Superfund Record of Decision: National Electric Coil/Cooper Industries, KY


          United States
          Environmental Protection
          Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-92/127
September 1992
SEPA    Superfund
          Record of Decision:
          National Electric Coil/Cooper
          Industries, KY

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                                         NOTICE

The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.

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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-92/127

4. TO* and SuMH*
SUPERFUND RECORD OF DECISION
National Electric Coil/Cooper Industries,;KY
First Remedial Action - Subsequent to follow
RoportD***
09/30/92
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9. Ptffonnlng Orgolntm
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11. Contac«(C) or Gr«n«
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EPA/ROD/R04-92/127
National Electric Coil/Cooper Industries, KY
First Remedial Action - Subsequent to follow

abstract (Continued)

local drinking water supply, drainage channels, river embankment property, and facility
grounds. In 1989, state investigations revealed VOC contamination in several residential
wells. Bottled water was provided to affected residences and municipal lines were
installed. As part of a 1990 removal action, EPA required the PRPs to excavate
5,100 tons of contaminated soil for offsite disposal. This ROD provides an interim
remedy for the VOC contamination in the bedrock aquifer to further restrict migration of
the VOC-contaminant plume. A future ROD will address a final remedy for the-shallow
aquifer beneath the site and any other site--related contamination. The primary
contaminants of concern affecting the ground water in the bedrock aquifer and air are
VOCs, including TCE, toluene, and xylenes; and metals, including lead.

The selected remedial action for this site includes onsite pumping and treatment of
contaminated ground water using air stripping to remove VOCs, with onsite discharge of
the treated water to the Cumberland River; capturing and treating resulting vapors using
activated carbon, and disposing of the spent carbon offsite as RCRA F001 waste; and
monitoring ambient air and ground water. The estimated capital cost for this remedial
action is $106,000, with an estimated annual O&M cost of $150,000.

PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals are based
on state effluent discharge limitations and include TCE 0.172 mg/1; 1,1-DCE 0.0021 mg/1;
vinyl chloride 0.128 mg/1; PCBs 0.0043 ug/1; cis-Lt2-DCE 0.07 mg/1; methylene chloride
0.011 mg/1; benzene 0.833 mg/1 and lead 0.072 mg/1. Ambient air performance standards
also will be met and include cis-l,2-DCE 5 ug/m3 ; TCE 5 ug/rr? ; and vinyl chloride 5 ug/nr.
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NATIONAL ELECTRIC COIL CO./
COOPER INDUSTRIES
SUPERFUND SITE
RECORD OF DECISION
SEPTEMBER 30, 1992
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RECORD OF DECISION
NATIONAL ELECTRIC COIL CO.,/COOPER INDUSTRIES SITE

TABLE OF CONTENTS

Description Page

THE DECLARATION i

1.0 SITE NAME, LOCATION, AND DESCRIPTION . . 1

1.1 Site Location 1
1.2 Affected Population 1
1.3 Topography 1
1.4 Adjacent Land Uses 1
1.5 Geology 1
1.6 Hydrogeology 4
1.7 Surface Water 4
1.8 Natural Resources 4
1.9 Climatology 8

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 8

2.1 Operational History 8
2.2 Enforcement Summary 9

3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 9

4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE
STRATEGY 10

5.0 SUMMARY OF SITE CHARACTERISTICS 11

5.1 Nature and Extent of Contamination Overview 11
5.2 Deep (Bedrock) Aquifer 11
5.3 Overburden Soils 15
5.4 Shallow (Overburden) Aquifer 15

6.0 SUMMARY OF SITE RISKS 15

7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES 20

7.1 Alternative 1 20
7.2 Alternative 2 21
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RECORD OF DECISION
NATIONAL ELECTRIC COIL CO.,/COOPER INDUSTRIES SITE

TABLE OF CONTENTS

Description Page

8.0 SUMMARY OF COMPARATIVE ANALYSIS ALTERNATIVES 21

9.0 THE SELECTED REMEDY 25

9.1 Major Components of the "Interim" Remedial Action 25
9.2 Performance Standards 26

10.0 STATUTORY DETERMINATION 29

10.1 Protection of Human Health and the Environment 29
10.2 Compliance with ARARs 29
10.3 Cost-Effectiveness 30
10.4 Utilization of Permanent 5 dutions and Alternative
Treatment Technologies or Resource Recovery Technologies
to the Maximum Extent Practicable 30
10.5 Preference for Treatment as a Principal Element 31
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RECORD OF DECISION
NATIONAL ELECTRIC COIL CO../COOPER INDUSTRIES SITE

TABLE OF CONTENTS

Description Page

FIGURE 1.1 Site Location Map 2

FIGURE 1.2 Site Plan 3

FIGURE 1.3A Generalized Stratigraphic Column .' 5

FIGURE 1.3B Generalized Stratigraphic Column 6

FIGURE 1.3C Generalized Stratigraphic Column 7

FIGURE 5.1 Proposed Interim Action Monitoring Well Locations 16

FIGURE 5.2 Removal Action Soil Excavation Boundaries 17
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RECORD OF DECISION
NATIONAL ELECTRIC COIL CO.,/COOPER INDUSTRIES SITE

TABLE OF CONTENTS

Description Page

TABLE 5.1 SUMMARY OF GROUND WATER SAMPLING RESULTS 12

TABLE 6.1 ORGANIC CONTAMINANTS OF CONCERN BY
ENVIRONMENTAL MEDIA _ 19

TABLE 9.1 EMISSION RATE AND AMBIENT AIR PERFORMANCE
STANDARDS 26

TABLE 9.2 SUMMARY OF KPDES EFFLUENT LIMITATIONS 27

TABLE 9.3 DESIGN PARAMETERS 28
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RECORD OF DECISION

THE DECLARATION

SITE NAME AND LOCATION

National Electric Coil Co../Cooper Industries Site
Dayhoit. Harlan County. Kentucky

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected "interim" remedial action for the National Electric
Coil Co./Cooper Industries Site, in Dayhoit, Harlan County. Kentucky, which was chosen in
accordance with CERCLA. as amended, and. to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the
administrative record for this site. The Commonwealth of Kentucky concurs with the selected
remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

This "interim" remedial action employs the use of an extraction well/air stripper system in order
to prevent further ground-water plume migration in the bedrock aquifer, which is one of two
distinct aquifers beneath the Site, and to initiate ground-water restoration while the RJ/FS and
post-RI/FS activities are being completed. The bedrock aquifer beneath and immediately
downgradient of the Site (up to an estimated extent of one-half mile) contains volatile organic
compound (VOC) contamination.

The components of the Selected Remedy are as follows:

• Extraction of contaminated bedrock aquifer ground water;
• Treatment of contaminated ground water using air stripper tower:
• Discharge of treated ground water to Cumberland River via KPDES reqirements:
• Emission controls on air stream leaving air stripper tower.
STATUTORY DETERMINATION

The "interim" remedial action is protective of human health and the environment in the short term
and is intended to provide adequate protection until a final ROD is signed. It complies with
Federal and state applicable or relevant and appropriate requirements for this limited-scope
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action, and is cost-effective. Although this "interim" action is not intended to address fully the
statutory mandate for permanence and treatment to the maximum extent practicable, this
"interim" action does utilize treatment and thus is in furtherance of that statutory mandate.
Because this action does not constitute the final remedy for the Site, the statutory preference for
remedies that employ treatment that reduces toxicity. mobility, or volume as a principle element.
although partially addressed in this remedy, will be addressed by the final response action.
Subsequent actions are planned to address fully the threats posed by conditions at this site.
Because this remedy will result in hazardous substances remaining on site above health-based
levels, a review will be conducted to ensure that the remedy continues to provide adequate
protection of human health and the environment within five years after commencement of the final
remedial action. Because this is an "interim" action ROD. review of this site and of this remedy
will be ongoing as EPA continues to develop final remedial alternatives for the Site.
Greer C. Tidwell Date
Regional Administrator
11
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Record fit'Derision
National Electric Coil Co . Sitt
Pauje 1 of 31
DECISION SUMMARY

1.0 SITE NAME, LOCATION, AND DESCRIPTION

1.1 Site Location

The National Electric Coil Co./Cooper Industries Superfund Site (NEC or Site), is located
on Old U.S. Route 119 adjacent o the Cumberland River in the town of Dayhoit.
Harlan County. Kentucky (Figure 1.1). The Site includes the 3.5 acre National Electric
Services manufacturing facility, which is currently operating, and also encompasses
the areal locations to which hazardous constituents might have migrated from the Site
(Figure 1.2).

1.2 Affected Population

The Dayhoit community is located downriver of the Site. Approximately 350 people live
in Dayhoit. Approximately 40 families reside at the Holiday Mobile Home Park within
close proximity to the Site.

1.3 Topography

The NEC site is located in the flood plain of the Cumberland River in Harlan County.
Kentucky. The Site is relatively flat except along the riverbank area, which slopes
steeply down to the Cumberland River. The topography of the area near the Site
consists of northeast-trending ridges of the Pine and Cumberland Mountain and the
bottomland associated with the Cumberland River and its tributaries.

1.4 Adjacent Land Uses

The facility property is bordered on the south by the Holiday Mobile Home Park, on the
north by the Kentucky Utility Company where a substation is located, on the east by
the Cumberland River, and on west by Old Highway 119. The property is fenced on all
sides.

1.5 Geology

Harlan County, Kentucky is located in the Cumberland Mountain section of the
Eastern Coalfields Region of Kentucky. The area near the Site is underlain by the
Pennsylvania-aged rocks in the Hance Formation of the Breathitt Group. The Site is in
the valley of the Cumberland River, and alluvial deposits up to 30 feet thick lie above
the bedrock. The upper bedrock unit in the area is the Cawood Sandstone Member of
the Hance Formation. This sandstone unit grades laterally into siltstone and thin-
bedded sandstone, and contains thin discontinuous coal seams. The base of the
Cawood Sandstone occurs at 100 to 130 feet below the ground surface, and is under-
lain by a portion of the Hance Coal Zone that consists of four seams interbedded with
sandstone, silty sandstone and shale. The principal coal seam is the Terry's Fork coal
bed that occurs at the base of the Hance coal zone.
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9/16/92
CKOUND MAIER
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SITE PLAN
NATIONAL ELECTRIC COIL CO. SUPERFUND SITE
SCALE IN FEET
40
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FILL COOPtR/NI/MW
DAIE: 9/16/92
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SOURE: U.SG.S. TOPOGRAPHIC QUADRANGLES, WALLINS CREEK (1974) AND HARLAN, KEMTUCKY (1978)
2000
4000
FIGURE 1-1
SITE LOCATION MAP
NATIONAL ELECTRIC COIL CO. SUPERFUND SITE
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Record of Decision
National Electric Coil Co.. Site
Page 4 of 31

The Site is located on the Cumberland Mountain overthrust block, south-southeast of
the Pine Mountain overthrust fault and north-northwest of the Cumberland Mountain
within an east-west trending synclinal trough. To the north, the bedrock dips three to
five degrees to the southeast. To the south, the bedrock dips one degree or less to the
north-northwest. There are northwest-southeast trending faults in the area that are
associated with the Pine Mountain Overthrust Fault.

A generalized stratigraphic column of the upper 400 feet encountered at the Site is
presented in Figure 1.3.

1.6 Hy drogeology

The Site is underlain by two significant water-bearing units. The uppermost, alluvial
deposits consisting of well to poorly sorted accumulations of sand. silt, and clay occur
at ground surface. The alluvial deposits are twenty-five to thirty feet thick in the
vicinity of the Site. They generally contain ground water under unconfined conditions.
at depths averaging twenty feet below existing land surface. Recharge occurs by
rainfall infiltration. Shallow ground-water flow is generally directed eastward towards
the Cumberland with respect to the facility.

The nlluvium is underlain at a depth of thirty feet by Pennsylvanian-age sedimentary
bed: _k. The consolidated units of interest include (in descending order):

• Cawood Sandstone - Sandstone grading laterally into siltstone and thin bedded
sandstone with isolated coal seams.

• Hance Formation - shale and siltstone underlain by coal seams interbedded
with sandstone and shale.

Ground water occurs under generally confined conditions within the bedrock's second-
ary fractures and faults. The unit is recharged from places where it crops out.
permitting rainfall infiltration from overlying hydrogeologic units in hydraulic connec-
tion. The bedrock unit's flow typically follows the river valley's axis to the southwest
with respect to the Site. The bedrock unit is repor ' to be a reliable source of water.
Study area bedrock wells range in depth from 58 to o39 feet below ground surface. The
potentiometric surface in the bedrock aquifer is about twenty-four feet below grade at
the Site. Because the alluvial water table is higher in elevation than the potentiometric
surface of the bedrock unit, recharge from the overlying unit into the bedrock is likely.

1.7 Surface Water

The Site is bounded on the east by the Cumberland River. The river flows from north
to south and serves as a discharge point for drainage leaving the Site. The Harlan
County Municipal water intake is located upstream of the Site at the Poor Fork Branch.

1.8 Natural Resources

Ground water in the bedrock aquifer is used for drinking water and industrial uses in
Harlan communities located in the Cumberland River valley downgradient of the Site.
Before discovery of the VOC ground-water contamination in February 1989 more than
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Record of Decision
National Electric G>il C<> . Sire
Page 8 of 31

140 wells in the Dayhoit area were utilized for domestic purposes.

Coal is mined extensively in the Harlan County area and this industry is the primary
employer for the county.

1.9 Climatology

Temperature in this area averages at 56T. Average annual rainfall is 50 inches, with
net precipitation at 16 inches. The prevailing winds are from the northeast.

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.1 Operational History

From 1951 to 1987 the National Electric Coil Co.. (NEC) operated under the ownership
of McGraw Edison Co. The business involved rewinding electric motors, manufacturing
coils, and rebuilding machinery used in the coal mining industry. Cooper Industries
purchased McGraw Edison in 1985 and continued operations until August 1987 when
the facility was sold to Treen Land Company.

Past practices at the facility involved the use of a trichloroethylene (TCE)-based solvent
to remove oil and tar from the used motors, capacitors, transformers, and other
equipment prior to their being rebuilt. Before servicing, the equipment was, reportedly.
lowered for cleaning into an approximately 1.000-gallon tank containing the TCE-based
solvent and located within a below-grade concrete pit. Periodically this tank was
drained for cleaning, and the contained liquid and waste matter was allowed to flow
overland and/or through a drainage pipe to the Cumberland River. PCB laden oil was
also allowed to drain from transformers arid other electrical equipment on site and/or
flow through the drainage piping that led to the river. Sludges from the solvent tank.
as well as debris (coal ash) containing high concentrations of heavy metals from a
furnace operated on site, were disposed of along the river. These disposal practices
continued until the mid-1980's and have resulted in ground-water contamination of the
local drinking water supply near the Site with the contaminant TCE and its degradation
by-products. Contamination of the Site's drainage channels, river embankment
property, and facility grounds also occurred.

Currently the Site is an active facility for rewinding and rebuilding electric motors and
hydraulic systems used for the mining of coal. Equipment brought to the facility for
refurbishment is now cleaned with a soap-based cleaner instead of the solvent based
degreaser used by the National Electric Coil Company. The manufacturing facility.
currently operating on the Site, employs less than 20 workers.

In February 1989. the Kentucky Department of Environmental Protection, Division of
Water, sampled the community well at the adjacent Holiday Mobile Home park as well
as other surrounding residential wells. Analyses of the approximately fifty (50) sample^
indicated the presence of VOCs, in twelve of the wells. Users of the contaminated well--
were provided with bottled water and water from temporary above ground storage tank--
in March 1989. prior to the installation of municipal water lines to the affected area>
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Record nt Derision
National Electric Coil Co.. Site
Page 9 of 31

Residential ground-water users in the areas either already contaminated or at risk of
future contamination were then connected to the Black Mountain Water District
municipal water system in August 1989. Funding for construction of a water line
extension was provided by Cooper Industries. There are reports that some residents do
not utilize the public water system. Reasons cited include both perceived poor water
quality and cost of services.

2.2 Enforcement Summary

In October 1990, EPA issued a Unilateral Administrative Order (Order) to Potentially
Responsible Parties (PRPs), McGraw-Edison Co./Cooper Industries. Inc.. Treen Land
Co.. and National Electric Service Co.. to conduct an early action removal of contami-
nated soils located on site. McGraw-Edison Co./Cooper Industries. Inc., undertook
the site Removal Action activities with the approval of current site property owner and
lessee. Treen Land Co., and lessor. National Electric Service Co. Approximately 5.100
tons of soil were excavated for off-site disposal during these Removal Action activities.
These contaminated areas were excavated for off-site disposal during the Removal
Actions conducted under EPA supervision from October 1990 through October 1991.
On March 19. 1992. EPA notified McGraw-Edison Co./Cooper Industries, Inc.. of the
Agency's determination that all activities outlined in the Order had been completed.

The site RI/FS and associated site studies will be conducted under the Administrative
Order by Consent that McGraw Edison/Cooper Industries, Inc., signed with the Agency
in May 1992. EPA will oversee all RI/FS and related site studies activities to be
performed by Cooper Industries to ensure compliance with all applicable laws and
regulations and to ensure that the work proceeds in a timely fashion.

The National Electric Coil Co./Cooper Industries Site was proposed for inclusion on the
National Priority List (NPL), as defined in Section 105 of CERCLA. as amended. 42
U.S.C. § 9605. on July 29. 1991. Finalization of this Site on the NPL has not occurred
at this time.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Proposed Plan for "interim" action at the National Electric Coil Co./Cooper Indus-
tries Site was presented at the public meeting held on July 28, 1992 at the Harlan
County Courthouse. This document was made available to the public in the informa-
tion repository maintained at the EPA Docket Room in Region IV, the Harlan County
Public Library, and at the Southeast County Community College Library. Notice of
availability of this document and notice of the public meeting was published in the
Harlan Daily Enterprise on July 15. 1992. The Public Comment Period was held from
July 15. 1992 through August 14. 1992.

At the public meeting, representatives from EPA answered questions regarding the
rationale for initiating site remediation as an "interim" action ROD prior to thorough
site characterization, by means of an RI/FS, and also on perceived site-related health
problems. A response to comments received during this period and to questions not
answered at the public meeting is included in the Responsiveness Summary, which is
part of this Record of Decision. This decision document presents the selected "interim
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Record of Decision
National Electric Coil Co.. Site
Page 10 of 31
remedial action for the Site, chosen in accordance with CERCLA. as amended by SARA
and. to the extent practicable, the National Contingency Plan (NCP). The decision for
this site is based on the administrative record.

At the completion of the RI/FS. EPA will develop another proposed plan which will
describe the final remedy and the process used to select that remedy. The proposed
plan will be mailed to interested parties and all persons who have requested to be
included on EPAs mailing list for the Site. EPA will conduct a 30-day public comment
period on the FS Report and the proposed plan to provide an opportunity for public
involvement in the final cleanup decision.

After the public comment period and the public meeting, EPA will again review and
consider all comments received from the community as part of the process of reaching
a final decision on the most appropriate remedial alternative, or combination of
alternatives, to address contamination found at the NEC site. EPA's final choice of a
remedy will be documented in a ROD. which will include the responsiveness summary.
4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The "interim" remedial action involves the use of a ground-water extraction well to
pump the VOC contaminated bedrock aquifer beneath the Site in order to restrict
further contaminant plume migration from the Site while bedrock aquifer characteriza-
tion is being conducted under a remedial investigation/feasibility study (RI/FS). The
bedrock aquifer addressed in this "interim" action is used as a drinking water source.
while the shallow aquifer beneath the Site is not and will be addressed in the final
remedy. This "interim" action does not constitute a final remedial action for this site.
Upon completion of the RI/FS, the ground-water treatment system embodied by this
"interim" remedial action may be incorporated into the Site remedy design specified in
the final action ROD. It is EPA's intent to install a comprehensive extraction well
system to address the site's ground-water contamination as part of a final action for
site clean-up once the RI/FS has been completed. An RI/FS typically takes from 18 to
24 months to complete. Once completed, the remedial design of this remedy will
commence in which engineering drawings and specifications will be developed. The
remedial design phase typically requires approximately 18 months.

Due to the length of time required to complete the RI/FS and post RI/FS activities. EPA
has elected to initiate groundwater cleanup activities at this time. This "interim"
remedial action will contain the volatile organic compound (VOC) contaminant ground-
water plume through pumping to reverse the hydraulic gradient of the plume migrating
from the Site. This "interim" remedial action will be monitored carefully to determine
the feasibility of achieving the goal of bedrock aquifer restoration by employing hydrau-
lic control methods on the contaminant plume.
-------
Record of Decision
National Electric G >il Ci >
F'a^e 1 1 of 31
5.0 SUMMARY OF SITE CHARACTERISTICS

5.1 Nature and Extent of Contamination Overview

A remedial investigation has not been conducted at the NEC site, so data collected
during previous site investigations serve as a basis for the Agency's current character-
ization of site media contamination. These previous investigations include numerous
Kentucky Natural Resources and Environmental Protection Cabinet (KNREPC). EPA.
and PRP on-site and off-site residential ground-water wells sampling events conducted
since February 1989. the site assessment conducted for purposes of NPL ranking, site
aquifer pump testing, and contaminated site soil Removal Action activities. These
investigations indicated the presence of hazardous substances handled and/or
disposed of at the Site as well as their degradation products in site soils and sediment
adjacent to the Site and the shallow overburden ground-water beneath the Site.
Extensive VOC contamination was detected in the deep bedrock aquifer ground water
onsite and downgradient of the Site.

Sampling of site environmental media indicated the presence of the following three
groups of hazardous substances CERCLA § 101: (1) volatile organic compounds
(VOCs), namely trichloroethene. cis-1.2-dichloroethene. vinyl chloride, benzene.
toluene, and ethylbenzene: (2) polychlorinated biphenyls (PCBs); and (3) metals.
namely, lead and chromium.

5.2 Deep (Bedrock) Aquifer

Bedrock aquifer ground water located beneath the Site and downgradient of the Site
flows through the upper unit of the Hance Formation. Production wells and residential
wells in the area are generally cased through the shallow coal seams and are construct-
ed (open borehole) in bedrock comprised of sandstone, then siltstone/shale, then
siltstone with increasing depth. Pump tests conducted on study wells constructed here
indicate that ground-water migration is fracture flow dominated and flows in a south-
westerly direction downgradient of the Site. Ground-water flow in the bedrock is not
influenced by the directional flow of the Cumberland.

The aquifer is contaminated with TCE and its degradation products, primarily cis-1.2-
DCE and vinyl chloride. These contaminants are dense nonaqueous phase liquids
(DNAPLs) and their fate and transport will be investigated more fully as part of the
RI/FS. Vinyl chloride has been detected as high as 350 ug/« and cis-l,2-DCE as high
as 905 ug/1 in off-site private wells. The Maximum Contaminant Levels (MCLs) for
these contaminants are 2 ug/f and 70 ug/f. respectively.

The VOC contaminant plume extends approximately one-half mile downgradient of the
site. This lateral plume delineation is based on analytical samples collected from
approximately 100 on-site and off-site private wells screened within the bedrock
aquifer. Table 5.1 provides a summary of ground-water data collected to date at the
site and in nearby areas. The depth of VOC contamination in the bedrock aquifer has
not yet been defined. The former Holiday Trailer Court community well, at 356 feet, is
the deepest contaminated offsite well from which ground-water samples have been
collected. This well, however, is only cased through the overburden and is construct rd
in 200 feet of open borehole. Therefore, the exact depth to which VOC contamination
-------
Table 5-1
Summary of Ground Water Sampling Remits
Marian County. Kentucky
Well
Number
KDEP
Well
Number
1 i NA
1A NA
4
5-0*
5-2'
5-10*
5-11'
6*
7«
9'
10
12-16'
12-17
13
NA
0
2
10
11
12
13
14
15
16
Owner
Apottolic Holiness Church
Apostolic Holiness Church
Apostolic Holiness Church
National Electric Service
National Electric Service
National Electric Service
National Electric Service
Holiday Trailer Court
W. E. McClelland
Retta M. Parks
Virginia S. Jones
KY Dept. of Highways (Eng.)
17 KYDept. of Highways (Maia)
18
15' 19
] 16
20
17' 49
19 50
20 100
21
51
27 NA
28 NA
31' • 52
Johnny E. Moore
Patsy Smith
Anna Maggard
Mike Turner
Russell Souleyret
Bruce Tarter
Guy L Saylor
Timothy Hawkins (James)
Matthew Hudson
James W. Brewer
Depth
(feet)
125
Sample
Date
05/90
125 05/90
30
126
125
270
120
356
195
210
175
180-210
180-210
U
91
90
200
U
150
60
60
U
05/90
04709/91
07/25/91
01/10/90
04709/91
07/25/91
03/02/89
04/09/91
07/25/91
03/06/89
03/06/89
04/06/89
09/89
04/09/91
07/25/91
02/13/89
02/28/89
02/28/89 •
02/28/89
03/03/89
03/10/89
04/06/89
02/28/89
03/03/89
04/06/89
09/20/89
03/02/89
03/04/89
03/02/89
03/04/89
07/21/89
09/20/89
03/02/89
09/21/89
03/02/89
03/02/89
03/10/89
06/07/89
09/20/89
03/07/89
03/10/89
03/07/89
03/10/89
09/20/89
03/06/89
06/07/89 •_,
06/07/89
09/29/89
03/06/89
03/02/89
09/21/89
03/10/89
03/10/89
100 03/06/89
32 53 Billy Smallwood ! 210 03/06/89
34 NA : Lucille Sargent
35 : 54 i David C Bailey
! 39" : NA : Joyce Turner
42 NA Harold Brown
44 : 308 Ray Jones
49" NA Donnie Morgan (Amy)
53 ! NA Elsie Sutton
54 NA I Glenn Howard
55 i NA Tony G. Tolliver
60 1 03/10/89
85 03/07/89
U
175
300
U
100
1 03/10/89
03/10/89
01/23/92
06/27/89
Concentration, ng/1 :
Vinyl
Chloride
ND
ND
ND
ND
ND
ND
ND
103
30.0
4.0
11.8
10.0
7.0
13.0
8.9
ND
ND
26.0
31.0
31.0
32.0
NA
13
59.0
298.0
NA
350.0
145.0
2.4
2.2
ND
ND
ND
ND
6.0
11.0
ND
ND
ND
ND
ND
20.0
20.0
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
03/10/89 1 ND
80 03/10/89 ND
U ! 03/10/89 ND
61" i 57 Juanita Dozier 220 ! 03/07/89 ND
cu-U-DCE
ND
ND
ND
ND
ND
340
3100
456
87.0
24.0
34.6
123.0
174.0
282.0
25.0
280.0
146
63.0
67.0
68.0
69.0
NA
ND
37.0
905.0
NA
1150
126.0
ND
ND
ND
ND
1.0
1.0
55.0
11.0
ND
ND
ND
ND
ND
29.0
27.0
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
TCE
ND
ND
ND
ND
ND
700
4800
264
1.0
ND
ND
16.0
ND
170
18.0
160
59.9
ND
ND
ND
ND
NA
ND
ND
ND
NA
107
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
Total [
VCXTs !
ND
ND !
ND i
5.2 i
5.66 1
1060 !
8350 1
877.7 i
118
38.7
51.6 i
149
182 ;
465
51.9
520.0 ':
211.86 !
99.0 !
98 i
110 j
111
NA !
134.3 j
96
1203 i
NA i
1611
271
2.4
2.2
ND
ND
1
1
62
11
ND
ND
ND i
ND
ND
49
47
ND
ND i
ND '
ND ;
ND i
ND i
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
NOTES
U Well depth unknown
NA Not analyzed for VOCs
• Wells to be sampled for VOCs and water level
" Wells to be monitored for water level only
-------
Table 5-1
Summary of Ground Water Sampling Remits
Well
Number
63"
71
KDEP
Well
Number
55 ^
56
76 ; NA
84*
85'
86
22
23
21
87 i 24
88*
90*
92'
32
34
33
93' 39
94 NA
95 42
97 40
Owner
Mattie L. Ball
Reed Howard
Oscar Shackelford
Richard Bracket! (Cecelia)
James Bradcett
Eli Cox
Ronnie Osborne
Don Cox
YoYo Market
Gary Parker
Paul Sutton
Helton
Barbara Jeffords
Cedric & Mary Sutton
98 41 Faye Scott
99 ( 1) 34 ! Lorene Simmons
101
102
43
45
116" 46
117 99
Hazel Tolliver (Floral
Teri Blanton
Jerry Nutter (Mary Ann)
Shamrock Fuel. Inc.
122" 1 44 Joel Howard . Sr.
125 29 Lawrence Hughetl
127 28 Robert Gosnell (Ernestine)
128 27 Abbey Cheek (Jeff Till)
129(2)' 27
130
30
131 26
133' 31
135'
137
138
140*
141
142
i 200
25
NA
38
37
35
NA
William D. Mansard
Nyai Bussell, Sr.
James Edward Cambrel
Pattie Hensley
J.C Maiden
Lu la Burke
Vacant House (Phylli Helton)
Carolyn West Fannon (Kenneth)
Joteph K. Tribble
JohnTribWe
1 : Audrey Stallard
I 201 2 PaulOsborne
203 4 i Loyall STP
204 5 : Emanuel Mason
206
207
7
8
i 208 9
Artesian Well
Joe Simpson
Levi Simpson
i 209 47 ! James Garland
Depth
(feet)
90
75
U
165
110
100
114

205
100
280
U
U
75
100
205
U
U
150
95
298
U
U
170
170
168
98
U
80
U
110
U
155
U
340
20
180-200
U
NA
U
270
65
210 48 'day Williams 145
Sample
Date
03/07/89
03/02/89
01/23/92
05/15/89
03/06/89
03/10/89
12/04/89
03/06/89
03/10/89
03/06/89
03/07/89
09/21/89
03/06/89
03/02/89
06/07/89
03/02/89
03/04/89
07/25/91
03/04789
03/06/89
09/20/89
03/06/89
09/21/89
03/08/89
03/06/89
03/08/89
03/04/89
03/07/89
03/04/89
03/02/89
03/10/89
03/04/89
03/07/89
03/02/89
03/06/89
06/07/89
03/06/89
06/07/89
03/07/89
06/07/89
09/20/89
03/06/89
06/07/89
03/06/89
06/07/89
09/20/89
06/07/89
09/21/89
03/04/89
03/04/89
03/04/89
05/07/89
09/21/89
07/27/89
08/06/89
03/06/89
03/06/89
03/06/89
03/02/89
03/08/89
03/10/89
03/02/89
03/07/89
03/04/89
03/04/89
Concentration, ng/1
Vinyl
Chloride
ND
ND
ND
ND
ND
ND
0.9
97.0
84.0
74.0
73.0
72.0
ND
ND
ND
59.0
57.0
63.9
52
6.0
3.0
ND
ND
ND
ND
ND
54.0
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
cu-U-DCE
ND
ND
ND
ND
ND
ND
2.0
98.0
81.0
131.0
133.0
72.0
ND
ND
ND
23.0
17.0
ND
ND
ND
ND
ND
ND
ND
ND
ND
18.0
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
TCE
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
Total
VOC-t
ND
ND
ND
ND
ND
ND
19
195
165
205 :
206
144 ;
ND
ND :
ND
82
74
63.9
•5.2 j
6.0 i
3 !
ND :
ND
ND
ND
ND
72
ND
3
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
NOTES
(1) Same as well 90
(2) Same as well 128
U Well depth unknown
NA Not analyzed for VOCs
• Wells to be sampled for VOCs and water level
•• Wells to be monitored for water level only
'Possible laboratory artifact
-------
Table 5-1
Summary of Ground Water Sampling Remits
Marian County, Kentucky
Well
Number
KDEP
Well
Number
211 i NA
212 58
213
NA
214 NA
Owner
Jack Ingle
Sid Helton TP
Marshall Jones
Helen Trail
215 i NA ; Terry's Creek Spring
216
217
NA
NA
218 NA
219
220
221
222
223
224
225
226
300
301"
302
303"
304"
305"
306"
307"
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Lucille Hibbard
Etta Bruce
Linda Hall
Emanuel Burkhart
Jackie Williams
Holiness Church
Robert Lee
Andrew Beckwell
Glenn Saylor
Eugene Young
Paul Haywood (Treemont SS)
Bill Bennett
E. W. Osborne
NA Bert Hensiey
NA i Irene Nalin
NA 1 Marilyn Griffey
NA
NA
Tim Creech
John L. Noe
NA Elden North
Depth
(feet)
u
u
u
41
U
420
80
Sample
Dmte
03/06/89
03/07/89
04/20/89
05/15/89
03/1 1/89
03/1 U89
05/3 1/89
07/17/89
05/3 1/89
378 07/21/89
U
U
U
U
380
300
305
120
265
440
100
07/26/89
07/26/89
10/28/89
03/06/89
03/10/89
05/31/89
03/11/89
03/10/89
01/23/92
01/22/92
01/23/92
365 01/22/92
U
200
200
160
01/22/92
01/22/92
01/22/92
01/22/92
Concentration, ng/1
Vinyl
Chloride
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
cii-14-DCE
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
TCE
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Total
VOC*t
ND
ND
ND
ND
ND
ND
ND
ND !
ND
ND i
ND !
ND !
ND
ND [
ND !
ND i
ND !
ND 1
ND 1
ND ! ND
ND
ND
ND
ND
ND
ND
ND i
ND !
ND |
ND i
ND i
ND i
NOTES
U Well depth unknown
NA Not applicable
" Wells to be monitored for water level only
-------
Record of Decision
National Electric CnilCn.. Site
15 of 31
extends in the fractured bedrock is not known. Figure 5.1 depicts the estimated extent of the
contamination plume identified in the RI. This "interim" action will initiate remediation of the
bedrock aquifer.

5.3 Overburden Soils

The Removal Action activities were conducted to delineate the areal extent of source
contaminated site soils in the overburden and to excavate these soils. Analytical
results of the samples collected in conjunction with the Removal Action and other site
assessment investigations showed site soils to be contaminated with VOCs. PCBs. and
metals. Contaminated soils and debris, totaling approximately 5.100 tons, were
excavated for off-site disposal from five principle areas: (1) the rear of the property
along the bank of the Cumberland River where fill material was located: (2) an outfall
area, also located along the river, at rear of the property where two drainage pipes
leading from the plant discharged: (3) an isolated area along the south fence line and
adjacent to the trailer park: (4) an isolated area where equipment and drums were
stored: and (5) the removal of two drainage lines leading from the plant. The action
levels that dictated removal were (1) 10 mg/kg PCBs: (2) 10 mg/kg total VOCs: (3) 5
mg/J TCLP lead: and 5 mg/« TCLP chromium, and (4) 100 mg/kg total lead and
chromium. The areas where soils were excavated are shown in Figure 5.2.

The overburden soils formation is approximately 30 feet in depth. Final characteriza-
tion of contamination in these alluvial soils will be completed during the Site RI/FS.

5.4 Shallow (Overburden) Aquifer

Samples collected on site from the overburden aquifer indicate that the shallow aquifer
is contaminated with metals and VOCs that are both TCE-related and gasoline degra-
dation compounds. No PCBs were detected. The maximum VOC concentrations of the
significant contaminants, cis-l,2-DCE, TCE. vinyl chloride, and benzene, were 3700
ug/<. 17.000 ug/{, 77 ug/{, and 19.000 ug/{. respectively. Lead and chromium
were detected at 127 ug/« and 594 ug/{. respectively.

Current characterization of this aquifer is based on the five wells installed in the
overburden aquifer during the preliminary site assessment activities on sites. Pump
tests performed on these wells indicate that this aquifer discharges into the Cumberl-
and River. Remediation of this aquifer will be addressed once the Site RI/FS has been
completed and a final remedy has been selected.

6.0 SUMMARY OF SITE RISKS

A formal baseline risk assessment has not yet been prepared for the NEC site, but will
be conducted during the RI/FS. The Agency's decision to initiate an "interim" remedial
action at this site is based on data collected during previous site investigations which
indicate that hazardous substance releases from this site are migrating through the
bedrock aquifer. The contaminants of concern have that been identified to date are
presented in Table 6.1. This "interim" remedial action will be conducted in order to
reduce VOC plume migration from the Site and. to the extent practicable, prevent
further ground-water quality degradation.
-------
"ILt COOPtR/RI/MWLC
DATE: 9/16/92
V NATIONAL
ELECTRIC
L
WILHOIT •
(DAYHCHT PO)
WILHOIT
(DAYHOIT PO)
HOLIDAY
MOBILE
HOME
PARK
STATE
HIGHWAY
GARAGE
LEGEND

WELL CLUSTER LOCATIONS FOR WELLS TO BE INSTALLED
DURING THE INTERIM ACTION (180') AND THE REMEDIAL
INVESTIGATIONS (300').
FIGURE 5-1
PROPOSED INTERIM ACTION
MONITORING WELL LOCATIONS
NATIONAL ELECTRIC COIL CO. SUPERFUND SITE
1600
-------
flLt COOt'LR/KMVACI/KACTARll
DA It; 9/16/92
OUTFAbL 001 AREA (OF)
D-5
CATCH
RJYEft&ANK FILL
EQUIPMENT
AND
DRUM STORAGE
| ARE A
(ED)
SOUTH FENCE LWE
AREA (FL)
SHADCD AREAS DENOTE
APPROXIMATE EXTENT Of EXCAVATIONS.
EXCAVATION WORK DURING 1990 AND 1991
FIGURE 5-2

REMOVAL ACTION SOIL EXCAVATION BOUNDARIES

NATIONAL ELECTRIC COIL CO. SUPERFUND SITE
-------
Record of Decision
National Electric Coil C< > .Sue
Page 18 of 31
Concentrations in off-site residential wells, completed in the bedrock aquifer, for vinyl
chloride have been observed as high as 350 ug/{ and for cis-1.2-DCE as high as 905
ug/f . The Maximum Concentration Limits (MCLs) for these contaminants in drinking
water are 2.0 pg/C and 70.0 ug/<>. respectively. Because the final site remediation
may not begin for another four years, the Agency has decided that containment of this
plume by pumping measures will reduce the spread the VOC plume through the
bedrock aquifer during this period. Thus, the establishment of new exposure pathways
to contaminated ground water at additional well points will be minimized, to the extent
practicable.

For an unspecified period of time prior to the discovery of ground-water contamination.
residents and workers in the Dayhoit area were exposed to VOC contaminated ground
water obtained from domestic and industrial wells completed within the bedrock
aquifer. Fifteen residential wells in the Dayhoit community, the Holiday Mobile Home
Park communal well and an on-site drinking water well for workers are known to have
been contaminated. Municipal water lines have been extended to residences beyond
the known affected areas.

Analytical results of the samples collected prior to the Removal Action site soil excava-
tions and in conjunction with other site assessment investigations showed site soils to
be contaminated with VOCs. PCBs, and metals and that ground-water samples
collected both on and off site contained VOC concentrations above health based levels.
Table 6.1 displays a listing of the contaminants of concern and are grouped by media.

Removal of these contaminated source soils located on the Cumberland River bank and
waste areas has reduced site risks to humans by eliminating exposure routes by which
direct dermal contact with and ingestion of these contaminants might occur and
removed potential sources of continuing ground-water contamination. During the
Removal Action contaminated soils and debris, totaling 5,100 tons, were excavated for
off-site disposal.

Data that is to be collected during the RI and data already collected in previous
investigations under EPA supervision will be evaluated in order to assess the current
and future risks posed by the Site. This data will be compiled for evaluation in the
baseline risk assessment.
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Record <>t Decision
National Electric Cntl C<> , Sire
Paue 19 of 31
TABLE 6.1: ORGANIC CONTAMINANTS OF CONCERN BY ENVIRONMENTAL MEDIA
CONSTITUENT
Arodor 1260. 1242. 1248. 1254
Benzene
Bromodichloromethane
Bromomethane
Chlorobenzene
Chlorome thane
Dibromochloromethane
1 .3-Dichlorobenzene
1.2-Dichlnroethane
1 ,2-cis-Dichlornethene
1 .2-Dichloropropane
Ethylbenzene
Merhvlene Chloride
1 . 1.2.2-Tetrachloroethane
Tctrachloroethene
Toluene
1.1.1 -Trichloroethane
1 . 1 .2 -Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes (Total)
SOIL
o
o
o
o
o
o
0
o
0
0
0
o
o
o
o
0
o
0
0
o
o
SEDIMENT

o
o

GROUND WATER

o
o

o •

o
o
o
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Record of Decision
National Electric C< >il Co .Site
Piuje 20 of 31
TABLE 6.1: ORGANIC CONTAMINANTS OF CONCERN BY ENVIRONMENTAL MEDIA
CONSTITUENT
Antimony
Barium lionicl
Beryllium
Cadmium
Chromium (VI)
Copper
Lead
Mercury
Nickel
Silver
Zinc
SOIL
o
0
o
o
o
o
0
0
o
o
0
SEDIMENT

GROUND WATER

7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES

The following alternatives were evaluated by EPA using the nine evaluation criteria.

1. No Action;

2. Contaminated Ground-Water Extraction Using On-site Well: Air Stripping of
Contaminated Water; Discharge of Remediated Ground-water: and Emission
Control of the Resulting Air And VOC Vapor Stream
7.1 Alternative 1: No Action

The Agency requires that this alternative be evaluated at every site to serve as a
baseline for comparison for all other alternatives considered. Under this alternative.
EPA would take no action at the Site at this time to minimize further migration of
contaminated ground water from the Site while the RI/FS is being conducted.
This alternative would not require any expenditures, and no time for implementation.
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Record of Decision
National Electric: Coil CM.. Site
21 .it' 31
7.2 Alternative 2: On-site Well Contaminated Ground-Water Containment/Extraction;
Air Stripping of Contaminated Water; Discharge of Remediated Ground Water to
Cumberland River; and Emission Controls on the Resulting Air/VOC Vapor Stream

This alternative will ensure that active treatment and containment of the contaminated
ground-water plume, migrating from the Site, will begin during the conduct of the
RI/FS. Ground water containing VOCs will be extracted at a rate of approximately 100
gallons per minute and will be pumped from an on-site 120-foot well completed in the
bedrock aquifer for treatment in an air stripper tower. A supplemental on-site extrac-
tion well may be utilized to allow flexibility in the ground-water treatment system. The
area of attainment extends downgradient from the Site, in a southwesterly direction, for
approximately 3300 feet.

Air stripping will remove approximately 99 percent of the VOCs contained in the
extracted ground water. The resulting vapors, stripped from the ground water, will be
captured in ah adjoined emissions control unit. Treated ground water exiting the air
stripper tower will be released to the Cumberland River in compliance with State of
Kentucky Pollutant Discharge Elimination System (KPDES) requirements before
discharge to the Cumberland River. State requirements for ground-water discharge.
ground-water withdrawal, and applicable State air emission regulations will be ob-
served as ARARs at this site.

In order to assess the performance of the ground-water extraction system an extensive
monitoring and sampling program will be initiated prior to the start up of the system
and during its operational period. Approximately thirty-three ground-water wells
located in the assumed path of the VOC plume in the Dayhoit. Fresh Meadows. Wallins
Creek, and Tremont communities will be utilized in this program. Selected ground-
water wells located in the hydraulically upgradient community of Keith will also be
monitored. Samples will be collected from approximately twenty-four of these wells for
chemical analysis prior to the start-up of the system and at established intervals
thereafter.

The extraction well and air stripper tower are already in place on site, so no capital
expenditure will be required for construction. The cost of this system was approxi-
mately $106,000. Annual operating costs for the system have been estimated to be
$150,000 per year. Implementation of this alternative will be initiated once the
baseline monitoring sampling event has been completed.

Residuals

Contaminated wastes generated from "interim" remedial action activities involving
treatment of TCE would be handled as a listed F001 coded solid waste and in compli-
ance with all applicable Land Disposal Restrictions (LDRs).
8.0 SUMMARY OF COMPARATIVE ANALYSIS ALTERNATIVES

This section profiles the Preferred Alternative against the nine criteria, noting how u
compares to the "No Action" alternative for the relevant evaluation criteria. The nine-
criteria are categorized into three groups: threshold criteria, primary balancing criien.i
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Record ol Decision
National Electric Coil Co.. Site
Page 22 of 31
and modifying criteria. The threshold criteria must be satisfied in order for an alterna-
tive to be eligible for selection. The primary balancing criteria are used to weigh major
tradeoffs among alternatives. Generally, the modifying criteria are taken into account
after public comment is received on the Proposed Plan. The evaluation follows.

THRESHOLD CRITERIA

Overall Protection addresses whether or not a remedy provides adequate protection
and describes how risks are eliminated, reduced, or controlled through treatment.
engineering controls, or institutional controls.

The ground-water extraction well/air stripper system, presented as Alternative 2.
provides protection of human health and the environment because it will initiate a
reduction in risks from future exposure to contaminants in ground water. The ground-
water containment aspect of this alternative provides environmental protection by
mitigating, to the extent practicable, the spread of the ground-water plume through the
bedrock aquifer, thus, reducing the volume of contaminated ground water that will
require restoration. Containment of the plume will reduce the chances that new
exposure pathways to the bedrock aquifer will be established at more well points.

The "No-Action" alternative provides protection to neither human health nor the
environment because it does not address the continued migration of VOC contaminants
from the Site. Thus the "No-Action" alternative would neither arrest the continued
ground-water plume migration nor initiate the reduction of site contaminants and the
potential risk these contaminants pose to human health and the environment via
continued ground-water degradation.

Compliance with ARARs addresses whether or not a remedy will meet all of the
applicable or relevant and appropriate requirements of other environmental statutes
and/or provide grounds for invoking a waiver. The ARARs identified for this "interim"
action are listed in section 10.2.

The air stripper tower will treat site ground water from the bedrock aquifer to meet all
Federal and State of Kentucky water quality standards for discharge to the Cumberland
River. Treated water will be released to the Cumberland River, only, in compliance with
KPDES. Additionally, air emissions leaving the air stripper system will meet the
Federal and State of Kentucky air emissions standards. Ground-water withdrawal
rates will not exceed those set by State regulations.

LDRs are applicable because treatment residuals resulting from the remediation of
ground water containing the F001 listed waste, TCE, is considered a listed RCRA solid
waste. All manifesting and generator requirements cited in CFR 262 and 268 will be
met during this CERCLA response action.

The final cleanup levels for the ground water are not addressed in this "interim" remedy
because such goals are beyond the limited scope of this action. The final cleanup
levels will be addressed by the final remedial action ROD for the Site.
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Record of Decision
NationalElectncC.nlCM.. Site
Pajje 23 of 3 1
PRIMARY BALANCING CRITERIA

Long-Term Effectiveness and Permanence refers to the ability to maintain reliable
protection of human health and the environment over time once cleanup goals have
been met.

The goal of this "interim" remedial action is short term in scope in that its purpose is to
prevent the spread of contaminants in the underlying bedrock aquifer while the RI/FS
and post-RI/FS activities are being completed. Still, Alternative 2 is consistent with the
Agency's long term goal of returning ground water to its beneficial uses because
contaminants are permanently removed as the bedrock aquifer is pumped in attempt to
hydraulically control ground-water plume's migration from the Site.

Data will be collected during this "interim" remedial action to evaluate the bedrock
aquifer's response to pumping in terms of hydraulic control and contaminant concen-
tration reduction. This information will be utilized in conjunction with that collected
during the RJ to develop alternatives for a final remedy selection. Long-term effective-
ness and permanence will be more thoroughly evaluated at that time.

Reduction of Toxicity, Mobility, or Volume of the Contaminants Through Treat-
ment is the anticipated performance of the treatment technologies a remedy may
employ.

The ground-water extraction well/air stripper system will reduce the toxicity. mobility.
and volume of VOC contaminants extracted from the bedrock aquifer by air stripping or
dispersing VOCs dissolved in ground water and by capturing the resulting vapors
through emission controls. The air stripper tower will effectively remove more than
99% of the VOCs contained in the ground water. Air containing vapors 'stripped' from
contaminated water will be blown through to a subsequent emission control unit prior
to being released to the atmosphere.

Short-Term Effectiveness addresses the period of time needed to achieve protection
from any adverse impacts on human health and the environment that may be posed
during the construction and implementation period until cleanup goals are achieved.

Projected emissions from VOCs stripped from contaminated ground water are below
those levels that will cause any adverse health effects. The Agency has developed
health based VOC emission limits for which the system will be monitored in the event
that ground-water contaminant concentrations increase significantly once "interim"
action ground-water pumping activities are underway. Currently, the air stripper tower
has been fitted with a granulated activated carbon (GAC) unit to control VOC vapors.
Additional GAC units or other emission controls will be added as necessary to meet thr
Agency's health based emission levels.

No adverse health impacts on human health and the environment are anticipated as
the result of construction activities because the extraction well/air stripper system is
already in place on site.

It is anticipated that the duration of the "interim" remedial action activities should n<>i
exceed four years. At the conclusion of the RI/FS the Agency will propose the final
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Record of Decision
National Electric Coil Co.. Site
Page 24 of 3 1

remedial actions under which the remaining site contamination will be fully addressed.

Implementability is the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement the chosen solution.

The ground-water extraction/air stripper system has already been constructed on site.
Ground-water wells comprising the monitoring well system, which will be monitored
during the system's operational period, have already been mutually identified by EPA.
the State, and Cooper Industries.
Cost

The estimated operational cost for the ground-water extraction/air stripper system is
estimated to be $150.000 per year. The initial cost for design and construction of the
system was $105,500.

MODIFYING CRITERIA

State Acceptance

The Commonwealth of Kentucky granted its concurrence with this "interim" remedial
action in a letter dated September 18. 1992. The terms of this concurrence were as
follows: (1) continuous monitoring of effluent vapors during the initial phase of the
extraction well/air stripper system operation; (2) assurance that quantitation limits for
do not exceed the corresponding maximum contaminant level for ground water
contaminants of concern: (3) request that additional wells in the Wallins Creek area be
analyzed for site contaminants of concern: and (4) compliance with Kentucky Pollutant
Discharge Elimination System requirements developed for this "interim" remedial
action.
Community Acceptance

The Agency received ninety-eight comments and/or letters during the Comment Period.
Also a petition, containing 141 signatures, was submitted by the Concerned Citizens
Against Toxic Waste in opposition to the tenets of this ROD. The Public Comment
Period was held from July 15, 1992 through August 14, 1992. No extension to the
comment period was requested.

Written comments to EPA in response to the Proposed Plan by community residents
and those read into the record at the Public meeting, held on July 17, 1992. expressed
the public's strong opposition to EPA's plan to initiate "interim" remedial actions at the
Site.

In general, three issues were presented by the community: (1) The "interim" remedial
action will begin before the Site has been characterized: (2) heavy metals and other site
contaminants would be released to the Cumberland River; and (3) air toxics will be
released from the air stripper tower.
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Record of Decision
National Electric Coil Cu.. Site
Paj?e 25 of 31
9.0 THE SELECTED REMEDY

Based upon consideration of the requirements of CERCLA. the National Contingency
Plan, the detailed analysis of alternatives and public and state comment, EPA has
selected a ground-water remedy for this site. The Selected Remedy, Alternative 2.
involves the use of a ground-water extraction system consisting of an extraction well
and a countercurrent air/water air stripper tower to hydraulically reduce, to the extent
practicable, the migration of the ground-water plume that extends approximately one-
half mile from the Site within the bedrock aquifer located in the Site's subsurface.
Alternative 2 calls for the implementation of an "interim" remedial action to protect
human health and the environment.

As stated the goal of this "interim" remedial action is to halt the spread of the bedrock
contaminant plume and to collect data on aquifer and contaminant response to
remedial measures. The ultimate goal of remediation, to be determined in a final
remedial action for this site, is to return the ground water to its beneficial uses, in this
case, for drinking water purposes. This remedial action will be monitored carefully to
determine the feasibility of achieving this goal with this method and to ensure that
hydraulic control of the VOC contaminant plume is maintained. After completion of the
RI/FS in accordance with the NCP, EPA will arrive at a final remedial decision for the
Site, and will issue a final ROD for ground water, which will specify the ultimate goal.
remedy, and anticipated remediation timeframe. Upon completion of the RI/FS. this
"interim" system may be incorporated into the design of the Site remedy specified in the
final action ROD.

9.1 Major Components of the "Interim" Remedial Action

Ground-water remediation will address the contaminated ground water at the Site.
Contaminated ground-water will be extracted from an approximately 120 foot well
completed in the bedrock aquifer. Recovered ground water shall be treated in an on-
site treatment system. Ground water will be pumped to the top of the packed air
stripper tower where it will flow downward. Air is simultaneously blown from the
bottom of the tower, countercurrently and upwardly through packing material. The
agitation created by air, water, and tower packing material contact causes volatilization
(stripping) of VOCs dissolved in the ground water. These contaminants have high
vapor pressures and they partition preferentially from the aqueous phase to a gaseous
one. Volatilized vapors are carried away in the air stream. The air stream, containing
VOC vapors, exits the tower and passes through the attached carbon bed unit. As the
air stream passes through the unit, VOC vapors are adsorbed in the emission control
unit. The remediated ground water will be discharged to the Cumberland River.

The effectiveness of the extraction well in reducing VOC concentrations in the bedrock
aquifer and its ability to arrest the migration of the plume will be evaluated through an
extensive monitoring program. The proposed monitoring program is comprised of
thirty-three residential, production, and monitoring wells that will be sampled during
the RI. Potentiometric changes and changes in plume contaminant levels will be
observed throughout the extraction well's operational period. Analytical samples will hr
collected from approximately twenty-four wells. A baseline sampling event to record
ground-water quality and level at each of the wells will be conducted before start-up oi
the extraction well system.
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Record of Decision
National Electric Cuil Cn.. Site
Page 26 of 3 1

The Selected Remedy enables EPA to initiate cleanup of the VOC contaminated
ground-water aquifer, while the RI/FS and related activities are being completed.
Further ground-water degradation as the result of contaminant migration will be
reduced. Further, the Selected Remedy will be used to monitor the hydrologic regime
at the Site and effectively evaluate operation and impact of the on-site ground-water
extraction well.

9.2 Performance Standards

Air Emissions and Ground Level Concentration Standards

Projected VOC emissions stripped from contaminated ground water are below those
levels that will cause any adverse health effects. The Agency has developed health-
based vinyl chloride, TCE, and cis-1.2-DCE emission limits for which the system will be
monitored in the event that ground-water contaminant concentrations increase
significantly once "interim" action ground-water pumping activities are underway.
These emission limits shall serve as performance standards for this ROD and are
presented in Table 9.1. The point of compliance for these emission levels shall be the
stack pipe exit point from which emissions are released to the air. Currently, the air
stripper tower has been fitted with a granulated activated carbon (GAC) unit to control
VOC vapors. Additional GAC units or other emission controls, such as a thermal
destruction unit, will be added as necessary to meet the Agency's health based
emission levels. Air emissions from the stripper will be monitored on a regular
schedule by EPA to ensure that any emissions exceeding the prescribed levels will be
detected.

Ambient air monitoring shall also be performed on the Holiday Trailer Park located next
to the site facilty. The fenceline separating the Site from the Holiday Trailer Park
property shall serve as the point of compliance. Ground level concentrations that shall
serve as performance standards are presented in Table 9.1.
TABLE 9.1 EMISSION RATE AND AMBIENT AIR PERFORMANCE STANDARDS

cis- 1 .2-Dlchloroethene
Trichloroethene
Vinyl Chloride
Action Level*
Emission Rate
(Ib/hr) / (g/sec) / (ppb)
41.0/5.1 / 4.72e06'
3.1 / 4.0e-01 / 2.2e05b
6.4e-02 / 8. le-03 / 1.2e04b
Ambient Air
5C
5d
5'
Emission rate based on 401 KAR 63:022. An inhalation unit risk factor has not been derived tor CLS- 1.2
DCE. therefore a health based emission rate could not be derived.
Emission rate derived from 10"6 risk level. 70-year inhalation unit risk
The cis-1.2-DCE practical quantitatlon limit (F'QLl: this level equals 0.6% of the allowable ambient air
level, based the occupational permissible exposure limit IPEL1 divided by 1000
The TCE PQL: equals a risk level of 8.5e-06. based on EPA's unit risk of 1.7e-06 ug/mj
The vinyl chloride PQL: equals a risk level of 4.2e-04. based on EPA's unit risk of 8.4e-05 pM/rn3
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National Electric Cud Ci i.. Site
Page 27 of 31
Treated Ground Water Discharge Standards

Treated ground water, exiting the tower, will be discharged to the Cumberland River in
compliance with the applicable KPDES requirements. KPDES discharge limits will
serve as performance standards for this ROD. They are presented in Table 2.
TABLE 9.2: SUMMARY OF KPDES EFFLUENT LIMITATIONS3
EFFLUENT PARAMETER
Flow (MGD)
Trlchloroethylene
1 . 1-Dichloroethylene
Vinyl Chloride
PCBs1
cis- 1 .2-Dichloroethylene
Benzene
Lead (T.R.)
Zinc (T.R.)
Chromium (Hexavalent)
Copper (T.R.)
Methylene Chloride
Tetrachloroethylene
DISCHARGE LIMITATIONS
kg/day (Ib»/day) Other Units (Specify)
Monthly
Average
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Daily
l^ayfipifTfi
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Monthly
Average
0. 18 MGD
0. 172 mg/l
0.0021 mg/l
0. 128mg/l
0.0043 ug/l
0.07 mg/l
0.833 mg/l
0.072 mg/l
0.117 mg/l
0.016 mg/l
0.018 mg/l
0.011 mg/l
0.555 mg/l
Daily
MiiTlniaat"
0.18 MGD
Report
Report
Report
Report
Report
Report
0.082 mg/l
0. 117me/l
0.016 mij/l
0.018 mg/l
Report
Report
The discharge limits contained in this table are those currently proposed by the Commonwealth of Kentucky
Division of Water. The permit with which these discharge limits shall comply is currently subject to pubiu-
comment, so these discharge limits may be amended. If the final KPDES requirements vary from those listtd
in this table, the final discharge limits are hereby incorporated by reference and will replace those listed
above.-
System Design Standards

The operating parameters under which the ground-water extraction/air stripper system
shall operate are contained in Table 9.3.
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National Electric Coil Co.. Site
Page 28 of 31
TABLE 9.3: DESIGN PARAMETERS
PARAMETER
Water Flow Rate
Column Height"
Column Diameter
Air Flow Rate

Stack Height
Stack Diameter
Exit Air Velocity
Exit Air Temperature
Air/Water Ratio
Stripping Efficiency
UNITS
L/min / gpm
m
m
mVmin
cfm
m
m
m/sec
=C
cmrcfm
%
VALUE
380 / 100
15.3
0.9
15.1
534.0
8.7
0.4
3.5
25
40:1
99.00
ARAR Requirements

The following major ARARs shall be met for the ground-water contaminants of concern
for this "interim" action.

Treated ground water discharged to the Cumberland River shall comply with applicable
KPDES limits. State ground-water withdrawal requirements shall be observed.

Certain RCRA regulations are applicable, specifically, LDRs. Solid wastes resulting from
the treatment of F001 ground v. er will be generated (i.e. spent GAC from air pollution
controls) and shall be handled as F001 listed RCRA solid waste until decontaminated.
Applicable manifest and generator requirements as cited in CFR § 262 and § 268 shall
be met during this CERCLA response action.
Compliance Monitoring

Air emissions and ground water exiting the air stripper tower and ground level ambiem
concentrations shall be monitored at this site in order to demonstrate compliance with
Performance Standards. If monitoring indicates an exceedence of the Performance
Standards set forth in Table 9.1 and Table 9.2. pumping shall cease.

Should pumping activities cease as a result of an exceedence of Performance Standard--
EPA shall determine what additional control measures are needed in order to achieve
these Performance Standards. Pumping activities shall resume upon implementation < °i
this determination.
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Record nt'Decision
National Electric Coil C'i . Site
Page 29 of 31
10.0 STATUTORY DETERMINATION

10.1 Protection of Human Health and the Environment

This "interim" remedial action protects human health and the environment from
exposure to bedrock aquifer contaminants. The ground-water extraction well/air
stripper system, presented as Alternative 2. provides protection of human health and the
environment because it will initiate a reduction in risks from future exposure to contami-
nants in ground water. The ground-water containment aspect of this alternative
provides environmental protection by mitigating to the extent practicable further spread
of the ground-water plume, thus, reducing the volume of contaminated ground water
that will require restoration. Containment of the plume will reduce the chances that new
exposure pathways to the bedrock aquifer will be established at more well points.

1O.2 Compliance with ARARs

Alternative 2 attains all of the requirements that have been identified as applicable or
relevant and appropriate to actions that will occur as the result of implementation of the
selected remedial action. The following are major applicable or relevant and appropriate
requirements (ARARs), risk-based levels and other "to be considereds" (TBCs) being
met/utilized for the specific components of the remedial action.

Chemical-Specific ARARs are health or risk-based concentration limits or ranges in
various environmental media for specific hazardous substances, pollutants, or contami-
nants. These ARARs set protective cleanup levels for the contaminants of concern in the
designated media or indicate an acceptable level of discharge into a particular medium
during a remedial activity.

401 KAR 63:022 is applicable to this response action because it regulates facilities which
emit the toxic air pollutants, specifically cis-1.2-Dichloroethene.

Location Specific ARARs are restrictions placed on the concentration of hazardous
substances or the conduct of activities solely because they are in specific locations.

40 CFR §264.18(b). Floodplain Management, mandates that hazardous waste treatment.
storage or disposal facilities located within a 100-year floodplain must be designed.
constructed, operated and maintained to avoid washout. This regulation is applicable
because the Site is located within the 100-year floodplain of the Cumberland River.

40 CFR 6.302. Fish & Wildlife Coordination Act, requires adequate protection of fish and
wildlife if any stream or other body of water is modified. Additionally, actions in
floodplains are required to avoid adverse effects, minimize potential harm, and restore
and preserve natural and beneficial values.

Action Specific ARARs are performance, design, or other similar action-specific
requirements that impacts particular remedial activities. These requirements are
triggered by the particular remedial activities that are selected to accomplish a remedy.
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National Electric Coil Co.. Site
Page 30 of 3 1

These requirements do not determine the remedial alternative, but, they do indicate how
a selected alternative must be achieved.

Resource Conservation Recovery Act (RCRA) (42 U.S.C. §§6921-39 (§§ 3001-19): 40 CFR
Parts 260-270) regulates the treatment, storage, and disposal of hazardous waste from
generation through ultimate disposal. RCRA applicable requirements may include LDR
and waste generator requirements set forth at 40 CFR Part 268.7 and Part 262. Any
offsite facility receiving the hazardous waste for disposal will meet the requirements set
forth in 268.41.

Because the Commonwealth of Kentucky may be authorized for some or all of the RCRA
provisions, the applicable regulations are hereby incorporated by reference.

Kentucky Pollutant Discharge Elimination System (401 KAR 5. specifically Parts 031.
065. and 075). Kentucky Water Quality Regulations is applicable to this response action
because it regulates the point-source discharge of treated ground water to the Cumberl-
and River by setting discharge limitations and monitoring requirements. This response
action shall abide by the substantative requirements these regulations set by the
Commonwealth of Kentucky, which has been authorized to implement the National
Pollutant Discharge Elimination System program under authority of the Clean Water Act
(CWA) § 402. Section 402 of the CWA incorporates sections 301, 302, 306. and 307.

KRS 151.140 is applicable to this response action because it regulates the withdrawal of
water from public waters within the Commonwealth of Kentucky. This response action
will comply with all substantative requiremnts of this regulation.

To Be Considereds (TBCs) are non-promulgated advisories or guidance issued by
Federal or State government that are not legally binding and do not have the status of
potential ARARs. However, as described below, in many circumstances TBCs will be
considered along with ARARs as part of the site risk assessment an may be used in
determining the necessary level of cleanup for protection of health or the environment.

Estimation of Air Impacts for Air Stripping of Contaminated Water (EPA-450/1-91-002)
Air/Superfund National Technical Guidance Series May 1991. This guidance outlines
the procedure under which air emission limits for this response action were derived.

10.3 Cost-Effectiveness

Alternative 2 utilizes an extraction well/air stripper system already in place on site. The
extraction well used in this system is a former production well. The cost of the air-
stripper tower was approximately $106.000. Yearly operational costs for this system are
estimated at $150,000 per annum.

1O.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Marifnnm Extent Practicable

This "interim" remedial action does not constitute a final action for remediation of the
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National Electric Cml Co.. Site
Page 31 of 31

shallow and bedrock aquifer ground water. It will, however, be effective in reducing the
toxicity. mobility, and volume of VOC contaminants extracted from the bedrock aquifer
by air stripping VOCs dissolved in ground water and by capturing the resulting vapors
through emission control. Selection of this remedy represents the best balance of
tradeoffs with respect to pertinent criteria, given the limited scope of the action.

1O.5 Preference for Treatment as a Principal Element

The Selected Remedy utilizes air-stripping as a means of treatment of the VOC contami-
nated bedrock ground water found at the Site. The statutory preference for treatment
will also be applied to the contaminated site media not addressed in this "interim"
remedial action as part of final response action.
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