United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-86/012
Sept 1986
SEPA
Superfund
Record of Decision:
Mowbray Engineering, AL
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TECHNICAL REPORT DATA
IPlease read Instructions on the revene before completing)
I. REPORT NO.
EPA/ROD/R04-86/012
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SuPERFUND RECORD OF DECISION
Mowbray Engineering, AL
5. REPORT DATE
September 25, 1986
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
1 1. CONTRACT/GRANT NO
12. SPONSORING AGENCY NAME AND ADDRESS
D.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Mowbray Engineering Company (MEC) site consists of a 3-acre swamp located in
Greenville, Butler County, Alabama. The study area evaluated in the RI/FS also included
the MEC plant property located across the street from the swamp. The MEC site lies in
the 100-year floodplain of the Tanyard Branch, and is saturated most of the year. An
aquifer underlying the site supplies 11,400 residents with potable water. Since the
early 1940s,MEC has been in the business of repairing electrical transformers. Waste
oils generated from this process were dumped onto the ground behind the plant. Oil was
also allowed to flow into a city storm sewer drain and ultimately into the swamp.
Dumping and other discharges continued until the mid 1970s. A fish kill occurred in 1975
in Tanyard Branch. As a result, MEC installed two underground storage tanks to collect
oils for resale and prevent future spills. In 1980 another fish kill occurred, and the
state sampled soils to determine the exact source of contamination. PCBs were detected
in swamp soils at 500ppm, leading to EPA removing the top six inches of swamp soil and
disposing the wastes in an approved offsite hazardous waste facility. The MEC site was
listed on the NPL in 1982, and RI/FS activities were initiated in January, 1985,
following discovery of PCBs in concentrations of l,737ppm in soils contained in the
storm water drainage pathway. The primary contaminants of concern are PCBs.
(See Attached Sheet)
KEY WOROS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
COSATi Field/Group
Record of Decision
Mowbray Engineering, AL
Contaminated Media: soils
Key contaminants: PCBs, oils
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS f Tilts Report/
None
21. NO. OF PAGES
73
20. SECURITY CLASS /TIlit page/
None
22. PRICE
BPA P"o»m 2220-1 (*•». 4-77) PMVIOUS COITION is OMOLCTI
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EPA/ROD/RO 4-86/012
Mowbray Engineering, AL
16. ABSTRACT (continued)
The selected remedial action includes: excavation, removal and disposal of
the underground storage tanks located on the MEC property; treatment or
disposal of waste oils encountered in the swamp area and in the underground
storage tanks by a TSCA-approved method; drainage diversion of surface runon
around the swamp area; excavation of soils contaminated above 25ppm PCBs ana
either offsite or onsite incineration, or onsite stabilization/solidification
of these soils. Infrared incineration is preferred, but if operating
parameters deem this technology impractical, solidification/stabilization will
be performed. The remedy also includes grading and revegetating the swamp;
proper closure of the abandoned onsite city supply well in accordance with
Alabama Department of Environmental Management well closure regulations; and
O&M involving maintenance of the drainage diversion ditch, the revegetated
area and possibly the solidified matrix. Estimated capital cost of the remedy
is $1.2-2.0 million for offsite incineration, $1.1-1.8 million for onsite
incineration, and $750,000 for solidification/stabilization. All costs
include O&M activity costs.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE
Mowbray Engineering Company
Greenville, Alabama
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents describing
site specific conditions and the analysis of cost-effectiveness of remedial
alternatives for the Mowbray Engineering Company site:
- Remedial Investigation and Feasibility Study Draft Report for Mowbray
Engineering Company site
- Public Health Evaluation of the Mowbray Engineering Company in Greenville,
Alabama
- Agency for Toxic Substances and Disease Registry Health Assessment for
Mowbray Engineering Company Site
- Sutmary of Remedial Alternative Selection
- Responsiveness Suimary
- Department of the Interior Release from Claims for Damages to the
Natural Resources under DOI Trusteeship.
- Alabama Department of Environmental Management review comments
DESCRIPTION OF SELECTED REMEDY
The selected alternative for the Mowbray Engineering Company (MEC) site
includes:
- Excavation, removal, and disposal of the underground storage tanks
located on the MEC property.
- Treatment or disposal of waste oils encountered in the swamp area and
in the underground storage tanks by a TSCA-approved method.
- Drainage diversion of surface runon around the contaminated swamp
area.
- Excavation of soils contaminated above 25 ppm PCBs and either offsite
incineration, onsite incineration, or onsite stabilization/solidification
of these soils. Incineration with an infrared-type incinerator is the
preferred option, but operating parameters are not fully known for this
technology. Should actual experience with this type of unit prove
unsatisfactory, the contaminated soils will be stabilized/solidified
onsite.
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- Grading and revegetation of the contaminated swamp area.
- Proper closure of the abandoned onsite city supply well (in accordance
with Alabama Department of Environmental Management well closure
regulations).
- Operation and maintenance (O&M) activities will include annual maintenance
of the drainage diversion ditch, the revegetated area and, possibly,
monitoring and maintenance of the solidified matrix. Other O&M activities
may be identified during the detailed design of the remedy.
DECLARATIONS .
Consistent with the Comprehensive Environmental Response Compensation and
Liability Act of 1980 (CERCLA) and the National Contingency Plan (40 CFR
Part 300), I have determined that the remedy described above provides
adequate protection of public health, welfare, and the environment. The
State of Alabama has been consulted; however, they do not agree with the
remedy.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, the selected remedy is the cost-effective remedial
action that provides for complete destruction or fixation of the
contaminants, and is necessary to protect public health, welfare or the
environment.
Date Jack E. Ravan
Regional Administrator
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GREENVILLE,
ALABAMA
ENGINEERING SITE
1000 1000
SCALI IN PUT
Figure 1-1. Site Location Map.
Mowbray Engineering Company Site.
Greenville, Alabama.
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RECORD OF DECISION
OF REMEDIAL ALTLRNATIVE SELECTION
MOWBRAY ENGINEERING COMPANY SITE
GREENVILLE
BUTLER COUNTY, ALABAMA
I. SITE LOCATION AND DLSCRIPTION
The Mcwbray Engineering Company (MEC) Superfund site consists of an approximate
three^acre swamp located on Beeland Street in Greenville, Butler County,
Alabama (Figure 1-1). The actual study area investigated in the Remedial
Investigation (RI) and Feasibility Study (FS) includes this swamp area and the
MEC plant property located across Beeland Street from the swamp (latitude
31°49'25"N and longitude 86836'48"W). The swamp area is bordered on
the north by a parking area adjacent to the Greenville Apparel Company
and on the south and southwest by First Street and Tanyard Branch. The
company property is bordered on the west by Beeland Street and by Second
Street on the south. The Alabama Power Company (AFC) is located across Beeland
Street from the swamp and across Second Street from the plant (Figure
1-2). The study area, which is less than half a mile from downtown
Greenville, lies in the 100 year flocdplain of Tanyard Branch.1 The swamp
and Tanyard Branch represent a topographic low for the area, which receives
surface drainage from the surrounding watershed. The population of
Greenville is approximately 8,069 (Census Bureau, 1984 estimate).
The upland area in the northeast corner of the swamp is covered by a
stand of loblolly pine with a thick growth of under story shrubs. The
northwest corner of the swamp, adjacent to Tanyard Branch, is saturated a
majority of the time and is covered with a dense growth of wetland grasses
and swamp oak. The central portion of the swamp, comprising the affected
area, is essentially denuded of surface vegetation and is stained with a
black oily substance, while the southern portion is covered with a diverse
group of weeds and underbrush and small pines.
The geologic formations of the Greenville area consist of beds of unconsoli-
dated clay, sandy clay, sand, gravel, chalk, marl, and limestone, which are
part of the Cretaceous and Tertiary Systems (Carter et. al, 1949). The
principle aquifer in the Greenville area is the Ripley Formation. This
aquifer is comprised of several sand layers, sandstone, sandy limestone,
and interbsddsd clay. The aquifer, which supplies Greenville's four city
wells with 200-600 gallons per minute, lies approximately 450 feet below
land surface) (bis) and serves approximately 11,400 people. The formation
of the site above the aquifer is characterized by alternating layers of
rock and clay. The first significant clay layer, which is approximately
37 feet thick, lies fron 18 to 55 feet bis. Inndiately below this clay
layer lies 20 feet of highly permeable strata characterized by rock,
boulders, and limestone.
1 May 1, 1980, National Flood Insurance Program (NFIP) Floodway Map for
Greenville, Alabama
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(flWMirr \
SCCONO STUgET
nir
Figure 1-2. Site Map.
Mowbray Engineering Company Site.
Greenville, Alabama.
Area of stained
soils
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-4-
II. SITE HISTORY
Since the early 1940's, MEC has been in the business of repairing electrical
transformers. The conpany was first located in downtown Greenville, but
in the mid 1950's, moved to its present location in a residential/light
industrial area on the outskirts of the Greenville business district.
From that time, MEC disposed of waste transformer oil by dumping it onto
the ground behind the plant. The oil was allowed to flow into a city
storm sewer drain at the property and ultimately into the swampy area
across Beeland' Street from the MEC plant. MEC continued discharging in
this manner until the mid-1970's. Between 1955 and 1974, the company
drained, repaired, and refilled an annual average of approximately 1,000
used transformers, each containing approximately nine gallons of oil.
In May 1975, a major fish kill in Tanyard Branch was traced to an overflow
of waste oils from a MEC holding tank. As a result/ EPA and the Alabama
Water Improvement Commission (AWIC) sampled and analyzed soils from the
swamp for PCBs. At that time/ only trace anoints of PCBs were found so
no further action was taken by the state. In late 1975, MEC installed
two underground storage tanks to collect the waste oil for resale and to
prevent future spills.
In 1980, following a second spill and fish kill, the state sampled and
found soil PCB levels of approximately 500 rag/kg. During February 1981,
EPA responded to the situation on an emergency (spill) basis (under Section
311 of the Clean Water Act (CWA)) and conducted an extensive sampling
investigation to determine the extent of contamination in the swamp and
to delineate an area for possible removal of contaminated soil to an
acceptable level (maximum 50 mg/kg PCBs). Following completion of this
investigation, EPA officials proceeded to remove the top six inches of
contaminated soil from the swamp. The contaminated soils were sent to an
approved, offsite hazardous waste facility. In August 1981, after removal
of the soil, EPA collected three surface samples from around the study
area to verify that PCB levels were below 50 mg/kg. Analytical results
from the three samples revealed a maximum concentration of 19 mg/kg.
Also in February 1981, personnel from the U.S. Food and Drug Administration
(FDA) collected catfish/ which are bottom feeders/ from Tanyard Branch
downstream of the site and concluded that PCB concentrations in edible
tissue were below the FDA level (2.0 mg/kg). In addition, EPA collected
samples of root systems of bullrush (Scirpus sp.) growing in the northwest
corner of the swamp to determine if the plants were concentrating PCBs.
The analyses of the root systems from two separate plants growing in the
water saturated soils indicated levels of PCBs above background in the
short, thick rhizomes of the plants. Concurrently with the extent of
contamination survey of the swamp/ EPA's Environmental Services Division,
Ecology Branch, conducted an ecological survey of Tanyard Branch and
Persimmon Creek/ which joins with Tanyard Branch approximately one mile
downstream of the site. The results of this investigation showed that the
Tanyard Branch was almost completely devoid of biota from below the swamp
to its confluence with Persimmon Creek. Two miles below the confluence,
Persimmon Creek biota appeared to be normal.
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-5-
In February 1961, the Centers for Disease Control (CDC) requested assistance
from National Institute for Occupational Safety and Health (NIOSH) to
evaluate occupational exposures to PCBs by employees at NEC. Based on
the data collected in this study, NIOSH concluded that workers did not
appear to be exposed to excessive levels of PCBs; however, NIOSH recommended
that workers reduce skin exposure to transformer oil as much as possible
(NIOSH, 1981 and 1982).
In 1982, the MEC site was listed on the National-Priorities List with a ranking
score of 53.67.
No further investigations occurred at the site until November 1983, when grab
soil sanples were collected front the swamp by the Alabama Department of
Environmental Management (ADEM) during a routine inspection at MEC. One
of the soil sanples collected from the storm water drainage pathway
through the site was reported to have a PCB concentration of 1,737 mg/lcg.
This triggered renewed interest in the site at the federal level.
In February 1984, the EPA Field Investigation Team (FIT), conducted a site
inspection of the swamp to characterize existing conditions and to prepare
a detailed sampling study plan to determine the possibility and extent of
reoontamination of the swamp. In April 1984, FTP conducted a sampling
investigation of the swamp and found that soils and groundwater in the :
swamp were contaminated with PCBe (Aroclor 1260) at levels similar to
those measured prior to EPA's 1981 cleanup of the site.
In January 1965, EPA received approval to begin remedial activities and
authorized Camp Dresser & McKee (CEM) to conduct a Remedial Investigation/
Feasibility Study (RI/FS) at the NEC site. In March 1985, CEM conducted
a general site reconnaissance and collected soil and sediment samples
from the Alabama Power Company (APC) property and from Tanyard Branch and
Persimmon Creek. Since all sanples were below the detection limit (1.0
mgAg) for PCBe, the APC was ruled out as a potential source of PCB
contamination to the swamp.
In August 1985, the RI Work Plan prepared by CEM received approval by EPA,
and a Public Meeting waa held to present it to the public and to receive
comments. Subsequently, the field work began and waa completed in November
1985. The combined RI and FS Report was completed in July 1986 and was
presented to the public for comment on August 12, 1966 at the FS Public
Meeting.
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-6-
III. CURRENT SITE STATUS
The initial review of existing information highlighted several deficiencies
in the data base for the MEG site that needed to be corrected before site
remedies could be adequately evaluated. Therefore, the primary objective
of the remedial investigation was to collect an adequate amount of data from
soil, ground water, surface water, and stream sediment samples to eliminate
these data gaps. Limited geological data were also collected during the
installation of monitor wells.
Surface Water/Sediment
Surface water samples collected both upstream and downstream of the site in
Tanyard Branch and Persimmon Creek (Figure 3-1) were found to contain no
contaminants above 1980 EPA Water Quality Criteria (Table 3-1). Stream
sediment samples collected upstream of the site in both streams were found to
contain no contaminants, although both downstream samples from the same
streams were found to contain very low levels of PCS. Samples collected from
downstream Tanyard Branch showed PCBs at 0-52 rag/kg, and samples collected
from downstream Persimmon Creek contained levels of PCBs at 0.45 rag/kg
(Table 3-2).
Groundwater
A total of four permanent monitor wells were installed at, or near, the MEC
site study area to evaluate migration via groundwater in the water table zone
(Figure 3-2). Only one monitor well, MW-2, was found to contain PCS in
groundwater samples. A sample from MW-2, located near the point where waste
oil from the MEC plant discharged into the swamp, was found to contain 2.4
ug/1 Arochlor 1260. However, the water samples collected from all the monitor
wells were unfiltared, and it is likely that the PCBs, which are nearly insoluble
in water, may have been adsorbed onto the clay particles collected with the
water samples.
Monochlorobenzene and dichlorobenzene were detected in MW-3 at 200.0 and 3.0
ug/1, respectively. Bis (2-ethylhexyl) phthalate was detected in samples
from all the monitor wells including MW-1, the upgradient background well.
Carbon disulfide was found in MW-1 (3.2 ug/1) and MW-2 (8.5 ug/1). This,
however, is not considered to be site-specific due to the low levels and
presence in both the upgradient and downgradient wells. Table 3-3 presents
the results of the monitor well sample analyses.
The sampling of a Greenville public water supply well currently in use showed
no PCBs; a trace quantity of phenol (5ug/l) was the only chemical found in
this well.
Soil
A total of 46 temporary boreholes were installed within the study area to
evaluate the area! and vertical distribution of contaminants and to determine
if the buried tanks had been leaking. Thirty temporary boreholes were drilled
in the swamp disposal area (Figure 3-3) and sixteen at the MEC transformer
processing area (Figure 3-4).
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0 1000
SCALI IN Pf|
Figure 3-1. Water Quality and Sediment Sampling.
MoMbray Engineering Company Site.
Greenville, Alabama.
-------
-8-
Table 3-1. Organic Ccrpounds Detected in Surface Water Sanples,
CLP Laboratory
Parameter (ug/1)
Sanple Carbon Disulfide Total Xylenes
MEC UPC 4.5J lOu
MEC DTB lOu 7.0J
u = ncne detected? value is minimum quantitaticn limit
J = estimated value
Table 3-2. Organic Compounds Detected in Surface Sediment Sample
CLP Laboratory
Parameter (rag/kg)
Sample PCS Aroclcr 1260
MEX: UPC o.22u
MEC EPC 0.45
MEC UTB 0.21u
MEC E7TB 0.52
u * none detected; value is minimum quantitaticn limit
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THAMES STREET
OftONVUJf
APftAMLQC
MttMPY \
SECOND STREET
nir
AtANOONCO
CITY WCU.
Figure 3-2. Monitor Well Locations.
Mowbray Engineering Company Site.
Greenville, Alabama.
Area of stained
soils
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-10-
Table 3-3. Analytical Results for Water Samples from Permanent Monitor
Wells, CLP Laboratory
Parameter s ( ug/ 1 )
KB (Aroclor 1260) *
Bis(2-Ethylhexyl) Phthalate
Carbon Disulfide
1 , 4-Dichlorobenzene
1, 1-Dichloroetnane
Chlorobenzene
Mtf-1
l.Ou
26
3.2J
lOu
lOu
lOu
Sample Location
MW-2 MW-3 W-4
2.4
2J
8.5J
lOu
10U
lOu.
l.Ou
3J
10. Ou
8.2J
3.3J
220
l.Ou
5J
10. Ou
lOu
lOu
lOu
u a none detected; value is mininun quantitation limit
J = estimated value
* PCB (Aroclor 1260) not detected in all monitor well samples by the en-
site laboratory.
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LEGEND
EXTENT OF PCB
CONTAMINATION
ABOVE 1 mg/kg
SVKMPY A*EA
• BORING LOCATION
A MONITOR WELL
AREA STAINED
WITH LEACHATE 30
/
-*-
/
30
Figure 3-3. Disposal Area Sampling Locations.
Mowbray Engineering Company Site.
Greenville, Alabama.
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ua
c
(V
C8A-
>«•
t
AQ-1
a
CENTER STORAGE AREA
C8A-3
80 A-1
in»
I
MOWBRAY ENGINEERING COMPANY
WBT-M
CONCRETE PAD
E8A-1
> X
ESA-2
WBT-
WBT-
WBI
BURIED STORAGE EBT- W
r
-'
STORM DRAIN SYSTEM
SECOND STREET
• BORING LOCATION ^
1
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-13-
Results of soil sample analyses revealed the presence of PCB (Arochlor 1260)
in both the MEC transformer processing area and in the swanp disposal area
west of Beeland Street. Levels of PCB in the soil samples range fron 54
mgAg to trace amounts in the swanp disposal area and from 62 mgAg to trace
amounts in the transformer processing area.
Other chemical compounds detected in soils from the processing area include
1, 2, 4-trichlorobenzene at levels up to 16 mg/kg, and several polynuclear
aromatic hydrocarbons (PAHs) at levels up to 15 mg/kg in the near surface.
Several metals were present at levels well within values typically found in
soils of the United States (Connor and Shacklette, 1975). Tables 3-4, 3-5,
and 3-6 present the soil sample results from the on-site laboratory and the
CLP laboratory for the processing area.
A similar suite of PAH compounds at levels of approximately 1 mgAg total
was detected in soils from the swanp disposal area. Bis (2-ethyIhexyl)
phthalate was detected, but its source may be attributed to its use in
electrical equipment. Low levels of phenol, chloroform, dichloroethane, and
trichloroethanes were detected. No dioxins, which may be formed by heating
chlorinated compounds, were detected. Tables 3-7, 3-8, and 3-9 present the
results of soil sample analyses from the onsite laboratory and the CLP
laboratory, respectively, for the awany disposal area.
•+
A pocket of oil was encountered approximately nine feet below ground surface
during the drilling of borehole C-2 in the swamr disposal area. A sample
was collected at this location for analysis for PCB, and the results showed
a concentration of PCBs at 1500 rag/tog. To determine the extent of this oil
layer, two offset borings, C2-NW and C2-S, shown on Figure 3-3, were drilled.
Oil was not observed during the drilling of the two offset borings, which
were hydraulically downgradient from C-2. On the basis of these borings,
and other borings in the swamp in general, the presence of oil is thought
to be localized and not wide-spread.
Geologic
Although no deep wells were installed during this investigation, the data
collected during the drilling program shows that a clayey sand unit interbedded
with a clay layer of variable thickness overlies a fairly thick black clay
that is believed to act as a confining layer in this area. Additional well
logs, supplied by the State of Alabama, for the Greenville area as well as a
log of an abandoned city well located in the swamp area show multiple clay
layers, up to 42 feet thick, in the top 100 feet bis around the Mowtray site
(Table 3-10). The presence of such clay confining layers indicates that the
primary aquifer for this region at a depth of over 400 feet bis is protected
from contamination.
Chemical of Concern
Based on the environmental sampling, PCBs are considered to be the only
potentially significant chemical found at the site baaed on the frequency
of detection, concentrations detected, and inherent toxicity. Several
PAHs were detected in the soils on the MBC property and the swamp disposal
area; however, since PAHs are fumed naturally by combustion they are
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-14-
Table 3-4. Analytical Results for Soil Sanples from Transformer Processing
Area, Onsite Laboratory
Sample
I1
3'
5'
PCB (Aroclor 1260) (mgAg)
Sanple Depth
10' 15' 20' 25' 30'
35'
ND - ncne detected (mininun quantitaticn lindt
Blank spaces indicate no sanple collected.
40'
45'
WBT-N
WBT-E
WETT-S
WBT-W
EBT-N
EBT-E
EBT-W
CSA-1
CSA-2
CSA-3
NSA-1
NSA-2
NSA-3
ESA-1
ESA-2
ESA-3
ESA-4
ESA-5
SDA-1
AG-1
AG-2
AG-3
AG-4
ND
9.3
36.1
ND
ND
6.8
61.7
ND
ND
ND
ND
ND
ND
ND
ND
3-2
ND
ND
ND
ND
.ND
ND
29.0
ND
ND
ND
ND
ND
ND
ND
ND
1.0
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.0
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
6.8
9.6
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
-------
Table 3-5. Organic Conpounds Detected in Soil Sanples from Transfonner Processing Area,
CLP Laboratory
ESA-1
Conpounds (mg/kg) i« 3'
Oft Alkyl-
ICi 12*0
Uractev 1240) 1 0.4*
HMNMCMM O.MM O.h.
rjfTOM U»JBI U*WI
-12L. ..». ..*
•MM (• M*/
-------
Table 3-5. Organic Compounds Detected in Soil Sanples from Transformer Processing Area,
CLP Laboratory (continued)
EBT-W
Compounds (mg/kg) 5r~
MtUtMi* PwcMt 22
1»1«M* 0.23
« Alkyl-
POi 12M
MW O.MM
•MM (Oil)
Nf»lM» O.MM
nttaUU O.MM
I1
14
27C
2.3M
2.3M
2.JM
2.3M
2.3M
J.Jy
2.3M
2.3M
Z.Jy
WBT-E
31
IS
0.72
O.Mu
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
O.Mu
15'
*
*
22M
22M
22M
22M
22«
22M
22M
22M
22M
WBT-N
1' V
10
2.2C
O.JTy
O.J7M
O.J7M
O.J7M
0.37M
0.37*
O.JTy
0.37M
O.JTu
10
O.Ofe
O.JTy
O.JTy
O.JTy
O.JTy
O.JTy
O.JTy
O.JTy
O.JTM
O.JTy
Sample Nuntoer
Depth
p „-*££ __ ,.SD^-1 ^1 CSA-1 CSA-
U
tic
24u
24y
24u
24y
24M
24M
24M
24M
24M
10 9
S.fcU
4 1C 62C
22M O.fc,
22M O.fc,
22u O.fc,
22M O.fc,
22M O.fcU
22M O.fc,
12* O.fc,
22u O.fc,
22u 0.4u
£\) i
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8JK
017 A A.
0.4lu 12
0.4IM 9.S
0.41M >.T
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0.4IM IS
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0.4IM T.JJ
0.4lu TJ
A Aiu I Bu
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1 0.0%,
O.J9u O.My
O.Mu O.Mu
O.Mu O.Mu
O.J9y O.Mu
O.Mu O.My
O.MM O.Mu
O.Mu O.Mu
O.Mu O.J9u
A *tfk.. n -uv
r
10
O.JJ
0.39u
O.J9u
O.J9u
O.JSu
O.J9u
O.J9u
O.J9u
O.J9u
I1
10
o.n
O.lSu
O.l^u
O.l-vu
0.1%u
O.liu
O.liu
O.JSu
O.lVj
1.2.4-Trlcktora-
TrlckUra-
*.4'-
(p.r'-oor)
y Mit*rlal
J MM«
• r
c ,
for
O.OlM
A <
W.V
2»J
o.22«
, but mot
O.My O.J9u O.My 0.
I.IJM
O.IW 22M 0.37M O.JTM I4J
2.3M
2.J»
O.My 22M
O.Mu 22M
O.Olu O.Mu
22u
O.JTu 0.24J 24M
O.J7y O.J7y J.2J
O.Olu O.Olu O.MM 0.27u
limit.
i*
5.* 0.4lu T.fc, O.My O.J9u O.J9u 0.3^u
O.fc, 0.4lu T.«u O.Mu O.Mu O.J9u O.Jiu
0.4lu T.8u O.Mu 0.J9u o.Mu 0. liu
l.9u O.Olu O.OSu O.Olu 0.01 O.Olu O.Olu
*QA/QC sanples
-------
-17-
Table 3-6. Metals Detected in Soil Sanples from Transformer Processing
Area, CLP Laboratory
Parameter
WBT-S
Sample Number
Depth
EBT-W ' ESA-1
- = not analyzed for
u = none detected; value is minimum quantitation liitdt
J = estimated value
NSA-2
Moisture Percent
Arsenic
Barium
Chromium
Copper
Lead
Antimony
Strontium
Vanadium
Yttrium
Zinc
Aluminum
Manganese
Calcium
Magnesium
Iron
Sodium
Potassium
Beryllium
Nickel
Cobalt
10
5.5J
7.4
16
3.2
4.4
28J
47
- .
10
5100J
85
88
150
20000
41
540
0.60U
6.1u
3.3u
21
42J
18
68
8.7
20
120J
260
-
72
16000J
540
140
350
110000
47
590
2.4
40
3.8u
22
19J
66
37
6.3
12
62
130
-
35
8700J
760
360
250
56000
19u
290
0.71
19
5.5
7
3.0u
4.1
4.7
l.Ou
4.5
3.0u
5.6
12
1.6
2.8
3900
19
160
230
5700
lOOu
-
l.Ou
2.0u
~
-------
-18-
Table 3-7. Analytical Results for Soil Sairples from Swamp Area,
Onsite Laboratory
Sanple
1'
3'
5'
PCB (Aroclor 1260)
Sanple Depth
10' 15' 20' 25'
30'
35'
40'
Al
A2
A3
A4
AS
Bl
B2
B3
B4
B5
Cl
C2
C3
C4
C5
Dl
D2
D3
D4
D5
El
E2
E3
E4
E5
C2-S
C2-NW
26
27
28
ND » none
ND
ND
6.0
ND
ND
2.0
2.6
4.8
14.0
ND
1.8
15.5
3.0
9.0
ND
ND
ND
2.5
18.0
ND
ND
ND
ND
1.5
ND
7.8
21.4
ND
2.2
7.2
detect
.ND
ND
ND
ND
ND
ND
ND
ND
1.9
ND
ND
10.0
6.6
6.9
ND
ND
2.0
3.0
25.0
ND
ND
ND
5.0
5.0
ND
ND
4.4
ND
ND
ND
ed (nri
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
19.4
ND
1.8
ND
ND
31.7
3.9
18.1
ND
ND
9.9
8.3
ND
ND
7.3
9.0
ND
p^Uf»n r
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10.2
ND
ND
ND
ND
4.2
7.0
ND
ND
ND
ND
quantil
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.2
ND
ND
ND
ND
lation
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
limit -
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1 nn/V
ND
ND
ND
ND
ND
ND
ND ND
ND
ND
ND ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND ND
ND ND
W)
Blank space* indicate no wnple collected.
-------
Table 3-8. Organic Compounds Detected in Soil Samples from Swanp Disposal Area,
CLP Laboratory
Compound (mgAg)
NoUtur* FMFrMMt
IMlMMM
fceiMMil
Oft Alkyl-
•CtMlM/4MUMlMM
KS 12*0
(AraclMC IMO)
0* Alkyl-
•U <*-*hyllMMqrl)
CtOctM-
hy4cM4aMMM
OkUMMMMMMM
(fcyfctJMlMVM
IfeMBMtlttMM
nMMMtlMM
2"""*
""TtftoMMM
ChcyMM
•MMMM (• ••*/•€ K)
nMVCMMtlMJM
•MMM-MrfytMB*
IMJMM U.l.KB)
••MM
IteyUw
kvthyl fthyl
••(•MB
MyckteriaMtMtf
•I HiMfl
»*>yi-
nuirMiM^"11
^^kthllM*
4-MMtMylflNMttl
I.I Mda.».lfc—
''•ikMM
TM«1 KylMMM
T*ldU«MMtlwl«MM
Al
I1
M
-
-
-
O.lfe
.
•.MM
-
-
O.MM
O.MM
O.MM
•.MM
O.MM
•!MM
O.MM
A ^M^Mft
•.MM
•.MM
-
O.MM
O.MM
O.MM
-
-
-
-
5'
If
-
-
-
O.IOM
*
O.MM
-
-
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
-
O.MM
O.MM
O.MM
-
_
-
-
I1
47
-
-
UJM
4.9
.
MM
- .
-
MM
MM
MM
MM
MM
MM
MM
MM
MM
MM
-
Mu
MM
MM
-
-
-
-
A2
3* 10'
M M
-
-
-
O.I) O.llu
_ _
O.MM O.MU
-
-
O.MM O.MM
O.llM O.MM
O.MM O.MM
O.MM O.MM
0 )!M 0 54w
O.MM O.MM
O.MM O.MM
O.MM O.MU
O.MM O.MM
O.MM O.MM
-
0.1 lu O.MM
O.MM O.MM
O.MM O.MM
-
-
-
-
Sample Number
Depth
A3
I1
27
-
-
-
• .2
_
27M
-
-
27u
27u
27M
27M
27u
27M
27M
27M
27u
27M
-
27u
27u
27M
-
-
-
-
3'
M
-
-
-
I.2C
_
0.44M
2JM
-
0.44u
.44u
.44*
.44M
.44M
.44u
0.44u
0.44M
0.44M
0.44M
-
0.44M
0.44u
0.44U
-
-
-
-
10'
20
0.01
VJM
A M
4JV
-
O.lluJ
_
I.JMJ
-
O.OlM
.7MJ
.7«J
.7MJ
.IMJ
.TMJ
!)MJ
.7«J
• >MJ
I.TMJ
I.7MJ
0.4M
I.7MJ
l.7uJ
I.TuJ
O.OlM
O.UlM
O.OlM
•.OlM
10'*
40
-
-
-
O.ltu
_
0.7ki
-
-
0.71u
0.71u
0.7Ju
0.7 In
0.71u
0.7Ju
0.71u
0.71u
0.71u
0.71M
-
0.7JM
0.71u
0.7K
—
-
-
-
A4
r
11
-
-
-
0.11
_
0.4ftu
-
-
0.4MU
0.4MU
0.4MM
0.4MM
O.Mu
O.MM
O.MU
O.MU
O.MU
O.MU
-
O.MU
O.MU
O.MU
—
-
-
-
5'
22
-
-
0.4JN
0.6
_
0.44u
-
-
0.44u
0.44u
0.44u
0.44M
0.44u
0.44M
0.44u
0.44M
0.44u
0.44u
~
0.44u
0.44u
0.4*o
~
-
-
-
A5
1*
H
-
-
-
0.74
_
O.M«
-
-
O.MU
O.MU
O.MM
O.MU
O.MU
O.MU
O.MU
O.MU
O.MM
O.MU
~
O.MU
O.MU
O.MU
"
-
-
-
Bl
3'
51
_
-
-
O.ltu
_
0.7Ju
-
-
0.7Ju
0.71u
0.7ki
0.7ki
0.7Ju
0.7Ju
0.7 Ju
0.71u
0.7fci
0.71u
~
0.71u
0.7Ju
0.7hi
~
-
-
-
1'
M
.
-
-
5.8
«
llu
-
-
llu
llu
llu
llu
llu
llu
llu
llu
llu
llu
-~
llu
llu
llu
-
-
-
-
3'
26
-
-
O.SJM
O.7SC
_
0.44u
-
-
O.44u
O.44u
0.44u
0.44u
0.44u
0.44u
O.44u
O.44u
O.44u
0.44u
-
O.44u
O.44u
O.44u
-
-
-
-
1.2,4-TrlckUra-
0.1
O.Wu
0.5lu
27u
0.44u
l.7uj
0.71u
O.;)u
llu
-------
Table 3-8. Organic Compounds Detected in Soil Samples from Swamp Disposal Area,
CLP Laboratory (continued)
Compound (ragAg)
HoUtura niGMJt
IbfaMM
Ot Alkyl-
•ctMf4i*lMM*
ICi 12*0
(AraClM 12*0)
01 Alkyl-
•MMBthnu*
u'**J!E2i**"1*
OtOeta-
OOMUMMMT
MffcthftlMM
IhMMthnM
nM*MtMM
I-JIBM
MM» (A)
MtteuMM
OuryMM
MM* (• M.70C K)
MUMMCMM
MM*-*-fyMM
MMM
24u
24u
24u
24u
24u
24u
24u
24u
~
-
24u
24u
24u
-
1 I
-
3'
24
*
~
~
s.t
—
27u
-
27u
27u
27u
27u
27u
27u
27u
27u
>
27u
27«
~
-
2/u
27u
27*
-
-
-
-
51
17
•*
•*
0.17
XUN
O.Mu
_
O.Mu
O.Mu
O.Mu
O.Mn
O.Mu
O.Mu
O.Mu
O.Mu
O.Mu
O.Mu
~
-
O.Mu
O.Mu
O.Mu
-
-
-
-
/\ ut _
B5
I1
la
~
—
-
0.2)
—
0.4lu
-
0.4lu
0.4lu
0.4lu
0.4lu
0.4lu
0.4 In
0.4lu
0.4lu
0.4lu
0.4lu
~
-
0.41u
0.4lu
0.4IU
-
-
-
-~
f\ XI..
3'
,.
:
-
-
O.ly
-
O.MU
.
O.MU
O.MU
O.MU
O.MU
O.MU
O.MU
O.MU
O.MU
O.MU
O.MU
~
-
O.)9u
0. Wu
O.Wu
-
-
-
~
n i
-------
Table 3-8. Organic Compounds Detected in Soil Samples from Swamp Disposal Area,
CLP Laboratory (continued)
Compound (teg/kg)
ItoUtura NcBMt
Ct Alkjrl-
•ctMydratMM*
la I2U
(ArocUr 12*0)
01 Attyl-
ItttMUt*
siSi-r"
IfeMMthnM
PlMMMtMM
fycMMi
•MM (A)
MtfcraMM
OwyMM
•MM (• «Mi/*r K)
•Mii <•*«•»
w«M>J[l.2.VOi)
•MM (CHI)
NMhjrl tUqrl
•I-MMMM/1
^^Oh. H.l-A*Mfcl«r>
nj^e*"
MMyl Butyl
HMtelat*
1,1 McfclavMCMM
I.l.l-Trldaacv-
Tot«l Xyl«MM
1,2.4-TrldOoro-
1*
22
-
SOJM
17
—
24u
24u
24u
24u
24u
24*
24M
24»
24«
24u
24*
_
~
24u
24u
24*
-
-
C2
31
it
-
2AM
12
_
24u
24u
24u
24»
24u
24u
24u
24u
24u
24*
24u
-
™
24u
24u
24>
-
-
Sample Number
Depth
C3 C4
15*
20
-
-
0.10J
— .
O.MM
O.Mu
O.MM
O.MM
O.MM
O.Mu
O.MM
O.MM
O.MM
O.Mu
O.Mu
-
"
0.1*1
O.MU
0.1*1
-
-
A «A_.
I1
II
-
-
•
_
»
24u
24>
24u
24u
24u
24*
24u
24u
24u
24u
-
"
24u
24u
24*
-
-
^4..
3'
12
-
40JN
10
_
24u
24u
24u
24u
24u
24u
24u
24u
I4u
24u
24u
-
"
24u
24u
24u
—
.
-
•»*..
15*
-
-
0.2JN
O.I)
_
O.Mu
O.Mu
O.MU
O.MM
O.MM
O.MM
O.MM
O.MM
O.MM
O.MU
O.Mu
-
"
0.1*1
O.MU
O.MU
-
-
I1
7
-
-
2»C
_
2lu
21u
2lu
2lu
2U
2lu
2 In
2lu
2lM
2lu
2lu
-
"
21u
2lu
2lu
-
-
31
it
-
IOJM
i.4
_
24u
24u
24M
24*
24u
24u
24u
24u
24u
24u
24u
-
24u
24u
24u
-
-
C5
I1
!
-
-
O.I7u
_
.Mu
O.Mu
O.Mu
O.Mu
O.Mu
O.Mu
O.MM
O.Mu
O.MM
O.Mu
O.MM
-
"
O.MU
O.MU
O.M«
-
-
3'
14
-
-
0.0*1
^
O.I4J
O.Mu
O.Mu
O.Mu
O.MM
O.MU
O.MU
O.MU
O.MM
O.MM
O.MU
-
O.MU
O.MU
O.MM
•*
_
-
f\ %A__
Dl
3'
14
-
-
0.0*1
„
O.M
O.MU
O.MU
O.MU
O.MU
O.Wu
O.MU
O.Hu
O.MU
O.MU
O.MU
-
0.1*1
O.Wu
O.Wu
-
.
-
i\ 1A. .
I1
12
-
-
0.17
.
O.Wu
O.Wu
O.Mu
O.Mu
O.Mu
O.Hu
O.Mu
O.Mu
O.MM
O.Mu
O.Mu
-
0.1*1
O.MU
0.1*1
""
_
-
n -ho..
02
3'
20
-
torn
4.K
_
0.44u
0.44U
0.44u
0.44u
0.44u
0.44u
0.44u
0.44u
0.44u
0.44u
0.44u
-
0.44u
0.44u
0.44u
~
_
-
A AA.i
10'
17
-
-
0.42
_
O.Wu
O.Wu
0.1*1
0 Wu
O.J*i
O.Wu
0.1*1
O.Wu
0.1*1
O.Mu
O.Mu
-
-
O.Wu
0.1*i
~
_
-
n 10..
D3
I1
14
-
-
17C
„
27u
27u
27u
27u
27u
27u
27u
27u
27u
27u
27u
-
27u
27u
27u
~
_
-
•>7..
24u 24u
-------
Table 3-8. Organic Compounds Detected in Soil Samples from Swanp Disposal Area,
CLP Laboratory (continued)
D3
Compound (mgAg) T1"
NalaUira PMttMt 14
TalMM*
Ct Alkyl-
•ctMy4niMM* 20JM
KB 12*0
(Araclar 1240) 2.»
Ok AUyl-
•U (2HRkylfeMjrl)
aSt?** **"
-,.**?****••* I
MffctkMM*. 24M
IfeMMtfcMM 24M
PlMMMthM* 24M
^fCVMJ 24M
•MM (A)
MtkraMM 24M
fhrj*M« 24M
•MM (» Mi/ar K>
•MM-*-ffyMM MM
WMW (1.2.XD)
•^ ^ 9Au
ryranv *•»
•MM (OU)
•KMCV&AkMt 24M
Mtkyt Kfcyl
Italy*!.?**..
(•M Ml-Ancfclor) -
mthyl-
MtltfMMM ""
riMMM* 24u
MBiyl Mtyl
IktMUtc 24u
4-mOyliPMiil 24u
1,1 DUfclinilhiMi
•tlMMM ~
Total lyl«MB
•[^ IcMofMtlM/l •»
1.2,4-Tlrlcklow
1'
,
^
•
—
JOC
O.MM
:
O.MU
O.MM
O.MM
O.MM
O.MM
O.MM
O.Mu
O.MM
O.MM
O.MM
"•
_
*
0.34u
0.3*u
O.MM
—
_
_
-
O.MU
EX
3'
,
_
~
-
A
29C
21.
^
2lu
2lM
2lM
2lM
2lM
2lM
2lu
2lM
2lM
2lM
—
.
-
2lM
2lM
2lu
•
«
-
-
2lu
I
5'
17
_
~
-
47
24u
"
24u
24u
24M
24M
24u
MM
24M
24M
24u
MM
*™
_
—
24y
24u
24M
—
.
-
-
24u
10'
ia
_
~
-
0.48
0.4u
:
0.4u
0.4u
0.4u
0.4M
0.4u
0.4M
0.4u
0.4u
0.4u
0.4M
—
_
-
0.4u
0.4u
0.4M
"
_
-
-
0.4u
E2
T1"
9
_
"
—
0.11
O.MU
—
O.MU
O.MM
O.MM
O.MM
O.MM
O.MM
O.MU
O.MM
O.MM
O.MU
~
_
-
O.MM
O.MM
O.MM
~
_
-
-
O.MU
S
E3
1'
14
_
"
-
O.l*i
O.IOuJ
^
O.Mu
O.MM
O.I4J
O.I3J
O.IJJ
O.I7J
0.47J
0.27J
0.2lu
0.25J
~
IJN
-
0.39M
O.Mu
O.MM
—
_
-
-
O.MM.
anple r
Depl
3'
u
*
"
-
O.J7C
O.Mu
"•
O.Mu
0.39u
O.Mu
O.MM
O.Mu
O.Mu
O.Mu
O.MM
O.Mu
O.MM
"
_
-
O.Mu
O.MM
O.MM
"
-
-
-
O.MU
•lumber
th
I1
24
~
"
-
2.6C
0.43J
~
0.44u
O.IJJ
0.22J
O.IU
0.44u
0.44u
0.44u
0.44M
0.44u
0.44u
'
-
0.4JM
0.44u
0.44u
0.44M
"
-
-
-
0.44u
E4
r*
14
0.002J
~
-
7.8JC
O.W
—
0.5u
O.S4
1.1
O.M
0. 16J
0.34J
O.MJ
0.0*
O.)2u
O.i2u
0.02UI
-
-
0.09J
0.52
0. 14J
0.02
O.OIJ
0.002J
-
0.52u
1'*
23
.
~
-
3.2C
0.43u
:
0.43u
0.41u
0.43M
0.4Ju
0.43u
0.41M
0.41u
0.43u
0.4Ju
0.4Ju
-
-
0.43u
0.43u
0.4Ju
-
-
-
0.4Ju
3'
17
_
—
20JN
24C
24u
:
24u
24u
24u
24u
24u
24u
24u
24u
24u
24u
-
-
24u
24u
24u
-
-
-
24u
E5
r 5'
10 6
O.Olu
— —
-
O.IBu 0.09
0.17u O.Jiu
O.Olu
0. 17u
0. J7u O.))u
0.1/u O.)5u
O.)7u O.lVi
0. )7u O.)5u
0.37u O.Jiu
0.17u 0.1 Vi
O.)7u O.lVi
0.37u O.lVi
O.)7u 0.15
O.OluR
-
-
O.J7u 0.3iu
0.17u O.liu
0. J7u O.l^u
O.Olu
O.Olu
-
0.01 0
0.17u O.lSu
- Hot MM>ly*wi for
v trial MM MMvlyiad, but not (tet*ct*4. Th«
nualMr U •lolaua
•t.
*QVQC sanpies
C DM* c«of lnM4
-------
-23-
T\able 3-9. Metals Detected in Soil Saitples from Svenp Disposal Area,
CLP Laboratory
Sample Number-Depth
Parameter (mgAg) A3-101
Moisture Percent 23
Barium • 34
ChroMum 26
Copper 2.6
Lead 15
Vanadium 20
Zinc 11
Alundnun 13000
Manganese 57
Calciun 210
Magnesium 360
Iron 2800
Nickel 7.2
Strontium 4.5
Titaniun 150
Yttrium 6.1
-------
-24-
Table 3-10. Well Log for the Abandoned City Water Supply Well
Depth of Stratum
Lithology Encountered (ft) Thickness (ft)
sandy clay
sand
clay
rock
boulders
rock
limestone
rock
clay
rock
clay
rock
clay
rock
sandy shale
clay
rock
clay
rock
clay
rock
clay
rock
clay
rock
sand *
rock
sand
rock
sand
rock
clay
rock
sand *
rock
sand
rock
sandy shale
bottom
0
8
18
55
57
64
66
75
77
80
156
168
224
235
236
242
248
249
287
288
328
330
342
343
442
450
484
486
489
494
499
500
521
523
537
538
542
543
546
8
10
37
2
7
2
9
2
3
76
12
56
11
1
6
6
1
38
1
40
2
12
1
99
8
34
2
3
5
5
1
21
2
14
1
4
1
3
* vater bearing zones
-------
-25-
ubiquitous in the environment. Although the chlorinated benzenes and
phthalates detected in soils at the site may have been associated with
past waste disposal activities at the site and chlorinated benzenes are
more mobile than PCBs, these compounds were found at relatively
low concentrations in only a few samples. Moreover, PCBs are several orders
of magnitude more toxic than either of these compounds.! Based on these
considerations, the contribution of these compounds to the several potential
risks currently posed by the site is considered to be insignificant when
compared to PCBs.
Assessing the toxicity of PCBs is complicated by the fact that several
different mixtures have been produced and distributed commercially and by
the presence in some commercial mixtures of highly toxic contaminants—
polychlorinated dibenzodioxins (PCDDs) and polychlorinated dibenzofurans (PCEFs),
Some of these contaminants can also be formed by the combustion of PCBs
or even by high-temperature conditions during service so that used
materials may be mere toxic than the oatmercial mixtures whose toxicity
has been studied.
In 1984, EPA noted that the weight of the evidence 6f the carcinogenicity
of PCBs was sufficient from animal bioassays but was inadequate from
human epidemiology studies and classified PCBs in group B2—suspected
human carcinogens- PCBs have been shown to be quite toxic to some aquatic
and terrestrial plants and animals, particularly following long-term
exposure. Information on the toxicity of PCBs to unicellular plants was
limited but suggested that effects could occur at levels less than 1 ug/liter
(EPA, I960).
Contaminant Migration and Exposure Assessment
Surface Water/Sediment. Persiimcn Creek, classified by the State of Alabama
for fish and wildlife uses (ANQ, I960), is reported to be used for
recreational fishing, although the extent of such use is uncertain.
During the field investigation phase of the RI, there were no fishermen
sighted in these waters; however/ this may be due to the tine of year of
the investigation (October-November). It is not known whether children
swim or play in Persinraon Creek, but it is probably reasonable to assume
that children play at least occasionally in this creek. Tanyard Branch
is considered unlikely to be used regularly for recreational activities
because of its nail size and inaccessibility (it is bordered by steep,
overgrown banks).
1-EPA (1986) recently calculated a potency factor of 6.9XKT4 (mg/kg/day)-1
for bis (2-ethylhexyl) pthalate; this compound is therefore over 4 orders
of magnitude less potent than PCB (potency factor -4.34 (ng/kg/day)-1).
Neither dichlorobenzene nor 1, 2, 4,-trichlorobenzene has been shown to be
carcinogenic, and these chemicals are generally not considered to be very
toxic, having reference doses (RfD) of 3 mg/day and 1.4 mg/day respectively
(EPA, 1985a, 1986).
-------
-26-
Since there were no contaminants above the I960 EPA Water Quality Criteria
in the upstream and downstream surface water sanples from Persirmon Creek
and Tanyard Branch and only very low levels of PCBs in downstream sediment
samples, in conjunction with the limited use of these streams, the potential
for significant exposure via dermal contact or inadvertent ingestion of
water by fishermen or children is considered remote.
Groundwater. The direction of groundwater flow in the study area is
toward Tanyard Branch. The swamp reportedly acts as a local discharge
point for shallow ground water, and much of the flow of Tanyard Branch is
reported to cone frcm ground water seeping along the stream bank. As
water containing PCBs in solution moves through the vadose zone and
within the aquifer, the PCBs will be adsorbed and desorbed by soils. The
net effect of these processes is that the rate of PCB transport will be
very slow, particularly compared to the rate of ground water flow.
PCBs have only been detected in one of the four monitoring wells, MW-2,
located near the eastern edge of the swamp near the drainage ditch. The
migration of PCBs from soils to ground water is controlled by the
physicochemical properties of both the PCBs and the soils, and the presence
of other organic contaminants that nay influence the solubility of PCBs.
PCBs are not very soluble in water and would bind tightly to any organic
material in soils. MH-2 shows low concentrations of PCBs; however, this
sample was unfiltered, and the level may not reflect dissolved concentrations.
Although an abandoned city well at the southeastern corner of the swampy
area could potentially serve as a conduit for vertical migration of
contaminated ground water, no PCBs were detected in the monitoring well
near this abandoned well, or the two nearest soil sanples (at detection
limits ranging from approximately 0-1 to 0.2 mg/kg). All residents in
the Greenville area are served from the city's public drinking water
system. None rely on private wells for their water supply. Therefore
the potential for exposure to PCBs via ingestion of groundwater is remote.
Soils. The most likely mechanisms by which PCBs in the soil at the MBC
property will migrate to the swamp area is via the storm sewer drainage
system - by erosion of soils to which PCBs are adsorbed and sediment transport
or by solubilization and runoff. Because of the low aqueous solubility of
PCBs (27 ug/litsr for Arcclor 1260; Mackay et al., 1963), and the high
affinity of PCBs for adsorption onto soils (log i^c » 6.83), erosion and
sediment transport are likely to be the predominant mechanism for surface
transport frca the MBC property to the swamp area. For the sane reasons,
erosion and sediment transport are likely to be the predominant surface
transport mechanisms by which PCBs could migrate from the swampy area
into Tanyard Branch. The swampy area generally drains westward into
Tanyard Branch, which borders it.
Under current use conditions, the potential for humans to come into direct
contact with PCB - contaminated soils at the MBC property or In the swamp
is not high. The MBC property is partially paved and, although there is
a fence around the property, soils in unpaved areas have been shown to be
contaminated. However, MBC has discontinued all operations and filed for
-------
-27-
bankruptcy in 1985, and there are no workers currently at the plant. The
swamp is not fenced, and no warning signs to deter users have been posted.
However, because of its unattractiveness as a recreational area (wet,
stained soils and overgrown appearance), it is considered unlikely that
the area would be used frequently.
-------
-28-
IV. ENFORCEMENT
In 1981, EPA conducted an immediate removal at the site pursuant to
Section 311 of the Clean Water Act. In 1982, the site was included on
the National Priorities List for further investigation and response
activities. In 1985, the United States obtained a money judgement against
the Mowfcray Engineering Company and its owner, dischargers of the
oil and PCBs, for the costs incurred in the 196rremoval. Later in 1985,
the ME3C and its owner filed petitions for bankruptcy under Chapter 7 of
the Bankruptcy Code. The United States filed Proofs of Claim for its
final judgement under Section 311 of the Clean Water Act and for response
costs incurred by the Hazardous Substances Response Trust Fund. These
claims are pending.
EPA has identified the potentially responsible parties (PRPs) in connection
with the site. These include the present owners of the site and the
generators of the hazardous substances (MBC and its owner). As stated
above, MBC and its owner have filed for bankruptcy under Chapter 7 of the
Bankruptcy Code, and Proofs of Claim have been filed for response costs
incurred by the Hazardous Substances Response Trust Fund. Based upon
available information, the site owners had no knowledge that PCBs were
disposed on their site. The property they own is actually a drainage
basin for the MEC facility. In addition, the site owners are not able
or willing to implement the remedy.
There have been no negotiations with the PRPs concerning the remedial
response activities at the site. Based upon the responses to earlier
notice letters sent to the PRPs, it has been determined that there
is no PRP willing and able to undertake the necessary remedial response
actions at the site. Therefore, it is recommended that the Hazardous
Substance Response Trust Fund be expended to cleanup the site.
-------
-29-
V. ALTERNATIVES EVALUATION
Public Health and Environmental Objectives
The MEC site has been inpacted by the discharge of PCB-contandnated
transformer oil from the MEC processing area, as previously discussed.
However, based on the results of the RI, it appears that PCBs at the site
are not likely to pose a significant health risk to persons having direct
contact with PCB-contaminated soils at the MEC property or the swamp under
the current use conditions of the study area. Any reuse of the MEC
property for industrial activities, or increased use of the swamp, would
be likely to lead to greater contact with contaminated soils and increased
risks to people using these areas. It should be noted that these risks
might only accrue to persons actually entering the MEC property or swanp
and becoming exposed. According to the Public Health Evaluation prepared
for this site, the relatively low levels of PCBs present in the soils of
the study area do not substantiate health related clean-up goals, under
the current use conditions of the area.
As stated, under current conditions of the MEC study area there is no
significant risk to public health. However, there is a potential for
these conditions to change in the future and to present an increased
risk. The MEC installed two-3,000 gallon underground storage tanks on
their plant property to store and recycle waste oils. Although these
tanks were not satrpled in the RI, it was discovered that oil remains in
the tanks. Because of the potential for these tanks to deteriorate over
time and release possible PCB-contaminated waste oil, these tanks
should be removed. Waste oils released may be transported to the awerop
area through the established drainage pathways or to the surface soils
surrounding the tanks and, thus, increase exposure potentials.
Additionally, a sub-surface pocket of oil in the swamp area was discovered
during the RI. The oil, which contained 1500 ppm of PCBs, may migrate to
the surface soils or into Tanyard Branch via erosion or sediment/soil
transport. This pocket was determined to be localized; however, there is
the potential for ^Mitirrml localized oil pockets to be present since
the sampling effort was conducted on an approximate 75-foot grid system.
The presence of additional pockets would increase the potential of exposure.
PCB-contaminated soils in the swamp area may also be transported into
Tanyard Branch via surface runoff and/or erosion. Therefore, remediation
of the site is necessary to prevent the potential for increased exposure
by this route.
Severe environmental impacts have been seen as a result of contamination
originating from the MEC site. The vegetation in the swamp area is
stressed, and part of the area is completely bare. In 1961, Tanyard
Branch was reported to be completely devoid of aquatic life downstream
from the site. Two components of the site-related contamination could
contribute to the effects seen—the transformer oils and PCBs. The
-------
-30-
presence of oil in the soils is probably responsible for the vegetative
stress and lack of vegetation in certain areas of the swanp, since PCBs
are not present at phytotoxic concentrations. The acute aquatic effects
seen in the past were probably due to the oil overflows rather than the
presence of PCBs in the oil. The low concentrations of PCBs detected to
date in the sediments would be unlikely to result in water column
concentrations of concern. Remediation of the site would be necessary to
restore the vegetation in the swanp and to protect aquatic life downstream
of the site.
Technologies Considered
Remedial response technologies have been identified to address the contamination
present in the study area of the MEC site. These technologies include
processes for the treatment or disposal of the contaminants. Technologies
were divided into broad categories, which are listed below, according to
their applicability to the problem. The response technologies
are presented in Table 5-1.
* Technologies for treatment or disposal of contaminated soils
0 Technologies for treatment or disposal of waste oils
0 Technologies for remediation of storage tanks "
Several combinations of these technologies will formulate remedial action
alternatives that fully comply with other appropriate environmental laws.
For instance, an alternative that addresses the contaminants in the soils
by onsite incineration, remediates the waste oils in the underground
storage tanks and in the subsurface oil pocket by the PCBX system, and
removes and disposes of the storage tanks to an approved landfill will
comply with the requirements of the Toxic Substances Control Act (TSCA)
and the Resource Conservation and Recovery Act (RCPA). During the RI it
was established that air quality at the site was not affected by the
contaminants present and, therefore, the requirements of the Clean Air
Act (CAA) are not a concern. Similarly, it was determined that the
groundwater of the study area has not been impacted and, thus, the Clean
Water Act (CWA) is also not a concern.
Other regulations that may apply are the Department of Transportation (DOT)
Hazardous Transport Rules for the transportation of hazardous material
to a treatment, or disposal facility and the appropriate state and/or
local regulations for the en-site operation of a treatment or disposal
facility.
Technology Screening
This section presents a screening of technologies for treatment or disposal
of contaminated soils only. Because of the beleived limited extent of
waste oils at the site, the screening of technologies for the treatment
or disposal of contaminated oils found in the subsurface swamp soils and
in the storage tanks will not be performed in accordance with the FS
-------
-31-
Table 5-1. Applicable Response Technologies
1. Technologies for Treatment or Disposal of Contaminated Soils
a. excavation
b. site drainage diversion (permanent diversion of surface runon
around the swamp area)
c. offsite disposal
d. offsite incineration
e. surface capping
f. onsite solvent extraction
g. onsite stabilization/solidification
h. onsite containment/encapsulation
i. onsite incineration
j. site restoration (grading & revegetation of the swanp area; proper
closure of the onsite abandoned city well; institutional controls,
as necessary)
2. Technologies for Treatment or Disposal of Waste Oils
a. Acurex system
b. PCBX system
c. ozonation
d. incineration
3. Technologies for Remediation of Storage Tanks
a. excavation/removal
b. disposal
-------
-32-
guidance and is not included. However, it should be noted that a TSCA-
approved technology for treatment or disposal of waste oils encountered
during remediation will be cannon to all alternative actions, except
the no action alternative. Technologies associated with storage tank
remediation are also not included because of the consideration of only
one alternative for remediation - excavation/removal and disposal.
The screening of soil technologies was performed in accordance to 40 CFR
Part 300.68 (g). More specifically, the screening used the broad evaluation
criteria of technical feasibility, public health and environmental
protection, and cost. By performing the screening process based on the
above criteria, those technologies that did not provide adequate protection
to the public health and environment, or cost substantially more than
other technologies without providing significantly greater benefits, were
eliminated.
Technologies Eliminated. Upon completion of the technologies screening,
two technologies were eliminated. These are:
* surface capping
• onsite solvent extraction
Surface capping can be an effective method for preventing erosional transport
of contamination and dermal contact with contaminated soils. However, the -
swamp is situated within a 100-year flocdplain, and occasional flooding
of the area will decrease the effectiveness of the cap. In addition,
groundwater seepage from the swamp ia a predominant means of infiltration
to Tanyard Branch. This win cause erosion of soil beneath the cap and
potential collapse of the cap. The overall effectiveness of surface
capping is rated low due to this and to the potential for continued
erosion of contaminated soils. Furthermore, surface capping will result
in a permanent increase in surface runoff which must be handled. Therefore,
this technology has been eliminated.
Attempts to extract soil contamination with solvents have had mixed
results. Because of this and because there is no long-term data for the
on-site solvent extraction process, its effectiveness and reliability are
rated lower than processes for which long-term operating records are
available. A by-product of this process is a waste solvent which would
contain high concentrations of PCBs. The waste solvent must be further
treated or disposed. Preliminary indications are that, due to the relatively
low levels of PCBs present at this site, several washings of soils nay be
necessary to obtain the desired decontamination, which would result in
significant cost increases. The number of washings can only be determined
by field testing the actual soils. This technology is not retained for
further consideration based on the above discussion.
Technologies Retained. Upon completion of the screening of technologies
for the treatment or disposal of contaminated soils* two technologies
were eliminated. The retained technologies presented in Table 5-2 will
be combined to form remedial action alternatives for a detailed analysis.
-------
-33-
Table 5-2. Retained Technologies for Treatment or Disposal
of Contaminated Soil
a. excavation
b. site drainage diversion
c. offsite disposal
d. offsite incineration
g. onsite stabilization/solidification
h. onsite containment/encapsulation
i. onsite incineration
j. site restoration
-------
-34-
Ranedial Action Alternatives Considered
The technolgies retained after the technology screening process (Table 5-2)
were combined to form seven remedial action alternatives. Conrnon to all
alternatives, except the no action alternative, are excavation and removal
of the underground storage tanks on the MEC property and remediation of
contaminated waste oils. Therefore, these components will not be repeated
in the discussion of each alternative. The seven alternatives are presented
in Table 5-3.
Detailed Analysis of Remedial Action Alternatives
Analysis Criteria. In accordance with the National Oil and Hazardous
Substances Contingency Plan (NCP), the seven alternatives were analyzed
based on important cost and non-cost factors, such as performance, reliability,
implementability, institutional requirements, and public health and
environmental considerations. These analysis criteria provide for the
determination of the most technically feasible, cost effective remedy
that adequately protects public health, welfare, and the environment.
In addition to considering such cost factors as capital and operation and
maintenance, the results of a sensitivity analysis were also considered -
in the overall cost of each alternative. The purpose of the sensitivity
analysis is to assess the effect of variation in specific assumptions
associated with the cost estimates of the remedial action alternatives.
The sensitivity analysis is especially concerned with factors that could
bring significant changes in the overall cost with only a small variation
in value. Determination of a distinct cleanup goal for the MBC site is
considered to be the most sensitive factor affecting costs of the various
alternatives. The estimated soil volume requiring treatment is dependent
on the level of contamination cleanup achieved. For cleanup levels of
10, 20, 30, and 50 mg/kg of PCS, the estimated soil volume requiring
treatment is presented in Table 5-4. Cost estimates for each of the
alternatives are presented for each of the four cleanup levels in
Table 5-5.
Alternative Analysis. The remedial action alternatives developed from
the retained response technologies to address the conditions at the MBC
site study area have been analyzed according to the criteria mentioned above.
The results of this analysis are shown in Table 5-6. The alternatives
are discussed below.
0 Alternative 1 - No Action: This alternative implies that there
is no threat posed by the contaminants present at the MBC site
and that no remedial action will be implemented. Contaminated
soils would remain in place and continue to be a means of
environmental and public exposure by erosion of contaminants
above acceptable levels into Tanyard Branch and the accessibility
of contaminated soils to dermal contact. Runon would not be
-------
-35-
Table 5-3. Ranedial Action Alternatives Considered
for Detailed Analysis*
Alternative 1 : No Action
Alternative 2 : Site Drainage Diversion
Alternative 3 : Offsite Disposal
Alternative 4 : Offsite Incineration
8 rotary kiln-type
8 infrared-type
Alternative 5 : Cnsite Stabilization/Solidification
Alternative 6 : Cnsite Containment/Encapsulation
Alternative 7 : Cnsite Incineration
* rotary kiln--type
• infrared-*ype
* Ccrponents canton to all remedial action alternatives include:
0 treatment or disposal of contaminated waste oil
0 remediation of storage tanks
-------
-36-
Table 5-4. Effect of Cleanup Levels on Estimated Soil Volumes
Requiring Treatment
Cleanup Level
(rag/kg)
10
20
30
50
Soil Volume
Swamp Area
12,100
4,300
800
0
Requiring Treatment
MEC Property
800
500
300
100
(cy)
Total
12,900
4,800
1,100
100
PCB Removed
(Ibs)
61.6
35.3
11.3
1.6
-------
-37-
T^ble 5-5. Cost Estiimtes for Remedial Action Alternatives ($1000)
Alternatives
1.
2.
3.
4.
•
e
5.
6.
No Action
Site Drainage Diversion
Capital Cost
0 & M Cost
Tbtal
Offsite Disposal
Capital Cost
0 & M Cost
Total
Offsite Incineration
rotary kiln-type
Capital Cost
0 & M Cost
Total
infrared-type
Capital Cost
O & M Cost
Tbtal
10
__
*
8,558
8
8,566
51,409
8
51,417
4,110
8
4,118
Cleanup Level (mg/kg)
20 30
__
3,278
8
3,286
19, 279
8
19, 287
1,627
8
1,635
__
. i ")") _ — ___.
8_ _ _ _ _ .
. 1 "3D — — — — — .
871
8
879
4,575
8
4,583
502
8
510
50
__
212
8
220
558
8
566
192
8
200
Cnsite Stabilization/Solidification
Capital Cost
0 & M Cost
Tbtal
1,992
310
2,302
842
232
1,074
337
232
569
194
156
350
Cnsite Containment/Qicapsulation
Capital Cost
0 & M Cost
Tbtal
733
950
1,683
387
475
862
256
318
574
190
158
348
-------
-38-
Table 5-5. Cost Estimates for Remedial Action Alternatives ($1000), (cont.)
Cleanup Level (mgAg)
Alternatives 10 20 30 50
7. Onsite Incineration
8 rotary kiln-type
Capital Cost
0 & M Cost
Total
' infrared-type
Capital Cost
0 & M Cost
Total
9,953
8
9,961
3,706
8
3, 714
3,805
8
3,813
1,474
8
1,482
996
8
1,004
458
8
466
226
8
234
178
8
186
* This alternative does not attain a specified cleanup level; therefore, a
sensitivity analysis based on cleanup levels was not performed.
-------
Table 5-6. Suimary of Remedial Action Alternative Analysis
Alteraat 1»«
Technical Paeelblllty
(•wire
ante I lapect
Public Health Coocerae laatltuttonal tequlreewnta
2. Sit.
Dralaafe
Diverale*
1. Offatte
DIaeoeal
4. Offalta
laclaaratloo)
•educed rlik of PCS related
layacle. Poteatlal laeacte
(• wet lead vegetatloa aad
Taayard preach flood plala.
Effective aa* nllflMa (or
preveajtlaa) •! a*lt ereelea.
Prove*, effect l»«, ••ally Nlalael lapact at new elle.
taa>lee>ea*ed. reaanae ceo,- (educed laa*ct ec e> let lag
ta»lMtle« free) elte te elle. Lew •••IreewoMat
•OU e»re>e« feclllty. rleke OM te •eeelellltr of
•fill* 4«rlM treeieeeretleo..
•educed rlek of public •«-
a«aure ky ereeloa ratkvey*
However, ceotaolaaate are
left ooalta.
Slgalflceat public heelth
rlek redwctlea) by rea»val
of PCee aad plecaaaat la a
aocured laadflll.
State drainage rcfulatlona, IX>T
Hatardoue Helcrlela Traaaport
••lea. TSCA. Pederal Mater
Quality Criteria. Claee Air Act.
AOCN regulation*.
Sea* ee Alternative 2.
Very effective, reliable, Pe tea* I el aetirce of air
aa4 le»leaieteele If take* aollMleei. Cavlroe
to oeraaaea* facility. rlak free) traaaportla«
Moot la facility at aaatbair haeeraoaa •atarlala.
alte la rata4 ellgMly tar* rlak reeoctleo Ate te
leae reliable aa4 laola- PCi oeatr»ctlaa.
eiee)tafcla.
Higher rlak redwctlea) than Saeve aa Alternative 2.
altaritat Ivea which atore Clean Air Act
oaelte or effalte. Short-
t«ra rlak froa traaaaort-
lag haaardeaa e>aterlela aad
OBCaval tea.
Qaalta Peaelkle aaa) laytaajeateblo
SolId!fleet lea/ Oaoe aac treat waate, bat
Stablllaatla* casflMa It la a aetrU
•Atck B€ewoa>te lataractlaai
Kith tao. aajvl
4. Oawlto Oaed eHteetelvely at aeal-
Caatelajnat/ tary aa4 ckealcel waate
•acaoawlatlaai Iaa4fllla. Creater opera-
tlaa> and amlateeeace
roaaili
lacreeaed raaoff ead loee
of laflitre!lee cepaclty
•ay altar (load plala
character let Ice. Peraaaaat
laaa at wet Iaad reaourcee
la area where eel la are
aelldlfled.
Poteatlal eavlrpaaaatal la-
pact If Hear laaka. la-
creeeed rwaaff aad laea
laflltretloa aay altar
flaad plala aad watlaad
characterlet Ice.
•lak reductloa by ere-
vealloa of coataailaaat
Ireaeaort. Saell aoael-
blllty of ceMaa>laaa4a
laachlag ewt.
•lek reductloa aot ae
(real aa alleraatlvea
which treat or raaeve
caataalaatloa.
Seae ee Alternative 2.
aa AlternalIve 2
7. Oajelte Highly effective and rail- Poeelble eeurce of elr pol- Air pollulloa aad rlek
laclaaretloa able Ojathed far PCI da- latlaa. Seeva rlek aaaocl- eaeocleled with dlapaae
etrwctloa. Here coeialeii
eoeretleo. aa4 greeter
awhile aa*oaltlaa.
latlaa. Sao-e rlek aaaocl- oaeocleled with dlapaaal
eted with ultlaata dlepoeel of eah aad aludge free)
of waete product a (eah ead laclMratar. Leaif-taro)
eludge). Lo«|-terei rlek rlek redwctlea due te PCI
reductlaa, due to PCB deatructloa rather thea
deetructloa. atorage er elapoaal.
ea Alternative 2.
Clean Air Act
-------
-40-
diverted around the swanp area, causing drainage from the surrounding
watershed to continue to aid erosion and contaminant transport from the
swamp. Also, the underground storage tanks would remain in place and
serve as a potential threat of future release of PCB-contaminated oil
into the environment by the deterioration of the tank. This
alternative has been considered under the mandates of the NCP, however,
based on the results of the RI and the above discussion, this alternative
would not meet the public health and environmental objectives.
Alternative 2 - Site Drainage Diversion: This alternative consists
of site drainage diversion and site restoration, in addition to the
components canton to all alternatives. This alternative does not
attain any specified cleanup goal. However, prevention of further
spreading of contamination is achieved by removal of the underground
storage tanks, treatment or disposal of waste oil, site drainage
diversion, and site restoration (revegetation). These preventative
measures are permanent and will reduce short-term and long-term
threats to nearby ccnnunities and limit the area of PCB related
environmental impacts. The exposure pathways of dermal contact and
incidental ingesticn are prevented by a vegetative barrier between
the contaminated soils and persons entering the site. Revegetation -
and drainage diversion will prevent contaminant migration via erosion.
However, the swamp area is located within a 100-year flood plain and-
diverting drainage around this area nay result in minimal alteration
of swamp vegetation or shape of the flocdplain.
Alternative 3 - Offsite Disposal: This alternative includes site
drainage diversion, excavation, offsite hauling, offsite
and site restoration. Specifically, this alternative removes
contamination above a specified cleanup level to an approved hazardous
waste facility, and therefore, is highly effective in
meeting cleanup goals at the MBC site. The remediation is permanent
for the existing site; the reliability is rated high, as offsite disposal
is a simple and proven technology. Since this alternative does not
involve installation of sophisticated and complex treatment systems
onsite, it is considered relatively easy to implement. Offsite
disposal of contaminants eliminates the potential for exposure
and contaminant migration at the existing site. Transportation of
the hazardous materials will result in a small risk to public health
and the environment along the transportation route.
Alternative 4 - Offsite Incineration: This remedial alternative
involves site drainage diversion, excavation, offsite hauling, offsite
incineration, and site restoration. Two offsite incineration technologies
are being considered. The first consists of transportation and
incineration at the rotary kiln facility in El Dorado, Arkansas.
The second consists of incineration at another EPA site where a mobile
infrared incineration system will be in use.
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Due to the success of test burns and full scale operations,
incineration is considered a technically reliable and effective
method for destroying PCB in contaminated soils, thereby preventing
future exposures and migration at the existing site and the
incineration site. Therefore, this alternative is rated more
effective than alternatives vdiich store contamination.
Offsite incineration has a high potential for public health and
environmental risk reduction since the process results in the
destruction of PCB contaminants. There -is a small risk to public
health and the environment associated with the excavation and
transportation of contaminants.
Alternative 5 - Onsite Stabilization/Solidification: This alter-
native consists of site drainage diversion, excavation, onsite
stabilization/ solidification, and site restoration. The purpose
of solidification is to transform the hazardous waste into a
physical form (monolithic block) which is more suitable for on-site
storage and reduces water permeability into the waste. The
solidified matrix acts as a barrier between the waste particles
and the environment. Erosion control is required for this technology.
Since this alternative would store contaminants permanently
onsite/ it is considered leas effective than treatment or disposal.
Solidification is not mechanically complex; however, significant
material testing and monitoring would be required during design
to assure that contaminants will not leach from the solidified
matrix. Future failure of the cement bond by mechanical or chemical
sources could cause a minor release of contaminants. Meeting the
technical permitting requirements for this alternative may be
extensive due to storage of contaminants and solidification of
soils in a 100-year floodplain.
The overall consequence of solidification is reduction of risk by
decreasing exposure to contaminants transported by surface or ground
waters. The degree of reduction depends on the extent of the material
solidified and the effectiveness of the process. Long-term threats
may result from increased site runoff, such as downstream flood
plain alteration.
Alternative 6 - Chsite Containment/Encapsulation: Site drainage
diversion, excavation, onsite containment/encapsulation, and site
restoration comprise this alternative. The purpose of containment/
encapsulation is to limit the leachability of the toxic materials
by physically keeping water from contacting the contaminated
material. This is done by sealing off contaminated areas with
impermeable liners and is considered technically feasible. However,
this option is considered storage, and therefore, is less effective
than technologies which fix, remove, or treat contamination. To
assure reliability, a monitoring schedule must be maintained and
the structural integrity of synthetic liners and the surface cap
must be frequently verified. Meeting the technical permitting
requirements may be extensive due to the storage of contaminants
in a 100-year floodplain.
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Public health risk is reduced through provision of a barrier to
exposure and migration of contaminants. Environmental risks
associated with contamination are traded for permanent affects on
site vegetation and runoff. Since no material is 100 percent
impermeable, the level of risk reduction may not be conplete.
The degree of risk reduction is proportional to the effectiveness
of the process.
Alternative 7 - Onsite Incineration: This alternative involves
site drainage diversion, excavation, onaite incineration, and
site restoration. Due to the success of test burns and full
scale operations, this option is a reliable and effective method
for destroying PCB found in soils and contaminated oils- Two
systems are being considered - a rotary kiln-type incinerator and
an infrared-type incinerator. There is a snail incremental risk
associated with the handling of incinerator sludge and scrubber
wastes. This increase would only affect the individuals involved
with the ultimate disposal of the waste, however. Local opposition
to incineration may make local acceptance of this alternative
difficult. However, there does not appear to be any federal
permitting requirements that would prohibit use of this alternative
if properly implemented.
Public health and environmental risk is reduced by destruction of
contaminants exceeding the cleanup goal. Onaite incineration
eliminates the transportation risk associated with offsite
incineration while providing the same effective and permanent
treatment.
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VI. COMMUNITY REIATIONS
Identifiable comunity concerns regarding the MEC site have been
limited. Public reaction to the EPA activities associated with the
CWA section 311 action in 1981 can be divided into three categories:
residents living near the site, or downstream of the
contaminated swamp area, who were concerned about hazards
associated with possible PCB exposure.
citizens who downplayed the contamination problem and tended
to view EPA's presence at the site as a typical example of
unnecessary government spending.
other members of the cantunity who followed press coverage
of the site, but did not feel strongly one way or another
about the site.
Owners of the swamp area took an active interest in EPA's site
activities. Property owner Boyd Foster informed EPA in July 1981
that he wanted an Environmental Impact Statement and Corps of
Engineers permit issued before the CWA Section 311 activities were
initiated at the site. At that tine, Foster stated that he would
not grant EPA site access unless these demands were met. After
conversations with EPA legal staff members regarding CWA requirements,
however, Foster and his partner Erastus Talbert agreed to let EPA go
ahead with its plans to excavate, divert, ditch, and backfill the
swamp area.
Press coverage during 1981 of EPA and ADEM activities at the MEC site
was fairly extensive. Both the Birmingham News and The MonLgaiiery Advertiser
carried stories about EPA's site plans and provisions for financing
the cleanup action. The Greenville Advocate also covered initial
site activities, but eventually stopped giving the site much attention
because its editors felt that EPA was "playing toward the Montgomery
and Birmingham press" and ignoring the local media. According to
Gene Harden of The Advocate/ the local newspaper was tired of finding
out about site activities by reading the Birmingham and Montgomery
newspapers. During 1961, EPA officials participated in a call-in
radio talk show on WKXN, the local Greenville radio station. EPA
officials responded to numerous questions from area residents
during the talk show, with the majority of questions pertaining to
dangers of PCS contamination and EPA's plans for the site.
Several community concerns existed following completion of the 1981
activities. Area residents were left with the impression that no
further contamination would be present at the site. Therefore, many
felt that no further response activities were necessary. Additionally,
area residents and local officials do not feel that they were adequately
informed about the site developments during response activities in
1981. Red Etheridge, Mayor of Greenville during the 1981 action,
stated that most of his information about site activities came from
his own contacts in the state government.
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-44-
Gene Harden of the Greenville Advocate claimed that his staff felt
EPA was more concerned with media representatives in Birmingham and
Montgomery than the local press. Lastly, many citizens did not feel
the response activities taken in 1981 were warranted. These sentiments
were combined with what local officials call a tendency to view the
presence of Federal officials and contractors as "a nuisance" and,
generally speaking, a waste of taxpayers' money.
With these thoughts in mind, comunity relations activities conducted
during the RI/FS were directed at keeping State and local officials
informed of activities being performed by EPA; informing area residents,
local news media, and other interested citizens of the progress and
results of the RI/FS; providing opportunities for the citizens to
content on the proposed field work, site documents, and remedial
alternatives; and establishing a public repository for all site
information.
To carry out the objectives stated above, an information repository
was established in August 1985 at the Greenville Public Library to
house all site information and documents. This repository is available
to the public during the normal working hours of the library.
Four fact sheets were nailed to citizens on the MEC nailing list at -
critical points during the RI/FS: before the Public Meeting conducted *
to present the Work Plan; after the RI field work was completed;
after the laboratory analytical results were received; and before the
FS Public Meeting.
Frequent telephone conversations were held with the PRPs for the
site, the Mayor of Greenville, and ADEM to provide current site
information and update the status of the site activities.
Crie anonymous letter was received by EPA. during the perfornance of
the RI/FS. This letter was signed "a concerned citizen of Greenville"
and expressed concern over the potential for diorLn to be present in
the swamp area and for the widespread use of MEC oil for the control
of dust, termites, wocdo and mosquitos in the Greenville area. The
RI determined that dioxin is not present in the soils of the swamp,
and these results were reported to the citizens.
As mentioned above, two public meetings were held to disseminate
information to the public. The first was held on August 27, 1965
for the purpose of explaining to the public why further response actions
are necessary for the site, presenting the Work Plan that describes
the proposed field activities, and soliciting public input on the
proposed actions. All Garments received were responded to. The second
meeting was held at the completion of the Draft RI/FS Report. Two
weeks prior to the meeting, this document was placed in the MEC information
repository and a Fact Sheet was mailed to the mailing list. The
meeting was held on August 12, 1986 at the Beeland Park Conrunity
Center. The results of the RI and all remedial alternatives under
consideration were presented to receive ccmnents. This marked the
beginning of a formal 3-week public cement period.
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Curing this Public Meeting, cements were received pertaining to the
alternatives presented, the cost of the RI/FS, and the current status of
the CERCLA reauthorization and funding for the MEG remedy. The overall
feeling of the citizens present was that EPA has spent too nuch money on
this site, and they supported no-action (Alternative 1) or limited action
(Alternative 2).
Only one written cotment was received during the-3-week public comment
period which concluded on September 2, 1986. The writer expressed the
opinion that most of the citizens who attended the Public Meeting favor
the no action alternative. The Responsiveness Sumary is attached as
Appendix A.
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VII. CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
In selecting remedial action alternatives, primary consideration must
be granted to remedies that achieve applicable or relevant and appropriate
environmental and public health standards. For the MEC site, such
laws and guidelines include:
- Toxic Substances Control Act (TSCA)
- DOT Hazardous Material Transport Rules
- Resource Conservation and Recovery Act (RCRA)
- Clean Air Act (CAA)
- Clean Water Act (CWA)
Specifically, contaminated soils, waste oils, and the underground
storage tanks removed from the MEC study area would be disposed in a
TSCA-approved waste facility. The level of PCBs that remain in the
onsite soils after excavation would be consistent with the proposed TSCA
regulations. Similarly, for incineration of contaminated soils, the
requirements of TSCA that pertain to incineration of PCBs would
be met.
For the alternatives which include transportation of contaminated
soils and waste oils, the DOT Hazardous Material Transport Rules require
that the proper labeling and safety requirements be implemented.
•
PCBs are not currently listed as a hazardous waste under the RCRA
regulations and, therefore, there are no requirements of RCRA that
are applicable to the remedial action alternative selected for this
site. However, if the stabilization/solidification or encapsulation
alternative is selected for site remediation, we should comply with
the RCRA requirements for closing wastes in place, as the requirements
nay be relevant and appropriate. Since the swarap area is situated in
a 100-year floodplain, floodproofing requirements for closing wastes in
place should be taken into account when designing the remedy.
During the incineration of PCB-contaminated soils, air quality monitoring
must be performed to ensure that the emissions from the incineration
process do not exceed applicable standards specified in the CAA. A
quality assurance/quality control plan that will specify the standards
that must be adhered to and the emmissions monitoring method employed
will be developed during the detailed design of the remedy.
Finally, the CWA sets forth water quality criteria that have been
developed to protect freshwater aquatic life. In order to ensure
that the criteria for PCBs in surface water is not exceeded by
erosion/sediment transport of contaminated soils from the swamp area
and dissolution of PCBs front the sediments to the surface water, the
contaminated soils will be removed from the swamp area to a level
adequate to protect aquatic life in Tanyard Branch.
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In 1966, the U.S. Fish and Wildlife Service conducted a survey of
Department of Interior trust responsibilities for natural resources at
the MEC site. This survey followed a preliminary survey conducted in
1985 and verified its conclusions. It was concluded that no resources
under the trusteeship of the U.S. Fish and Wildlife Service are known to
occur in any area that could be affected by PCBs discharged from the MEC.
Table 7-1 illustrates the applicability and conpliance of each remedial
action alternative considered with the various environmental laws and
guidelines.
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Table 7-1. Consistency with Other Environmental Laws
Toxic Substances Control Act (TSCA)
Resources Conservation and
Recovery Act (RCRA)
DOT Hazardous Material Transport
Rules
Clean Air Act (CAA)
Clean Water Act (CWA)
Safe Drinking Water Act (SEWA)
Alternatives
123456
X
X
X
X
N
X
N
X
c
X
N
X
c
X
c
X
c
X
c
X
c
c
c
X
c
X
c
X
c
X
c
X
c
X
c
X
c
X
c
c
t
X
C a Compliance
N » Non-conpliance
X = Not applicable
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VIII. RECOMENDED ALTERNATIVE
The remedial action alternative reccmnended for the MEC site is excavation
of soils contaminated above 25 ppm PCBs from the swamp disposal area and the
transformer processing area and either onsite or offsite incineration
using an infrared-type incinerator. The alternative will also include
site drainage diversion, storage tank removal, remediation of waste oils
encountered in the swamp area and in the storage tanks, and site restoration
(Alternative 4 or 7). There are several unknown operating details of the
infrared-type incinerator that need to be specified in the detailed
design of the remedy. If these details prove this type of incineration
unsatisfactory, stabilization/solidification of the contaminated soils
above 25 ppm PCBs will be the recommended alternative, along with the
other components described above (Alternative 5).
Incineration of PCB-contaminated soils using the infrared-type incinerator
is the preferred method for soil remediation. This method allows for
complete destruction of PCBs in the soil, resulting in maximum risk
reduction, thereby being a permanent, cost-effective solution. The
infrared-type incinerator operates without the intake air and fuel requirements
associated with the rotary kiln-type incinerator. Consequently, air
handling stacks and scrubbers can be reduced, and air emissions from the :
burning of fuel are eliminated. Fran preliminary estimates, this method
is more cost-effective than the rotary kiln-type and appears to be
an effective method for the level of PCBe present at the MEC site.
This alternative also would not require long-term operation and maintenance
(0 & M) measures and will not create the uncertainties associated with
offsite disposal or in-situ containment (encapsulation).
As mentioned, several operating details of the infrared-type incinerator
are as yet unknown. These parameters include cost, acceptance of the
contaminated soils at the offsite location, and the ability of the
incinerator to meet the technical requirements of the TSCA permit.
Stabilization/solidification has been retained, therefore, as a reccrmended
alternative should the infrared-type incinerator prove to be unsatisfactory.
This method would entail solidifying (fixing) the contaminated soils into
a permanent matrix for placement and storage in the swamp area. This
method has been proven effective as a permanent solution that limits the
solubility, toxicity, and mobility of the contaminants. This is a cost-effective
method but, due to the uncertainties associated with long-term monitoring
to ensure that no contaminants are leaching into the environment, this
alternative is not as effective as incineration and should only be implemented
if incineration is not feasible. Stabilization/solidification is selected
over encapsulation (Alternative 6), which is also a cost-effective method
that stores contaminants onsite, because encapsulation does not permanently
fix the contaminants as solidification does. Encapsulation encloses the
waste with a liner that requires extensive long-term monitoring and liner
maintenance to maintain its integrity.
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The cleanup level of 25 ppm PCBs has been chosen for the contaminated
soils in the MEC study area to be consistent with the proposed TSCA
regulations. These regulations require that soils in an industrial
area that have experienced previous PCB-contaminated oil spills be
remediated to a level of 25 ppm of PCBs. For this site, remediating
the soils to a 25 ppm PCS level is feasible and will result in adequate
protection to public health, welfare, and the environemnt.
In contrast, the no action alternative (Alternative 1) or the limited
action of the site drainage diversion alternative (Alternative 2) do not
require remediation of the contaminated soils in the study area.
Contaminated soils would remain onsite and continue to be a threat to
public health and the environment. For this reason, these alternatives
are not recommended for remediation at this site. Alternative 3, Offsite
Disposal, is also not recommended for remediation of this site. This
alternative removes contaminated soils above the 25 ppm cleanup level to
an approved waste facility, and therefore, is highly effective in meeting
the public health and environmental objectives at the site. This remedy
is permanent for the existing site; however, contaminants are not destroyed
or detoxified - merely transported from one site to another. The alternative
is also not cost-effective in comparison with the recommended alternative.
As mentioned above, in addition to the recommended method for remediating
contaminated soils, several other components comprise the recommended
alternative. Site drainage diversion will consist of a diversion channel
and grassed waterway with a stone center for permanent diversion of
surface water runon around the contaminated swamp area. Drainage diversion
is necessary to prevent continued erosion of contaminated soils from the
swamp area to Tanyard Branch. The underground storage tanks on the MEC
property will be excavated, removed, and disposed in an approved waste
facility. This will prevent any future release of KB-contaminated oil
into the environment from the deterioration of the tanks. Any waste oils
found in the tanks will be collected, analyzed for PCBs, and treated or
disposed according to TSCA regulations. Similarly, the pocket of oil
discovered in the swamp disposal area will be collected, analyzed, and
treated or disposed. Any additional oils encountered during remediation
of the swamp area will be handled in the same manner.
Upon completion of the remedial action implementation, the site will be
restored. This will consist of backfilling, grading, revegetating, and
fertilizing the swamp area and backfilling and grading the area of the storage
tank removal. In addition to this, the abandoned onsite city supply well
will be properly closed according to ADEM well closure regulations.
Although no contamination was found in the area of this well or in the
groundwater, proper closure of the well will ensure that contaminants
that may migrate to this area via erosion/sediment transport do not
migrate down the well casing and contaminate the public water supply.
Additional controls, such as fencing the area or land use restrictions
will be identified during the detailed design of this remedy, if necessary.
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0 & M requirements for the recotmended alternative consist of maintenance
of the drainage diversion ditch and the revegetated area. If
stabilization/solidification is implemented, 0 & M activities will also
include maintenance of the soilidified matrix and long-term monitoring to
ensure that the contaminants are not leaching from the matrix.
The estimated cost of the recontnended alternatives, which include soil
cleanup to 25 ppn PCBs, plus the estimated cost for 0 & M are as follows:
Alternative 4: Offsitc Incineration - $1.2 million to $2.0 million
Alternative 7: Onsite Incineration - $1.1 million to $1.8 million
Alternative 5: Stabilization/Solidification - $0.75 million
According to 40 CFR Part 300.68(i), the appropriate extent of remedy
shall be determined by the lead agency's selection of a cost-effective
remedial alternative which effectively mitigates and minimizes threats to
and provides adequate protection of public health, welfare, and the
environment. The recommended alternatives are cost-effective while
providing complete destruction of the contaminants or permanent fixation
of the contaminants in a matrix, and thus, result in maximum risk reduction
to public health, welfare, and the environment. The alternatives considered
in this document that could be implemented at a lower cost do not provide
adequate protection to public health, welfare, and the environment.
Other alternatives may meet the public health and environmental objectives -
but do so at a higher cost.
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IX. OPERATION AND MAINTENANCE
Operation and maintenance for the reconmended alternatives consists of
maintenance of the revegetated area and of the drainage diversion ditch
and, if applicable, maintenance and long-term monitoring of the solidified
matrix.
To ensure that the revegetation efforts of the remediation activities are
successful and vegetative growth flourishes, bi-annual maintenance checks
of the area will be necessary. Previous attempts to revegetate this area
were unsuccessful, however no maintenance was performed. With the proper
backfill, fertilization, and maintenance, this area could be re-established
with fertile growth. If additional measures are seen as necessary to
improve the conditions, these should immediately be implemented. The
maintenance schedule will be presented in the detailed design of the remedy.
Similarly, the drainage diversion ditch will also require bi-annual
maintenance checks to ensure that the ditch is in good condition and
adequately diverts surface runon from the storm sewer drain around the
swamp area. The diversion ditch is important for reducing erosion and
sediment transport from the swamp area to Tanyard Branch as much as
possible. If maintenance is necessary, these measures will be implemented
immediately. Again, the detailed design will specify these maintenance :
activities.
If stabilization/solidification is performed to remediate the soils,
additional 0 & M activities will be required. Bi-annual monitoring
of the matrix will be implemented to detect leaching of contaminants
from the matrix, should this be occurring. Additionally, as with the vegetative
cover and drainage ditch, the solidified matrix will also require
bi-annual maintenance checks to determine the integrity of the matrix.
Measures will be outlined in the detailed design of the remedy to rectify
any problems discovered from the maintenance checks and monitoring. The
detailed design will also specify the details of the monitoring program
to be performed.
The 0 & M requirements discussed above will be implemented for 30 years.
EPA is willing to perform these activities for one year after implementation
of the remedy. The State of Alabama does not agree with the remedy and
does not currently have a mechanism for cost-sharing of the remedy or
performance of the remaining O & M activities. However, ERA will work
with the State to reach a mutually agreeable settlement.
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X. SCHEDULE
Upon approval of the recorrmended alternative by the Regional
Administrator, the next step in the process is to prepare a detailed
design of the remedy. PRPs do exist for this site; however, the
owner of the MEC has filed for bankruptcy, and the remaining PRPs
have not indicated a desire to perform the remedy. Thus, the earliest
that the design, and inplementation, can begin is after CtKZLA is
reauthorized and seme agreement is reached with the State of Alabama
to provide a 10% cost share.
XI. FUTURE ACTIONS
Once the reccmended alternative is performed and the required 0 & M
activities are underway, there will be no future actions necessary for
the MEC site.
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RESPONSIVENESS SUMMARY
MOWBRAY ENGINEERING COMPANY SITE
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IV
This is the Responsiveness Summary for the Mowbray Engineering Company
Superfund site in Greenville, Alabama. The U.S. Environmental Protection
Agency (EPA) in Region IV received only one written comment on the Feasibility
Study (FS) during the required public comment period. Therefore, in lieu of a
descriptive summary of public comments and EPA's responses, this
Responsiveness Summary document includes a short discussion of EPA's community
involvement activities; a description of the single comment received and EPA's
response; the fact sheet describing the FS, and a summary of the public
meeting held on the FS.
The Remedial Investigation/Feasibility Study (RI/FS> for the site was
conducted from spring 1985 to spring 1986. A community relations plan that
described community concerns and recommended EPA community relations
activities was prepared in May 1985. Following one recommendation of the
plan, EPA established an information respository at the Greenville Public
Library. The repository contained educational documents and research
materials on the site, including the RI/FS work plan and the RI/FS report.
Once the draft FS was completed, a fact sheet was prepared that described
EPA remedial activities at the site, the proposed cleanup alternatives, and
the public comment period. It was mailed to individuals on the mailing list
and placed in the information repository. Announcements were placed in local
papers describing the public comment period and the public meeting on the FS.
EPA held the public meeting on August 12, 1986, and the public comment period
covered the period from August 12 to September 2, 1986. Approximately fifteen
to twenty residents attended the meeting. The presentations, questions from
the audience, and EPA responses are in the public meeting summary.
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COMMENT ON THE FEASIBILIITY STUDY FOR THE MOWBRAY ENGINEERING COMPANY SITE
Comment:
The only written comment received during the three-week public comment
period expressed the opinion that most of the citizens who had attended the
public meeting favored the No Action remedial alternative.
EPA Responsa:
EPA has evaluated the No Action alternative as mandated by the National
Oil and Hazardous Substances Contingency Plan. This alternative implies that
there is no threat posed by the contaminants present at the Mowbray
Engineering Company site. Selecting this alternative would mean that no
remedial action would be implemented. The contaminants would remain in place
and serve as a potential source of future PCB contamination.
Allowing the site to remain in this condition would not meet the public
health and environmental objectives for this site, nor would it conform with
other environmental laws. For these reasons, the No Action alternative is no*
recommended as the remedial action alternative for this site. -
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Fact Sheet for FS Public Meeting
REMEDIAL INVESTIGATION/
FEASIBILITY STUDY SUMMARY
U.S. EPA
REGION IV
MOWBRAY ENGINEERING COMPANY SITE
GREENVILLE, ALABAMA
JULY 1986
Introduction
The U.S. Environmental Protection Agency (EPA) recently completed a
Remedial Investigation and Feasibility Study (RI/FS) defining site conditions
and evaluating remedial alternatives for the Mowbray Engineering Company
Superfund site in Greenville, Alabama. This fact sheet provides background
information on the site and summarizes the findings of the draft RI/FS report.
At sites like this one, EPA typically conducts an extensive investigation
and study called a Remedial Investigation and Feasibility Study. (See
Appendix A for a detailed description of the Superfund cleanup process.) The
first part of the study, the RI, is conducted to define the type, level, and
extent of contamination. The second part, the FS, is to evaluate the cleanup
alternatives. Superfund cleanups are designed to: (1) control or eliminate
the source of contamination at hazardous waste sites; and (2) minimize the
impact of contaminants.
Sit* Background
The Mowbray Engineering Company (MEC) site is located in an industrial and
residential area in Greenville. The study area consists of the MEC plant and
a swaap, while the actual Superfund site consists of the swaop alone. MEC is
located east of Beeland Street and north of First and Second Streets, and the
swamp is directly west from the MEC plant across Beeland Street. MEC does not
own the swamp property. A tributary of Persimmon Creek, called Tanyard
Branch, runs near the west side of the swaap. (See Figure 1 for a site map.)
Figure 1
SITE LOCATION MAP
MOWIRAY CNaiMIIftlNa COMPANY «ITI
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MEC has been rebuilding and reconditioning electrical transformers at this
plant since the mid-1950's. (However, Mowbray Engineering Company has since
ceased operations at the site, and in 1985 the company declared bankruptcy.)
Between 1955 and 1977, waste oil from these operations, containing
polychlorinated biphenyls (PCBs), was discarded on the ground behind the
plant. These oils flowed into a drain that was connected to the city storm
sewer system. The sewer system then drained onto the swamp across Beeland
Street, and then into Tanyard Branch. In 1977, however, MEC stopped disposing
its oil on the ground and began to recycle it.
In 1975, a major fish kill in Tanyard Branch was traced to overflow waste
oils from an MEC holding tank. However, upon inspection of the swamp, only
trace amounts of PCBs were found. In 1980, another oil spill at the MEC plant
was reported to the Alabama Water Improvement Commission (AWIC), and this time
AWIC investigations revealed oil and PCB levels above 500 parts per million
(ppm) in the swamp. Between February and August 1981, EPA conducted an
extensive sampling progam and performed an emergency cleanup of the swamp.
In February 1981, the Centers for Disease Control (CDC) asked the National
Institute for Occupational Safety and Health (NIOSH) to evaluate occupational
exposures to PCBs at MEC. NIOSH personnel collected blood samples and
conducted physical exams for some workers, and collected air and dust samples
from the work area. NIOSH concluded that workers did not appear to be exposed
to excessive levels of PCBs. However, NIOSH did recommend that workers -
minimize exposure to transformer oil and that any transformer suspected of
containing PCBs not be processed at the site.
The site was included on the National Priorities List (NFL) in December
1982. The NPL is a listing of the nation's worst hazardous waste sites;
inclusion on the list enables EPA to use Federal Superfund money for site
investigation and cleanup. The site is ranked 118 of 786 sites on the NPL.
In November 1983, routine sampling at MEC by the Alabama Department of
Environmental Management (ADEM) revealed high concentrations of PCBs in the
stormwater drainage pathway through the sit*. In the spring of 1984, EPA
conducted a sit* inspection and additional sampling. PCBs were found in the
surface of the swamp, ground water, surface water and sediment from the nearby
streams.
In the spring of 1985, EPA contractors began the Remedial Investigation
for the site, which lasted approximately one year. Contractor personnel
collected samples from the soil in the study area, from upstream and
downstream locations on Tanyard Branch and Persimmon Creek, and from
ground-water monitor wells. These investigations revealed PCB contamination
in soil on the NEC property and in the swamp. Trace amounts of PCBs were
found in sediment samples downstream of the site, but no PCBs were detected in
surface waters in samples either upstream or downstream of the site. One
ground-water sample was found to contain low, but detectable levels of PCBs.
This finding could have been caused by the particular sampling method used,
however. Air monitoring has revealed no air contamination from the site.
All Greenville residents are connected to the city water system; none use
private wells. Furthermore, because of the local geology and the nature of
the contaminants, EPA has concluded that it seems highly unlikely that
contaminants in the study area could migrate to reach the city's drinking
water supply.
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What is a Feasibility Study?
EPA conducts a Feasibility Study (FS) to evaluate various ways to clean up
hazardous waste sites. EPA assesses how easily the remedies can be
implemented, how well they will clean up the environment and protect public
health, and how much they will cost. EPA's objective is to choose the most
environmentally sound and cost-effective cleanup method.
The remedies considered in the Feasibility Study for the Mowbray
Engineering Company site are described below. •
Alternatives Considered in the FS of the Mowbray Engineering Company Site
The Feasibility Study of the Mowbray Engineering Company site used
findings from the Remedial Investigation to evaluate applicable technologies
for remediation and cleanup of the swamp and MEC property. This evaluation
resulted in the development of seven alternatives. Each alternative except
the "No Action Alternative" includes, as common components, the excavation and
removal of underground storage tanks on the MEC property, the cleanup of
contaminated waste oil, and restoration (revegetation) of the swamp. This
section describes each of the alternatives considered.
1. Sit* Drainage Diversion. A channel consisting of a grassy
waterway with a stone center would be constructed to permanently .
divert surface runon around the contaminated swamp area. Drainage
diversion is necessary to prevent spreading of contaminants by
erosion of contaminated.soils.
2. Off site Disposal. For this alternative, all wastes contaminated
with PCBs above a particular level are removed from the site and
transported to a chemical waste facility permitted to receive PCBs.
3. Offsite Incineration. This remedial alternative consists of
transporting the wastes to one of two out-of-state incineration
facilities that are designed to destroy PCB-contaminated soil.
During incineration, the PGBs are destroyed while the soil is left
essentially unchanged.
4. Onsite Stabilization/Solidification. This remedial alternative
uses a variety of techniques to minimize the solubility (ability to
dissolve in water), toxicity, or mobility of the contaminants. These
techniques are also designed to facilitate the handling of the
wastes. Stabilization involves adding chemicals to the wastes to
achieve these objectives. Solidification involves changing the
wastes's physical characteristics by compacting it into a form that
is tightly held together and easily stored onsite.
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5. Onsita Containment/Encapsulation. The purpose of this
alternative is to limit the movement of contaminants by physically
keeping water from contacting the contaminated material. This
technology consists of sealing off contaminated soils with materials
that prevent such movement. Available materials include concrete,
asphalt, and plastics.
6. Onsite Incineration. This alternative consists of transporting
one of two possible mobile incineration facilities to the site for
incineration of contaminated soils.
7. No Action. This alternative implies that no remedial measures
would be taken at the site. EPA is required by law to consider a
no-action alternative in every Feasibility Study.
N«xt Steps
A public comment period, as described below, will be held to allow
citizens to comment on the remedial alternatives considered in the Feasibility
Study. Following the conclusion of the comment period on the draft FS report,
a formal decision document will be prepared that summarizes EPA's decision
process and the selected remedies. This document will include the
Responsiveness Summary (a report that summarizes citizen comments and EPA -
responses) and will be submitted to the EPA Regional Administrator for his
approval. Submission of this decision document is expected to occur in
September 1986. At that time, the design of the remedy will be developed.
Upon completion of the design, implementation of the remedy will begin.
Copies of the draft RI and FS report are available for review in the
information repository at the following location:
Greenville Public Library
101 Adams Street
Greenville, Alabama 36037
(205) 382-3216
Hours: Hon., Tues., Thurs., Fri.: 10 am - 5 pm
Wed.: 1 pa - 4 pa
Sat.: 9 am - 12 noon
When completed, the Responsiveness Summary will also be placed on file in the
information repository.
Public Comment Invited
EPA will hold a public meeting on Tuesday, August 12, 1986 from 7 p.m. to
9 p.m. at the Beeland Park Community Center (Room 4), East Commerce Street,
Greenville (phone 205-382-3031). At the meeting, EPA will present a summary
of the RI/FS process (including the results of the RI/FS) and explain the
proposed remedies for the site. There will also be an opportunity for
citizens to ask questions. The question-and-answer period will be recorded to
assist in the preparation of a Responsiveness Summary.
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The public meeting will mark the start of a three-week public comment
period on the draft FS report. The comment period will begin August 12, 1986,
and conclude on September 2, 1986. During this three-week period, the public
is encouraged to review the remedies proposed in the draft FS report and
submit written comments to EPA. Copies of the draft FS report are available
at the information repository. All comments must be post-marked no later than
September 2, 1986 and should be sent to:
Meredith Clarke Anderson
Remedial Project Manager
U.S. Environmental Protection Agency
345 Court land Street NE
Atlanta, Georgia 30365
For questions or further information contact either of the following:
Meredith Clarke Anderson Michael Henderson
Remedial Project Manager Community Relations Coordinator
U.S. Environmental Protection Agency Office of Public Affairs
345 Court land Street NE U.S. Environmental Protection Agency
Atlanta, Georgia 30365 345 Cour-cland Street NE
(404) 347-2643 Atlanta, Georgia 30365
(404) 347-3004
MAILING LIST ADDITIONS
To be placed on the mailing list to receive information on the Mowbray
Engineering Company site, please fill out and nail this form to:
Michael Henderson
Coamunity Relations Coordinator
Office of Public Affairs
U.S. Environmental Protection Agency
345 Courtland Street NE
Atlanta, GA 30365
Nairn:
Address:
Affiliation:
Phone:
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Fact Sheet for FS Public Meeting
APPENDIX A
EPA SUPERFUND PROCESS
In 1980, Congress enacted the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA, more commonly known as "Superfund").
This act authorizes EPA to respond to releases or threatened releases of
hazardous substances that may endanger public health or welfare, or the
environment.
This appendix provides a simplified explanation of how a long-term
Superfund response works at sites like the Mowbray Engineering Company site.
1. After a site is discovered, it is investigated, usually by the State.
2. The State then ranks the site using a system that takes into account:
• Possible health risks to the human population;
• Potential hazards (e.g., from direct contact, inhalation,
fire, or explosion) of substances at the site;
• Potential for the substances at the site to contaminate
drinking water supplies; and
• Potential for the substances at the site to pollute or
otherwise harm the environment.
If the problems at a site are deemed serious by the State and EPA, the
site will be listed on the National Priorities List (NPL), a roster of
the nation's worst hazardous waste sites. Every site on the NPL is
eligible for Federal Superfund money.
3. If a site or any portion thereof poses an imminent threat to public health
or the environment at any time, EPA may conduct an emergency response
called an immediate removal action.
4. Next, EPA usually conducts a Remedial Investigation (Rl). The RI
assesses how serious the contamination is, identifies what contaminants
are present, and characterizes potential risks to the community. As part
of the RI, EPA typically conducts an endangerment assessment that
describes the problems at the site and the potential health and
environmental consequences if no further action is taken at the site.
5. Following completion of the RI, EPA performs a Feasibility Study (FS).
The FS examines various cleanup alternatives and evaluates them on the
basis of technical feasibility, public health effects, environmental
impacts, institutional concerns (including compliance with State and local
laws), impact on the community, and cost. The findings are presented in a
draft FS report.
6. Following completion of the draft FS report, EPA holds a public comment
period to receive citizen comment concerning the recommended
alternatives. The minimum duration is three weeks. Citizens may provide
comments either orally at public meetings or through written
correspondence to EPA.
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APPENDIX A (continued)
7. After public comments have been received, EPA then chooses a specific
cleanup plan.
8. This cleanup plan and the Responsiveness Summary (a description of public
comments and EPA responses to those comments) are compiled in the
Record of Decision (ROD). The ROD is then submitted to the EPA
Regional Administrator for his approval.
9. Once the Regional Administrator signs the ROD, EPA designs the specific
cleanup plan for the site.
10. When the design is finished, the actual remedial activities at the site
can begin.
The time necessary to complete each of these steps varies with every
site. In general, an RI/FS takes from one to two years. Designing the cleanup
plan may take six months. And implementing the remedy - the actual
containment or removal of the waste - may take from one to three years. If
ground water is involved, the final cleanup may take many more years.
Ongoing community relations activities during a cleanup include public
meetings, news releases, fact sheets like this one, and other activities
intended to keep citizens and officials informed and to encourage public
participation. These activities are scheduled throughout the course of the
remedial cleanup process. Specific activities vary from site to site
depending on the level and nature of concern. The range of community
relations activities that can occur is described in EPA's Coununity Relations
Plan for the site.
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MOWBRAY ENGINEERING COMPANY SITE
PUBLIC MEETING SUMMARY
I. OVERVIEW
On August 12, 1986, the U.S. Environmental Protection Agency (EPA) in
Region IV held a public meeting from 7 to 8 pm to discuss the results of the
Remedial Investigation and Feasibility Study (RI/FS) for the Mowbray
Engineering Company (MEC) Superfund site located in Greenville, Alabama. The
public meeting was.held in the Beeland Park Community Center in Greenville.
Approximately fifteen to twenty local residents, including the Mayor of
Greenville, attended. Reporters from the Greenville Advocate and the
Montgomery Advertiser were also present.
Representing EPA at the meeting were Jim Orban, Superfund Unit Chief;
Ralph Jennings, Superfund Unit Chief; Meredith Anderson, Remedial Project
Manager; Michael Henderson, Community Relations Coordinator; and Elizabeth
Osheim, Assistant Regional Counsel. Contractor personnel present were Mary
Leslie and Mark Burgess of Camp Dresser & McKee, Incorporated; and Sara Watson
of ICF Incorporated. The meeting began with a description of the MEC site, a
presentation of the results of the RI/FS, and an explanation of the upcoming
public comment period. A question-and-answer period followed. :
A summary of EPA's presentations, and the questions and answers that
followed is outlined below. The presentations are given in chronological
order; the questions and answers have been organized into topics.
II. PRESENTATIONS
A. Introduction and Sit* History - M«r«dith Anderson
Ms. Anderson described the purpose of the meeting and introduced the EPA
and contractor personnel present. She noted that the information presented at
the meeting was available in the RI/FS. She said that the full RI/FS prepared
by EPA and its contractor is currently available for public review in the
information repository located in the Greenville Public Library. Ms. Anderson
invited the public to review the material and submit comments to her at the
address listed in the fact sheet on the site. She indicated that copies of
this fact sheet, which presents key information relevant to the Mowbray RI/FS,
were available at the door.
Ms. Anderson next described the site area, the history of Mowbray
Engineering Company's operations and disposal practices, and the nature of the
contamination at the site. She explained that the results of the RI provided
the technical information about the nature and extent of contamination found
at the MEC site. EPA's field work on the RI was concluded in November 1985.
The FS was completed in June 1986, at which point the formal RI and FS reports
were written. Ms. Anderson showed several slides of the site to illustrate
sampling procedures and the geography of the area.
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B. Remedial Investigation - Mary Leslie
Ms. Leslie explained what an RI is, why it is performed, and how it is
conducted. She said that the purpose of the RI is to gather data about the
existing contamination onsite; the routes available that would allow the
contamination to migrate offsite towards local bodies of water or other areas;
and the people, animals, or environmentally sensitive areas that could
possibly be affected by this contamination. This data is then used to
determine the nature of the public health threat from the site.
Ms. Leslie stated that the RI was undertaken to fill specific data gaps
that had not been addressed by previous investigations. She said the areas
that required further sampling included:
soils on the MEC property;
the swamp area;
ground water near the site;
surface waters; and
sediments upstream and downstream from the site,
especially in lanyard Branch and Persimmon Creek.
To gather this information for the RI, Ms. Leslie said that samples were
collected from various monitor wells around and on the site. These samples
were then analyzed for traces of contamination.
Ms. Leslie showed maps of the site depicting the locations of the monitor
wells installed by EPA. She explained the rationale for their placement by
citing these examples:
Monitor well #1 was located upstream of the site to
establish a baseline for comparing the results of samples
from the other wells. Monitor well #2 was located where
EPA believed it was most likely that contaminants would
migrate from the site.
Ms. Leslie said the results of the RI indicated that, overall, relatively
few polychlorinated biphenyls (PCBs, the main contaminants of concern) were
discovered at the Mowbray site. She said very low levels of PCBs were found
downstream from the site, while none were found upstream from the site. Ms.
Leslie observed that the RI established that there was little probability for
contamination of ground water in the vicinity of the site. She did note,
however, that significant levels of PCBs were found in selected areas -- near
the storage tanks on the MEC property, in monitor well #2, and in localized
pockets of subsurface oil in the swamp.
Ms. Leslie spoke about the completion of a public health evaluation for
the site. She said that this evaluation is based upon the results of the RI,
the known toxicity of the contaminants, their concentration at the site, the
possible routes for contaminant migration, and the possible receptors of the
contaminants. Based on these factors, Ms. Leslie said the public health
evaluation concluded that there was no serious threat to the public health.
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C. Feasibility Study - Mark Burgess
Mr. Burgess explained that, based on the areas and levels of contamination
found during the RI, many different options for addressing the contamination
at the site were developed. He said these options were evaluated on the basis
of technical feasibility, environmental impact, public health impact, and
cost. Mr. Burgress said that EPA then shortened the original list of
alternatives to seven options. He described the advantages, disadvantages,
and costs for each of the final options.
The cost information Mr. Burgress presented is listed in the table below.
He suggested that any one of the seven alternatives could clean the site to a
level where the PCBs remaining in the soil would range from ten milligrams per
kilogram (mg/kg) to fifty mg/kg. He explained further that cleaning up the
site to a level of ten mg/kg means that the only soil left at the site would
contain less than ten mg/kg of PCBs.
In the following table, costs are given for each alternative that would
clean up the site over increasing levels of PCBs. The lower the level of PCBs
allowed to remain at the site, the more soil must be removed and the more the
action will cost.
D. Table of Cleanup Alternatives and Explanation
Cost ($)
PCB Laval
Cleanup
Alternative 10 mg/kg* 20 mg/kg 30 mg/kg 50 mg/kg
1. No Action 0000
2. Site Drainage Diversion 129,600 129,600 129,600 129,600
3. Off-Site Disposal 8,266,000 3,285,900 879,500 219,600
4. Off-Site Incineration
(Permanent facility) 51,417,300 19,287,500 4,583,400 566,300
(Temporary facility) 4,118,500 1,635,300 509,800 199,700
5. On-site Solidification 2,307,800 1,074,500 569,500 349,600
6. Containment/Encapulation 1,682,500 861,900 574,300 348,400
7. On-Site Incineration 6,837,500 2,647,300 734,900 210,000
* mg/kg means milligrams per kilogram.
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Explanation of Cleanup Alternatives
All the following cleanup alternatives, with the exception of Alternative
1, have four common components. These components include: drainage diversion
to prevent the erosion of contaminated soil into lanyard Branch; removal of
storage tanks containing contaminated oil; treatment or disposal of
contaminated waste oils; and restoration of the site by revegetation.
The significant difference between these alternatives covers how the
contaminated soil is treated. The list below provides a brief explanation of
the advantages and disadvantages unique to each alternative.
Alternative 1.- No Action
Advantages: No additional cost.
Disadvantages: The site would be left as it is now,
pockets of PCBs would remain at the site, and the
contaminated soils and storage tanks could potentially
release additional PCBs at a later date.
Alternative 2: Site Drainage Diversion
This option includes the four components listed above.
Advantages: It prevents erosion of soils, leakage of
storage tanks, and contact with contaminated soil.
Disadvantages: The contaminated soils are left on site
and, if the vegetative cover were removed, contaminated
soils could continue to erode into Tanyard Branch.
Alternative 3: Off-site Disposal
This option involves excavating the soil and taking it to
an approved landfill. As with the remaining four options,
the range of costs is very wide and depends on the extent
of the cleanup. Cleaning up the site to very low levels of
PCBs means handling much greater quantities of soil which
thereby raises the cost.
Advantages: The technology is easy to implement, and
the contaminated soils would be properly disposed.
Disadvantages: The contaminated soil would be
transported through Greenville and other towns and cities,
creating the potential for accidental exposure to the
public.
Alternative 4: Off-site Incineration
The soil would be excavated and taken to either a mobile or
permanent incineration facility.
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Advantages: The PCBs are permanently destroyed instead
of simply placed in another area.
Disadvantages: The contaminated soil would be
transported through Greenville and other towns and cities,
creating a potential hazard to the public.
Alternative 5: On-site Solidification
The soil would be excavated, mixed with cement-like
substances, and put back on the site.
Advantages: The soils cannot move or erode, there is no
need to transport the contaminants, and there is a barrier
to prevent contact with the contaminants.
Disadvantages: The soils would be left on site, there
would be additional storm water runoff to Tanyard Branch,
and EPA would need to establish a long-term monitoring
program to verify the effectiveness of this remedy.
Alternative 6: Containment/Encapsulation
The contaminated soils would be enclosed in a clay or "
plastic liner.
Advantages: The contaminants are contained and cannot
move, and there is no need to transport soils off-site.
Disadvantages: Contaminants are left on site, and EPA
would need to establish a long-term monitoring program to
ensure the integrity of the liner.
Alternative 7: On-site Incineration
Soils are excavated, incinerated on site and put back onto
the site.
Advantages: This is a permanent remedy as the PCBs are
destroyed, there is no need to transport the soils, and the
facility provides some opportunity for employment of local
residents.
Disadvantages: The on-site incineration facility is
unaesthetic and is a potential source of air pollution.
E. Conclusion - Meredith Anderson
Ms. Anderson restated where the pockets of contamination were found at the
MEC site, reiterated that the public health evaluation had found no threat to
public health, and listed again the seven alternatives in the FS. She
explained that EPA currently favored Alternative 2. However, Ms. Anderson
said EPA was eager to have public comments on all seven alternatives and would
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consider those conments in making its final selection. She said that the
public's contents and the EPA responses would be compiled into a document
called the Responsiveness Sumiary; this sutrnary and the recommended remedy
would then be presented to the Regional Administrator for final approval.
III. QUESTIONS AND RESPONSES
A. Questions on Remedial Action Alternatives
1. Question: One resident inquired whether EPA was ready to abandon
the site by choosing the No Action Alternative.
Response: EPA responded that the No Action Alternative is one of
the options EPA must consider.
2. Question: Several residents asked if specific parts of various
alternatives could be performed. One asked if the No Action Alternative were
chosen and the tanks remain, would the tanks leak. Could EPA simply
remove the tanks?
Response: EPA responded that the tanks may leak and that the Agency
may choose to do any combination of the alternatives presented.
3. Question: Another resident asked if only part of Alternative 2
could be done, and what was the cost of Alternative 2.
Response: EPA said that they may choose to perform any part of an
alternative. However, there are certain items that fit into the
same category as the tanks. They cause similar, substantial problems
and require minimal effort to remove them. That is why EPA has
put these items together as Alternative 2. The cost of Alternative 2
is $129,600.
4. Question: One resident asked why the off-site incineration alternative
is so expensive and why there is such a wide range of costs associated
with incineration.
Response: EPA explained that when soil is burned at a permanent
incineration facility, the soil bulk is not reduced. Therefore, the
facility must use its landfill capacity to dispose the incinerated
soil. The costs are also high if the site is cleaned to a low
level of PCBB. Off-site incineration is also an expensive
technology in general.
5. Question: One resident asked about the composition of the soil
around the site and whether it could be stabilized with lime.
Response: EPA responded that the top level of soil is clay, the
next six inches of the site is top soil, and beneath that layer
is two and half feet of mainly sandy clay. The exact composition
of soil varies over the site. This composition is incompatible
with the use of lime for stabilization.
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B. Questions on PCB Levels
1. Question: One resident asked what PCB level EPA considers to be
hazardous and why EPA would clean up the site beyond that level.
Response: EPA responded that the question of PCB toxicity continues
to be studied and debated. In the past, one conmon interpretation
of the Toxic Substances Control Act led to cleanups down to 50 ppm.
However, new Toxic Substances Control Act regulations have been
proposed that will result in cleanup down to the 10-25 ppm range.
2. Question: A resident asked how many samples contained PCBs
exceeding 50 ppm, and where were these samples found.
Response: EPA answered that six or seven samples contained PCBs
exceeding 50 ppm. The exact data is in the RI/FS report. These
samples were found on the MBC property and in localized areas
in the swamp.
3. Question: Several questions considered why there was such a large
difference between PCB levels found in samples evaluated in the field and
those evaluated in the laboratories. The samples from the field all
showed PCB levels lower than the laboratory measurements.
Response: EPA said that the field instruments used for measuring PCBs
are less sophisticated and less precise than the laboratory
instruments. The field measurements were taken so that EPA could
screen samples quickly to decide where to take additional samples.
Any sample that is split and sent to two laboratories will show
different results. It is not uncommon for laboratories to find
contamination levels in one sample that are twice as high as
those found in another sample. EPA stressed, however, that even
where results of individual samples differ, the data for this
site does show the same trends in the concentration of PCBs.
C. Questions on the Need for Cleanup
Questions: In a series of questions, one resident said he had a
letter from Mr. Devine of EPA stating that the remedial cleanup action
performed in 1981 at the site was satisfactory and no additonal work was
needed. He asked if Mr. Devine had changed his mind. He stated that he
had asked Mr. Dtvine to do another independent study and that he didn't
think EPA had cleaned up the site adequately. He also questioned the
need for additional work now because there could be no new contamination
as MEC had not been in operation since the time of the letter. He concluded
by recommending the No Action Alternative.
Response: EPA responded that Mr Devine's letter was written in
1981 and referred to the specific immediate removal at the site
as satisfactory. EPA believes that the site continues to be a
source of contamination, regardless of whether MEC had been in
operation since 1981. In any case, new data was needed to
determine if the contaminants had migrated, and if so, where they
had migrated.
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D. Questions on the Future of the Site
Question: One resident who owned a small piece of the swamp
property asked if the No Action Alternative were chosen, what would happen
to the property. Would anyone buy it?
Response: EPA explained that the property would remain as it is
now. When any site is cleaned up, the next step is to delete it
from the National Priorities List (NPL). If the No Action Alternative
is selected, attempts to take the site off the NPL would be the
next logical step. The contaminant levels would be the same but
the area would no longer be a Superfund site. There should be no
more risks with buying that property than with buying any other
property that could turn out to be contaminated.
E. Questions on Financing Superfund Remedial Actions
1. Question: One resident asked who pays for the cleanup.
Response: EPA stated that initially EPA pays for the cleanup with
money from the national Superfund. Then, EPA attempts to
recover those costs from responsible parties identified through
ongoing legal research conducted by EPA.
2. Question: One resident asked if Superfund was funded out of
general tax revenues. In a follow-up question, the resident asked why
EPA was having problems funding Superfund if the money comes from chemical
companies.
Response: EPA explained that 87% of the Trust Fund comes from a
tax on chemicals; 13% comes from general tax revenues. The
problem now is that the law exists but that the funding has
expired. There is a new Superfund bill which has been agreed to
by the House and Senate Conference Catmittees. However, there is
still some disagreement over the funding issue. The bill must
pass both the House and Senate and be signed by the President.
3. Question: One resident asked what would happen to this site if
Superfund isn't funded.
Response: EPA responded that the funding would not exist but the
law would. Therefore, EPA predicted that the Agency would probably
be very agressive in hunting out responsible parties to finance
cleanups. However, the site would essentially remain in limbo
for some time.
F. General Questions
In reponse to a request for the number of complaints EPA has received
about the site, EPA stated that it has received one anonymous letter.
In response to a question asking if a 3 or 4 page comment would be
considered, EPA stated that a comment of any size would be welcome.
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In response to requests for the approximate cost of the investigation and
the time period covering that expense, EPA responded that the investigation
has cost $400,000 since January 1985. EPA added that this includes all field
work, planning, and documentation. A typical RI/FS costs $500,000-$800,000.
Meeting Adjournment
Ms. Anderson then thanked everyone for coming, and the meeting adjourned at
8 pm.
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