PB94-964134
EPA/ROD/R05-94/259
November 1994
EPA Superfund
Record of Decision:
Ormet Corporation,
Hannibal, OH,
9/12/94
-------
RECORD OF DECISION
DECLARATION
Site Name and Location
Ormet Corporation
Hannibal, Ohio
Statement of Basis and Purpose
This Record of Decision presents the selected remedy for the
Ormet Corporation Superfund Site (the Site). The remedy was
chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by
the Superfund Amendments Reauthorization Act (SARA) and, to the
extent practicable, with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). The decision is
based on the administrative record for the Site.
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 an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The purpose of this remedy is to eliminate or reduce
contamination in soils, sediments and g~ound water, and to reduce
the risks associated with exposure to contaminated materials.
This is the first and final remedy planned for the Site: The
components of the remedy include:
Ground Water -
Pumping shall continue at the Ormet Ranney well
and existing interceptor wells to maintain capture
zone of contaminated ground water. Interceptor
well water shall be treated by ferrous salt
precipitation and clarification, or other means
necessary to achieve standards set by the Ohio
Environmental Protection Agency (OEPA) Program
implementing the National Pollutant Discharge
Elimination System (NPDES). Treated water shall
be discharged to the Ohio River.
Leachate -
Trench drains shall be installed to intercept and
extract all leachate seeping from the Construction
Material Scrap Dump (CMSD). Leachate shall be
treated to NPDES discharge limits.
-------
CMSD -
The Construction Materials Scrap Dump (CMSD) shall
be re-contoured and covered with a dual-barrier
cap that meets the requirements of the Resource
Conservation Recovery Act (RCRA) , Subtitle C.
Soils -
Residual soil contamination in the Former Spent
potliner Storage Area (FSPSA) shall be treated by
in-situ soil flushing.
Sediments -
Contaminated soils from the Carbon Runoff and
Deposition Area (CRDA) shall be excavated and
consolidated under the cover at the CMSD. Soils
to be excavated from the trench drains shall also
be consolidated under the CMSD cap.
PCB and PAR-contaminated sediments shall be
removed by dredging from the Outfall 4 stream
backwater area. Sediments with PCB' concentrations
lower than 50 ppm shall be solidified and
consolidated under the CMSD cap. Sediments with
PCB concentrations higher than 50 ppm shall be
disposed of off-site in a EPA approved disposal
facility.
Site-wide -
Use of institutional controls to limit ground
water and land use.
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable, and, with respect to the FSPSA,
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principle element. However, the CMSD, sediments, and CRDA soils
will not be treated. It is impracticable to treat the
homogeneous materials in the CMSD, and it is not cost-effective
to treat on-site the small volume of soils and sediments to be
excavated. Solidification will reduce mobility of the PCBs and
PARs in sediments; however, EPA has determined in the past that
solidification does not co~stitute treatment.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years of commencement of remedial action to ensure
that the remedy continues to be protective of human health and
the environment.
-------
State Concurrence
The State of Ohio does not concur with the selected remedy.
/
-------
H.
J.
K.
L.
TABLE OF CONTENTS
A.
SITE LOCATION AND DESCRIPTION
. '1 . . . . .
B.
SITE HISTORY AND ENFORCEMENT ACTIVITES . . . . .
. .. .. ..
C.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
.. .. .. .. ..
.. .. .. ..
D.
SCOPE OF THE SELECTED REMEDY. . .
.. .. .. .. .. .. ..
.. .. .. ..
E.
SUMMARY OF SITE CHARACTERISTICS
.:1 .. .. ..
.. .. .. .. .. .. .. ..
F.
SUMMARY OF SITE RISKS
.. .. .. .. .. .. .. .. .. .. .. .. .. ..
G.
RATIONALE FOR FURTHER ACTION.
.. .. .. .. .. .. .. .. .. .. .. .. ..
DESCRIPTION OF ALTERNATIVES
.. .. .. .. .. .. .. .. .. .. .. .. .. ..
1.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
THE SELECTED REMEDY
.. .. .. .. ..
.. .. .. .. .. .. ..
STATUTORY DETERMINATIONS.
.. .. .. .. .. .. .. .. ..
DOCUMENTATION OF SIGNIFICANT CHANGES
.. .. .. .. .. .. .. .. .. ..
APPENDIX 1 .......... ... ...RESPONSIVENESS SUMMARY
APPENDIX 2 ............. ...ADMINISTRATIVE RECORD INDEX
1
1
3
4
4
7
11
11
15
22
29 .
35
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
Ormet Superfund Site
A.
SITE LOCATION AND DESCRIPTION
The Ormet Superfund Site (the Site) is owned and operated by the
Ormet Corporation (Ormet), a primary aluminum reduction facility.
The Site is located in Monroe County, Ohio, on the west bank of
the Ohio River (river mile 123.4) approximately 35 miles south of
Wheeling, West Virginia and 2.5 miles north of Hannibal, Ohio, on
State Highway 7 (Figure 1). Immediately to the southwest of the
Ormet Site is the Consolidated Aluminum Corporation (CAC).
The Ohio River is immediately adjacent to the Site, and is used
for commercial and recreational boat traffic. The Hannibal Lock
and Dam is approximately 3 miles down-river. The primary
population centers are Hannibal, Ohio (2.5 miles south, .
population 800), New Martinsville, West Virginia (across the Ohio
River from Hannibal, population about 6,705), and Proctor, West
Virginia (population 150, about 3/4 miles downwind and upriver) .
There are no drinking water intakes along the river within 100
miles downstream of Ormet.
The Ormet Site is located in an area known as Buck Hill Bottom, a
portion of the Ohio River Floodplain that formed as river
sediments were deposited on the inside of a meander bend. This
lens-shaped bottomland is approximately 2.5 miles long and 0.5
mile wide. The Ormet property occupies about 245 acres in the
northern portion of the area. The northeastern portion of the
Ormet property is the area that was investigated during the
Remedial Investigation and Feasibility Study (RI/FS) (Figure 2) .
The southwestern portion contains the active manufacturing
facility. .
B.
SITE HISTORY AND ENFORCEMENT ACTIVITES
Since the plant started operations in 1958, Ormet's main process
has been the reduction of alumina to produce aluminum metal.
From 1958 to 1968, approximately 85,000 tons of spent potliner, a
hazardous by-product of aluminum production (containing cyanide),
were placed in an unlined, 10-acre open area in the northeast
part of the Site, identified in Figure 2 as the Former Spent
potliner Storage Area (FSPSA).
There are five impoundments on Site, called the Former Disposal
Ponds (FDP). Total area of FDPs 1-4 is about 5 acres. FDP 5 is
about 13 acres in size. These ponds are unlined and constructed
of natural materials. FDPs 1 through 4 received approximately
50,000 cubic yards of process waste from the air emissions wet
scrubbing system in the form of sludge, the primary constituents
of which were alumina, particle carbon, and calcium-based salts.
-------
From 1968 to 1981, much of the potliner waste was removed from
the FSPSA by Ormet and transported to an on-site recovery plant
that removed a useable material called cryolite from the
potliner. Waste slurry from the cryolite recovery plant was
routed to FDP 5, although FDPs 1-4 may have received minor
amounts of cryolite plant waste. The tailings are alkaline and
consist primarily of carbonaceous material from the potliner,
along with sodium and calcium-based salts. The volume of
materials in FDP 5 is about 370,000 cubic yards. Since 1980,
spent potliner material generated by the plant has been
transported off-site for disposal.
From about 1966 until mid-1979, Ormet deposited waste -
construction materials and other miscellaneous plant debris,
including capacitors and spent potliner, in the southeastern
corner of the Site, adjacent to Pond 5 and the Ohio River (Figure
2). This 4 to 5 acre area is designated as the Construction
Material Scrap Dump (CMSD). A list of materials disposed of in
the CMSD is contained in the RI report, Appendix G.
An area referred to as the Carbon Runoff and Deposition Area
(CRDA) (Figure 2) contains carbon deposits, probably carried
there by storm water runoff from an area of the Ormet plant where
spent graphite anodes were crushed in a mill. Some of the carbon
runoff may also have entered the 004 outfall stream and backwater
area (Figure 2) .
In 1972, Ormet initiatied a ground water investigation which
identified high levels of fluoride coming from FDP 5. To protect
the quality of its process water, two extraction wells were
installed to intercept the plume. These wells have operated
continuously through the present day.
A 1978 study by Ormet showed improvement in the ground water from
under FDP 5, but indicated decreased quality in the area of the
FSPSA. A 1984 study confirmed that the FSPSA was leaching
contaminants to ground water. Additional sampling in 1985, 1986,
and two rounds of sampling during the Remedial Investigation (RI)
in 1988 and 1990 show concentrations of fluoride in ground water
decreasing down-gradient of the disposal ponds, but fluoride and
cyanide are on the rise in and downgradient of FSPSA.
The 1985 study identified low levels of toluene but no other
organic compounds in ground water.
Based on contamination found at the Site and its potential impact
on drinking water supplies, U.S. EPA placed the Site on the
National priorities List (NPL) in September 1985.
In May 1987, the United States Environmental Protection Agency
(EPA), Ohio Environmental Protection Agency (OEPA), and Ormet
Corporation (Ormet) entered into an Administrative Order by
2
-------
Consent (Consent Order) providing for Ormet to conduct the
Remedial Investigation/ Feasibility Study (RI/FS) under EPA and
OEPA supervision. The RI report was completed in December 1992
and the FS was completed in December 1993.
II
In addition to defining the contamination found in the disposal
areas described above, seeps were discovered during the RI near
the Plant Recreational Area ballfields and along the western edge
of the CMSD. The seeps contained cyanide ranging in
concentrations from 79 to 950 ppb.
C.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
EPA held a public availability session :in April 1993, after the
RI was completed, to explain to interested parties the results of
the investigation and what the next st~ps would be. At this
time, EPA conducted one-on-one, in-home interviews with residents
to determine whether people had concerns about the Site they did
not wish to express publicly. No such concerns were conveyed to
the interviewers.
The RI/FS reports and the Proposed Plan were released for public
comment on April 11, 1994. Information repositories have been
established for the Administrative Record at the New Martinsville
Public Library and the Hannibal Post Office.
A public meeting was held on April 20,1994, at the River High
School in Hannibal, Ohio. EPA conducte~ the meeting, explained
the Proposed Plan, and answered questidns about the Site and the
Superfund remedy selection process. Approximately 40 people
attended. Oral comments were documented by a court reporter, and
a transcript of the meeting has been placed in the Administrative
Record.
EPA received a timely request for extension of the comment period
from Ormet on April 25, 1994, and the extension was granted.
Therefore, the RI/FS and Proposed Plan ~ere available for public
comments from April 11 to June 10, 1994. Comments received
during that period, and EPA's response .to those comments, are
documented in the attached Responsivene~s Summary.
The public participation requirements o'f CERCLA sections 113
(k) (2) (i-iv) and 117 have been met in the remedy selection
process. This decision document presents the selected remedial
action for the Ormet Site chosen in accordance with CERCLA, as
amended by SARA and, to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). The
decision for this Site is based. on the Administrative Record.
3
-------
D.
SCOPE OF THE SELECTED REMEDY
This ROD addresses the final remedy for the Ormet Site. The
threats to human health and the environment result from source
materials in the CMSD, the FSPSA, the CRDA, and backwater area
sediments, which have migrated or threaten to migrate to ground
and surface water. This response action shall contain the source
material in the CMSD, CRDA and the backwater area, treat
contaminated soils in the FSPSA, and restore a Class II aquifer
to drinking water quality.
This remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicabie for the
Site. Treatment of the soils in the FSPSA is expected to
eliminate the source of cyanide in ground water, and allow for
unrestricted use of that portion of the Site. However, it is
impracticable to treat the contents of the CMSD because of the
heterogeneity of landfill contents, so this source shall be
contained. The small volume of soils and sediments to be
excavated makes a treatment component for these media non-cost-
effective, so they will be consolidated under the CMSD cap.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a five-year review shall be
conducted to ensure that the remedy continues to be protective of
human health and the environment.
E.
SUMMARY OF SITE CHARACTERISTICS
Site Geology and Hydrology
The Site is located in the Ohio River valley near the base of the
West Virginia Panhandle. The area is part of the Appalachian
Plateau province, characterized by steep hills and valleys. The
Ohio River receives virtually all natural drainage in the area.
The only flat land is generally found as small areas of
floodplain adjacent to the Ohio River, where deposition of
sediments and changing river levels have carved terraces in the
alluvial materials. Proximity to the river for transportation
and water, and ease of development, has made these flat areas
magnets for development.
The sandy, gravelly sediments that form these bottomlands make
prolific aquifers along the length of the Ohio River. The same
qualities that make them good aquifers also make them vulnerable
to contamination.
The Ormet property itself consists of two main, relatively flat
terraces at about 630 and 665 feet elevation. To the northwest
of the property and Highway 7 are steep, heavily forested hills
that rise in elevation to 1300 feet in less than a mile. A small
4
-------
stream bisects the property, generally separating the active
plant from the disposal areas to the northeast. The source of
this stream is a permitted outfall (Outfall 004) for plant
process water. The stream conveys the process water and
stormwater runoff along the southwester~ edge of the disposal
areas to a small backwater area of the Ohio River (Figure 2) .
The alluvial aquifer beneath the surface of Buck Hill Bottom is a
source of drinking water, currently producing about 4 million
gallons per day. Most of this water is II pumped by two high-
capacity "Ranney" wells, one on Ormet property, the other
belonging to CAC. The CAC well provides drinking water to both
CAC and Ormet employees, a total of about 3200 people.- Ormet
uses its Ranney well to provide non-contact cooling water to its
alumina reduction process. The ground water under the Site would
be classified as Class lIb ground water, since it is not
currently used for drinking but has the potential to be used, and
is considered restorable in a reasonable timeframe.
Nature and Extent of Contamination
The areas and media investigated duringithe two phases of the RI
included the following:
*
*
Former Disposal Ponds (FDPs)
Former Spent potliner Storage Area (FSPSA)
Carbon Runoff and Deposition Area (CRDA)
Construction Material Scrap Dump and Western
Seeps (CMSD)
Ballfield and Northern Seeps (SP)
Ground Water (GW)
Surface Water (SW)
Sediments (from Ohio River and Backwater Area)
Air
Environmental Evaluation
(SED)
*
*
*
*
*
*
*
*
As a result of the investigation, low to moderate levels of
contamination were identified in all media and sources. Specific
contaminants of concern for human healt~ are shown in Table 1.
Cyanide, fluoride, chromium, arsenic, a¥d polynuclear aromatic
hydrocarbons (PAH) were found in solids'from the FDPs. The
contaminants do not appear to be migrating to any significant
degree, either to ground water or air, except that fluoride is
present in ground water down-gradient of FDP-5 at levels that
exceed the MCL. A comparison with sample results from 1972,
however, shows that fluoride concentrations down-gradient of FDP-
5 have decreased by one to three orders of magnitude at a given
sampling location. For example, at sampling location TH-6/MW-34,
fluoride levels have declined from a high in 1972 of 1050 ppm to
1990 levels of 6.5 ppm. Similar reduction is seen at location
MW-17. MW-39 is the highest recent result at 110 ppm, but this
5
-------
is still a tenfold reduction over 1972 results. It is apparent
that fluoride leaching from FDP-S has long-since peaked, and can
be expected to continue its decline as long as the current
pumping regime is maintained.
Pond solids are characteristically alkaline in nature (i.e., pH >
7.0). There is no evidence of surface runoff from the ponds.
However, a steel conduit extends from the pond 5 dike along the
Ohio River north of the CMSD, and may provide subsurface drainage
from that pond, or from the CMSD. Sampling results of effluent
from the conduit showed cyanide at greater than 4 mg/L.
At the FSPSA, relatively high concentrations of PARs were
detected in soils in the 2-4 foot horizon. Because PARs are
relatively immobile, they are not expected to contribute
significantly to releases to ground water from the FSPSA.
Moderate levels of cyanide and arsenic, both mobile in ground
water, were identified in the FSPSA. The FSPSA is the primary
contributor to cyanide and fluoride contamination in ground
water, and may also be a factor in the arsenic showing up in
down-gradient wells. In contrast to the situation at FDP-S
above, fluoride levels in and down-gradient of the FSPSA have
shown an increasing trend since 1972. For example, at the MW-
18/TH-11 location, levels of fluoride have risen from 10 ppm in
1972 to 710 ppm in 1990.
The CRDA is underlain by moderate to low-permeability soils. A
single composite sample from the CRDA showed polychlorinated
biphenyls (PCBs) at 56 mg/kg. PARs were detected in the
surficial carbon soil at higher levels than in the underlying
native soils, indicating low potential for migration to ground
water. However, the CRDA is a probable source of PCBs and PARs
to the backwater and river bank, transported by stormwater
runoff. Arsenic was also detected as high as 83 mg/kg in soils
at the CRDA. .
The CMSD is a significant source of cyanide and PCBs in the
seeps, backwater sediments, and river water. The principal
transport mechanism appears to be discharge of seep water to the
004 Outfall stream, and there may be transport via the steel
conduit mentioned above. There is a low-permeability clay/silt
layer underneath the CMSD which appears to provide a natural
barrier to contaminants leaching to ground water, and the Ormet
Ranney well creates a hydraulic gradient away from the river, so
ground water discharge to surface water is not considered a
reasonable migration pathway. PARs are present at levels that
contribute to an increased ecological risk, but are not believed
to be migrating out of the source area.
Two seeps were identified to the north of FDP 5 and the CMSD.
These seeps drain out in the vicinity of the plant recreation
6
-------
area ballfield.
mg/l.
Sample results indicate cyanide as high as 1.5
Ground water at the Site is contaminateo in excess of Safe
Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs) for a
number of contaminants, including tetrabhloroethene (PCE),
cyanide, fluoride, arsenic, antimony, and beryllium. The primary
source of the plume appears to be due to infiltration of
precipitation through the FSPSA. The plume extends about 3,000
feet from the FSPSA before it reaches the interceptor wells. It
is characterized by a basic pH near the FSPSA, which becomes
progressively more neutral with distance from the source. Sodium
is also typically elevated in the plume. Table 2 shows ranges of
concentrations at the Site for chemicals of concern in ground
water.
A small backwater area at the mouth of the 004 outfall stream
creates a sink for contamination. PCBs at nearly 100 ppm and
total PAHs of over 1100.ppm were identified in the sediments..
Although industrial activity upstream from the Site contributes a
certain level of ambient contamination in Ohio River water and
sediment as it reaches the Site, both media are showing some
effects from the Site. The effects are: mainly in the form of
elevated pH and concentrations of PAHS,llPCBS and cyanide.
Because the influence of the two Ranne~ wells makes the river a
losing stream for ground water in this tretch, stormwater runoff
and seep discharge are the most likely 'transport mechanisms to
the river. I
These same transport mechanisms account for the PAHs and PCBs
found in the backwater area sediments, which are the main
contributors to the current risk. PCBs were not found in
sediment samples upstream from the backwater area, and PAHs are
two orders of magnitude lower in background samples.
Sampling of fugitive dust emissions indicate that PMlO particles
are migrating off-site. However, air modeling indicates the risk
to the nearest down-wind receptors in Proctor, West Virgina, is
negligible.
F.
SUMMARY OF SITE RISKS
Human Health Risks
Analytical data collected during the RI: from all media were
combined with site-specific and nation~lly applied standard
assumptions and criteria to produce a Baseline Risk Assessment
(BRA). The BRA is used to estimate thd risks from the Site to
human health and the environment if no 'Iaction is taken and none
7
-------
of the existing controls are operated or maintained. The results
of a human health BRA are presented in terms of the potential for
an individual to have an excess lifetime cancer risk (ELCR) due
to exposure to Site contaminants and/or to experience toxic (non-
carcinogenic) effects from Site contaminants, as measured by a
Hazard Index (HI). EPA considers a cumulative ELCR of 1 x 104
(one in ten thousand) and/or a HI of 1 or greater to present
sufficient added risk to prompt a response action.
In the initial step of the BRA, a list of contaminants of concern
was developed by applying screening criteria set out in EPA's
Risk Assessment Guidance for SUDerfund (RAGS) to chemicals and
compounds identified at the Site. Chemicals were screened out if
they were not detected, infrequently detected and not generally a
high risk chemical, present at levels below those essential to
human nutrition, considered to be present due to field or lab
contamination, or a tentatively identified compound (one whose
identity and therefore concentration could not be resolved by the
analytical process used. Table 1 contains a comprehensive list
of the chemicals that survived the screening process and were
considered in the human health and/or the environmental risk
assessment.
In the exposure assessment, reasonable maximum exposure (RME)
scenarios were developed for a variety of human receptors based
on current land uses on and around the Site, and based on
hypothetical future land uses. For exposure to occur, there must
be an actual or potential complete pathway for contamination to
move from the Site and ultimately enter a receptor's body.
Potentially complete exposure pathways are detailed in Tables 3
and 4 for current and hypothetical future land use, respectively.
From the list of chemicals of concern, exposure point
concentrations (EPC) were calculated. The EPCs were combined in
standard equations with toxicity and cancer potency data from EPA
data bases and standard or site-specific exposure assumptions to
calculate an estimate of the carcinogenic and non-carcinogenic
risks to individuals identified in the RME scenarios. Table 5
contains the risk characterization estimates.
The risk characterization indicates that estimated risks are
greatest under a future residential land use scenario that
includes direct contact with and ingestion of contaminated soils
and sediments, inhalation of particulate matter, ingestion of
contaminated ground water, and ingestion of fish contaminated
with PCBs from the Site. The ELCR under this RME scenario is
approximately 1 x 10-1, driven by ingestion of fish containing
PCBs. Given the nature of the sample used to estimate fish
tissue concentrations, this estimate appears to be a worst case
rather than reasonable maximum exposure. In addition, this
stretch of the Ohio River is under a fish consumption advisory
8
-------
due to ambient contamination from a variety of industrial sources
up- and down-river. Fishing advisories, while not enforceable,
may tend to minimize the amount of fish ingested by any given
individual. .
If fish ingestion is not considered, the ELCR is approximately 9
x 10.3 for a future resident living down wind of pond 5. A Hazard
Index greater than 1 occurs for future residential adults from
ingestion of drinking water, and for children based on drinking
water and soil contact.
Under a hypothetical future situation in which the facility is
operating but the existing barrier wells are no longer-pumped
(possibly due to changes in the manufacturing process), future
plant workers could experience an increased cancer risk of
1 x 10-3 and an HI > 1 from ingestion of drinking water in the
event the CAC Ranney well becomes contaminated. The contributing
chemicals in both future residential and industrial drinking
water scenarios are arsenic, beryllium, and tetrachloroethene.
The unacceptable risks under current exposure scenarios are an
ELCR of 1 x 10-1 and HI > 1 to a current resident who regularly
ingests fish (see above) and an ELCR of 2 x 104 to a hypothetical
trespasser who gains access to the Site, from the Ohio River and
is exposed to surface water and sediments in the backwater area
and along the river bank. PCBs and PAHs are the chemicals
contributing to the trespasser risk. The CMSD, CRDA, and the
sediments themselves are the sources of!i the PAHs and PCBs.
EPA believes it is valid to estimate risks under a variety of
present and future scenarios, including;1 future residential use,
at any site. By estimating the risk unher the highest form of
exposure, EPA can compare a remedy which eliminates that risk to
remedies that eliminate risk based on lpwer but perhaps more
likely exposure scenarios. EPA can thep make a more informed
risk management decision.
A significant area of controversy for this Site is the question
of whether future residential development of the Site is a likely
use, and therefore whether it is a reasonable scenario on which
to base a remedy selection. Historically, EPA has considered
future residential use to be a valid scenario because most
Superfund Sites are not active, operating industrial facilities.
Many Sites are closed, abandoned, and not maintained by the
owner, or no owners can be found, which increases the
possibilities for residential use.
Ormet, on the other hand, is an active manufacturing facility,
a rural area, next to another manufacturing facility (CAC).
There are no residences in the immediate area. Monroe County
Census figures indicate a 10% decrease in the population in the
in
9
-------
past 8 years. EPA believes it is reasonable to assume that the
current land use will continue for the forseeable future. This
will make residential development of the Site highly unlikely.
Therefore, the selected remedy is based on clean-up to standards
based on future commercial/industrial use of the property.
However, EPA believes it is also reasonable to assume that at
some time in the future the Ormet Ranney well may no longer be
used, in which case containment of the plume would be lost and
contamination allowed to reach the CAC drinking water well and
affect the drinking water supply for over 3000 workers.
Therefore, the remedy also focuses on restoration of the ground
water to drinking water quality.
Environmental Risks
An environmental evaluation performed at the Site concluded that
the contaminants of concern from an ecological standpoint are
known to produce sublethal and other toxic effects in the types
of organisms found on Site.
Two State endangered species occupy the Ohio River in the general
area of the Site. The Ohio lamDrev has been reported at
locations an unspeciifed distance downstream of the Hannibal lock
and dam. The channel darter may occur in the vicinity of the
lock and dam. However, the lock and dam may provide a barrier to
their movement upstream. In addition, a State special interest
species in the river is the qhost shiner, which occupies large
pools and protected backwaters.
Sediments from the southwestern CMSD seeps and the backwater
produced high mortality among bioassay organisms. Hvallela
azteca experienced 100 percent mortality, and growth of
Chironomous tentana was depressed.
area
Surface water in the backwater area and immediately downstream
exceeds the four-day average ambient water quality criteria
(AWQC) for antimony, lead, cyanide, and PCBs. Cyanide at two
locations exceeded the one-hour average criterion. This
demonstrates that Site contaminants in river water can
potentially cause lethal and sublethal effects in aquatic
organisms.
In addition, concentrations of contaminants in river sediments
were compared to reference sites (relatively clean) and sites
with a high instance of tumors in fish. Sediments on-site and
downstream of the Site exceed the lowest concentrations for PCBs
and PARs observed at the fish tumor Sites. Backwater area PAR
concentrations exceeded the highest levels reported from the fish
tumor Sites, indicating the backwater area is likely to pose
severe carcinogenic risk to fish entering from the Ohio River,
due to exposure to PCBs and PARs in sediments. As discussed
10
-------
above, the CMSD and the CRDA are the likely sources for PCBs and
PARs in the backwater area sediments and the river.
G.
RATIONALE FOR FURTHER ACTION
. Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementation of the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health or welfare, or the environment.
Therefore, based on the findings of the RI report and the
discussion above, a Feasibility Study (FS) was performed to
develop alternatives to address the threats at the Site.
The backwater area sediments pose a current threat to human
health and the environment, and will be addressed by the remedy.
The CRDA and CMSD, while not themselves posing unacceptable
risks, are sources of contamination to the sediments and as such
must be addressed by the remedy. The FSPSA and ground water
contamination must be addressed because the aquifer is a current
source of drinking water and under a future scenario where
Ormet's Ranney well should cease pumping, the CAC drinking water
well could be contaminated, thus exposing workers to unacceptable
levels of contamination.
Because the human health risk assessment identified risk from all
sources to hypothetical future residents, the former disposal
ponds (FDPs) were carried through the FS. As discussed in
Section F, above, and based on community input during the public
comment period; EPA believes future residential use to be an
unlikely scenario. Under none of the current use scenarios did
the FDPs contribute to any significant risk. Estimated risk
under future industrial use falls with the acceptable risk range.
While FDP-S appears'to be a source of elevated fluoride in ground
water, data from the last 20 years indicate a steady decrease in
fluoride levels down-gradient of FDP-S due to the pumping of the
interceptor wells and Ormet's Ranney well. It is reasonable to
believe this trend will continue. Site-wide ground water
compliance monitoring during remedial action will provide a basis
to determine whether the downward trend is continuing. Therefore
these areas will not require active remedial action, and will not
be considered further in this decision document. The
descriptions of alternatives in Section H below are modified from
the FS to eliminate remedial components and costs associated with
the FDPs.
H.
DESCRIPTION OF ALTERNATIVES
The Feasibility Study (FS) Report identified and evaluated
alternatives that could be used to address threats and/or
11
-------
potential threats posed by the Site. All of the alternatives
described in the following paragraphs, except for the No Action
Alternative, include the common element of Site-wide
institutional controls in the form of deed restrictions and a
common perimeter fence. In addition, capping components in
Alternatives 3 through 10 include provisions for flood protection
because part of the CMSD is located in the 100-year flood plain
ALTERNATIVE 1:
NO ACTION
CERCLA requires that a "No Action" alternative be considered as a
basis upon which to compare other alternatives. This remedy was
assembled by combining the no-action remedial measures- for each
of the areas and media under consideration in the FS Report. The
no-action response for ground water is considered to exclude
continued pumping of the Ormet Ranney well and interceptor wells,
which currently contain the plume in the alluvial aquifer beneath
the Ormet property. No operation and maintenance (0 & M)
activities are included to prevent further deterioration of
present Site conditions over the long-term. This alternative
would not comply with State or Federal health-based stand~rds and
would not adequately protect human health or the environment.
ALTERNATIVE 2 - ALTERNATIVE 10: These alternatives are composed
of different combinations of the remedial action components which
are listed in Table 6. The specific alternatives are shown in
Table 7.
In consideration of the ground water policy set forth in the NCP
{40 CFR 300.430 (a) (iii) (F)), the remediation goal for ground
water is to resore it to drinking water quality.
Alternatives 2 through 10 all include collection and treatment of
CMSD and ballfield seeps using collection trenches (SP-4). The
liquid would be routed to an oil-water separator first, then to
the ground water treatment system for treatment prior to
discharge to the river. These alternatives also include re-
routing of the 004 Outfall ditch through the CRDA to bypass the
backwater area and discharge directly to the river.
Alternatives 2-8 all include GW-3 component for ground water,
consisting of continuing to operate the existing pumping system,
with treatment of the barrier well water by Ferrous salt
precipitation and clarification to achieve NPDES discharge
standards, followed by discharge to the Ohio River.
The ground water component (GW-S) for Alternatives 9 and 10 calls
for new extraction wells to be installed closer to the source,
with the idea of collecting lower volumes of more highly
contaminated ground water. An added step of activated alumina
adsorption would be added to the ,treatment train. The Ormet
Ranney well would continue to pump in this alternative.
12
-------
'I :::~'" .
Based on data provided in the FS report (Appendix K), there
appears to be no significant difference in remediation time frames
between GW-3 and GW-5. Both are expected to achieve the goal
within 35 to 40 years, based on calculations provided in FS
Appendix K. The calculations, however, do not take into account
the increased restoration that may be realized by implementation
of soil flushing, as is called for in several alternatives as a
component of the FSPSA remedy.
Alternatives 2 through 5 are containment only alternatives,
except for the treatment of collected seep water and ground
water, followed by discharge to the river. Because no
treatment of source areas occurs, the volume of untreated waste
remaining in place is essentially the same as that reported in
the RI for the source areas:
FSPSA
---------------
CRDA
---------------
CMSD
---------------
sediments
---------------
no waste volume estimate:
contaminants are residual
cyanide, fluoride, and PAR
from previously removed
potliner.
5,700 CY carbon material
containing PARs, PCBs and
arsenic
240,000 CY fill material
containing cyanide, PCBs,
PARs.
2,000 CY containing PCBs, PAR,
cyanide
For Alternatives 3, 4, and 5 a portion of the waste would be
excavated and landfilled off-site. However, this still
represents a containment measure.
Alternative 2 achieves containment through the use of vegetated
soil covers for the source areas, except that the CRDA would be
consolidated under the cover for the CMSD, and river sediments
would be contained in place with sheet piling and concrete
revetments. (FSPSA-2, CMSD-3, CRDA 3, SED-6).
Cost: Capital
- $9,670,000
o & M - $1,300,000
Present Worth - $15,lPO,OOO
(includes first
on ground water
Annual cost
30 years at 10%
10 years 0 & M
Alternative 3 would consolidate all of the CRDA, and river
sediments at concentrations less than 50 mg/kg PCBs, within the
CMSD (concentrations greater than 50 would be disposed of off-
site). An estimated 1000 CY of sediments would be excavated and
solidified prior to diposal in the CMSD. Then all remaining
sources, including the CMSD, would receive single barrier
synthetic caps (basically a layer of 40 mil high-density
13
-------
polyethylene (HDPE) with a vegetated soil cover for protection.
(FSPSA-4, CMSD-4, CRDA-3, SED-8).
Cost: Capital - $12,150,000
o & M - $1,300,000
. Present Worth - $17,550,000
Annual cost
30 years at 10%
Alternative 4 is essentially the same as Alternative 3, except
that all the sediments would be excavated, and the source areas
would receive dual barrier caps consisting of 2 feet of .
engineered clay cover with the addition of a 40 mil HDPE layer.
This cover would comply with RCRA Subtitle C landfill closure
requirements. (FSPSA-3, CMSD-5, CRDA-3, SED-7).
Cost: Capital - $16,400,000
o & M - $1,300,00
Present Worth - $21,800,000
Annual cost
30 years at 10%
Alternative 5 is identical to Alternative 3 except approximately
4,000 yards of the more contaminated soil from the FSPSA would be
excavated and transported for off-site disposal. (FSPSA-9, CMSD-
4, CRDA-3, SED-8).
Cost: Capital - $14,150,000
o & M - $1,300,000
Present Worth - $19,550,000
Alternative 6 involves excavation of the entire CMSD and CRDA,
with on-site thermal oxidation and on-site disposal of the
residual ash under a single-barrier synthetic cap. The FSPSA
component would be the same as Alternative 5, and river sediments
would be fully excavated and consolidated on-site with the
CMSD/CRDA residuals. This would result in a volume of treated
waste of approximately 246,000 CY. (FSPSA-9, CMSD-7, CRDA-5,
SED-7. )
Cost: Capital - $109,700,000
o & M - $1,300,000
Present Worth - $115,100,000
Alternative 7 incorporates a treatment component for the source
of contamination to ground water. Under this alternative, the
FSPSA would be subjected to in-situ soil flushing, at the
conclusion of which it would receive a vegetated soil cover. The
CMSD and CRDA components would be the same as in Alternative 6.
The sediments would be excavated and treated by solvent
extraction, with the residuals consolidated under the CMSD cap.
This alternative would result in the highest degree of treatment,
with the total volume of treated waste on the order of 250,000
CY, including the un-estimated waste volume at the FSPSA.
(FSPSA-6, CMSD-7, CRDA-5, SED-9).
14
-------
Cost: Capital - $108,400,000
o & M - $1,300,000
Present Worth - $113,800,000
Alternative 8 calls for in-situ soil flushing at the FSPSA,
followed by a single-barrier synthetic cap. The CMSD, CRDA, and
river sediments would be dealt with the same as in Alternative 5.
(FSPSA-6, CMSD-4, CRDA-3, SED-8). .
Cost: Capital - $12,150,000
o & M - $1,300,000
Present Worth - $17,550,000
In Alternative 9, the CRDA and river sediments would be
completely ,excavated and the FSPSA would undergo partial
excavation. The river sediments would be solidified, and
material from all three areas taken to off-site disposal
facilites. The FSPSA residual materials would be contained under
a single-barrier synthetic cap. The CMSD would be excavated and
would undergo on-site thermal oxidation, with residuals contained
under a single-barrier synthetic cap. The GW-5 ground water
component would be implemented here. (FSPSA-9, CMSD-7, CRDA-4,
SED-10) .
Cost: Capital - $123,400,000
o & M - $3,000,000
Present Worth - $134,400,000
Alternative 10 involves only containment measures. The CRDA and
sediments would be excavated and consolidated in the CMSD after
the sediments were solidified. All remaining source areas would
receive single barrier clay caps that would comply with Ohio
solid waste closure requirements. (FSPSA-10, CMSD-8, CRDA-3,
SED-10) .
Cost: Capital - $34,100,000
o & M - $3,000,000
Present Worth - $44,100,000
1.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP sets out nine criteria against which Alternatives 1
through 10 were evaluated. The criteria are based on the remedy
selection requirements of CERCLA Section 121, and are described
in Table 8.
Because of the large number of components that were developed to
address many of the sources, it is more efficient to compare the
performance of the components of the alternatives against
criteria 2 through 7 (the balancing criteria). This will provide
15
-------
a clearer picture of the relative merits of the components.
a description of each component, refer to Table 6.
For
Threshold Criteria
1.
Overall Protection of Human Health and the Environment
All alternatives under consideration except for Alternative 1
(the No Action alternative) are protective of Human Health and
the Environment. Alternatives 2 through 10 would eliminate the
risks associated with drinking contaminated groundwater by
pumping the groundwater and treating it prior to discharge to the
Ohio River. In addition, Alternatives 2 through 10 would
eliminate the risk associated with the FSPSA, CMSD, CRDA, and
sediments through containment and/or treatment. Therefore,
potential impacts to human health or the environment will be
eliminated under these alternatives.
Alternative 1 would not provide or enhance protection of human
health or the environment because it does not contain or treat
contamination sources at the Site. Because Alternative 1 fails
to meet this threshold criterion, it will not be considered
further in this document.
2.
Compliance with ARARs
Below is an analysis of the ability of the components of each
alternative to achieve key ARARs. For a detailed breakdown of
all potential ARARs considered in the FS, please see Table 7-2 in
Attachment 3 to the Addendum in the FS report. For a General
discussion of the ARARs listed in this section, see Section K.
40 CFR 141 (the Safe Drinkinq Water Act (SDWA): SDWA Maximum
Contaminant Levels are relevant and appropriate to groundwater
remedial actions that are current and potential sources of
drinking water. Both GW-3 and GW-S, the two groundwater
remediation alternatives, will meet this ARAR.
OAC:374S-33-01 throuqh OAC:374S-33-10 (Clean Water Act, the
National Pollutant Discharqe Elimination System (NPDES): NPDES
requirements are applicable to direct discharges of pollutants to
surface waters. States must establish site specific discharge
limits and other requirements for discharges of toxic pollutants
based on application of "best available technology economically
achievable" (BAT). Both GW-3 and GW-S involve discharge of
treated groundwater to surface water. Both of these alternatives
will include treatment technology sufficient to meet these
requirements.
RCRA Subtitle C at 40 CFR 264.310 (OAC:374S-57-10): RCRA
Subtitle C Landfill Closure requirements apply to closure of RCRA
hazardous waste landfills. EPA has determined that these
16
-------
requirements are relevant and appropriate to remedial alternative
components involving capping in place of materials in the CMSD
because disposal of spent potliner had occurred in the CMSD, and
this material was subsequently listed as a RCRA hazardous waste.
CMSD-5 will meet these requirements. CMSD-3, CMSD-4 and CMSD-8
involve caps that do not meet these requirements, and can
therefore be eliminated from further consideration. EPA
determined that RCRA Subtitle C is relevant but not appropriate
to remedial alternative components involving capping in place of
materials in the FSPSA because the potliner was removed from the
FSPSA for processing in the cryolite recovery plant.
RCRA Subtitle D: RCRA Subtitle D Landfill Closure Requirements
(OAC: 3745-27-11(G)) regulate closure of areas containing solid
wastes. EPA has determined that these requirements are relevant
and appropriate to CMSD-7 (treatment residuals from excavation
and thermal oxidation of the CMSD would be landfilled on-site)
and remedial alternative components involving capping in place of
materials in the FSPSA. FSPSA-IO, employing a single barrier
clay cap, meets this requirement. FSPSA-4 and FSPSA-9, employing
a single-barrier FML cap, will meet this requirement if a
detnonstration of "equivalency" to the materials set forth in the
regulation can be made. EPA has determined that a single-barrier
FML cap can be designed to comply with OAC: 3745-27-11(g).
FSPSA-3, employing a dual barrier cap, would meet and exceed the
Subtitle D requirements. FSPSA-2, employing a soil cover, does
not meet this requirement. FSPSA-6 involves treatment of soils
by soil flushing to remove contaminants of concern for ground
water protection. However, soil flushing has not been
demonstrated to be effective at treating polynuclear aromatic
hydrocarbons (PAHs). Because PAHs are present in the FSPSA soils
above risk-based levels for direct contact, a final cover may be
needed after treatment goals are achieved in order to be
protective from direct contact. A solid waste cap pursuant to
OAC:3745-27-11(G) would accomplish this, and could be considered
relevant; however, a solid waste cap is intended to prevent not
only direct contact, but to prevent infiltration of precipitation
from leaching contaminants to ground water. Because soil
flushing will have already treated the soils for leachable
contaminants, the additional level of protection afforded by a
solid waste cap is not warranted, and would not be appropriate.
A vegetated soil cover will provide sufficient protection from
direct contact, and is more cost effective. This would represent
a combination of FSPSA-6 and FSPSA-2.
40 CFR Part 761 (Regulations under the Toxic Substance Control
Act, regulating disposal of Polychlorinated Biphenyls (PCBs)
greater than 50 ppm): These regulations are applicable to all
remedial alternative components that involve excavation of PCB-
contaminated soils with concentrations greater than 50 ppm. PCBs
were found in the CRDA soils and backwater area sediments, and in
the CMSD. CRDA-3 and CRDA-4 will comply with these regulations
17
-------
because the excavated soils with PCBs greater than 50 ppm will be
disposed in a TSCA-compliant landfill. Remedial components CRDA-
5 and CMSD-7, involving thermal oxidation would meet TSCA
requirements for destruction removal efficiency.
Balancing Criteria
3 .
Long-Term Effectiveness and Permanence
GW-3 and GW-5 would both provide long-term effectiveness and
permanence. In fact, GW-3 has been containing the groundwater
contamination plume for approximately 20 years and it has been
estimated that the plume will be remediated if the pumping
continues over .the next 30 to 40 years. GW-5, which calls for
replacing-the existing intercepter wells with wells located in
the center of the plume is expected to remediate the groundwater
within similar timeframes as those estimated for GW-3.
CRDA-3, CRDA-4, and CRDA-5 would all provide long-term
effectiveness; however, only CRDA-5 would provide for a permanent
solution through excavation, treatment .and off-site disposal.
Since all of these options require disposal in a landfill, long-
term maintenance of these landfills would be required.
SED-7, SED-9, SED-4, and SED-IO would all be effective over the
long-term; however, SED-9 would provide for a more permanent
solution by treating the contaminated sediments via solvent
extraction prio~ to consolidation under a cap. SED-6 would be
less effective in that this alternative allows for containment in
the backwater area, leaving the contained sediments vulnerable to
flood events. In addition, SED-6 would eliminate a benthic
habitat. SED-8 would not be effective in the long-term since
this alternative allows for PCB contaminated sediment to remain
in the backwater area above the cleanup level of 1 ppm.
CMSD-5 and CMSD~7 call for containment under either a dual and
single barrier cap, respectively, both of which would be
effective over the long-term given proper operation and
maintenance (0 &M). By its nature, a dual barrier cap provides
an added level of effectiveness by allowing less infiltration of
precipitation than a single barrier cap (all other components of
both caps being equal). All capping alternatives would require
such long-term maintenance to maintain their effectiveness.
FSPSA-9, FSPSA-4, FSPSA-3, FSPSA-10 all call for containment
under either a single or dual barrier cap which would be
effective over the long-term. FSPSA-6 includes a vegetative
cover which would not reduce infiltration through the fill, but
which would promote continued flushing of contaminants to ground
water for extraction and treatment. All alternatives would
require long-term maintenance. In addition, FSPSA-6 calls for
soil flushing which provides for permanent treatment of this
18
-------
.. ~"~~~I~~J-~
source by flushing out contaminants which could then be captured
by a groundwater pumping system.
4.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Both 9f the groundwater alternatives (GW-3 and GW-5) will reduce
the toxicity, mobility or volume (TMV) of contaminants through
treatment by pumping out contaminated groundwater and treating it
prior to discharge to the Ohio River.
CRDA-5 would reduce TMV through off-site thermal treatment with
off-site disposal of the residual ash. CRDA-3 and CRDA-4 are
purely containment alternatives, which will reduce mobility but
not through treatment.
SED-9 would reduce TMV through treatment; however, treatment will
result in an additional waste stream which would require further
treatment prior to disposal. SED-7, SED-4, and SED-I0 would
reduce mobility of contaminants through solidification prior to
disposal under the CMSD cap. Solidification is necessary due to
the high water content of the sediments. However, there will be
a total volume increase due to the addition of the solidification
agents. SED-6 and SED-8 would not reduce TMV through treatment.
CMSD-7 would reduce TMV through treatment by thermal oxidation.
CMSD-5 would not reduce TMV through treatment; however, capping
will reduce the mobility of contaminants by placing an
impermeable barrier over the waste.
FSPSA-9, FSPSA-4, FSPSA-3, and FSPSA-I0 would not reduce TMV
through treatment. Although FSPSA-9 calls for partial excavation
of the FSPSA, this alternative simply transfers this material to
an off-site disposal facility, therefore there would be no net
volume reduction to the environment. FSPSA-6 would increase
mobility of contaminants to the groundwater through soil
flushing; however, the groundwater pumping system would capture
the contaminants and treat the groundwater prior to discharge to
the Ohio River.
5.
Short-Ter.m Effectiveness
Both GW-3 and GW-5 are estimated to achieve cleanup levels in
approximately 35 to 40 years. Currently the intercepter wells
and Ranney well called for in GW-3 are containing the
contaminated groundwater. GW-5 calls for relocating the
intercepter wells from the edge of the plume to the center of the
plume, closer to the FSPSA. Relocating the current intercepter
wells would not be effective in the short-term because it would
not capture contaminated groundwater located between the FSPSA
and the Ranney well. .
19
-------
CRDA-3 and CRDA-5would be equally effective in the short-term.
CRDA-4 may pose some short-term exposures since the material
would need to be transported off-site for disposal.
All of the sediment alternatives (SED-4, 7, 6, 8, 9, and 10)
would present short-term impacts to the benthic habitat in the
backwater area'during dredging arid/or containment. However,
since this area'is connected to the Ohio River, resedimentation
is expected to occur rapidly, except for SED-6 which would
eliminate the backwater area. SED-6 eliminates the backwater
area by cutting this area off from the Ohio River and capping the
sediments in place. SED-8 would allow PCBs above the cleanup
level (1 ppm) to remain in the backwater area.
CMSD-5 would provide more short-term effectiveness through
capping than CMSD-7, which calls for excavation of the CMSD prior
to treatment and capping. Excavation of the CMSD could cause
fugitive dust emissions which would require engineering controls
during implementation.
FSPSA-4, FSPSA-3, and FSPSA-10 would provide more short-term
effectiveness through capping than'FSPSA-9, which calls for
excavation of the FSPSA prior to treatment and capping.
Excavation of this area could cause fugitive dust emissions which
would require engineering controls during implementation. FSPSA-
6, which calls for soil flushing is expected to take ten years to
reduce the contaminant concentrations prior to capping.
6.
Implementability
GW-3 has been operating for approximately 20 years and is
successfully containing the groundwater plume on-site. GW-5
would be implementable, but less so than GW-3 since GW-3 is
already in existence and GW-5 would require the placement of
additional wells. In addition, there are concerns that the
treatment plant under GW-3, which was recently constructed, may
not be able to handle the higher concentration of contaminated
groundwater which would be produced by placing new wells closer
to the FSPSA (GW-5). However, the new well locations under GW-5
could be accommodated with an additional treatment component
added to the treatment system.
CRDA-3, CRDA-4, and CRDA-5 are readily implementable. Given the
relatively small volume of material, off-site landfill capacity
should not pose a problem for CRDA-4.
All of the sediment alternatives will require at least temporary
isolation of the backwater area from the Ohio River which can be
achieved by placing sheet piling along the entrance to the river.
All of the sediment alternatives appear to be readily
implementable; however, SED-9 may require a treatability study
prior to solvent extraction treatment. Given the relatively
20
-------
small volume of material, off-site landfill capacity should not
pose a problem for SED-4.
CMSD-S would be readily implementable. CMSD-7 would be
implementable; however, given its proximity to the Ohio River,
excavation and treatment of such a large volume of material may
. pose some construction problems.
FSPSA-3, FSPSA-4, FSPSA-6, and FSPSA-I0 are expected to be
readily implementable. FSPSA-9 implementability would be
dependent on the availability of off-site landfill space for
disposal of the excavated material. A treatability study would
be needed prior to implementation of FSPSA-6.
7.
Cost
The currently operating groundwater system (GW-3) is
cost $1.8 million, whereas GW-S is estimated to cost
million. In addition, the O&M costs are expected to
for GW-S than for GW-3.
estimated to
$3.3
be higher
CRDA-3 would cost $100,000 for excavation and consolidation with
the CMSD. The costs increase by an order of magnitude to $1.6
million under both CRDA-4 and CRDA-S when this small volume of
material is excavated and treated/disposed off-site.
The least expensive sediment alternatives are SED-6 and SED-8
which are estimated to cost $228,000 and $224,000, respectively.
Both of these alternatives contain at least a portion of
contamination in-situ and do not provide any form of treatment.
SED-7 is the most cost effective at $270,000 by removing the
material and solidifying prior to placement under the CMSD cap.
SED-4 is the least cost-effective in that it provides the same
level of treatment as SED-7 but is estimated to cost $1.3
million. SED-9 provides a higher level of treatment than SED-7
but still requires containment under the CMSD cap. SED-9 is
estimated to cost $1 million. SED-I0 is estimated to cost
$400,000 for excavation, solidification and consolidation under
the CMSD cap. The additional cost for SED-I0 compared to SED-7
is the result of excavating river sediments. Given the highly
industrialized use of the Ohio River in this area, a fishing
advisory has been in place for the Ohio River between East
Liverpool, Ohio and the Greenup Locks and Dam near Portsmouth,
Ohio. EPA believes that by addressing the backwater area.
sediments, the source of contamination from the Ormet Site, the
Ohio River will be protected from contamination from the Ormet
Site. Therefore, remediation of the Ohio River sediments is not
considered necessary.
CMSD-7 is the least cost-effective alternative in that it is
estimated to cost $68 million and will still require some
21
-------
containment after treatment.
at $1.8 million.
CMSD-5 is much more cost-effective
The least expensive containment alternatives for the FSPSA are
FSPSA-4 and FSPSA-10 which are estimated to cost $1.4 million for
a single barrier cap. FSPSA-9 is the most expensive alternative
at an estimated cost of $2.6 million for partial excavation and
both off-site disposal and an on-site single barrier cap. FSPSA-
3 has an estimated cost of $1.8 million. FSPSA-6 is the most
effective of the FSPSA alternatives because it provides for
treatment of the Site's principal threat via soil flushing at an
estimated cost of $520,000 {consisting of $420,000 for 10 years
of flushing and $100,000 for containment after year 10~. At the
time the FS was prepared, soil clean-up standards had not been
determined {see Section J below}. Should soil flushing need to
extend beyond year 10 to achieve soil clean-up standards, the
costs will increase by about $4,000 per year, which is the
estimated annual 0 & Mcost. .
Modifying Criteria
8.
State/Support Agency Acceptance
The State of Ohio did not concur with the proposed plan because
it felt the plan was not stringent enough. Given the revised
risk management scenario and associated no-action component at
the former disposal ponds, the State does not concur with the
selected remedy either.
9.
Community Acceptance
EPA proposed a remedy for public comment based on future
residential use at the Site. Substantial community response
indicated support for a remedy that does not assume future
residential use, commenting that based on current demographics
and the economic situation of the area, the possibility of future
residential occupancy of the Site is remote. Because EPA has
modified the remedy to address the concerns of the community to
the extent practicable, EPA expects that the community will
support the remedy.
J.
THE SELECTED REMEDY
The combinations of remedial components that form the
alternatives analyzed in the FS were developed to address risk
based on future residential use of the Site. EPA has made a risk
management decision to focus the remedy on the more likely
situation that the Site use will remain the same as it currently
stands or, at most, industrial development will occur.
Accordingly, EPA has developed the selected remedy from the
following combination of remedial components:
22
-------
Institutional Controls
Institutional controls shall be implemented for the Site. These
controls shall be in the form of access restrictions and deed
restrictions. Access restrictions shall include installation of
a chain-link fence a minimum 6 feet high topped with three
strands of barbed wire. The fence shall, at a minimum, fully
encompass all source and/or disposal areas including the former
disposal ponds, and shall be kept locked at all times. Regular
inspections shall be performed to ensure the integrity of the
fence is maintained.
EPA shall provide language in a consent decree or enforcement
order issued to Ormet setting restrictions against installation
of drinking water wells and against construction for any
residential purposes. These restrictions shall be recorded with
the deed for the Ormetproperty in the manner customary for such
recordings in the jurisdiction within which the property lies.
The restrictions shall be recorded no later than the start of
remedial action.
Ground Water
GW-3: Ground water shall be extracted using the existing.
system of two barrier wells for contaminant capture, supplemented
by the high-capacity Ormet Ranney well to ensure plume
containment. The water from the extraction wells shall be
treated by a system that will allow the quality of the effluent
to meet standards set by the State's NPDES program and
incorporated into a permit issued to Ormet by the State.
The system shall maintain a capture zone so as to prevent Site
contaminants from migrating in the subsurface to the Ohio River.
Water quality shall be monitored three times per year starting no
later than 4 months after remedial action is completed. Changes
in the frequency of groundwater monitoring may be considered
based on information collected during operation of the extraction
system over the course of the remedy.EPA shall select the
specific monitoring locations during the remedial design. These
locations may include, but are not limited to, existing
monitoring wells.
Parameters to be monitored shall be determined during remedial
design, and shall include, put are not limited to, analysis for
volatile organic compounds, metals, and cyanide. The GW-3
component shall be operated until the ground water throughout the
plume has achieved the clean-up standards for 3 consecutive
years, as demonstrated through sampling at the specific
monitoring locations. The clean-up standards for contaminants of
concern for ground water are listed in Table 2. It should be
noted that the standard set for-manganese is an interim standard,
based on background established in the BRA. A statistical
23
-------
determination of background for manganese may be performed during
remedial design, based on data from wells not affected by the.
contaminant plume identified in the RI report. EPA may then
determine a final clean-up standard for manganese.
CMSD ~eeps
SP-4: CMSD seeps shall be remediated by installation of
gravel-filled collection trenches, wherein seep water shall flow
to a sump and be pumped from the sump to an oil/water separator.
If the effluent from the oil/water separator meets NPDES
standards in the NPDES permit, it may be routed to the Ohio
River. Otherwise, the effluent shall be routed to a carbon
adsorption treatment system to remove PCBs and any other organic
contaminants. The existing ground water treatment plant alone
will not be able to treat the seep water effectively because of
the presence in the seep water of PCBs. If metals or cyanide
removal is also necessary to meet NPDES standards, treatment for
such contaminants shall also be performed prior to discharge to
the Ohio River. Spent carbon from the carbon filters shall be
considered a hazardous waste. If it is regenerated for re-use
the treatment shall be done at a RCRA Subpart X-licensed
facility. If not regenerated it shall be disposed of at a RCRA
Subtitle C disposal facility.
Soils excavated to install the CMSD seep trenches shall be
temporarily stored and analyzed for PCBs. Should the soils
exceed 50 ppm total PCBs they shall be disposed of off-site at an
EPA-approved TSCA facility. Soils of less than 50 ppm shall be
solidified along with the backwater sediments and consolidated
under the CMSD cap.
PCBs were found in the seeps during the RI, but no soil sampling
was performed adjacent to the seeps. This area is a potential
source area of PCBs to the backwater sediments. Therefore,
during design a limited soil sampling program for PCBs shall be
performed on the area between the western slope of the CMSD and
the 004 outfall stream. If PCBs are found in the soil in excess
of 1 mg/kg (the sediment clean-up standard) they shall be treated
in the same manner as the soils excavated to install the trench
drains.
Former Spent Pot1iner Storage Area
FSPSA-6, in contingent combination of FSPSA-2: Surface and
subsurface contamination in the FSPSA shall be treated by in-situ
soil flushing. Water, or another appropriate flushing fluid,
shall be sprayed or infiltrated through the soils. Contaminants
will be flushed to ground water for ultimate capture and
treatment under GW-3.
24
-------
Unlike applying MCLs to ground water clean-up, there are no
promulgated clean-up standards that can be applied .to soil,
especially with respect to potential impacts of soil to ground
water. EPA has instead accepted the use of computer-aided
numerical models and other methods that take site specific data
on soil conditions and generate contaminant concentrations for
soil that are protective of ground water (EPA!S40!2-89!OS7,
Determininq Soil Response Action Levels Based on Potential
Contaminant Miqration to Ground Water: A Compendium of Examples) .
During the design phase of the remedy, a soil model acceptable to
EPA, such as SESOIL, shall be utilized to develop site-specific
soil clean-up standards for the ground water contaminants of
concern listed in Table 2. Once the clean-up standards are
accepted by EPA they shall' 'be incorporated into this ROD.'Aily
data needed for input to the soil model that were not collected
during the RI shall be acquired during design.
Treatment of the FSPSA soils may cease when soil clean-up
standards are achieved, as demonstrated by sampling and analysis
of soils in the FSPSA for the contaminants listed in Table 2, and
when all compliance points for ground water in and immediately
down-gradient of the FSPSA achieve ground water cleanup levels
for three consecutive monitoring events. The compliance
monitoring program shall continue in all monitoring locations
while residual ground water contamination (that which has
migrated out of the immediate area of the FSPSA) continues to be
extracted and treated.
When treatment ceases, a representative number of soil samples
shall be analyzed for carcinogenic polynuclear aromatic
hydrocarbons (CPAHs). The results shall be used to calculate
residual risk levels based on direct contact under a construction
worker, maintenance worker, and plant worker industrial exposure
scenario. If residual risk exceeds an ELCR of l x l04, a
vegetated cover shall be installed to prevent direct contact.
construction Materials Scrap Dump
CMSD-S: The CMSD shall be re-contoured to remove as much waste
as possible from below the lOO-year flood level. Although RCRA
Subtitle C does not require a dual-barrier cap a priori, a dual
barrier cap shall be installed over the CMSD to ensure maximum
protection from the effects of inundation in the event of a lOO-
year flood. At a minimum, the cap shall include the following
components:
.
A vegetated soil layer of sufficient thickness that the clay
layer is below the local frost line;
Six-inch sand drainage layer, or synthetic equivalent;
40 mil high-density polyethylene flexible membrane liner;
.
.
25
-------
.
.
.
Two-foot thick engineered clay layer;
Soil necessary to achieve slope requirements;
Controls that will prevent erosion in the event of a
year flood, such as rip-rap or concrete revetments.
100-
Figure 3 shows a schematic drawing of the capping components,
except for the erosion controls. .cThe cap shall shall meet all
substantive requirements of RCRA Subtitle C for a hazardous waste
landfill closure, including requirements for post-closure care.
The conduit located to the north of the CMSD which discharges
directly to the Ohio River shall be removed.
Carbon Run-off and Deposition Area
CRDA-3: The CRDA shall be excavated down to native soil and the
materials consolidated within the CMSD prior to installation of
the CMSD cap. Excavation shall continue until the remaining
soils in the CRDA meet the sediment clean-up standards (as
determined through verification sampling), to ensure no further
contamination of the backwater area occurs. The 004 outfall
stream shall be re-routed through the CRDA, or other appropriate
area of the property, to bypass the backwater area and discharge
directly to the Ohio River. The CRDA shall be re-vegetated to
prevent excessive sediment loading to the backwater area and the
river, and controls shall be put in place to prevent continued
run-off from the plant area to the CRDA.
Composite samples of the excavated soils shall be analyzed for
PCBs. Soils in any container whose composite sample result
exceeds 50 ppm" shall be disposed of off-site in an EPA-approved
TSCA disposal facility. Soils below 50 ppm shall then be
consolidated with the CMSD prior to installation of the CMSD cap.
Backwater Area Sediments
SED-7: The backwater area shall be temporarily isolated from
the Ohio River by sheet piling or another appropriate method.
Sediments in the backwater area shall then be excavated and
temporarily bulk-stored. Clean-up standards for sediments are as
follows:
Total Carcinogenic PAHs
Total PCBs
60.0 ppm
1.0 ppm
Because there are no promulgated standards for sediment quality,
the PAH cleanup standard was set based on calculation of risk-
based levels assuming a trespassing scenario, as set out in the
Baseline Risk Assessment (BRA) (see Attachment 1 of the Addendum
to the FS). The value was compared to values calculated from EPA
guidance on Sediment Quality Criteria (U.S. EPA, 1988, Interim
Sediment Criteria Values for Non-Polar Hydrophobic Organic
Contaminants). The human health values were lower than the
26
-------
sediment criteria. Therefore, to protect both human health and
the environment, the clean-up standard above was chosen.
The clean-up standard for PCBs is based also on the calculated
value from the sediment quality guidance. This standard is
consistent with levels for human exposure under a residential
scenario, as set out in Oswer Directive 9355.4-01 FS A Guide to
Remedial Actions at Superfund Sites With PCB Contamination,
August 1990. Although residential exposure is not considered
likely at the Ormet Site, this clean-up standard will be
protective of human health and the environment.
Achievement of the sediment cleanup standards in the backwater
area shall be verified by sampling as excavation proceeds.
Dredging will be considered complete when sampling over the full
area of the backwater indicates compliance with the standards.
A fact that must be considered is that dredging is an inexact
technology, and cannot be expected to remove all sediment above
the standards, although that is the intent of the remedy. In
addition, during dredging a certain amount of re-suspension of
sediment can be expected which, when it settles out, will
probably contain PCBs greater than the risk-based concentration.
EPA expects a dredging method to be used that will minimize
resuspension and remove as much sediment as possible. However,
within the limits of the technology the PCB standard may not be
achieved through dredging alone. An additional consideration in
selecting the dredging method is the need to minimize air
emissions of PCBs.
Once dredging is completed and the temporary barrier is removed,
re-sedimentation will commence as "clean" river sediments are
carried into and deposited over the bottom of the backwater area.
Once sufficient sediment thickness has accumulated, any remaining
PCBs (and PARs as well) will be effectively covered and further
contact minimized.
Composite samples of the excavated sediments shall be analyzed
for PCBs. Sediments in any container whose composite sample
result exceeds 50 ppm shall be disposed of off-site in an EPA-
approved TSCA disposal facility. Sediments between 1 ppm and 50
ppm shall undergo solidification, then be consolidated with the
CMSD prior to installation of the CMSD cap. Because of the
potential for reaction of some solidification agents with water
(e.g., lime and water create an exothermic reaction),
treatability studies and best engineering judgement shall be used
to determine the most appropriate method of solidification, in
order to reduce air emissions as much as is practicable.
27
-------
Points of Compliance
For ground water, the point of compliance with the cleanup levels
shall be everywhere within the plume, including the area under
the FSPSA, because the remediation goal for ground water is
restoration to drinking water quality. EPA shall select specific
locations to serve as points of compliance during remedial
design. These locations may include existing monitoring wells,
but additional wells may also be required by EPA.
The area to be monitored for ground water compliance shall also
include locations downgradient of FDP-5. FDP-5 is currently
within the plume area, and is contributing to ground w~ter
contamination, though not to the extent of the FSPSA (see Section
E, Nature and Extent of Contamination). EPA believes that
natural flushing will continue to reduce FDP-5's contribution to
ground water contamination in a timeframe commensurate with the
time needed for flushing at the FSPSA. The five-year reviews
required under CERCLA will provide adequate intervals to evaluate
the ground water situation with respect to FDP-5.
Once excavation and disposal of the CRDA and backwater area soils
and sediments is completed and the outfall stream re-routed,
verification sampling in the backwater area shall establish a
baseline for continued monitoring, to ensure that any waste
remaining on Site does not provide a continued source of
contamination to the river. The point of compliance for
determining that the remaining wastes are not mobile to surface
water and river sediments shall be the boundary of the backwater
area, as delineated by the location of the temporary barrier that
will be installed prior to excavation of the sediments. The
media to be sampled shall be surface water and sediments.
Residual Risk
Once the remedy is fully implemented, as demonstrated through
achievement of the clean-up standards; the carcinogenic risk
under a current land use and future worker use of drinking water
is expected to still exceed the risk range of 1 x 10~ ELCR, with
HI >1 for fluoride. The reason the preferred risk level of 1 x 10
~ will not be achieved is that the contaminant concentrations at
the lower risk level are not measurable. The analytical
detection limit is 1.5 ug/l for both arsenic and beryllium. The
residual risk exceeds the upper limit of EPA's acceptable risk
range of 1 x 10~ to 1 x 10~ due to the presence of arsenic and
beryllium. The clean-up standard for arsenic has been set at the
analytical quantitation limit because that standard is the lowest
quantitative measure that can practicably be achieved and is
consistent with background concentrations for arsenic in ground
water established in the risk assessment. It is not practicable
to establish clean-up levels below naturally occurring
28
-------
background, even if this results in exceeding the risk range.
All other ground water clean-up standards are based on the MCLs,
per OSWER directive 9355.0-30, and the NCP.
Implementation of this remedy will not restore the Site to
residual risk levels consistent with residential use, which EPA
considers to be unlikely. Should such use occur, however, the
remedy may no longer be protective, and further remediation may
be warranted. Any change in land use will be considered under
the 5-year reviews as well as during implementation of the
remedy.
Cost of the Remedy
Capital:
o and M:
Present:
Worth
$12,000,000
$1,300,000 annual
$17,400,000
K.
STATUTORY DETERMINATIONS
U.S. EPA's primary responsibility at Superfund sites is to
undertake remedial actions that protect human health and the
environment. Section 121 of CERCLA, as amended by SARA, has
established several other statutory requirements and preferences.
These include the requirement that the selected remedy, when
completed, must comply with all applicable, and relevant and
appropriate requirements (ARARs) imposed by Federal and State
environmental laws, unless a waiver of the ARAR is justified.
The selected remedy must also provide overall effectiveness
appropriate to its costs, and use permanent solutions and
alternative treatment technologies, or resource recovery
technologies, to the maximum extent practicable. Finally, the
statute establishes a preference for remedies which employ
treatment that significantly reduces the toxicity, mobility or
volume of contaminants.
The selected remedy for the O~et Site will satisfy the statutory
requirements established in Section 121 of CERCLA, as amended by
SARA, to protect human health and the environment, to comply with
ARARs, to provide overall effectiveness appropriate to its costs,
and to use permanent solutions and alternate treatment
technologies to the maximum extent practicable. Treatment is not
part of the CMSD, CRDA, or seeps components of the remedy because
an attempt to treat the hazardous substances present in these
areas prior to consolidating the CRDA and seeps into the CMSD and
then capping the CMSD would not provide a sufficiently
significant additional decrease in risk presented by these areas
to justify the increased cost of attempting such treatment.
29
-------
1.
Protection of Human Health and the Environment
Implementation of the selected remedy will protect human health
and the environment by reducing the risk of exposure to hazardous
substances present in surface soils, seeps, sediments, and ground
water at the Site. Excavation of the contaminated sediments and
placement of them into an approved Toxic Substances Control Act
(TSCA) -compliant facility (if over 50 ppm PCBs) or
solidification and placement in the CMSD (if less than 50 ppm
PCBs) will remove the direct contact threat to humans and the
ecological risk to fish and other organisms in the backwater
area. Excavation of the CDRA and seeps and placement into the
CMSD will remove the threat of continued migration of hazardous
substances from these areas into the backwater area.
Installation of trench drains and collection of seep water will
prevent contaminants from migrating from the CMSD to the
backwater area. A RCRA Subtitle C-compliant for the CMSD will
reduce the risk of exposure to hazardous substances present in
soil, seeps and sediment at the Site, and will also reduce the
rate of infiltration by which precipitation passes through the
contaminated soil and maintain that reduction over time. By
reducing the rate of infiltration, the final cover will also
reduce the rate of leachate generation in the CMSD; therefore,
the final cover will also reduce the risk that hazardous
substances, pollutants, and contaminants present in the CMSD will
migrate into the backwater area and contaminate the clean
sediments. Soil flushing the FSPSA will increase the rate at
which hazardous substances leach into the ground water and will,
therefore, reduce the length of time needed to clean up the FSPSA
as a source of contamination to ground water. Extracting and
treating the ground water will reduce the ingestion-related risk
to future workers and will restore the aquifer to its most
beneficial use. Institutional controls will be imposed to
restrict uses of the Site to prevent exposure to hazardous
substances and contaminants in the soils and ground water at the
Site. No unacceptable short-term risks will be caused by
implementation of the remedy.
2.
Attainment of Applicable or Relevant and Appropriate
Requirements
Section 121(d) of CERCLA requires that remedial actions meet
legally applicable or relevant and appropriate requirements
(ARARs) of other environmental laws. Legally "applicable"
requirements are those cleanup standards, standards of control,
and other substantive environmental protection requirements,
criteria or limitations promulgated under Federal or State law
that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstances at
a CERCLA site. "Relevant and appropriate" requirements are those
requirements that, while not legally applicable to the remedial
action, address problems or situations sufficiently similar to
30
-------
~,tj "'t t "" "'l$f '>'¥f. fA- -If-
those encountered at the site that their use is well suited to
the remedial action.
Non-promulgated advisories or guidance documents issued by
Federal or State governments ("to-be-considered or TBCs") do not
have the status of ARARs; however, where no applicable or
. relevant and appropriate requirements exist, or for some reason
may not be sufficiently protective, non-promulgated advisories or
guidance documents may be considered in determining the necessary
level of clean-up for protection of human health and the
environment.
Below is a discussion of the key ARARs for the selected remedy.
For a complete list of potential ARARs and TBCs for the that were
evaluated for the alternatives considered at this Site, see
Attachment 3 to the Addendum in the FS Report. Table 9 lists
ARARs for the selected remedy. To the extent that a regulation
referenced by a listed ARAR is inconsistent with the requirements
of the ROD, the ROD requirements shall prevail. .
Action-sDecific ARARs
Toxic Substances Control Act
Regulations promulgated pursuant to the Toxic Substances Control
Act regulate the disposal of PCBs in concentrations of 50 ppm or
greater. PCBs were found in five media at the Site: in sediments
and surface water in the Outfall 004 backwater area; in fill
material at the CMSD; in the CMSD seep water; and in a composite
soil sample taken at the CRDA. Because these soils and sediments
will be excavated and disposed of, TSCA is applicable and
disposal must be in accordance with TSCA requirements. PCB-
contaminated soils and sediments with concentrations of 50 ppm or
greater will be disposed of in compliance with TSCA and 40 CFR
761.60. PCB-contaminated soils and sediments with concentrations
less than 50 ppm are not subject to TSCA disposal requirements
and may be consolidated in the CMSD.
Resource Conservation and Recovery Act
Subtitle C and D Closure Reauirements
Resource Conservation and Recovery Act (RCRA) , closure
requirements govern the closure/capping of hazardous waste
(Subtitle C) and solid waste (Subtitle D) disposal areas. Spent
potliner was deposited in the FSPSA and the CMSD. Spent potliner
from primary aluminum reduction is a listed hazardous waste
(KOSS) under RCRA Subtitle C, at 40 CFR 261.32. Because these
materials were deposited prior to 1980, the effective date of
RCRA, RCRA Subtitle C requirements are not applicable.
31
-------
Cyanide is the hazardous constituent for which spent potliner is
listed (40 CFR Part 261, App. VII). Because cyanide is present
in the spent potliner at the CMSD, and this material is to be
capped in place without treatment, the RCRA Subtitle C closure
requirements are both relevant and appropriate for the CMSD.
Ohio's hazardous waste program is authorized pursuant to Subtitle
C; thus the RCRA subtitle C closure requirements for hazardous
waste landfills in Ohio is OAC:3745-57-10. Spent potliner was
disposed of there, and seeps containing cyanide emanate from the
western boundary of the CMSD toward the backwater area and the
river. These seeps indicate that the cyanide is mobile within
the CMSD. The selected remedy will meet this ARAR.
The soils in the FSPSA will be treated in situ by soil flushing.
The cyanide will be removed from the soil in the soil flushing
process. However, as discussed in Section F above, CPAHs in
surface soil may present an unacceptable risk from direct contact
and soil flushing is not expected to be effective for CPAHs.
Should a residual risk remain after treatment that exceeds a I x
10-4 risk (industrial use), capping of the FSPSA or other
remedial measures may be required to prevent direct contact.
Should capping be required, RCRA subtitle C or D closure
requirements would be relevant but not appropriate for the
reasons discussed in Section I above.
Chemical-specific ARARS
Federal Drinking Water Standards at 40 CFR Part 141 promulgated
under the Safe Drinking Water Act (SDWA) include both Maximum
Contaminant Levels (MCLs) and, to a certain extent, non-zero
Maximum Contaminant Level Goals (MCLGs), that are applicable to
municipal drinking water supplies servicing 25 or more people.
The National Contingency Plan ("NCP") at 40 CFR
300.430{e) (2) (i) (B) provides that MCLs and non-zero MCLGs
established under the SDWA shall be attained by remedial actions
for ground waters that are current or potential sources of
drinking water.
At the Ormet Site, MCLs and non-zero MCLGs are not applicable,
but are relevant and appropriate, because the aquifer below the
Site is a used as a source of potable water. The selected remedy
shall meet MCLs and non-zero MCLGs at the Site.
The NCP provides that ground water clean-up standards should
generally be attained throughout the contaminant plume or at and
beyond the edge of the waste management area when waste is left
in place. The point of compliance for the federal drinking water
standards will be throughout the plume.
Section 402 of the Clean Water Act establishes the National
Pollutant Discharge Elimination System ("NPDES") program. This
program has been delegated to the State of Ohio and Ohio has set
32
-------
.. '1,.," ,M"', 'f"""" 'j" <0' ~r
forth its NPDES regulations at OAC:3745-33-0l through OAC:3745-
33-10. Discharge of the treated ground water will meet these
ARARs .
Location-specific ARARs
A small portion of the Ormet Site is located in the lOO-year
flood plain of the Ohio River. Floodplain protection is an
environmental area of substantial concern, especially in light of
the damage caused by the Mississippi River floods in 1993. U.S.
EPA is committed to ensuring that all actions it takes within
floodplains proceed with adequate protection against such
catastrophic events. Controls to safeguard human h~alth and the
environment in the event of flooding must be part of any
containment design considered at Ormet.
A potential location-specific ARAR that was evaluated during the
RIfFS, and mentioned in the Proposed Plan, was OAC:3745-54-l8 B,
which requires a hazardous waste facility located in a floodplain
{in this case, a portion of the Construction Materials Scrap Dump
(CMSD)) to be designed, constructed, operated, and maintained so
as to prevent washout of hazardous materials in a 100-year flood
event.
OAC:3745-54-l8 B is applicable to the active portion of a
facility. Since there will be no active portion at Ormet because
the selected remedy requires closure of the CMSD under RCRA
SubtitleC, this regulation is not applicable to Ormet.
Nevertheless, floodplain protection is assured because Subtitle C
closure and post-closure care regulations at OAC:3745-57-l0 are
relevant and appropriate and EPA has determined OAC:3745-57-l0
provides a standard of floodplain protection equivalent to
OAC:3745-54-l8 B. OAC:3745-57-l0 requires the final cover to be
designed and constructed in a manner to minimize infiltration
through the closed landfill and erosion or abrasion of the cover.
Because a portion of the CMSD is located within a IOO-year
floodplain, design and construction of the final cover pursuant
to OAC 3745-57-10 must include measures sufficient to meet the
above requirements, and prevent transport of hazardous materials
away from the landfill, during a 100-year flood.
The selected remedy is a Subtitle C cap with a dual-barrier
system combined with erosion controls appropriate to maintain the
integrity of the containment system for the site's location in a
floodplain. The cap will effectively prevent infiltration of
floodwaters or precipitation, which could leach hazardous waste. .
Erosion controls will prevent scouring of the cap and transport
of waste directly to surface water.
Alternatively, OAC:3745-54-lB B might be considered relevant and
appropriate; however, as it is simply equivalent to what is
required by the closure regulation. it has not been specifically
33
-------
listed as a relevant and appropriate requirement. To the extent
that OAC:374S-S4-18 B is relevant and appropriate to a remedial
action involving capping of the CMSD, EPA has determined that the
selected remedy would meet any requirements of that regulation
for protection from washout.
3.
Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative
in proportion to its cost to achieve environmental benefits. For
ground water, GW-3 is the most effective component because it
provides the same degree of protection as does GW-S at a cost
which is lower than costs for GW-S. For the CRDA, CRDA-3 is the
most cost-effective component because it involves such a small
volume of material that treatment and off-sit'e disposal of it
would not provide an increment of protection sufficiently greater
than that provided by excavation and containment (CRDA-3) as to
warrant the additional costs. For sediments, SED-7 is the most
cost-effective component because it will remove the risks in the
backwater area at the most reasonable cost through excavation and
solidification, followed by containment in the CMSD. The less
expensive remedial components for sediment would leave some of
the contaminated backwater area sediments in-place. The more
expensive components would provide additional treatment, but
would still be followed by containment in the CMSD. The
treatment would not provide sufficient additional environmental
benefit as to warrant the additional costs. For the CMSD, CMSD-S
is the most cost-effective component. The estimated cost of
CMSD-S is $1.8 million, as compared to $68 million for CMSD-7,
In addition, treatment residuals from CMSD-7 would still have to
be contained on site, with associated cap maintenance costs.
Because CMSD-S removes all pathways for contaminant migration at
a significantly lower cost than CMSD-7, the cost of CMSD-7 is not
proportional to the environmental benefits that may be achieved.
Finally, for the FSPSA, FSPSA-6 is the most cost-effective
component because it provides effective treatment of the Site's
principal threat at the lowest cost of all remedial components
except no action.
The selected remedy for this Site, consisting of all of these
components, is cost-effective because it provides the greatest
degree of overall effectiveness proportional to its costs when
compared to the other alternatives evaluated. The net present
worth of the remedy is $17,400,000. See Section 1.7. of this
decision document for a detailed comparison of costs.
.
4.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
The selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be used in a
34
-------
."""'-~""""-""-"I:""Ji:.1( ...'jI
cost-effective manner at this Site. Of those alternatives that
are protective of human health and the environment and that
comply with ARARs, EPA has determined that the selected remedy
provides the best balance in terms of long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume of
contaminants, short term effectiveness, implementability, and
cost, taking into consideration State and community acceptance.
The excavation and placement of the backwater sediments, seeps,
and CRDA material into the CMSD, followed by installation and
maintenance of a final cover over the CMSD, ground water
extraction and treatment, treatment of the FSPSA, and restriction
of Site access through installation of a fence and institutional
controls wil~ provide the most permanent solution practicable,
proportional to the cost. .
s.
Preference for Treatment as a Principal Element
Based on current information, EPA believes that the selected
remedy is protective of human health and the environment and
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. The remedy does
satisfy the statutory preference for treatment of the principal
threat; the cyanide in the FSPSA and the ground water. It does
not, however, satisfy the preference for treatment in the CMSD,
CRDA, sediments or seeps because such treatment was not found to
be practicable or cost effective.
L.
DOCUMENTATION OF SIGNIFICANT CHANGES
A significant change from the preferred alternative set out in
the proposed plan, to the remedy selected in this decision
document, is that the former disposal ponds (FDPs) have been
eliminated as sources to be addressed by the remedy. The
principal reason for this is that EPA revised its risk management
approach based on input from the community during the public
comment period.
In the proposed plan, EPA based its preference for the proposed
alternative on a future, residential use scenario. Under this
scenario, EPA determined that all source areas needed to be
remediated because of the risk posed to future residents.
However, after consideration of the majority of public comments
which rejected the future residential use scenario, EPA has
modified its risk management approach for this site. The
majority of the community views expressed were very skeptical
regarding the likelihood of residential development in the area.
Commenters believe that the cost and degree of protectiveness
associated with the level of clean-up necessary to address future
residents was overwhelming, given the unlikelihood of such land
use. The logic presented at the public meeting was that if Ormet
35
-------
should go out of business due to the expense of the residential
use scenario remedy, there would be no incentive to develop
residential property near the Site because there would be no jobs
to support such residents. One commenter provided Monroe County
Census data showing a decline in population since 1982. Given
this public sentiment, along with the fact that Ormet has been
. operating at this location for 34 years and other companies
occupy much of the adjoining land along the Ohio River, EPA
agrees that the current land use is unlikely to change to
residential use in the foreseeable future. Therefore, the remedy
selected for the Site is now governed by current land use.
The Baseline Risk Assessment did not evaluate future industrial
use at the site, because it was assumed that clean-up to
acceptable residential risk levels would be protective of future
workers. Subsequent to revising the risk management approach,
u.S. EPA has evaluated the risks to future workers from the FDPs
under several scenarios and concludes that the risk to current or
future worker from exposure at the FDPs falls with the acceptable
risk range of 1 x 10~ to 1 X 104 ELCR. Details of the additional
risk evaluation are documented in the Administrative Record, in
memoranda dated June 28, 1994, and August 1, 1994.
The RI report did conclude that the ponds are probably a minor
source of ground water contamination, which is currently being
catured and treated and will continue to be captured and treated
under GW-3. EPA believes that over the time needed to treat the
residual contamination in the FSPSA (the primary source of
contamination to ground water), any contamination in the FDPs
that is going to leach to ground water will have done so (see
further discussion in Section E above). Compliance monitoring
during and after remedial action will provide a basis to evaluate
this hypothesis further.
Consequently, EPA now selects the no action alternative for the
FDPs because they present no significant direct exposure or
inhalation risk under the current land use scenario or under
future industrial use scenarios. However, this determination by
EPA does not preclude the State of Ohio from exercising any
authorities it may have to require additional work at the former
disposal ponds.
Because waste will be left in place at the Site, EPA will be
conducting five-year reviews of the Site and will, therefore,
have the opportunity to reevaluate the protectiveness of the
remedy should land use in the area change. The five-year reviews
will also be appropriate intervals in which to document the
fluoride trends in ground water.
The Proposed Plan provided that a solid waste cover may be
installed at the FSPSA if residual risk after soil flushing
36
-------
_e__',- ~ --"..-. !
should be unacceptable. However, the Proposed Plan did not
propose soil clean-up standards that are protective of ground
water for the FSPSA, as set forth in Section J above. Once these
standards are achieved, there will be no need to prevent
infiltration of precipitation (a primary objective of solid and
hazardous waste caps) because all leachable contaminants above
the standards will have been treated. Should residual risk due
to carcinogenic PARs in surface soil be unacceptable, as
discussed in Sections F and J, a vegetative soil cover will
provide sufficient protection against direct contact.
In responding to comments about the appropriateness of the
proposed ground water clean-up standards for vanadium and
manganese, EPA re-checked the calculation of the risk-based
numbers for those contaminants, and. tQund that the standards for
both manganese and vanadium need revision. Apparently, an error
in calculation resulted in the proposed vanadium standard of S4
ug/L. After re-calculating, EPA has revised the risk-based
standard to 260 ug/L.
For manganese, based on the current reference dose, the risk-
based standard should be revised from 380 ug/L to 180 ug/L to'
achieve a Hazard Index of unity. However, 180 ug/L is below the
background level for manganese of 230 ug/L determined in the
Baseline Risk Assessment. Comments received during the public
comment period suggest naturally occurring background may be even
higher than this. Therefore, EPA is setting an interim clean-up
standard for manganese of 230 ug/L. EPA may revise this standard
if a statistical analysis performed during remedial design
indicates a significantly different background standard would be
more appropriate.
The impact of these changes on the cost of the remedy is to
reduce it by the amount estimated in the FS for clean-up of the
FDPs. The value of that component is as follows:
Solidification -
Containment
Total
$7,900,000
$2,900,000
$12,BOO,000
All risk scenarios presented in the BRA were available during the
public comment period, and summarized in the Proposed Plan. EPA
has not changed any of the remedial components or considered any
new technologies or process options in making this change. In
response to public comments, EPA revised its risk management
scenario and performed an additional risk evaluation to ensure
the revised remedy was protective of human health and the
environment. EPA believes the preceding explanation provides
sufficient basis for revising the proposed plan to the remedy
selected herein.
37
-------
FIGURE I.
General Location of the Ormet
corporation Plant.
~_~r rnr~r~~;nn
o
2OQO
-------
~"'GERAGHTY :-
Hac NIUER. INC. ..-
~ ~...... ~.....
OIlIlIT
COli '011" flON
8"'.
/
\)"::,,
/
/
/
..,.......
'I.e, vol
D~l
o
o 0
I I .
MW.2!I
Mw'23
UO !
Ttl-ll i
o
MW.22
sao
~!l!Q
MW'21
SIlO
M~.~6.
.1"',
wEllS IHSTalllO OuRING 1911
'1110 OLAfll a ASSOelAIlS 51uOI
WillS ..SULlED DulI,"G ,98'
GIUG"n a lUll lA, ,,,e SIuO.
WHLS ,"5IAlUD DUR'N~ .986
GlRAG"" . "'LlfA 'Ne 51UO'
S60 INOI["US . wIll CluSIIA
(ONS,SIING 0' . SOIAUO.. '~O A
OU' MONIIOII'''G wtu
.".'1
.".')4
...
I
-ltJDO'r. 10 'HI r I
&A~ _Alii.'" ",&..
RIV£II MEASURING
POllfT
.
Gcrlahl}''' Millcr,lnc:.
-
,,"W.4)
'"
WEllS INStALLED DUR"'~ PHAS[ ,
III S60 INO.CUtS . WHL [lUSHA
CONSISTINO 0' " S.lAllOW "10 .
ou, MOHITOII'"O wHL
QlHUAL LOCAroON 0' S[[PS
UMPLIO OU","O I"E A'
o 0
o
1000""
1"'.'
t
RIVER
--- In _.--
OHIO
-------
:j
'"
~
-<
a:
Q
~
a:
~
o
a::
11-
~
~
Q
...
~
a
2'-(f'
L
G
I
G
c;
i
.
1!5
~
ci
z
~
Ii:
o
~
o
z
~
III:
11-
...
..
I
G
~
Ii!
.
Q
~ HYOROSEEO
/ SURFACE
BORROW
,--.., -- -- --
- - -
---
COMPACTED CLAY
BARRIER LAYER
EXISTING SOIL
(N.T.S.)
. _..
GEOTEXTILE FABRIC
DRAINAGE LAYER
40-MIL HOPE SYNTHETIC
MEMBRANE
TYPICAL DUAL BARfER CAP DETAIL
A~ GERAGHTY
I h~~'s!!1:;
I. .~~ . C:MMON
VIABLE
~
o
.. -.
- ., . - .
-
--
---
- "...-, ,...-, ~
----
ORMET CORPORATION
HANNIBAL OHIO
FIGURE
3
-------
Chemical
INORGANICS
AlwdnUIII
Antl.ony
Anenle
Bulu
BerylUUIII
Cad.lua
Calclua
Chro.lwD
Cobalt
Copper
Iron
Lud
HIBnesiUIII
HenSlnue
Mercury
Nlc:kel
Pota..lulil
5e1 en lUll
511ver
Sod lUll
Thal Hum
Vanadlua
Zinc
Cyanide
Non-CLP Inorganlcs
OIloride
Cy.nlde, Amenable
Cyanide, total
Fluoride
MltroBen, Ammonia
Snlca
Su Uate
TABLE
1
SUHMAK'i 01-' CONTAMINANTS OF CONClmN AT TilE ORMET COIU'ORATiON SITE
616-199,000 2_,_fk9-42,500 18,100-101,000 58,800-121,000 0.384-1.05 0.029-118
7.6-88 9.5-56 0.011-0.032 0.025-0.042
15-123 3.0-25 3.8-663 32.2-56.9 0.005-0.006 0.0018-0.394 5.3-10.0
17-8~8 33-136 137-309 106-150 0.012-0.072 0.042-4.75 72-165
1.0-14 0.23-2.2 1.5-7.8 2.6-3.8 0.00055-0.00064 0.00025-0.035 0.94-2.0
1.8-2.7 1.2-2.0 2.0-3.6 0.02-0.03 0.0041-0.012 1.7-2.0
586-352,000 806-24,300 2,130-194,000 8,610-16,100 3.97-117 2.81-144 2,110-32,500 20.5-43.1
6.4-119 4.8-168 14-47 2.0-42.5 0.023-0.06 0.0058-0.401 13.52 O.OOB-O.Oll
2.0-19 1.9-13.0 1.8-23 4.2-11.4 0.0051-0.052 0.0042-0.814 2.1-32 0.007
12-130 1.8-791 29-94 303-542 0.013-0.1~ 0.017-1.02 30-119 0.004-0.026
3,180-13~600 6,690-106,000 5,210-49,800 21,800-27,800 0.408-2.62 0.044-144 12,500-43,500 1.81-5.13
2.3-214 7.2-74 2.9-85 54.7-84.1 0.003-0.005 0.0023-0.139 20-92 0.003-0.009
172-6,010 661-2.930 2,110-3,860 901-1,670 4.8-48.5 0.61-16.7 1,370-6,120 5.92-7.19
13-227 198-3,220 131-2,140 330-1,060 0.003-31.3 0.01-15.4 519-1,490 0.262-0.772
0.14-0.59 0.089-0.098 0.17-0.31 0.00026'0.0033 0.22-0.39
19-656 0.59-146 24-558 36.6-62.5 0.043-0.051 0.026-0.767 10-73
810-2,510 796-2,810 1,200-2,750 311-1,150 3.17-29.9 4.36-42.1 901
0.31-0.61 0.014-0.02 0.0023-0.027
2-2.4 11 0.018-0.049
6,~10-69,400 1,190-14,200 1,960-11,500 22,300-48,100 945-4,900
0.67-1.2 0.54-0.6
13-741 6.1-62 31-270
13-170 24-109 28-294
1.8-294 2.7-647 0.82-254
Range of Conc-=ntriltlons
DI.po.al Pot liner
Pond.. _./kS Arel, -S/kg
CRDA, IIIg/kS
CHSD, mg/kg
Sl!l!pS J ~I&/I.
29.4-42.4
59.6-125
7.9-21.7
0.006-0.029
0.006-0.029
0.163-4.383
4-350 5-200 8-10
1-120 )-28
2-410 1.0-1,900 )-Uo 7.9-21.7
31-1,200 0.)-1,500 64-270 440-540
13-146 13-360 10-110
8-79 14-29
34-8,000 22-1,700 41-270
39-17
0.0686-0.9
0.0794-8.8
6.5-200
1.5-4.2
6-28
210-6,100
(a) Metll valuel In this column for total metlla.
(b) Itnlt Indlclte. either not detected or not analyzed for.
Groundwater,
.S/L
18.1-2,640
0.0028
0.0026-0.369
0.0081-0.449
0.011-18.6
5-320
0.01-41.0
0.01-67
0.1-1,000
0.1-230
5-4,)00
8-850
River
Sediments .
IIS/kS
6,5110-12,bOO
501-2,060
8.9-17.0
106-524
1.1-42
91i-300
1-39
2.3-11]
43-88
11-)]
13-60
contlnued-
Surfac~
Water. mg II.,
0.811i-1.1I1I(.d
0.04
0.005-0.011
0.048-0.018
0.01-0.012
1. 72-2.'J9
10.)-I~.J
O.Ol)-U.llbb
}]-41
0.078
0.007b-O.l,lU
0.1-12
3-6
65-110
~
f
~
~\
-------
1Mble 1 - continued
Range of C
-------
Table 1 - continued
Chemical
Semlvolatllee - continued
. BenzoCa)pyrene
IndenoCt,2,3-cd)pyrene
DlbenzCI,hJlnthrlcene
Benlo(.,h,l)perylene
~
Aroclor-1242
Aroctor-lZlt8
Dtlpo..t Potllner
Pond.. .l/ka Are., .a/ks
0.43-SS
0.25-'0
0.&1-11
0.22-'5
0.043-710
0.061-220
0.086-220
0.085-190
Ranse of Concentrations
CRnA, ms/k&
CHSO. mg/kg
0.091-.091-19 18-160
0.08-6.6 S.2-14
0.15-1.7 35-220
0.084-5.4
3.6-22.6
Seeps, mg/L
0.0008)-0.0014 --
Groundwater.
!lS/L
River
Sediments,
!lS/kH
0.56-1110
0.61-91
0.093-22
0.26-88
1.0l,-'J1.5
Surface
\.later, mg/I.
0.001-0. 001 ~
~
~
~
~
~
~
-------
CHEMICALS OF CONCERN FOR GROUND WATER. SHOWING CLEAN-UP
STANDARDS AND RESIDUAL RISK
TABLE 2.
Chemicals of Concentration Clean-up Residual Risk
Concern for Range ( ug jl) Standard at Clean-up
Ground Water (ugjl) Standard
Tetrachloroethene 5.0 - 40 51 ELCR=3.1E-06
Arsenic 1.8 - 394 102 ELCR=1.20E-04
Beryllium 0.25 - 35.0 41 ELCR=1. 7E-04
Cyanide 11. 0 - 18,600 2001 HI=0.2
Manganese~ NO - 15,400 2303.4 HI=0.9
Vanadium 2.6 - 369 2603 HI=0.73
Fluoride 100 - 710,000 40001 HI=1. 3
1. MCL or Proposed MCL
2. Analytical Quantitation
3. Risk Based
4. Background
Limit (higher than background)
a. Manganese is an interim standard per Section J of the ROD
Assumptions for Residual Risk Levels:
Worker exposed to drinking water.
assumed.
No showering so no inhalation
C
EF
ED
ATn
ATe
BW
IR
RfD
SF
Concentration
250 days
25 years
25 years
70 years
70 kg
2Ljday water
Reference Dose
Slope Factor
at Clean-up Standard (mgjL)
Residual Risk Calculations
HI =
C x IR x EF x ED
RfD x BW x AT~ x 365 daysjyr
ELCR =
SF x C x IR x EF x ED
BW x ATe X 365 daysjyr
-------
population
Occupational
(Adult)
Recreational
. (Adult' Child)
Residential
(Adult' Child)
TABLE 3
POTENTlAl.LY COHPI.ETE PATHWAY SUMMARY - CURRENT SCENARIOS
Expo8ure Point
Plant Recreation Area
Plant Recreation Area
Proctor. West Virginia
(off-site)
Source/Release
Hechanh.
Disposal
potUner
fuSitive
emtssion
ponda.
area/
dust
Disposal ponds.
potUner area'
fuSitive dust
emission.
seepage
Disposal
potUner
fugitive
emission
ponds,
are.'
dUlt
Exposure
Hed!um
Exposure
Route
Air
Inhalation
(Particuhtes
, Volatiles)
SoU
Ingestion
So11
Dermal
Air
Inhalation
SoU
Ingestion
So11
Permol
Air
Inhalation
(Particulates
, Volatiles)
Quantify?
Yes - Particulates.
No ~ Volatiles, unable LO
quantify with available
data.
No - Unable to quonLlfy
with available data.
No - Unable to quantify
with available data.
No - Occupational cxposurcs
repreaent higher exposure
potential. Ormet workers
and families are not
frequent visitors to area.
No - Pathway not alwaY9
complete. exposure
infrequent and pot'~1I1 1;1)
low. .
Yes - Particulates.
No - Volatiles, unable to
quantify with available
data.
continued-
~
f'\
~
~
~
~
~
-------
Table
3 - continued
population
Residential
(Adult & ChUd)
Hypothetical
Trespasser
Exposure Point
Ohio River
004 Backwater Area
(Ohio River to .
Outfall 004
discharge pipe)
Ohio River Bank
Source/Release
Hechantem
Disposal pond's,
potUner erea'
CHSD, Carbon
Runoff Area'
fugitive dust
emission,
surface runoff
004 Dischsrge,
CHSD, Carbon
Runof f Area'
fugitive dust
e.teeton,
surface runoff
Disposal Ponds.
poUlner Area,
CHSD, Carbon
Runof f Area'
fugitive dust
emis81on. '
Bur face runoff
Exposure
Hedium
Surface Wster
Surface Water
Sediments
Surface Water
Sediments
Surface Water
Sediments
Exposure
Route
Incidental
Ingution
Ingestion of
Fish
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
De rma I
Ingestion
Dermal
Quant ify?
No - Current exposure
potential for these path-
ways low. Psthway
evaluated for future
residential scenario.
Yes
Yea
Yes
Yes
Yes
Yes
Yea
Yes
Yes
Yes
Yes
continued-
~
~
~)
~
~
~
1"'\
-------
Table
3 - continued
population
Hypothetical
Trespasser
Exposure Point
Source Areas
Seeps
Source/Release
Mechaniam
Disposal Ponds.
Pot liner Area.
CHSD. Carbon
Runoff Area'
fugitive dust
emission.
direct contact
Groundwater/
Itepage to
surface
Exposure
Hedtum
SoU
Air
Surface Water
Exposure
Route
Dermal
Ingestion
Inhalation
Ingestion
Dermal
Quantify?
No - Pathways involving
direct contact with the
source likely presents low
potential. Evaluated in
future scenarios.
No - Path~ay evaluated
for worker whose exposure
potential is higher.
No - Pathway not always
complete snd potential
for exposure 19 low.
No - Pathway not always
complete and potential for
exp08ure is low.
~
t'\
~~)
~
~
~
%"'\
-------
Population
Occupational
(Adult Plant or
Maintenance
Worker)
Resident
(Adult" Child)
TABLE 4
POTENTIALLY COMPLETE PATHWAY SUMMARY - HYPOTIIETICAL FUTURE SCENARIOS
Exposure Points
CAC Ranney Ve 11
Drinking water well
in plume
Residence-Downwind
of Pond 5
Residence-
PotUner Area
Residence -
Ponds 1-5
Resldence-CRDA
Resldence-CHSD
Ohio River
004 Backwater area
(Ohio River to out-
fall 004 discharge
pipe)
Source/Release
Hechanism Exposure Media
Disposal ponds. Groundwater
potl1ner area/
fnUltt"8tion
Diaposal ponds. Groundwater
potltner areal
infiltration
Specific source Air
areaa/fuSittve
dust. direct
contact
SoU
SoU
Exposure
Route
Ingestion
Ingestion
Inhalation
Dermal
Inhalation
(Particulates
& Volatilea)
Ingestion
De rmal
Quantify?
Yes
Yes
No. Pathway not
likely to present
hi,gh exposure
potential.
Yes. Particulates
where pathway 15
complete, , ,
No.. Vola t 11 co'
unable,t~ q~~ntlfy
with available data.
Yes
Yes
Disposal ponds. Surface Water Ingestion Yes
potliner'area/ Dermal Yell
CMSD. carbon Sediment Ingeation Yes
runoff area/ Dermal Yea
fugitive duat Fish Ingestion Yes ~
surface runoff
004 Discharge. Sediments Ingestion Yes ~
CHSD. carbon De rmal Yes ~)
runoff area/ ~
fugitive dust Surface Water Ingestion Yes ~
em18s1on. sur- Dermal Yes
face runo ff ~
~
-------
~able 5 Su.mary of Potential Excess Lifetiae Cancer Risks and Non - carcinoaenic Hazards. from the
9rmet. Hannibal. Ohio
"~Rothet~ curren~
tledia II&B HI ~
Backwater Area Sedi.ents 2 x 10-4 -- PCB, PAR
Media ~ HI ~
pond 5 soils 3 x 10.4 1.0 As, Be, PAD
pond 1-4 soils 1 x 10.3 3.0 As,Be,PAII,V
FSPSA soils 1 x 10.3 0.8 As, Be, PAH
CRDA soils 1 x 10.3 3.0 As, PAH, PCB
CHSD soils 5 x 10.J 1.0 As, Be, PAH, PCB
Backwater Area Sediments J x 10.4 PCB, PAM
ground water 2 x 10-3 600 As,Be,CN-,F,Mn,PCE,V
H~Dothetical Future ~
Media tLcR HI SCOC
ground water 1 x 10.J 30 As,Be,CN",F,Mn,PCE,V
risk range 18 10~ 10~)
EtcR a Excess lifetime cancer risk - CU.S.EPA'S acceptable
HI a Hazard index - (HI < 1.0 i8 protective)
Scoc = Chemicals of concern significant to risks
PCB = POlychlorinated biphenyl
PAM = polynuclear aromatic hydrocarbon
-------
TABLE 6. COMPONENTS OF REMEDIAL ACTION ALTERNATIVES
Groundwater
. GW-5:
Pumping of Ranney and existing interceptor wells,
treatment of the interceptor well water by ferrous salt
precipitation, clarification of effluent, and discharge
to the Ohio River;
pumping of Ranney well and new interceptor wells
installed closer to the FSPSA, treatment of interceptor
well water by ferrous salt precipitation,
clarification, post-treatment by activated alumina.
adsorption, and discharge to the Ohio River;
. GW-3:
CMSD and Ballfield Seeps
. SP-4:
Collection of Ballfield and CMSD seeps using trench
drains, treatment of CMSD seeps by oil/water separation
and/or carbon adsorption;
Former Spent potliner Storaqe Area
. FSPSA-2:
containment by vegetated soil cover;
. FSPSA-3:
containment by dual barrier cap;
. FSPSA-4:
containment by single barrier synthetic cap;
. FSPSA-6:
Treatment by in-situ soil flushing and containment
by vegetated soil cover;
. FSPSA-9:
Partial excavation with off-site landfilling of
excavated Soils, and containment by single barrier
synthetic cap;
. FSPSA-10:
containment by single barrier clay cap;
Construction Material Scrap Dump
. CMSD-3: Recontouring, and vegetated soil cover;
. CMSD-4: Recontouring and containment by single barrier
synthetic cap, placement of rip rap/other engineering
controls to prevent washout of CMSD materials;
. CMSD-5: Recontouring and containment by dual barrier cap,
placement of rip rap/other engineering controls to
prevent washout of CMSD materials;
35
-------
TABLE 5 (CONT'D
construction Material Scrap Dump (cont'd
. CMSD-7:
Complete excavation, ~reatment by thermal oxidation,
and containment by single barrier synthetic cap,
placement of rip rap/other engineering controls to
prevent washout of CMSD materials;
. CMSD-8: Containment by single barrier clay cap, placement of
rip rap/other engineering controls to prevent washout
of CMSD materials;
Carbon Run-off and Deposition Area
. CRDA-3: Excavation and consolidation under CMSD cover;
. CRDA-4: Excavation with off-site landfilling of the excavated
material;'
. CRDA-5: Excavation and treatment by thermal oxidation;
Backwater Area Sediments
. 8ED-4:
Complete dredging, treatment by solidification, and
off-site landfilling of the dredged sediments.
. SED-6:
sheet piling containment and concrete revetments.
. SED-7:
Complete dredging, treatment by solidification, and
consolidation under CMSD cap.
. SED-8:
Partial dredging, treatment by solidification,
consolidation under CMSD cap.
. SED-9:
Complete dredging, treatment by solvent extraction, and
consolidation under CMSD cap.
. SED-10: Complete dredging (including Ohio River sediments),
treatment by solidification, and consolidation under
CMSD cap.
36
-------
Silewide
Remedinl
Allernnlivc
Numher
I
2
3
4
S
6
7
8
9
10
.---
RemedlRl
Alternative
Ctuegory
No-Action
Conlninmenl
Conlninment
Conlftinment
Conlninment/Orr-Sile Dispow
T realment/Conlninment
T reatmenl/Conlllinrnent
ExcnvnlionlT reatment/ConlRinment
Excftvlllion/TrealrnentlOrr-Sile Dispo~1
Treatmenl/Contllinmenl
TABLE 7
FORMATION OF SITEWIDE REMEDIAL ALTERNATIVES
Remedial Meesuret
H H H "...,...H. ~~i~~:i ~f~ t~~;i
Grotind W.ier' .......". SiOfiije' Area Ponda sCtlip t>iiitij)
,., ~::
OW.I SP-I FSPSA-I FDP-I CMSD-I CRDA.I SED-I
OW-3 SP-4 FSPSA.2 FDP-2 CMSD.) CRDA.) SED-6
OW.) SP-4 FSPSA-4 FDP-S CMSD-4 CRDA-3 SED-8
OW-) SP-4 FSPSA-) FDp.7 CMSD-S CRDA-) SED-7
OW.) SP-4 FSPSA-9 FDP-S CMSD-4 CRDA-3 SED.8
OW-) SP-4 FSPSA-9 FDP-) CMSD:7 CRDA-S SED.7
OW.) SP-4 FSPSA.6 FDP-7 CMSD-7 CRDA-S StD-9
OW.) SP-4 FSPSA-6 FDP-S CMSD-4 CRDA-) SED-R
OW-S SP-4 FSPSA-9 FDP-7 CMSD.7 CRDA-4 SED-4
OW.S SP-4 FSPSA-IO FDp.IO CMSD-8 CRDA-) SED-IO
-------
Table 8
Th:eshold Criteria:
Ni=e Evaluation Criteria
1.
2.
Overall Protection of Human Health and the Enviro~ent:
Addresses whether a remedy provides adequate protection and
describes how risks posed through each exposure pathway are
eliminated, reduced, or controlled through treacment,
engineering controls, or institutional controls.
Comcliance with ARARs: Addresses whether a remedy will meet
all requirements of other federal and state environmental
laws and regulations and/or provides grounds for invoking a
waiver.
pr~ Bal~cing Criteria:
3.
4.
Lona-Term Effectiveness and Permanence: Refers to expected
residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time, once cleanup levels have been met.
Reduction of Toxicitv. Mobilitv. or Volume Throuah
Treatment: Assesses the deqree to which a remedy utilizes
treacment to address the principle threats at the Site.
5.
Shore-Term Effectiveness: Addresses the potentiaJ. ac:1verse
effects that implemen1;a.ticn cf a remedy may have on human
health and the enviromaent, i. e. during construction aDd
before cleanup levels are achieved.
6.
Imnl~entabilitv: Addresses the technical and
al"bftinistrative feasibility of a remedy, including the
availability of services and materials.
~: Includes the estimated capital and operation aDd
maintenance costs for a remedy, also expresseQ in net
present worth costs. .
7.
Kad1.~ OdotC'2.aa
8.
State Acce1:)tance: Indicates whether the State of Ohio
supports the alternative.
C~t,.,itv Acc81:)tance: Addresses the acceptability of the
alternative to the local. co""nnity based on COl"""Elnts
received during the public c~~ut period.
9.
-------
TABLE 9.
STATE ARARS
APPLICABLE OR RELEVANT AND APPROPRIATE
REOUIREMENTS (ARARS) FOR THE SELECTED REMEDY
ohio Administrative Code
OAC:3745-1-04:
OAC:3745-1-05:
OAC:3745-9-10:
OAC:3745-51-07
OAC 3745-54-15:
OAC: 3745-54-31:
General Narrative Water Qualitv Standards
Antidegradation Policy for Surface Water
Water Well and Test Hole Abandonment
A.B: Residues of Hazardous Wastes in Empty
containers
Inspection Requirements for Hazardous Waste
Facilities.
Design and Operation of Hazardous Waste
Facilities.
General Ground Water Monitoring Requirements
Ground Water Corrective Action Program
Disposal and Decontamination of Equipment,
Structures, and Soils
Post-Closure Care and Uses of the Property
Proper Use of Containers
Environmental Performance Standards for Land-
Based Units
Cover Inspection During and Immediately After
construction
Closure and Post-Closure Care
13: special Requirements for Igniteable,
Reactive, or Incompatible Waste
MCLs for Inorganic Chemicals
Inorganic Monitoring Requirements
Alternate Analytical Techniques
OAC:3745-54-97 A-F:
OAC:3745-55-01:
OAC:3745-55-14:
OAC:3745-55-17:
OAC:3745-55-71-78:
OAC:3745-57-01 A-D:
OAC:3745-57-05 A:
OAC:3745-57-10:
OAC:3745-57-12.
OAC:3745-81-11 B:
OAC:3745-81-23 A:
OAC:3745-81-27:
Ohio Revised Code
ORC:3734.02(F):
ORC: 3734.02 (I) :
ORC:3734.05:
ORC:3767.13. .14:
FEDERAL ARARS
Unauthorized Storage, Treatment, or Disposal
of Hazardous Waste
Air Emissions From Hazardous Waste Facilities
Prohibits Violation of Air Pollution Control
Regulations
Prohibits Nuisances in Waterways
40 CFR 761. 60 (a) (5) :
Disposal of PCB-Contaminated Dredged
Materials
------- |