE RISKS FOR ADULT TRESPASSERS
AT THE MCGRAW-EDISON SITE
Carcinoaenic Risk -- Current and Future Exposure
Exposure
Pathway
Reasonable Maximum
Ex?osure (RME)
Reasonable Average
Exposure (RAE)
Incidental Ingestion of Soils
4 x 10 .7
2xlO.g
Dermal Contact with Soils
lxlO-6
4 x 10 -6
Inhalation of Volatilized
Soil Chemicals
2 X 10.10
9 X 10"2
Inhalation of Entrained
Soil Particles
Sx 10.8
3 x 10 .9
Incidental Ingestion of Surface
Water
2 x 10 .7
8 x 10 .9
Dermal-Contact with Surface
Water
2 x 10 .7
7 x 10 .9
Incidental Ingestion of
SedimentS
NA
NA
Dermal Contact with SedimentS
NA
NA
All Pathways Combined
2 X 10 -6
6 X 10 -8
21
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TABLE 3 -- SUMMARY OP EXPOSURE RISKS FOR CHILD TRESPASSERS
. AT THE MCGRAW-EDISON SITE
Hazard Index -- Current and Future Exposure
Exposure
Pathway
Reasonable Maximum
EXDosure (RME)
Reasonable Average
EXDosure (RAE)
Incidental Ingestion of Soils
0.008
0.0003
Dermal Contact with Soils
0.0007
0.00004
Inhalalion of VolatilizetJ
Soil Chemicals
0.000003
0.000001
Inhalation of Entrained
Soil Particles
0.000001
0.000001
Inddental Ingestion of Surface
Water
0.04
0.007
Dermal Contact-with Surface
Water
0.004
0.0006
Im:idental Ingestion of
Sediments
0.004
0.0003
Dermal Contact with Sediments
0.0006
0.0003
All Pathways Combined
0.06
0.008
22
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TABLE 4 -- SUMMARY OF EXPOSURE RISKS FOR CHILD TRESPASSERS
AT THE MCGRAW-EDISON SITE
Carcinoaenic Risk -- Current and Future Exposure
Exposure
Pathwav
Reasonable Maximum
Exposure (RME)
Incidental Ingestion of Soils
8 x 10 -7
Reasonable Average
Exposure (RAE)
5 x 10 -8
Dermal Contact with Soils
5 x 10 -7
5x 10-8
Inhalation of Volatilized
Soil Chemicals
I X 10-10
2 X 10-"
Inhalation of Entrained
Soil Particles
7 x 10 -8
6 x 10 -9
Incidental Ingestion of Surfacc
Water
2 x 10 -7
3xlO-8
DermarContact with Surface
Water
6x 10-8
9 x 10 -9
Incidental Ingestion of
Sediments
NA
NA
Dermal Contact with Sediments
~
2 X 10 -6
NA
All Pathways Combined
1 X 10 -7
23
-------
TABLE 5 -- SUMMARY OP EXPOSURE RISKS OFF-SITE ADULT RESIDENTS
AT THE MCGRAW-EDISON SITE
Hazard Index -- Current Exposure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Reasonable Average
Exposure (RAE)
Ingestion of Ground Water
0.6
0.2
Dermal Contact with Ground
Water
0.003
0.0009
Inhalation of Ground Water
Volatile Chemicals
0.006
0.001
Inhalation of Volatilized
Soil Chemicals
0.000001
0.000001
Inhalation of Entrained Soil
Panicles
0.000001
0.000001
Incidental Ingestion of Surface
Water
0.002
0.0003
Dermal Contact with Surface
Water
0.0006
0.00008
Incidental Ingestion of
S~uiments
0.0001
0.000001
Dermal Contact with
Sediments
0.00008
0.000006
All Pathways Combined
0.6
0.2
24
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TABLE 6 -- SUMMARY OF EXPOSURE RISKS FOR OFF-SITE ADULT RESIDENTS
AT THE MCGRAW-EDISON SITE
Carcinoqenic Risk -- Current Exposure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Ingestion of Ground Water
6 x 10 04
Reasonable Average
Exposure (RAE)
5 x 10 .5
. Dermal Contact with Ground
Water
8 x 10 .5
4xlO00
Inhalation of Ground Water
Volatile Chemicals
6 x 10 -5
2 x 10 .6
Inhalation of Volatilized
Soil Chemicals
2 X 10.10
2 X 10-"
Inhalation of Entrained Soil
Panicles
] x 10.7
7 x 10 .9
Incidental Ingestion of Surface
Water
2 x 10 -7
lxlO-8
Dermal Contact with Surface
Water
4 x 10 -7
2xlO-8
Incidental Ingestion of
St:dimt:nts
NA
NA
Dermal Contact with
Sediments
~
NA
All Pathways Combined
7 x 10 -I,
6 x 10 -5
25
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TABLE 7 -- SUMMARY OF EXPOSURE RISKS FOR OFF-SITE CHILD RESIDENTS
AT THE MCGRAW-EDISON SITE
Hazard Index -- Current Exposure
Exposure
Pathway
Reasonable Maximum
EXDosure (RME)
Reasonable Average
Exposure (RAE)
Ingestion of Ground Water
2
0.7
Dermal Contact with Ground
Water
0.006
0.002
Inhalation of Ground Water
Vulatile Chemicals
U.03
0.007
Inhalation of Volatilized
Soil Chemicals
0.000005
0.000001
Inhalation of Entrained Soil
Panicles
0.000001
0.000001
Incidental Ingestion of Surface
Waler
0.009
0.002
Dermal Contact with Surface
Water
0.001
0.0002
Incidental Ingestion of
S~diments
0.001
0.00006
Dermal Contact with
S~diments
0.0002
0.00001
All Pathways Combined
2
0.7
26
-------
TABLE 8 -- SUMMARY OF EXPOSURE RISKS FOR OFF-SITE CHILD RESIDENTS
AT THE MCGRAW-EDISON SITE
carcinoaenic Risk -- Current EXDosure
Exposure
Pathway
Reasonable Maximum
EXDosure (RME)
Reasonable Average
EXDosure (RAE)
Ingestion of Ground Water
4x 10""
lxlO""
Dermal Contact with Ground
Water
3 x 10 ,5
4 x 10 -6
Inhalation of Ground Water
Volatile Chemicals
5 x 10 .5
6x 10-6
Inhalation of Volatilized
Soil Chemicals
2 X 10"0
4 x 10'"
Inhalation of Entrained Soil
Particles
I x 10 .7
lxlO-8
Incidental Ingestion of Surface
Water
2 x to .7
4xlO-8
Dermal Contact with Surface
Water
I x 10 ,7
2 x 10 ,8
Incidental Ingestion of
SedimentS
NA
NA
Dermal Contact with
SedimentS
NA
NA
All Pathways Combined
5 x 10 .1,
1 x 10 .1,
27
-------
TABLE 9 -- SUMMARY OF EXPOSURE RXSXS ON-SXTE ADULT WORKERS
AT THE MCGRAW-EDXSON SXTE
Hazard Index -- Future Exposure
Exposure
Pathway
Reasonable Maximum
EXDosure (RME)
Reasonable Average
EXDosure (RAE)
Incidental Ingestion of Soils
0.01
0.0008
Dermal Contact with Soils
0.002
0.0002
Inhalation of Volatilized
Soil Chemicals
0.00002
0.000003
Inhalation of Entrained
Soil Particles
0.000001
0.000001
Incidental Ingestion of Surface
Water
0.008
0.002
Dermal Contacrwith Surface
Water
0.002
0.0003
Incidental Ingestion of
SedimentS
0.003
0.00007
Dermal Contact with SedimeOls
0.0003
0.00001
All Pathways Combined
0.03
0.003
28
-------
TABLE 10 -- SUMMARY OF EXPOSURE RISKS FOR ON~SITE ADULT WORKERS
AT THE MCGRAW-EDISON SITE
Carcinoaenic Risk -- Future Exposure
Incidental Ingestion of Soils
5 x 10 -6
Reasonable Average
Exposure (RAE)
2 x 10 .7
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Dermal Contact with Soils
6x 10-6
4 x 10 .7
Inhalation of Volatilized
Suil Chemicals
~ x 10 .9
2 X 10.,0
Inhalation of Entrained
Soil Particles
2x 10-6
7x 10-8
Incidental Ingestion of Surface
Water
I x 10 .7
8 x 10 .9
Dermal Contact with Surface
Water
I x 10 .7
7 x 10 .9
Incidental Ingestion of
SedimentS
NA
NA
Dermal Contact with Sediments
NA
NA
All Pathways Combined
1 x 10 -5
6 x 10 -7
29
-------
TABLE 11 -- SUMMARY OF EXPOSURE RISKS FOR CONSTRUCTION WORDRS
AT THE MCGRAW-EDISON SITE
Hazard Index -- Future Exposure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Reasonable Average
Exposure (RAE)
Incidental Ingestion of Soils
0.006
0.0002
Dermal Contact with Soils
0.0007
0.00004
Inhalation of Volatilized
Soil Chemicals
0.00001
0.000001
Inhalation of Entrained
Soil Particles
0.000001
0.000001
Incidental Ingestion of Surface
Water
0.008
0.002
Dermal Contact with Surface
Water
0.002
0.0003
Incidental Ingestion of
SedimentS
0.003
0.00007
Dermal Contact with Sediments
().OO03
0.00001
All Pathways Combined
0.02
0.003
30
-------
TABLE 12 -- SUMMARY OF EXPOSURE RISKS FOR CONSTRUCTION WORDRS
AT THE MCGRAW-EDISON SITE
Carcinoqenic Risk -- Future Exposure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Incidental lngestio~ of Soils
2 x 10 .7
Reasonable Average
Exposure (RAE)
5 x 10 -9
Dermal Comact with Soils
2 x to.7
1 x 10 -8
Inhalation of Volatilized
Soil Chemicals
2 X 10.'0
5 X 10.'2
Inhalation of Emraincd
Soil Particles
IxtO-6
3 x 10 -8
Incidental Ingestion of Surface
Water
I x 10 .8
9 X 10"0
Dermaf Comact with Surface
Water
I x 10.8
8 X 10"0
Incidental Ingestion of
Sediments
NA
NA
Dermal Comact with Sediments
NA
NA
All Pathways Combined
1 x 10 -6
5 x 10 -8
31
-------
TABLE 13 -- SUMMARY OF EXPOSURE RISKS ON-SITE ADULT RESIDENTS
AT THE MCGRAW-EDISON SITE
Hazard Index -- Future EXDosure
Exposure
Pathway
Reasonable Maximum
EXDosure (RME)
Reasonable Average
EXDosure (RAE)
Ingestion of Ground Water
0.6
0.2
Dermal Contact with Ground
Water
U.003
0.0009
Inhalation of Ground Water
Volatile Chemicals
-------
~,.
TABLE 14 -- SUMMARY OF EXPOSURE RISKS FOR ON-SITE ADULT RESIDENTS
AT THE MCGRAW-EDISON SITE
Carcinoqenic Risk -- Future Ex~osure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Reasonable Average
E~osure (RAE)
Ingestion of Ground Water
6x 10-4
5 x 10 .5
Dermal Contact with Ground
Waler
8 x 10 .5
4x 10-6
Inhalation of Ground Water
Volatile Chemicals
6 x 10 .5
2x 10-6
Incidental Ingestion of
Suil
2 x 10 .5
2 x 10 .7
Dermal Contact with Soil
I x 10 .5
4 x 10 .7
Inhalation of Volatilized
Soil Chemicals
1 x IO .9
9 x 10'"
Inhalation of Entrained Soil
Panicles
5 x IU .7
3 x 10 .8
Incidental Ingestion of Surface
Watcr
2 x IO .7
8 x 10 .9
Dermal Contact with Surfac.:e
Water
2 x 10 .7
7 x 10 .9
Incidental Ingestion of
S~dimenlS
NA
NA
Dermal Contact with
SedimenlS
NA
NA
All Pathways Combined
8 x 10 -4
6 x 10 -5
33
-------
TABLE lS -- SUMMARY OF EXPOSURE RISKS FOR ON-SITE CHILD RESIDENTS
AT THE MCGRAW-EDISON SITE
Hazard Index -- Future Exposure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Reasonable Average
Exposure (RAE)
Ingestion of Ground Water
2
0.7
Dermal Contact with Ground
Water
U.OO6
0.002
Inhalation of Ground Water
\'olatile Chemicals
U.03
0.007
Incidental Ingestion of
Soil
0.3
0.04
Dermal Contact with Soil
0.005
0.0004
Inhalation of VoJatilized
Soil Chemicals
0.0002
0.000003
(nhalation of Enuained Soil
Partides
U.OOOOOI
0.000001
(ncidental (ngestion of Surface
Water
0.04
0.007
Dermal Contact with Surface
Water
0.004
0.0006
lm:idental (ngestion of
Sediments
0.004
0.0001
Dermal Contact with
Sediments
0.0006
0.00003
All Pathways Combined
2
0.8
34
-------
TABLE 16 -- SUMMARY OF EXPOSURE RISKS FOR ON-SITE CHILD RESIDENTS
AT THE MCGRAW-EDISON SITE
carcinoaenic Risk -- Future Exposure
Exposure
Pathway
Reasonable Maximum
Exposure (RME)
Reasonable Average
Exposure (RAE)
Ingestion of Ground Water
4xlO-4
lxlO-4
Dermal Contact with Ground
Water
3 x 10 -5
4x 10-6
Inhalation of Ground Water
Volatile Chemicals
5 x 10 .5
6x 10-6
Incidental Ingestion of
Soil
3 x 10 .5
6 x 10 -6
Dermal Contact with Soil
4x 10-6
5 x 10 -7
Inhalation of Volatilized
Soil Chemicals
8 X 10-\0
2 X 10-10
Inhalation of Entrained Soil
Particles
5 x 10 -7
6xlO-8
Incidental Ingestion of Surface
Water
2 x 10 -7
3x 10-8
Dermal Contact with Surface
Water
6 x 10 .8
9 x 10 -9
Incidental Ingestion of
SedimentS
NA
NA
Dermal Contact with
SedimentS
NA
NA
All Pathways Combined
5 x 10 -4
1 x 10 -4
35
-------
TABLE 17 -- SUMMARY OF PREDICTED BLOOD LEAD LEVELS FROM EXPOSURE
TO LEAD IN SITE MEDIA
MEDIA CURRENT OFF-SITE CURRENT CHILD FUTURE ON-SITE
CHILD RESIDENT TRESPASSER CHILD RESIDENT
RME RAE RME RAE RME RAE
Air
Concentration 0.00424 0.0024 0.0186 0.0106 0.0186 0.0106
(ug/m3)
Soil
Concentration NA NA 107.51 61.01 107.51 61.01
(mgJkg)
Ground water
Concentration 58.57 4U.32 NA NA 58.57 4U.32
(ug/L)
Diet Default Default Default Default Default Default
-
Paint Intake None None None None None None
M:Hernal
Contribution None None None None None None
11000 Lead
(PbB) Level
(ug/dL)
Age: 0.5 - 1 2.53 2.01 1.78 1.37 3.46 2.54
1 - 2 4.23 3.18 1.82 1.41 5.18 3.72
2 - 3 5.07 3.78 1.85 1.45 6.00 4.30
3-4 5.35 3.98 1.89 1.48 6.29 4.51
4-5 5.67 4.20 1.93 1.51 6.64 4.75
5 - 6 5.87 4.34' 1.94 1.52 6.83 4.89
6 - 7 6.00 4.45 1.98 1.57 6.95 4.99
36
-------
7.0
REMEDIAL GOALS
EPA's mandate under the Superfund laws and regulations is to
select remedies that will be protective of human health and the
environment, that will maintain protection over time and that
will minimize untreated waste. In establishing remedial goals
for the McGE site, EPA considered applicable or relevant and
appropriate requirements (ARARs) specific to the contaminants of
concern; the Baseline Risk Assessment; Maximum Contaminant Levels
(MCLs) and Maximum contaminant Level Goals (MCLGs) established
under the Safe Drinking Water Act; and EPA policy.
For ground water contamination, EPA considers a cleanup
level of 5 ppb TCE to be protective of human health and the
environment. These levels represent an excess upper bound
lifetime cancer risk on the order of 1 x 10 <6. This means that
one individual out of a million faces an increased likelihood of
developing cancer as a result of exposure to the contaminants
under the exposure scenarios discussed in the McGE Baseline Risk
Assessment. The cleanup goal for TCE also complies with the
drinking water MCL for that contaminant.
For soil contamination, EPA has determined that a cleanup
level of 200 ppb for TCE, which has been detected at levels up to
1,OOO~000 ppb in ground water and 5,000 ppb in the soils, is
adequate to protect human health and the environment. The
cleanup level for TCE in soil was calculated as the residual
concentration in soil which would not adversely affect ground
water (to concentrations above 5 ppb) through continual leaching.
8.0
DESCRIPTION OF ALTERNATIVES
Cooper Industries performed a Feasibility Study (FS) to
develop and evaluate alternatives for remediation of and source
control measures for the contaminated ground water and soils at
the site. The remedial alternatives that were evaluated in
detail are presented below. (Alternatives for contaminated
ground water will be identified with an "GW" prefix; source
control measures for soils will be identified with a "SS" prefix.
Identification numbers will match those presented in the FS
Report found in the Administrative Record.) All costs and
implementation times are estimated.
37
-------
For Ground Water contamination:
Alternative GW-1
Alternative GW-2
Alternative GW-3A -
Alternative GW-3B -
Alternative GW-4A -
Alternative GW-4B -
Alternative GW-5A -
Alternative GW-5B -
~
No Action
Limited Action Alternative
Extraction Wells, Treatment using
Activated Carbon, and Discharge to
the centerville Publicly Owned
Treatment Works (POTW)
Extraction Wells, Treatment using
Activated Carbon, and Discharge to
Surface Water
Extraction Wells, Treatment using
UV Oxidation, and Discharge to the
Centerville POTW
Extraction Wells, Treatment using
UV Oxidation, and Discharge to
Surface Water
Extraction Wells, Treatment using
Air stripping, and Discharge to the
Centerville POTW
Extraction Wells, Treatment using
Air Stripping, and Discharge to
Surface Water
An additional alternative was proposed for consideration
after the completion and submittal of the draft FS. The new
technology is considered an innovative technology and may be
effective in reducing the time in which the remedy would be
implemented. This alternative is considered an addendum to the
FS and will be considered in the evaluation of alternatives. The
alternative is described in Appendix F of the FS, dated June
1993.
Alternative GW-6 -
Chemically Enhanced Solubilization,
Extraction Wells, Treatment using
Air Stripping, and Discharge
38
-------
For Contaminated soils:
Alternative SS-l -
No Action Alternative
Alternative 55-2 -
Limited Action Alternative
Alternative SS-3 -
In-Situ Treatment
Alternative SS-4 -
Excavation and Off-Site Disposal
Excavation and On-Site Disposal
Alternative SS-5 -
8.1 CONTAMINATED GROUND WATER
Ground water treatment technologies described in the
paragraphs 8.1.1 to 8.1.5 are anticipated to continue for a
period of thirty (30) years. The ground water treatment
technology described in paragraph 4.1.6 is anticipated to
continue for a period of fifteen (15) years.
8.1.1 Alternative GW-l - No Action Alternative
The NCP requires EPA to consider a no action alternative.
This alternative would provide no treatment of the soils or
ground water and no engineering controls or institutional con-
trols. This alternative would rely entirely on natural processes
to lower contaminant concentrations in the ground water. Ground
water monitoring would be performed under this alternative to
evaluate natural attenuation of contaminant concentrations in
ground water. Installation of new monitoring wells and semi-
annual sampling of the monitoring well networks would be
performed. The costs associated with this alternative have an
estimated present worth of $490,000. (See the Glossary for a
definition of "net present worth") .
8.1.2 Alternative GW-2 - Limited Action Alternative
This alternative would require that institutional controls
for the McGE Site be provided and require the construction of
drainage controls at the McGE site. The institutional controls
would consist of deed restrictions on all deeds for real property
affected by the ground water contaminant plume, provisions for
alternate (public) water supplies at locations potentially
affect~d by ground water contamination and provide for long-term
ground water monitoring. The manufacturing building's existing
roof and storm drains would be repaired and modified to divert
storm water from the former TCE storage area. This would prevent
ponding of storm water on the ground surface and reduce
infiltration of the wate~ into the subsurface. This would reduce
the potential for leaching of TCE from the soils into the ground
water. Ground water samples would be collected and analyzed for
39
-------
VOCs semi-annually. The analytical data would be used to
evaluate natural attenuation of the contaminant concentrations in
the ground water plume. The present worth cost of this
alternative is estimated to be $680,000. The time required to
implement this alternative, which would involve construction of
drainage controls, installation of public water supply
connections and implementation of deed restrictions, is estimated
to be one year.
The following alternatives (GW-3, GW-4 and GW-5) identify
remedial technologies considered for the McGE ground water. The
major features of each remedial alternative will be presented.
Each alternative involves extraction of ground water to control
migration of the contaminant plume in the ground water. The
actual number and location of extraction wells will be determined
during the remedial design phase. It is assumed that each
monitoring well will be equipped with a submersible pump, which
will operate automatically based on water level controls.
Monitoring the effectiveness of the treatment technology and
maintenance of the ground water extraction system would be
required for all three (3) treatment technologies. Semi-annual
ground water sampling from monitoring wells is anticipated.
Ground water monitoring wells will consist of both existing and
new wells. The number and location of monitoring wells will be
identified during the remedial design phase of the project.
Treated ground water will be discharged to either the
centerville publicly owned treatment works (POTW), designated
with a "A" suffix; or to surface water, via drainage features,
designated with a "B" suffix. A permit from the Centerville POTW
will be required for the "A" options. A National Pollutant
Discharge-Elimination System (NPDES) permit would be required for
the off-site surface water discharges (liB" options). Costs
associated with each discharge option are very similar in amount,
therefore only one cost will be presented for each of the three
alternatives.
The operation and maintenance (O&M) costs associated with
each of the following ground water remedial technologies is very
similar. The present worth costs presented for each of the
ground water alternatives assumes O&M costs for a period of
thirty years. The costs included in the O&M cost estimate
include: maintenance of building improvements associated with
drainage controls; collection of ground water measurements; semi-
annual sampling and analyses of ground water; and weekly
maintenance of the extraction wells and equipment used in
conjunction with each remedial alternative for the first year of
operation.
40
-------
8.1.3 Alternative GW-3 - Extraction Wells, Treatment
using Activated Carbon
This alternative includes ground water monitoring, drainage
control installation for the manufacturing building, extraction
of ground water and on-site treatment of the extracted ground
water using filtration and granular activated carbon (GAC). A
schematic diagram for GAC treatment is presented as Figure 10.
The extracted ground water would be pumped through a filtration
system, to remove suspended solids, prior to being passed through
the GAC beds. The GAC would remove VOCs including TCE from the
ground water. The ability of GAC to adsorb VOCs is limited.
Once the capacity of the GAC filter is reached, the filter would
have to be replaced. The used filter would then be recharged by
thermal treatment or would be disposed of in an appropriate
manner. Thermal treatment of the GAC filter would remove and
destroy the VOCs. This alternative is a proven technology. The
present worth cost of alternative GW-3 is $3,000,000.
8.1.4 Alternative GW-4 - Extraction wells, Treatment
using UV Oxidation
Monitoring of ground water, installation of drainage
controls for the manufacturing building, extraction of ground
water and on-site treatment of the extracted ground water using
filtration and ultra-violet (UV) oxidation are the features of
this remedial alternative. The extracted ground water will be
filtered to remove suspended solids prior to being subjected to
UV oxidation. UV oxidation destroys VOCs by a chemical reaction
involving hydrogen peroxide. A process flow diagram for UV
Oxidation treatment is presented as Figure 11. Air emissions or
solid waste residues are not produced by this alternative. This
is an innovative technology. A bench scale or pilot scale
treatability test will be required to evaluate the effectiveness
of UV oxidation at the site and to develop design parameters. A
pretreatment system to adjust the influent water prior to
treatment may be required. A post-treatment process to capture
any VOCs that escape the UV oxidation process could be necessary.
Pretreatment and post-treatment processes are not included in the
cost estimates. The present worth of alternative GW-4 is
$3,200,000.
41
-------
g .. TREATED WATER TO DISCHARGE.
". " FURl. TION
'.
COLLECTION
TANK CARBON ADSORPTION
. , CANISTERS
. '.
, D D D
FIL TER I SPENT CARBON I
SOLIDS
SAMPLING PORT
s:--
N
EXTRACTION WEll
ITYPICAU
FM' . FLOW LlETER/TO' AliZER
I
I
MCGRAW-EDISON FACILITY
RECORD OF DECISON
FIGURE 10 - GRANULAR ACTIVATED
CARBON TREATMENT SCHEMATIC
-------
SAMPLING PORT
J:-o
W
EXTRACTION WEll
\TYPICAL)
COLLECTION
TANK
OVERPREssunE IIElIfF -l~'
PI
flOW SWitCH "15
-I .
fLOW INOICATOR Z a:
tfMl'EHAtUIIE INDICAtOR 0 W
i=UJ
«~
cc(
-J:
~O
,---------.
I' ,
, ,
\" "
, ,
, I
"
. ,,, ,
i ,I" \'...,\ I
l~_--__--~J
PRETREATMENT
(SEE NOTE It
SAMPLING PORt
\"
r-
/" - PRESSURE INOICATOR
~ SAMPLING POOT
TI ~
.1 --I--
TREATED WATEf\
TO DISCHARGE
TEMPERATURE SWITCH
~
I
I
HYDROGEN PEROXIDE FEED
MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE 11 - PROCESS DIAGRAM
UV OXIDATION TREATMENT
-------
8.1.5 Alternative GW-5 - Extraction Wells, Treatment
using Air stripping .
This remedial alternative would consist of ground water
monitoring, roof drainage control installation, and ground water
extraction and treatment using air strippers. The collected
ground water would be passed through an air stripper unit. In a
packed-tower air stripper, water flows downward in a film layer
over the packing material and air is blown, simultaneously, into
the base of the tower and flows upward. A process flow diagram
of Air Stripper treatment is presented as Figure 12. VOCs are
transferred from the water to the air and carried out in the off-
gas at the top of the column. Treated water is collected at the
base of the tower. Another type of air stripper unit is the
diffused air stripper. Air bubbles are introduced in the bottom
of the tank through a network of air diffusers. VOCs are
transferred to the air bubbles from the water as they rise in the
tank. A pretreatment stage may be required before the water
enters the air stripper unit. Post-treatment of the off-gases
could be required to meet the requirements of Air Emission
Standards for Process Vents (40 CFR 264, Subpart AA). A
treatability test would be needed to evaluate the need for
pretreatment or post-treatment systems. Pretreatment and post-
treatment systems are not included in the cost estimates. The
present worth cost of alternative GW-5 is estimated to be
$2,800,000.
8.1.6 Alternative GW-6 - Chemically Enhanced
SolUbilization, Extraction Wells, Treatment using
Air Stripping
Chemically enhanced solubilization (CES) is a ground water
treatment process that uses surfactants such as those used in
detergents at low concentrations to increase the solubility of
organic contaminants in the subsurface. The CES process can be
combined with ground water extraction and reinjection
technologies to accelerate the removal of dense nonaqueous phase
liquids (DNAPLS) by increasing the solubility of the DNAPL while
maintaining hydraulic control over the contaminant plume.
Surfactants are selected based upon their ability to maximize
contaminant solubilization while minimizing decreases in the
DNAPL/water interfacial tension. The surfactants are also
selected based on their relative toxicity and biodegradability.
44
-------
SAMPLING PORT
I>< I
-C?-I,/ ---- I
g .~-------~.
PRETREATMENT
(SEE NOTE 11
AIR IN . -~
... ...1.
......,.,...........
,,_......""""'"
,~,
..........,..",..,..
J DISCHARGE TO
ATMOSPHERE
r---- ..
I' 't
: \\, ,/ J
-I )'- I AIR EMISSIONS TREATMENT
1/ \1 UNIT (OPTIONAl!
L_____.I
lIOOO REDISTRIBUTOR
PACKINB RESTRAINER
SUEll
~
"
RANDOM PACKINB
lIOUID REDISTAI8UTOR
PACKINO SUPPORT
fMf . flOW MelE",
1 0 r Aliltn
. ~ ~ 'iAMPlINB PORT
!n! ., ~
PACKED TOWER
AIR STRIPPER
TREATED WATER TO DISCHARGE.
MCGRAW-EDISON FACILITY
RECORD OF DECISION
FIGURE 12 - PROCESS DIAGRAM
AIR STRIPPER TREATMENT
-------
This remedial alternative would consist of ground water
monitoring, roof drainage control installation, surfactant
injection wells (CES), ground water extraction and treatment
using air strippers and reinjection of treated ground water that
has been dosed with surfactant. A schematic for the CES
Treatment process is presented as Figure 13. The surfactant
injection wells would be used to remediate the DNAPL which EPA
believes is found in the Upper Sand beneath the TCE storage area.
Ground water would then be extracted removing the solubilized TCE
DNAPL. The extracted ground water would be treated by passing it
through an air stripper unit as discussed in section 8.1.5. A
portion of the treated water would be reinjected after dosing it
with surfactant. Excess treated ground water would be diverted
to the Centerville POTW or the southwest drainage ditch. Pre-
design DNAPL plume delineation and treatability studies would be
required to design an effective CES extraction/injection system.
The estimated present worth cost of alternative GW-6, assuming
that it will take 15 years to complete, is $3,400,000.
8.2
CONTAMINATED SOILS
The soils in the TCE storage area are contaminated with TCE.
Information gathered during the RI and other site characterization
studies indicate that high concentrations of TCE are present at
depth and in the "perched" ground water which has been detected
directly b~neath the location of the former TCE storage tank. The
TCE present in the soils and perched ground water will act as a
continuing source of contamination to surface water and to the
underlying ground water if not removed. The following remedial
alternatives are source controls for the contaminated soils.
8.2.1 Alternative 88-1 - No ~ction
No remedial action would be taken for this alternative.
Consideration of this alternative is required by the NCP to serve
as a baseline against which all other alternatives are compared.
Natural processes would be relied upon to lower contaminant
concentrations in the soil source areas. There would be no cost
associated with this alternative.
8.2.2 Alternative 88-2 - Limited Action
This alternative consists of implementation of institutional
controls and natural attenuation of contaminants to reduce
potential health risks posed by the soil source areas.
Institutional controls would consist of placement of deed
restrictions on the McGE facility and construction and
maintenance of a security fence around the facility. The
estimated present worth of this alternative is $80,000.
46
-------
.04 -,._,
8I.R'ACTANT-
D08ED WATER
ORotN)WATER
TREAn.t:Hf
..
I
\ ~-~r ~-- ~- --~ ~!
WATED WATER tl
TO DISCHARGE 8t11FACTANT t ~R'
:;~ .~.~!
FILL ;..t:.~
~
i; .:'
TILL UNIT 3
--- - - - - -
- --- -.- - ----
--- - - -- -- - --
------ - --- - -
'J;i~~~::.!.!,i5:: ;-t{Tn~;~ ~i;({;;;;);.1V>~;:";!:{(~;~~1~i:';t;E1%
- -~
l:-
'-J
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WA1D LEVEL
LEGEND
gr aNJIIIAJOAl I'\M'
MCGRAW-EDISON FACILITY
RECORD OF DECISON
J>
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8.2.3 Alternative SS-3 - In-situ Treatment
This remedial alternative would utilize a soil vapor
extraction system (VES) to extract VOCs from the soils in the TCE
source area. Typically, vapor extraction applies to only the
unsaturated (vadose) zone in soils. The effectiveness of VES is
limited by the ability of soil gas to migrate through the soil.
Ground water extraction systems are often used in conjunction
with VES to lower the water table and increase the thickness of
the vadose zone. A system of soil vents (similar to granular
drainage blankets or extraction wells) would be installed in the
area affected by the TCE contamination, see Figure 14 for an
idealized cross-section of the soil vent system. These soil
vents would be connected to a common vapor collection manifold.
Air movement through the contaminated soils would be enhanced by
the installation of inlet or injection. wells. A negative
pressure (vacuum) would be induced by installing a blower at the
end of the extraction manifold. Construction of a cap over the
area surrounding the source area would minimize the potential
that atmospheric air would be drawn into the system. Without a
cap, atmospheric air could be collected without first passing
through a zone of contamination. The VOCs in the soil vapor
phase would be drawn to the blower and then discharged. A
process flow diagram for the VES Treatment is presented as Figure
15. An air emission treatment system may be necessary to treat
the VOCs removed from the soils. Typical air emission' treatment
systems include vapor phase activated carbon and catalytic
oxidation systems. A pilot scale test would be needed to
evaluate the effectiveness of VES at the McGE facility. For
purposes of the cost estimate, it was assumed that an asphalt cap
would be constructed over the source area. The present worth
cost of this remedial alternative is $2,100,000.
8.2.4 Alternative SS-4 - Excavation and Off-site
Disposal
This remedial alternative would involve the excavation of
the soils contaminated with TCE in the source area. Based on the
data gathered during the RI and site characterization studies,
the estimated depth of TCE contamination ranges from 10 to 35
feet. Cost estimates based on excavation depths of 10 feet and
35 feet have been prepared to identify the potential remedial
cost range. The excavated soils would be transported to an off-
site permitted landfill. Treatment before off-site disposal may
be required if the TCE concentrations exceed those specified in
the RCRA land disposal restriction criteria. For cost estimating
purposes, it was assumed that 2,000 cubic yards of soil would
require treatment prior to off-site disposal. Treatment could be
48
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onbLN>wATen
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,. WAIER lEVEL
.. - WATER flOW DIRECTION
---- VA"OR flOW DI1EClION
II
WEll SCREEN INIERVAl
MCGRAW-EDISON FACILITY
RECORD OF DECISION
--.-...----.. .._--
FIGURE 14 - SOIL VENT SYSTEM
IDEALIZED CROSS-SECTION
-------
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-------
accomplished by utilizing low temperature thermal treatment
equipment or by land farming treatment techniques.
Low temperature thermal treatment units are typically mobile
(truck-mounted) units that are used to heat soil to temperatures
of 300. to 600. F. Volatile contaminants, including VOCs, are
desorbed from the soil at these temperatures and are transferred
to the hot air exhaust stream. Air emissions are either
discharged directly to the ambient air or are treated before
discharge. Operating parameters are established after
treatability tests and prestart-up test runs.
A temporary enclosed area would be constructed for land
treatment. The excavated soils would be placed within the
enclosure where temperature and moisture conditions could be
monitored and closely controlled. The soils would be
periodically tilled or mixed to aerate the soil and facilitate
the desorption of VOCs. Some biodegradation of the VOCs would be
expected. A ventilation system would be required to control soil
gas emissions. Contaminated soil would be excavated in six to
eight inch layers (called "lifts") and placed within the
enclosure. Samples of the soil being treated would be collected
periodically and analyzed to monitor the progress of VOC removal.
Once the cleanup criteria (200 ppb) was achieved, the soils would
be transported to the off-site disposal facility. Air emissions
from land treatment could be subject to the Air Emission
Standards for Process Vents (40 CFR 264, Subpart.AA) and may
require monitoring and additional treatment if exceedances are
detected.
In evaluating the costs for this remedial action, there are
several scenarios to consider: the depth of soil excavation
could be assumed to be 10 feet or 35 feet; the excavated soils
may need no treatment (NT) prior to off-site disposal; or the
excavated soils may require treatment prior to off-site disposal.
If treatment is needed, the soils can be subjected to lower
temperature thermal treatment (LTT) or to land treatment (Land).
The estimated present worth costs of these options are presented
below.
10 ft. Excavation 35 ft. Excavation
NT $ 8,680,000 NT $19,420,000
LTT $10,035,000 LTT $20,780,000
Land $ 9,730,000 Land $20,480,000
51
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8.2.5 Alternative 88-5 - Excavation and on-site
Disposal
The Resource Conservation and Recovery Act (RCRA)
requirements for land disposal are applicable to this
alternative. The recently enacted Corrective Action Management
Unit (CAMU) Final Rule (40 CFR Part 264, February 15, 1993)
governs the applicability of RCRA land disposal requirements to
CERCLA wastes that are managed (i.e., treated and replaced)
within a CAMU. The CAMU rule would allow the excavation,
treatment to site-specific cleanup criteria, and replacement of
the TCE-contaminated soils on-site.
This remedial alternative would mirror soil alternative SS-4
in all respects except for disposal. The CAMU rule would allow
the treated soils to be used as backfill on the McGE Site, as
long as applicable or relevant and appropriate RCRA criteria were
met. The remedial alternative is considerably less expensive
than Alternative SS-4 since the costs associated with
. transportation and off-site disposal are eliminated.
As with Alternative SS-4, there are several scenarios to
consider: the depth of soil excavation could be assumed to be 10
feet (12,500 cubic yards of soil to be treated) or 35 feet
(28,500 cubic yards of soil to be treated); and the excavated
soils may require treatment prior to their use as backfill on-
site. The ?oils -would be subjected to lower temperature thermal
treatment (LTT) or to land treatment (Land). The estimated
present worth costs of these options are presented below.
10 ft. Excavation 35 ft. Excavation
illT $ 4,600,000 LTT $ 9,200,000
Land $ 1,200,000 Land $ 2,300,000
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP has established nine criteria to be used to evaluate
remedial alternatives. (Section 13.0 provides a glossary of the
nine criteria.) These criteria serve as the basis for conducting
detailed analyses in the Feasibility Study, and subsequently are
used to identify an appropriate remedy for the site. To select a
remedy, each alternative must be evaluated with regard to these
criteria and then compared to each other, see Tables 18 and 19.
The selected remedies are the alternatives for ground water
and soil which provided the best balance of trade-offs in this
comparative analysis.
52
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\J)
~
TADJIK 18
SUMMARY - EVALUATION OF GROUNDWATER REMEDIAL ALTERNATIVES
WITH RESPECT TO THE "NINE CRITERIA"
I
ImMEDlAL ALTERNATIVE
CRITERIA GW-I GW.2 GW.3 GW.4 GW-S GW.6 COMMENTS
Overall Protection of
Human Health and the No Yes Yes Yes Yes Yes
Environment
Compliance with ARARs No No Yes Yes Yes Yes
Long. Term Effectiveness 1#3.spent GAC maybe landfilled;
and I'ermanence No No Yes Yes Yes Yes #S & #6 -stripped VOCs to air
Re~uctlon Toxicity, I#s & #6-alr emissions may
Mobility or Volume No No Yes Yes Yes Yes pose risk to community at lar~e
through Treatment
1#6-TCE maybe become more
Short-Term Effectiveness No No Yes Yes Yes Yes mobile with CF.8
!#6-innovatlve; it has not had
Implemenlabilily N/A Yes Yes Yes Yes Yes full-scale application
Cost $490,000 $680,000 $3,000,000 $3,200,000 $2,800,000 $3,400,000
construe! on t me 6 months 6 months I yeor 1 yeRr I ytOr 18 months
State Acceptance No No -- .- .. .. No comments received fnlm
.L _.
Community Acceptance No .. Yes Yes .. ..
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V1
.$:'0
TAUI.": 19
SUMMARY - EVALUATION OF SOIL SOURCE AREA REMEDIAL ALTERNATIVES
WITH RESPECT TO THE "NINE CRITERIA"
I
REMEUIAL ALTERNATIVE
CRITERIA SS-I 88-1 S8-] 88-4 S8-5 COMMENTS
Overall PrQtection of Alternatives SS-4 and SS-5 include alternative
lIuman lI(,!alth nnd the No Yes Yes Yes Yes methods of treatment for the excavated soil -
Environment land farming & low temperature thermal
SS-I there are no AKARs for TC~
Compliance with AKARs Yes . Yes Yes Yes Yes contaminated soil
tong-Term ElTectiveness 8S-3 if 110 treatment TCE vented to air
and J-ermanence No No Yes Yes Yes S8-4 landfill used could fail - no LT
Reduction Toxicity, ' SS-3 may not treat air emissions
Mobility or Volume No No Yes Yes Yes S8-4 only partial treatment of the TCE in soil
through Treatment 8S-5 reduction of TCE in soli to action level
I SS-3 and SS-S may represent a risk to the
Short-Term ElTectiveness Yes Yes Yes Yes Yes community-at-Iarge while treatment occurs
SSe] this treatment in clays is somewhat
Jmplementabillty N/A Yes Yes Yes Yes innovative, question will It be effective
Cost $0 $ 80,000 $1,100,000 $ K,680,000 $1,100,000 S8-4 & SS-5 - based on information gathered
$11,000,000 $9,100,000 excavation depths range from 10 to 35 n.
1 me 10 rnp ernenl N/A 6 Rlonlhs 10 yurs 6 rnonlhs 2 years
State Acceptance No u .. .. .. No comments received from the State of Iowa
Community Acceptllnce No No Yes -- u
-------
EPA has determined that the best alternatives for the McGE
Site are GW-4 (Ultraviolet Catalyzed Oxidation) and SS-3 (In-situ
Treatment using soil vapor extraction). Alternatives GW-4 and
SS-3 are somewhat innovative for the conditions at the Site.
Because it is possible that these technologies may not be
effective in addressing the contamination and resultant risk at
the Site, contingent remedial alternatives have been selected.
These contingent alternatives are GW-3 (Granular Activated
Carbon) and SS-5 (lower temperature thermal treatment of
excavated soils with on-site disposal). As discussed in the
following sections, GW-4 and SS-3 provide the best balance of
trade-offs among the alternatives with respect to the nine
criteria. Alternatives GW-3 and SS-5 provide the next best
balance of trade-offs among the alternatives with respect to the
nine criteria, should one or both of the primary alternatives be
unable to satisfactorily address the contamination.
The detailed analysis and evaluation of all the alternatives
which were considered are discussed below (contaminated ground
water alternatives first, followed by soil alternatives). The
alternatives are evaluated in relation to the criteria and
compared to the other alternatives under each criterion.
The NCP prioritizes the nine criteria into three categories.
The first such category includes the threshold criteria. An
alternative must meet the following two threshold requirements to
be considered as a final remedy for the site:
9.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The No Action alternatives (GW-1/SS-1) do not provide
overall protection to human health and the environment, and
therefore, will not be evaluated further because this threshold
criteria was not attained. The Limited Action ground water
alternative (GW-2) provides for a reduction of the long-term
residual risks represented by potential use of the ground water.
The remaining ground water Alternatives (GW-3, GW-4, GW-5, and
GW-6) provide elimination of long-term residual risks posed by
the ground water. The advantage of GW-6 is that CES would reduce
the time required to meet remediation goals when compared to
using conventional extraction and treatment technologies.
Surfactant injection into the subsurface would not pose a threat
to human health and the environment. The surfactant used would
be selected based on its non-toxicity, its ability to degrade and
the non-toxicity of the degradation products.
The Limited Action soil alternative (SS-2) reduces the risk
of exposure to the contaminated soils by implementation of
institutional controls. However, migration of TCE to the surface
wa~er from the contamina~ed soils may still occur. Soil
alternatives (SS-3, SS-4 and SS-5) provide long-term reduction of
risks represented by TCE source area soils.
55
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9.2 COMPLIANCE WITH ARARS
The alternative(s) selected must 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 cir-
cumstance found at the site. If it is determined that a require-
ment 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 suffi-
ciently similar to the circumstances of the release or remedial
action contemplated and are well-suited to the site.
Chemical-specific ARARs associated with the site include the
Safe Drinking Water Act, the Clean Water Act, the Clean Air Act,
and the Iowa Environmental Quality Act (Iowa Code, Chapter 455, A
and B). These ARARs are applicable because they are legal
requirements. Action-specific ARARs associated with the site
include the occupational Safety and Health Act (OSHA), the
Resource Conservation and Recovery Act (RCRA), the Clean Water
Act, the Iowa Environmental Quality Act (Iowa Code, Chapter 455,
A and B), and the Iowa Groundwater Protection Act (Iowa Code,
Chapter 455, E). These ARARs are applicable because they are
legal requirements. No Federal or State location-specific ARARs
were ident~fied for the site.
The limited action ground water Alternative (GW-2) does not
comply with chemical-specific ARARs. This alternative will not
be considered further since it does not meet this threshold
criteria. Ground water Alternatives (GW-3, GW-4, GW-5, and GW-6)
and soil Alternatives (SS-2, SS-3, SS-4, and SS-5) would meet the
chemical-specific and action-specific ARARs.
The second category of criteria include the primary
balancinq criteria. The following five criteria are used to
evaluate the alternatives to determine the option that provides
the best balance for selection of the final remedies for the
site.
9.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
Extraction and treatment of the TCE-contaminated ground
water identified as ground water Alternatives GW-3, GW-4, GW-5,
and GW-6 would eliminate all or the majority of the long-term
risks associated with direct contact to the contaminated ground
water. The VOCs removed from the ground water by GW-3 would be
captured in granular actiVated carbon which would be thermally
recharged or if spent, disposed of in an acceptable manner. The
VOCs removed from the ground water by GW-4 will be permanently
56
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destroyed thereby eliminating the associated long-term risks.
The VOCs removed from the ground water by GW-5 and GW-6 will be
vented to. ambient air. These ground water alternatives may have
minor residual risks associated with their implementation since
the contaminants will not be destroyed. The time benefit gained
by utilizing CE5 in conjunction with conventional extraction
technologies (GW-6) may be offset by the potential for increased
mobility of the DNAPL after surfactant injection.
50il Alternative 55-2 does not provide long term
effectiveness or permanence. The contaminants would remain in
the subsurface soils and continue to leach into the underlying
ground water for a long period of time. 50il Alternatives 55-3,
55-4 and 55-5 would remove the contaminants, which would
eliminate the risks to the ground water associated with the
source areas. However, long-term effectiveness at the place of
disposal for 55-4 (licensed landfill) may result in residual
risks. 50il Alternatives 55-3 and 55-4 would treat the soils
such that the action levels for the Site are attained. Venting
of the VOCs removed from the soil during treatment could
represent minor residual risk to the community at large.
9.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
The preferred alternatives to be selected must treat
contaminated ground water and soils to achieve reduction of
toxicity, mobility, and volume of contaminants at the site.
Ground water Alternatives GW-3 and GW-5 would treat the
contaminated ground water to achieve a reduction in toxicity,
mobility and volume of contaminants in the ground water. The
release of the VOCs removed by GW-5 and GW-6 to ambient air could
represent a residual risk. .
Alternative GW-6 (CE5) will enhance the ability of
conventional ground water extraction technologies to reduce the
toxicity, mobility and volume of contaminants in the Upper and
Intermediate sands. The mobility of the organic contaminant
(TCE) will be increased for the short term prior to extraction.
The reduction of toxicity, mobility and volume of the
contaminant is contingent upon the effectiveness of the
extraction system at maintaining hydraulic control.
50il Alternatives 55-3, 55-4 and 55-5 would treat the con-
taminated soils, at varying degrees, to achieve a reduction in
toxicity, mobility and volume of contaminants available for
migration to the ground water. 50il Alternative 55-4 treats only
a portion of the contaminated soils before off-site disposal.
There would be no change in the toxicity or mobility of TCE in
the untreated soils. 50Yl Alternative 55-3 does not provide for
the destruction of the VOCs removed from the soil and released to
the air.
57
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9.5 SHORT-TERM EFFECTIVENESS
The short-term effectiveness criterion addresses how well an
alternative is expected to perform, the time necessary to achieve
performance and the potential adverse impacts of its
implementation. All of the presented alternatives would provide
for short-term effectiveness. Alternative SS-2 requires that
access to the site be restricted to achieve protection from
direct contact with site contaminants. The short-term risks
associated with alternatives GW-3, GW-4, GW-5 and GW-6 would
include the normal construction hazards associated with
construction of wells and installation of a filtration system.
The short-term risks associated with alternatives SS-3, SS-4 and
SS-5 would include the normal construction and contact hazards
associated with excavation of contaminated soils. Workers on-
site could be exposed to contaminated soils and ground water;
these exposures can be reduced and controlled by use of
appropriate health and safety procedures.
Installation of the wells and treatment system for the
ground water alternatives (GW-3, GW-4, GW-5 and GW-6) is
estimated to take 6 months. The time required to achieve a
reduction in contaminant levels in ground water to the health-
based levels is unknown. Extraction of the ground water should
preclude migration of the contaminant plume. The soil
alternatives (SS-3, SS-4, and SS-5) would require approximately
one to two_(l - 2) years to complete.
All alternatives, soil and ground water, would have minimal
short-term risks as described above. However, as previously
noted, compliance with the action-specific ARARs will effectively
minimize and control the exposures.
9.6 IMPLEMENTABILITY
Ground water alternatives GW-3 and GW-5 are proven
technologies. They have been demonstrated to be effective at
numerous sites. The technology is available from numerous
vendors and as such is considered implementable. The ground
water alternatives GW-4 and GW-6 are considered innovative
technologies. However, GW-4 can also be considered a
demonstrated technology that is available from a number of
vendors and as such is considered implementable. This technology
(GW-4) would involve the use of conventional construction
techniques in conjunction with the UV Oxidation process for the
voc wastes being treated. Ground water alternative GW-6 has not
yet had a full scale demonstration, which suggests that
implementation difficulties may occur during start-up and initial
full-scale operation of the system. Because GW-6 is an emerging
innovative technology, it is anticipated that more EPA review of
the design construction and operation of the CES system would be
58
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required. At the present time there is only one vendor of the
CES technology.
Implementation of soil alternative 55-3 would involve the
use of proven technologies. However, the ability to remove
contaminants from the soil source area may not be possible using
conventional or modified vacuum systems. Soil alternatives 55-4
and 55-5 also use proven technologies. Both would involve the
use of standard excavation practices to remove the contaminated
soils. Alternative (55-5) would utilize proven thermal
technologies to treat the excavated soils. Soil alternatives 55-
3, 55-4 and 55-5 should be considered implementable.
Ground water Alternatives GW-4, GW-5, and GW-6 and soil
Alternatives 55-3, 55-5 and the treatment technologies associated
with 55-4 would require treatability studies to identify any
site-specific operational problems prior to implementation.
Ground water alternative GW-3 should be implemented relatively
easily. Portions of soil Alternative 55-2, placement of deed
restrictions on adjacent properties, could be difficult to
implement.
9.7 C05T
The costs of the ground water alternatives would include the
costs associated with installation of new monitoring wells,
annual ground water monitoring, construction and-installation of
drainage controls, extraction and on-site treatment of the ground
water. The estimated costs for the ground water alternatives is
$2,750,000 for GW-3i $3,000,000 for GW-4i $2,500,000 for GW-5i
and $3,400,000 for GW-6. These costs reflected the estimated
present worth of pumping and treating ground water for 30 years
for alternatives GW-3, GW-4 and GW-5 and for pumping and treating
ground water for 15 years for GW-6.
The costs for in-situ treatment of the soils (55-3) in the
TCE source area which include the construction of an asphalt cap,
installation of soil vents, and installation of a vacuum, blower
and venting system, are estimated to be $2,300,000. The range of
present worth costs for alternative 55-4 (off-site disposal of
TCE-contaminated soils) is $8,700,000 to $10,000,000 for
excavation and off-site disposal of 12,500 cubic yards of soil
and $19,400,000 to $20,500,000 for excavation and disposal of
28,500 cubic yards. The costs associated with land treatment of
the excavated soils and replacement on-site (55-5 land) are
estimated to be $1,200,000 for 12,500 cubic yards and $2,300,000
for 28,500 cubic yards. The cost of alternative (55-5), on-site
low temperature thermal treatment and replacement of the soils,
is $4,600,000 assuming the volume of soil to be treated is 12,500
cubic yards and $9,200,00Q assuming the volume of soil to be
treated is 28,500 cubic yards.
59
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The third category of criteria are the modifyina criteria.
The following two criteria are considered when evaluatina the
alternatives and are used to help determine the final remedies
for the site: .
9.8 STATE ACCEPTANCE
The State of Iowa has been informed of EPA's selected
remedies: ultraviolet catalyzed oxidation treatment of extracted
ground water and in-situ treatment of the soils using soil vapor
extraction techniques. The state of Iowa has not indicated
opposition to the selected remedies: however, official
concurrence will not be given on the selected remedial actions.
9.9 COMMUNITY ACCEPTANCE
.The community and other interested citizens or parties were
given the opportunity to review the Proposed Plan and supporting
documents of the Administrative Record. A thirty-day comment
period was available for the public to comment on these
documents. A Public Hearing was held in Centerville, Iowa on
August 18, 1993 to discuss the Proposed Plan and the preferred
remedial alternatives. The transcript of the Public Hearing,
which contains the comments received during the meeting, is
included in the Administrative Record which is available at the
Drake Public Library or at EPA-Region VII. No comments
indicating $trong opposition from the general public to the
preferred alternatives were received. Comments that were
submitted are addressed in the Responsiveness Summary.
10.0 THE SELECTED REMEDY
Alternatives GW-4 (ground water) and 55-3 (soil) provide the
best balance between the options with respect to the criteria.
Based on the evaluations prepared for each of the proposed
remedial action alternatives, EPA has made an initial determina-
tion that the appropriate remedial action for the McGraw-Edison
site is to address ground water contamination by extraction
followed by UV Oxidation treatment. The preferred remedial
action selected for soils is to use in-situ treatment, which will
remove the contaminants by applying a vacuum to the soils. This
alternative, while proven to work in more permeable soils, may
not be capable of removing sufficient amounts of contaminants to
achieve the action level of 200 ppb TCE. These alternatives will
require treatability/pilot testing to assure their applicability
for the Site conditions. If based on the results of the
treatability testing, these preferred alternatives are not
feasible, then the contingent preferred remedial technologies
would be GW-3 and 55-5 (LTT). Alternative GW-3 would address
ground water contamination by treating the extracted water using
granular activated carbon. Alternative 5S-5 (LTT) would address
soil contamination by treating the excavated soils using low
60
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temperature thermal treatment to achieve the soil action level of
200 ppb TCE. The treated soils would then be used as backfill on
the site. These alternatives will reduce the contaminant
concentration of ground water and the source area soils to
protective levels. The soil alternative will minimize the
potential for contaminant migration to surface water and ground
water. These remedial alternatives provide the best balance of
the factors identified by the nine criteria.
EPA believes that these alternatives satisfy the statutory
requirements of Section 121 of CERCLA, 42 U.S.C. 9621: they are
protective of human health and the environment: they comply with
all Federal and State ARARs: they are cost-effective: and they
utilize permanent destruction technologies to address the contam-
inants of concern.
The preferred alternatives would be protective of human
health and the environment by permanently destroying the TCE
contamination in the ground water and removing the TCE from
source area soils. The removal of TCE from the soils will remove
the source of contamination of the surface water thereby
effectively eliminating the risk posed by the surface water. The
contaminated ground water would be extracted and treated using UV
Oxidation techniques until health-based action levels are
achieved. The results of treatability tests will be used to
determine the ultimate applicability of this technology at the
McGEsite. If UV Oxidation cannot be applied, then the ground
water will be extracted and treated using granular activated
carbon until MCLs, which are health-based action levels, are
achieved.
The TCE-contaminated soil would be treated in-situ (in-
place). A vacuum would be applied to the soils to remove the
VOCs (TCE) from the pore spaces. The removed VOCs would be
vented to the ambient air or treated using an activated carbon
and/or catalytic oxidation system. Removal and treatment of the
VOCs would continue until residual concentrations are such that
they would not constitute an on-going source of TCE to the
underlying ground water. As a contingency plan the soils would
be excavated to the specified site action level (developed such
that the remaining soils would not constitute an on-going source
of TCE contamination to the ground water) and treated to achieve
the site specific action level (200 ppb) before being used as
backfill at the site.
These treatments would provide for maximized long-term
effectiveness and the greatest assurance of reduction of
mobility, toxicity, and volume of the treatments considered.
The preferred alternative for the VOC ground water contami-
nation should not present any significant increased short-term
risks to human health or the environment. This preferred alter-
61
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native would utilize an innovative technology that has been
at other sites to remove and destroy the ground water
contamination. Its cost is reasonable and justifiable when
compared to those of the other alternatives considered.
used
The preferred alternative for the TCE-contaminated soil may
involve some exposure risks as the contaminants will be removed
from the soil and transferred to the air. Inserting a granular
activated carbon filter into the venting system will capture the
majority of the contaminant volume. Actual system designs will
be made after the treatability tests are performed. The
contingency alternative could involve some short-term ~isks due
to exposure to the excavated untreated soils. The contingency
alternative would also, as proposed, allow discharge of the
contaminants removed from the soil to the air. However, proper
controls would be provided to minimize these risks. The soil
remedial alternatives (preferred and contingency) would
permanently remove the threat of continued migration of TCE to
the underlying ground water. contaminant removal from the soils
would assist in the protection of human health and the
environment posed by long-term and continued contamination of the
ground water by the source area soils, thus, providing excellent,
long-term effectiveness.
The overall effectiveness of the preferred alternatives are
proportional to their estimated costs. The costs are necessary
to ensure long-term permanent protection of human health and the
environment. The added costs associated with the UV Oxidation
treatment of the ground water, is justified and reasonable when
considering the fact that the contamination would be effectively
and permanently destroyed.
The preferred alternatives for this site, extraction and UV
Oxidation treatment of the VOC contaminated ground water and in-
situ treatment (removal) of the TCE from the contaminated soils,
will provide long-term protection of human health and the
environment at practicable and reasonable costs. Implementation
of these remedies will allow the site to be used for commercial,
industrial or recreational uses without significant risks to
human health or the environment. These alternatives provide the
best balance of all factors considered when evaluating possible
options at this site.
10.1
GROUND WATER
The selected remedial technology involves extraction and
collection of ground water utilizing an extraction well network,
temporary storage, followed by treatment to remove the volatile
organic compounds. The selected treatment, ultraviolet catalyzed
oxidation, uses ultraviolet (UV) light and hydrogen peroxide to
speed up the chemical oxidation of organic contaminants. The
hydrogen peroxide molecules form hydroxyl radicals in the
62
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presence of UV light.
organic contaminants.
carbon dioxide, water
residues are produced
These hydroxyl radicals react with the
The products of complete reaction are
and inorganic salts. No emissions or solid
by the UV Oxidation process.
Implementation of the ground water remedy will include the
following. Extraction wells will be installed in the surface
fill material, and the upper and intermediate sand units. Each
well will be equipped with a submersible pump, which will operate
automatically based on level controls. The extraction system
will be designed to operate on a pulsed or continuous flow basis.
The discharge from each well will be connected to a common piping
system which will transfer the extracted ground water to an on-
site collection tank, UV oxidation chamber, and hydrogen peroxide
feed system. The treatment system will be housed in the existing
manufacturing building. Pretreatment of the ground water to
reduce alkalinity, turbidity or suspended solids may be required
before the water enters the oxidation chamber.
Ground water monitoring will be conducted to evaluate the
effectiveness of the extraction and UV treatment system and to
identify changes in contaminant concentrations. Ground water
monitoring would be conducted annually.
10.2
SUBSURFACE SOILS
Implementation of the selected remedial alternative for the
subsurface soils will consist of the following. An asphalt cap
would be constructed over the contaminated area to prevent
"short-circuiting" of the air flow which will be used to remove
the volatile organic compounds. If the air flow is allowed to
"short-circuit", the air will not be pulled through the lower
more contaminated soil zones but will be allowed to enter and
exit very near the surface. Vapor extraction vents and inlet or
injection vents will be installed in the upper sand and shallow
fill. The vapor extraction vents along with inlet or injection
vents will be used to remove contaminated soil vapors from the
subsurface. The inlet or injection vents will be used to enhance
the air movement into the contaminated soil zones. The vapor
extraction vents will be connected to a soil vapor collection
header and a blower. The blower will exert negative pressure
(vacuum) on the system to remove the contaminated soil vapors
from the subsurface. The treatment system will be housed in the
existing manufacturing building. The need for treatment of the
air emissions will be evaluated during the remedial design
process.
63
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11.0 STATUTORY DETERMINATIONS
The remedial actions selected for implementation at the
McGraw-Edison Site are consistent with CERCLA and are not
inconsistent with the NCP. The selected remedies are protective
of human health and the environment, attain ARARs, and are cost-
effective. The selected remedies also satisfy the statutory
preference for treatment which permanently and significantly
reduce the toxicity, mobility, or volume of hazardous substances
as a principle element.
The selected remedies for the Site will address the release
or threat of release posed by the contaminated soils and ground
water. The remedies are thereby protective.
The ground water cleanup levels to be attained through UV
Oxidation treatment or Granular Activated Carbon treatment, if it
is determined that UV Oxidation will not meet cleanup criteria,
will reduce the risks associated with contaminated ground water
to a level that is protective of human health and the
environment. The cleanup level addresses the risks from direct
contact, inhalation and ingestion of the contaminated ground
water or the vapors originating from the contaminated ground
water. These cleanup levels are the Federal MCLs.
The soil cleanup levels to be attained through in-situ
treatment using soil vapor extraction or excavation followed by
lower temperature thermal treatment with on-site disposal, if it
is determined that in-situ treatment cannot be successfully
implemented, will reduce the risks associated with these
contaminated materials to a level protective of human health and
the environment. The soil cleanup levels were based on
protecting the ground water from continued leaching of the
volatile organic contaminants and to address the risks which
result from exposure, through direct contact, ingestion or
inhalation, to contaminated ground water.
The selected remedies will meet or attain all applicable or
relevant and appropriate Federal and State requirements that
apply to the Site.
12.0
DOCUMENTATION OF SIGNIFICANT CHANGES
There were no significant changes made to the Proposed Plan
in this Record of Decision.
64
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13.0
GLOSSARY
EPA used the following nine criteria, as specified in the
National contingency Plan CIINCpII), to evaluate alternatives
identified in the FS. While overall protection of public health
and the environment is the primary objective of the remedial
action, the remedial alternative(s) selected for McGE must
achieve the best balance among these evaluation criteria
considering the scope and relative degree of contamination at the
site.
1. Overall Protection of Human Health and the Environment -- in
order for an alternative to be considered, it must evaluated to
determine if it adequately protects human health and the
environment, in both the short and long-term, from unacceptable
risks posed by hazardous substances, pollutants, or contaminants
present at the site by eliminating, reducing, or controlling
exposures to levels established during development of remediation
goals.
2. compliance with Applicable or Relevant and Appropriate
Requirements CARARs) -- in order for an alternative to be
considered, it must be assessed to determine if it attains ARARs
under Federal environmental law and State environmental or
facility siting laws or provide grounds for invoking a statutory
waiver pursuant to CFR 300.430(f)(1) (ii)(C).
3. Long-Term Effectiveness and Permanence -- each alternative
must be assessed to evaluate its ability to maintain reliable
protection of human health and the environment over time once the
cleanup goals have been met.
4. Reduction of Toxicity, Mobility, or Volume -- are the three
principal measures of the overall performance of an. alternative.
The 1986 amendments to the Superfund statute emphasize that,
whenever possible, EPA should select a remedy that uses a
treatment process to permanently reduce the level of toxicity of
contaminants at the site; the spread of contaminants away from
the source of contamination~ and the volume or amount of
contamination at the site.
5. Short-Term Effectiveness -- each alternative must be
evaluated to assess the likelihood of adverse impacts on human
health or the environment that may be posed during the
construction and implementation of an alternative until the
cleanup goals are achieved.
6. Implementability -- each alternative must be evaluated to
determine whether it is feasible, technically and admin-
istratively. The availability of materials and service needed to
implement the alternative are a part of this assessment.
65
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7. Cost -- the cost of implementing an alternative, as well as
the cost of operating and maintaining the alternative over the
long term, and the net present worth of both the capital and
operation and maintenance costs.
8. state Acceptance -- addresses whether, based on its review of
the RIfFS and Proposed Plan, the State concurs with, opposes, or
has no comments on the alternative EPA is proposing as the remedy
for the site.
9. community Acceptance -- addresses whether the public concurs
with EPA's Proposed Plan. Community acceptance will be evaluated
based on comments received at the upcoming public meetings and
during the public comment period.
Terms Used in the Record of Decision
Administrative Order on Consent (AOC): A legal and enforceable
agreement signed between EPA and Potentially Responsible Parties
(PRPs) whereby the PRPs agree to perform or pay for the cost of
site response actions. The agreement describes actions to be
taken at a site and may be subject to a public comment period.
Applicable or Relevant and Appropriate Requirements (ARARs):
ARARs include any State or Federal statute or regulation that
pertains to_protection of public health and the environment in
addressing certain site conditions or using a particular cleanup
technology at a Superfund site. Iowa's Groundwater Protection
Act is an example of an ARAR. EPA must consider whether a
remedial alternative meets ARARs as part of the process for
selecting a cleanup alternative for a Superfund site.
Aquifer: A layer of rock or soil that can
ties of ground water to wells and springs.
source of drinking water and provide water
well.
supply usable quanti-
Aquifers can be a
for other uses as
Background levels: The amount or level of any constituent that
occurs naturally in soil, water, or air.
Bedrock: The layer of rock located below the overb~rden soils.
At the McGE site, the bedrock was encountered at a depth of about
30 feet. Bedrock can be unweathered (solid and unaltered),
weathered (altered by water, exposure to the elements), or frac-
tured (altered by earth's movements). Aquifers can be found in
certain types of bedrock.
Biota:
The animal and plant life of a region.
Carbon adsorption: A treatment system in which contaminants are
removed from ground water or surface water by forcing water
66
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through tanks containing granular activated carbon, a specially
treated material that attracts and binds the contaminants.
comprehensive Environmental Response, compensation, and Liability
Act (CERCLA): A Federal law passed in 1980 and modified in 1986
by the Superfund Amendments and Reauthorization Act (SARA). The
acts created a special tax that goes into a Trust Fund, commonly
known as Superfund, to investigate and clean up abandoned or
uncontrolled hazardous waste sites. Under the program, EPA can
either: 1) pay for site cleanup when parties responsible for the
contamination cannot be located or are unwilling or unable to
perform the work; or, 2) take legal action to force parties re-
sponsible for site contamination to clean up the site or pay back
the Federal Government the cost of the cleanup.
contaminants of Concern (COCs): Contaminants, identified during
the site investigations and risk assessments, that pose a
potential risk because of their toxicity and potential routes of
exposure to pUblic health and the environment.
Downqradient: Downstream from the flow of ground water. The
term refers to ground water flow in the same way that it does to
a river's flow.
Ground water: Water, filling spaces between soil, sand, rock and
gravel particles beneath the earth's surface, that often serves
as a source of drinking water.
Institutional Controls: Controls placed on property to restrict
access and (future) development.
Maximum contaminant Levels (MCLs): The maximum permissible level
of a contaminant in water that is or may be consumed as drinking
water. These levels are determined by EPA and are applicable to
all public water supplies. .
Migrate:
To move from one area to another; to change location.
Monitoring Wells: Special wells installed at specific locations
on or off a hazardous waste site where ground water can be sam-
pled at selected depths and studied to determine such things as
the direction in which the ground water flows and the types and
concentrations of contaminants present.
National contingency Plan (NCP):
guides the Superfund program.
The Federal regulation that
Net Present Worth: The amount of money necessary to secure the
promise of future payment or series of payments at an assumed
interest rate. .
67
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operation and Maintenance (O&M): Activities conducted at a site
after response actions occur, to ensure that the cleanup or
containment system continues to be effective.
organic compounds: Chemical compounds composed primarily of
carbon and hydrogen, including materials such as oils, pesti-
cides, and solvents.
Overburden: Material of any type, but usually clays, silts and
sands, that overlies a geological layer, such as bedrock or gla-
cial till, that contains a useful material.
Parts per Billion (ppb): A unit of measurement used to describe
levels of contamination. For example, one gallon of a solvent in
one billion gallons of water is equal to one part per billion.
Parts per Million (ppm): A unit of measurement used to describe
levels of contamination. This measurement is usually used when
referring to contamination levels in soils or sediments rather
than water. For example, one-half pound of contaminant in 250
tons of soil is equal to one part per million.
Permeability: The ability of a substance to allow liquids or
gases to pass through, due to interconnected pores within the
substance.
Persistence: The ability of a substance to remain or persist in
the environment for long periods of time.
Potentially Responsible Parties (PRPs): Any individual(s) or
company(s), (such as owners, operators, transporters, or genera-
tors) who are potentially responsible for the contamination
problems at a Superfund site. Whenever possible, EPA requires
PRPs, through administrative and legal actions, to clean up a
hazardous waste site.
Resource Conservation and Recovery Act (RCRA): RCRA is a Federal
law that regulates the transportation, storage, treatment, and
disposal of hazardous wastes. The requirements for a RCRA land-
fill include protective liners and a leachate collection system.
Remedial Alternatives: The technology, or combination of tech-
nologies, used by EPA in treating, containing, or controlling
contamination at a Superfund site. A remedial alternative usual-
ly addresses both soil and sediments, and ground water contamina-
tion.
Remedial Investigation/Feasibility study (RI/FS): A two-part
study that determines the" nature and extent of the problem pre-
sented by the release and evaluates the options available for
remedial action. The Remedial Investigation (RI) emphasizes data
68
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collection and site characterization and is typically performed
concurrently with the Feasibility study (FS). The FS emphasizes
data analysis in conjunction with technologies available for
consideration as remedial alternatives.
sediments: The sand or mud found at the bottom and sides of
bodies of water such as creeks, rivers, streams lakes, swamps,
and ponds. Sediments typically consist of relatively small soil
particles (such as silt, clay, or sand) and organic (plant) mat-
ter. Gravel sized particles are sometimes included, as well.
Solvents: Liquids capable of dissolving other liquids or solids
to form a solution. The chief uses of industrial solvents are as
cleaners and degreasers. Solvents are also used in paints and
pharmaceuticals. Many solvents are flammable and toxic to vary-
ing degrees.
Toxicity: A measure of the degree to which a substance is
harmful to human and animal life.
upgradient: This term refers to the direction of ground water
flow in the same way that the term upstream refers to a river's
flow.
Unconfined: The condition where the water table is exposed to
the atmosphere through openings in the loose and discontinuous
blanKet of weathered rock and debris overlying solid bedrock.
Unilateral Administrative Order (UAO): A legal and enforceable
document signed by EPA and issued administratively, whereby the
PRPs are required to perform site cleanup.
69
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APPENDIX A
SUMMARY OF APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs)
-------
STANDARD, REQUIREMENTS,
CRITERIA, OR LIMITATION
National Primary Drinkin,!!
Water Standanls
National Sewndary Drinkin,!!
WaleI' Siandards
Maximum Contaminanl Lcwl
(joals
. Water Quality Criteria
Releases from Solid WasIl'
Management Units
National Amhient Air
Quality Standards
TABLB A-1
PBDBRAL CHBMICAL-SPBCIPIC ARARs
MCGRAW-BDISON FACILITY
CITATION
DESCRIPTION
APPLICABLE OR
RELEVANT AND
APPROPRIATE
COMMENT
411 CFR Pari 141
ESlahli:.hl':' hcallh-hased
standard:. for puhlic waleI'
systems (maximum cOnlaminanl
levels ).
411CFR Pari 14.~
ESlahlishes wclfare-ha:.cd
standards for puhlic waler
(secondary maximum contaminant
levels ).
40 CFR Pari 141
Eslahlishes drinking water
(!ualily ~oah :'1'1 al kvl'ls of
non known or anticipated
adverse health effects with an
adequate margin of safety.
40 CFR Pari n I
Quality Criteria
for Water, 19~6
Set criteria tin wOller quality
hased on IOxkily 1o "qualk
org~nisms and human health.
.tll CFR Pari 26.t
Suhparl F
ESlahlishes maximum l"IlIItaminanl Yes
concentrations Ihal can he
released from hazardous waste
units in Pari 2M, Suhparl F.
40 CFR Pari 50
Estahlishes primary (health
hased) and secondary (welfare
hased) standards for air quality.
Yes
The MCL., for organic and
inorganic wntaminanls an:
relevant and appropriate for
ground water.
Yes
Secondary MCb for these
parameters/contaminanls may he
relevant and appropriale tin
ground water.
Yes
Proposes MCLGs for organic
contaminants should he Ireated
as "other criteria. al1visories,
and guidance".
Yes
A WQCs may he relevant and
appropriate for surface waler
discharges,
On-:.ite hazardous waste
management unit may he
considered. Same levels as
MCL'i.
Yes
Standards for particulate matter
must he monitored during some
remedial activities,
-------
STANDARD, REQUIREMENTS,
CRITERIA. OR LIMITATION
Nalional Emission SlandanJs
for Ha/ardous Air Pollulanls
Oc('upalional Hcallh and
Sakly Rq.!ulalions
TABLE A-I (continued)
PBDBRAL CHEMICAL-SPBCIPIC ARABs
MCGRAW-BDISOR PACILITY
CITATION
DESCRIPTION
-to CFR Pan fli
Estahlishcs cmission Icvels for
l'cnain hazardous air poilu lams.
29 CFR 19111.111011
Suhpan Z
ESlahlishcs pcrmissihlc
cxposure limils for work-placc
cxposurc 10 many chemkals.
APPLICABLE OR
RELEVANT AND
APPROPRIATE
COMMENT
Ycs
Siandards for somc chcmkab
may he relevam and appropriall'
10 Ihe Silc.
Lisled chemkals dClccled
on-silc. Siandards applkahlc 10
remedial work exposure.
Yes
-------
STANDAHD, REQUIREMENTS.
CRITERIA, OR LIMITATION
Iowa Environmental Quality
Aet
TABLE A-2
STATB CHEMICAL-SPBCIFIC AHARa
MCGRA.-BDI~ON FACILITY
CITATION
DESCRIPTION
APPLICABLE OR
REI.EVANT AND
APPROPRIATE
COMMENT
lo\\"a ('\Ilk. Chapter
45:'. A anti B
ESlahlishes stantlanJs for
proleelion of Ihe environmenl
(air. surfaee waler. ground
water) within Ihe Statl',
Yes
These requirements may he
relevant and approprialc at
the Site.
-------
STANDARD, REQUIREMENTS,
CRITERIA. OR LIMITATION
CLEAN WATER ACT
National Pollulion Di~l'hargl:
Elimination SY~Il:m (N PDES)
Naljonal PrClrl:alml:nl
Standards
SOLID WASTE DISPOSAL ACT
Crilcria for Classilkalion of
Solid Waslc Disposal Facililies
and Praclices
Siandards Applicahlc 10
GeneralOrs of Hazardous
Wasle
TABLE A-3
PBDBRAL ACTION-SPBCIPIC AHARs
MCGRAW-BDISON PACILITY
CITATION
I
DESCRIPTION
:\3 USC 1251-1176
40 CFR Pari 125
RC4uires pl:rmih tin Ihe
dischargl' of pollulanls for any
point sourcc inlo walers of Ihe
Unilcd Slale~.
40 CFR Pari 401
SCIS slandards 10 conlrol
pol1ulants which pa~s Ihrough or
inlCrfcrl: with IITaln\l'nl
works or which may cOnlaminalc
sewage sludgc.
40 USC 6t)O l-6t)X7
40 CFR Pan 257
Establishcs crilcria for use in
dClcrmining which solid waste
disposal facililies and praclices
pose a rcasonahlc prohahility of
advcrse cITccls on puhlic hcallh
or Ihe environmcnl and Ihcrehy
constitulc prohihitcd open dumps.
40 CFR Pari 262
Estahlishes slandards for
gcnerators of hazardous wastc.
APPLICABLE OR
RELEVANT AND
APPROPRIATE
COMMENT
Yes
Permil nOI re4uired for
CERe-LA aClivilics: hll\\'l'\'l'r.
Icchnical rC4uirements lill
discharge must he mCI if on.
sitc watcr Irealment Ol:curs
and is discharged 10 surfan'
water.
Yes
Only if the Irealed ground
watcr is discharged to a
puhlidy owned trealmenl
works.
Yes'
Thc allcrnalc soil rcmcdy will
involve on-sHe disposal of
Ireated soil.
Ycs
Thc allcrnalc ground water
remedy will involve
transponation of spent GAC
fillers.
-------
STANDARD. REQUIREMENTS.
CRITERIA, OR LIMITATION
Standards Applkahle 10
Tran~porlers of Hazardous
Wa~ll'
Corllingcnl)' Plan and
Emngenl)' Procedures
Manifcsl Syslem, Record-
keeping
I Jse and Managemenl of
Conlainers
Tanks
WasIl' Piles
Land Disposal
CITATION
..0 CFR Pari 261
Suhparl D
Suhparl E
Suhparl I
Suhparl J
Suhparl L
..0 eFR Pari 26S
TABLE A-3 (continued)
FBDBRAL ACTION-SPECIFIC ARABs
MCGRAW-BDI,OH FACILITY
DESCRIPTION
APPLICABLE OR
RELEVANT AND
APPROPRIATE
COMMENT
ESlahlishes slandards which apply
10 Ir;tnsporters of hazardous wasil'
within the US if Ihe IranSpOrlalion
rl~l.Juires a manifest under
-tfl CFR Pari 262.
Estahlishes restriclion fur
hurial of wasil'S and olhcr
hazardous materials.
Yes
Yes
Yes
Yes
Yes
Yes
If 1 he allernale ground
waleI' is implemenled.
Inmspurlalion of
h;mlrdolls wasil' would
prohahly occur.
If ground water treatmenl
hazardous waste.
II" Ihe implemenled remedy
involves off-sill' transporl
of hazardous wastc.
If Ihe implemenled remedy
involves storage of containers.
If Ihe implemenled remedy
involve the use of tanks to
treat or slore hazardous malerial.
If Ihe implemenled remedy
would treal or slore hazardous
malerials in piles.
II" rhe implemenled remedy
would involve tmriai of
contaminaled soils or residues
conlaining prohibited WaSIl'S, a
CERCLA waiver may he needed. .
-------
STANDARD. REQUIREMENTS,
CRITERIA, OR LIMITATION
eorrcCli\'c Al:\ion
Managemenl Unit Rule
OCCUPATIONAL SAFETY AND
HEALTH ACT'("OSHA")
HAZARDOUS MATERIALS
TRANSPORTATION ACT
Hazardous Materials
Transportation Rcgulations
TABLE A-3 (continued)
FBDBRAL ACTION-SPBCIFIC ABARs
MCGRAW-BDISON PACILITY
CITATION
5X Fl'd. Rq~. X65X.
codified al ..0 eFR Paris
260. 211". 2115. 270. and n I
2lJ 1 JSe 115 I ,67X
2<)CFR Pari IlJlO
4lJ use IX()I.I~n
49 eFR Parl~ 171- J7X
DESCRIPTION
APPLICABLE OR
RELEVANT AND
APPROPRIATE
COMMENT
'\'~
If the impkmcnll'd rl'lIIcdy
involvcs treatmcnt and dispo~al
of on-sill..' soils.
Allow~ Hcatcd ~oib 10 hl'
dispmcd of on-site within a
Corrcl:tive AClion Managemcnt llnil.
Rcgulales worker hcallh and
safelY at hazardous wastc ~itcs.
Rcgulates transporlalion of
hazardous matcrials.
Yc~
Under 40 eFR ]INI..lX,
rcquiremenls of the Al:t apply to
all response activilies under
the NCP.
Ycs
If Ihe implemented remedy
involves transp0rlation of
hazardous materials.
-------
STANDARD. REQUIREMENTS,
CRITERIA. OR LIMITATION
Iowa Environmental Quality
Al:t
CITATION
TABLE A-4
FBDBRAL ACTION-SPBCIFIC AHARs
MCGRA.-BD~SOH FACILITY
DESCRIPTION
APPLICABLE OR
RELEVANT AND
APPROPRIATE
COMMENT
Iowa lode, Chaplcr
455, A. B. and E
ESlahlishes slandards lor Yes
prolcl:lion 01 Ihc environmenl
(air, surfal:c wain, !!fOund
wall'r) wilhin thl' Siall'.
These requirements ma~ "l'
relevant and appropriall' al
Ihe Sile.
-------
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
THE RESPONSIVENESS SUMMARY
MCGRAW-EDISON FACILITY
CENTERVILLE, IOWA
Prepared By:
u. S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 1993
-------
1.0
2.0
3.0
3.1
3.2
MCGRAW-EDISON FACILITY
RECORD OF DECISION
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
PAGE
OVERVIEW
......... ... ............... ....... ............ 1
BACKGROUND ON COMMUNITY INVOLVEMENT
...................1
SUMMARY OF COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD................................. 2
Comments from Interested citizens ..................... 2
Comments from the site Owner .......................... 5
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McGraw-Edison Facility
centerville, Iowa
Responsiveness Summary
1.0
OVERVIEW
In the Proposed Plan released to the public, the
Environmental Protection Agency (EPA), made a preliminary
selection for the preferred alternative for remedial action at
the McGraw-Edison Facility. EPA's recommended alternatives
addressed the TCE-contamiriated soils and ground water at the
.Site. The preferred alternative involved the extraction and
treatment of the contaminated ground water using ultraviolet
catalyzed oxidation and the extraction of the TCE within the soil
using a soil vapor extraction system.
Judging from the comments received during the public comment
period, the residents of Centerville generally accepted the
preferred alternative as presented.
2.0
BACKGROUND ON COMMUNITY INVOLVEMENT
Representatives of EPA and the Iowa Department of Natural
Resources (IDNR) met with representatives of the community and
Appanoose.County on July 22, 1987. The purpose of the meeting
was to answer questions regarding the "Superfund process" and
liability of property owners.
EPA and the Iowa Department of Health held Availability
Session meetings with adjacent property owners and other
interested citizens in Centerville, Iowa on March 27, 1991. The
'purpose of these meetings was to discuss the Site conditions and
the health risks that the Site represented to the general public.
The Administrative Record was placed in the Drake Public
Library on August 11, 1993. A public meeting was held in
Centerville on September 24, 1991 to inform the public of the
initiation of remedial investigation activities at the site and
to provide details of those activities. Fact sheets, identifying
significant site activities, were mailed to everyone on the Site
mailing list (which included local media, officials and PRPs)
during November 1990, March 1991, September 1991, and August
1993.
The remedial investigation (RI) and feasibility study (FS)
reports and the Proposed Plan for the McGraw-Edison facility were
1
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released to the public on August 10, 1993. These three documents
were included in the addendum to the administrative record which
is located in the EPA Record Center, Region VII and at the Drake
PUblic Library in Centerville. Notice of the availability of
these documents was published in the Dailv Iowegian on August 10,
1993. A public comment period was held from August 10 to
September 9, 1993. A public hearing was held in Centerville,
Iowa on August 18, 1993. At this meeting, representatives from
the EPA, the Iowa Department of Health (IDOH), and the Agency for
Toxic Substances and Disease Registry (ATSDR) were available to
answer questions about the site and the remedial alternatives
under consideration.
3.0
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD
. Comments raised during the public comment period on the
draft Feasibility Study (FS) and Proposed Plan are summarized
below. The Public Comment Period was held from August 10 to
September 9, 1993.
3.1
Comments from Interested citizens
The following are comments from citizens who attended the public
hearing on the Proposed Plan for the McGraw-Edison site.
~omment #1
One commenter asked if there would be any incineration on-site.
Response
The preferred remedial alternatives identified in the Proposed
Plan would not involve on-site incineration. The preferred
ground water technology uses a chemical oxidation process
utilizing ultraviolet light. The alternate soil remedial
technology would employ lower temperature thermal treatment.
This technology would heat the soils to volatilize the organic
contaminant (TCE), but would not incinerate the soils. No on-
site incineration is contemplated at the McGraw-Edison Site.
Comment #2
One commenter stated that it was nice to see things finally
happen and getting done.
Response
EPA looks forward to continuing to work with the potentially
responsible parties in completing clean-up activities at the
site.
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Comment #3
One commenter asked when EPA anticipates that the site cleanup
will be completed.
Response
The answer to this question depends on many variables. The
cleanup process will include both subsurface soils and ground
water. There are many geologic features of the subsurface that
are not completely understood. Based on the knowledge presently
available, it is estimated that it will take 10 years to remove
the TCE contamination from the subsurface soils and 30 years to
remove the TCE from the ground water to the point where the
Maximum contaminant Level (MCL) of 5 parts per billion (ppb) is
attained. .
In the shorter term, the design process for the selected remedial
alternatives is expected to take 6 to 9 months. After the design
is approved, construction can be initiated for the remedial
action. It is estimated that construction will take 6 to 12
months. A period of operation, generally one to two years, will
be needed to ensure that the systems are operating as designed.
Long-term response will begin after this initial "shakedown"
period is complete.
Comment #4
One commenter asked if the majority of the building would be
available for occupancy and use when the long-term response
portion of the remedial action starts.
Response
The desire of the community and Appanoose County to be able to
use the building is understood and appreciated. However, EPA can
only make that decision after a careful evaluation of all
residual risks to human health and the environment, from the
building, has been made. If the residual risks, from the
building, are within the acceptable range, it may be possible for
a majority of the building to be used during the long-term
response. EPA does not own the building and cannot restrict
access to the building unless such access presents a threat to
human health or the environment. The ultimate decision as to the
use of the building will be made by the property owner.
Comment #s
One commenter asked if there was anything EPA could do, such as
prepare a risk assessment. for site and building use, to assist
Cooper Industries in its decision-making process regarding future
building occupancy.
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Response
The mission of EPA is to respond to threats to human health and
the environment. If a portion of the building is to be
considered for use during the long-term response action, an
assessment of the risk to human health and the environment will
be required. If EPA determines that the building can be safely
occupied at some future point during the long-term response
action, EPA cannot restrict access.
Comment #6
One commenter asked whether EPA believed that the property will
ever be cleaned up.
Response
It is difficult to estimate the time required to cleanup ground
water. Once a chemical contaminant reaches ground water, it
diffuses, disperses and may float or sink depending on whether or
not it is heavier than water. A small amount of contaminant can
contaminate large volumes of water.
The information gathered during the site characterization studies
and the remedial investigation were used in conjunction with
computer models of ground water regimes and the chemical
characteristics of TCE to estimate the time needed to "clean" the
water to 5 parts per billion TCE. The modeling indicated that
approximately 30 years would be required to achieve 5 ppb TCE if
the TCE in the soil source area were removed.
Comment #7
One commenter voiced a concern about the uncertainty regarding
future use of the building and the resultant effect on the
community and Appanoose County.
Response
As discussed in the Feasibility Study, it is anticipated that the
existing building will house the blower for the in-situ soil
technology and the ultraviolet oxidation chamber and appurtenant
equipment for ground water cleanup. The entire building will not
be available for use by an industrial concern. Both EPA and
Cooper Industries, have in the past been aware of and been
sensitive to the fact that the building is very important to the
community and Appanoose County. That sensitivity is expected to
continue as long as human health and the environment is protected
from any excess risks caused by the site contaminants.
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3.2
Comments from Cooper Industries
Comment #1
The legal or factual basis for a contingent soil or ground water
remedy was disputed.
Response
There is no statutory or regulatory prohibition on the selection
of a contingent remedy. The National Contingency Plan, 40 C.F.R.
Part 300 (NCP) states that EPA shall identify the remediation
goals in the Record of Decision (ROD) and discuss how the
selected remedy will meet these goals. (40 C.F.R.
~ 300.430(f) (5).) In addition, the NCP encourages the
development of alternatives using innovative technologies in the
Feasibility Study (40 C.F.R. 9 300.430(e) (2) (G) (ii) and
~ 300.430(e) (5).) To promote the development and use of
innovative technologies, EPA has developed guidance (OSWER
Directive 9355.3-02) for the issuance of RODs which have
contingent remedies.
The preferred remedial technologies identified for the McGraw-
Edison site, in-situ treatment of the contaminated soils using
soil vapor extraction techniques and ultraviolet catalyzed
oxidation treatment of the contaminated ground water, were viewed
by the EPA as somewhat innovative. The technologies have been
used successfully at a limited number of sites: however, the soil
conditions and the amount of sediments in the ground water at the
McGraw-Edison Site may prevent the achievement of remediation
goals. With that possibility in mind, the EPA elected to
identify contingent remedial technologies that could be
implemented in the event that the performance criteria specified
in the ROD could not be attained.
Another important requirement of the NCP is that the public be
given the opportunity to comment on EPA's proposed remedy at each
site. (40 C.F.R. 9 300.430(f) (3).) EPA's Proposed Plan for the
MCGraw-Edispn Site contained a thorough discussion of the primary
and contingent portions of the remedy, and each were evaluated
using the nine criteria set forth in the NCP. The public has
therefore had the opportunity to comment on the contingent remedy
as well as the primary remedy, fulfilling this requirement.
Comment #2
If the contingent remedy is required, it would be a fundamental
change that demands advance notice to the public of the proposed
change and the information supporting the decision.
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Response
Implementation of a contingent remedial action would not be a
fundamental change in the ROD. The ROD sets forth performance
criteria which must be met by the preferred remedial technology.
In the event that the preferred remedial technology does not
attain the performance criteria, the contingent remedy,
identified in the Proposed Plan and the ROD, would be
implemented. As discussed above, notice to the public on the
potential use of the contingent remedial technology and
availability of the supporting information was given during the
Proposed Plan Public Comment Period. All interested parties have
had the opportunity to comment with regard to the use of the
contingent remedial technology.
Comment #3
The designation of contingent remedies by EPA is contrary to
remedy selection procedures identified in the National
Contingency Plan (NCP).
Response
Both the primary remedies and the contingent remedies were
thoroughly evaluated in the Proposed Plan using the nine criteria
set forth in the NCP. (40 C.F.R. ~ 300.430(e) (9) (iii).) In
addition, EPA followed the public participation ~equirements of
the NCP in publishing the Proposed Plan, including the contingent
remedies. See also the response to Cooper Industries' Comment
#1.
Comment #4
The preferred remedial alternatives identified by EPA will be
fully successful.
Response
EPA must ensure that the performance standards set forth in the
Proposed Plan and the ROD will be attained. EPA is -optimistic
that the preferred remedial technologies will be successful.
There is, however, some uncertainty regarding the effectiveness
of the soil vapor extraction system and the associated
enhancements in the low permeability clay soils at the site. EPA
also has allowed for uncertainty as to the effectiveness of the
ultraviolet catalyzed oxidation treatment system, given the
excessive turbidity and high levels of very fine particulate
matter which has been observed in the ground water at the site
(generally over 100 Nephelometric Turbidity units (NTUs».
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Comment #5
The contingent remedies identified in the Proposed Plan are
factually premature and would violate the NCP's mandatory public
participation procedures.
Response
As discussed above, EPA has developed guidance which specifically
addresses the development and issuance of RODs with contingency
remedies. In addition, as discussed in the Responses to Cooper
Industries' Comments ~l and ~3 above, EPA has fully complied with
the public participation procedures of the NCP in its
identification and evaluation of both the primary and contingent
remedies.
Comment #6
If the preferred remedial technologies are not adequately
addressing the contamination at the Site, the intervening
developments in site characterization methods, risk assessment
standards, and potential new technologies should be evaluated and
the ROD amended at that time. A retroactive substitution of a
contingent technology should not be applied.
Response
The identification of contingent remedial technologies and their
ultimate use, in the event that performance standards are not
achieved, is not a retroactive substitution but pre-selection of
remedial technologies that have been evaluated against the nine
criteria and found to result in long-term effectiveness,
permanent reduction of toxicity, mobility or volume and are
considered cost-effective.
If one or both of the preferred remedial technologies cannot
attain the specified performance standards and if in the
intervening time period new or existing (but considered untried)
technologies have been identified that are able to address the
site contamination in a permanent and cost-effective way, the NCP
sets forth procedures for amending a ROD if a technology not
discussed in the ROD were considered for selection. In the event
that another technology is substituted for either the primary or
contingent remedies set forth in the ROD, EPA would provide
another opportunity for public comment prior to amending the ROD.
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Comment #7
The available data is insufficient to evaluate fully the
appropriateness of the contingent remedies identified in the
Proposed Plan.
Response
The EPA believes that the data contained in the Remedial
Investigation report and in the Feasibility study are sufficient
to evaluate the appropriateness of the contingent remedies
identified in the Proposed Plan. The Feasibility Study provides
ample information regarding the long-term effectiveness, the
reduction of toxicity, mobility or volume, the short-term
effectiveness, the implementability and the cost-effectiveness of
each of .the identified remedial technologies for an adequate
analysis to be performed for each.
Comment #8
soil Vapor Extraction (SVE) enhancement technologies exist and
should be utilized to enhance the effectiveness of the technology
in the on-site clayey soils. The incremental costs associated
with the enhancement SVE technologies are more cost-effective
than the excavate/treat technologies.
Response
The EPA did not exclude the enhancement technologies for soil
vapor extraction identified in the Feasibility study. It is
assumed that high vacuum (dual phase) vapor extraction and
pneumatic fracturing of the soils may be required to achieve the
performance standards. Use of the high vacuum system is
anticipated given the low permeability of the clay soils on-site.
It is EPA's understanding that the pneumatic fracturing of the
soils should result in more soil surface area exposed to the
vacuum pressure, thereby allowing more contaminated soil vapors
to be removed from the subsurface.
Comment #9
The Corrective Action Management unit (CAMU) Rule is being
challenged. If the challenge is successful, the on-site
replacement of excavated and treated soil would no longer
available and the excavated soils may have to be disposed
site, which would significantly increase the costs.
be
off-
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Response
EPA is aware that the CAMU Rule is being challenged. If, due to'
the outcome of that challenge, the waste-handling procedures
outlined in the CAMU rule are no longer available as a remedial
alternative, the soil contingent remedy would no longer be
implementable. Should the SVE technology be incapable of
attaining the specified performance standards, EPA would have to
evaluate other remedial alternatives which could be employed to
achieve the performance standards. The selection of a different
-~ remedial alternative would represent a significant change from
- the soil contingent remedial technology specified in the Proposed
Plan and the ROD. If such a change were necessary, EPA would
provide for public participation as set forth in the NCP, prior
to any necessary amendment to the ROD.
Comment #10
Land farming is more cost-effective than Lower Temperature
Thermal (LTT) as a treatment technology for the contingent soils
remedy.
Response
EPA is concerned that the TCE released from excavated soils
through voTatilization in a land farming operation may be at
levels high enough to require additional treatment of the vapors.
The land farming treatment alternative did not provide for a
method of capturing the volatilized TCE and treating it before
releasing it to the atmosphere. LTT treatment technology, on the
other hand, does afford a means of treating the volatilized gases
before release to the atmosphere and is therefore more protective
of human health and the environment.
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